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NatWest Group plc
2021 Annual Report
and Accounts
Thrive
T
ogether
Approval of Strategic report
The Strategic report for the year
ended 31 December 2021 set out
on pages 1 to 81 was approved
by the Board of directors on
17 February 2022.
By order of the Board
Jan Cargill
Chief Governance Officer
and Company Secretary
17 February 2022
Chairman:
Howard Davies
Executive directors:
Alison Rose (Group CEO)
Katie Murray (Group CFO)
Non-executive directors:
Frank Dangeard
Patrick Flynn
Morten Friis
Robert Gillespie
Yasmin Jetha
Mike Rogers
Mark Seligman
Lena Wilson
Contents
Our 2021 reporting suite brings together NatWest Group’s
financial, non-financial and risk performance for the year. The
reports are designed primarily to meet the expectations of our
investors (including holders of bonds issued under our green,
social and sustainability framework), as well as regulators, and
our wider stakeholders, including customers, colleagues and
society more broadly. The main reports within this suite and
their focus are detailed below:
Available within this report:
Strategic report: an overview of our business, our 2021
financial and non-financial performance and progress against
our purpose-led strategy to champion potential, helping people,
families and businesses to thrive.
Governance and remuneration report: a review of our
corporate governance and remuneration, including the
Report of the directors and Annual report on remuneration.
Risk and capital management report: an overview of the
management of key risks relating to our business operations
and disclosures on our capital, liquidity and funding position.
Financial statements: our financial statements and related
notes, including the independent auditor’s report.
Strategic report
2
Financial performance
3
Operational highlights
4
Chairman’s statement
6
Group Chief Executive’s review
12
Our purpose framework
14
Our stakeholders
18
Our strategy
20
Our strategy in action
28
Key performance indicators
30
Our purpose-led areas of focus
32
Market environment
34
How we create value
38
Business performance
40
Retail Banking
42
Private Banking
44
Commercial Banking
46
RBS International
48
NatWest Markets
50
Ulster Bank RoI
51
Outlook
52
Section 172(1) statement
54
Stakeholder focus areas
54
Customers
57
Investors
58
Colleagues
62
Communities
63
Regulators
63
Suppliers
64
Climate-related disclosures
72
Risk overview
74
Top and emerging risks
76
Viability statement
78
Non-financial information statement
80
Governance at a glance
82
Financial review
96
Governance
188
Risk and capital management
286
Financial statements
429
Additional information
Company announcement and
Financial supplement
Our latest company information including our
financial performance for the year with a focus
on key metrics and measurement.
Climate-related Disclosures Report
Details our progress in 2021 on our climate ambitions
including an overview of our approach to climate
related governance, strategy (including scenario
analysis), risk management, metrics and targets.
ESG Supplement
Provides an overview of our purpose in action and
key environmental, social and governance matters
including progress in 2021.
Pillar 3 Report
Focuses on our regulatory reporting requirements
and provides an explanation of our risk profile,
including our capital adequacy, risk appetite
and risk management.
Mica Johnson,
Owner, Floral Glory
Thrive
T
ogether
NatWest Group champions potential,
helping people, families and businesses
to thrive.
We are the UK’s leading business bank,
and we serve 19 million customers
across every region of the UK.
As a relationship bank for a digital world,
we are helping to break down barriers
that hold back our customers and we are
helping to build their financial confidence.
Because when people, families and
businesses thrive, we all…
1
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
2021
(9,280)
(7,858)
(7,758)
2020
2019
2021
2.7
0.4
3.8
2020
2019
2021
3,983
(481)
4,032
2020
2019
2021
3,136
(753)
2,950
2020
2019
2021
4,707
2,650
2,754
2020
2019
Financial performance
Financial strength
enables our purpose
Operating
profit/(loss)
before tax £m
Operating
expenses £m
Profit/(loss)
attributable
to ordinary
shareholders £m
Total capital
return to
shareholders
(paid and
proposed) £bn
2021
1 Jan
2022
16.2
18.5
18.2
15.9
2020
2019
CET1
ratio %
We have delivered a strong operating performance in 2021. Group
RoTE was 9.4%, benefiting from a £1.3 billion net impairment release.
We achieved our Group cost reduction target of 4.0% and lending
growth across our UK and RBSI retail and commercial businesses
was 2.6%, excluding UK Government financial support schemes. Our
capital and liquidity position remains strong after returning £3.8 billion
to shareholders, and default levels have remained low across all our
portfolios. The CET1 ratio was 18.2%, reducing to 15.9% on 1 January
2022 following regulatory RWA and capital changes. We have made
good progress on our phased withdrawal from the Republic of Ireland
and will focus the financial commentary below on the Group excluding
Ulster Bank RoI (Go-forward group).
Total income, excluding notable items, in the Go-forward group
was 5.6% lower than prior year. Across the UK and RBSI retail
and commercial businesses income increased by 1.4% reflecting
strong balance sheet growth, principally in our mortgage book. NWM
income was below expectations, down by 61.5%, compared with 2020,
reflecting continued weakness in Fixed Income, impacted by subdued
levels of customer activity and ongoing reshaping of the business, and
exceptional levels of market activity in the prior year.
We delivered a cost reduction of £256 million, or 4.0%, in 2021, in line
with our target for the year
(1)
. This has been achieved by transformation
across our customer journeys and NWM business, in line with the
strategic announcement made in February 2020 and a £68 million
reduction in the bank levy charge. Strategic costs of £787 million
included £237 million in NWM related to transformation, £124 million
of redundancy charges, £88 million of technology spend, and an
£85 million goodwill impairment.
A net impairment release of £1,278 million reflects the low levels
of realised losses we have seen across the year. Total impairment
Operating
profit before
impairment
losses £m
provisions reduced by £2.4 billion to £3.8 billion during 2021 and
as a result ECL coverage ratio decreased from 1.66% to 1.03%.
We are pleased to report a 2021 attributable profit of £2,950 million,
with earnings per share of 25.4 pence and a RoTE of 9.4%. A final
dividend of 7.5 pence per share is proposed, bringing our total 2021
paid and proposed capital distributions to £3.8 billion through a
combination of ordinary dividends, directed buybacks of the UK
Government stake and our on-market buyback programme.
Across the UK and RBSI retail and commercial businesses, and
excluding UK Government support schemes, net lending increased by
2.6%. Mortgage growth exceeded the market, however commercial
lending was behind market as we have sought to reduce certain
exposures, through targeted sector reductions and capital actions, whilst
continuing to focus on supporting customers through sustainable lending.
During the second half of the year we completed £8.1 billion Climate and
Sustainable Funding and Financing against our £100 billion target.
The CET1 ratio remains strong at 18.2%, or 17.8% excluding IFRS 9
transitional relief. The 30 basis points reduction in the year includes
capital distributions of c.240 basis points, partially offset by the reduction
in RWAs, c.170 basis points, and the attributable profit net of IFRS 9
transitional relief and other capital movements. RWAs of £157.0 billion
reduced by £13.3 billion in 2021 mainly reflecting business movements
in Commercial Banking, including targeted sector reductions,
improvement in risk parameters and active capital management.
On 1 January 2022, the proforma CET1 ratio was 15.9% including the
impact of regulatory RWA inflation, 200 basis points, the removal of the
software development costs capital benefit, 20 basis points, and the
tapering of IFRS 9 transitional relief, 10 basis points. RWAs increased
by £18.8 billion, including £14.8 billion associated with mortgage risk
weight changes.
(1)
Total expenses excluding litigation and conduct costs, strategic costs, operating lease depreciation (OLD) and Ulster Bank RoI direct costs.
2
NatWest Group
2021 Annual Report and Accounts
Operational highlights
Operational highlights
2021
2020
2019
Growth
UK and RBSI retail and commercial businesses net lending excluding
UK Government support schemes
305.7bn
£297.9bn
£289.7bn
Gross new mortgage lending in Retail Banking
36.0bn
£31.5bn
£33.3bn
AUM Net New Money (NNM)
£3.0bn
£1.5bn
£0.6bn
Percentage of customers using digital channels exclusively to interact with us
Retail Banking
60%
58%
46%
Commercial Banking
83%
82%
76%
Simplification
Reduction in other operating expenses
£256m
£277m
£310m
Artificial intelligence – retail banking Cora conversations
10.7m
8.4m
5.4m
Video banking interactions per week
10,200
3,300
<100
Capital
Directed buyback value
£1,125m
On-market buyback value
£676m
Dividend per share (paid and proposed)
10.5p
3p
14p
Risk-weighted assets (RWAs)
157.0bn
170.3bn
179.2bn
CET1 ratio
18.2%
18.5%
16.2%
As at 1 Jan 2022
15.9%
Return on tangible equity
9.4%
(2.4%)
9.4%
Read more about our strategic priorities on pages 18 and 19.
3
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Chairman’s statement
For much of 2021, there was a
growing sense of cautious optimism
that we might finally have put the
worst of the COVID-19 pandemic
behind us. However, towards the end
of the year, our resilience was put to
the test once more as the spread
of new variants necessitated the
reintroduction of various restrictions.
That brought particular challenges for our colleagues,
our customers and for the bank itself. But it also presented
opportunities and NatWest Group’s commitment to helping
people, families and businesses to thrive has never been
more important. We are building from extremely robust
foundations as a bank which holds strong market positions,
serving 19 million customers throughout the UK.
For the moment, a number of the key economic
indicators remain relatively positive – growth has returned,
unemployment is low, and the bank is seeing little in the
way of significant defaults among its customers.
However, there is no doubt that the rising cost of living is
making life difficult for many. It seems certain that inflation
will continue to increase in the short term at least – especially
as energy prices remain high. And we are yet to see the full
impact that the end of government support schemes will have
on the employment or housing markets. The uncertainty is not
just COVID-19-related, with global, European and domestic
political considerations also having an impact.
The Bank of England’s response has been limited so far and
while the market is anticipating a continued trajectory of
rate rises over the next twelve months, the low interest
rate environment is set to persist for some time to come.
Building a
purpose-led bank
to champion
potential
We champion potential; breaking
down barriers and building financial
confidence so the 19 million people,
families and businesses we serve
in communities up and down the
country can rebuild and thrive.
Howard Davies
Chairman
4
NatWest Group
2021 Annual Report and Accounts
‘The extensive support that the bank has provided to
its customers, colleagues and communities throughout
the pandemic was a key focus for the Board in 2021. We
also spent a significant amount of time ensuring that the
implementation of the bank’s strategy and transformation
agenda was subject to rigorous oversight and scrutiny.’
Against that backdrop, NatWest Group delivered a strong
financial performance in 2021, returning to profitability
and writing-back some of our pandemic-related impairment
provisions as the economic outlook improved. The bank’s
share price also saw a sharp recovery throughout the year,
increasing around 35% and outperforming our UK peers.
As our economy recovers and is reshaped to reflect new and
accelerating trends, we are focused on delivering sustainable
growth by creating deeper relationships with our customers
and giving them the support they need at every stage of their
lives – whether that is buying a house, saving for retirement
or setting up and growing their own business.
The UK banking industry as a whole has held up well
during the pandemic, remaining open for business and
well capitalised. NatWest Group retains one of the strongest
capital ratios among major European banks and we once
again comfortably passed the Bank of England’s stress test
in December 2021, further demonstrating the resilience of
our balance sheet to future crises. This, combined with our
continued capital generation, means our bank is well placed
to support its customers, invest for growth and drive
sustainable returns to shareholders.
£3.8 billion shareholder distributions were announced for
the financial year 2021, through buybacks – both directed and
on-market – and dividends. We also announced that we would
distribute at least £1 billion in dividends each year to 2023 as
we continue to optimise our capital ratio.
UK Government Investments (UKGI), which manages
the government’s shareholding, announced three separate
transactions during the course of 2021: the directed buyback
by NatWest Group; an on-market placement of shares; and an
ongoing trading plan. The government stake reduced from 62%
at the start of 2021, to less than 53% by the end of the year.
£3.8 billion
(paid and proposed)
shareholder distributions
announced for 2021
Final dividend of
7.5p per share
This was welcome progress. And we may take part in
further directed buybacks at the next opportunity, subject to
agreement from HM Treasury. Any transaction of this nature
could take the government’s shareholding below 50% for the
first time since the financial crisis. And while that would have
little impact on our governance or operations, it would be an
important symbolic moment for our bank.
NatWest Group’s financial performance has also been reflected
in the bonus pool for 2021, which has increased from the
previous year, where a significant reduction was made to reflect
our COVID-19-related losses. It is important to note, however,
that the bonus pool is slightly down on pre-pandemic levels.
It has been a period of relative stability in terms of Board
composition, with no changes to our membership in 2021.
As you would expect, we keep the composition, skills and
experience of the Board under review, and over the next
year or so we will need to recruit new members to cope
with planned retirements. In the main, the Board continued
to meet virtually throughout 2021. For 2022, we intend to
adopt a hybrid calendar with some meetings being held
virtually and some meetings in person, subject to relevant
government guidelines. Our virtual meeting technology has
served us well during the pandemic and we will continue to use
it to support the efficient and effective running of the Board.
The extensive support that the bank has provided to its
customers, colleagues and communities throughout the
pandemic was a key focus for the Board in 2021. We
also spent a significant amount of time scrutinising the
implementation of the bank’s strategy and transformation
agenda as well as enhancing our oversight of the bank’s culture.
The progress that Alison Rose and her strong and capable
leadership team have delivered in the last two years has
helped to ensure that NatWest Group is well placed to succeed
and grow as the needs and expectations of our customers
evolve. We are delivering on our purpose, underpinned by
our strategic priorities, and as a result, generating long-term
growth for our business, playing a positive role in our
communities and driving sustainable returns to our
shareholders. We know that by championing the potential
of the 19 million people, families and businesses we serve,
we will help them to thrive. And if they thrive, so will we.
Howard Davies
Chairman
5
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Group Chief Executive’s review
We champion
potential, helping
people, families,
and businesses
to thrive
Our future and our growth are
built on this one, clear purpose.
It’s what drives us, defines us,
and guides us. Because getting this
right means success – for ourselves
and for everyone we serve.
Alison Rose
Group Chief Executive Officer
NatWest Group’s execution is
centred around our purpose,
driving sustainable growth through
our strategic priorities. We are a
relationship bank for a digital world,
building ever deeper and closer
connections with our customers
throughout their financial lives,
enabling people, families and
businesses to thrive.
As I look back on 2021, I’m filled with admiration for
the resilience and adaptability that our colleagues and
customers have demonstrated during the pandemic. Faced
with unprecedented and constantly evolving challenges to the
UK’s public health and economy, the collective response has
been nothing short of extraordinary.
As it has been throughout the pandemic, the health and
well-being of our colleagues and customers continues to be
our highest priority. In particular, for the key workers who
have remained in our offices and branches to provide the
level of service and support our customers have needed
to rebuild and thrive.
NatWest Group is the UK’s leading business bank. It is also
a truly regional bank, serving 19 million customers throughout
the UK. We are proud of the role we play and the relationships
we already have across every part of the country. And we are
well positioned to deepen these relationships and to help our
customers, our economy and our bank to grow because
of the actions we have taken in recent years.
Thrive together
In spite of the difficult economic environment and the pressure
this continues to place on people, families and businesses up
and down the country, the UK remains an attractive and
entrepreneurial market, with small and medium-sized
enterprises (SMEs) driving around half of UK turnover and
employing 60% of the private sector workforce. It is also
an increasingly competitive market, where banks have
to maintain their relevance to earn their growth.
As the economy starts to recover and grow, customers’
expectations of banks are changing faster than ever. So too
is the way people live and work. Customers want a simple,
6
NatWest Group
2021 Annual Report and Accounts
Clima
te
L
ea
r
nin
g
En
te
rp
ris
e
Supporting customers at
every stage of their lives
Simple to deal with
Sharpened capital
allocation
Powered by innovation
and partnerships
These help us make a
meaningful
contribution to society while balancing
the needs of our customers,
colleagues
and shareholders
Our initial
areas of
focus
We
champion
potential,
helping
people,
families
and
businesses
to
thrive
Our purpose
Our strategy
engaging experience, designed to anticipate particular needs
and reflect their priorities, just as they have in other areas of
their lives.
When I first took up my role as Chief Executive, we committed
to a purpose that guides all of our decision-making – we
champion potential, helping people, families and businesses
to thrive. We also set out clear areas of strategic focus to
deliver on this purpose in order to drive sustainable returns
for our shareholders and build sustainable value in our bank.
We are executing well against these areas of focus, delivering
growth in key areas while controlling costs, better allocating
our capital and accelerating our digital transformation.
As a relationship bank for a digital world, our focus now is
on the opportunities we see for future growth. It is a simple
principle: if our customers and economy thrive, so will we.
Sustainable growth will come from ever closer and
deeper relationships with our customers at every stage
of their lives. Relationships that are based on insight and
shared goals, delivering a simpler customer experience
that removes complexity and frustration. Relationships
that reflect customers’ values and aspirations for themselves
and society. Relationships that start earlier in our customers’
lives and which adapt to meet their evolving needs.
All of which will be enabled by the strategic partnerships
and acquisitions we have made, and by our efforts to simplify
how customers interact with our bank so they can enjoy
an easier, frictionless banking experience. It will also be
driven by a better allocation of our capital – with £3 billion
being invested in the business across a three-year period
from 2021 to 2023, in addition to the sustainable returns
we are delivering to shareholders.
7
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Chief Executive’s review
continued
Delivering on our strategy
Of course, we are building from strong foundations. Our
operating profit for 2021 of £4.0 billion (£4.3 billion including
operating profit from discounted operations
(1)
) increased from a
loss of £481 million (£351 million loss including operating profit
from discounted operations
(1)
) the year before. This included
impairment releases of £1.3 billion, which reflected the low
levels of realised losses we have seen across the year.
We also continued to make progress against our other financial
targets. The bank’s net lending – excluding government
schemes – grew by £7.8 billion in 2021, primarily driven by
growth in mortgages. We removed a further £256 million of
costs from the business and retain a capital ratio well above
our target range.
At the same time, our digital transformation accelerated
as our customers chose to interact with us in different ways.
Around 60% of our retail current account holders now
only interact with us digitally
(1)
and we have seen further
strong growth in mobile payments and video banking. This
digitalisation of customer journeys is crucial to our future
growth, and our Net Promoter Scores are improving in key
segments as a result. For example, our much-improved
online process for renewing mortgages now takes as little
as 10 minutes.
We are also using our digital capabilities to keep our customers
safe and to build their financial capabilities, with credit scoring
now available in our app, dedicated support lines available
for customers in vulnerable situations and more than 1 million
customers growing their savings with us by £100 or more
for the first time.
As the UK’s leading business bank and a committed champion
of start-ups, we are removing barriers to enterprise, tackling
inequality and supporting growth by helping entrepreneurs
achieve their ambitions. We offer the UK’s largest fully funded
business accelerator network, with accelerator hubs across
the country providing support for high-growth businesses,
especially those led by under-represented groups. During the
pandemic, we pivoted this support for entrepreneurs to be
delivered digitally, as we did with our ‘Dream Bigger’
programme which helps 16–18-year-old girls develop
Committed to
embedding ESG
principles and
leading on
climate action.
(1)
Go-forward group excludes Ulster Bank RoI.
(2)
Income excluding notable items.
(3)
Between 1 July 2021 and the end of 2025.
(4)
Go-forward group other operating expenses defined as total expenses excluding litigation and conduct costs.
(1)
Refer to the Non-IFRS financial measures section for details of the basis of preparation and reconciliation of Non-IFRS financial and performance measures.
(2)
Retail Banking current account customers only based as at 31 December 2021 – metric is 87% of our retail customer needs are now met digitally, with 60% of our customers banking
entirely digitally. Only activity in the last quarter is considered.
A purpose-led company
with clear strategic
priorities, strong market
positions and capacity
to grow.
Supporting
19
million customers
throughout the UK.
Investing in our
digital proposition
to better serve
customers and
reduce cost.
Underpinned by
a robust balance
sheet and
an intelligent
approach to risk.
Focused on generating
long-term sustainable
value and a return
on tangible equity
of comfortably above
10% for the Group
in 2023.
Income
excluding
notable items to be
above £11.0 billion
in 2022 in the
Go-forward group.
(1,2)
Accelerating
growth
Provide an
additional
£100 billion
of Climate and
Sustainable
Funding and
Financing.
(3)
Simplification via
digital and
technology
~3% cost reduction
per annum through
to 2023.
(1,4)
Disciplined
deployment of
capital
CET1 ratio of
13-14% by 2023,
~14% by the end
of 2022.
Long-term
sustainable returns
an
d distributions
Intention to
distribute a
minimum of £1
billion
in each of
2022 and 2023.
Capital generative
business enabling
us to reinvest for
growth and return
excess to investors.
Our investment case: delivering against our strategic priorities to help our customers
to thrive and drive sustainable returns for shareholders
8
NatWest Group
2021 Annual Report and Accounts
transferable entrepreneurial skills. We also helped create
the SME Transformation Taskforce to unlock the growth
opportunity for the UK economy, identified in our
‘Springboard to Sustainable Recovery’ report.
Turning to our own business, the capital restructuring of
NatWest Markets has made substantial progress. It is simpler,
less capital intensive and better able to create opportunities for
our commercial customers by meeting their financing and risk
management needs, and by providing access to global markets
as well as leadership in high-growth areas, such as the green
and sustainable bond markets. As a result, we are creating
a new franchise called Commercial and Institutional by
bringing together our Commercial Banking, NatWest Markets
and RBS International businesses. The creation of this new
franchise is a further step in removing complexity and
becoming a simpler bank for customers to deal with.
We continue to make good progress on our phased withdrawal
from the Irish market, minimising job losses and protecting
services while supporting our customers and colleagues to
allow a smooth transition. During the year, we signed two
agreements with Allied Irish Banks p.l.c. (AIB) and Permanent
TSB p.l.c. (PTSB) which account for about 60% of the
Ulster Bank loan book in the Republic of Ireland, including
the transfer of colleagues, wholly or mainly supporting
the relevant portfolios and 25 branch locations.
These structural changes, along with our strong capital
position and continued capital generation, mean that we
are well placed to invest for growth, to provide the support
our customers need as the economy recovers and to drive
sustainable returns to shareholders, with £3.8 billion
shareholder distributions announced for 2021 through
dividends and buybacks.
The bank’s financial performance in 2021 also included a fine
following breaches of the Money Laundering Regulations 2007.
NatWest Group takes its responsibility to prevent and detect
financial crime extremely seriously. We deeply regret that we
failed to adequately monitor one of our customers between 2012
and 2016 to prevent money laundering. And while the case has
now come to an end, we continue to invest significant resources
in the ongoing fight against financial crime and fraud.
We are delivering our strategy through four strategic
priorities, with the aim of driving long-term sustainable
value and delivering on our 2023 targets, which we are
now updating. In 2022, we expect to deliver income excluding
notable items of above £11.0 billion in the Go-forward group
(1,2)
.
We are amending our cost reduction target to around 3% per
annum for 2022 and 2023
(2,3)
, reflecting higher inflation and our
ongoing investment in the business. Nevertheless, we maintain
a strong focus on continued cost discipline. We retain our 2023
CET1 ratio of 13–14%, and we have upgraded our return on
tangible equity target in 2023 to comfortably above 10% for
the Group.
Tackling climate change
One key area where our bank has a critical role to play is
in helping to tackle climate change. It is the biggest challenge
we face as a society, requiring collaboration and co-operation
on a global scale, and NatWest Group was proud to sponsor
the COP26 global climate conference which took place in
Glasgow in October/November 2021.
Our industry has a responsibility to drive and influence positive
change. As such, NatWest Group is committed to getting its
own house in order, bringing to an end the most harmful
activity and providing the support, advice and products our
customers need in order to accelerate the transition to a
net-zero economy.
We are one of the few banks to offer a Green Mortgage product,
with £728 million of lending to retail customers since its launch
in Q4 2020, and we established the Sustainable Homes and
Buildings Coalition with British Gas, Worcester Bosch and
Shelter to improve the energy efficiency of buildings in the UK.
Working with the fintech company CoGo, we were also the
first bank to introduce a carbon-tracking feature in our mobile
banking app. And we are helping colleagues and customers
to move to electric vehicles through a collaboration with
Octopus Energy.
Our Springboard to Sustainable Recovery report found that the
transition to net zero can create a huge opportunity for SMEs.
Close to 40% of our accelerator hubs are dedicated to supporting
sustainable businesses to help our most innovative start-ups to
take advantage of this opportunity. There is a clear societal
responsibility here, but also an obvious commercial imperative
in helping our customers to thrive as we transition to net zero.
Building a culture to champion potential
In seeking to make a positive contribution to the communities we
serve, we are also building an open, inclusive and progressive
place to work, breaking down barriers for our customers and
for our colleagues.
We are a learning organisation and our culture is critical to our
future success. We have worked with our colleagues as well
as with our customers, suppliers and communities to create a
new set of values that reflect the organisation we are today.
Values that match the ambition, optimism and energy our
purpose has given us, and that we can all believe in.
This builds on the progress we have made in recent years as
we consider the needs of all our colleagues and stakeholders.
In 2021, we launched our global Talent Academy to help
identify and develop colleague potential, with almost 4,000
accepted onto the programme. We also offered mental health
workshops for our line managers and our 1,300 Wellbeing
Champions, as well as seeing strong take up of our virtual
GP and physiotherapy offers.
(1)
Income excluding notable items.
(2)
Go-forward group excludes Ulster Bank RoI.
(3)
Go-forward group other operating expenses defined as total of expenses less litigation and conduct
9
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Chief Executive’s review
continued
Alison Rose talks about the
legacy of COP26 and NatWest
Group’s continued commitment
to help reach the 2015 Paris
Agreement goals.
Climate change in
conversation
What did it mean for NatWest Group
to be a principal partner of COP26?
Firstly, it was a huge honour. As one of the UK’s
biggest banks – and indeed the biggest for business
– we have both the ability and the responsibility to
take a major role in the fight against climate change.
We wanted to achieve two things at the conference:
to demonstrate how we can support our customers;
and to ensure that we play a leading role in the
global coalition of financial services organisations
tackling climate change.
We know the financial sector is a key enabler in
the drive towards net-zero emissions, so we invited
our customers to COP26 and held events that
explained the huge opportunity that climate change
can bring to businesses. We formed alliances to help
customers ‘green’ their homes, and collaborated with
organisations such as CoGo to help our customers
understand their carbon footprint. In this sense,
we saw the conference as an incredible chance
to showcase and develop the practical support we
can offer our retail and business customers to lower
their emissions.
With regard to collaborative action, we signed
up to the UK Government’s joint declaration on
accelerating the transition to 100% zero emission
vehicles, as well as announcing that we will be one
of 27 new members of the Powering Past Coal
Alliance, to accelerate the global transition from
coal. This follows on from our role as a founding
member of the Net Zero Banking Alliance and
becoming part of the new coalition of the Glasgow
Financial Alliance for Net Zero (GFANZ).
Outside the bank, we launched our ‘CareerSense’ programme,
providing more than 8,200 young people with free access
to tools that will develop critical skills and support their
employability prospects. We were also recognised by
the ‘Good Business Pays’ campaign for our commitment to
paying our suppliers the day after receiving an invoice, in
line with the Supplier Charter which we introduced in 2020.
In our top three layers globally, 38% of roles are currently filled
by female colleagues, a 9% increase since we first introduced
our target to have a full gender balance in these roles by 2030,
but a 1% decrease from 31 December 2020. We know we
have more to do and we continue to focus on the recruitment,
retention and advancement of women to meet our 2030 target.
In 2020, we launched the Racial Equality Taskforce to listen,
learn and better understand the barriers faced by colleagues,
customers and communities from Black, Asian and Minority
Ethnic backgrounds. Of those who disclose their ethnicity,
we have an aggregate of 11% Black, Asian and Minority
Ethnic colleagues in our top four layers in the UK; a 3%
increase since our 14% target was first introduced in 2018.
Living up to our purpose
Over the coming years, we will create a closer and deeper
relationship with the people, families and businesses that
we serve throughout the UK. From teenagers to retirees,
from newlyweds to new homeowners and from start-ups
to the largest multinationals, we will understand them
better, provide more value to them and help them to thrive.
By playing such a central role throughout the lives of our
customers, by taking action on the issues they care about
and by retaining their business as their needs and aspirations
change, our bank will go from strength to strength.
More than that, it will make a meaningful contribution to our
society, helping to grow and transition our economy as we
move towards net zero, sustainably growing our business
by living up to our purpose.
Alison Rose
Group Chief Executive Officer
10
NatWest Group
2021 Annual Report and Accounts
Read more about our Climate-related
disclosures on pages 64 to 71.
You mention the financial sector
is a key enabler, how can banking
make a difference?
Banks have a vital role to play –
by providing customers with access
to the necessary finance, expertise
and products, there is the chance
to drive real, positive change.
Importantly, I believe this is not only
good for the planet, but good for business
too. Our ‘Springboard to Sustainable
Recovery’ report clearly highlights this.
The report shows that small and medium-
sized enterprises (SMEs) can deliver
a significant amount of the UK’s
abatement targets, if they get the
right support. And this, we believe,
is a huge opportunity for businesses.
Demand for the financing to make this
happen is already significant. In 2020,
we set out to provide £20 billion of Climate
and Sustainable Funding and Financing over
two years. I am delighted that we met this
initial target in under 18 months, so in October
2021 we committed to an ambitious new goal
of providing an additional £100 billion of Climate
and Sustainable Funding and Financing between
1 July 2021 and the end of 2025.
Education and guidance are also key, which is why
we worked with fintech company CoGo in 2021 to
introduce a carbon-tracking feature in our mobile banking
app helping retail customers reduce the climate impact
of their spending. We are also working on similar pilot
schemes for our business customers.
What do you think will be the biggest
legacies of COP26?
I think history will judge COP26 as the point when
serious, collective climate action began across all
industries and all countries. In particular, it showed
the private sector starting to act together and at scale:
putting their own houses in order; taking action on
deforestation and biodiversity loss; and focusing on
the opportunities of the transition to net zero.
Most of all though, as 100,000 activists walked the
streets of Glasgow, it felt like a rallying call to embed
climate in all our decisions. Time will tell, but I hope
that COP26 will be remembered as the moment
where climate change truly became a global priority.
11
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Our purpose framework
A relationship bank
for a digital world
We champion potential, helping people,
families and businesses to thrive
Read more on page 13
We are guided by
our purpose
Read more on pages 14-17 and 54-63
Delivering long-term sustainable value and
attractive returns, now and for the next generation
Focused on growth, underpinned by our values
and an intelligent approach to risk:
We are informed
by the needs of our
stakeholders
Customers
Colleagues
Regulators
Read more on pages 18-19
We have four
strategic priorities…
Read more on pages 30-31
…creating a positive
impact through our
areas of focus
Climate
Enterprise
Learning
Supporting
customers at every
stage of their lives
Communities
Investors
Suppliers
Simple to
deal with
Sharpened capital
allocation
Powered by
innovation and
partnerships
12
NatWest Group
2021 Annual Report and Accounts
Our purpose
NatWest Group champions potential, helping people, families
and businesses to thrive. Because when they thrive, so do we.
Our purpose guides and underpins everything we do.
It enables us to build long-term value, to invest for growth,
to make a positive contribution to society and to drive
sustainable returns for shareholders.
Our stakeholders
We aim to balance the different interests of our stakeholders –
customers, investors, colleagues, communities, regulators and
suppliers – in all our decision-making, especially when there
are difficult choices to be made. We also recognise the need
for transparency and openness, regularly engaging and
seeking the views of our stakeholders.
Our blueprint for better business
Our strategy
We are a relationship bank for a digital world. Our strategy
for growth delivers on our purpose and drives sustainable
returns to shareholders through four strategic priorities:
we will support our customers at every stage of their lives;
we will be powered by innovation and partnerships as we
accelerate our digital transformation; we will be simple
to deal with; and we will allocate our capital in a way
that delivers for customers and shareholders.
Our values
Our values are at the heart of how we deliver our purpose-led
strategy. In 2021, responding to feedback from stakeholders,
we engaged with colleagues, customers and communities to
re-envision a modernised set of values that fully align with our
strategic priorities. These collaborative and evolved values
will be launched in 2022 and will form an integral part of
our cultural identity.
Our positive impact
We recognise the huge responsibilities that our role
brings – from supporting the day-to-day financial needs
of 19 million customers, to the positive impacts we can have
on the environment and wider society.
We have identified three focus areas where we can make
a meaningful contribution and build long-term value in
our business:
Climate
We have made addressing the climate challenge and
supporting our customers in their transition to net zero
a key strategic priority.
Enterprise
We are committed to removing barriers to enterprise and
providing businesses in the UK the support they need to grow.
Learning
We are helping people to take control of their finances,
to make the most of their money, safely and securely –
now and in the future.
Our robust balance sheet, strong capital position and capital
generative businesses mean we are well placed to support our
customers and invest for growth, as well as driving sustainable
returns to shareholders and creating long-term value for all
our stakeholders.
Honest and fair
with customers and
suppliers
A responsible and
responsive employer
A good citizen
A guardian for
future generations
Our purpose:
Deliver long-term
sustainable
performance by
championing potential,
helping people, families
and businesses to thrive
13
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Our stakeholders
Stakeholder
engagement
Our business is made up of a network of relationships. Listening, engaging
and partnering with stakeholders helps us to address our business impacts
and improve outcomes for customers, society and the environment. Below,
we highlight who our key stakeholders are and some examples of how we
collaborate with them to create value.
How we engaged
What we discussed
Outcome of engagements
Challenges we faced
Customers – the people and businesses we serve
(*) Within the scope of EY assurance. Refer to page 78
Face to face with retail customers via branches, mobile
branches and with our community bankers. Also, through
our video banking, telephony and secure messaging services.
Customer surveys including Net Promoter Scores (NPS),
syndicated surveys, focus groups and listening sessions.
Complaints.
With businesses, through Bankline for our business and
commercial customers; our Accelerator, Business Builder
and Digital Boost programmes; and our Banking on Business
Surveys, polls and discussions.
We support customers with their financial wellbeing, goals
and plans, our products and services, and with advice on
how to avoid fraud and scams.
Customer experience and satisfaction, climate change
(including COP26), problem debt and financial distress, our
youth proposition, and building thriving local communities.
Examples included service quality, and processes such
as fraud blocking and customer due diligence.
COVID-19, Brexit, support for small and medium-sized
enterprises (SMEs), removing barriers to enterprise,
UK Government’s Levelling Up agenda, transition to a net-
zero economy.
In 2021 we delivered 6.1 million
(*)
financial capability interactions and helped
470,813
(*)
additional customers start to save. We helped 111,895 people to
identify scams and know where to go to get help in 2021.
In terms of customer advocacy in 2021, NPS for Retail Banking improved by six
points for NatWest and seven points for Royal Bank of Scotland. In Commercial
Banking, NatWest maintained a leading score in the market while Royal Bank
of Scotland is one of the leading brands – refer to page 56 for full details.
Complaints provided us with the opportunity to improve our journeys for
customers and enhance colleague capability.
Our Digital Boost collaboration has supported SME recovery and helped
drive inclusive economic growth. We have committed to support Digital Boost
to offer expertise to 500,000 women and 200,000 people from ethnically
diverse backgrounds.
Several customers reached out to us
expressing their dissatisfaction at the
closure of their local branch.
The way people bank with us has
changed dramatically in recent years,
with an increased demand for mobile
and online services as customers benefit
from a faster and easier way to bank.
However, we still have more than 800
branches open and 16,000 physical
points of presence including our ATM
network and our relationship with the
Post Office.
Closing a branch is a decision we take
very seriously – we know it can affect
people who are less confident with the
alternatives we offer. We will strive to
guide those customers through the
changes and find the best way to
serve them from now on.
Customer engagement programme for
non-executive directors.
Customer feedback videos.
Customer experience and how our customers think about us.
Changing customer behaviours and product feedback.
Non-executive directors were able to observe customer-facing colleagues in
action and to hear customer feedback as part of a focus group or customer
listening surgery.
Feedback videos were shown to NatWest Group Board as part of the
annual Board strategy session and provided useful insights to help inform
Board discussions.
Colleagues – the people who deliver our purpose
Our View opinion survey.
Wellbeing Champions, Inclusion Champions, Our Colleague
Experience Squad and employee-led networks.
Team meetings, town halls and all-colleague webinars.
Junior Management Team (JMT).
Our View asks for colleague opinion on topics such as
purpose, wellbeing, inclusion, leadership and reward.
Our colleague representative groups are passionate
about advancing topics that influence our culture, such
as wellbeing; new ways of working; diversity, equity
and inclusion; colleague capability; and remuneration.
Several of the above topics, plus our sustainability aims.
The JMT mirrored the size and shape of the executive
leadership team, and supported several strategic goals.
Our View September 2021 survey results showed that overall colleague
sentiment remains strong, despite the impact of the pandemic.
Our c.1,300 Wellbeing Champions supported and amplified our wellbeing
strategy, signposting colleagues to the right resources at the right time.
We continued to support our c.24,000 participant employee-led networks,
who empowered colleagues and helped to create an inclusive workplace.
In 2021, we transformed our approach to mandatory diversity, equity and inclusion
learning. With help from some of our c.1,500 Inclusion Champions, we created an
e-Learning module featuring videos focusing on lived experiences of colleagues.
The JMT created Mystery Meetups – an initiative that encourages connections
across NatWest Group, promoting wellbeing and a one-bank mentality.
Over 46,700 colleagues (81%)
participated in our September 2021
Our View survey. Despite colleague
sentiment on culture, purpose, inclusion
and building capability remaining strong,
scores in the reward category have
declined since 2020, but remain aligned
with the Global Financial Services Norm
(GFSN) in all but one question. We will
seek to address this, subject to
performance, in 2022.
Across all 15 measured categories,
NatWest Group is an average of 11
percentage points above the GFSN
and five percentage points above the
Global High Performance Norm (GHPN).
Colleague Advisory Panel.
Board and Group Sustainable Banking Committee (SBC)
talent sessions with potential Group Executive Committee
(ExCo) successors.
Wellbeing, remuneration (including executives and
the wider workforce), climate, retail banking strategy,
sustainability and purpose.
Board: customer behaviour and purpose, sustainability
and climate.
SBC: how we can continue to support, build relationships,
and grow within the communities we serve.
The Colleague Advisory Panel continued to provide an important
two-way communication channel between the Board and colleagues
on key topics of interest.
Executive talent sessions helped our non-executive directors get to know
potential future leaders, through focused debates on strategic topics.
14
NatWest Group
2021 Annual Report and Accounts
How we engaged
What we discussed
Outcome of engagements
Challenges we faced
Customers – the people and businesses we serve
(*) Within the scope of EY assurance. Refer to page 78
Face to face with retail customers via branches, mobile
branches and with our community bankers. Also, through
our video banking, telephony and secure messaging services.
Customer surveys including Net Promoter Scores (NPS),
syndicated surveys, focus groups and listening sessions.
Complaints.
With businesses, through Bankline for our business and
commercial customers; our Accelerator, Business Builder
and Digital Boost programmes; and our Banking on Business
Surveys, polls and discussions.
We support customers with their financial wellbeing, goals
and plans, our products and services, and with advice on
how to avoid fraud and scams.
Customer experience and satisfaction, climate change
(including COP26), problem debt and financial distress, our
youth proposition, and building thriving local communities.
Examples included service quality, and processes such
as fraud blocking and customer due diligence.
COVID-19, Brexit, support for small and medium-sized
enterprises (SMEs), removing barriers to enterprise,
UK Government’s Levelling Up agenda, transition to a net-
zero economy.
In 2021 we delivered 6.1 million
(*)
financial capability interactions and helped
470,813
(*)
additional customers start to save. We helped 111,895 people to
identify scams and know where to go to get help in 2021.
In terms of customer advocacy in 2021, NPS for Retail Banking improved by six
points for NatWest and seven points for Royal Bank of Scotland. In Commercial
Banking, NatWest maintained a leading score in the market while Royal Bank
of Scotland is one of the leading brands – refer to page 56 for full details.
Complaints provided us with the opportunity to improve our journeys for
customers and enhance colleague capability.
Our Digital Boost collaboration has supported SME recovery and helped
drive inclusive economic growth. We have committed to support Digital Boost
to offer expertise to 500,000 women and 200,000 people from ethnically
diverse backgrounds.
Several customers reached out to us
expressing their dissatisfaction at the
closure of their local branch.
The way people bank with us has
changed dramatically in recent years,
with an increased demand for mobile
and online services as customers benefit
from a faster and easier way to bank.
However, we still have more than 800
branches open and 16,000 physical
points of presence including our ATM
network and our relationship with the
Post Office.
Closing a branch is a decision we take
very seriously – we know it can affect
people who are less confident with the
alternatives we offer. We will strive to
guide those customers through the
changes and find the best way to
serve them from now on.
Customer engagement programme for
non-executive directors.
Customer feedback videos.
Customer experience and how our customers think about us.
Changing customer behaviours and product feedback.
Non-executive directors were able to observe customer-facing colleagues in
action and to hear customer feedback as part of a focus group or customer
listening surgery.
Feedback videos were shown to NatWest Group Board as part of the
annual Board strategy session and provided useful insights to help inform
Board discussions.
Colleagues – the people who deliver our purpose
Our View opinion survey.
Wellbeing Champions, Inclusion Champions, Our Colleague
Experience Squad and employee-led networks.
Team meetings, town halls and all-colleague webinars.
Junior Management Team (JMT).
Our View asks for colleague opinion on topics such as
purpose, wellbeing, inclusion, leadership and reward.
Our colleague representative groups are passionate
about advancing topics that influence our culture, such
as wellbeing; new ways of working; diversity, equity
and inclusion; colleague capability; and remuneration.
Several of the above topics, plus our sustainability aims.
The JMT mirrored the size and shape of the executive
leadership team, and supported several strategic goals.
Our View September 2021 survey results showed that overall colleague
sentiment remains strong, despite the impact of the pandemic.
Our c.1,300 Wellbeing Champions supported and amplified our wellbeing
strategy, signposting colleagues to the right resources at the right time.
We continued to support our c.24,000 participant employee-led networks,
who empowered colleagues and helped to create an inclusive workplace.
In 2021, we transformed our approach to mandatory diversity, equity and inclusion
learning. With help from some of our c.1,500 Inclusion Champions, we created an
e-Learning module featuring videos focusing on lived experiences of colleagues.
The JMT created Mystery Meetups – an initiative that encourages connections
across NatWest Group, promoting wellbeing and a one-bank mentality.
Over 46,700 colleagues (81%)
participated in our September 2021
Our View survey. Despite colleague
sentiment on culture, purpose, inclusion
and building capability remaining strong,
scores in the reward category have
declined since 2020, but remain aligned
with the Global Financial Services Norm
(GFSN) in all but one question. We will
seek to address this, subject to
performance, in 2022.
Across all 15 measured categories,
NatWest Group is an average of 11
percentage points above the GFSN
and five percentage points above the
Global High Performance Norm (GHPN).
Colleague Advisory Panel.
Board and Group Sustainable Banking Committee (SBC)
talent sessions with potential Group Executive Committee
(ExCo) successors.
Wellbeing, remuneration (including executives and
the wider workforce), climate, retail banking strategy,
sustainability and purpose.
Board: customer behaviour and purpose, sustainability
and climate.
SBC: how we can continue to support, build relationships,
and grow within the communities we serve.
The Colleague Advisory Panel continued to provide an important
two-way communication channel between the Board and colleagues
on key topics of interest.
Executive talent sessions helped our non-executive directors get to know
potential future leaders, through focused debates on strategic topics.
Key ESG topics for our stakeholders
In 2021 we carried out an Environmental, Social and Governance (ESG) materiality assessment, involving a programme of
stakeholder engagement to deepen our understanding of the ESG topics that matter most to them. The findings guide our reporting
and decision-making, ensuring we remain focused on the right issues. While we have identified climate, enterprise and learning as
the three focus areas of our purpose where we can make a meaningful contribution, our 2021 assessment confirmed that our
stakeholders believe there are many other important ESG topics for NatWest Group to consider, particularly those related to
our core business responsibilities.
Read more about our ESG materiality assessment, including our methodology, in our 2021 Environmental,
Social and Governance Supplement.
How we engage
across the company
How we engage
at Board level
For further information on how stakeholder considerations influenced the
Board’s discussions and decision-making, refer to our section 172(1)
statement
on pages 52 to 53, and our Corporate governance report on page 102.
15
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Our stakeholders
continued
How we engaged
What we discussed
Outcome of engagements
Challenges we faced
Communities – the places where we have an impact
(*) Within the scope of EY assurance. Refer to page 78
We continued to engage with our charity relationships,
supporting them through Payroll Giving, colleague fundraising
and volunteering, and disaster and emergency appeals.
We supported young people through the delivery of our
MoneySense and CareerSense programmes.
NGOs, academia and think tanks.
We discussed raising awareness of charitable donations,
and enabling employee volunteering and fundraising
opportunities through our Do Good Feel Good campaign.
MoneySense gave financial advice to young people while
our CareerSense programme provided critical
employability skills – especially to those from
underprivileged backgrounds.
We discussed several climate-related topics, such as our
lending policies, Paris Alignment, biodiversity and COP26.
Our direct community investment in 2021 amounted to £7,266,818
(*)
. Across all
of our fundraising and volunteering programmes, our colleagues have given
£3,543,533 and 43,003 worktime volunteering hours.
MoneySense has helped 10 million young people learn about money since it
was launched in 1994, and is currently supported by over 6000 active volunteer
colleagues. CareerSense has seen 8,200 pupil registrations since its launch in
June 2021.
We sponsored COP26, published our first Nature and Biodiversity Statement,
and signed up to the Net Zero Banking Alliance and other commitments.
During 2021, the COVID-19 pandemic
resulted in NatWest Group temporarily
closing two popular volunteering
programmes – MoneySense for Schools
and The Conservation Volunteers (TCV).
MoneySense for Schools remained
closed throughout 2021, though online
resources were still available. However,
due to the TCV programme being
delivered outdoors, in June we were
once again able to offer colleagues the
chance to do their bit to help nature
and biodiversity to thrive.
The Chairman, Group CEO, Group CFO and selected
non-executive directors attended the COP26 Climate Summit
along with members of the executive team.
Progress against our climate ambitions, goals and targets.
Regulatory and investor expectations in relation to climate.
Non-executive directors and the executive team spent time talking with
customers, colleagues and industry peers at a range of climate-focused events.
Suppliers – where we source our goods and services
Regular review meetings with key suppliers.
Policy due diligence activity.
Audit reviews.
Environmental and ethical sustainability.
Prompt payment.
Risk management.
In collaboration with key stakeholders, we completed the first review
of our Supplier Charter, which sets out our aims and expectations in
several key areas.
We worked with EcoVadis – a leading organisation providing third-party
evidence-based assessments of sustainability performance – to measure our
own performance and that of our suppliers against the charter, enabling us
to identify social, environmental and ethical improvements.
Where suppliers that underwent the
EcoVadis assessment performed below
the global average, we know there is
more we can do to engage and support
them in improving their performance on
key sustainability topics.
To achieve this, we have put in place
a strategy for 2022 that aims to enable
our suppliers to improve and help us
cultivate a more responsible value chain.
Business reviews (regular Board reports)
Regular updates on key supplier and partnership
relationships and initiatives being undertaken with them.
Business review updates provided the Board with visibility on key supplier
activity and how this supported our purpose, strategy, financial performance
and climate ambitions.
Investors – providers of the capital and funding that supports our business activities
Investor spotlight sessions, presentations at industry
conferences and meetings with our senior management.
These presentations provided a deep dive into key areas
of the business, progress to date and future priorities.
Institutional investors and research analysts gained a deeper understanding of
our business and were able to ask questions of the wider management team.
COVID-19 restrictions presented a
challenge for the 2021 AGM. As a
solution to investors being unable to
attend the AGM, we held a virtual
shareholder event one week prior to
the AGM. Investors had the opportunity
to hear from Board members and ask
questions prior to voting on the AGM
resolutions. Answers and a recording of
the event were made available on our
website. Holding the event demonstrated
that engagement with investors is a
priority for the Board.
The Chairman, Group CEO, and Group CFO took part in
a programme of engagement through quarterly results
presentations and 1-1 meetings with our largest investors.
The Chairman, Group CEO, and other non-executive
directors represented the Board at three virtual shareholder
events with private shareholders.
The Chairman and a number of non-executive directors
hosted a corporate governance forum for investors.
Progress against strategic priorities, financial performance,
capital return policy, environmental, social and governance
topics, regulation and the macroeconomic environment.
As above, plus a discussion around dividends and share
price performance, supporting enterprise and tackling
climate change.
Board succession planning, diversity and inclusion, key
areas of Board focus, ‘Say on Climate’ resolutions.
The Chairman, Group CEO and Group CFO have an open dialogue
with institutional investors, updating investors on progress and keeping
the Board informed about their views and priorities throughout the year.
Private shareholders also had the opportunity to raise any concerns directly
with Board members at our virtual shareholder events.
Investors received an update on key corporate governance topics and the
Board heard their views on evolving practice for Say on Climate resolutions.
Regulators – who we seek to comply with
We engaged in several regulatory consultations.
Alternative risk-free reference rates (to replace LIBOR).
Credit risk.
Cybersecurity.
Historical conduct issues.
Access to cash.
COVID-19 support measures and recovery.
Environmental, Social and Governance issues.
We sent bilateral responses to material consultations or other requests for
comment/input issued by various government, regulatory and standard setting
bodies during 2021.
We engaged with regulators during the policy proposal phase on several
occasions to help inform priorities – examples included the independent review
of ring-fencing and proprietary trading and the FCA’s proposals for a new
consumer duty.
In December 2021, NatWest Bank Plc
was fined £264.8 million by the FCA for
three breaches of the Money Laundering
Regulations 2007. We deeply regret that
we failed to adequately monitor one of
our customers between 2012 and 2016
for the purpose of preventing money
laundering. We cooperated fully with
the FCA’s investigation. As part of its
ongoing programme of investment in
its people, processes and technology,
NatWest Group’s financial plans
already include over £1 billion to
further strengthen financial crime
controls over the next five years.
Prudential Regulation Authority (PRA) attendance at
July 2021 Board meeting.
Non-executive directors engaged with regulators through
continuous assessment and proactive engagement meetings.
PRA periodic summary meeting (PSM) outputs.
Topics included strategy, financial performance, capital
distributions, Board and Committee priorities, Board
effectiveness, governance, risk and control environment,
financial crime and ring-fenced bank independence.
The Board were able to hear directly from the PRA on the key messages in the
PRA’s PSM letter, including regulator expectations for key areas of Board focus.
Engagement meetings allowed the directors to understand the regulators’ key
areas of interest and provide them with direct feedback on those topics.
16
NatWest Group
2021 Annual Report and Accounts
How we engaged
What we discussed
Outcome of engagements
Challenges we faced
Communities – the places where we have an impact
(*) Within the scope of EY assurance. Refer to page 78
We continued to engage with our charity relationships,
supporting them through Payroll Giving, colleague fundraising
and volunteering, and disaster and emergency appeals.
We supported young people through the delivery of our
MoneySense and CareerSense programmes.
NGOs, academia and think tanks.
We discussed raising awareness of charitable donations,
and enabling employee volunteering and fundraising
opportunities through our Do Good Feel Good campaign.
MoneySense gave financial advice to young people while
our CareerSense programme provided critical
employability skills – especially to those from
underprivileged backgrounds.
We discussed several climate-related topics, such as our
lending policies, Paris Alignment, biodiversity and COP26.
Our direct community investment in 2021 amounted to £7,266,818
(*)
. Across all
of our fundraising and volunteering programmes, our colleagues have given
£3,543,533 and 43,003 worktime volunteering hours.
MoneySense has helped 10 million young people learn about money since it
was launched in 1994, and is currently supported by over 6000 active volunteer
colleagues. CareerSense has seen 8,200 pupil registrations since its launch in
June 2021.
We sponsored COP26, published our first Nature and Biodiversity Statement,
and signed up to the Net Zero Banking Alliance and other commitments.
During 2021, the COVID-19 pandemic
resulted in NatWest Group temporarily
closing two popular volunteering
programmes – MoneySense for Schools
and The Conservation Volunteers (TCV).
MoneySense for Schools remained
closed throughout 2021, though online
resources were still available. However,
due to the TCV programme being
delivered outdoors, in June we were
once again able to offer colleagues the
chance to do their bit to help nature
and biodiversity to thrive.
The Chairman, Group CEO, Group CFO and selected
non-executive directors attended the COP26 Climate Summit
along with members of the executive team.
Progress against our climate ambitions, goals and targets.
Regulatory and investor expectations in relation to climate.
Non-executive directors and the executive team spent time talking with
customers, colleagues and industry peers at a range of climate-focused events.
Suppliers – where we source our goods and services
Regular review meetings with key suppliers.
Policy due diligence activity.
Audit reviews.
Environmental and ethical sustainability.
Prompt payment.
Risk management.
In collaboration with key stakeholders, we completed the first review
of our Supplier Charter, which sets out our aims and expectations in
several key areas.
We worked with EcoVadis – a leading organisation providing third-party
evidence-based assessments of sustainability performance – to measure our
own performance and that of our suppliers against the charter, enabling us
to identify social, environmental and ethical improvements.
Where suppliers that underwent the
EcoVadis assessment performed below
the global average, we know there is
more we can do to engage and support
them in improving their performance on
key sustainability topics.
To achieve this, we have put in place
a strategy for 2022 that aims to enable
our suppliers to improve and help us
cultivate a more responsible value chain.
Business reviews (regular Board reports)
Regular updates on key supplier and partnership
relationships and initiatives being undertaken with them.
Business review updates provided the Board with visibility on key supplier
activity and how this supported our purpose, strategy, financial performance
and climate ambitions.
Investors – providers of the capital and funding that supports our business activities
Investor spotlight sessions, presentations at industry
conferences and meetings with our senior management.
These presentations provided a deep dive into key areas
of the business, progress to date and future priorities.
Institutional investors and research analysts gained a deeper understanding of
our business and were able to ask questions of the wider management team.
COVID-19 restrictions presented a
challenge for the 2021 AGM. As a
solution to investors being unable to
attend the AGM, we held a virtual
shareholder event one week prior to
the AGM. Investors had the opportunity
to hear from Board members and ask
questions prior to voting on the AGM
resolutions. Answers and a recording of
the event were made available on our
website. Holding the event demonstrated
that engagement with investors is a
priority for the Board.
The Chairman, Group CEO, and Group CFO took part in
a programme of engagement through quarterly results
presentations and 1-1 meetings with our largest investors.
The Chairman, Group CEO, and other non-executive
directors represented the Board at three virtual shareholder
events with private shareholders.
The Chairman and a number of non-executive directors
hosted a corporate governance forum for investors.
Progress against strategic priorities, financial performance,
capital return policy, environmental, social and governance
topics, regulation and the macroeconomic environment.
As above, plus a discussion around dividends and share
price performance, supporting enterprise and tackling
climate change.
Board succession planning, diversity and inclusion, key
areas of Board focus, ‘Say on Climate’ resolutions.
The Chairman, Group CEO and Group CFO have an open dialogue
with institutional investors, updating investors on progress and keeping
the Board informed about their views and priorities throughout the year.
Private shareholders also had the opportunity to raise any concerns directly
with Board members at our virtual shareholder events.
Investors received an update on key corporate governance topics and the
Board heard their views on evolving practice for Say on Climate resolutions.
Regulators – who we seek to comply with
We engaged in several regulatory consultations.
Alternative risk-free reference rates (to replace LIBOR).
Credit risk.
Cybersecurity.
Historical conduct issues.
Access to cash.
COVID-19 support measures and recovery.
Environmental, Social and Governance issues.
We sent bilateral responses to material consultations or other requests for
comment/input issued by various government, regulatory and standard setting
bodies during 2021.
We engaged with regulators during the policy proposal phase on several
occasions to help inform priorities – examples included the independent review
of ring-fencing and proprietary trading and the FCA’s proposals for a new
consumer duty.
In December 2021, NatWest Bank Plc
was fined £264.8 million by the FCA for
three breaches of the Money Laundering
Regulations 2007. We deeply regret that
we failed to adequately monitor one of
our customers between 2012 and 2016
for the purpose of preventing money
laundering. We cooperated fully with
the FCA’s investigation. As part of its
ongoing programme of investment in
its people, processes and technology,
NatWest Group’s financial plans
already include over £1 billion to
further strengthen financial crime
controls over the next five years.
Prudential Regulation Authority (PRA) attendance at
July 2021 Board meeting.
Non-executive directors engaged with regulators through
continuous assessment and proactive engagement meetings.
PRA periodic summary meeting (PSM) outputs.
Topics included strategy, financial performance, capital
distributions, Board and Committee priorities, Board
effectiveness, governance, risk and control environment,
financial crime and ring-fenced bank independence.
The Board were able to hear directly from the PRA on the key messages in the
PRA’s PSM letter, including regulator expectations for key areas of Board focus.
Engagement meetings allowed the directors to understand the regulators’ key
areas of interest and provide them with direct feedback on those topics.
17
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Our strategy
A strategy to deliver our purpose,
driving sustainable returns
Supporting customers at
every stage of their lives
Powered by innovation
and partnerships
Simple to deal with
Sharpened capital allocation
We acquired fintech company RoosterMoney,
whose pocket money app aims to build money
confidence and financial capability from an
early age.
We delivered £2.2 billion of gross lending to
small and medium-sized businesses in 2021
and processed 1 in 4 UK payments.
In Retail Banking, we have completed £728
million of Green Mortgages since their launch
in Q4 2020, rewarding customers for choosing
an energy efficient home.
We made it easier for our customers to
understand their financial health, by providing
c.1 million financial health checks during 2021.
Around £3 billion in investment continues to be
made (over 2021–2023), of which c.80% relates
to digital and technology programmes.
As the first major bank to join forces with
a renewable energy supplier through our
collaboration with Octopus Energy, we offer our
retail, business and wealth customers a tailored
package that improves the cost and efficiency
of owning and running an electric vehicle.
Collaborating with the fintech firm CoGo,
we were the first bank to introduce a carbon-
tracking feature in our mobile banking app.
We established the Sustainable Homes and
Buildings Coalition with British Gas, Worcester
Bosch and Shelter to improve the energy
efficiency of buildings in the UK.
87% of our retail customer needs are now
met digitally, with 60% of our customers banking
exclusively digitally.
(1)
There were 10,200 video banker conversations
per week in 2021 across Retail Banking,
compared with 3,300 per week in 2020.
In 2021, Cora, our AI virtual assistant,
handled 10.7 million Retail Banking
conversations, up 27% on the previous year.
Following our investments to improve customer
journeys, 70% of digitalised new account
openings in Retail Banking were completed
without human intervention in 2021; this
compares with 45% in 2020.
The NatWest Markets’ refocus has made
substantial progress in 2021; risk-weighted
assets reduced from £38 billion in 2019 to
£24 billion in 2021.
We have made good progress on our phased
withdrawal from the Republic of Ireland and
expect the majority of the Allied Irish Banks p.l.c.
(AIB) and Permanent TSB p.l.c. (PTSB) asset
sales to be largely complete by the end of 2022
and deposits to reduce over a longer timescale.
£3.8 billion shareholder distributions were
announced for the financial year 2021.
We completed £17.5 billion in Climate and
Sustainable Funding and Financing in 2021,
including £8.1 billion contribution towards
our £100 billion target.
(2)
Outcomes
We are more relevant to our customers by building
deeper relationships and evolving our propositions
to meet more of their needs throughout their lives.
Through technology and digital expertise, we
deliver an excellent customer experience by
harnessing our internal knowledge and experience
of partnering with leading external organisations
around the world.
By being simple to deal with we improve both
customer experiences and colleague engagement.
We focus on great customer service technology
and improving customer journeys.
Effective deployment of capital and efficient
portfolio discipline helps manage risk and drives
sustainable returns.
Our execution is centred around our purpose, driving sustainable growth
through our strategic priorities. We are a relationship bank for a digital world,
building ever-deeper and closer connections with our customers throughout
their financial lives, enabling people, families and businesses to thrive.
18
NatWest Group
2021 Annual Report and Accounts
Supporting customers at
every stage of their lives
Powered by innovation
and partnerships
Simple to deal with
Sharpened capital allocation
We acquired fintech company RoosterMoney,
whose pocket money app aims to build money
confidence and financial capability from an
early age.
We delivered £2.2 billion of gross lending to
small and medium-sized businesses in 2021
and processed 1 in 4 UK payments.
In Retail Banking, we have completed £728
million of Green Mortgages since their launch
in Q4 2020, rewarding customers for choosing
an energy efficient home.
We made it easier for our customers to
understand their financial health, by providing
c.1 million financial health checks during 2021.
Around £3 billion in investment continues to be
made (over 2021–2023), of which c.80% relates
to digital and technology programmes.
As the first major bank to join forces with
a renewable energy supplier through our
collaboration with Octopus Energy, we offer our
retail, business and wealth customers a tailored
package that improves the cost and efficiency
of owning and running an electric vehicle.
Collaborating with the fintech firm CoGo,
we were the first bank to introduce a carbon-
tracking feature in our mobile banking app.
We established the Sustainable Homes and
Buildings Coalition with British Gas, Worcester
Bosch and Shelter to improve the energy
efficiency of buildings in the UK.
87% of our retail customer needs are now
met digitally, with 60% of our customers banking
exclusively digitally.
(1)
There were 10,200 video banker conversations
per week in 2021 across Retail Banking,
compared with 3,300 per week in 2020.
In 2021, Cora, our AI virtual assistant,
handled 10.7 million Retail Banking
conversations, up 27% on the previous year.
Following our investments to improve customer
journeys, 70% of digitalised new account
openings in Retail Banking were completed
without human intervention in 2021; this
compares with 45% in 2020.
The NatWest Markets’ refocus has made
substantial progress in 2021; risk-weighted
assets reduced from £38 billion in 2019 to
£24 billion in 2021.
We have made good progress on our phased
withdrawal from the Republic of Ireland and
expect the majority of the Allied Irish Banks p.l.c.
(AIB) and Permanent TSB p.l.c. (PTSB) asset
sales to be largely complete by the end of 2022
and deposits to reduce over a longer timescale.
£3.8 billion shareholder distributions were
announced for the financial year 2021.
We completed £17.5 billion in Climate and
Sustainable Funding and Financing in 2021,
including £8.1 billion contribution towards
our £100 billion target.
(2)
Outcomes
We are more relevant to our customers by building
deeper relationships and evolving our propositions
to meet more of their needs throughout their lives.
Through technology and digital expertise, we
deliver an excellent customer experience by
harnessing our internal knowledge and experience
of partnering with leading external organisations
around the world.
By being simple to deal with we improve both
customer experiences and colleague engagement.
We focus on great customer service technology
and improving customer journeys.
Effective deployment of capital and efficient
portfolio discipline helps manage risk and drives
sustainable returns.
(2)
In October 2021, having surpassed our previous 2020-21 £20 billion target during
H1 2021, NatWest Group announced an ambition to provide £100 billion climate
and sustainable funding and financing between 1 July 2021 and the end of 2025.
(1)
Retail Banking current account customers only based as at 31 December 2021 –
metric is 87% of our retail customer needs are now met digitally, with 60% of our
customers banking entirely digitally. Only activity in the last quarter is considered.
19
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Our strategy in action
We’re always here to help our customers
when they need us.
So, when Nathalie decided to pursue her goal of buying a car to give her
more flexibility when travelling, we were ready to support.
It was late afternoon on a Friday when Nathalie got in touch with us. She’d
wanted a car for a long time and was unsure on how to go about it, but a
prompt on her NatWest mobile app about a personal loan offer was the
encouragement she needed to drive ahead with her plans.
Nathalie booked a video call with us using her mobile app and was
speaking to one of our team within 15 minutes. We made the process
simple and easy for Nathalie, taking her through the loan application and
also identifying that Nathalie would benefit from a savings account.
By 6pm that evening, Nathalie had the loan money in her account, giving
her the financial support she needed to buy a car. We’re passionate about
getting to know our customers and supporting them with all their banking
needs, whether we’re helping them in-person in a branch, or through one
of our innovative digital channels like video banking.
We think the help we gave to Nathalie is a great example of NatWest
Group’s determination to build deeper relationships with our customers
and support them to achieve their different goals in life.
Supporting
customers
at every stage
of their lives
Watch the story online
“We’re passionate
about getting to
know our
customers and
supporting them
with all their
banking needs”
20
NatWest Group
2021 Annual Report and Accounts
20
NatWest Group
2021 Annual Report and Accounts
Paul French,
Senior Personal Banker,
NatWest Torquay Branch
21
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Our strategy in action
Vernon is passionate about brewing,
and sustainability.
His company, Wye Valley Brewery in Herefordshire, has grown
from humble beginnings to now distributing to over 1,200 pubs,
as well as selling to all the major supermarkets.
And as the business’s operations have expanded over the years,
so have its sustainability ambitions. Reducing its carbon footprint has
been a key priority. The company had already installed over 1,000
solar panels, producing around 280 kilowatts of electricity, but it
also wanted to make the switch to all-electric vehicles.
For Vernon, investing in sustainable and innovative technology is
key to the long-term success of his business. And this is exactly
where NatWest was able to help.
When Vernon mentioned his plans to the NatWest relationship manager,
we were able to tell him of our collaboration with Octopus Energy.
Through our collaboration – the first time a major bank and a renewable
energy supplier have joined forces – we offer our retail, business and
wealth customers a tailored package that improves the cost and efficiency
of owning and running an electric vehicle.
The brewery now has eight charging points which the staff can use
and are also open to the public. Vernon believes it has made a real
difference in his company’s shift to electric vehicles.
With our focus on partnerships and innovation, NatWest Group is making
it easier and more affordable for our customers to make a positive
difference to our environment.
Powered by innovation
and partnerships
Watch the story online
“With our focus
on partnerships
and innovation,
NatWest is making
it easier and more
affordable for our
customers to
make a positive
difference to our
environment.”
22
NatWest Group
2021 Annual Report and Accounts
Vernon Amor,
Managing Director,
Wye Valley Brewery
23
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Our strategy in action
Mica Johnson,
Owner,
Floral Glory
24
NatWest Group
2021 Annual Report and Accounts
Mica had always dreamed of running
her own business.
Indulging her passion for flowers, she launched Walsall-based
florist Floral Glory. However, a month after she went self-employed,
the pandemic struck.
Being a start-up company can be hard enough at the best of times.
But trying to connect with suppliers and customers during a national
lockdown was a real challenge. Mica needed all the support she
could get.
As a long-standing personal banking customer, she knew NatWest
was simple to deal with. So she reached out to our business banking
team for help with setting up Floral Glory’s payments system.
Running her business from home initially meant that transactions
needed to work across virtual and physical platforms. Tyl by NatWest
provided the solution.
It allowed Mica to accept online payments securely through her
website or by phone. The next-day business settlement also really
helped in the early days when cash flow was so important.
After the lockdown, when Mica moved into her premises, Tyl once
again helped her keep things simple. The portable card machine was
ideal for moving around the shop, while each payment integrated
straight into her accounting software.
Mica’s story shows how NatWest is here to help.
By combining the right products and being simple to deal with,
we make life easier for our customers.
Simple
to deal with
Watch the story online
“By combining the
right products and
being simple to
deal with, we
make life easier
for our customers.”
25
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Our strategy in action
Lightsource bp,
solar array
26
NatWest Group
2021 Annual Report and Accounts
The team at Lightsource bp believe
there’s huge potential in the transition
to a net-zero economy.
They should know. As a global leader in the development and
management of solar energy projects, they’ve seen the market
for renewables grow sharply over the past decade.
But accessing that opportunity has required hard work, innovation
and, of course, the financing to make it happen.
NatWest Group has supported Lightsource bp throughout its journey
from a UK start-up 10 years ago, to its emergence as a major renewable
energy firm.
The company now employs 700 industry specialists working across
17 countries to help deliver affordable and sustainable solar power
for businesses and communities around the world.
For us, our work with Lightsource bp aligns perfectly with our
purpose and climate ambitions. We know the financial sector is a
key enabler in the drive towards net-zero emissions, but it’s more than
that. As well as being good for the environment, it’s also good business.
It’s a belief we have committed to with our announcement in 2021
to provide an additional £100 billion of Climate and Sustainable Funding
and Financing by the end of 2025.
And we’re continuing our journey with Lightsource bp too – agreeing
in 2021 to be part of the funding package for the company’s ambitious
new growth strategy.
We believe focusing the allocation of capital in this way makes perfect
sense. It’s good for our business, the companies we support, and our planet.
Sharpened
capital allocation
Watch the story online
“Focusing the
allocation of
capital in this way
makes perfect
sense. It’s good
for our business,
the companies
we support, and
our planet”
27
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
2021
289.7
310.8
317.3
2020
2019
2021
310
277
256
2020
2019
2021
1 Jan
2022
16.2
18.5
18.2
15.9
2020
2019
2021
9.4
(2.4)
9.4
2020
2019
Financial
Measuring
our performance
Key performance indicators
£m
%
%
Achieve net lending growth in
our UK and RBSI retail and
commercial businesses.
Achieve a c.4% cost reduction in
other expenses excluding OLD
and Ulster Bank RoI direct costs
in 2021.
Achieve CET1 ratio target of
13-14% by 2023.
Achieve return on tangible
equity target of 9-10% by 2023.
Net lending
Cost reduction
CET1 ratio
Return on tangible
equity
Across the UK and RBSI retail
and commercial businesses and
excluding UK Government support
schemes, net lending increased by
£7.8 billion, or 2.6% largely driven
by mortgages. Mortgage growth
exceeded the market, however
commercial lending was behind
market as we have sought to
reduce certain exposures, through
targeted sector reductions and
capital actions, whilst continuing
to focus on supporting customers
through sustainable lending.
A cost reduction of £256 million,
or 4.0%, in 2021, in line with our
target for the year.
This has been achieved by
transformation across our
customer journeys and in the
NatWest Markets business.
The CET1 ratio remains strong
at 18.2%. The 30 basis points
reduction in the year principally
reflects capital distributions,
partially offset by the reduction in
RWAs and the attributable profit.
RWAs of £157.0 billion reduced
by £13.3 billion in 2021 mainly
reflecting business movements in
Commercial Banking, including
targeted sector reductions,
improvement in risk parameters
and active capital management.
Return on tangible equity
which was 9.4% at year end,
benefitted from significant
impairment releases.
Supporting customers at
every stage of their lives.
Simple to deal with.
Powered by innovation
and partnerships.
Sharpened capital
allocation.
Sharpened capital
allocation.
Supporting customers at
every stage of their lives.
Simple to deal with.
In 2022 we expect income
excluding notable items to be
above £11.0 billion in the
Go-forward group.
In both 2022 and 2023 reduce
Go-forward operating expenses,
excluding litigation and condu
ct
costs by around 3%.
Aim to end 2022 with a CET1
ratio of around 14% and target
a ratio of 13-14% by 2023.
In 2023, we expect to achieve
a return on tangible equity of
comfortably above 10% for
the Group.
Link to remuneration
Read more on how the KPIs are aligned to executive directors’ remuneration in our Annual remuneration report on pages 158 to 174.
Why is it important?
Delivering long-term sustainable performance.
Run a safe and secure bank.
Our performance
Link to strategy and areas of focus
How we measure our progress and our future priorities
Future priorities
Read more: Our investment case on page 8 and Outlook statement on page 51
£bn
28
NatWest Group
2021 Annual Report and Accounts
2021
13
7
4
-2
-2
-7
22
24
23
2020
2019
2021
12.0
9.4
8.1
2020
2021
c.60,700
2020
c.55,000
2021
79
80
80
2020
2019
£bn
Increase the likelihood that
customers will recommend our
brands. Achieve NPS targets
for our core customer-facing
businesses.
Net Promoter Score
NatWest Retail main bank NPS
exceeded its target by five points,
up six points year on year.
NatWest Business Banking
missed its target by two points
and continues to be ranked 3rd.
NatWest Commercial Banking
retained first position and its
lead over next best competitor.
Simple to deal with.
NPS improvement of: one point
for NatWest Retail Main Bank or
be 5th or better; four points for
NatWest Business Banking and
be 3rd or better.
Read more: Our customers on
page 54 to 56.
Why is it important?
Link to strategy and areas of focus
Future priorities
How we measure our progress
Our performance
Honest and fair with customers
and suppliers.
Support removal of barriers to
UK enterprise growth through
the provision of learning,
networking and funding
interventions.
Achieve the culture target,
as measured through the
NatWest Group ‘Our View’
colleague survey.
Provide an additional £100 billion
of Climate and Sustainable
Funding and Financing from
1 July 2021 – end 2025.
Non-financial
Climate and Sustainable
Funding and Financing
Supporting enterprise
Build up and strengthen
a healthy culture
We have supported c.55,000
(1)
individuals or businesses through
enterprise programmes with
c.200,000
(1)
customer interventions
delivered. Of those supported,
c.26% were from Black Asian and
Minority Ethnic backgrounds
c.60% identified as female.
c.52% were purpose-led.
c.75% were outside of London and
the South East.
In 2021 we exceeded our target
on Culture by two points. Our
target was to be seven points
above the Financial Services
Culture Board (FSCB) norm.
For Culture measurement and
assessment, our calculation
methodology aligns with that
used by the FSCB.
In October 2021 having
surpassed our 2020-2021 target
of £20 billion in the first half of
2021 we announced an ambition
to provide an additional £100
billion between 1 July 2021
and the end of 2025. In 2021
we provided £17.5 billion of
Climate and Sustainable
Funding and Financing
(*)
,
including £8.1 billion
(*)
contribution to our
£100 billion target.
Support 35,000 businesses
through enterprise
programmes
(*)
with 200,000
customer interactions to start,
run and grow a business.
We independently survey
thousands of customers each
year, asking them how likely
they would be to recommend
the bank.
Funding and financing
provided to support climate and
sustainable activities, in line with
our Climate and Sustainable
Finance Inclusion (CSFI) criteria.
Read more: Our purpose-led
areas of focus on pages 30 and
31 and in our ESG Supplement.
Read more: Our colleagues
section on pages 58 to 61
and in our ESG Supplement.
Read more: Our climate-related
disclosures on pages 64 to 71
and in our Climate-related
Disclosures Report.
A good citizen.
Remove barriers to
UK enterprise growth.
A responsible and
responsive employer.
Build up and strengthen
a healthy culture.
A guardian for future
generations.
To be a leading bank in
the UK helping to address
the climate challenge.
Climate
Enterprise
Learning
(*)
Within the scope of EY assurance. Refer to page 78.
(1)
Refer to page 31 for further details.
29
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Our purpose-led areas of focus
building long-term value
Our purpose-led focus areas
Our ambition
Our areas of focus
contribute to UN Sustainable
Development Goals (SDGs):
We are committed to championing potential, helping people, families and
businesses to thrive. Aligned to our purpose are three focus areas where we
believe we can make a long-term, meaningful contribution to our customers,
colleagues and communities. These are: climate, enterprise and learning.
Climate
A leading bank in the UK helping to address
the climate challenge
Our targets
Net zero
(1)
by 2050
£100bn
Climate and Sustainable Funding and Financing between 1 July 2021 and the end
of 2025
-50%
at least halve the climate impact of our financing activity by 2030
50%
of our UK mortgage customers’ homes at, or above, EPC C rating by 2030
Full phase out of coal – by 1 January 2030
(2)
-50%
reduce our direct
(3)
own operations carbon footprint by 2025
As well as highlighting
activity that relates to each
of the SDGs above, case
studies throughout this
report will reference positive
impacts mapped against
other SDGs. More detail
on our embedding of SDGs
can be found in our ESG
Supplement. As signatories
of the UN Principles for
Responsible Banking, we
also remain committed to
aligning our strategy with
the 2015 Paris Agreement
and the SDGs.
(1)
Please refer to section 1.2 in the
NatWest Group plc Climate-related
Disclosures Report for further detail
on our net-zero ambitions.
(2)
Please refer to section 3.5.2 in the
Natwest Group plc Climate-related
Disclosures Report for further details
on outcomes.
(3)
Against a 2019 baseline. Direct own
operations is defined as Scope 1,
Scope 2 and Scope 3 (paper, water,
waste, business travel, commuting
and work from home) emissions. It
excludes upstream and downstream
emissions from our value chain.
(4)
In October 2021, having surpassed
our previous 2020-21 £20 billion
target during H1 2021, NatWest
Group announced an ambition to
provide an additional £100 billion
Climate and Sustainable Funding
and Financing between 1 July 2021
and the end of 2025.
Enterprise
Removing the barriers to enterprise
Our targets
35,000
individuals or businesses supported through enterprise programmes in 2021
(8)
200,000
interventions delivered to start, run or grow a business in 2021
(8)
60%
of those supported will be female
75%
of those supported will be based outside London and the South East
20%
of those supported will be of a Black, Asian and/or Minority Ethnic background
10%
of those supported will be social purpose-led
Learning
Building financial capability and resilience and enhancing the skills of
our colleagues
Our targets
15m
financial capability interactions delivered by 2023
2m
additional customers helped to start saving by 2023
100%
front-line colleagues professionally accredited within the first 18 months in role
UK
Social Mobility Apprenticeship Programme extended across multiple UK locations
30
NatWest Group
2021 Annual Report and Accounts
Our 2021 performance
£17.5bn
(*)
Climate and Sustainable
Funding and Financing
completed, including £8.1bn
contribution towards our
£100bn target
(4)
2020: £12 bn
£728m
(*)
Retail Banking Green
Mortgage completions
(7)
38%
(*)
of Retail Banking mortgages
are at, or above, EPC rating C
(5)
2020: 36%
52%
of gross lending and investment
balances at 31 December 2019
estimated for financed emissions.
A further eight high carbon
emitting sectors estimated
2020: 45% (four sectors)
-46%
reduction in our
direct
(3)
own operational
carbon footprint
(3)
Credible
transition plan
assessments
completed for oil and gas majors
and in scope coal customers
(2)
Climate
Read more on page 20 of
NatWest Group plc 2021
Environmental, Social and
Governance Supplement
(5)
Percentage of £110.3 billion UK Retail Banking mortgages where EPC data is available. 2020 comparative for England and Wales
mortgages only.
(6)
Retail Banking RBS, NatWest and Ulster Bank Northern Ireland mobile apps.
(7)
Retail Banking Green Mortgage products relate only to mortgages for energy efficient homes (EPC A or B rated) and are aligned to
the World Green Building Council definition of green mortgages.
(8)
Represents approximate number of interventions delivered by and individuals supported through enterprise programmes during 2021,
which is based upon data provided by third parties delivering these interventions without further independent verification by
NatWest Group.
(9)
Includes instances where customers had savings with other banks and transferred them to their NatWest Group account.
(*)
Within the scope of EY assurance. Refer to page 78.
Read more on page 24 of
NatWest Group plc 2021
Environmental, Social and
Governance Supplement
c.55,000
individuals and businesses
supported through enterprise
programmes in 2021
(8)
c.75%
of those supported were based
outside of London and the
South East
c.200,000
interventions delivered to start,
run or grow a business in 2021
(8)
c.52%
individuals or businesses
supported were
purpose-led businesses
c.60%
of those supported identified as
female purpose-led businesses
c.26%
of those supported were of
Black, Asian and Minority
Ethnic background
Enterprise
Read more on page 29 of
NatWest group plc 2021
Environmental, Social and
Governance supplement
8.96m
(*)
financial capability interactions
delivered by 31 December 2021
against the 2023 target
1.07m
(*)
additional customers helped
to start saving by 31 December
2021 against the 2023 target
(9)
99.6%
front-line colleagues
professionally accredited within
the first 18 months in role
Learning
31
NatWest Group
2021 Annual Report and Accounts
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Financial review
Governance
Risk and capital management
Additional information
Financial statements
Customers
Overview
Customers’ needs and behaviours are changing as a result of
new technologies. The impact of COVID-19 has accelerated
digital trends as well as prompting different ways of working,
shopping, socialising and communicating. Demographic shifts
and changing labour patterns are also having a profound
long-term effect on customer behaviours, as people work
longer, retire later, rent for longer or buy property later in life.
Our response
Understanding these trends allows us to better support our
customers’ needs, being there at every stage of their lives
and tailoring banking services and products that meet their
evolving expectations. By harnessing new technology and
partnering with leading organisations, we have again
enhanced and evolved our customer experiences in 2021.
We have also continued our efforts to make banking more
accessible for all of our customers through improving face-to-
face, digital and remote interactions. And in 2021, we again
devoted significant focus to supporting customers facing
financial difficulty or in vulnerable situations, as well as
helping more people to start saving.
Technology
Overview
New business models and customer behaviours continue to
rapidly evolve through advancing technology. COVID-19 has
increased our customers’ reliance on technology with a further
shift to digital, reinforcing the need for modern capabilities and
resilient systems. Our active digital users across both personal
and business customers continued to grow in 2021.
Our response
With a focus on innovation, and through collaborations
with experienced companies, our technology solutions have
driven significant benefits for our customers. This has been
particularly evident again in 2021 with our approach to Open
Banking. Leveraging the ability to combine transaction and
bank issuance data has helped us generate invaluable insights
for our commercial customers. In terms of our own digital
estate in 2021, we have also delivered further technological
innovation to help protect privacy and customer confidentiality.
In addition to the strong focus on delivering innovative
solutions for our customers, technology transformation
continues to prioritise simplification, stability and resilience,
as well as year-on-year run-cost reduction.
The environment we operate in is constantly changing. Understanding
the multiple influences on our business enables us to be prepared for change,
to respond quickly, and to create value for the long term.
NatWest Group continues
to adapt to evolving market trends
Economy
Overview
In 2021, the UK economy continued its recovery from the
impact of COVID-19 and lockdown restrictions, with GDP
approaching pre-pandemic levels towards the end of the year.
The employment market continued to remain robust, with the
furlough scheme proving an effective tool to lessen the impact
of COVID-19 as well as helping the labour market emerge from
COVID-19 in a position of strength. Towards the end of 2021,
UK job vacancies remained elevated. Against this backdrop,
inflationary pressure began to build with the Consumer Prices
Index ending the year well ahead of the Bank of England’s 2%
target. Countering inflation is therefore likely to remain high on
the agenda for policy makers in the short to medium term. In
the longer term, demographic change, climate change, high
levels of debt and inequality could all have financial impacts
for our customers.
Our response
Our business performance is correlated with economic factors.
Put simply, when people, families and businesses thrive, so
do we. We know the tough economic conditions many of our
customers have faced throughout the year. As such, we have
remained focused on removing barriers to doing business and
providing more opportunities for companies to grow, helping
the economy to build back better. Initiatives such as our
‘Accelerator’ programme, our ‘Springboard to Sustainable
Recovery’ report, and an additional £1 billion in funding to
help support female-led businesses in the UK recover from
COVID-19 have been a key part of this.
Market environment
“COVID-19 has increased
our customers’ reliance
on technology with a
further shift to digital,
reinforcing the need
for modern capabilities
and resilient systems.”
32
NatWest Group
2021 Annual Report and Accounts
Cyber threats
Overview
Cyberattacks pose a constant risk to our operations, both in
relation to our own digital estate and indirectly with regards
to our supply chain. Cybercrime continues to evolve rapidly.
Attacks may be from individuals or highly organised criminal
groups intent on stealing money or sensitive data, or potentially
holding organisations to ransom.
Our response
We continue to invest significant resources in the development
and evolution of cybersecurity controls, deploy rigorous due
diligence with regards to third parties and work to protect and
educate our colleagues and customers on fraud and scam
activity. To provide continuity of service for customers with
minimal disruption, we monitor and assess a diverse and
evolving array of threats, both external and internal, as well
as developing, strengthening or adapting existing control
capability to be able to absorb and adapt to such disruptions.
Climate change
Overview
Climate change represents an inherent risk to NatWest
Group, not only from its impact on the global economy and
our customers, but also through its potential effects on asset
values, operational costs and business models as the essential
transition to a net-zero economy accelerates. These risks are
subject to increasing regulatory, political and societal change.
Conversely, the requirement to reduce carbon emissions also
means NatWest Group has a significant role to play in areas
such as the provision of Climate and Sustainable Funding
and Financing.
Our response
Climate risk was formally incorporated into the NatWest Group
risk directory as a principal risk in February 2021 and in April
2021, NatWest Group Board Risk Committee approved a
principles-based climate risk policy. Our Climate Opportunities
Group (COG) was established to support our ambition to be a
leading bank in helping to address climate change. The COG
brings together colleagues from all business segments to
conceptualise and develop opportunities that complement the
NatWest Group climate ambition. Being a principal partner of
COP26 gave us the opportunity to re-state our commitment
to working with our partners to help reduce carbon emissions.
At the conference in Glasgow, we focused on highlighting the
practical support we are providing our customers to help them
achieve their climate ambitions, as well as strengthening our
existing partnerships and building new ones. Our commitment
to tackling climate change means we have already reduced
our direct own operations footprint by 46%, against a 2019
baseline and plan to achieve a 50% reduction by 2025. We
have also set stretching targets for our wider operational
value chain and have an ambition to halve the impact of
our financing activity by 2030.
Regulation
Overview
We operate in a highly regulated market which continues
to evolve in scope. Areas of current regulatory focus include:
delivering good customer outcomes, in particular the FCA’s
current proposals for a Consumer Duty, which looks to
expand its rules and principles to force firms to provide better
consumer protection; operational resilience, in light of the UK
authorities’ new policy requirements; climate change, and
the development of the regulatory framework for sustainable
finance; fraud and financial crime, with a focus on protecting
customers from ever-more sophisticated scams; capital and
liquidity management, including the UK’s approach to the
implementation of Basel III; the UK’s future regulatory
framework, following its exit from the European Union and
the opportunities that this provides; digital currencies, with
the development of both public (central bank digital currencies)
and private (e.g. stablecoins) offerings which have the potential
to materially change the digital payments landscape; improving
diversity, equity and inclusion in financial services, through
policy developments focused on improved data collection
and reporting, and use of targets for representation.
Our response
We constantly monitor regulatory change and work with our
regulators to help shape those developments that materially
impact the bank, lobbying when necessary either bilaterally
or in partnership with one of our affiliated industry bodies.
We implement new regulatory requirements where applicable
and use our frequent engagement meetings with regulators
to discuss key regulatory priorities.
(1)
Since 1 July 2021, UK & Ireland £5.5 billion, Western Europe £1.9 billion and
Other £0.6 billion.
United Kingdom and Ireland
W
estern Europe
Other
T
ot
al:
£17.5bn
£7.8bn
£8.5bn
£
1
.2bn
Nat
W
est Group 2021 Climate and Sus
tainable
Funding and Financing – Geographic
al split
(1)
33
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Governance
Risk and capital management
Additional information
Financial statements
Purpose-led and integrated value creation
We aim to create value for our
stakeholders, having a positive impact
on our environment and wider society.
Our work lends particular support
to the below seven sustainable
development goals.
Find out more in the following sections:
How we
create value
1
Financial
Human and relationships
NatWest Group was a
principal partner for COP26,
widening the involvement
of the business community,
young people and civil society,
enabling voices to be heard
to help progress be made.
Our business activities
2
Our resources
1
How we create value
3
Our resources
Nature
Infrastructure
34
NatWest Group
2021 Annual Report and Accounts
9.4% return on tangible equity, 18.2% CET1 ratio,
£256 million cost reduction and £2,950 million profit
attributable to ordinary shareholders.
We support the financial lives of our customers and
drive economic growth through our well-known brands.
We make appropriate use of shareholder capital and
other forms of financial capital, including £479.8 billion
in customer deposits.
We are committed to sustainability as a driver of value
creation through our investment, products and service.
Financial
We rely on an engaged, healthy and inclusive workforce
of 58,500
(1)
to deliver our strategy to 19 million customers
in the UK.
Our relationships with all stakeholder groups help to shape
and support our strategy and operations. This includes our
shareholders and regulators, suppliers, consumer and
campaign groups, local communities and more.
Human and relationships
Our resources
Our business activities
2
(1)
NatWest Group headcount for both continuing and discontinued operations at 31 December
2021, based on global data for active permanent colleagues (including FTC and excl. temps).
We understand we are part of the natural world, benefiting
from resources and ecosystem services to conduct our
business activities. We are forming expert partnerships to
restore degraded lands and forests, to support the needs
of local communities and nature, as well as removing
120,000 tonnes of CO
2
e each year.
Nature
We depend on our property and technology infrastructure,
and that of our supply chain, to run the bank’s systems
and operations. We are also investing significantly in
technology and human expertise to deliver a leading
digital customer experience.
Infrastructure
Products and services
We provide a comprehensive range of banking and financial
services to personal, business and commercial customers
via our businesses. Examples include current and savings
accounts, credit cards, mortgages and investments for our
personal customers; as well as banking, lending, project
finance, risk management and trading solutions for our
large commercial customers.
Revenues and returns
We earn income from interest charged on lending to our
customers and fees from transactions and other services.
We pay interest to customers who place deposits with us
and to investors who buy our debt securities. We also make
reward payments on products like our Reward bank accounts
and credit cards. The attributable profit generated is either
returned to shareholders or retained and reinvested into
improving our business to benefit our stakeholders.
Customer relationships
We support our personal, business, commercial and
institutional customers with financial services that meet their
needs, which include keeping their funds safe and secure,
improving financial capability and supporting enterprise.
We believe in treating customers fairly, offering flexibility
to our customers in how they choose to bank with us and
providing extra help to customers in vulnerable situations
or financial difficulty.
Partners and networks
Being powered by innovation and partnerships means
we work with a diverse range of partners to help shape our
business strategy and deliver positive outcomes for customers
and society. This includes our supply chain, communities,
academia, regulators, expert advisers, consumer groups and
charities, as well as strategic partners. We are also members
of, or signatories to, a large number of organisations, trade
bodies and frameworks that help us create long-term value
and balance the interests of stakeholders.
35
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Governance
Risk and capital management
Additional information
Financial statements
3
How we create value for our customers and society
Supporting enterprise
Creating opportunities for
businesses and enterprise
£34.6 billion
gross lending to SMEs and mid-corporates in Commercial Banking,
supporting economic growth.
£1 billion
additional funding made available to support female-led businesses
in the UK to recover from the disruption caused by COVID-19.
Building financial
capability
Helping people make
better financial decisions
470,813
(*)
additional customers helped to start to save and 6.1 million
(*)
financial
capability interactions delivered in 2021.
10 million
MoneySense has helped 10 million young people learn about
money since it was launched in 1994.
Helping to address the
climate challenge
Taking action on the risks and
opportunities of climate change
£17.5 billion
(*)
Climate and Sustainable Funding and Financing completed, including
£8.1 billion contribution towards our £100 billion target.
(1)
38%
(*)
of Retail Banking mortgages are at or above EPC rating C.
(2)
Jobs and the economy
Supporting employment across
the UK
Early career
We hired over 1,000 interns, graduates and apprentices in 2021
including 205 colleagues who have been recruited through our social
mobility apprentice programmes.
£1.73 billion
Payment of £1.73 billion in tax was made to the UK
Government in 2021 which supported central government
and local authority spending.
(3)
Protecting our
customers
Keeping money safe and
accessible for our customers
£193.3 million
(*)
We prevented 542,969 cases of attempted fraud against our customers,
amounting to over £193.3 million in the UK.
159 hotline
We are one of the original pilot organisations behind the
new ‘159’ fraud reporting hotline, launched in 2021.
Improving digital
capability
Offering customers more choice
and ways to bank
9.7 million
(*)
active digital customers. 8.3 million actively use our mobile app
and 4.2 million use our online banking platform.
60%
(*)
of our active current accounts are customers exclusively
banking with us using digital channels through mobile or online.
Community and
charitable giving
Making a difference in our
local communities
32,235 trees
planted by colleagues, in our new tree planting programme with
The Conservation Volunteers.
43,003 hours
were volunteered by our colleagues to local communities and good
causes received o
ver £3.5 million through their giving and fundraising.
Helping our colleagues
to thrive
Building a great place to work
that reflects the society we are
proud to serve
Our integrated wellbeing strategy allows us to support colleagues,
customers and communities, and is a key part of NatWest Group
being a purpose-led organisation.
+14 points
Colleague sentiment on inclusivity has continued to increase in 2021,
now reaching a score of 93 percentage points. We are 14 percentage
points above the Global Financial Services Norm and 10 percentage
points above the Global High Performing Norm.
Homes and housing
Helping more people access
efficient homes
£728 million
(*)
Retail Banking Green Mortgage
completions.
(4)
Over 48,000
We have supported more than
48,000 customers with first-time mortgages.
(*)
262,000
customers were helped with mortgage
payment holidays between 2020 and 2021
due to the challenges caused by COVID-19.
Supporting customers at
every stage of their lives
Simple to
deal with
Sharpened
capital allocation
Powered by innovation and
partnerships
Purpose-led and integrated value creation
continued
36
NatWest Group
2021 Annual Report and Accounts
How we create value for our customers and society
Supporting enterprise
Creating opportunities for
businesses and enterprise
£34.6 billion
gross lending to SMEs and mid-corporates in Commercial Banking,
supporting economic growth.
£1 billion
additional funding made available to support female-led businesses
in the UK to recover from the disruption caused by COVID-19.
Building financial
capability
Helping people make
better financial decisions
470,813
(*)
additional customers helped to start to save and 6.1 million
(*)
financial
capability interactions delivered in 2021.
10 million
MoneySense has helped 10 million young people learn about
money since it was launched in 1994.
Helping to address the
climate challenge
Taking action on the risks and
opportunities of climate change
£17.5 billion
(*)
Climate and Sustainable Funding and Financing completed, including
£8.1 billion contribution towards our £100 billion target.
(1)
38%
(*)
of Retail Banking mortgages are at or above EPC rating C.
(2)
Jobs and the economy
Supporting employment across
the UK
Early career
We hired over 1,000 interns, graduates and apprentices in 2021
including 205 colleagues who have been recruited through our social
mobility apprentice programmes.
£1.73 billion
Payment of £1.73 billion in tax was made to the UK
Government in 2021 which supported central government
and local authority spending.
(3)
Protecting our
customers
Keeping money safe and
accessible for our customers
£193.3 million
(*)
We prevented 542,969 cases of attempted fraud against our customers,
amounting to over £193.3 million in the UK.
159 hotline
We are one of the original pilot organisations behind the
new ‘159’ fraud reporting hotline, launched in 2021.
Improving digital
capability
Offering customers more choice
and ways to bank
9.7 million
(*)
active digital customers. 8.3 million actively use our mobile app
and 4.2 million use our online banking platform.
60%
(*)
of our active current accounts are customers exclusively
banking with us using digital channels through mobile or online.
Community and
charitable giving
Making a difference in our
local communities
32,235 trees
planted by colleagues, in our new tree planting programme with
The Conservation Volunteers.
43,003 hours
were volunteered by our colleagues to local communities and good
causes received o
ver £3.5 million through their giving and fundraising.
Helping our colleagues
to thrive
Building a great place to work
that reflects the society we are
proud to serve
Our integrated wellbeing strategy allows us to support colleagues,
customers and communities, and is a key part of NatWest Group
being a purpose-led organisation.
+14 points
Colleague sentiment on inclusivity has continued to increase in 2021,
now reaching a score of 93 percentage points. We are 14 percentage
points above the Global Financial Services Norm and 10 percentage
points above the Global High Performing Norm.
Homes and housing
Helping more people access
efficient homes
£728 million
(*)
Retail Banking Green Mortgage
completions.
(4)
Over 48,000
We have supported more than
48,000 customers with first-time mortgages.
(*)
262,000
customers were helped with mortgage
payment holidays between 2020 and 2021
due to the challenges caused by COVID-19.
Examples of how we create value
(*)
Within the scope of EY assurance. Refer to page 78.
(1)
In October 2021, having surpassed our previous 2020-21 £20 billion target during
H1 2021, NatWest Group announced an ambition to provide £100 billion climate
and sustainable funding and financing between 1 July 2021 and the end of 2025.
(2)
Percentage of £110.3 billion UK Retail Banking mortgages where EPC data is available.
2020 comparative for England and Wales mortgages only.
(3)
Comprises £787 million corporate tax, £473 million irrecoverable VAT, £126 million bank
levies, £257 million employer payroll taxes and £88 million other taxes.
(4)
Retail Banking Green Mortgage products relate only to mortgages for energy efficient
homes (EPC A or B rated) and are aligned to the World Green Building Council definition
of green mortgages, which has Pioneer status with the Green Home Finance Principles
established by the Green Finance Institute.
37
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Building a purpose-led bank
Our business
performance
Retail Banking
Through the NatWest and Royal Bank of Scotland brands
we provide a comprehensive range of banking products
and related financial services including current accounts,
mortgages, personal unsecured lending and personal deposits.
We’re here for customers whenever and wherever they need
us – from our mobile app and online banking, through to our
contact centres and high street and mobile branches.
Commercial Banking
We offer comprehensive banking and financing solutions
to start-up, SME, commercial, corporate and institutional
customers in the UK. We’re there for our customers as they
start, grow and manage their businesses. Our innovative
products and services help customers achieve their growth,
environmental and social targets. We deliver a high-quality
sales and service experience through our expertise and deep
engagement, locally, regionally and nationally through face-to-
face, direct and digital channels. We continue to support our
customers through the Brexit transition period and beyond.
Ulster Bank RoI
Since the end of July 2021 (apart from the UBIDAC asset
finance business which remains fully open), commercial
banking has been closed to new customers, remaining open
for existing customers only. Since the end of October 2021,
we have stopped accepting applications from new personal
customers, but continue to consider applications on a reduced
number of products from existing personal customers, mainly
mortgages. We continue to support our existing customers
pending further decisions on the phased withdrawal.
RBS International
As one of the largest full-service banks operating in the
local and institutional banking sectors in the Channel Islands,
Isle of Man and Gibraltar, we serve international customers
with a UK connection through our International Banking
proposition. We operate under six brands: RBS International;
NatWest International; Isle of Man Bank; Coutts Crown
Dependencies; NatWest Trustee and Depositary Services and
RBS International Depositary Services. We have wholesale
branches and fund depositary services businesses in the UK
and Luxembourg to further serve our institutional clients
and protect investors.
Private Banking
Private Banking is the Investment Centre of Expertise for
NatWest Group, servicing all client segments across Retail,
Premier & Private Banking. We provide private banking and
wealth management services to UK-connected high-net-worth
individuals and their business interests through the Coutts & Co
brand. We continue to focus on delivering the best client
experience through a proactive engagement model which
supports clients across both sides of their balance sheet –
improving returns by deepening client relationships and
enhancing our digital banking capabilities to make it easier
for clients to deal with us.
NatWest Markets
We help NatWest Group’s corporate and institutional
customers manage their financial risks safely and achieve
their short-term and long-term sustainable financial goals.
We think and act as one bank for our customers, collaborating
with teams across NatWest Group to be the partner of choice
for our customers and their financial markets needs. By
focusing on the things we do best and that matter most
to our customers, we help champion their potential.
38
NatWest Group
2021 Annual Report and Accounts
UN Principles for Responsible Banking
We have now been signatories to the UN Principles for
Responsible Banking for over two years. In 2021, we
undertook a portfolio impact analysis using the United
Nations Environment Programme Finance Initiative (UNEP FI)
developed tool, responded to the collective progress survey,
and were active in working groups on financial inclusion and
health, biodiversity, and the collective commitment on climate
action. We remain committed to aligning our strategy with
the UN Sustainable Development Goals and the 2015 Paris
Agreement and our progress against the six principles can
be found in our second self-assessment report included in
our 2021 ESG Supplement.
Human Rights and Modern Slavery
At NatWest Group, we understand that businesses have an
important role to play in promoting respect for human rights.
We seek to act in accordance with the Universal Declaration of
Human Rights and our approach to respecting human rights
is informed by other international standards and principles
including the UN Guiding Principles on Business and Human
Rights (UNGPs). We have established a human rights steering
group, a management group that brings representatives from
across NatWest Group together to coordinate our activities,
and to make recommendations to NatWest Group Executive
Committee and Board to develop and strengthen our approach.
More information can be found at natwestgroup.com.
Tackling modern slavery forms an integral part of our approach
to human rights. We seek to tackle modern slavery and human
trafficking through continued implementation of policies covering
our customers, colleagues and suppliers and by monitoring our
financing and supply chain for this activity. Our full approach is
outlined in our annual Modern Slavery and Human Trafficking
Statement which can be found at natwestgroup.com.
In 2021, we continued to engage with a range of stakeholders in
relation to human rights including charities, Non-Governmental
Organisations (NGOs) and campaign groups to help grow our
knowledge and understanding of these issues. We remained
members of the Thun Group and the UN Global Compact’s
UK Modern Slavery Working Group. We also continued to
work with anti-slavery charity Unseen to support survivors
and raise awareness of modern slavery with colleagues
throughout NatWest Group.
1.
Alignment
4. Stakeholders
2.
Impact & Target
Setting
3.
Clients &
Customers
6.
Transparency &
Accountability
5.
Governance
& Culture
Ways of Working
Re-imagining the workplace
How do you manage a never-before
moment in the world of work?
That was the question we were suddenly
posed with when COVID-19 hit. But as the
pandemic played out, we quickly started to
think beyond immediate operational requirements
to what a new way of working could look like –
considering the needs of over 58,000 colleagues
across a number of jurisdictions.
But we also knew we had a real opportunity to make
the return to the work environment different from
how it had always been: a more flexible design.
Tailored to what mattered most to our colleagues.
To get there, we adopted a robust, data and
experience-led approach. Through extensive
colleague interviews, executive engagement and
external research we started to build a picture of the
new way colleagues would like to work and interact.
Our insights quickly guided us that one size
wouldn’t fit all. And that a ‘Ways of Working’
framework designed around three models was a
flexible and dynamic way to both deliver colleague
choice and better meet customer needs.
Colleague safety, and health and wellbeing were
paramount during roll-out. To ensure this, we knew
that having a range of measures in place – from a
‘Wellbeing Hub’ and ‘Best Practices Zones’, to
working from home guides and mental health
advice – was vital.
We also realised that getting it right would take time.
So we created a feedback loop, gathering colleague
views and adapting our process. For example,
following colleague suggestions we introduced
reorientation events as well as onsite wellbeing
support to help colleagues back into the office.
We’re still on a journey, but it’s one we’re on together.
“Our insights quickly
guided us that one size
wouldn’t fit all”
39
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Business performance
Retail
Banking
In Retail Banking, we’re focused on
creating lifelong relationships with our
customers. Whether it’s providing early
financial education, helping them onto
the property ladder or building secure
financial futures, we’re there at every
stage of our customers’ lives. We are
delivering on our strategy to support
building a relationship bank for a digital
world – combining the best people and
the best technology.
By investing in world-class digital experiences which meet the
needs of our customers (from our digital banking app and AI
virtual assistant Cora, to video calling with expert advisers), we
make sure they have 24/7 access to the help and information
they need. Our focused investment in driving deeper-value
exchanges with customers while digitalising more customer
journeys and simplifying our business has resulted in a further
£52 million gross annualised cost reduction, as well as income
growth from a number of products and journeys.
We’re extremely proud of providing 30 years of free early
financial education to children through our MoneySense
programme. And we’re delighted to now evolve this further
through the acquisition of RoosterMoney in October 2021 – a
leading children’s banking app, which builds financial skills in a
fun, accessible way. We are committed to helping more young
customers with their financial capability and have seen a steady
increase in the proportion of young people choosing to bank
with us in 2021 versus pre-pandemic levels.
We have also increased the number of customers who choose
us as their main bank in 2021, reaching our highest-ever score
for customer satisfaction. We are helping all our customers
make the most of their money and achieve their goals, especially
at a time when many are facing financial difficulties. We know
that at every life stage, whether our customers have a short-
or long-term goal, saving needs to be easy and rewarding. Our
Digital Regular Saver account, alongside budgeting and goal
tools, was designed specifically to help first-time savers build
financial resilience.
(1)
We aim to address the savings gap by
helping two million customers start saving by the end of 2023;
since launch we have enabled over one million customers to
start their savings journey, including almost 471,000 in 2021.
We also conducted more than 661,000 financial health checks in
2021, of which over 350,000 were completed via video banking.
We recognise that building secure financial futures begins early
on in our customers’ lives and we are there to support them
from the start. Our digital investing platform, NatWest Invest
and Royal Bank Invest, helps our customers with their long-
term financial plans. By offering digital access to five funds
managed by Coutts, customers can plan for life’s big events
or simply invest towards securing their financial future. Nearly
33,000 retail bank customers started investing through the
platform in 2021.
When our customers are ready to step onto the property
ladder, they’re in safe hands, we have 11.5% flow share of
UK mortgages, we helped more than 48,000 customers to buy
their first home and over 40,000 customers to re-mortgage. Our
continued digitalisation of the mortgage journey means that we
can now offer customers browsing price-comparison websites
a more seamless experience; gaining a decision in principle
upfront without them having to leave the website. Through our
Green Mortgage, which we provided to around 2,900 customers
in 2021, we proactively supported customers to lower their
carbon footprint by offering discounted mortgage rates for
buying more energy efficient homes.
We are also there to support our customers with their short-
term borrowing needs and enable them to achieve their goals
sooner. We have over 3.8 million users of our ‘Know My Credit
Score’ tool, with just under 1.4 million signing up in 2021. This
helps customers better understand their credit options – and
how the decisions they make today, could affect their finances
tomorrow. We launched a new Purchase and Balance
Transfer credit card and grew credit card balances faster
than the market in the second half of the year. Our credit card
customers can also now manage large purchases more easily
by setting up an instalment plan to spread payments between
three and 24 months.
We’re always striving to make banking simpler for our
customers. We now have over eight million customers
regularly using our mobile app, which uses biometric
authentication to make the user experience secure and
convenient and 60% of our customers now interact with us
exclusively via digital channels. We’ve also launched ‘Banking
My Way’ in the app, making it easier for customers to tell us
how we can best support their needs relating to accessibility
or personal circumstances.
(1)
Active customers aged 17+ who have saved more than £100 with us for the first
time. Includes instances where customers had existing savings with other banks and
transferred them to their NatWest Group account
Total income
(£m)
4,445
2020: 4,181
Operating expenses
(£m)
(2,513)
2020: (2,540)
Operating
profit
(£m)
1,968
2020: 849
Return on equity
(%)
26.1
2020: 10.2
Net loans to customers
(£bn)
182.2
2020: 172.3
Video banking financial
health checks
350k
2020: 173k
Customers exclusively
using digital channels
(%)
60
2020: 58
Customers helped to
buy their first home
48k
2020: 32k
40
NatWest Group
2021 Annual Report and Accounts
Over the last few years, we have
significantly improved Cora’s capability
and intelligence. In 2021, Cora handled
10.7 million retail banking conversations,
up 27% on the previous year.
The AI virtual assistant also fully
supported 47% of all customer
queries without having to hand
over to a human.
Cora is now able to help customers
by providing personalised responses
to a range of different banking needs,
from providing help on how to access
the mobile app, to updating us when
they move home.
In 2021, for the first time, Cora
began assisting customers over the
phone, allowing the use of natural
conversation to self-serve.
Cora is now a key part of the
bank’s digital and telephony offering,
with a constantly evolving role in
frontline customer support. As well
as improving our service efficiency,
it also enables our colleagues to focus
on more complex customer enquiries.
We will continue to invest in the use
of innovative technologies to make it
easier for our customers to get the
support they require, when and
where it is needed.
For us, this is a vital component
of being a relationship bank for
a digital world.
“The AI virtual
assistant also fully
supported 47%
of all customer
queries without
having to
hand over
to a human.”
Cora supporting our customers
Using AI to provide that personal touch
‘Cora’ is NatWest Group’s customer-facing
AI virtual assistant, helping to provide support
for our customers using both our digital and
telephony channels.
41
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Private
Banking
We partner with our clients and their families as their wealth
needs evolve over their lifetime, ensuring that their wealth
has its intended consequences. In 2021, we launched NatWest
Group’s first digital Junior ISA, which so far has enabled over
4,000 clients to start saving for their children’s future more
easily. We continue to develop our digital capabilities and have
seen strong growth in digital sales with over 26% of net new
money now being executed through digital channels. We also
continue to meet the more complex lending and investment
needs of Coutts clients through face-to-face specialist advisers
and we welcomed a 29% increase in new Coutts clients in 2021
compared with 2020.
As a result of our collaboration with global asset manager
BlackRock, Coutts invests in a dedicated range of bespoke funds
managed and administrated by BlackRock on their platform.
Coutts set the investment strategy and ESG policy for the funds
and this relationship provides efficiency benefits for our clients.
We have also increased our ability to influence change at the
companies held within these bespoke funds to drive better ESG
outcomes, engaging with over five times more companies across
the UK, Europe and North America and voting on 79% more
company resolutions in 2021 compared with 2020. Our online
investment product series, Personal Portfolio funds, available
as NatWest Invest, Royal Bank Invest and Coutts Invest grew
significantly and more than doubled from £0.9 billion in 2020
to £1.9 billion in 2021.
Coutts collaborated with BGF Group (BGF) to launch the UK
Enterprise Fund and provide additional growth funding and
support to SMEs across the UK. The fund is co-investing
equity growth capital alongside BGF, taking minority stakes
in businesses looking to scale in the UK, with initiatives to
support female entrepreneurship and promote the diversity
of management teams. In 2021, over 100 clients invested a
combined £42 million and Coutts and BGF intend to launch
a further fund in 2022.
In November, we launched our first full-scale brand and
television campaign to increase awareness and consideration
among a new type of client: younger (35-44), female and
entrepreneurial. The campaign ‘real success takes true
character’, focused on the duality of acting in the right way
being the reason for achieving long-term success and played
into the progress we have made to become a B Corporation
and our responsible investing credentials.
In June, we started to incentivise new and existing clients
to improve the energy efficiency of their homes. We offer
discounted mortgage fees on homes with an A or B EPC ratings
and fee rebates to clients who improve their EPC rating above C
within a year of taking out their mortgage. We continue to grow
our nascent Green Mortgage book and have further plans to
help our clients understand the carbon intensity of their homes.
Coutts has been recognised by the Green Finance Institute as
a Pioneer of the UK Green Home Finance Principles.
We introduced our new Coutts mobile app to a pilot population
with a full roll out planned for 2022. We have introduced
integrated biometrics for enhanced security and easy-to-use
digital features such as first time beneficiary payment
authorisation. In app domestic payments can be completed in
one of the most efficient journeys in the UK market amongst
other notable features. The latest digital tools have enabled
clients to self-serve all disclosures during the onboarding
process, including electronic e-signatures, and enabled us
to send automated fraud alerts via SMS.
(1)
Private Banking manages assets under management portfolios on behalf of Retail
Banking and RBSI and receives a management fee in respect of providing this service.
Business performance
continued
Private Banking is the Centre of
Expertise for asset management
across NatWest Group, and in 2021 we
continued to see growth in customers
investing with us across our brands
and through various mediums, such as
digital or face-to-face. Coutts provides
our high-net-worth and ultra-high-net-
worth clients with day-to-day banking,
flexible lending and responsible
investments, underpinned by first-class
client service. In July 2021, Coutts
became a Certified B Corporation,
evidencing our commitment to
balance people, profit and the planet.
Total income
(£m)
816
2020: 763
Operating expenses
(£m)
(520)
2020: (455)
Operating profit
(£m)
350
2020: 208
Return on equity
(%)
17.0
2020: 10.3
Net loans to customers
(£bn)
18.4
2020: 17.0
AUMA
(
1)
(£bn)
35.6
2020: 32.1
Customer deposits
(£bn)
39.3
2020: 32.4
NatWest Invest/Royal
Bank Invest/Coutts
Invest users
78,890
2020: 44,410
42
NatWest Group
2021 Annual Report and Accounts
It’s a conviction woven deeply
in our history, most notably in the
philanthropic legacy of Angela Burdett-
Coutts, whose family forged the bank.
And now more than ever, we know
we have a responsibility to make a
positive difference to the world we live
in. It’s why – over two years ago – we
made the decision to aim to be part
of the ever-growing community of
Certified B Corporations.
B Corps are a new kind of business.
Ones that balance purpose and profit
– being required to consider the impact
of their decisions on their workers,
customers, suppliers, community
and the environment.
However, the journey to B Corp
certification is understandably long and
rigorous. The external accreditation
took over 18 months and involved
answering around 300 questions on
everything from company governance
and how we care for our colleagues, to
our environmental impact and what we
contribute to the community.
Most meaningfully perhaps, we also
changed our Articles of Association,
enshrining the importance of
considering all stakeholders
in our decision-making.
In July 2021, as a result of these efforts,
Coutts gained the proud distinction of
being a Certified B Corp.
Since then, we have been busy.
Coutts was a founding member of
the ‘B Finance UK Coalition’ which
was launched at COP26, and also
supported B Lab UK’s Boardroom
2030 initiative.
But for us, this is very much just
the beginning.
“For us, this is
very much just
the beginning”
Doing well by doing good
Coutts becomes a Certified B Corp
As a business, we believe we can be
a force for good.
“More than
ever, we know
we have a
responsibility to
make a positive
difference to the
world we live in.”
43
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Commercial
Banking
In 2021, we opened over 78,000 accounts for new businesses,
supported c.55,000 individuals and businesses through
c.200,000 interventions; of those supported c.52% were
purpose-led businesses, c.60% identified as female and c.26%
were from Minority Ethnic backgrounds. Further to publishing
our ‘Springboard to Sustainable Recovery’ reports in March
and October, we implemented our SME Task Force across all
our regions to focus on five areas identified with the potential
to create opportunity for SMEs tackling climate change. We
continued our support for customers through Brexit, facilitating
UK imports and exports by onboarding 27 more non-UK
suppliers to Supply Chain Finance programmes and increasing
the proportion of our lending to non-UK suppliers by 50%.
As transaction volumes recovered in the second half of 2021,
our investments in Payit and Tyl led to continued growth in
their respective customer bases. Payit became one of the
largest Open Banking-enabled ‘Payment Initiation Service’
platforms in the UK by volume and Tyl, our point-of-sale
solution for small businesses, processed its 50 millionth
transaction during 2021. Our Confirmation of Payee API also
won the first public tender with HMRC. We collaborated with
NatWest Markets to underwrite 56 new transactions, £6 billion
commitments, and improve onboarding processes enabling
customers to take advantage of our award-winning
corporate FX services.
Our strategy of collaborating with industry leaders to deliver
better customer experiences evolved at pace in 2021 with a
joint offering of charging infrastructure with Octopus, allowing
customers to understand the carbon emissions of their supply
chains and working on The Global Farm Metric with the
Sustainable Food Trust.
We gave 16,000 additional SME customers access to a
relationship manager through the launch of our new direct
relationship manager proposition. We enhanced 32 digital
sales and servicing journeys, enabling our customers to start
and complete more journeys digitally. In 2021, over 60% of
customers’ service requests were initiated digitally and
over two thirds of those were processed with no human
intervention. Our AI virtual assistant, Cora handled over
1.2 million chats, of which more than half required no
human intervention.
We continue to be disciplined in our capital allocation, allowing
us to best support the economy in line with our strategy while
maintaining a resilient balance sheet. In 2021, we embedded
our climate commitments in our capital allocation and pricing-
decision frameworks. Our new sector strategy reflects a
continued rebalancing of our balance sheet towards sectors
aligned to an economic recovery and building a fair transition
to a green economy across the regions. In 2021, we delivered
a £1.5 billion risk-weighted assets (RWA) saving from targeted
sector reductions, significant risk transfers and other active
capital management actions; improving RWA efficiency by
around 1%.
Business performance
continued
We pivoted from our leading role
supporting customers with £14.4 billion
of approved government scheme
lending through the COVID-19 crisis
to support UK businesses to grow with
£4 billion of SME-scale funding. We
grew lending in areas where we have
competitive advantage, such as climate
and sustainable funding and financing
where we delivered £5.2 billion of
lending. As a relationship bank for a
digital world, our innovations allow us
to better support our customers across
a growing number of digital channels
while simplifying and automating our
own processes.
Total income
(£m)
3,875
2020: 3,958
Operating expenses
(£m)
(2,354)
2020: (2,430)
Operating
profit/(loss)
(£m)
2,594
2020: (399)
Net loans to customers
(£bn)
101.2
2020: 108.2
Return on equity
(%)
22.0
2020: (4.5)
Tyl payments
processed
(m)
39.3
2020: 13.6
44
NatWest Group
2021 Annual Report and Accounts
“Speed of
arrangement
was crucial.
Working to short
timescales we
were able to
deliver the
contract for
the required
facility quickly.”
It’s why we place so much importance
on championing potential in those early
years. When a business has a clear
commercial opportunity, we want to
help them deliver on their ambitions.
PensionBee is a great example.
A direct-to-consumer financial
technology company and a leading
online pension provider in the UK,
it enables customers to interact with
their retirement savings through
its unique combination of smart
technology and dedicated
customer service.
We assisted PensionBee in March
2021, in the run up to its planned
IPO, with a £10 million revolving credit
facility through our innovative Growth
Capital team. Our support gave the
company that vital element of flexibility
around optimising its capital structure
to protect its cash runway.
Speed of arrangement was crucial.
Working to short timescales we were
able to deliver the contract for the
required facility quickly, providing
PensionBee with fast assurance that
liquidity would be available if needed.
The company is continuing to move
from strength to strength. Having
more than doubled its assets under
administration to £2.25 billion in the year
between September 2020 and 2021, it is
now listed on the High Growth Segment
of the main market of the London Stock
Exchange and has announced its
intention to transition to the Premium
Segment in the first half of 2022.
For us, seeing PensionBee’s success
is massively rewarding. It shows that our
support made a difference – at a time
when it was needed most.
“We want to help
them deliver on
their ambitions”
There when it counts
Championing business potential
We know it’s essential for growing businesses
to get the right kind of support at the right time.
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
RBS
International
We have continued to support our customers through life’s
changing circumstances. We helped our customers grow
their deposits, with over 500 customers (who had either never
saved with us or had previously saved less than £100 with us)
now saving at least £100. We provided 8,729 financial health
checks, of which over 21% were virtual and we removed six
different mortgage fees and launched our mortgage broker
portal to simplify our offering and support customers. We
also launched our Green Mortgage to NatWest International
customers in the UK as we support the wider climate
ambitions of NatWest Group.
Following the successful launch of Cora, our AI virtual
assistant, 63% of interactions have been completed without
the need for human intervention. RBSI’s Social Enterprise
Mentoring Scheme is also now well established and involves
partnering with a social enterprise in each retail banking
jurisdiction to share our knowledge and expertise. We have
also shared our wellbeing material, which received the
‘Wellbeing in the Workplace Star Award’ for our work
with Gibraltar Samaritans.
Partnering with four banks, RBSI will contribute £90,000 over
three years to help secure the future of Jersey’s Community
Savings Limited – a registered charity working to promote
financial inclusion.
Operating profit of £358 million was £259 million higher than
2020, primarily reflecting a £52 million impairment release
combined with income growth and cost reduction. Net loans
to customers increased by £2.2 billion, or 16.5%, and customer
deposits by £6.2 billion, or 19.8% compared with Q3 2021.
During the year, Moody’s upgraded our long-term credit
rating to A3, bringing us more in line with our peers, setting
our rating outlook to stable and affirming the short-term
credit rating at P-2; this reflects the resilience of the business
throughout the pandemic, our continued profitability and
strong balance sheet position.
In responding to changing customer demands, we introduced
cheque deposits in our mobile app among other new features
across our personal digital channels, contributing to a 23%
increase in users. Overall, 82% of local banking customers
are now registered with digital banking which is a 14%
increase compared with 2020.
Our Institutional Banking and Depositary Services business
has received significant investment as it progresses on its
digitisation journey. Customers have felt the benefits of this
and the business continues to be a driver of growth with
Climate and Sustainable Funding and Financing solutions
increasingly popular. We have worked closely with NatWest
Markets to strengthen our combined position as a trusted
partner for these clients by supporting them with a holistic
offering across products and geographies.
Business performance
continued
Our strategy of digital transformation
across the communities we operate
in remained unchanged despite the
COVID-19 pandemic. Parts of the
transformation programme were also
accelerated in recognition of rapidly
changing customer behaviours and
needs. We believe this focus on
becoming a bank that is easy to
deal with helps fulfil our purpose of
championing potential, helping people,
families and businesses to thrive.
Total income
(£m)
548
2020: 497
Operating expenses
(£m)
(242)
2020: (291)
Operating profit
(£m)
358
2020: 99
Return on equity
(%)
22.5
2020: 6.1%
Net loans to customers
(£bn)
15.5
2020: 13.3
Retail customers
registered with
digital banking
(%)
82
2020: 68
Net Promoter Score
36
2020: 30
Financial health checks
8,729
2020: 9,872
46
NatWest Group
2021 Annual Report and Accounts
“For us, this is
about fulfilling
our purpose,
being part of the
community we
live and work in”
Helping financial inclusion
RBSI in the community
Think about what it means to be outside the
financial system. To not have a bank account.
To not be able to pay bills, obtain credit or save
for the future.
The effects can be devastating,
trapping people in a vicious cycle
of poverty and financial exclusion,
unable to participate fully in society.
It’s a problem that we felt we could
(and, should) help with. So, we
decided to do something about it.
We got together with four other
local banks in Jersey to support
Community Savings Ltd – a registered
charity which works to promote
financial inclusion in Jersey by providing
services, guidance and practical
assistance to those most in need.
We know Community Savings well.
We’ve been banking the charity since
2018 and recognise the outstanding
work it does in Jersey supporting the
financial inclusion of the islanders.
Community Savings relies on grants,
donations and bequests to ensure the
continued running of its long-standing
initiative. Its customers’ money is not
used to fund its operations and it strives
to provide its services free of charge.
Over the next three years, we
are contributing £90,000 to ensure
that the charity is able to help provide
access to mainstream banking services.
For us, this is about fulfilling our
purpose, being part of the community
we live and work in. But it’s also more
than that. We look after each other here
on the island, and helping people with
financial inclusion is a big part of that.”
Lynn Cleary
Chief Financial Officer,
RBS International
47
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Business performance
continued
NatWest
Markets
We have made progress during 2021 to better support NatWest
Group’s corporate and institutional customers through refining
our global footprint and product range. We have also simplified
our operating model and leveraged expertise across the bank
to improve core processes to support cost reduction.
Our Foreign Exchange (FX) teams have worked with NatWest
Group’s Commercial, Retail and Private Banking segments
on technology and customer sales initiatives to ensure that
customers across NatWest Group benefit from our market-
leading expertise.
We collaborated across RBSI, NatWest Markets and
Commercial Banking to establish a team to grow our offering
to the investment management sector and provide a more
integrated experience for our Funds and Sponsors customers.
We continued to support our customers with their ESG and
climate-related finance needs, with product innovation across
bonds, FX, interest rate derivatives and private finance. In
2021, we completed £9.7 billion of Climate and Sustainable
Funding and Financing, including £3.3 billion which will
contribute towards the new NatWest Group target of
£100 billion between 1 July 2021 and the end of 2025.
Our support for customers has been recognised by a number
of awards:
‘Lead manager of the year, sustainability bonds – local
authority/municipality’, and ‘Lead manager of the year,
green bonds – supranational, sub-sovereign and
agency (SSAs)’, from the Environmental Finance
Bond Awards 2021.
‘Sterling Bond House of the Year’ from the IFR Awards 2020
(awarded February 2021).
‘Best Agent of International US Private Placements’ from
the GlobalCapital Private Debt Awards 2020 (awarded
February 2021).
‘Best Bank for ALM and Libor Transition Management’
from the GlobalCapital Covered Bond Awards 2021.
‘#1 bank for Overall FX Service Quality to the UK corporate
sector’ from Coalition Greenwich 2021.
We have advanced product innovation in the voluntary carbon
market by supporting NatWest Group’s collaboration with
other international banks to develop a transparent global
marketplace for carbon offsets with clear and consistent
pricing and standards known as Carbonplace. We also
progressed the development of our digital bond capability,
completing a successful pilot trade of a blockchain bond in
the secondary market.
We made significant progress on the implementation of our
agreement with BNP Paribas for the provision of house futures
and associated back-office services, and in January 2022 we
successfully went live with the outsourcing of back office
services for our US-based Listed Derivatives business.
NatWest Markets incurred an operating loss of £711 million
in 2021. A reduction in income was driven by a weak
performance in Fixed Income, reflecting subdued levels of
customer activity and the continued reshaping of the business.
This also contrasted with the exceptional levels of market
activity seen in 2020. We continued to reduce costs in line
with the strategic announcement in February 2020, with other
expenses decreasing by 12.6%. RWAs were £2.7 billion lower
than 2020 reflecting lower levels of market risk and counter-
party credit risk, including the impact of capital optimisation
actions taken throughout the year.
Note: The NatWest Markets operating segment is not the same as the NatWest Markets
Plc legal entity (NWM Plc) or group (NWM or NWM Group). The NatWest Markets
segment excludes the Central items & other segment.
We have supported our customers’
evolving needs with innovative
solutions and continued to deliver a
more integrated customer proposition
across NatWest Group. We have made
good progress on building a refocused,
sustainable business from which we
can grow. We incurred an operating
loss in 2021, but have continued to
reduce our risk-weighted assets
(RWAs) and operating expenses.
Total income
(£m)
415
2020: 1,123
Operating expenses
(£m)
(1,161)
2020: (1,310)
Operating loss
(£m)
(711)
2020: (227)
Risk-weighted assets
(£bn)
24.2
2020: 26.9
Climate and Sustainable
Funding and Financing
(£bn)
9.7
2020: 7.2
GBP-denominated DCM
volume by bookrunner
– FY 2021 Dealogic
#1
2020: #1
48
NatWest Group
2021 Annual Report and Accounts
One of the most important ways
we can do this is by helping tackle
climate change.
To build out the green infrastructure
needed to reach net-zero targets first
requires the funding and the market
mechanisms to deliver it. This is where
NatWest Markets has a vital role to play.
Following the UK Government’s
announcement of its first-ever sovereign
green bond, we supported the second
issuance of green gilts in October 2021
as joint bookrunner.
The bond, which matures in July 2053,
is the longest-dated sovereign green
bond currently outstanding in the
market. Crucially, it will help finance a
whole range of climate projects such
as offshore windfarms, zero-emission
transport and schemes to decarbonise
homes and buildings.
With these two green issuances, the
UK’s Debt Management Office has
become one of the top three largest
sovereign issuers of green bonds in
the world.
NatWest Markets is proud to be part of
this process, and to have helped deliver
on the government’s commitment to
issue a minimum of £15 billion of
green gilts in 2021–22.
Supporting the UK
Government to tackle
climate change
NatWest Markets and green finance
Being purpose-led is about knowing and fulfilling
our responsibilities. It means delivering on our
commitments to our stakeholders, society and
the environment.
“NatWest Markets
is proud to have
helped deliver on
the government’s
commitment to
issue a minimum
of £15 billion
of green gilts
in 2021–22”
49
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Ulster Bank
Rol
During 2021, we entered into binding agreements for the
sale of material parts of our commercial and personal banking
businesses with Allied Irish Banks p.l.c. (AIB) and Permanent
TSB p.l.c. (PTSB), which subject to regulatory and other
approvals and other conditions being satisfied, are
expected to be completed during 2022 and 2023.
Since the end of July 2021, (apart from the UBIDAC asset
finance business), commercial banking has been closed to
new customers, remaining open for existing customers only.
Since the end of October 2021, we have stopped accepting
applications from new personal customers, but continue to
consider applications on a reduced number of products
from existing personal customers, mainly mortgages.
We have focused on effective and timely communications,
engaging with all customers impacted by the loan sales and
launched the ‘Choose, Move & Close’ readiness campaign
designed to give personal customers, especially those in
vulnerable situations, as much notice as possible of the steps
they will be required to take to move the products they hold
with us that are not already covered by the sale agreements.
This readiness campaign is an important step in our closure,
not just for customers but for the industry too, as we work
together to ensure the safe transition of customers to their
new providers. With this in mind, we are engaging with the
rest of the industry within the bounds of competition law, to
allow them time to prepare for the volume of customers who
will need to move or switch accounts. We are also engaging
with the main direct debit originators and large employers
to provide advance notice of the changes to allow them time
to prepare to help their own customers and employees who
will be switching accounts.
In July 2021, we launched our Customer Charter, a set
of principles developed from our colleagues’ ideas and
suggestions for how we best serve customers and the
communities in which we operate throughout the withdrawal
process. This includes helping customers in vulnerable
situations to close or move their accounts, continuing to
provide financial education to customers and donating
surplus office furniture to local communities and charities.
Following the announcement of the phased withdrawal,
our focus on colleague wellbeing has been a key priority.
Listening sessions were held to answer questions and keep our
colleagues informed. We also invested significantly in learning
and development to support colleagues, which has included
one-to-one career coaching sessions and career development
focus workshops.
Following the announcement to
begin a phased withdrawal from the
Republic of Ireland, we have made
progress to develop and implement
a plan which acts in the best interests
of customers, colleagues and
stakeholders. Our focus is to support
customers and colleagues now and
help them to prepare for the future.
Continuing operations
Total income
(€m)
265
2020: 250
Operating expenses
(€m)
(557)
2020: (498)
Total income
(€m)
578
2020: 574
Operating expenses
(€m)
(609)
2020: (548)
Net loans to customers
(€bn)
7.9
2020: 20.0
Operating loss
(€m)
(259)
2020: (405)
Net loans to customers
(€bn)
18.6
2020: 20.0
Operating profit/(loss)
(€m)
68
2020: (255)
Business performance
continued
The results above are presented for continuing operations.
For further details on the treatment of discontinued operations
refer to Note 8 to the consolidated financial statements.
Total including discontinued operations
50
NatWest Group
2021 Annual Report and Accounts
Outlook
Outlook.
The economic outlook remains uncertain. We will monitor and react to market conditions and refine our internal
forecasts as the economic position evolves. The following statements are based on current market interest rate
and economic expectations.
In 2023, we expect to achieve a return on tangible equity of comfortably above 10% for the Group.
In 2022, we expect income excluding notable items to be above £11.0bn in the Go-forward group.
We plan to invest around £3 billion over 2021 to 2023 but, with continuing simplification, we plan to reduce
Go-forward group operating expenses, excluding litigation and conduct costs, by around 3% in both 2022
and 2023.
As a result of positive actions to change the shape of our book in recent years, we expect our through-the-cycle
impairment loss rate to be around 20 – 30 basis points. We expect our 2022 and 2023 impairment charge to be
lower than our through the cycle loss rate.
Across 2022 and 2023, we expect movements in RWAs to largely reflect lending growth and our phased
withdrawal from the Republic of Ireland.
Capital and funding
We aim to end 2022 with a CET1 ratio of around 14% and target a ratio of 13-14% by 2023.
We intend to maintain ordinary dividends of around 40% of attributable profit and to distribute a minimum of
£1 billion in each of 2022 and 2023 via a combination of ordinary and special dividends.
We intend to maintain capacity to participate in directed buybacks of the UK Government stake, recognising that
any exercise of this authority would be dependent upon HMT’s intentions and is limited to 4.99% of issued share
capital in any 12-month period.
We will consider further on-market buybacks, in addition to the £750 million announced today, as part of our
overall capital distribution approach as well as inorganic opportunities provided they are consistent with our
strategy and have a strong shareholder value case.
As part of the NatWest Group capital and funding plans we intend to issue between £3 billion to £5 billion
of MREL-compliant instruments in 2022, with a continued focus on issuance under our Green, Social and
Sustainability Bond Framework. NatWest Markets plc’s funding plan targets £4 billion to £5 billion of public
benchmark issuance.
Ulster Bank RoI
We have made good progress on our phased withdrawal from the Republic of Ireland and expect the majority of
the Allied Irish Banks and Permanent TSB asset sales to be largely complete by the end of 2022 and deposits to
reduce over a longer timescale.
We would expect income and RWAs to follow the balance sheet trajectory. We expect the cost base to reduce
over time and anticipate other operating expenses, excluding withdrawal related costs, in 2023 will be around
€200 million lower than 2021.
We expect to incur disposal losses through income of around €300 million in 2022 and withdrawal related costs
of around €600 million across 2022-24, with around €500 million incurred by the end of 2023.
We expect the phased withdrawal to be capital accretive.
(1)
The guidance, targets, expectations and trends discussed in this section represent NatWest Group plc management’s current expectations and are subject to change, including as a
result of the factors described in the Risk Factors section on pages 406 to 426 of the 2021 NatWest Group plc Annual Report and Accounts and on pages 179 to 201 of the NatWest
Markets Plc 2021 Annual Report and Accounts These statements constitute forward-looking statements. Refer to Forward-looking statements in this document.
51
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Section 172(1)
statement
In this statement we describe how
our directors have had regard to the
matters set out in section 172(1) (a) to
(f) of the Companies Act 2006 (section
172) when performing their duty to
promote the success of the company.
Board engagement with stakeholders
The Board reviews and confirms its key stakeholder groups
for the purposes of section 172 annually. For 2021, they
remained customers, colleagues, communities, investors,
regulators and suppliers. Examples of how the Board has
engaged with key stakeholders, including the impact on
principal decisions, can be found in this statement and on
pages 14 to 17 (stakeholder engagement) and pages 102
to 113 (Corporate governance report).
Supporting effective Board discussions
and decision-making
Our purpose continues to influence Board discussions
and decision-making.
Our Board and Committee terms of reference reinforce the
importance of considering both our purpose and the matters
set out in section 172. Our Board and Committee paper
template includes a section for authors to explain how the
proposal or update aligns with our purpose and a separate
section for them to include an assessment of the relevant
stakeholder impacts for the directors to consider.
Our directors are mindful that it is not always possible to
achieve an outcome which meets the requirements, needs
and/or expectations of all stakeholders who are, or may be,
impacted. For decisions which are particularly challenging
or complex, we introduced an additional page to our paper
template in 2021 which provides directors with further
information to support purposeful decision-making. This
additional page uses the Blueprint for Better Business as
a base and is aligned to our broader purpose framework.
Principal decisions
Principal decisions are those decisions taken by the Board
that are material, or of strategic importance, to the company,
or are significant to NatWest Group’s key stakeholders.
This statement describes three examples of principal
decisions taken by the Board during 2021.
Likely long-term consequences.
Employee interests.
Relationships with customers, suppliers and others.
The impact on community and environment.
Maintaining a reputation for high standards of business
conduct.
Acting fairly between members of the company.
Section 172(1) statement
Withdrawing from the
Republic of Ireland
What was the decision-making process?
In February 2021, the Board took the decision to commence
a phased withdrawal from the Republic of Ireland. This was a
very carefully considered decision by the Board that followed a
strategic review of the Ulster Bank business in the Republic of
Ireland, which concluded that Ulster Bank Ireland Designated
Activity Company (UBIDAC) would not be able to generate
sustainable long-term returns for NatWest Group plc’s
shareholders. Alongside the decision to withdraw, it was
announced that a non-binding Memorandum of Understanding
with Allied Irish Banks, p.l.c had been entered into in connection
with the sale of a portion of UBIDAC’s performing commercial
loan book.
To support the Board in its decision-making, it received
comprehensive papers prepared by management which
updated the Board on the progress of each stage of the
strategic review and sought the Board’s support to proceed to
the next stage. These papers included detailed analysis of the
potential options available to execute the withdrawal (including
potential counterparties and transactions), valuations, financial
impacts, key risks, and stakeholder impacts and engagement
plans. During its discussions, the Board acknowledged the
complexity and challenges of a withdrawal and the various
options were explored through the lenses of time, value,
execution risk and stakeholder impacts.
How did the directors fulfil their duties under section
172? How were stakeholder interests considered?
At each stage of the strategic review the directors were
mindful of their duties under section 172 including the likely
long-term consequences of the decision. Each update the
Board received provided an overview of relevant stakeholder
considerations. The Board discussed in detail the various
stakeholders that would be impacted (including shareholders,
employees, customers, suppliers, regulators and communities),
what their concerns were likely to be and the key messages
that would support engagement. The Chairman and Group
CEO undertook engagement directly with key stakeholders and
reported back to the Board on their discussions. The UBIDAC
CEO also attended each meeting at which the strategic review
was discussed to provide direct feedback to the Board on
stakeholder concerns and considerations.
How was our purpose considered as part of the decision?
Considering relevant stakeholder interests is key to purposeful
decision-making. Our new purposeful decision-making page
was used to provide the Board with a detailed analysis of
stakeholder considerations and impacts, using the Blueprint
for Better Business framework. Having taken the decision to
withdraw, the Board agreed this should be done in an orderly
manner that was considerate to customers, colleagues,
suppliers and other stakeholders.
Actions and outcomes
The Board continues to receive updates on the execution
of the withdrawal. A binding agreement was subsequently
reached with Allied Irish Banks p.l.c. on the sale of the
majority of UBIDAC’s performing commercial lending portfolio.
Factors considered:
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NatWest Group
2021 Annual Report and Accounts
Approving capital
distributions
Approving our
refreshed values
What was the decision-making process?
During 2021, the Board recommended a final dividend, agreed
to participate in a directed buyback of ordinary shares from
Her Majesty’s Treasury, approved an interim dividend and
agreed to commence an on-market buyback of ordinary
shares, as well as providing outlook guidance to investors
on capital distributions.
The Board’s decisions were informed by the 2021 capital
distribution plans as well as regular updates on NatWest Group
plc’s financial and capital positions. A key focus of Board-level
discussions was how surplus capital was being managed.
The Group Board Risk Committee also reviewed all capital
distributions proposals in advance of Board consideration,
and recommended them to the Board for approval.
How did the directors fulfil their duties under section
172? How were stakeholder interests considered?
Again, in taking decisions, the directors were mindful of
their duties under section 172. For the dividend decisions the
directors were particularly focused on whether the declaration
of a dividend would support the long-term sustainable success
of the company. The Board also sought advice from NatWest
Group plc’s corporate brokers on investor expectations in
respect of the outlook guidance.
How was our purpose considered as part of the decision?
The Board is aware that in taking decisions on capital
distributions, it also needs to consider the financial implications
of those decisions in terms of continuing to support customers
and maintaining financial stability.
Actions and outcomes
The final dividend of 3 pence per ordinary share was approved
by shareholders at the Annual General Meeting in April 2021
and an interim dividend of 3 pence per ordinary share was
approved by the Board in July 2021.
The outlook guidance on capital distributions was announced
as part of the 2020 annual results in February 2021. It stated
that, subject to market conditions, the company intended to
maintain ordinary dividends of around 40% of attributable
profit and aimed to distribute a minimum of £800 million per
annum from 2021 to 2023 via a combination of ordinary and
special dividends. This was updated by the Board in July 2021
which increased the outlook guidance for capital distributions
from £800 million to £1 billion for 2021 and future periods
(again subject to market conditions).
In March 2021, the company participated in a directed
buyback of ordinary shares from Her Majesty’s Treasury and
in July 2021 the Board agreed to commence an on-market
buyback of ordinary shares, further reducing the UK
Government’s shareholding in NatWest Group plc.
What was the decision-making process?
In July 2021, the Board received an update on the work being
undertaken to refresh our values and the related behavioural
framework to provide greater alignment to our purpose and
strategy. At that time, the Board confirmed its support for the
refresh and noted that the final proposal would be brought
back to the Board for approval.
In December 2021, the Board was presented with detailed
proposals from management seeking approval for the
recommended refreshed values and behaviours. The paper
explained the behavioural science and data-led approach that
had been adopted and the range of stakeholders that had
been engaged. The paper also set out the first draft of the
people proposition that would be aligned to the refreshed
values. The Board discussed the proposals and provided
positive feedback on both the approach taken and the
refreshed values.
How did the directors fulfil their duties under section
172? How were stakeholder interests considered?
The paper explained very clearly the stakeholder engagement
that had been undertaken in developing the refreshed values
and the draft people proposition, both in terms of the stakeholder
groups consulted (which included colleagues, customers and
communities) and the methods of engagement used (such as
interviews with senior executives, workshops, focus groups,
digital surveys, external partner review by Blueprint for Better
Business and virtual engagement). A stakeholder overview also
set out stakeholder impacts and a number of Board members
provided direct input and feedback as part of the stakeholder
engagement process. Colleagues were, understandably, the
key focus of the Board’s discussions.
How was our purpose considered as part of
the decision?
The refresh of our values was undertaken to provide greater
alignment with our purpose and strategy and the Board
acknowledged this as part of its discussions.
Actions and outcomes
The Board approved the refreshed values in December 2021
and noted the intention to launch them to colleagues,
customers and communities in 2022.
Factors considered:
Factors considered:
“The Board knows how important it is
to engage with our stakeholders, to
listen to them and to consider their
interests during Board discussions and
decision-making. Understanding the
needs of our stakeholders is at the
core of our purpose framework.”
Howard Davies,
Chairman
53
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2021 Annual Report and Accounts
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Financial review
Governance
Risk and capital management
Additional information
Financial statements
Listening and responding to our customers
We want to know what our customers think about
us. It helps us better understand their needs and
improve the products and services we offer.
To achieve this, we have in place a framework of independent
customer feedback surveys that measure satisfaction across
our business segments. In terms of customer advocacy in 2021,
Net Promoter Scores (NPS) for Retail Banking improved by
six points for NatWest and seven points for Royal Bank of
Scotland. Business Banking NPS remained flat. In Commercial
Banking NPS declined by two points for NatWest and six points
for Royal Bank of Scotland. Refer to page 56 for the full
breakdown of scores.
The insight from these surveys is reported at the most senior
levels of the bank and plays a crucial role in how we address
the evolving requirements of our customers. In 2021, we
responded to customer feedback with a range of
innovative solutions.
Stakeholder focus areas
Customers
Customer trust
NatWest
74%
Q4 2021
76%
Q4 2020
Royal Bank
of Scotland
68%
Q4 2021
61%
Q4 2020
Source: Yonder reputation tracker, GB, trust amongst Retail Banking customers
Listening, engaging and
partnering with our stakeholders
is vital for the success of our
business. It helps us to address
our operational impacts
and improve outcomes for
customers, society and the
environment. In the following
sections we detail some of the
notable steps we have taken
to respond to our stakeholders’
changing requirements
during 2021.
So that customers can settle payments easily between family
and friends (without the need to share account details or hold
cash), we launched ‘PayMe’. This service uses Payit, our Open
Banking Payments solution, to request a payment from anyone
who uses online or mobile banking and has a participating UK
Bank account. Payment can be made via a link or QR code,
which can be scanned by any device with a camera.
Our approach to Open Banking and the innovative use of
data has also created opportunities for reusing services and
capabilities across NatWest Group products, making it simpler
and quicker to develop and deploy them to our customers.
For example, through Tyl, Payit and Mettle we will be able to
offer a seamless, one-bank payments proposition, delivering
personalised, smart insights for businesses so they can track
sales, target customers and grow loyalty.
Elsewhere, a new feature launched in 2021 in the mobile
banking app to enable our retail and commercial customers
to deposit cheques has swiftly become one of the app’s
most used features – testament to both the demand for,
and usability of the function. For our Commercial Banking
customers, we also enhanced our digital platform offering
‘Bankline’, with new and improved functionality within
the service.
Making banking more accessible
We recognise that our customers’ individual needs are all
different. As such, we aim to make banking as accessible
as possible for everyone, offering our customers the ability
to choose from a variety of face-to-face, digital and
remote options.
We have more than 800 branches and 16,000 physical points
of presence, including our ATM network and our relationship
with the Post Office, which remain an important part of how
we deliver services to our customers and communities.
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2021 Annual Report and Accounts
Customers can now also take greater digital control of
their finances through our mobile app, including the ability
to open an account, check their credit score and apply for a
mortgage. Our app is compatible with both Apple and Android
accessibility features such as inverting colours and magnifiers,
as well as biometric log-ins. We have also introduced a dark/
light mode for customers with visual impairments or dyslexia.
Our AI virtual assistant, Cora supports customers via the
‘message us’ feature in the app, and our contact centre
colleagues are just a click away with the ‘tap to call’ function.
When our customers want the reassurance of a face-to-face
conversation remotely, our video banking service is available.
We offer customers who require additional support a range of
accessibility services, such as accessible statements in braille,
large print and audio CD. BT’s Relay UK service also supports
customers with hearing impairments through a type-to-talk
service, while accessible card readers, rubber signature
stamps, braille card wallets and our talking ATM service
are other key accessibility features.
Combating financial crime
Detecting and preventing financial crime to protect people,
families and businesses is a key priority for NatWest Group.
Along with other major banks and telecoms companies, we
participated in a pilot scheme to introduce a hotline to help
fight fraud across the industry and protect our customers
from fraud and scams.
Spearheaded by Stop Scams UK (SSUK), the phone
number ‘159’ is designed to disrupt scams in which victims
have been contacted or engaged by a scammer via phishing or
impersonation. The number works by encouraging customers
experiencing suspected fraud to stop, hang up and call 159,
at which point they are directed to their bank.
Supporting customers in vulnerable situations
At any time, a customer may find themselves either in a
vulnerable situation or caring for a loved one experiencing a
vulnerability. The continuing impact of COVID-19 has meant
that for many of our customers this was a reality in 2021. Our
dedicated customer care line, which was set up in response to
the pandemic, has continued to support a significant number of
our customers in 2021. Our support service ‘Banking My Way’
continues to develop, with customers now able to tell us about
the support they need by updating their details in the new
mobile app function.
In 2021, we continued to work with organisations such
as ‘GamCare’ and the ‘Money Advice Trust’ to improve
the support available to customers in vulnerable situations,
connecting them to expert advice where appropriate. We also
significantly expanded our referral programme with Citizens
Advice, connecting customers to their advisers where we
identify additional advice or vulnerability needs. In February
2021, with the domestic abuse charity SafeLives, we launched
The Circle Fund. The Circle Fund, available for three years,
supports SafeLives to provide small grants to help economic
abuse victims and survivors to regain financial confidence
and control. This follows from our announcement to donate
£1 million for the fund in 2020.
We know how important our branches are
to our customers. But we also know that the
ways in which our customers live, work and
bank have altered dramatically in the past
two years. To meet these changing needs
and to help people, families and businesses
to rebuild and thrive, we plan to turn our
branches into sustainable local banking hubs.
We want to provide our customers a space in the
heart of our high streets with a range of specialist
services, venturing beyond traditional banking to
help break down barriers to enterprise and increase
financial capability. Our Broadmead Bristol hub,
which opened earlier in 2021, is the first example
of this.
Within the hubs, retail customers are able to
connect face-to-face and learn more about financial
education and how to best manage their money,
and businesses can access expert advice and
collaboration spaces. The hubs will also include
enterprise zones, where potential and current
customers can liaise with local enterprise managers
and other specialists with access to initiatives such as
‘Women in Business’ or our ‘Accelerator’ programme.
Among the other features are: dedicated events
and learning spaces, which can also be used by
local charities or community groups; customer hot
desks offering free Wi-Fi; private consultation rooms,
where we can provide confidential assistance to
customers both face to face and digitally; and
self-service areas with colleague assistance to
support people with simple banking transactions
quickly and conveniently.
And from listening to our customers, we understand
that managing the environmental impact of the
space is vital. To help reduce waste and promote
sustainability, we’ve incorporated recycled furniture,
included water bottle refill stations for customers
and removed paper marketing materials. We’ll
also measure the climate impact of our new
local banking hubs through the SKA and Energy
Performance Certificate (EPC) assessments.
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2021 Annual Report and Accounts
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Financial review
Governance
Risk and capital management
Additional information
Financial statements
Account opening
Q4 2021
28
Q4 2021
14
Q4 2021
45
Q4 2021
25
Q4 2021
78
Dec 2021
74%
Q4 2021
37
Dec 2021
68%
Q4 2020
16
Q4 2020
16
Q4 2020
44
Q4 2020
22
Q4 2020
76
Dec 2020
76%
Q4 2020
32
Dec 2020
61%
Source: Strategic NPS benchmarking study run
through InMoment
Source: Strategic NPS benchmarking study run
through InMoment
Source: Strategic NPS benchmarking study run
through InMoment
Source: Strategic NPS benchmarking study run
through InMoment
Source: Operational NPS study run
through InMoment
Source: Yonder reputation tracker, GB,
Trust among Retail Banking customers
Source: Operational NPS study run
through InMoment
Source: Yonder reputation tracker, GB,
Trust among Retail Banking customers
Lending
NatWest
Mortgage
Day-to-day servicing
Royal Bank of Scotland
Mobile Banking
Online Banking
Retail Banking
Business and Commercial Banking
Customer Trust
Stakeholder focus areas
continued
Overall NPS
NatWest
Royal Bank of Scotland
Business
Q4 2021
-2
Q4 2021
-12
Q4 2020
-2
Source: MarketVue
Business Banking from
Savanta, England &
Wales, businesses with
a turnover up to £2m
Q4 2020
-13
Source: MarketVue
Business Banking from
Savanta, Scotland,
businesses with a
turnover up to £2m
Q4 2021
22
Q4 2021
21
Q4 2020
24
Source: MarketVue
Business Banking from
Savanta, England &
Wales, businesses with
a turnover up to £2m
Q4 2020
27
Source: MarketVue
Business Banking from
Savanta, Scotland,
businesses with a
turnover over £2m
Commercial
Banking:
Retail
Q4 2021
13
Q4 2020
7
Source: Strategic NPS
benchmarking study run
through InMoment,
England & Wales
Q4 2021
-2
Q4 2020
-9
Source: Strategic NPS
benchmarking study run
through InMoment,
Scotland
Customers
continued
Our brands are our main connection with customers. We track customer advocacy for our key brands and services using the Net
Promoter Score (NPS), a commonly used metric in banking and other industries across the world.
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Investors
Transparency and engagement
Private investors
We engaged with our private investors through
our Annual General Meeting (AGM), virtual
shareholder events, and our annual and
strategic report communications.
In light of ongoing restrictions related to the COVID-19
pandemic, investors were not be able to attend the 2021
AGM in person. However, we held a live virtual shareholder
event a week prior to the AGM. Investors were invited to
submit questions either in advance of, or during, the virtual
event and the answers to questions on key themes were
displayed on our website.
In addition, we held two further virtual events in July and
November 2021. At these events, we spoke about the work
NatWest Group is doing to support and stimulate enterprise,
why it was so important for us to sponsor COP26 and how
tackling climate change is at the core of our purpose. These
virtual shareholder events remain a key component of our
stakeholder engagement programme and provide an
opportunity for private investors to hear from, and ask
questions of, Board members and senior management on
topics such as innovation, enterprise, sustainability and our
financial performance. It is our intention to deliver further
virtual events in 2022.
In addition, we published investor updates on the topics of
‘Championing Enterprise’ and ‘Our Purpose: Beyond COP26’.
These updates provided information on initiatives such as the
relaunch of our enterprise programme, the additional £1 billion
in funding to help support female-led businesses in the UK
recover from the pandemic, the introduction of our carbon
footprint tracker for our mobile app and our launch of the
UK’s first carbon-neutral podcast. Our investor updates and
recordings of our virtual events can be found on our website.
Institutional investors
We have a well-established programme of engagement
with our institutional investors. The financial year begins
with a presentation on our annual results in February, hosted
by our Chairman, CEO and CFO. This live event includes an
interactive Q&A session to give research analysts and investors
an opportunity to ask questions and engage with our
management team. We then follow up quarterly with
presentations to the market when we announce each set of
financial results in April, July and October. While these events
could not be held face to face in 2021, we were able to host
a live presentation and Q&A session via Zoom, enabling the
same level of interaction in a virtual forum.
In addition to the quarterly results presentations, we hosted a
programme of virtual one-to-one and group meetings with
institutional investors from around the world. Across our
management team, we hosted over 250 meetings with
investors covering key topics such as progress against our
financial targets, strategic priorities, innovation, ESG and
industry challenges. While the total number of one-to-one
meetings was lower than the prior year when we saw an
unusually heightened demand for time with management due
to the pandemic, our CEO and CFO engaged regularly with UK
Government Investments and our largest active institutional
investors throughout the year.
To enhance our investor relations programme during a
challenging time when we were unable to meet face to face,
we hosted a series of ‘Meet the Exco’ and business spotlight
presentations via Zoom. These events gave analysts and
investors the opportunity to hear from key members of our
executive team as they discussed their priorities for the year
ahead and to ask questions live over Zoom.
Environmental, Social and Governance (ESG) issues were
regularly discussed at our one-to-one meetings and we also
engaged with specialist socially responsible investors through
a programme of meetings with ESG analysts from institutional
investors, presentations at ESG-focused conferences and
increased interactions with sustainability rating agencies.
Alongside the virtual shareholder events mentioned above,
members of our Board hosted a live virtual corporate
governance forum. This gave investors the opportunity to hear
an update on Board priorities in 2021 and the opportunity for
a discussion on corporate governance topics directly with our
non-executive directors.
A key development in terms of the transparency of our
business during 2021 was the enhancement of two key
areas of our non-financial reporting. In recognition that
climate change is a critical global issue which has significant
implications for our investors (as well as our customers,
employees, suppliers and partners), we produced our first
standalone Climate-related Disclosures Report in February
2021. This comprehensive document was a material step
towards alignment with the Financial Stability Board’s Task
Force on Climate-related Financial Disclosures (TCFD)
recommendations and recommended disclosures. The report
covered our climate strategy and associated ambitions,
governance, scenario analysis, risk management and
climate-related metrics.
We also produced our first Environmental, Social and
Governance Supplement – providing investors and other
stakeholders with a deeper understanding of the work that
we are doing to understand and manage issues facing our
business, customers, communities and society as a whole.
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Governance
Risk and capital management
Additional information
Financial statements
Colleagues
Helping our colleagues to thrive
We want NatWest Group to be a great place
to work. By offering a fulfilling job, a healthy
workplace, fair rewards, excellent development
and great leadership, we believe together our
colleagues can thrive and unlock the full potential
of NatWest Group.
Our People Pledge sets out commitments and initiatives in
direct response to what colleagues tell us is important to help
them in their jobs. Throughout 2021, we have worked with
colleagues to champion their potential across all five parts
of the pledge: ‘Help you develop your skills’; ‘Support your
wellbeing’; ‘Help customers thrive’; ‘Create inclusive and
connected teams’; and ‘Help you make a difference’.
The pandemic has drastically altered how we work and has
changed (perhaps forever) the relationship between employers
and employees. We listen to our colleagues and use this insight
to attract, engage and retain the best talent for the future. Our
colleague listening strategy – which includes: our colleague
opinion surveys; a Colleague Advisory Panel (CAP) that
connects colleagues directly with our Board; the ‘Colleague
Experience Squad’, a group of colleagues who volunteer to
provide feedback on colleague products and services; and
Workplace, our social media platform – contributes to our
deeper understanding of colleague sentiment. We also track
metrics and key performance indicators which we can
benchmark with sector and high-performing comparisons.
Over 46,700 colleagues (81%) participated in our September
2021 Our View survey. The results showed that colleague
sentiment remains strong, despite the pandemic. Lead
measures in culture, purpose, inclusion and building capability
showed a continued and sustained year-on-year improvement
(+1 percentage point each). Across all 15 measured categories,
NatWest Group sits an average of 11 percentage points above
the Global Financial Services Norm (GFSN) and five percentage
points above the Global High Performance Norm (GHPN).
(1)
Regular interactions with our employee representatives such
as trade unions, elected employee bodies and works councils
are a vital means of transparency and engagement for us.
We frequently use these sessions to discuss developments
and updates on the progress of our strategic priorities. In 2021,
topics included ‘ways of working’ and ‘health and safety in the
context of the pandemic’. We are also committed to respecting
our employees’ rights of freedom of association across all our
business. In addition, our CAP was set up in 2018 to help
promote colleague voices in the boardroom.
For full
details, refer to the Corporate governance report
and ESG Supplement.
Performance and reward
Our approach to performance management provides clarity for
our colleagues on how their contribution links to our purpose,
with all colleagues set performance goals across a balanced
scorecard of measures. We continue to ensure employees are
paid fairly for the work they do and are supported by simple and
transparent pay structures in line with industry best practices.
We keep our policies and processes under review to ensure we
do so. In general, the scores from the reward category in Our
View declined since 2020, although in all but one category they
remain above the GFSN. We will be looking to address this,
subject to performance, in 2022.
In the UK, our rates of pay continue to exceed the Living Wage
Foundation benchmarks and we ensure employees performing
the same roles are paid fairly. We ensure colleagues have an
awareness of financial and economic factors affecting our
performance through quarterly ‘Results Explained’
communications and ‘Workplace Live’ events with our Group
Chief Executive Officer and Group Chief Financial Officer.
Refer to our Directors’ remuneration report for full details
on our remuneration policies and employee share plans.
Helping colleagues realise their potential
At NatWest Group, we exist to champion potential and help
people, families, and businesses to thrive – helping them at
every stage of their lives. We’ll achieve our ambition to be a
relationship bank for a digital world by working together as
one team, across NatWest Group. Investing in our workforce in
a variety of ways helps us achieve that. To support this, we’re
building a learning organisation that tests ideas and learns
every day – helping colleagues develop the capabilities to
stay relevant and employable for the future.
The COVID-19 pandemic has accelerated the pace of change,
and it is likely that predictions made for 5-10 years’ time –
working seamlessly alongside robotics, smarter uses of AI
and collaboration across organisations and boundaries – will
become the norm more quickly. This will have a significant
impact on how people work and the capabilities they will
need to thrive in this new world.
At NatWest Group, we believe that we have an obligation to
help build skills across our industry. Working with the Financial
Services Skills Commission, we led the build of an industry-
wide skills framework that is available via an online tool to all
financial services organisations in the UK. Its purpose is to
create a consistent language around skills across the industry
– which in turn will support mobility and is in line with our
commitment to support wider communities.
In 2021, we provided all colleagues with access to build future
skills through the NatWest Group Learning Academy, bringing
together learning opportunities and curated content into a
single place. This supports our commitment for all colleagues
to be upskilled in future-focused skills by 2025. Around 80% of
colleagues have used it since it launched in 2020 and, in 2021,
we’ve offered new topics including cybersecurity and innovation.
It has helped us to increase colleague learning completions
by 10%, with our target (aligned to the UN Sustainable
Development Goals) to increase them by 50% at the end
of 2023.
As well as increasing our colleagues’ learning and
development, we’re also focused on ensuring that it’s the right
kind. We have made a commitment that half of all learning at
NatWest Group is focused on building critical skills for the
future. We have prioritised data and digital capability and have
given our colleagues access to a range of opportunities to build
these skills through the NatWest Group Academy. Early
Stakeholder focus areas
continued
(1)
NatWest Group Our View results exclude Ulster Bank RoI.
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2021 Annual Report and Accounts
Supporting our colleagues’ wellbeing
To be part of NatWest Group means being part of
something bigger than ourselves, where the strength
of our culture underpins everything we do; an
organisation where we all learn, grow, thrive and
support each other. A vital part of this is having a
fully embedded wellbeing strategy; refer to our ESG
Supplement for full details.
progress is positive with data learning up 134% and digital
learning up 31%. We also continue to invest in our people to do
their job, with 99.6% of our front-line colleagues professionally
accredited within their first 18 months in role.
We are committed to reskilling colleagues whenever possible.
The Mobility Hub supports with redeploying colleagues and
reskilling them for future work. In 2021, we commenced our
first formal reskill programme, with 20 colleagues who were at
risk of redundancy taking the opportunity to reskill as software
engineers. Of these, 17 accepted permanent positions.
In 2021, we launched our global Talent Academy to help
identify and develop colleagues with high potential through
a programme of challenging and purposeful development
opportunities. For the first time, colleagues were encouraged
to self-nominate regardless of role, level, working pattern
and location. Following a robust assessment process, 3,911
colleagues were accepted on to the programme. The cohort
is 53% male and 47% female, and 23% of the successful
applicants come from a Black, Asian and Minority Ethnic
background, thus providing NatWest Group with a diverse
talent pipeline for the future.
As we committed to, we hired over 1,000 interns, graduates
and apprentices in 2021; including 205 colleagues who were
recruited through our social mobility apprentice programmes
and we aim to hire a further 1,100 interns, graduates and
apprentices in 2022.
We are also focusing on building our leaders’ capabilities,
which is critical to delivering our purpose-led strategy.
Our ‘Determined to Lead’ programme has helped focus
and energise our people leaders, cultivating a framework for
common leadership behaviours and practices. In addition, our
leadership, talent and career support activity is enabled by our
new Leadership and Coaching Faculty. This resource gives
our leaders access to clear thinking, relevant frameworks
and problem-solving approaches at the point of need.
Supporting this, our succession planning processes enhance
our framework to spot, develop and mobilise a diverse pool
of our most promising talent. Successors are assessed and
developed against a purpose-led profile that defines the
behaviours, traits and drivers associated with success in a
purpose-led role and organisation. Our Succession Council
gives bank ExCo successors the opportunity to engage directly
with the CEO and other ExCo members to ensure they have
the potential and aspiration to reach ExCo level. Our most
talented senior leaders are given exposure through Board &
Talent sessions with interactive sessions discussing topics
that are shaping the direction of NatWest Group.
Following the success of our first NatWest Junior Management
Team (JMT), a second cohort was selected in September 2021.
The JMT mirrors the NatWest Group Executive Committee and
brings a fresh perspective and voice to that team. They also
deliver key strategic projects to broaden their experience,
exposure and connections across NatWest Group.
Refer to our ESG Supplement for full details on how we
support colleagues to realise their potential.
Diversity, equity
and inclusion
Creating a diverse, equitable and inclusive workplace is
integral to fulfilling our purpose. It enables us to truly connect
with, and serve, our diverse customers and communities with
the products and services they need. We remain committed
to progressing our diversity, equity and inclusion strategy,
focusing on becoming gender balanced, ethnically diverse,
disability smart, LGBT+ innovative and an inclusive workplace.
Inclusive workplace
Colleague sentiment on inclusivity continued to increase
in 2021, reaching a score of 93 percentage points. We are
14 percentage points above the GFSN and 10 percentage
points above the GHPN. Although sentiment has increased
in all colleague groups, our focus is now on where scores
may vary for our minority colleague groups.
Our 2021 Inclusion Week showcased diversity, equity and
inclusion across our business. This offered time to reflect on
why we need a diverse and inclusive workplace, to celebrate
the progress we are making, and challenge ourselves to do
more. We also continued to focus on behavioural change
through new and enhanced learning modules. These include
our mandatory learning and additional optional learning (such
as ‘Choose to Challenge’, which educates colleagues on the
importance of challenging behaviours that are not inclusive).
For more details refer to our ESG Supplement.
We continued to support our employee-led networks, which
have around 24,000 members globally. These include: Gender,
Multicultural, Disability, Rainbow (LGBT+), Armed Forces,
Families & Carers, Sustainable Futures, and Aspire. In 2021,
NatWest Markets Americas’ Energized Employees Network
(and sub-networks) focused on uniting and empowering
colleagues by running several events and initiatives, including
‘One Small Step: The George Floyd Verdict’ hosted by the
Black Professional Network and ‘New Ways of Working
and the Impact on Women’ hosted by the Gender Network.
We have been listed in the ‘Working Families Benchmark Top
10 Employers’, showing that we are among those leading the
way in building a flexible, family-friendly workplace. We have
also been accredited as a ‘Good Work Standard’ employer at
Excellence (highest) level by the Mayor of London’s office.
We marked ‘South Asian Heritage Month’ with cultural
celebrations and awareness campaigns that define the diverse
cultural tapestry of our South Asian colleagues. We ran events
(such as wedding traditions across different faiths) and created
a memory wall for colleagues to share personal histories.
For the third consecutive year, NatWest Poland received the
highest score in ‘Diversity IN CHECK’ – a certification granted
to employers well advanced in managing diversity and
inclusion considerations.
References to ‘colleagues’ in this Strategic report mean all members of our workforce
(for example, contractors, agency workers).
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Financial review
Governance
Risk and capital management
Additional information
Financial statements
Gender balanced
Our Board composition exceeds the FTSE Women Leaders
target with a figure of 36% female representation. We have
female representation of 29% on our executive management
team, with a female Chief Executive Officer, Chief Financial
Officer, Chief Marketing Officer, Chief People & Transformation
Officer and Chief Governance Officer & Company Secretary.
We have a target to have full gender balance in our CEO-3
and above global roles by 2030. At 31 December 2021, we
had, on aggregate, 38% women in our top three layers, a
decline of 1% since 31 December 2020. While representing
an increase of 9% since targets were introduced in 2015, we
know we have more to do and we continue to focus on the
recruitment, retention and advancement of women to meet
our 2030 target.
The mean gender pay gap for NatWest Bank is 30.1%
(median: 34.2%) and the mean gender bonus gap is 26.0%
(median: 12.5%). The statutory bonus gap calculated in line
with regulation is the number including recognition vouchers
(mean 50.5%; median 92.9%). This means that even colleagues
who received a small recognition voucher – for example a £10
voucher – are included in the calculations. Most colleagues in
our more junior jobs only receive fixed pay – a change made
to provide more certainty over earnings; and this means
that many colleagues included in the statutory bonus
gap calculations only received a recognition voucher.
We currently have a higher proportion of women in these
roles. We therefore believe the figures excluding recognition
vouchers, 26.0% (median: 12.5%), are the most accurate
reflection of our gender bonus gap today.
In line with being a signatory to HM Treasury’s ‘Women in
Finance Charter’, we are committed to implementing its four
key industry actions for gender balance across financial
services. Executive Sponsor for Gender, David Lindberg
(CEO, Retail Banking), is also part of the external
Accountable Executive Taskforce for the Charter.
In 2021, we were listed as a ‘Times Top 50 Employer for
Women’ for the 11th consecutive year. For the fifth year,
we’ve retained our place in Bloomberg’s ‘Global Gender
Equality Index’. NatWest Group India was recognised as the
‘Winner of Gender Inclusive Workplace’ by ‘UN Women Asia
Pacific Awards 2021’ for the region and as a ‘Top 10 Best
Workplaces for Women 2021’, awarded by the Great Place to
Work (GPTW) Institute, India. Elsewhere, NatWest Poland won
the ‘Fair to Women’ award, in recognition of their initiatives
and, more specifically, for supporting women in technology.
We continued our long-standing collaboration with Women
in Banking and Finance (WiBF), a volunteer-led organisation
which aims to connect members to thought leaders, business
leaders and women at all stages of their careers. Alison Rose
was presented with WiBF’s first President’s Award, recognising
her contribution to financial services over many years.
Ethnically diverse
Introduced in 2018, our ethnicity target is to have 14% Black,
Asian and Minority Ethnic colleagues in our top four layers
(CEO-4 and above) in the UK by 2025. At 31 December 2021,
Stakeholder focus areas
continued
of 86% of colleagues who disclosed their ethnicity in the top
four layers in the UK, we have on aggregate 11% Black, Asian
and Minority Ethnic colleagues. This represents a 3% increase
since targets were introduced. Overall, of those who disclose
their ethnicity, 17% of colleagues in the UK identify as Black,
Asian and Minority Ethnic.
In line with our commitment to transparency under the UK
Government’s Race at Work Charter and in anticipation of
a requirement to disclose our ethnicity pay gap, we have
voluntarily disclosed our ethnicity pay gap for NatWest Group
combined UK & Ireland. The mean ethnicity pay gap for
NatWest Group is 9.3% (median: 13.0%). The mean ethnicity
bonus gap for NatWest Group is 24.2% (median: 17.9%).
These bonus gap numbers are excluding recognition
vouchers, the numbers including recognition vouchers
are 32.8% (median 46.3%).
We are proud to be placed in the ‘Top 10 Outstanding
Employers’ as part of ‘Investing in Ethnicity Employer’s
Maturity Matrix’, a position we have held since its inception
in 2018. The Matrix creates a framework and provides a
benchmark to assist employers on their ethnicity journey.
In 2020, we launched the Racial Equality Taskforce to listen,
learn and better understand the barriers faced by colleagues,
customers and communities from Black, Asian and Minority
Ethnic backgrounds. The Taskforce set out ten commitments
in the Banking on Racial Equality report, including a new UK
target to have Black colleagues occupying 3% of UK roles
(CEO-5 and above) by 2025. At 31 December 2021, we have
1.5% of colleagues who identify as Black in the top five layers
in the UK. Overall, of those who disclose their ethnicity, 2%
of our colleagues in the UK identify as Black. In 2021, we
published a first anniversary update on the report, for full
details refer to natwestgroup.com.
In October, we celebrated Black History Month 2021 with
a theme of Black Excellence. This provided opportunities
to celebrate Black people striving to be the best version of
themselves, and spotlight Black role models excelling in their
chosen fields. We ran events throughout the month, with a
keynote lecture from Lord Simon Woolley, supported by
our Executive Sponsors for Ethnicity Simon McNamara
(Chief Administration Officer) and Nigel Prideaux
(Chief Communications Officer).
In 2021, we relaunched our Ethnicity Advisory Council to
support our ethnicity and inclusion strategy. Chaired by Simon
McNamara, nominated diversity and inclusion specialists from
different industries will provide critical challenge, guidance,
and direction on our strategy.
Disability smart
In 2021, we re-launched a career development programme
on a virtual platform for colleagues with a disability to explore
common barriers which impede progress and provide access
to tools and techniques to help overcome them.
We undertook a discovery session with Lexxic (specialist
psychology consultants) to help us create an environment
where neurodiversity can flourish. This helped inform us of
areas for improvement, with the aim of exploring how to
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2021 Annual Report and Accounts
become an even more neuroinclusive employer. We have
a roadmap in place, with five key areas: governance and
strategy; awareness and education; positive management
culture; attracting and retaining neurodiverse talent; and
future ways of working.
Since 2019 we have sponsored the Business Disability
Forum’s (BDF) Scottish Disability Conference, bringing together
organisations to support each other in becoming disability
smart. In 2021, the conference ran virtually and consisted
of workshops which facilitated group discussions on topics
including disability and diversity in the wake of COVID-19, how
to have conversations about disability at work, and supporting
neurodiverse colleagues in the workplace. The workshops had
more than 330 attendees.
In 2021, we refreshed our disability smart e-learning module
to help colleagues understand how we can be more inclusive
and accessible for all colleagues and customers. The module
included an overview of why accessibility is important
from our Executive Sponsor for Disability, Oliver Holbourn
(Director of Strategy & Ventures) and featured colleagues
sharing experiences.
Our efforts to be disability smart are recognised through a gold
rating in the BDF benchmark and Leader (the highest level)
status in the UK Government’s Disability Confident Scheme.
In India, we launched an On-Demand Sign Language
programme to facilitate access to sign language interpreters
for colleagues with hearing impairments for one-on-one
discussion and team meetings. NatWest Group India received
special recognition for disability smart work practices at the
GPTW Diversity & Inclusion Award Summit 2021. In Poland, we
ran a ‘Becoming Disability Smart’ project to increase support
for colleagues with disabilities. A new assistive technology
and workplace adjustment process was introduced, as well
as updated safety arrangements for disabled colleagues.
LGBT+ innovative
In 2021, we celebrated Pride by running a host of different
events that celebrated some of the successes we’ve had with
progressing our work. We also participated in the UK Stonewall
Workplace Equality Index to understand what more we can
do to support our LGBT+ colleagues and customers. This will
provide us with a definitive benchmark and allow us to assess
our achievements and progress on LGBT+ equality going
forward. Our Executive Sponsor for LGBT+, Jen Tippin (Chief
People & Transformation Officer), is guiding and shaping our
roadmap for the future.
During 2021, we created a new LGBT+ e-learning module
to be launched in 2022. The module focuses on establishing
colleagues’ understanding of various subjects across the gender
identity and sexual orientation spectrum. Our global learning
uses colleagues’ perspectives and insights from external
partners to enhance understanding. We also reviewed and
updated our international travel safety guidance for LGBT+
colleagues and our family friendly policies to ensure language
and scenarios are LGBT+ inclusive.
As a founding partner of the British LGBT Awards in 2015,
we continued our support in 2021 as a sponsor. The awards
2021 UK ethnicity profile by level
#Black,
Asian and
Minority
Ethnic
#White
%Black,
Asian and
Minority
Ethnic
CEO-3 and above combined
52
566
8
CEO-4
262
2,018
11
CEO-5
886
5,171
15
Target population
(CEO-4 and above combined)
314
2,584
11
(*)
2021 Global gender profile by level
#Women
#Men
%Women
CEO
1
100
CEO-1
3
12
20
CEO-2
48
80
38
CEO-3
270
429
39
CEO-4
1,298
1,863
41
Target population
(CEO-3 and above combined)
322
521
38
(*)
Note: Our reporting reflects our organisational (CEO) levels. This is more reflective of
our organisational structure and enables comparison to be made externally. To maintain
integrity, we remove colleagues from our reporting that sit in CEO-3 and above that do
not hold leadership or influential roles.
For ethnicity: Our reporting only includes colleagues who have disclosed their ethnicity.
We report CEO to CEO-3 as a total to comply with GDPR restrictions.
For gender: There are differences between CEO and CEO-1 reporting versus reporting
on the gender balance of our Executive Management Team. Female representation on
our Executive Management Team is 29%
Male
Female
Directors of the company
7
4
Executive employees
72
24
Director of subsidiaries
189
68
Permanent colleagues
(active and inactive)
30,000
29,500
There were 353 senior managers (in accordance with the definition
contained within the relevant Companies Act legislation), which
comprises our executive population and individuals who are
directors of our subsidiaries.
(*)
Within the scope of EY assurance. Refer to page 78.
spotlight organisations working to better meet the needs of
LGBT+ people. In 2021, Jen Tippin delivered a keynote speech
at the awards and presented the lifetime achievement award.
NatWest Group India received special recognition for LGBT+
workplace practices at the GPTW 2021 Diversity & Inclusion
Award Summit. In Poland, we once again hosted and
organised the NatWest LGBT+ Business Awards in recognition
of organisations and influencers making a real difference to
the lives of LGBT+ people in a very challenging climate.
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Stakeholder focus areas
continued
Young people have been hit hard by
the pandemic. From disrupted study
time to reduced job prospects, the
current generation of pupils and
school leavers will be feeling the
shockwaves of COVID-19 for a long
time to come. – Bless Chiwanda
Stronger together
Making a positive contribution to the communities
in which we live and work is integral to delivering
on our purpose.
The last two years have been incredibly tough for many
of our customers, but we have also seen the remarkable
collective support that happens when people come together.
We firmly believe NatWest Group has a role to play in this
process, positively impacting communities at both a local
and national level.
Focused on our communities
During the year we worked with the Centre for Social Justice
(CSJ) to carry out dedicated research into community strength:
‘Pillars of the Community’ explored what government, business
and the third sector can do to strengthen local communities as
the UK recovers from the pandemic. The research identified
the barriers that prevent local communities from thriving and
set out a range of policy initiatives that could help to overcome
these barriers.
We were also once again in regular contact with our
communities, including through our regional boards,
leveraging existing relationships and forming new ones. Our
seven regional boards are key to delivering the bank’s strategy
at a local level and championing potential across the UK. With
membership drawn from across the bank, the local insight and
strong teamwork of the boards is vital in demonstrating our
purpose to the communities we are part of.
The boards have been particularly important during
the pandemic, bringing people together to help serve our
customers and support our colleagues. In 2021, the regional
boards continued to focus on engaging with colleagues,
customers and communities across the nations and regions
of the UK, particularly in the areas of climate, learning
and enterprise.
Real-life support
We believe in supporting our customers with practical
measures that can help them in their day-to-day lives.
In doing so, we can provide part of the vital infrastructure
that communities need to live and thrive, such as our mobile
banking fleet, which visited nearly 600 communities every
week in 2021.
In response to the pandemic we have changed the way we
interact with our customers and communities, launching video
banking so our customers can meet with us from the comfort
of any location they choose. Elsewhere, NatWest Group’s
collaborations with Business in The Community (BITC), Hatch
and Digital Boost are another vital link with our business
communities, providing access to networks, sponsorship
and mentorship opportunities.
Helping young people into work
In 2021, we launched our ‘CareerSense’ programme – which
provides free-to-access tools to develop critical skills and
support youth employability prospects for 13 to 24-year-olds –
especially for those from low-income families and Black, Asian
and Minority Ethnic backgrounds. In November 2021, we also
Communities
Our CareerSense
programme
Supporting young people into workplaces
Bless Chiwanda
Journey Developer
welcomed our first cohort to the CareerSense ‘Find Your Path’,
an initiative for young people not in employment, education or
training, which has been created and delivered in partnership
with regional youth delivery partners. The scheme helps young
people to benefit from a range of skills-development sessions,
mentoring and paid work experience.
To support the CareerSense programme we have developed
the mycareersense.com website, which offers access to a
range of free tools and resources, as well as the learning
content accessed through our NatWest Learning Academy.
In addition, we launched an external learning academy
‘Learning with NatWest’ in November 2021 which supports
communities, families and businesses (both customers and
non-customers), focusing on five key capabilities: climate;
employability; entrepreneurship and enterprise; future skills;
and financial capability. For more information, please refer
to our NatWest Group ESG Supplement.
So, when NatWest Group launched the CareerSense
programme in 2021, I saw it as great way of offering some
practical help, and welcomed the opportunity to get
involved.
Along with almost 600 of my colleagues, who
have also volunteered, I became a CareerSense
Ambassador: a role that has involved me supporting a local
high school in Edinburgh, running sessions for S4 pupils.
The experience has been great. Not just because of
the positive feedback from the school, but because I’ve
been able to see so many of the young people get engaged
about their next steps. It’s also given me the opportunity
to reflect on my own personal development. To think
about the skills and behaviours I use daily to deliver
my work, while also making a positive change to my
local community.
Since its launch in June 2021, over 8,200 pupils have
registered to attend a skills exploration workshop. That’s a
lot of young people getting the career support they need.
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2021 Annual Report and Accounts
Our Supplier Charter
As a purpose-led business, we foster strong
relationships with all our key stakeholders,
including our supply chains. In 2022, our ambition
is to quantify the impact of all supplier activities
through a supplier engagement framework.
A key milestone towards this ambition was the launch of
the NatWest Group ‘Supplier Charter’ in September 2020.
The charter sets out our aims and expectations in the areas
of ethical business conduct, human rights, environmental
sustainability, diversity and inclusion, the Living Wage and
prompt payment. It details what we expect from our suppliers,
but also outlines our own commitments in these key areas and
the outcomes we aim to achieve by working together. In 2021,
led by NatWest Group’s Chief Administrative Officer and with
collaboration from subject matter experts and policy owners,
we completed our first annual review of the charter.
Central to the aims of charter, we worked with EcoVadis
– a leading organisation providing third-party, evidence-based
assessments of sustainability performance. EcoVadis is helping
us to understand and measure our own performance and that
of our suppliers against the charter, enabling us to identify
social, environmental and ethical improvements. NatWest
Group has made significant progress in the first year of
working with EcoVadis, with 834 suppliers invited to take
part in the assessment, representing over 85% of our in-scope
supplier spend. During 2021, NatWest Group Supply Chain
Services has delivered the biggest and fastest deployment
of EcoVadis supplier sustainability assessments in the UK.
Continuing to support our suppliers
We are determined to pay our suppliers promptly for the
services that they provide to us. Our standard payment
terms are normally 30 days. However, from earlier on in the
COVID-19 pandemic and since, we have maintained immediate
payment on receipt of goods and services whenever possible.
This supports our suppliers during this difficult financial period
and goes beyond our commitment undertaken as a signatory
to the UK Government’s ‘Prompt Payment Code’, which
requires payment to be made in 60 days.
Ongoing dialogue
We operate in a highly regulated market
which continues to evolve in scope. As such,
we understand the need to have an ongoing,
constructive and open dialogue with all relevant
regulatory bodies.
During 2021, this included bilateral responses to material
consultations or other requests for comment/input issued by
various government, regulatory and standard-setting bodies.
Key consultations that NatWest Group has responded to
bilaterally include the FCA’s Consumer Duty proposals; its
work on diversity and inclusion; the UK Government’s plans
for audit and corporate governance reform; the independent
review of Ring-fencing and Proprietary Trading; and the
Payment Systems Regulator’s proposals on Authorised
Push Payment (APP) scams.
We formally engage with our regulators, at both senior
executive and Board level, as well as via individual non-
executive directors, through continuous assessment and
proactive engagement meetings. Most notably, during 2021,
we kept our regulators fully informed of any contingencies
and impacts on our operations as a result of COVID-19.
This has been particularly relevant for monitoring compliance
with the Financial Conduct Authority’s Senior Managers
and Certification Regime to ensure that all governance
arrangements across NatWest Group have been kept under
review in the context of the pandemic. We have also engaged
with regulators during policy proposal phases on a number of
occasions to help inform priorities.
Suppliers
Regulators
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Climate-related disclosures overview
Climate-related
disclosures
We recognise that climate change is a global issue which has
significant implications for our customers, employees, suppliers,
partners, investors and therefore NatWest Group itself.
Our ambition is to be a leading bank in the UK helping to
address the climate challenge. We have set ourselves the
challenge to halve the climate impact of our financing activity
by 2030 and to become net zero
(1)
by 2050.
NatWest Group confirms that it has:
made climate related financial disclosures for the year ended December 31, 2021 that it believes are consistent with the Task
Force on Climate-related Financial Disclosures (“TCFD”) Recommendations and Recommended Disclosures (as defined in
Appendix 1 of the Financial Conduct Authority Listing Rules) and summarised in the tables on pages 66-69;
set out these disclosures in its “2021 NatWest Group Climate-related Disclosures Report” (the “Climate Report”), published today
(and available on natwestgroup.com); and
adopted this approach given the detailed and technical content of the climate-related financial disclosures as it believes these
presentations best present its climate related financial disclosures in a decision-useful manner to the users of those reports.
(1)
Science Based Targets initiative (SBTi) defines net zero as reducing Scope 1, 2 and 3 emissions to zero or to a residual level that is consistent with reaching net-zero emissions at a
global or sector level in eligible 1.5 degree-aligned pathways.
(2)
Upstream operational value chain emissions are all the indirect Scope 3 emissions required for our operations to occur, including emissions from our suppliers, energy creation and
transport to our facilities, and our mail. Downstream operational value chain emissions are all of the indirect Scope 3 emissions associated with our operations during and after serving
our customers, including customer transport to and from our facilities, how our products are used and how they are disposed of.
Accelerating
the speed of
transition to a
net-zero
economy
Helping to
end the most
harmful activity
Championing
climate
solutions
Net-zero
emissions for
our operational
value chain
(2)
Embedding
climate into
our culture and
decision-making
Net zero by 2050
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2021 Annual Report and Accounts
Climate ambition statements
A leading bank in the UK helping
to address the climate challenge
We have an ambition to achieve net zero by 2050, this includes:
Financed emissions
: Greenhouse gas emissions from loans and investments activity, attributable to NatWest Group.
Assets under management:
Greenhouse gas emissions associated with our discretionarily managed assets.
Our operational value chain:
Greenhouse gas emissions related to the upstream and downstream activities associated with
our operations.
Helping to end the most harmful activity
We plan to phase out of coal for UK and non-UK customers
who have UK coal production, coal fired generation and
coal related infrastructure by 1 October 2024, with a full
global phase out by 1 January 2030.
Embedding climate into our culture and
decision-making
Each year, we plan to include targets for executive
remuneration that reflect our latest climate ambitions.
We have an ambition to at least halve the climate impact
of our financing activity by 2030 and align with the 2015
Paris Agreement. To do this, we plan to quantify our climate
impact and set sector-specific targets by the end of 2022.
We plan to continue the integration of the financial and
non-financial risks arising from climate change into our
enterprise wide risk management framework (EWRMF).
Net-zero emissions for our operational
value chain
We have a target to reduce our direct
(3)
own operations
carbon footprint by 50% by 2025, against a 2019 baseline.
We plan to reduce the carbon footprint for our wider
operational value chain by 50%, against a 2019 baseline,
by 2030 and achieve net zero by 2050.
We plan to use only renewable electricity in our direct own
global operations by 2025 (RE100) and improve our energy
productivity 40% by 2025 against a 2015 baseline (EP100).
We plan to install electric vehicle charging infrastructure in
15% of spaces across our UK portfolio by 2030 and upgrade
our fleet of 300 vehicles to electric by 2025 (EV100).
Accelerating the speed of transition to a
net-zero economy
Championing climate solutions
We have a target to provide £100 billion Climate and
Sustainable Funding and Financing between 1 July 2021
and the end of 2025.
We have an ambition to support our UK mortgage
customers to increase their residential energy efficiency and
incentivise purchasing of the most energy efficient homes,
with an ambition that 50% of our mortgage portfolio has
an EPC rating of C or above by 2030.
We plan to collaborate cross industry and create
products and services to enable customers to track
their carbon impact.
We plan to reduce the carbon intensity of our funds and
discretionary portfolios by 50% by 2030 and to achieve
net zero on discretionarily managed assets by 2050.
For our full report, refer to
the 2021 Climate-related
Disclosures Report
(3)
Our Scope 1, Scope 2 and Scope 3 (paper, water, waste, business, travel commuting, work from home). Excludes upstream and
downstream emissions from our wider operational value chain as well as financed emissions.
Net zero by 2050
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NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Governance
NatWest Group’s governance around climate-related risks and opportunities
The Board’s oversight of climate-related risks and opportunities
Summary
Board monitoring and oversight of climate-related risks and opportunities is supported by clear roles and responsibilities
for the Board and Board Committees, as well as regular management reporting on climate strategy, ambition, and risk
management activities.
Key Board level decisions and areas of discussion and/or challenge related to climate strategy, climate scenario analysis,
risk appetite, reporting controls and embedding climate measures within remuneration and performance structures.
The Boards of NatWest Group’s principal subsidiaries exercised oversight of key climate-related risks and opportunities through
regular risk reporting and management updates.
Future priorities
Continue to oversee progress against NatWest Group’s climate ambitions and targets, particularly long term reduction in financed
emissions and development of transition plans to support this.
Continue to build knowledge at Board level and to support the directors in addressing and overseeing climate-related risks within
NatWest Group’s overall business strategy and risk appetite.
References
NatWest Group plc 2021 Climate-related Disclosures Report – sections 2.1, 2.2.
Management’s role in assessing and managing climate-related risks and opportunities
Summary
NatWest Group CEO and Chief Risk Officer jointly share accountability under the Senior Managers and Certification Regime for
identifying and managing the financial risk of climate change.
This responsibility is delegated amongst the Executive and senior leadership teams. Cross-bank climate-related groups, advisory
teams and committee structures support with collaboration, escalation, and additional controls.
The Climate Change Executive Steering Group acts as the primary management forum responsible for overseeing direction and
progress on NatWest Group’s climate-related commitments.
Future priorities
Further embed operating models and business processes to support the management of climate-related risks and opportunities,
including coordination of actions to support further development and execution of climate transition plans.
Continue to maintain a One Bank approach to climate strategy development and transition plans, including at subsidiary levels.
References
NatWest Group plc 2021 Climate-related Disclosures Report – sections 2.1, 2.3.
Climate-related
disclosures overview
NatWest Group publicly committed to support the Financial Stability Board’s Task Force on
Climate-related Financial Disclosures (TCFD) recommendations in 2017. Our first stand-alone
2020 Climate-related Disclosures Report provided updates on climate as a key focus area
for NatWest Group.
During 2021, we have continued to progress our work and the tables on the following pages
summarise the content of the 2021 Climate-related Disclosures Report. Please refer to the
NatWest Group plc 2021 Climate-related Disclosures Report for further detail.
Disclosures summary
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2021 Annual Report and Accounts
Strategy
The actual and potential impacts of climate-related risks and opportunities on NatWest Group’s businesses, strategy
and financial planning
Climate-related risks and opportunities identified over the short, medium and long term
Summary
NatWest Group’s climate ambition, announced in February 2020, recognises various short, medium and long-term climate-related
risks and opportunities to embed climate in our business and culture, as well as support our customers in their transition to net zero.
Future priorities
Further enhance capabilities associated with climate-related risks and opportunities measurement.
References
NatWest Group plc 2021 Climate-related Disclosures Report – sections 1.1, 1.2, 1.3, 1.4, 3.1, 3.2, 3.3, 3.4, 3.5, 4.3, 5.1.
The impact of climate-related risks and opportunities on our businesses, strategy and financial planning
Summary
NatWest Group made a number of environmental, social and ethical (ESE) policy updates during 2021 to help end the most
harmful activity and concluded a credible transition plan (CTP) assessments for oil and gas majors and in scope coal customers.
This supported our stated ambition to stop lending and underwriting to companies with more than 15% of activities related to
thermal and lignite coal, unless they had a CTP in line with the 2015 Paris Agreement in place by the end of 2021.
We continued to harness climate-related opportunities. We exceeded our 2020-2021 Climate and Sustainable Funding and Financing
target in under 18 months and supported our retail customers with a range of Green Mortgage products.
Our work on climate scenario analysis has supported our assessment of climate related risks and opportunities and helped re-affirm
our climate ambition. We continued to build powerful partnerships, acting as principal partner at COP26, and becoming a founding
member of the Net Zero Banking Alliance and Glasgow Financial Alliance for Net Zero (GFANZ).
We worked to incorporate climate in the financial planning process by developing our first carbon plan. This included an assessment
of carbon impacts of current and planned climate-related opportunities as well as climate-related risks, particularly those related to
dependencies on future policy and technology development.
Future priorities
Continue to integrate climate in business activities.
Further enhance carbon planning capability to support the development of transition plans to measure and track our progress
towards our ambition to halve the climate impact of our financing activity by 2030.
References
NatWest Group plc 2021 Climate-related Disclosures Report – sections 1.1, 1.2, 1.3, 1.4, 3.1, 3.2, 3.3, 3.4, 3.5. 3.6, 3.7, 3.8.
The resilience of our strategy, taking into consideration different climate-related scenarios, including a 2°C or lower scenario
Summary
During 2021, NatWest Group has developed its scenario analysis capabilities and deepened its understanding of climate-related
risks and opportunities through its participation in the Bank of England’s Climate Biennial Exploratory Scenario (CBES) exercise.
NatWest Group has also taken further steps to translate these insights into tangible action that will enable us and our customers
to mitigate climate-related risks and take advantage of the opportunities that the transition to net zero will create.
NatWest Group has used three scenarios published by the Bank of England for its CBES exercise as the foundation for its scenario
analysis, including an early action scenario which assumes the increase in global temperature is limited to under 2.0°C. Also,
scenarios have been used to estimate financed emissions reductions required by 2030 to support our net zero by 2050 ambition.
Future priorities
Continue to enhance scenario modelling and analytic capabilities.
Continue to address significant challenges related to the availability of granular customer data.
Respond to developing regulatory requirements on the approach to climate-related risk within the regulatory capital regime.
References
NatWest Group plc 2021 Climate-related Disclosures Report – sections 3.4, 3.7, 3.8, 5.7.
G
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Risk Management
How NatWest Group identifies, assesses, and manages climate-related risks
Our processes for identifying and assessing climate-related risks
Summary
Climate risk was incorporated into the NatWest Group risk directory as a principal risk in February 2021 and in April, Board Risk
Committee approved a principles-based climate risk policy that defined the key requirements for the identification, assessment,
and management of climate risk, through the incorporation of climate considerations in key risk management processes.
We completed a qualitative assessment of the current and potential impact of physical and transition climate risk as a causal
factor to other risks. This assessment of relative significance identified the following principal risks as being most exposed to
climate-related impacts: credit risk; operational risk; reputational risk; conduct risk and regulatory compliance risk.
NatWest Group regularly considers existing and emerging regulatory requirements related to climate change through external
horizon scanning and monitoring of emerging regulatory requirements which is completed by our Legal, Governance and
Regulatory Affairs team.
Future priorities
Continue enhancements to our enterprise wide risk toolkit to support identification and assessment of risk impact on other principal risks.
References
NatWest Group plc 2021 Climate-related Disclosures Report – section 3.1, 3.2, 4.1.
Our processes for managing climate-related risks
Summary
The management of climate risk is largely delivered through three mechanisms: scenario analysis, long-term balance sheet
transformation and enhanced climate risk data capabilities.
NatWest Group has established a climate risk appetite statement, determining the level of risk which the climate risk policy seeks
to operate within.
A climate maturity rating was developed, which supports ongoing assessment of climate risk management throughout
the organisation. This approach translated NatWest Group’s climate risk policy into thematic management outcomes.
As at 31 December 2021, NatWest Group has achieved first generation implementation of climate risk management, with a
predominantly qualitative approach to internal risk policy outcomes, covering priority sectors or customers. Where quantitative
approaches are applied, they are predominantly conducted on an ad hoc basis.
Future priorities
Work will continue to further integrate climate-related risk across business processes to achieve full integration within risk
management and decision-making.
Future target state includes, but is not limited to, climate risk being systematically captured as a quantified risk factor within lending
and risk decision-making, informing limits and pricing.
References
NatWest Group plc 2021 Climate-related Disclosures Report – sections 3.1, 3.2, 4.2.
How our processes for identifying, assessing, and managing climate-related risks are integrated into overall risk management
Summary
Retail credit risk: A review of EPC and flood impact was finalised for the Retail Banking residential mortgage portfolio; Credit
oversight tracking of EPC and flood risk concentrations have been developed. In addition, preliminary climate operational
measures were developed.
Wholesale credit risk: Continued evolution of our credit risk frameworks to incorporate climate risk, for example its inclusion
in Transaction Acceptance Standards (TAS) and in climate commentary within credit applications for the majority of the
wholesale portfolio.
Operational risk: NatWest Group-wide operational risk climate scenarios were completed in 2021. Two distinct extreme heat
scenarios were considered.
Reputational risk: Review of risk acceptance criteria (RAC) suite to validate the sectors which present high environmental, social
and ethical (ESE) risk.
Conduct risk and regulatory compliance risk: Supported the development and embedding of climate focused questions which have
been embedded into the existing governance processes.
Future priorities
Continue to assess impact of climate-related risks on NatWest Group’s financial and non-financial risk profile as part of risk and
control assessment of relevant processes.
Further embedding of climate considerations in product design and lending decisions through the use of climate risk data
(EPC and flood analysis, CBES findings).
References
NatWest Group plc 2021 Climate-related Disclosures Report – sections 3.1, 3.2, 4.3.
Disclosures summary
continued
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Metric and Targets
The metrics and targets used to assess and manage relevant climate-related risks and opportunities where such
information is material
The metrics used to assess climate-related risks and opportunities in line with our strategy and risk management process
Summary
Metrics used to assess climate-related risks:
Exposures to heightened climate-related risk sectors.
Energy efficiency and flood risk assessment for Retail Banking residential mortgage portfolio.
Capital markets transactions.
NatWest Group own operational footprint.
Estimates of financed emissions and emission intensities.
Metrics used to assess climate-related opportunities:
Climate and Sustainable Funding and Financing.
NatWest Group Own Green Bond issuance.
We added performance against climate targets as part of the bonus pool assessment for our wider workforce. Refer to the Directors’
Remuneration Report in the NatWest Group plc 2021 Annual Report and Accounts for further details.
Future priorities
We will continue to develop metrics and measurement capabilities to monitor and manage climate-related risks and opportunities
during 2022.
References
NatWest Group plc 2021 Climate-related Disclosures Report – sections 3.4, 4.2, 4.3, 5.1, 5.2, 5.3, 5.4, 5.5, 5.6., 5.7.
Scope 1, Scope 2 and, if appropriate, Scope 3 greenhouse gas (GHG) emissions, and the related risks.
Summary
We continued to develop and enhance capabilities to measure our carbon footprint in relation to our own operational footprint as
well as financed emissions:
We reduced our direct own operations carbon footprint by 46% against a 2019 baseline, and increased our renewable electricity
consumption to 97%.
We worked on enhancing our capabilities across an additional eight emissions intensive wholesale sectors. We also extended the
scope of emissions calculations for the oil and gas sector beyond extraction activities covered in 2020. We have now analysed
52% of our loans and investment portfolio based on 2019 gross on-balance sheet loans and investments.
Future priorities
To support our commitments to the Net Zero Banking Alliance, we will align to the Science Based Targets initiative’s (SBTi)
definition and account for the wider value chain, including suppliers, for our own operational footprint.
We have submitted our 2030 sector emissions reduction estimates to SBTi for validation and will continue our work to enhance
availability of data to support future calculations of financed emissions and emissions intensities.
References
NatWest Group plc 2021 Climate-related Disclosures Report – sections 5.6, 5.7, 5.8.
The targets used by the organisation to manage climate-related risks and opportunities and performance against targets
Summary
Our stated climate ambition is to be a leading bank in the UK helping to address the climate challenge. We have committed to achieve
net zero by 2050 across our financed emissions, assets under management and our operational value chain. Progress is monitored via
climate-related targets and ambitions across the following thematic opportunities:
Accelerating the speed of transition.
Helping to end the most harmful activity.
Championing climate solutions.
Embedding climate into our culture and decision-making.
Net zero for our operational value chain.
Future priorities
We will continue to monitor our performance against our climate-related targets and ambitions and revise, as appropriate.
References
NatWest Group plc 2021 Climate-related Disclosures Report – sections 1.1, 3.5, 5.
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NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Own operational footprint
Own operational
footprint
During 2021
(1)
, we reduced our direct own operations
(2)
carbon footprint
(3)
46% against 2019 baseline, and increased
our renewable electricity consumption to 97%.
Net-zero carbon
(3)
We plan to reduce the carbon footprint for our wider operational
value chain by 50% (against a 2019 baseline) by 2030 and
achieve net zero by 2050.
While there was previously no standard definition of net zero,
as part of COP26, in October 2021 the SBTi released the
‘SBTi Corporate Net Zero Standard’, the world’s first net zero
framework which encapsulates the full value chain of Scope 3
and deep decarbonisation targets. To support NatWest Group’s
public commitments to the Net Zero Banking Alliance, we plan
to align to the SBTi’s definition for own operations and also
account for the wider value
(4)
chain, including suppliers. We
have a target to reduce our direct own operations carbon
footprint by 50% by 2025 (2019 baseline) and plan to halve the
carbon footprint of our wider operational value chain by 2030,
with minimum 90% decarbonisation by 2050 for all emissions
(refer section 5.7 of the NatWest Group plc 2021 Climate-
related Disclosures Report for approach to financed emissions).
We intend to neutralise the remaining 10% of emissions with
high quality internationally recognised carbon credits
(5)
to
achieve net zero. We plan to continue making significant
emission reductions within our own operations, alongside
investments to mitigate GHG emissions through carbon
removal projects, programmes and solutions that provide
benefits to climate, especially those that generate additional
co-benefits for people and nature, in line with SBTi guidance.
As the first part of our journey, we are disclosing an initial view
of our upstream emissions for our 2021 footprint, with a plan
to refine this view and disclose our downstream emissions for
2022. Further, from 2022, NatWest Group will be using the
outputs from our 2021 energy audits to run a programme to
improve our building EPC ratings, reducing our climate impact.
Our 2021 total market-based operational footprint 66,149
tCO
2
e covers Scopes 1, 2 and our direct own operation
upstream Scope 3. This includes emission reductions from
the use of green electricity covering 97% of our consumption
through green tariffs and renewable electricity certificates,
but in accordance with the Greenhouse Gas Protocol, it does
not include emissions reduction from the use of carbon credits.
Further detail on our decarbonisation plans can be found
on page 71 of the NatWest Group plc 2021 Climate-related
Disclosures Report.
When announcing our Climate Positive
(6)
ambition in February
2020, the wide-ranging impacts from COVID-19 could not have
(1)
Our own operational footprint reporting year runs from October 2020 to September 2021.
(2)
NatWest Group defines direct own operations as our Scope 1, Scope 2 and Scope 3 (paper, water, waste, business travel, commuting and work from home) emissions. It therefore
excludes upstream and downstream emissions from our value chain.
(3)
Carbon/carbon footprint in this section refers to GHG emissions reported as carbon dioxide equivalent.
(4)
Upstream operational value chain emissions are all the indirect Scope 3 emissions required for our operations to occur, including emissions from our suppliers, energy creation and
transport to our facilities, and our mail. Downstream operational value chain emissions are all of the indirect Scope 3 emissions associated with our operations during and after serving
our customers, including customer transport to and from our facilities, how our products are used and how they are disposed of.
(5)
NatWest Group used carbon credits for our 2021 achievement. These projects remove carbon from the atmosphere through tree planting and are dual-validated and verified under the
Verified Carbon Standard (VCS) and Climate, Community and Biodiversity Standards (CCB).
(6)
NatWest Group defines Climate Positive as reducing location-based emissions from our direct own operations 25% from our 2019 baseline and using carbon credits to neutralise our
baseline market-based emissions of 120,000 tCO
2
e.
been anticipated. By procuring a minimum 120,000 tCO
2
e in
carbon credits, in line with our market-based 2019 baseline,
while simultaneously reducing emissions from our own
operations, we have already achieved our ambition to be
Climate Positive in 2021 for our direct own operations. We
used 120,000 tCO
2
e of internationally recognised carbon
credits which add environmental, social and community
benefits compared to the 2021 residual market-based 66,149
tCO
2
e Scope 1, 2 and 3 emissions. We had previously targeted
a 25% reduction in emissions from our direct own operations
by 2025 (2019 baseline) but are now increasing this to 50% as
we seek to build on the emissions reductions that have already
occurred.
Energy and carbon
In 2021, we reduced our direct operational Scope 1, 2 and 3
(business travel, paper, waste, water, commuting and work
from home) emissions by 46% against a 2019 baseline. This has
been through a number of emission reduction activities as well
as impacts from COVID-19.
Despite COVID-19, a number of key projects were still
completed in 2021. Notable highlights include:
Renewable power
: NatWest Group has partnered to
develop a solar generation facility in the UK under a
corporate power purchase agreement. The facility is due
to start generating low-carbon electricity for the bank
from 2024 and will bring additional renewable generation
capacity online to facilitate the decarbonisation of the UK
power grid. Once constructed, the facility is expected to
generate 40% of NatWest’s electricity demand in the UK.
Branch investments
: The high-performance specification
implemented for a branch fit-out in Bristol meant that we
achieved an energy performance rating of ‘B’ and achieved
Royal Institute of Chartered Surveyors (RICS) SKA Silver
rating in terms of the design’s broader sustainable design.
Lifts
: The first phase of a replacement passenger lift system
at our offices at 250 Bishopsgate, London, leading to a 30%
reduction in the energy use of the lifts; making the lifts ‘A’
rated in terms of energy.
Building Management System investment
: In our Coutts
head office we have invested in ‘out BMS controllers’ which
have provided a better environment for our colleagues and
enable more efficient energy management from the facilities
management team. We have also installed dashboard
screens in the customer and colleague areas in both the
Coutts head office and 250 Bishopsgate to educate on
the energy usage of the buildings.
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NatWest Group
2021 Annual Report and Accounts
Streamlined energy and carbon reporting
2021
2020
Greenhouse gas (GHG) emissions
UK and
offshore
(1)
area
Global total
(excluding UK
and offshore)’
UK and offshore
(1)
area
Global total
(excluding UK
and offshore)
Emissions from the combustion of fuel and operation of any facility
(Scope 1
(2)
Direct) CO
2
e (tonnes)
(*)
17,464
1,663
18,443
1,921
Emissions from the purchase of electricity, heat, steam or cooling by
the company for its own use (Scope 2
(3)
Indirect) Location-based
CO
2
e emissions (tonnes)
(*)
52,735
16,305
63,841
23,057
Total gross Scope 1 & Scope 2 (location-based) emissions CO
2
e (tonnes)
(*)
70,199
17,968
82,284
24,977
Energy consumption used to calculate above emissions (kWh)
329,396,747
40,652,346
347,909,621
49,510,271
Intensity ratio: Location-based CO
2
e emissions per FTE (Scope 1 & 2)
(tonnes/FTE)
1.71
1.03
1.83
1.37
Scope 3
(4)
CO
2
e emissions from direct operations, paper, water, waste,
business travel, commuting and working from home (tonnes)
(*)
36,016
8,855
38,502
14,967
Total gross CO
2
e emissions for direct operations (Scope 1, location-based
Scope 2, Scope 3) (tonnes)
(*)
106,215
26,823
120,787
39,944
Intensity ratio: Location-based CO
2
e emissions per FTE (Scope 1, 2 & direct
operations Scope 3) (tonnes/FTE)
2.59
1.54
2.69
2.19
Scope 2
(5)
(Indirect) Market-based CO
2
e emissions (tonnes)
(*)
12
2,139
8,860
2,346
Emissions methodology and basis of preparation
Boundary:
We have reported on all emission sources required under the Companies (Directors’ Report) and Limited Liability
Partnerships (Energy and Carbon Report) Regulations 2018. Our reporting year runs from October 2020 to September 2021.
The emissions reporting boundary is defined as all entities and facilities either owned or under our operational control.
Calculation
: Emissions have been calculated using the Greenhouse Gas Protocol Corporate Standard and associated guidance and
include all greenhouse gases, reported in tonnes of carbon dioxide equivalent (CO
2
e) and global warming potential values. When
converting data to carbon emissions, we use Emission Factors from UK Government Emissions Conversion Factors for Company
Reporting (Department for Business, Energy & Industrial Strategy, 2021), CO
2
emissions from fuel combustion (International Energy
Agency, 2021) or relevant local authorities as required. NatWest Group utilises a third-party software system, Envizi, to capture and
record our environmental impact and ensure audit requirements are met. All data is aggregated at a regional level to reflect the
total regional consumption. The regional consumption results are then collated to reflect the total NatWest Group footprint. CO
2
e
values are attributed to these sources via an automatic conversion module in the Envizi system. For more information, please see
the own operational footprint page on natwestgroup.com.
(1)
Offshore area as defined in The Companies (Directors Report) and Limited Liability Partnerships (Energy and Carbon) Regulations 2018. This includes Jersey and Guernsey but not our
overseas sites in America, EMEA and Asia-Pacific. These are included in the global total (excluding UK and offshore).
(2)
Scope 1 emissions from natural gas, liquid fossil fuels, fluorinated gas losses and owned/leased vehicles.
(3)
Scope 2 emissions from electricity, district heating and cooling used in NatWest Group premises.
(4)
Scope 3 emissions from paper and water, category 5: waste (UK and RoI only), category 6: business travel including air, rail, hired vehicles and our grey fleet, category 7: employee
commuting and working from home.
(5)
Market-based Scope 2 emissions. UK market-based emissions have dropped 99% (to 12 tCO
2
e) as we have procured 100% of the electricity we have consumed from renewable
sources using green tariffs and renewable electricity certificates, whereas in 2020, we sourced 90% of our UK electricity from renewable sources, with the remaining 10% accounting
for 8,848 tCO
2
e. The 12 tCO
2
e arises from district cooling and district heating, which is used at only a few sites.
(*)
Within the scope of EY assurance (2021 only).
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NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Risk overview
Risk management
Risk is an inherent part of doing business. Some types of
risk – such as credit risk or market risk for example – are an
integral part of NatWest Group’s day-to-day activities and a
vital part of revenue generation. Other risks, such as those
arising from changes in the economy or the competitive
landscape, are an inescapable part of the environment in
which NatWest Group operates and must also be managed
and mitigated.
Effective risk management is a vital element of ensuring
NatWest Group is able to achieve its long-term strategy
and fulfil its purpose.
NatWest Group operates an enterprise-wide risk management
framework. The framework – which is supported by policies,
standards and operational procedures – sets out a consistent
approach to managing risk across the organisation. It is
aligned to NatWest Group’s purpose and is designed to
support intelligent risk-taking.
While the Board reviews and approves the framework, all
colleagues share ownership of risk management. The industry-
standard three lines of defence approach is used to define
responsibilities. This aims to ensure that risks are properly
identified and assessed, managed and mitigated, monitored
and reported.
NatWest Group’s independent Risk function designs and
maintains the framework. The Risk function – which is led by
the Chief Risk Officer – also provides oversight and monitoring
of all risk management activities. The Chief Risk Officer plays
an integral role in providing the Board with advice on NatWest
Group’s risk profile, the performance of its controls and in
providing challenge where a proposed business strategy
may exceed risk tolerance.
NatWest Group has identified a number of principal risks.
These are risks that are an inherent part of banking activity
and have the potential to significantly affect NatWest Group’s
performance or prospects. They are categorised as financial
and non-financial principal risks.
In addition, a regular process identifies top and emerging risks.
These are specific scenarios of concern that may combine
elements of several principal risks – or create new types of
threat altogether – and which, without appropriate management
and mitigation, could have a significant negative impact on
NatWest Group’s ability to meet its strategic objectives.
These are detailed on page 75.
Risk appetite is a key component of the framework. It defines
the level and types of risk NatWest Group is willing to take as
part of its business activities. Risk appetite is set in line with
overall strategy and approved by the Board. It supports the
strategic aim of building a sustainable business by providing
colleagues with a structured approach to risk-taking within
agreed boundaries.
Information on the risk profile relative to risk appetite, as well
as details of new and emerging risks, is reported regularly to
the Board and to NatWest Group’s senior risk committees.
Principal financial risks
Principal non-financial risks
Credit risk
Conduct risk
Traded market risk
Financial crime risk
Non-traded market risk
Operational risk
Capital adequacy
Regulatory compliance risk
Liquidity and funding
Model risk
Earnings stability
Climate risk
Pension risk
Reputational risk
Areas of focus in 2021
The global economy continued to grow, though more
slowly than expected. The aftershocks of the pandemic also
intensified uncertainty around both the pace of recovery and
the longer-term future. Accordingly, risk management played
a critical role throughout the year, focusing both on striking
the correct balance between risk and opportunity, and also
on ensuring that supporting processes, policies and controls
were properly optimised to deal with the heightened risk
environment. Providing a clear risk perimeter allowed NatWest
Group’s customer-facing franchises to operate safely as they
set out to achieve NatWest Group’s purpose of helping people,
families and businesses to thrive.
As a result, NatWest Group’s credit risk profile remained in line
with expectations, though given the heightened uncertainty,
this remained an area of significant risk management focus.
Impairment releases were significant. IFRS 9 forward-looking
expected credit losses for performing assets in Stage 1 and
Stage 2 reduced and actual Stage 3 default charges were
relatively modest. However, NatWest Group anticipates
increased default levels in 2022 as the longer-term impacts
of pandemic-related disruption emerge. Other headwinds,
such as ongoing supply chain challenges and inflation,
have the potential to heighten the credit risk profile.
NatWest Group’s traded and non-traded market risk profiles
were also broadly stable, though the potential second-order
effects of the pandemic on both remain a key risk
management consideration.
Compliance and conduct
Further progress was made on the compliance agenda during
2021. This included the introduction of a digital rules-mapping
platform intended to enhance NatWest Group’s assessment
and implementation of regulatory obligations. In addition,
a new ring-fencing hub was established to provide an
aggregated view of ring-fencing compliance and risk
management. The conduct risk profile also remained a key
focus. In December 2021, the NatWest Markets subsidiary
pleaded guilty to one count of wire fraud and one count of
securities fraud related to historical spoofing conduct by
former employees in US Treasuries markets between 2008 and
2014. As part of the plea agreement, NatWest Markets will pay
Impactful and effective risk management supports NatWest Group
in delivering its strategy and purpose.
72
NatWest Group
2021 Annual Report and Accounts
a criminal fine and a criminal forfeiture as well as restitution.
The plea agreement also imposes an independent corporate
monitor. NatWest Markets has also committed to compliance
programme reviews and improvements. Throughout the year,
with many colleagues working from home, additional controls
around the supervision of certain roles remained in place to
ensure secure and compliant operations. Controls established
to mitigate risks relating to the recording of regulated
communications, the flow of inside information and
management of conflicts of interest also remained a focus.
Financial crime
While work continues to enhance the control environment
relating to financial crime risk, operational weaknesses
between 2012 and 2016 resulted in the inadequate monitoring
of a UK-incorporated NatWest Bank Plc customer. Regulations
require risk-sensitive ongoing monitoring of customers for the
purposes of preventing money laundering. NatWest Bank Plc
co-operated fully with the regulator’s investigation into this
case and, in October 2021, pleaded guilty to three breaches
of the Money Laundering Regulations 2007.
NatWest Group takes its responsibility to prevent and detect
financial crime extremely seriously and continues to make
significant multi-year investments to strengthen and improve
its overall financial crime framework with prevention systems
and capabilities. This investment continued during 2021 and
there was significant risk management focus on the systems
and processes relating to customer due diligence, transaction
monitoring and automated customer screening. NatWest
Group continues to work with law enforcement agencies,
industry bodies and regulators to develop intelligence and
collaborative solutions to prevent financial crime.
Anti-bribery and corruption (ABC)
NatWest Group is committed to ensuring it acts responsibly
and ethically, both when pursuing its own business
opportunities and when awarding business. Consequently,
it has embedded appropriate policies, mandatory procedures
and controls to ensure its employees, and any other parties it
does business with, understand these obligations and abide by
them whenever they act for NatWest Group. ABC training is
mandatory for all staff on an annual basis, with targeted
training appropriate for certain roles. NatWest Group considers
Risk management process
This diagram summarises the main risk management processes and responsibilities within NatWest Group.
Risk activities
Responsibilities
Governance
Identify and
Assess
Report
Monitor
Manage/
Mitigate
Board
Responsible for reviewing the effectiveness
of the risk management and internal control
systems of NatWest Group, including the
nature and extent of the risks it may take
in pursuit of its strategic objectives.
Strategic consideration of principal risks –
together with top and emerging risks –
against NatWest Group’s business plan.
Leads the development of, and assesses/
monitors, risk culture.
NatWest Group Risk Function
Design and implementation of the enterprise-
wide risk management framework and
policies. Oversight of franchise and entity
risk management activities.
Aggregated reporting of franchise/
entity-level management of principal risks
– together with top and emerging risks –
against the agreed risk appetite set by the
Board, including assessment of the way
correlation and concentration levels may
change in aggregate.
Franchises and Entities
Take risks within the risk appetite set by
the Board in pursuit of business objectives.
Day-to-day risk management including,
identification and assessment, mitigation
and monitoring.
Reporting on franchise/entity-level
management of principal/top and emerging
risks within appetite. Horizon-scanning to
identify and assess likely changes in risk
environment/landscape.
Board
Sets risk appetite, reviews and
approves the enterprise-wide
risk management framework.
Board Risk Committee
Provides oversight and advice
to the Board on current and
future risk profile. Reviews the
effectiveness of internal controls
to manage risk.
Group Audit Committee
Reviews the effectiveness of
NatWest Group’s system of
internal control relating to
financial management.
Executive Risk Committee
Reviews, challenges and debates
all material risk and control
matters across NatWest Group.
Franchise Risk
Committees
Detailed oversight of risk profile
relative to risk appetite for
specific franchises/entities.
Top
down
Bottom
up
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NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Risk management
continued
ABC risk in its business processes including, but not limited to,
corporate donations, charitable sponsorships, political activities
and commercial sponsorships. Where appropriate, ABC
contract clauses are required in written agreements.
Climate risk
The impact of climate change on NatWest Group and its
customers continued to be a central risk management focus
during the year. A new Climate Centre of Excellence was
established to provide specialist expertise across NatWest
Group, including horizon scanning to identify strategic
opportunities and risks. In addition, the qualitative
consideration of climate-related risk was made mandatory for
most of the wholesale portfolio within credit assessments, and
enhancements were made to NatWest Group’s environmental,
social and ethical framework to address reputational risks
arising from carbon-intensive sectors. NatWest Group also
participated in the Bank of England’s Climate Biennial
Exploratory Scenario stress test exercise. This exercise was
designed to support improved understanding of the financial
system’s exposure to climate-related risks and the likely
challenges to business models emerging from climate change.
While participation was mandatory, the exercise also helped
NatWest Group in understanding and preparing to manage
risks that could arise, both in terms of the transition to
net zero and the physical risks from climate change.
LIBOR
Risks relating to the reform of interest-rate benchmarks were a
consistent focus during the year. With the exception of certain
tenors, publication of the London Inter-Bank Offered Rate
(LIBOR), a key benchmark in the global financial markets for
many years, ceased on 31 December 2021. In preparation for
the move to alternative risk-free rates – including the Sterling
Overnight Index Average (SONIA) – NatWest Group stopped
offering Sterling LIBOR for new transactions on 31 March
2021. A Group-wide transition programme coordinated work
to help customers smoothly transition from a range of LIBOR-
based products, such as mortgages, investment-backed
lending and derivatives, to those using alternative benchmarks.
Significant attention was paid to the potential conduct risks
arising from transition activity, as well as related operational
risks, in order to ensure appropriate customer outcomes.
In addition, there was a strong focus on carefully managing
the associated compliance risk, market risk and counterparty
credit risk. The complexity of the transition, especially in
relation to so-called ‘tough legacy’ contracts that cannot be
transitioned to alternative reference rates, also heightened
execution risk. The FCA has proposed that use of synthetic
sterling LIBOR may be permitted for a number of legacy
contracts. It’s expected that management of related risks
will remain a focus into 2022 as NatWest Group continues
to support its customers through the transition.
Information and cyber-security
Cyber crime is an ever-present threat across the digital
landscape and continues to evolve rapidly. Attacks may be
from individuals or highly-organised criminal groups intent
on stealing money or sensitive data, or potentially holding
organisations to ransom. NatWest Group takes this threat
seriously and continues to work with industry bodies, peers
and the National Cyber Security Centre to gather and
share intelligence. During 2021, there was continued risk
management focus on ensuring defences remain optimised
for the evolving threat.
Risk culture
NatWest Group’s multi-year programme to enhance risk
management capability at every level of the organisation
continued with an ongoing emphasis on risk culture. This work
aims to embed a generative risk culture across all three lines
of defence – where risk management is an integral part of
the way colleagues work and think. The approach supports
intelligent risk-taking, better customer outcomes, stronger and
more sustainable business as well as an improved cost base.
During 2021, there was a focus on a number of risk culture
initiatives, including improvements in risk data and systems
alignment as well as enhancements to risk identification
processes and risk culture management information.
Model risk
An effective understanding of likely future outcomes and the
scale of likely hazards is an essential part of forward-looking
risk management. NatWest Group is heavily reliant on
modelling across all aspects of its business. Ensuring its models
are designed effectively – and that associated assumptions,
data inputs and techniques are appropriate – remained a key
risk management focus in 2021. This included a programme
of ongoing work to upgrade a number of models to improve
predictability and compliance with new regulatory requirements.
Risk-weighted assets (RWAs)
RWAs were down £13.3 billion at 31 December 2021, ending
the year at £157 billion (from £170.3 billion in 2020). This was
mainly driven by a £9.8 billion reduction in credit risk RWAs
as well as reductions in market risk RWAs (£1.4 billion),
counterparty credit risk RWAs (£1.2 billion) and operational
risk RWAs (£0.9 billion).
Common Equity Tier 1 ratio
NatWest Group maintained a strong CET1 ratio of 18.2%
(2020 – 18.5%), reflecting both the £13.3 billion reduction in
RWAs and a £2.9 billion decrease in CET 1. This decrease was
mainly driven by the directed buy-back and associated pension
contribution of £1.2 billion and on-market share buy-backs
totalling £1.5 billion, as well as foreseeable dividends and
associated pension contributions of £1.2 billion and a £1.1
billion decrease in the IFRS 9 transitional adjustment and other
reserve reductions, offset by the £3 billion attributable profit
in the period. The CET1 ratio reduced to 15.9% on 1 January
2022 as a result of regulatory RWA and capital changes.
Leverage ratios
The CRR leverage ratio decreased to 4.4% (2020 – 5.2%) due
to a £40 billion increase in leverage exposure and a £4 billion
decrease in Tier 1 capital. The UK leverage ratio decreased
to 5.8% (2020 – 6.4%) due to the decrease in Tier 1 capital.
Stress testing
Under the 2021 Bank of England solvency stress test, on an
IFRS 9 transitional basis NatWest Group’s low point CET1
ratio was 10.4%. This was above the reference rate of 7%.
The transitional Tier 1 leverage ratio low point was projected
to be 4.4% under stress. NatWest Group also took part in the
Bank of England’s Climate Biennial Exploratory Scenario.
Liquidity and funding
The liquidity portfolio increased by £24.1 billion to £286.4
billion. Primary liquidity increased by £38.2 billion to £208.6
billion. The increase in primary liquidity resulted mainly from
customer deposits, TFSME funding, new issuances and a
methodology change to include UBIDAC cash at central banks.
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2021 Annual Report and Accounts
Top and emerging
risks
A continuous process is used to identify and manage the Group’s top and
emerging risks. These are risks that could have a significant negative impact on
the ability to operate or meet strategic objectives.
External
Climate-related
risks
NatWest Group and its customers may face significant climate-related risks, including those arising from the transition
to a net-zero economy. These risks are receiving increasing regulatory, political and societal scrutiny, both in the UK
and internationally. There are significant uncertainties as to the extent and timing of the manifestation of the physical
risks of climate change, such as more extreme and frequent weather events and reductions in biodiversity. Embedding
climate risk into the Group’s risk framework and adapting NatWest Group’s operations and business strategy to
address the risks is in line with the purpose-led strategy.
Competitive
environment
NatWest Group operates in markets that are highly competitive, raising the threat of a loss of market share, reduced
revenue and lower profitability. The risks mainly relate to changes in regulation, developments in financial technology
(including digital currency), new entrants to the market and changes in customer behaviour. The Group closely
monitors the competitive environment and adapts strategy as appropriate to deliver innovative and compelling
propositions for customers.
COVID-19
The COVID-19 crisis could impede the Group’s ability to meet its targets and deliver its purpose-led strategy. Despite
delivery of a mass vaccination programme in the UK, uncertainty remains around the future evolution of the virus and
the ultimate impact of the pandemic on NatWest Group and its customers. Key mitigation measures to manage the
uncertainty include scenario analysis, stress testing and active portfolio management including the adjustment of
risk appetite.
Cyber threats
The threat from cyber attacks is constant both directly to businesses such as NatWest Group and to others in the
supply chain. As cyber attacks evolve and become more sophisticated, NatWest Group continues to invest in additional
capability and controls designed to defend against the evolving threats. There is a sustained focus on managing the
impact of the attacks and maintaining the availability of services for NatWest Group’s customers.
Economic and
political risks
NatWest Group is exposed to economic and political risks in the markets in which it operates. Economic uncertainty
remains high due to a combination of inflationary pressures including supply chain frictions and disruption due to new
COVID-19 variants. A range of complementary approaches is used to mitigate these risks including scenario analysis
and stress testing. The Group continues to monitor geopolitical risks alongside domestic political risk including those in
relation to the UK’s withdrawal from the European Union and a Scottish independence referendum. In the longer term,
demographic change, high levels of debt and inequality could all have financial impacts. As a result, these risks are
closely monitored and strategic plans are adapted as appropriate.
Regulatory, legal
and conduct risks
NatWest Group is subject to extensive laws and regulations and expects government and regulatory intervention
in the financial services industry to remain high for the foreseeable future. The Group implements new regulatory
requirements, where applicable, and incorporates the implications of related changes in its strategic and financial
plans. However, changes in laws or regulations, or failure by NatWest Group to comply with these, may adversely
affect NatWest Group’s business, results of operations and outlook.
Internal
Change risk
The implementation of NatWest Group’s purpose-led strategy and the refocusing of NatWest Markets carry significant
execution, operational and people risks. NatWest Group continues to manage and implement change in line with
its strategic plans while assessing execution risks and taking appropriate mitigating action. In addition, the Group
continues to monitor and strengthen its control environment including in relation to financial crime, through robust
governance and controls frameworks.
Data
management
NatWest Group operations and strategy are highly dependent on the accuracy and effective use of data. Failure
to have current, high-quality data and/or the ineffective use of such data could result in a failure to deliver NatWest
Group’s strategy including reducing costs and meeting customer expectations. The Group is focused on delivering
a long-term data strategy alongside control and policy framework enhancements governing data usage.
People risk
NatWest Group’s success depends on its ability to attract, retain and develop highly skilled and qualified personnel,
including senior management, directors and key employees in a highly competitive market and under internal cost
reduction pressures. A combination of strategic workforce planning, including in relation to critical role resource and
retention of specific skills, and close monitoring of staff turnover levels and colleague wellbeing are key mitigants.
Third-party
suppliers
Operational risks arise from NatWest Group’s reliance on third-party suppliers to provide a range of services,
including information technology. While the ineffective management of these risks could adversely affect NatWest
Group, significant resources and planning have been devoted to mitigate the risks including the implementation of
robust risk controls.
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NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
In assessing NatWest Group’s future prospects, the Board
considers a period of three years to be appropriate. Although
strategic and business planning – as well as internal stress
tests – are based on a five-year timespan, levels of uncertainty
increase as the time horizon extends and therefore the shorter
period is considered more suitable for this assessment. The
Board will continue to monitor and consider the appropriateness
of this period.
In assessing NatWest Group’s viability over that three-year
time frame, the Board has considered a wide range of
information, including:
Strategic
NatWest Group’s long-term business and strategic plans;
Its liquidity and funding profile, including projections over
the relevant period;
Its current capital position and projections over the
relevant period.
Risk
NatWest Group’s risk profile and risk management
practices, including the processes by which risks are
identified and mitigated;
Its principal risks as well as the top and emerging risks
that could have a significant negative impact on NatWest
Group’s licence to operate or meet its strategic objectives
over the medium term;
Internal stress tests, which include consideration of
NatWest Group’s principal and emerging risks within
the scenario design.
Regulatory
The results of the Bank of England 2021 solvency
stress test;
The Group’s results in the Bank of England’s Climate
Biennial Exploratory Scenario (CBES);
The output of the Group’s 2021 Internal Capital Adequacy
Assessment Process (ICAAP) and Internal Liquidity
Adequacy Assessment Process (ILAAP).
Operating environment
The wider political and economic environment within which
NatWest Group operates, including uncertainties relating
to the geopolitical outlook and the global pandemic.
The Group’s business and strategic plans, which are reviewed
and evaluated on an annual basis at minimum, provide
long-term direction. This includes multi-year forecasts
assessing NatWest Group’s expected financial position
throughout the planning period. Threats to the achievement
of those plans – including financial, operational, conduct and
financial crime risks – are identified and assessed through
NatWest Group’s enterprise-wide risk management framework.
As part of this, Board-approved risk appetite is a key
consideration. Performance against risk appetite for each of
the principal risks is reported to the Board on a regular basis
together with assessments of emerging risks that could have an
impact within the planning horizon. NatWest Group’s principal
risks and uncertainties are set out on pages 72 to 75. Further
detail can be found in the Risk and capital management
section of the Annual Report and Accounts (pages 187-285).
The effects of COVID-19 and associated government responses
remained an important consideration particularly in relation to
the impacts on customers – including the end of government
support schemes and the likely trajectory of the overall
recovery. The impact of the pandemic and potential
aftershocks are subject to continuous monitoring with
additional focus in NatWest Group’s senior risk committees and
at Board level. In addition, other impacts, such as the effect of
sustained supply chain disruption for business and corporate
clients, were also a focus.
A series of internally-developed stress scenarios supports
NatWest Group’s planning processes. During 2021, a range of
future economic conditions of increasing severity was defined
in order to support internal modelling and assess NatWest
Group’s potential performance over the planning horizon.
These included a base case – or central – scenario using a set
of assumptions such as expected GDP growth of 1.7% over the
scenario period, an average Bank of England base rate of 0.8%
and a total change in the UK house price index of 12.1%. This
scenario also assumed a resilient labour market following the
end of the government furlough scheme and inflation peaking
in early 2022, followed by a gradual easing of pressures in the
medium term. While potential performance was also assessed
against a more positive, or upside scenario, NatWest Group’s
likely response to more adverse and challenging conditions
was assessed using a suite of downside scenarios ranging from
moderate to extreme. The assumptions used in these scenarios
included GDP contraction of -1.8% and -7.9%, base rate of
1.5% or -0.5%, and house price index falls of -3% and -26%.
Additional scenarios, assuming much more severe conditions
– ranging from a sharp economic downturn in the UK to
persistent COVID-19 impacts and a global recession – were
also used for internal modelling and planning purposes. These
included a range of challenges relating to NatWest Group’s
principal risks. Internal scenarios used for the ICAAP are
designed to be extreme but plausible and take account of
potential risk management actions and mitigation supported by
the enterprise-wide risk management framework. For example,
a range of financial crime scenarios was assessed using both
one-in-25-years and one-in-100-years stresses to analyse the
likely impacts of extreme events on the Group’s licence to
operate. These assessed the potential impacts of external
fraud, sanctions, money laundering, tax evasion or bribery
Viability statement
Viability
statement
In accordance with Provision 31 of the UK Corporate Governance Code,
the Board is required to make a statement in the Annual Report and Accounts
regarding NatWest Group’s viability over a specified time horizon.
76
NatWest Group
2021 Annual Report and Accounts
and corruption events on the Group. Similarly, such exercises
were carried out across credit risk, market risk, pension risk,
capital adequacy, liquidity and funding, operational risk and
conduct risk – in order to ensure NatWest Group remains
appropriately resilient even in extreme circumstances.
In addition, NatWest Group’s top and emerging risks are a
significant consideration in internal planning as well as in
assessing future capital and liquidity resilience under
adverse scenarios through the ICAAP and ILAAP.
Reverse stress testing is also used to assess scenarios and
circumstances that could make NatWest Group’s business
model unviable. These exercises begin with a definition of
business model failure – including capital adequacy thresholds
– and then analyse the events that could cause that failure.
NatWest Group uses a range of stress scenarios that include
systemic events, that may affect the entire financial system,
idiosyncratic events that would create adverse consequences
for only NatWest Group and a combination of these. During
2021, reverse stress testing considered the impact of sustained
income challenges and increased impairments in a recession.
Significant drops in UK GDP (-9%, -12, -15%) were factored in
together with high unemployment (16–17%), a collapse in asset
prices (commercial real estate values falling, for example, by
up to 50%) and a dramatic reduction in house prices (-34%,
-47% and -50%). In each of the extreme scenarios, NatWest
Group remained above the defined thresholds.
The results of the 2021 Bank of England solvency stress
test were also considered as part of the assessment.
The assumptions involved in this stress scenario included a
significant drop in UK GDP (37% of 2019 UK GDP) between
2020 and 2022, an unemployment spike just under 12% and
a 33% fall in residential and commercial property prices. The
scenario also included a 31% cumulative fall in world GDP.
NatWest Group remained considerably above the hurdle
rate before and after strategic management actions.
In considering NatWest Group’s prospects over the period of
the viability assessment, the Board’s assessment in this regard
is that NatWest Group is appropriately resilient and able to
withstand a combination of severe economic shocks without
breaching regulatory thresholds.
The assessment also considered the effects of an intensifying
competitive environment particularly in the context of the
disruption to underlying economic cycles due to COVID-19.
Throughout the year, consideration was given to the likelihood
of a catastrophic cyberattack within the time frame of the
assessment. While NatWest Group operates a multi-layered
system of defences, there is a possibility that a successful
cyberattack could have a severe effect on operations.
However, the evolving threat is continually monitored.
NatWest Group remains prepared and continues to invest
in this area to ensure that it remains robustly protected.
Planning also takes into account a range of correlated
risks in order to ensure that NatWest Group’s strategy
and forecasts remain appropriate for the evolving
environment. During 2021, there was further
management focus on the potential crystallisation of a
severe but plausible combination of both principal risks
and top and emerging risks. Such combinations could
amplify existing risks and adversely affect NatWest
Group’s profitability. The results of these exercises
were considered by the Executive Risk Committee
and form part of NatWest Group’s forward-looking
risk management activity.
While considering both near-term and medium-term
risks in its assessment – and given the increased
uncertainty over longer-term predictions – the Board
noted analysis performed as part of NatWest Group’s
participation in the Bank of England’s CBES test. While
this is a mandatory stress test, the activity supports
NatWest Group in understanding and preparing to
manage risks that could arise, both in terms of the
transition to net zero and the physical risks from
climate change. This included a Group-wide
operational risk scenario, assuming significant business
disruption due to an intense heatwave. Aspects of the
CBES scenarios were also used in the Group’s ICAAP
process and in internal stress tests, particularly in
relation to credit risk.
In drawing its conclusions, the Board also considered
the following:
The Group’s strong capital position (CET1 ratio
of 18.2%–17.8% excluding IFRS 9 transitional relief).
The current capital position provides significant
headroom above both NatWest Group’s minimum
requirements and its MDA threshold requirements;
Its ability to generate capital in recent years;
Its proposed distribution strategy to shareholders;
and
Its strong liquidity position (LCR of 172% at
31 December 2021 and liquidity headroom
of £89.9 billion).
Based on the factors above, the current financial
forecasts, the management of NatWest Group’s
principal risks, including mitigating actions, and the
strength of its capital and liquidity positions, NatWest
Group’s Board has a reasonable expectation that
NatWest Group will be able to continue in operation
and meet its liabilities over the three-year period of
the assessment.
77
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Non-financial information statement
Non-financial
information statement
This non-financial information statement provides an overview of topics and
related reporting references in our external reporting as required by sections
414CA and 414CB of the Companies Act 2006. We integrate non-financial
and Environmental, Social and Governance (ESG) information across the
Strategic report and wider reporting suite, thereby promoting cohesive
reporting of non-financial and ESG matters.
ESG reporting frameworks and guidance
We are actively monitoring developments including in relation
to metrics. In 2021, our focus included the Sustainability
Accounting Standards Board (SASB) standards, the Global
Reporting Initiative (GRI) standards, the Task Force on
Climate-related Financial Disclosures (TCFD) and the World
Economic Forum (WEF) International Business Council (IBC)
metrics. As signatories of the UN Principles for Responsible
Banking, we are committed to an ongoing process to align
our strategy with the 2015 Paris Agreement and the UN
Sustainable Development Goals (SDGs). Our climate
ambition strives to make a positive contribution.
Further information on non-financial and ESG
matters can be found within our reporting suite
Climate-related Disclosures Report
ESG Supplement
natwestgroup.com
Assurance Approach
NatWest Group plc appointed Ernst & Young LLP (EY) to
provide independent assurance over certain sustainability
metrics, indicated with (*) in the NatWest Group’s 2021
Strategic Report, the 2021 Environmental, Social and
Governance (ESG) Supplement, and the 2021 Climate-related
Disclosures Report. The assurance engagement was planned
and performed in accordance with the International Standard
on Assurance Engagements (UK) 3000 (July 2020) Assurance
Engagements Other than Audits or Reviews of Historical
Financial Information (“ISAE (UK) 3000 (July 2020)”). An
assurance report was issued and is available at natwestgroup.
com. This report includes further details on the scope,
respective responsibilities, work performed, limitations
and conclusion.
78
NatWest Group
2021 Annual Report and Accounts
Reporting
requirement
Page references
in this document
Relevant policy
available at
natwestgroup.com
Business model
Our purpose framework
Our strategy
Our strategy in action
Our purpose-led areas of focus
How we create value
Our business performance
12 to 13
18 to 19
20 to 27
30 to 31
34 to 37
38 to 50
Our
stakeholders
Our stakeholders
Section 172(1) statement
Stakeholder focus areas
14 to 17
52 to 53
54 to 63
Environment
Market environment
Climate-related disclosures
Top and emerging risks
Risk overview
Risk factors
32 to 33
64 to 71
75
72 to 75
406 to 426
Environmental, social
and ethical policies
Our colleagues
Colleagues
Approving refreshed values
Diversity and Inclusion
58 to 61
53
59 to 61
Our code of conduct
Governance
Governance at a glance
Section 172(1) statement
Boardroom Inclusion Policy
Corporate governance
Directors’ remuneration report
Report of the directors
80 to 81
52 to 53
114 to 115
102 to 113
136 to 142
184 to 186
Boardroom
Inclusion Policy
Social matters
Market environment
Our strategy in action
Stakeholder focus areas
How we create value
32 to 33
20 to 27
54 to 63
34 to 37
Supplier Charter
Respect for
human rights
Human rights and Modern Slavery
39
Statement on Human
Rights
Anti-bribery
and corruption
(ABC)
Risk overview
Risk and capital management
Mandatory learning for all colleagues
72 to 75
188 to 285
73 to 74
Statement on Anti-
Bribery and Corruption
Risk
management
Risk overview
Top and emerging risks
Risk and capital management
Risk factors
73 to 74
75
188 to 285
406 to 426
Environmental, social
and ethical policies
79
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Governance at a glance
Governance
at a glance
Our Board
The Board has 11 directors comprising the Chairman, two executive directors and eight independent non-executive directors.
Biographies of the directors are available on pages 98 to 101 and at natwestgroup.com.
Board governance framework
The Board is collectively responsible for promoting the long-term success of NatWest Group plc, driving both shareholder value and
contribution to society. To assist in providing effective oversight and leadership, the Board has established the following committees:
NatWest Group plc Board
Group Audit
Committee
see report – page 116
Group Board
Risk Committee
see report – page 124
Group
Nominations and
Governance
Committee
see report – page 114
Group
Performance and
Remuneration
Committee
see report – page 136
Group
Sustainable
Banking
Committee
see report – page 132
Technology
and Innovation
Committee
see report – page 134
The Group CEO has established the Group Executive Committee to support her in discharging her responsibilities in
managing NatWest Group’s businesses day to day.
Further information on our governance structure is available on pages 102 to 187.
Information on how stakeholders have influenced Board discussions and decision-making during 2021 is available in
our section 172(1) statement on pages 52 to 53.
Various corporate documents including our Articles of Association and terms of reference for the Board and Board
Committees are available at natwestgroup.com.
Executive directors
Alison Rose
(Group CEO)
Katie Murray
(Group CFO)
Independent non-
executive directors
Frank Dangeard
Patrick Flynn
Morten Friis
Robert Gillespie
Yasmin Jetha
Mike Rogers
Mark Seligman (Senior
Independent Director)
Lena Wilson
Company Secretary
Jan Cargill
Francesca Barnes, Graham Beale and Ian Cormack are the three additional independent non-executive directors of NatWest
Holdings Limited and also attend NatWest Group plc Board meetings and relevant Board Committee meetings as observers.
Further information can be found in the Corporate governance report on pages 102-113.
Chairman
Howard Davies
80
NatWest Group
2021 Annual Report and Accounts
Board composition
The charts below describe our Board’s composition by gender,
tenure, age, and skills and experience as at 31 December 2021.
Female e
x
ecutive direct
ors: 2
Female non-e
x
ecutive
directors
: 2
Male Chairman +
non-ex
ecutive directors
: 7
Board composition b
y gender
2
2
7
0-3 years
: 2
3-6 years: 6
6-9 years
: 3
Board tenur
e
2
6
3
45-55: 2
56-65: 5
66-75: 4
Board age r
ange
2
5
4
Board diversity and inclusion
The Board operates a Boardroom Inclusion Policy (available
at natwestgroup.com) which reflects the most recent industry
targets and is aligned to the NatWest Group Inclusion Policy
and Principles applying to the wider bank.
Throughout 2021 the Board met the recommendation of the
Parker Review with at least one member of the Board being
of Black, Asian or Minority Ethnic background and it intends
to continue to meet that recommendation (9% of the Board
at the end of 2021).
At the end of 2021 the Board exceeded the recommendation
of the FTSE Women Leaders Review (formerly the Hampton-
Alexander Review) of 33% female representation on the board,
with 36% of the Board being female.
Board skills and experience
The Board is structured to ensure that the directors provide
NatWest Group plc with the appropriate combination of skills,
experience and knowledge as well as independence.
The bar chart opposite is an extract from our Board skills
matrix, which is reviewed by the Group Nominations and
Governance Committee and approved by the Board annually.
The matrix reflects our directors’ self-assessment of the skills
and experience they bring to Board discussions, in line with
pre-determined criteria aligned to current and future
strategic priorities.
The 2021 external Board evaluation did not identify any
immediate or material gaps in Board skills and experience,
however it was acknowledged that the Board would benefit
from additional technology expertise. The Board and Group
Nominations and Governance Committee will continue to
keep Board skills and composition under review during 2022.
UK Corporate Governance Code
Throughout 2021, NatWest Group plc applied the principles
and complied with all of the provisions of the 2018 UK
Corporate Governance Code with the following exceptions:
Provision 17 – that the Group Nominations and Governance
Committee should ensure plans are in place for orderly
succession to both the board and senior management
positions, and oversee the development of a diverse
pipeline for succession; and
Provision 33 – that the Group Performance and
Remuneration Committee should have delegated
responsibility for setting remuneration for the Chairman
and executive directors.
The Board considers these are matters that should be reserved
for the Board.
Our full 2018 UK Corporate Governance Code compliance
statement is available on page 181.
Our full Corporate governance report is available on pages 102
to 187 and includes our Board Committee reports, the Directors’
remuneration report and the Report of the directors.
Board skills and e
xp
erience
Skills and experience
Number of directors
0
2
4
6
11
10
8
Risk management
Broad Financial Services
T
ransformation
Financial Mark
ets / Inves
tment Banking
Environment
al, Social and Governanc
e (incl climate)
CEO / Senior Executiv
e Management
Customer e
xperience
Government / r
egulatory / public sector
Retail / C
ommercial / Private Banking
Digital and Innov
ation
CFO / A
ccountant
T
echnology (infrastructure, cyber)
81
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Financial review
Chief Financial
Officer’s
review
84
Financial summary
86
Summary consolidated balance sheet
87
Segment summary income statements
88
Segment performance
95
Summary financial statements
We have delivered a strong operating
performance in 2021.
Group RoTE was 9.4%, benefiting from a £1.3 billion net
impairment release. We achieved our Group cost reduction
target of 4.0% and lending growth across our UK and RBSI
retail and commercial businesses was 2.6%, excluding UK
Government financial support schemes.
Our capital and liquidity position remains strong after
returning £3.8 billion to shareholders, and default levels
have remained low across all our portfolios. The CET1 ratio
was 18.2%, reducing to 15.9% on 1 January 2022 following
regulatory RWA and capital changes. We have made good
progress on our phased withdrawal from the Republic of
Ireland and will focus the financial commentary below on
the Group excluding Ulster Bank RoI (Go-forward group).
Total income, excluding notable items, in the Go-forward
group was 5.6% lower than prior year. Across the UK and
RBSI retail and commercial businesses income increased by
1.4% reflecting strong balance sheet growth, principally in our
mortgage book. NWM income was below expectations, down
by 61.5%, compared with 2020, reflecting continued weakness
in Fixed Income, impacted by subdued levels of customer
activity and ongoing reshaping of the business, and
exceptional levels of market activity in the prior year.
Bank NIM
(1)
of 2.39% was 7 basis points lower than 2020
impacted by reduced structural hedge income, yield curve
movements and lower unsecured balances.
We delivered a cost reduction of £256 million, or 4.0%, in 2021,
in line with our target for the year. This has been achieved
by transformation across our customer journeys and NWM
business, in line with the strategic announcement made
in February 2020 and a £68 million reduction in the bank
levy charge.
A net impairment release of £1,278 million reflects the low
levels of realised losses we have seen across the year. Total
impairment provisions reduced by £2.4 billion to £3.8 billion
during 2021 and as a result ECL coverage ratio decreased
from 1.66% to 1.03%.
We are pleased to report a 2021 attributable profit of £2,950
million, with earnings per share of 25.4 pence and a RoTE
of 9.4%.
A final dividend of 7.5 pence per share is proposed, bringing
our total 2021 paid and proposed capital distributions to £3.8
billion through a combination of ordinary dividends, directed
buybacks of the UK Government stake and our on-market
buyback programme.
Across the UK and RBSI retail and commercial businesses,
and excluding UK Government support schemes, net lending
increased by 2.6%. Mortgage growth exceeded the market,
however commercial lending was behind market as we have
sought to reduce certain exposures, through targeted sector
reductions and capital actions, whilst continuing to focus on
supporting customers through sustainable lending.
Customer deposits in the Go-forward group increased by
£49.3 billion, or 12.0%, in 2021 including £9.4 billion related
to Treasury repo activity. Across the UK and RBSI retail and
commercial businesses customer deposits increased by 10.0%,
as customers continued to build and retain liquidity.
Katie Murray
Chief Financial Officer
82
NatWest Group
2021 Annual Report and Accounts
Continuing operations
Two legally binding agreements for the sale of the UBIDAC business were announced in 2021 as part of the phased withdrawal from the Republic
of Ireland: the sale of commercial lending to Allied Irish Banks p.l.c. (AIB) and the performing non-tracker mortgages, performing micro-SME
loans, UBIDAC’s asset finance business and 25 of its branch locations to Permanent TSB p.l.c (PTSB).
The business activities relating to these sales that meet the requirements of IFRS 5 are presented as a discontinued operation and as a disposal
group on 31 December 2021.
The Financial review presents the results of the Group’s continuing operations. For further details refer to Note 8 Discontinued operations and
assets and liabilities of disposal groups in the Notes to the consolidated financial statements.
Year ended
2021
£m
2020
(1)
£m
Variance
£m
Continuing operations
Go-forward group income
(2,3)
10,284
10,286
(2)
Total income
10,512
10,508
4
Operating expenses
(7,758)
(7,858)
(100)
Profit before impairment releases/(losses)
2,754
2,650
104
Operating profit/(loss) before tax
4,032
(481)
4,513
Profit/(loss) attributable to ordinary shareholders
2,950
(753)
3,703
Excluding notable items within total income
(4)
Go-forward group income excluding notable items
(2,3)
10,074
10,670
(596)
Total income excluding notable items
(3)
10,267
10,892
(625)
Operating expenses
(7,758)
(7,858)
100
Profit before impairment releases/(losses) excluding notable items
2,509
3,034
(525)
Operating profit/(loss) before tax excluding notable items
3,787
(97)
3,884
UK and RBSI retail and commercial businesses income excluding notable items
(3)
9,620
9,486
134
Performance key metrics and ratios
Bank net interest margin
(3,5)
2.39%
2.46%
(0.07%)
Bank average interest earning assets
(3,5)
£314bn
£301bn
£13bn
Cost:income ratio
(3)
73.4%
74.4%
(1.1%)
Loan impairment rate
(3)
(35bps)
85bps
(120bps)
Total earnings per share attributable to ordinary shareholders – basic
25.4p
(6.2p)
31.6p
Go-forward group return on tangible equity
(2)
10.0%
(1.3%)
11.3%
Return on tangible equity
(3)
9.4%
(2.4%)
11.8%
Balance sheet
Go-forward group customer deposits
(2,3)
£461.4bn
£412.1bn
£49.3bn
UK and RBSI retail and commercial net lending excluding UK Government support schemes
(3)
£305.7bn
£297.9bn
£7.8bn
Capital, liquidity and funding
Common Equity Tier (CET1) ratio
(6)
18.2%
18.5%
(0.3%)
Risk-weighted assets (RWAs)
£157.0bn
£170.3bn
(£13.3bn)
Liquidity coverage ratio (LCR)
172%
165%
7%
Total wholesale funding
(3)
£77bn
£71bn
£6bn
Tangible net asset value (TNAV) per ordinary share
(3)
272p
261p
11p
(1)
Comparative results have been re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the consolidated
financial statements.
(2)
Go-forward group excludes Ulster Bank RoI and discontinued operations.
(3)
Refer to the Non-IFRS financial measures section for details of the basis of preparation and reconciliation of non-IFRS financial measures.
(4)
Refer to page 84 for details of notable items within total income.
(5)
NatWest Group excluding NatWest Markets, Ulster Bank RoI and liquid asset buffer.
(6)
Based on CRR end-point including the IFRS 9 transitional adjustment of £0.6 billion (31 December 2020 – £1.7 billion). Excluding this adjustment, the CET1 ratio would be 17.8%
(31 December 2020 – 17.5%.)
TNAV per share increased by 3 pence in the quarter to 272
pence largely reflecting the attributable profit partially offset
by movements in the cash flow hedging reserve.
Capital, funding and liquidity
The CET1 ratio remains strong at 18.2%, or 17.8% excluding
IFRS 9 transitional relief. The 30 basis points reduction in the
year includes capital distributions of c.240 basis points, partially
offset by the reduction in RWAs, c.170 basis points, and the
attributable profit net of IFRS 9 transitional relief and other
capital movements. RWAs of £157.0 billion reduced by £13.3
billion in 2021 mainly reflecting business movements in
Commercial Banking, including targeted sector reductions,
improvement in risk parameters and active capital management.
On 1 January 2022, the proforma CET1 ratio was 15.9%
including the impact of regulatory RWA inflation, 200 basis
points, the removal of the software development costs capital
benefit, 20 basis points, and the tapering of IFRS 9 transitional
relief, 10 basis points. RWAs increased by £18.8 billion,
including £14.8 billion associated with mortgage risk
weight changes.
The liquidity coverage ratio (LCR) of 172%, representing £89.9
billion headroom above 100% minimum requirement, increased
by 7 percentage points compared with 2020. Total wholesale
funding increased by £6.0 billion in the year to £76.7 billion.
(1)
Excludes NatWest Markets, liquid asset buffer and Ulster Bank RoI.
83
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Financial review continued
N
N
a
a
t
t
W
W
e
e
s
s
t
t
G
G
r
r
o
o
u
u
p
p
Annual Report and Accounts 2021
84
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Financial summary
2021
2020
(1)
Variance
Income -
Continuing operations
£m
£m
£m
%
Interest receivable
(2)
9,313
9,798
(485)
(4.9)
Interest payable
(2)
(1,699)
(2,322)
623
(26.8)
Net interest income
7,614
7,476
138
1.8
Net fees and commissions
2,124
2,000
124
6.2
Income from trading activities
323
1,125
(802)
(71.3)
Other non-interest income
451
(93)
544
nm
Non-interest income
2,898
3,032
(134)
(4.4)
Total income
10,512
10,508
4
nm
Go-forward group income excluding notable items
(3)
10,074
10,670
(596)
(5.6)
Total income excluding notable items
(3)
10,267
10,892
(625)
(5.7)
Notable items within total income
(3)
Retail Banking
Retail Banking debt sale gain
8
Metro Bank mortgage portfolio acquisition loss
(58)
Private Banking
Consideration on the sale of the Adam & Company investment
management business
54
Commercial Banking
Commercial Banking fair value and disposal loss
(22)
(37)
Commercial Banking tax variable lease repricing
32
NatWest Markets
NatWest Markets asset disposals/strategic risk reduction
(4)
(64)
(83)
Own credit adjustments (OCA)
6
(24)
Central items & other
Share of associate profit/(loss) for Business Growth Fund
219
(22)
Liquidity Asset Bond sale gains
120
113
Loss on redemption of own debt
(138)
(324)
IFRS volatility in Central items & other
(5)
47
83
Property strategy update
(44)
FX recycling loss in Central items & other
(40)
Ulster Bank RoI
Ulster Bank RoI gain arising from the restructuring of structural hedges
35
Total
245
(384)
(1)
Comparative results have been re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the consolidated
financial statements.
(2)
Interest receivable and interest payable on trading assets and liabilities are included in income from trading activities.
(3)
Refer to the Non-IFRS financial measures section for details of the basis of preparation and reconciliation of Non-IFRS financial and performance measures
(4)
Asset disposals/strategic risk reduction in 2020 relates to the cost of exiting positions and the impact of risk reduction transactions entered into, in respect of the strategic
announcement on 14 February 2020.
(5)
IFRS volatility relates to loans which are economically hedged but for which hedge accounting is not permitted under IFRS.
2021 compared with 2020
Total income, excluding notable items, in the Go-forward
group
(1)
was £596 million, or 5.6% lower than prior year.
Across the UK and RBSI retail and commercial businesses
income increased by 1.4% reflecting strong balance sheet
growth, principally in our mortgage book. NWM income was
below expectations, down £757 million, or 61.5% compared
with 2020, reflecting continued weakness in Fixed Income,
impacted by subdued levels of customer activity and
ongoing reshaping of the business, and exceptional levels of
market activity in the prior year.
(1)
Go-forward group excludes Ulster Bank RoI.
(2)
NatWest Group excluding NatWest Markets, liquid asset buffer and Ulster Bank RoI.
Bank NIM
(2)
of 2.39% was 7 basis points lower than 2020
impacted by reduced structural hedge income, yield curve
movements and lower unsecured balances.
Structural hedges of £190 billion generated £1.3 billion of
incremental net interest income for the year, compared
with £1.1 billion of incremental net interest income on a
balance of £159 billion in 2020.
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2021
2020 (1)
Variance
Operating expenses -
Continuing operations
£m
£m
£m
%
Staff expenses
3,265
3,416
(151)
(4.4)
Premises and equipment
1,030
989
41
4.1
Other administrative expenses
1,427
1,535
(108)
(7.0)
Strategic costs
787
1,013
(226)
(22.3)
Litigation and conduct costs
466
113
353
nm
Depreciation and amortisation
783
792
(9)
(1.1)
Operating expenses
7,758
7,858
(100)
(1.3)
Excluding:
Litigation and conduct costs
466
113
353
nm
Strategic costs
787
1,013
(226)
(22.3)
Operating lease depreciation
140
145
(5)
(3.4)
Ulster Bank RoI direct costs
273
239
34
14.2
6,092
6,348
(256)
(4.0)
(1)
Comparative results have been re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the consolidated
financial statements.
2021 compared with 2020
Operating expenses excluding litigation and conduct costs,
strategic costs, operating lease depreciation and Ulster
Bank RoI direct costs decreased by £256 million, or 4.0%, in
line with our target for the year. This has been achieved by
transformation across our customer journeys and NWM
business, in line with the strategic announcement made in
February 2020 and a £68 million reduction in the UK bank
levy charge.
Strategic costs of £787 million included £237 million in NWM
related to transformation, £124 million of redundancy
charges, £88 million of technology spend and an £85 million
goodwill impairment.
Litigation and conduct costs of £466 million represent the
net impact of a number of remediation and litigation
matters concluding. This amount includes penalties
associated with the resolution of FCA’s investigation into
potential breaches of the UK Money Laundering Regulations
2007. Refer to Note 27 for additional information on other
litigation and regulatory matters.
2021
2020
Variance
Impairments -
Continuing operations
(1)
£m
£m
£m
Loans - amortised cost and FVOCI
369,827
372,399
(2,572)
(0.7%)
ECL provisions
3,806
6,186
(2,380)
(38.5%)
ECL provisions coverage ratio (%)
1.03
1.66
(0.6)
(38.0%)
Impairment (releases)/losses
ECL (release)/charge
(2)
(1,278)
3,131
(4,409)
(140.8%)
Amounts written off
876
937
(61)
(6.5%)
(1)
Comparative results have been re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the consolidated
financial statements.
(2)
The table above summarises loans and related credit impairment measured on an IFRS 9 basis. Refer to Credit Risk – Banking activities in the Risk and capital management section
for further details.
2021 compared with 2020
A net impairment release of £1,278 million reflects the low levels of realised losses we have seen across the year. Total
impairment provisions reduced by £2.4 billion to £3.8 billion during 2021 and as a result ECL coverage ratio decreased from
1.66% to 1.03%. Whilst we are comfortable with the strong credit performance of our book, we continue to hold economic
uncertainty post model adjustments (PMA) of £0.6 billion, or 15.3% of total impairment provisions. We will continue to assess
this position throughout the year.
2021
2020 (1)
Tax -
Continuing operations
£m
£m
Tax charge
(996)
(74)
UK corporation tax rate
19.0%
19.0%
Effective tax rate
24.7%
(23.7%)
(1)
Comparative results have been re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the consolidated
financial statements.
2021 compared with 2020
A tax charge of £996 million for the year ended 31 December 2021 arises rather than the expected tax charge of £766 million
based on the UK corporation tax rate of 19%. The higher tax charge reflects the UK banking surcharge, and other non-
deductible items such as UK bank levy. These factors have been partially offset by the impact on the group's UK net deferred
tax asset of the increased tax rate from 1 April 2023, enacted on 10 June 2021. Further details can be found in Note 7 to the
consolidated financial statements.
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Summary consolidated balance sheet as at 31 December 2021
2021
2020
Variance
£m
£m
£m
Assets
Cash and balances at central banks
177,757
124,489
53,268
43%
Trading assets
59,158
68,990
(9,832)
(14%)
Derivatives
106,139
166,523
(60,384)
(36%)
Settlement balances
2,141
2,297
(156)
(7%)
Loans to banks - amortised cost
7,682
6,955
727
10%
Loans to customers - amortised cost
358,990
360,544
(1,554)
(0%)
Other financial assets
46,145
55,148
(9,003)
(16%)
Other assets (including intangible assets)
14,965
14,545
420
3%
Assets of disposal groups
9,015
9,015
nm
Total assets
781,992
799,491
(17,499)
(2%)
Liabilities
Bank deposits
26,279
20,606
5,673
28%
Customer deposits
479,810
431,739
48,071
11%
Settlement balances
2,068
5,545
(3,477)
(63%)
Trading liabilities
64,598
72,256
(7,658)
(11%)
Derivatives
100,835
160,705
(59,870)
(37%)
Other financial liabilities
49,326
45,811
3,515
8%
Subordinated liabilities
8,429
9,962
(1,533)
(15%)
Notes in circulation
3,047
2,655
392
15%
Other liabilities
5,797
6,388
(591)
(9%)
Total liabilities
740,189
755,667
(15,478)
(2%)
Total equity
41,803
43,824
(2,021)
(5%)
Total liabilities and equity
781,992
799,491
(17,499)
(2%)
Tangible net asset value per ordinary share (pence)
(1)
272p
261p
11p
4%
(1)
Tangible net asset value per ordinary share represents tangible equity divided by the number of ordinary shares.
Total assets of £782.0 billion as at 31 December 2021
decreased by £17.5 billion, 2%, compared with 31
December 2020. This was primarily driven by decreases in
derivatives, trading assets and other financial assets
partially offset by cash and balances at central banks.
Cash and balances at central banks increased by £53.3
billion, 43%, to £177.8 billion mainly as a result of a net
customer funding surplus driven by significant deposit
inflows flow in addition to £15.6 billion liquidity and debt
portfolio optimisation activity.
Trading assets decreased by £9.8 billion, 14%, to £59.2
billion mainly driven by reductions in cash collateral and
debt securities. Trading liabilities decreased by £7.7 billion,
11%, to £64.6 billion due to reduction in cash collateral.
Derivative assets decreased £60.4 billion, 36%, to £106.1
billion, and liabilities, decreased by £59.9 billion, 37%, to
£100.8 billion. These movements were driven by a decrease
in underlying volumes due to matured trades and buyouts
exceeding new trades and lower mark-to-market
valuations due to higher interest rates for major currencies
in the year.
Loans to customers - amortised cost, decreased by £1.6
billion, to £359.0 billion including £11.3 billion decrease in
Ulster Bank ROI predominantly due to a reclassification of
banking portfolio loans to assets of disposal groups,
partially offset by an £9.9 billion increase in Retail Banking
driven by strong gross mortgage lending.
Other financial assets, which includes debt securities,
equity shares and other loans, decreased by £9.0 billion,
16%, to £46.1 billion, primarily due to reductions in debt
securities.
Customer deposits increased by £48 billion, 11%, to £479.8
billion including increases of £17.1 billion in Retail Banking,
£10 billion in Commercial Banking and £7.0 billion in Private
Banking as customers retained liquidity in light of the
COVID-19 economic uncertainty. Treasury reflected a £9.4
billion increase in customer facing repos due to prevailing
market conditions.
Other financial liabilities, which includes customer deposits
at fair value through profit and loss and debt securities in
issue, increased by £3.5 billion, 8%, to £49.3 billion.
Subordinated liabilities have decreased by £1.5 billion, 15%,
to £8.4 billion due to redemptions partially offset by new
issuances.
Other liabilities decreased by £0.6 billion, 9%, to £5.8 billion
mainly due to lower lease liabilities in the year.
Owners’ equity decreased by £2.0 billion, 5%, to £41.8
billion, driven by share repurchase, ordinary and paid-in-
equity dividends paid, partially offset by the attributable
profit for the year.
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Segmental summary income statements
Continuing operations
Go-forward group
Total
Central
excluding
Total
Retail
Private
Commercial
RBS
NatWest
items
Ulster
Ulster
NatWest
Banking
Banking
Banking
International
Markets
& other
Bank RoI
Bank RoI
Group
2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
Net interest income
4,074
480
2,582
383
9
(14)
7,514
100
7,614
Non-interest income
371
336
1,293
165
406
199
2,770
128
2,898
Total income
4,445
816
3,875
548
415
185
10,284
228
10,512
Other expenses
(2,250)
(504)
(2,153)
(228)
(907)
(42)
(6,084)
(421)
(6,505)
Strategic costs
(187)
(19)
(93)
(11)
(254)
(201)
(765)
(22)
(787)
Litigation and conduct costs
(76)
3
(108)
(3)
(243)
(427)
(39)
(466)
Operating expenses
(2,513)
(520)
(2,354)
(242)
(1,161)
(486)
(7,276)
(482)
(7,758)
Impairment releases
36
54
1,073
52
35
1,250
28
1,278
Operating profit/(loss)
1,968
350
2,594
358
(711)
(301)
4,258
(226)
4,032
Total income excluding
notable items
4,445
762
3,865
548
473
(19)
10,074
193
10,267
Return on tangible equity
(1)
na
na
na
na
na
na
10.0%
na
9.4%
Return on equity
(2)
26.1%
17.0%
22.0%
22.5%
(13.1%)
nm
nm
nm
na
Cost:income ratio
(1)
56.5%
63.7%
59.3%
44.2%
279.8%
nm
70.3%
nm
73.4%
Customer deposits (£bn)
188.9
39.3
177.7
37.5
2.3
15.7
461.4
18.4
479.8
Average interest
earning assets (£bn)
196.0
27.2
168.1
37.8
32.7
nm
nm
15.9
524.9
Net interest margin
(1)
2.08%
1.76%
1.54%
1.01%
nm
nm
nm
nm
nm
Third party customer
asset rate
(3)
2.66%
2.36%
2.71%
2.26%
nm
nm
nm
nm
nm
Third party customer
funding rate
(3)
(0.06%)
(0.01%)
0.08%
nm
nm
nm
0.02%
nm
2020 (4)
Continuing operations
Net interest income
3,868
489
2,740
371
(57)
(57)
7,354
122
7,476
Non-interest income
313
274
1,218
126
1,180
(179)
2,932
100
3,032
Total income
4,181
763
3,958
497
1,123
(236)
10,286
222
10,508
Other expenses
(2,295)
(466)
(2,261)
(244)
(1,038)
(19)
(6,323)
(409)
(6,732)
Strategic costs
(226)
(15)
(179)
(49)
(267)
(252)
(988)
(25)
(1,013)
Litigation and conduct costs
(19)
26
10
2
(5)
(120)
(106)
(7)
(113)
Operating expenses
(2,540)
(455)
(2,430)
(291)
(1,310)
(391)
(7,417)
(441)
(7,858)
Impairment losses
(792)
(100)
(1,927)
(107)
(40)
(26)
(2,992)
(139)
(3,131)
Operating profit/(loss)
849
208
(399)
99
(227)
(653)
(123)
(358)
(481)
Total income excluding
notable items
4,231
763
3,995
497
1,230
(46)
10,670
222
10,892
Return on tangible equity
(1)
na
na
na
na
na
na
(1.3%)
na
(2.4%)
Return on equity
(2)
10.2%
10.3%
(4.5%)
6.1%
(3.8%)
nm
nm
nm
na
Cost:income ratio
(1)
60.8%
59.6%
59.9%
58.6%
116.7%
nm
71.7%
nm
74.4%
Customer deposits (£bn)
171.8
32.4
167.7
31.3
2.6
6.3
412.1
19.6
431.7
Average interest
earning assets (£bn)
181.4
23.8
163.1
31.7
37.9
nm
nm
16.6
483.7
Net interest margin
(1)
2.13%
2.05%
1.68%
1.17%
nm
nm
nm
nm
nm
Third party customer
asset rate
(3)
2.89%
2.53%
2.86%
2.51%
nm
nm
nm
nm
nm
Third party customer
funding rate
(3)
(0.19%)
(0.11%)
(0.08%)
(0.01%)
nm
nm
nm
(0.04%)
nm
nm = not meaningful
(1)
Refer to the Non-IFRS financial measures section for details of the basis of preparation.
(2)
NatWest Group’s CET1 target is approximately 14% but for the purposes of computing segmental return on equity (ROE), to better reflect the differential drivers of capital usage,
segmental operating profit adjusted for preference share dividends and tax is divided by average notional equity allocated at different rates of 14.5% (Retail Banking), 15.5% (Ulster
Bank RoI), 11.5% (Commercial Banking), 12.5% (Private Banking), 16% (RBS International) and 15% for all other segments, of the period average of segmental risk-weighted assets
equivalents (RWAe) incorporating the effect of capital deductions. NatWest Group return on equity is calculated using profit attributable to ordinary shareholders. Refer to the Non-
IFRS financial measures section for details of the basis of preparation.
(3)
Third party customer asset rate is calculated as annualised interest receivable on third-party loans to customers as a percentage of third-party loans to customers. This excludes
assets of disposal groups, intragroup items, loans to banks and liquid asset portfolios. Third party customer funding rate reflects interest payable or receivable on third-party
customer deposits, including interest bearing and non-interest bearing customer deposits. Intragroup items, bank deposits, debt securities in issue and subordinated liabilities are
excluded from the customer funding rate calculation. Net interest margin is calculated as net interest income as a percentage of the average interest-earning assets, excluding
assets of disposal groups and without these remaining exclusions.
(4)
Comparative results have been re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the consolidated
financial statements.
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Segment performance
Retail Banking
2021
2020
Variance
Income statement
£m
£m
£m
%
Net interest income
4,074
3,868
206
5
Non-interest income
371
313
58
19
Total income
4,445
4,181
264
6
Other expenses
(2,250)
(2,295)
45
(2)
Strategic costs
(187)
(226)
39
(17)
Litigation and conduct costs
(76)
(19)
(57)
300
Operating expenses
(2,513)
(2,540)
27
(1)
Impairment releases/(losses)
36
(792)
828
(105)
Operating profit
1,968
849
1,119
132
Performance ratios
Return on equity
(1)
26.1%
10.2%
15.9%
Net interest margin
2.08%
2.13%
(0.05%)
Cost:income ratio
56.5%
60.8%
(4.3%)
Loan impairment rate
(2bps)
45bps
(47bps)
(1)
Return on equity is based on segmental operating profit after tax adjusted for preference dividends divided by average notional equity based on 14.5% of the period average of
segmental risk-weighted assets incorporating the effect of capital deductions (RWAes), assuming a 28% tax rate.
2021
2020
Variance
Capital and balance sheet
£bn
£bn
£m
%
Loans to customers (amortised cost)
- personal advances
7.1
7.3
(0.2)
(3)
- mortgages
172.8
163.0
9.8
6
- cards
3.8
3.8
Total loans to customers (amortised cost)
183.7
174.1
9.6
6
Loan impairment provisions
(1.5)
(1.8)
0.3
(17)
Net loans to customers (amortised cost)
182.2
172.3
9.9
6
Total assets
210.0
197.6
12.4
6
Customer deposits
188.9
171.8
17.1
10
Risk-weighted assets
36.7
36.7
2021 compared with 2020
In 2021, Retail Banking continued to grow net lending with
an measured approach to risk, delivering a return on equity
of 26.1% and operating profit of £1,968 million. Lending
growth was supported by a strong performance in
mortgages and a return to unsecured lending growth in the
second half of 2021.
Retail Banking completed £1.1 billion of Climate and
Sustainable Funding and Financing in 2021, which will
contribute towards the new NatWest Group target of £100
billion of Climate and Sustainable Funding and Financing
between 1 July 2021 and the end of 2025.
Total income was £264 million, or 6.3%, higher than 2020
reflecting mortgage balance and margin improvement,
higher transactional-related fee income and non-repeat of
loss on acquisition, partially offset by the impact of the
lower interest rate environment on deposit returns, lower
average unsecured balances and the annualised impact of
regulatory changes on fee income.
Net interest margin was 5 basis points lower than 2020
reflecting lower deposit returns and lower average
unsecured balances, partly offset by higher mortgage
margins.
Other expenses decreased by £45 million, or 2.0%,
compared with 2020 primarily reflecting an 8.8% reduction
in headcount as a result of continued customer digital
adoption, automation and improvement of end-to-end
customer journeys, including digitalising the customer
account opening processes, leading to an increase in
straight through processing within journeys from 45% in
December 2020 to 70% in December 2021.
Strategic costs of £117 million in Q4 2021 include an £85
million impairment of goodwill, reflecting a legacy business
in accelerated run down within Retail Banking.
An impairment release of £36 million primarily reflects ECL
provision releases in the non-defaulted portfolio.
Net loans to customers increased by £9.9 billion, or 5.7%,
compared with 2020 as a result of strong gross new
mortgage lending and improved retention. Gross new
mortgage lending was £36.0 billion with flow share of
11.5%, supporting mortgage balance growth of £9.8 billion
or 6.0%, representing a stock share of 11.0%. Cards were
stable however, we have seen improved customer spend
and demand in the second half of 2021. Personal advances
reduced by £0.2 billion as customers made higher overdraft
repayments in H1 2021, reflecting the impact of UK
Government restrictions partly offset by growth in H2 2021
as customer demand for personal loans increased as the
UK economy recovered.
Customer deposits increased by £17.1 billion, or 10.0%,
compared with 2020 as UK Government schemes combined
with Covid related restrictions resulted in lower customer
spend and increased savings in H1 2021.
RWAs were broadly stable compared with 2020 primarily
reflecting lending growth, offset by continued quality
improvements.
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Segment performance
continued
Private Banking
2021
2020
Variance
Income statement
£m
£m
£m
%
Net interest income
480
489
(9)
(2)
Non-interest income
336
274
62
23
Total income
816
763
53
7
Other expenses
(504)
(466)
(38)
8
Strategic costs
(19)
(15)
(4)
27
Litigation and conduct costs
3
26
(23)
(88)
Operating expenses
(520)
(455)
(65)
14
Impairment releases/(losses)
54
(100)
154
(154)
Operating profit
350
208
142
68
Performance ratios
Return on equity
(1)
17.0%
10.3%
6.7%
Net interest margin
1.76%
2.05%
(0.29%)
Cost:income ratio
63.7%
59.6%
4.1%
Loan impairment rate
(29bps)
58bps
(87bps)
(1)
Return on equity is based on segmental operating profit after tax adjusted for preference dividends divided by average notional equity based on 12.5% of the period average of
segmental risk-weighted assets incorporating the effect of capital deductions (RWAes), assuming a 28% tax rate.
2021
2020
Variance
Capital and balance sheet
£bn
£bn
£m
%
Loans to customers (amortised cost)
- personal
2.3
2.2
0.1
5
- mortgages
11.8
10.7
1.1
10
- other
4.4
4.2
0.2
5
Total loans to customers (amortised cost)
18.5
17.1
1.4
8
Loan impairment provisions
(0.1)
(0.1)
Net loans to customers (amortised cost)
18.4
17.0
1.4
8
Total assets
29.9
26.2
3.7
14
Assets under management (AUMs)
(2)
30.2
27.0
3.2
12
Assets under administration (AUAs)
(2)
5.4
5.1
0.3
6
Assets under management and administration (AUMA)
(2)
35.6
32.1
3.5
11
Customer deposits
39.3
32.4
6.9
21
Loan:deposit ratio
47%
52%
(5%)
(10)
Risk-weighted assets
11.3
10.9
0.4
4
(2)
The definition of AUMs/AUAs has been updated to provide clarity on assets where the investment management is undertaken by Private Banking. AUMs now comprises assets
where the investment management is undertaken by Private Banking irrespective of the franchise the customer belongs to. AUAs now comprises third party assets held on an
execution-only basis in custody. Total AUMA remain as before.
2021 compared with 2020
In 2021, Private Banking delivered strong growth across
AUMA, lending and deposits which has supported a 2021
return on equity of 17.0% and operating profit of £350
million. Digital net new money across NatWest Invest, Royal
Bank Invest and Coutts Invest of £0.8 billion in 2021 is more
than double 2020. Approximately 2,114 new customers
were onboarded into Private Banking, an increase of
around 29% compared to 2020.
NatWest Group completed the sale of Adam & Company’s
investment management business on 1 October 2021 for a
total consideration of £54 million, which has been recorded
as a notable item in the Q4 2021 results.
Total income was £53 million, or 6.9%, higher than 2020
reflecting a £54 million consideration from the sale of the
Adam & Company investment management business in Q4
2021 and strong balance growth partially offset by lower
deposit returns in a lower interest rate environment.
Net interest margin decreased by 29 basis points reflecting
lower deposit returns and higher liquidity portfolio costs.
Other expenses were £38 million, or 7.9%, higher than 2020
principally due to investment in digital infrastructure and an
increase in headcount related to the enhancement of AUMA
growth propositions.
A net impairment release of £54 million in 2021 mainly
reflects ECL provision releases in non-default portfolios.
Net loans to customers increased by £1.4 billion, or 8.2%,
compared with 2020 driven by continued strong mortgage
lending growth of £1.1 billion or 10.3%, including gross new
lending of £3.3 billion. RWAs increased by £0.4 billion, or
3.7%.
Customer deposits increased by £6.9 billion, or 21.3%,
compared with 2020 reflecting strong personal and
commercial inflows as UK Government restrictions resulted
in clients continuing to build and retain liquidity.
AUMAs increased by £3.5 billion, or 10.9%, driven by an
increase in AUM net new money (NNM) of £3.0 billion and
AUM positive investment performance of £2.1 billion,
partially offset by the £1.8 billion impact of the sale of Adam
& Company’s investment management business and £0.2
billion EEA resident client outflows following the UK’s exit
from the EU. AUM NNM of £3.0 billion represents 9.3% of
opening AUMAs, which is double NNM in 2020.
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Commercial Banking
2021
2020
Variance
Income statement
£m
£m
£m
%
Net interest income
2,582
2,740
(158)
(6)
Non-interest income
1,293
1,218
75
6
Total income
3,875
3,958
(83)
(2)
Other expenses (excluding operating lease depreciation)
(2,013)
(2,116)
103
(5)
Strategic costs
(93)
(179)
86
(48)
Litigation and conduct costs
(108)
10
(118)
(1,180)
Operating expenses
(2,354)
(2,430)
76
(3)
Impairment releases/(losses)
1,073
(1,927)
3,000
(156)
Operating profit/(loss)
2,594
(399)
2,993
(750)
Performance ratios
Return on equity
(1)
22.0%
(4.5%)
26.5%
Net interest margin
1.54%
1.68%
(0.14%)
Cost:income ratio
59.3%
59.9%
(0.6%)
Loan impairment rate
(104bps)
173bps
(277bps)
(1)
Return on equity is based on segmental operating profit after tax adjusted for preference dividends divided by average notional equity based on 11.5% of the period average of
segmental risk-weighted assets incorporating the effect of capital deductions (RWAes), assuming a 28% tax rate.
2021
2020
Variance
Capital and balance sheet
£bn
£bn
£m
%
Loans to customers (amortised cost)
- business banking
14.3
13.5
0.8
6
- SME & mid corporates
34.6
32.4
2.2
7
- specialised business
15.5
14.8
0.7
5
- large corporates & institutions
(1)
18.8
21.4
(2.6)
(12)
- real estate
(2)
18.6
21.5
(2.9)
(13)
- commercial - EU divestment
(3)
5.9
(5.9)
(100)
- other
(4)
0.9
1.6
(0.7)
(44)
Total loans to customers (amortised cost)
102.7
111.1
(8.4)
(8)
Loan impairment provisions
(1.5)
(2.9)
1.4
(48)
Net loans to customers (amortised cost)
101.2
108.2
(7.0)
(6)
Total assets
184.6
187.4
(2.8)
(1)
Customer deposits
177.7
167.7
10.0
6
Loan:deposit ratio
57%
65%
(8%)
(12)
Risk-weighted assets
66.4
75.1
(8.7)
(12)
(1)
Segment reporting for income, impairments and loans to customers for large corporates & institutions (LC&I) includes the Western European business segment.
(2)
Real estate includes commercial real estate and housing associations.
(3)
EU Divestment balances from Q2 2021 integrated within business banking (Q3 2020 - £0.9 billion, Q4 2020 - £1.1 billion) and SME & mid corporates (Q3 2020 - £5.0 billion, Q4 2020
- £4.8 billion), as the Incentivised Switching Scheme (ISS) closed at the end of June 2021.
(4)
Other includes shipping and project finance.
2021 compared with 2020
Commercial Banking delivered a resilient performance with
a return on equity of 22.0% and operating profit of £2,594
million including a £1,073 million impairment release as the
UK economy continued to recover. Returns have improved
through active capital management, pricing discipline, and
a targeted sector strategy linked to our purpose.
Growth in Tyl, our innovative merchant acquiring platform
saw over £1.5 billion of transactions in 2021, three times
2020 levels, as transaction activity recovered and
customers favoured digital payment solutions and reduced
their reliance on cash and branch.
Commercial Banking completed £5.2 billion of Climate and
Sustainable Funding and Financing in 2021, including £2.7
billion in H2 2021 which will contribute towards the new
NatWest Group target of £100 billion between 1 July 2021
and the end of 2025.
Total income was £83 million, or 2.1%, lower than 2020 due
to reduced deposit returns in a low interest rate
environment and lower lending volumes, partially offset by
a recovery in transactional banking fee income in H2 2021
driven by the UK economy.
Net interest margin decreased by 14 basis points in 2021
reflecting lower deposit returns.
Other expenses, excluding OLD, decreased by £103 million,
or 4.8%, compared with 2020 reflecting cost efficiencies and
simplifying our operating model enabling better service to
our customers including building momentum in our digital
service, whilst reducing our headcount by 9.8%.
Impairment release of £1,073 million primarily reflects ECL
provision releases related to the improved economic outlook
with Stage 3 defaults remaining at low levels.
Net loans to customers decreased by £7.0 billion, or 6.4%,
compared with 2020 primarily reflecting and targeted
sector reductions including real estate, retail and leisure
and active capital management of £1.0 billion. Customer
liquidity resulted in net revolving credit facility (RCF)
repayments of £1.7 billion driven by large corporates &
institutions and real estate as well as UK Government
financial support scheme repayments of £1.3 billion. RCF
utilisation was approximately 19% of committed facilities in
2021, significantly below pre-COVID-19 levels of
approximately 27%. These items were partially offset by
£1.4 billion lower loan provisions and growth in specialist
businesses of £0.7 billion.
Customer deposits increased by £10.0 billion, or 6.0%,
compared with 2020 reflecting customer behaviour to build
and retain liquidity.
RWAs decreased by £8.7 billion, or 11.6%, compared with
2020 mainly reflecting business movements including
targeted sector reductions in real estate and retail,
improvement in risk parameters and active capital
management of £1.5 billion.
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Segment performance
continued
RBS International
2021
2020
Variance
Income statement
£m
£m
£m
%
Net interest income
383
371
12
3
Non-interest income
165
126
39
31
Total income
548
497
51
10
Other expenses
(228)
(244)
16
(7)
Strategic costs
(11)
(49)
38
(78)
Litigation and conduct costs
(3)
2
(5)
(250)
Operating expenses
(242)
(291)
49
(17)
Impairment releases/(losses)
52
(107)
159
(149)
Operating profit
358
99
259
262
Performance ratios
Return on equity
(1)
22.5%
6.1%
16.4%
Net interest margin
1.01%
1.17%
(0.16%)
Cost:income ratio
44.2%
58.6%
(14.4%)
Loan impairment rate
(33bps)
80bps
(113bps)
(1)
Return on equity is based on segmental operating profit after tax adjusted for preference dividends divided by average notional equity based on 16% of the period average of
segmental risk-weighted assets incorporating the effect of capital deductions (RWAes), assuming a 17.5% (14% prior to Q1 2021) tax rate.
2021
2020
Variance
Capital and balance sheet
£bn
£bn
£m
%
Loans to customers (amortised cost)
- corporate
12.7
10.4
2.3
22
- mortgages
2.4
2.5
(0.1)
(4)
- other
0.5
0.5
Total loans to customers (amortised cost)
15.6
13.4
2.2
16
Loan impairment provisions
(0.1)
(0.1)
Net loans to customers (amortised cost)
15.5
13.3
2.2
17
Total assets
40.6
34.0
6.6
19
Customer deposits
37.5
31.3
6.2
20
Risk-weighted assets
7.5
7.5
Depositary assets
(1)
479.4
427.5
51.9
12
(1)
Assets held by RBSI as an independent trustee and in a depositary service capacity.
2021 compared with 2020
During 2021 RBS International (RBSI) delivered £358 million
of operating profit with return on equity of 22.5% through
strong lending and deposit volumes, an impairment release
and continued growth in our depositary offering. This was
achieved while continuing investment in our digital offering
to customers including new payment features on the mobile
app for both personal and business customers and the
extension of our video banking proposition delivered in 2021.
RBSI completed £1.5 billion of Climate and Sustainable
Funding and Financing in 2021, including £0.9 billion in H2
2021 which will contribute towards the new NatWest Group
target of £100 billion between 1 July 2021 and the end of
2025.
Total income increased by £51 million, or 10.3%, compared
with 2020 as a result of higher average lending balances in
Institutional Banking, including higher non-utilisation fees,
and higher depositary fee income.
Net interest margin decreased by 16 basis points in 2021
reflecting a higher proportion of lower yielding assets with
central banks due to the higher volume of short term
customer deposits in the year.
Other expenses decreased by £16 million, or 6.6%,
compared with 2020 primarily reflecting the reduction in the
bank levy charge for 2021.
An impairment release of £52 million in 2021 largely reflects
releases across Stage 1 and 2 within the wholesale sector.
Net loans to customers increased by £2.2 billion, or 16.5%,
compared with 2020 as a result of higher Institutional
Banking sector volumes.
Customer deposits increased by £6.2 billion, or 19.8%,
compared with 2020 as a result of higher call balances in
the Institutional Banking sector throughout the year.
Depositary assets were £51.9 billion, or 12.1%, higher than
2020 reflecting strong performance in the funds sector
primarily in the UK.
RWAs of £7.5 billion are broadly stable compared with 2020
as a result of lending volume growth primarily in the
Institutional Banking sector, offset by model updates in the
period.
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continued
NatWest Markets
(1)
2021
2020
Variance
Income statement
£m
£m
£m
%
Net interest income
9
(57)
66
(116)
Non-interest income
406
1,180
(774)
(66)
Total income
415
1,123
(708)
(63)
Other expenses
(907)
(1,038)
131
(13)
Strategic costs
(254)
(267)
13
(5)
Litigation and conduct costs
(5)
5
(100)
Operating expenses
(1,161)
(1,310)
149
(11)
Impairment releases/(losses)
35
(40)
75
(188)
Operating loss
(711)
(227)
(484)
213
Analysis of income by product
(2)
Fixed income
(64)
518
(582)
(112)
Currencies
427
583
(156)
(27)
Capital Markets
336
384
(48)
(13)
Capital Management Unit & other
(29)
(62)
33
(53)
Income before revenue share paid, asset disposals and OCA
670
1,423
(753)
(53)
Revenue share with other NatWest Group segments
(197)
(193)
(4)
2
Income excluding asset disposals and OCA
473
1,230
(757)
(62)
Asset disposals/strategic risk reduction
(3)
(64)
(83)
19
(23)
Own credit adjustments (OCA)
6
(24)
30
(125)
Total income
415
1,123
(708)
(63)
Performance ratios
Return on equity
(4)
(13.1)%
(3.8)%
(9.3)%
Cost:income ratio
279.8%
116.7%
163.1%
2021
2020
Variance
Capital and balance sheet
£bn
£bn
£bn
%
Loans to customers (amortised cost)
7.5
8.4
(0.9)
(11)
Total assets
200.7
270.1
(69.4)
(26)
Funded assets
96.1
105.9
(9.8)
(9)
Risk-weighted assets
24.2
26.9
(2.7)
(10)
(1)
The NatWest Markets operating segment is not the same as the NatWest Markets Plc legal entity (NWM Plc) or group (NWM or NWM Group) because the NatWest Markets segment
excludes the Central items & other segment.
(2)
Product performance includes gross income earned on a group-wide basis, including amounts contributed to other segments.
(3)
Asset disposals/strategic risk reduction relates to the cost of exiting positions, which includes changes in carrying value to align to the expected exit valuation, and the impact of risk
reduction transactions entered into, in respect of the strategic announcement on 14 February 2020.
(4)
Return on equity is based on segmental operating profit after tax adjusted for preference dividends divided by average notional equity based on 15% of the period average of
segmental risk-weighted assets incorporating the effect of capital deductions (RWAe), assuming a 28% tax rate.
2021 compared with 2020
NatWest Markets has supported its customers’ evolving
needs with innovative solutions and continued to deliver a
more integrated customer proposition across NatWest
Group. NatWest Markets has made good progress on
building a refocused, sustainable business from which it can
grow. NatWest Markets incurred an operating loss in 2021
but has largely completed its RWA reduction and
continued
to reduce operating expenses, and in Q4 2021, introduced
changes to Rates which will improve the strategic alignment
with the rest of the business and drive income growth.
NatWest Markets performance at the beginning of 2022 has
been in line with expectations.
NatWest Markets completed £9.7 billion of Climate and
Sustainable Funding and Financing in 2021, including £3.3
billion in H2 2021 which will contribute towards the new
NatWest Group target of £100 billion between 1 July 2021
and the end of 2025.
Income excluding asset disposals/strategic risk reduction
and OCA was £757 million, or 61.5% lower than 2020. The
performance of Fixed Income was weak in 2021 impacted
by subdued levels of customer activity and the reshaping of
the business, in contrast to the prior year which benefitted
from exceptional levels of market activity generated by the
initial spread of the COVID-19 virus. Both Currencies and
Capital Markets income were lower than in 2020 but
performed broadly in line with expectations.
Other expenses decreased by £131 million, or 12.6%,
compared with 2020 reflecting continued reductions in line
with the strategic announcement in February 2020.
A net impairment release of £35 million in 2021 reflects
releases against a number of cases throughout the year.
RWAs decreased by £2.7 billion, or 10.0%, compared with
2020 reflecting lower levels of market risk and counterparty
credit risk, including the impact of capital optimisation
actions taken throughout the year.
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Segment performance continued
Ulster Bank RoI
Continuing operations
2021
2020 (1)
Variance
2021
2020 (1)
Variance
Income statement
€m
€m
€m
%
£m
£m
£m
%
Net interest income
116
137
(21)
(15)
100
122
(22)
(18)
Non-interest income
149
113
36
32
128
100
28
28
Total income
265
250
15
6
228
222
6
3
Other expenses
(487)
(462)
(25)
5
(421)
(409)
(12)
3
Strategic costs
(25)
(28)
3
(11)
(22)
(25)
3
(12)
Litigation and conduct costs
(45)
(8)
(37)
463
(39)
(7)
(32)
457
Operating expenses
(557)
(498)
(59)
12
(482)
(441)
(41)
9
Impairment releases/(losses)
33
(157)
190
(121)
28
(139)
167
(120)
Operating loss
(259)
(405)
146
(36)
(226)
(358)
132
(37)
Average exchange rate
- €/£
1.163
1.125
(1)
Comparative results have been re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the consolidated
financial statements.
2021
2020
Variance
2021
2020
Variance
Capital and balance sheet
€bn
€bn
€bn
%
£bn
£bn
£m
%
Loans to customers (amortised cost)
- mortgages
7.3
15.2
(7.9)
(52)
6.2
13.7
(7.5)
(55)
- other lending
1.1
5.7
(4.6)
(81)
1.0
5.1
(4.1)
(80)
Total loans to customers (amortised
cost)
8.4
20.9
(12.5)
(60)
7.2
18.8
(11.6)
(62)
Loan impairment provisions
(0.5)
(0.9)
0.4
(44)
(0.5)
(0.8)
0.3
(38)
Net loans to customers (amortised
cost)
7.9
20.0
(12.1)
(61)
6.7
18.0
(11.3)
(63)
Total assets
27.2
29.6
(2.4)
(8)
22.8
26.6
(3.8)
(14)
Funded assets
27.2
29.6
(2.4)
(8)
22.8
26.6
(3.8)
(14)
Customer deposits
21.9
21.8
0.1
0.5
18.4
19.6
(1.2)
(6)
Risk-weighted assets
10.9
13.2
(2.3)
(17)
9.1
11.8
(2.7)
(23)
Spot exchange rate - €/£
1.190
1.113
2021 compared with 2020
Ulster Bank RoI continues to make progress on its phased
withdrawal from the Republic of Ireland. On 17 December
2021 UBIDAC entered a legally binding agreement with
Permanent TSB p.l.c. (PTSB) for the proposed sale of
approximately €7.6 billion of gross performing loans as at
30 June 2021, comprising performing non-tracker
mortgages, performing loans in the micro-SME business,
the UBIDAC Asset Finance business, including its digital
platform, and 25 Ulster Bank branch locations. Completion
of the sale is subject to obtaining competition, regulatory
and other approvals, including PTSB's holding company
shareholder approval, and other conditions being satisfied.
The transaction is expected to occur in phases between Q4
2022 and Q1 2023 with the majority of loans expected to
transfer by Q4 2022.
Progress continues with Allied Irish Banks, p.l.c. (AIB) for
the transfer of approximately €4.2 billion, plus up to €2.8
billion of undrawn exposures, of performing commercial
lending. A key part of the process is to complete the
regulatory approvals and the Competition and Consumer
Protection Commission (CCPC) has already carried out an
extended preliminary investigation and on 31 December
2021 announced its decision to carry out a Phase 2
investigation into the proposed sale. There is no firm date
for the completion of this process. Discussions are ongoing
with other counterparties about their potential interest in
other parts of the bank.
The values shown above represent the continuing
operations of Ulster Bank RoI, including re-presented
comparatives for the income statement. The re-
presentation is in accordance with IFRS 5 ‘Non-current
Assets Held for Sale and Discontinued Operations’.
Total income was €15 million, or 6.0%, higher than 2020
reflecting gains arising from the adjustment of the swap
hedging portfolio to align the modelled maturity position of
deposits and other balances to the withdrawal plan, offset
by lower lending levels and fee income as a result of the
decision to withdraw from the RoI market.
Other expenses were €25 million, or 5.4%, higher than
2020, due to higher VAT costs and regulatory levies,
partially offset by a 15% reduction in headcount, lower
advertising spend and back office operational costs.
A net impairment release of €33 million in 2021 reflects
improvements in the reducing loan portfolios and economic
forecasts.
Net loans to customers decreased by €12.1 billion primarily
due to the reclassification of €10.7 billion of loans to the
disposal group.
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Central items & other
2021
2020
Variance
£m
£m
£m
%
Central items not allocated
(301)
(653)
352
(54)
Funding and operating costs have been allocated to operating segments based on direct service usage, the requirement for market
funding and other appropriate drivers where services span more than one segment. Residual unallocated items relate to volatile
corporate items that do not naturally reside within a segment.
2021 compared with 2020
Central items not allocated represented a £301 million operating loss in 2021 principally reflecting litigation and conduct
charges of £243 million, strategic costs of £201 million and losses on redemption of own debt of £138 million related to the
repurchase of legacy instruments, partially offset by a £219 million share of gains under equity accounting for Business Growth
Fund, and other Treasury income. 2020 included the day one loss on redemption of own debt of £324 million related to the
repurchase of legacy instruments, property-related strategic costs and litigation and conduct charges.
94
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2021 Annual Report and Accounts
Financial review continued
N
N
a
a
t
t
W
W
e
e
s
s
t
t
G
G
r
r
o
o
u
u
p
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Annual Report and Accounts 2021
95
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Summary financial statements
NatWest Group’s financial statements are prepared in accordance with IFRS. Selected data under IFRS for each of the last three
years is presented below.
2021
2020
(1)
2019
(1)
Summary consolidated income statement
£m
£m
£m
Net interest income
7,614
7,476
7,799
Non-interest income
2,898
3,032
6,188
Total income
10,512
10,508
13,987
Operating expenses
(7,758)
(7,858)
(9,280)
Profit before impairment losses
2,754
2,650
4,707
Impairment releases/(losses)
1,278
(3,131)
(724)
Operating profit/(loss) before tax
4,032
(481)
3,983
Tax charge
(996)
(74)
(439)
Profit/(loss) from continuing operations
3,036
(555)
3,544
Profit from discontinued operations, net of tax
276
121
256
Profit/(loss) for the year
3,312
(434)
3,800
Attributable to:
Ordinary shareholders
2,950
(753)
3,133
Preference shareholders
19
26
39
Paid-in equity holders
299
355
367
Non-controlling interests
44
(62)
261
3,312
(434)
3,800
(1)
Comparative results have been re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the consolidated
financial statements.
2021
2020
2019
Summary consolidated balance sheet
£m
£m
£m
Cash and balances at central banks
177,757
124,489
80,993
Trading assets
59,158
68,990
76,745
Derivatives
106,139
166,523
150,029
Settlement balances
2,141
2,297
4,387
Loans to banks and customers - amortised cost
366,672
367,499
334,501
Other financial assets
46,145
55,148
61,452
Other and intangible assets
14,965
14,545
14,932
Assets of disposal groups
9,015
Total assets
781,992
799,491
723,039
Deposits
506,089
452,345
389,740
Trading liabilities
64,598
72,256
73,949
Settlement balances, derivatives, other financial liabilities and subordinated liabilities
160,658
222,023
206,147
Other liabilities
8,844
9,043
9,647
Owners' equity
41,796
43,860
43,547
Non-controlling interests
7
(36)
9
Total liabilities and equity
781,992
799,491
723,039
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NatWest Group
2021 Annual Report and Accounts
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Financial review
Governance
Risk and capital management
Additional information
Financial statements
Governance
96
NatWest Group
2021 Annual Report and Accounts
96
Governance
98
Our Board
102
Chairman’s introduction
103
Corporate governance
114
Report of the Group Nominations and
Governance Committee
116
Report of the Group Audit Committee
124
Report of the Group Board Risk Committee
132
Report of the Group Sustainable Banking Committee
134
Report of the Technology and Innovation Committee
136
Directors’ remuneration report
158
Annual remuneration report
175
Other remuneration disclosures
181
Compliance report
184
Report of the directors
187
Statement of directors’ responsibilities
97
NatWest Group
2021 Annual Report and Accounts
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Financial review
Governance
Risk and capital management
Additional information
Financial statements
Our
Board
Corporate governance
Howard Davies
Chairman
Alison Rose
Group Chief Executive Officer
Date of appointment:
1 November 2019
Committee memberships
N/A
Contribution to the Board:
Alison has been instrumental in
leading NatWest Group’s progress
and performance as a purpose-led
organisation, since NatWest Group’s
purpose was announced in February 2020.
Having gained a wealth of frontline
banking experience during her 29-year
career with NatWest, Alison brings a
strong customer focus to Board
discussions alongside an essential
stakeholder lens. Alison is a passionate
supporter of diversity and is executive
sponsor for NatWest Group’s
employee-led networks.
Relevant experience:
Having joined as a graduate in 1992,
Alison’s diverse career at NatWest Group
has included a number of senior leadership
roles, including Deputy CEO of NatWest
Holdings; Chief Executive of Commercial &
Private Banking; Head of Europe, Middle
East and Africa, Markets & International
Banking; and Global Head of International
Banking Capital and Balance Sheet. In
2019, Alison was commissioned by the UK
Government to report on the barriers to
women starting businesses. She now
sits on the Rose Review Board and is
responsible for driving forward its
recommendations.
Current external appointments:
Board member of the Institute of
International Finance
Member of the International Business
Council for the World Economic Forum
Trustee of Business in the Community
(BITC) and Chair of the Scottish BITC
Advisory Board
Non-executive director of Great
Portland Estates plc
Director of the Coutts Charitable
Foundation
Member of the UK Government’s Help
to Grow Advisory Council
Date of appointment:
14 July 2015 (Board), 1 September 2015
(Chairman)
Committee memberships
Contribution to the Board:
Howard brings substantial financial
services knowledge and experience to the
Board, together with a deep understanding
of global economic, environmental and
social issues. With extensive board level
experience, Howard draws on his prior
regulatory and supervisory expertise to
contribute both strategic and practical
insights to Board discussions and debate.
Howard is also a highly adept Chairman
with valuable leadership and stakeholder
management skills.
Relevant experience:
Howard has held several regulatory
roles during his career including Chairman
of the UK Financial Services Authority
and Deputy Governor of the Bank of
England. Howard was Director of the
London School of Economics and Political
Science and is also Professor of Practice
at the Paris Institute of Political Studies
(Sciences Po).
Howard has also previously served as a
non-executive director of Morgan Stanley
and Prudential plc, as Chairman of
Phoenix plc and as Chair of the UK
Airports Commission.
Current external appointments:
Chairman of Inigo Limited
Member of the Regulatory and
Compliance Advisory Board of
Millennium Management LLC
Chair of the International Advisory
Council of the China Securities
Regulatory Commission
Member of the International Advisory
Council of the China Banking and
Insurance Regulatory Commission
N
Date of appointment:
1 January 2019
Committee memberships
N/A
Contribution to the Board:
Katie is a Chartered Accountant with
nearly 30 years experience in finance and
accounting gained through several roles
across the financial services industry.
Katie’s deep knowledge and experience
in specialist areas including capital
management, investor relations and
financial planning mean she is well
placed to provide valuable input and
expertise during Board discussions.
Relevant experience:
Katie joined NatWest Group as Director
of Finance in 2015 and was appointed as
Deputy Chief Financial Officer in March
2017. She was appointed as Chief
Financial Officer in January 2019.
Katie was previously the Group Finance
Director for Old Mutual Emerging Markets,
based in Johannesburg (2011 to 2015),
having held various roles across Old
Mutual from 2002. Prior to this Katie
worked at KPMG for 13 years. She is
a member of the Institute of Chartered
Accountants in Scotland.
Current external appointments:
Member of the Money and Pensions
Service Advisory Group
Katie Murray
Group Chief Financial Officer
Board Committees
Group Nominations & Governance Committee
S
Group Sustainable Banking Committee
A
Group Audit Committee
T
Technology and Innovation Committee
Ri
Group Board Risk Committee
Re
Group Performance & Remuneration Committee
Underline indicates Committee Chairman
N
98
NatWest Group
2021 Annual Report and Accounts
Date of appointment:
1 April 2017 (Board), 1 January 2018
(Senior Independent Director)
Committee memberships
Contribution to the Board:
Mark, a former senior investment banker,
brings comprehensive financial services
knowledge and substantial FTSE 100
board experience to the Board. A former
boardroom adviser, Mark contributes
significant banking and corporate
transformation expertise in particular,
alongside a range of customer and
wider stakeholder engagement skills.
Relevant experience:
Mark has held various senior roles at
Credit Suisse/BZW during his executive
career, including Deputy Chairman, CSFB
Europe and Chairman, UK Investment
Banking, CSFB.
Mark has served as a non-executive
director on company boards across a
range of industry sectors, including BG
Group plc, as Senior Independent Director
of Kingfisher plc, and as Deputy Chairman
of G4S plc. He has significant experience
of chairing committees and as a Senior
Independent Director.
Current external appointments:
Non-executive director of
Smiths Group plc
Non-executive director and trustee of
The Brooklands Museum
A
Re
N
Date of appointment:
16 May 2016
Committee memberships
Contribution to the Board:
Frank is a former investment banker
and technology company CEO with
substantial global board expertise.
This broad background enables Frank to
make a valuable contribution to Board
discussions, particularly in relation to
technology, digital and innovation matters.
Frank’s experience also encompasses key
areas including customer experience,
stakeholder engagement, ESG and risk.
In April 2018, Frank assumed the role of
Chairman of NatWest Markets Plc, which
enables him to bring a unique perspective
to Board debate.
Relevant experience:
During his executive career, Frank held
various roles at Thomson S.A., including
Chairman and Chief Executive Officer,
and was Deputy Chief Executive Officer
of France Telecom. Prior to that he was
Chairman of SG Warburg France and
Managing Director of SG Warburg.
Frank has also held a number of non-
executive roles at Crédit Agricole CIB,
EDF, Home Credit, Orange, Sonaecom
SGPS and Arqiva Group Limited. He
was also Deputy Chairman and acting
Chairman of Telenor ASA, an international
media communications group.
Current external appointments:
Chairman of NortonLifeLock Inc.
Non-executive director of IHS
Holding Limited
Chairman of SPEAR Investments I B.V.
Chairman of the Advisory Board of
STJ Advisors
Re
T
Date of appointment:
1 June 2018
Committee memberships
Contribution to the Board:
Patrick contributes significant retail
and commercial banking experience to
the Board, together with a background
in complex organisational restructuring
and technology transformation. This
experience enables Patrick to provide
insightful contributions to Board
discussions on complex matters,
alongside his significant financial
knowledge and expertise.
Relevant experience:
Patrick was the Chief Financial Officer
and a member of the Executive Board
of ING Group for over eight years to
May 2017. Prior to that, he worked for
HSBC for 20 years. Patrick is a Fellow
of Chartered Accountants Ireland.
Current external appointments:
Non-executive director and Senior
Independent Director of Aviva plc
A
T
Ri
N
Mark Seligman
Senior Independent Director
Frank Dangeard
Independent non-executive director
Patrick Flynn
Independent non-executive director
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Additional information
Financial statements
Morten Friis
Independent non-executive director
Robert Gillespie
Independent non-executive director
Corporate governance
continued
Yasmin Jetha
Independent non-executive director
Date of appointment:
2 December 2013
Committee memberships
Contribution to the Board:
Having run a global investment bank
during his executive career, Robert has
in-depth knowledge of banking and its
role within the economy. As a Chartered
Accountant, Robert understands complex
organisations and demonstrates strong
stakeholder management and leadership
skills, which enable him to provide
constructive views and contributions
during Board discussions.
Relevant experience:
Robert’s career in investment banking
specialised in corporate advisory work. He
was also Director General of the Takeover
Panel from 2010 until 2013. Prior to that
Robert held a number of senior positions
at UBS including being global head of
investment banking, Chief Executive of
UBS for EMEA and Vice Chairman of UBS
Investment Bank. Robert began his career
at Price Waterhouse (now PwC) and then
S.G. Warburg which subsequently became
part of UBS.
Robert was also previously Chairman of
The Boat Race Company Limited.
Current external appointments:
Non-executive director of Burford
Capital Limited
Professor of Practice at the University
of Durham
Non-executive director of Social
Finance Limited
A
Ri
Re
N
Date of appointment:
10 April 2014
Committee memberships
Contribution to the Board:
Morten is a former frontline banker,
who subsequently became a Chief
Risk Officer in a universal bank. He has
in-depth knowledge and expertise in risk
management within the financial services
industry, which enables him to make
a substantial contribution to Board
discussions and debate on risk matters.
Morten is also knowledgeable in regulatory
matters, capital markets, transformation
management and corporate resolution.
Relevant experience:
Morten’s extensive executive career
included various roles at Royal Bank
of Canada and its subsidiaries, such
as Senior Vice President, Group Risk
Management, Chief Credit Officer and
then Chief Risk Officer. Previously he
was also a Director of RBC Bank (USA);
Westbury Life Insurance Company; RBC
Life Insurance Company; and RBC Dexia
Investor Services Trust Company.
Morten also served as a Non-executive
director of Jackson National Life Insurance
Company for five years, and was chair of
its board risk committee and a member
of its audit committee.
Current external appointments:
Member of the board of directors of
the Harvard Business School Club
of Toronto
A
Ri
N
Date of appointment:
1 April 2020
Committee memberships
Contribution to the Board:
Yasmin brings a wealth of retail banking
and customer experience to the Board, as
well as valuable technology and innovation
insights, and a strong background in
general management. Yasmin adds
strength and depth to the Board in these
important areas, supporting challenge and
debate and effective decision-making.
On 1 April 2020 Yasmin re-joined the
Board of NatWest Group plc, having first
been appointed in June 2017. Yasmin
stepped down in April 2018 in order
to serve solely as a director of our key
ring-fenced entities, and, like the majority
of our directors, she continues to serve on
these boards in addition to the Board of
NatWest Group plc.
Relevant experience:
During her executive career, Yasmin held
Chief Information Officer roles at Bupa
and the Financial Times, where she later
became the Chief Operating Officer. Prior
to that Yasmin held a number of senior
roles at Abbey National PLC, in a career
spanning nearly 20 years, where latterly
she served as an executive director on
the board.
Yasmin has also held a number of
non-commercial roles including Vice
Chair of the Board of Governors at the
University of Bedfordshire (2008 to 2011)
and Vice Chair of the National Committee
of the Aga Khan Foundation (UK) Ltd, a
non-denominational charity that works
with communities in Africa, Asia and the
Middle East.
Current external appointments:
Non-executive director of Guardian
Media Group plc
Non-executive director of Nation Media
Group Limited
S
T
100
NatWest Group
2021 Annual Report and Accounts
Mike Rogers
Independent non-executive director
Lena Wilson
Independent non-executive director
Jan Cargill
Chief Governance Officer and Company
Secretary
Date of appointment:
26 January 2016
Committee memberships
Contribution to the Board:
Mike is an extremely experienced retail
and commercial banker, with extensive
boardroom experience. As a former Chief
Executive, Mike brings a broad-based
skillset and perspective to the Board,
particularly in relation to customer
experience, general management
and stakeholder engagement.
Relevant experience:
During his executive career Mike was
Chief Executive of Liverpool Victoria
Group and he held a variety of roles, both
in the UK and overseas, at Barclays Bank.
This included roles in business banking,
wealth management and retail banking
where Mike was Managing Director of
Small Business, Premier Banking and
UK Retail Banking.
Current external appointments:
Chairman of Experian plc
Chairman of Aegon UK plc
Re
S
Date of appointment:
1 January 2018
Committee memberships
Contribution to the Board:
Lena contributes significant knowledge
and experience to the Board drawn from a
broad executive and non-executive career.
She has extensive transformation and
development skills, with experience
in enterprise, internationalisation,
stakeholder management, ESG
and general management.
As Chair of the NatWest Group Colleague
Advisory Panel since it was established in
2018, Lena provides valuable insights on
customer and people issues in particular.
Relevant experience:
Lena has a portfolio of Chair roles in the
listed, private equity and professional
services sectors. She has been a FTSE 100
non-executive director for 10 years and
previously served on the boards of Scottish
Power Renewables Limited and Intertek
Group plc. Lena was Chief Executive of
Scottish Enterprise from November 2009
until October 2017 and prior to that, was
Senior Investment Advisor to The World
Bank in Washington DC.
Lena was a member of Scotland’s
Financial Services Advisory Board and
Chair of Scotland’s Energy Jobs Taskforce.
In June 2015 she received a CBE for
services to economic development
in Scotland.
Current external appointments:
Chair of Picton Property
Income Limited
Chair of AGS Airports Limited
Senior Independent Director of
Argentex Group plc
Member of the UK Prime Minister’s
Business Council for 2022
Chair of the Advisory Board of Turtle
Pack Limited
Chair of Chiene + Tait LLP
Visiting Professor, University
of Strathclyde Business School
Re
S
Ri
Date of appointment:
5 August 2019
Contribution to the Board:
Jan works closely with the Chairman to
ensure effective and efficient functioning
of the Board and appropriate alignment
and information flows between the Board
and its Committees. She is responsible for
advising the Board and individual directors
on all governance matters, and also
facilitates Board induction and
directors’ professional development.
Relevant experience:
Jan is a chartered company secretary
with over 20 years corporate governance
experience. She was appointed Chief
Governance Officer and Company
Secretary in 2019, and prior to that held
various roles in the legal and secretariat
functions, including Head of Board and
Shareholder Services.
Jan has a law degree and is a Fellow
of the Chartered Banker Institute. She
is also an Associate of The Chartered
Governance Institute and has an INSEAD
Certificate in Corporate Governance.
101
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Chairman’s
introduction
Corporate governance
continued
Contents
98
Our Board
103
Corporate governance
114
Report of the Group
Nominations and
Governance Committee
116
Report of the Group
Audit Committee
124
Report of the Group Board
Risk Committee
132
Report of the Group
Sustainable Banking
Committee
134
Report of the Technology and
Innovation Committee
136
Directors’ remuneration
report
181
Compliance report
184
Report of the directors
187
Statement of directors’
responsibilities
Dear Shareholder,
I am pleased to present the Corporate
Governance Report for 2021.
The Board met mostly virtually during the
year and while we missed the opportunity to
meet and engage with colleagues in person,
virtual meeting technology continued to offer
an effective alternative which supported the
efficient running of the Board.
The Board spent significant time overseeing
the implementation of our strategy and transformation programme alongside other
key priorities including our ongoing withdrawal from the Republic of Ireland, capital
distributions and financial crime. COVID-19 also remained a key area of focus for
the Board in 2021, particularly the support being provided to our customers and
colleagues. The three additional independent non-executive directors of NatWest
Holdings Limited attend all Board and relevant Board Committee meetings
as observers and contribute a ring-fenced bank perspective to Board and
Committee discussions.
Further details of the Board’s principal activities during 2021 can be found on
page 104.
As a Board, we know how important it is to engage with our stakeholders, to listen
to them and to consider their interests during Board discussions and decision-making.
Understanding the needs of our stakeholders is at the core of our purpose framework
as shown on pages 12 to 13.
Examples of how the Board has engaged with key stakeholders and considered
their interests, including the impact on principal decisions, can be found on pages
14 to 17 and pages 52 to 53 of the Strategic report and later in this Corporate
governance report.
There were no changes to Board or Board Committee membership during 2021,
however we continue to keep the composition, skills and experience of the Board
under review.
Board effectiveness
In 2021, the Board and Committee evaluation was externally facilitated by
Independent Board Evaluation. Further information on how the evaluation
was conducted, key outcomes and actions arising can be found on page 112.
UK Corporate Governance Code 2018
All directors are committed to observing high standards of corporate governance,
integrity and professionalism.
Information on how the company has applied the Principles and complied with the
Provisions of the UK Corporate Governance Code 2018 (the Code) can be found in this
Corporate governance report under the Code’s five main section headings. A formal
statement of compliance with the Code can be found on page 181.
In conclusion I would like to thank my fellow Board members for their outstanding
contributions and commitment throughout the year.
Howard Davies
Chairman of the Board
17 February 2022
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2021 Annual Report and Accounts
Board and Committee meetings
The table below shows Board and Committee membership and directors’ meeting attendance during 2021. There were six
scheduled Board meetings during 2021, the same number as in 2020.
In addition to scheduled meetings, additional ad hoc meetings of the Board and some of its Committees were held throughout the
year to receive updates and deal with time-critical matters. There were eight additional Board meetings held in 2021 compared to
16 additional meetings held in 2020. When directors are unable to attend meetings convened at short notice, they receive the
papers and have the opportunity to provide their feedback in advance.
In accordance with the Code, the Chairman and the non-executive directors met at least once without executive directors present.
Board and Committee membership and meeting attendance in 2021
Board
Group Audit
Committee (GAC)
Group Board Risk
Committee (BRC)
Group Nominations
and Governance
Committee (N&G)
Group Performance
and Remuneration
Committee (RemCo)
Group Sustainable
Banking Committee
(SBC)
Technology and
Innovation
Committee (TIC)
Director
Scheduled
Ad hoc
Scheduled
Ad hoc
Scheduled
Ad hoc
Scheduled
Ad hoc
Scheduled
Ad hoc
Scheduled
Ad hoc
Scheduled
Ad hoc
Howard Davies
6/6
8/8
4/4
Alison Rose
6/6
8/8
Katie Murray
6/6
8/8
Frank Dangeard
(1)
6/6
7/8
8/8
3/3
4/4
Patrick Flynn
6/6
8/8
5/5
8/8
1/1
4/4
4/4
Morten Friis
6/6
8/8
5/5
8/8
1/1
4/4
Robert Gillespie
6/6
8/8
5/5
8/8
1/1
4/4
8/8
3/3
Yasmin Jetha
6/6
8/8
5/5
2/2
4/4
Mike Rogers
(1)
6/6
7/8
8/8
3/3
5/5
2/2
Mark Seligman
6/6
8/8
5/5
4/4
8/8
3/3
Lena Wilson
6/6
8/8
8/8
1/1
8/8
3/3
5/5
2/2
(1)
Mr Dangeard and Mr Rogers were each unable to attend one ad hoc meeting, due to prior commitments.
How the Board operated in 2021
The Board continued to meet largely virtually during 2021.
A hybrid meeting was held in July and in September the full
Board was able to meet in person for the first time since the
start of the pandemic.
At each scheduled Board meeting the directors received
reports from the Chairman, Board Committee Chairmen,
Group Chief Executive Officer (Group CEO), Group Chief
Financial Officer (Group CFO), Group Chief Risk Officer
and other members of the executive management team, as
appropriate (referred to in the Board annual calendar which
follows as ‘regular reports’). Other senior executives attended
Board meetings throughout the year to present reports to the
Board. This provided the Board with an opportunity to engage
directly with management on key issues and support
succession planning.
The Board and Group Executive Committee (ExCo) operating
rhythm continues to support a proactive and transparent
agenda planning and paper preparation process. This
process includes the following key elements:
A pre-Board meeting with the Chairman, Group CEO,
Group CFO and Chief Governance Officer and Company
Secretary to ensure the Board and executive management
are aligned on Board agendas.
A post Board meeting with the Chairman, Group CEO
and Chief Governance Officer and Company Secretary
to discuss what went well or could be improved after
each meeting.
A look ahead paper at each ExCo and Board meeting
setting out key items that will be discussed at the
next meeting.
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Governance
Risk and capital management
Additional information
Financial statements
Corporate governance
continued
Board annual calendar for 2021
Spotlight and ad hoc items
Scheduled items
Training
January
(ad hoc)
Strategy updates
Capital distributions
Executive remuneration
February
Strategy updates
Budget
Capital distributions
Banking Standards Board
presentation (now Financial
Services Culture Board or FSCB)
Regular reports
Business reviews
2020 Annual Results (including
ESG Supplement and Climate-
related Disclosures Report)
Legal and regulatory report
Board business insights pack
2021 Board objectives
2021 Annual General Meeting
arrangements
March
(ad hoc)
Talent engagement session
Strategy
One Bank transformation
Colleague Advisory Panel report
Directed share buyback
Internal Capital Adequacy
Assessment Process
Internal Liquidity Adequacy
Assessment Process
Board succession planning
Financial crime
Operational resilience
Consumer protection
April
Strategy updates
One Bank transformation
Regular reports
Business reviews
Risk management framework
Risk appetite
Q1 2021 results
Legal and regulatory report
Board business insights pack
2021 Annual General Meeting
arrangements
Health and safety annual review
Governance Framework
annual review
Principal areas of Board focus in 2021
As in 2020, a short set of Board objectives was adopted for
2021, closely aligned to our purpose and strategic priorities.
These have supported agenda planning and helped to guide
how the Board spends its time, ensuring appropriate focus on
the longer-term and strategic issues. Whilst our response to the
COVID-19 pandemic continued to be a priority for the Board,
there was a shift away from standalone pandemic-related
updates towards integrated reporting on COVID-19 related
matters across the Board agenda, including through our
regular reports and business reviews.
The Chief Governance Officer and Company Secretary
maintains an annual agenda planner designed to ensure
that all matters set out in the Board’s terms of reference are
considered by the Board. The table below is an overview of the
main matters considered by the Board during 2021 and also
shows the Board training provided. In 2021, we introduced the
use of videos into Board training and presentations which has
been well received by the Board. They have been used, for
example, to deliver background materials as well as insights
from colleagues and customers to support Board discussions.
Ad hoc meetings of the Board were held concurrently with
scheduled meetings of the Board of NatWest Holdings Limited
in March and September, to deal with any time critical matters
or to support efficient review of items of mutual interest.
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NatWest Group
2021 Annual Report and Accounts
Spotlight and ad hoc items
Scheduled items
Training
June
Talent and executive succession
Recovery plans
Capital distributions
Annual Board strategy session
Regular reports
Colleague Advisory Panel report
Business reviews
Legal and regulatory report
Board business insights pack
Group money laundering reporting
officer report
Financial crime
2020 Modern Slavery and
Human Trafficking statement
Our View mid-year survey results
2021 solvency stress test results
Directors’ duties in resolution
July
Prudential Regulation
Authority presentation
and engagement session
Culture spotlight
One Bank transformation
Brand portfolio
Capital distributions
Resolvability Self-Assessment
On-market share buyback
Regular reports
Business reviews
H1 2021 results
Legal and regulatory report
Board business insights pack
Cyber security
September
(ad hoc)
One Bank transformation
Budget and stress scenarios
Climate Biennial Stress Test
results
Financial crime
Financial crime
October
Strategy updates
One Bank transformation
Our View annual survey results
Regular reports
Business reviews
Q3 2021 results
Talent and executive succession
Legal and regulatory report
Board business insights pack
Climate
December
Strategy updates
One Bank transformation
Annual Board effectiveness review
Budget
Capital distributions
Operational resilience
Our values refresh
Culture measurement report
Annual purpose update
Brand portfolio
Board skills matrix
Executive performance and
remuneration
Regular reports
Business reviews
Colleague Advisory Panel report
Risk management framework
Risk appetite
Board business insights pack
Financial crime
2022 Annual General Meeting
arrangements
Online training
Included video materials as part
of training or Board materials.
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Financial review
Governance
Risk and capital management
Additional information
Financial statements
Subsidiary governance and ring-fencing
NatWest Group plc is a listed company with equity listed on the
London and New York stock exchanges.
NatWest Holdings Limited (NWH) is the holding company for
our ring-fenced operations, which include our retail, commercial
and private banking businesses. A common board structure is
operated such that the directors of NWH are also directors of
The Royal Bank of Scotland plc and National Westminster Bank
Plc. Known collectively as the NWH Sub Group, the boards of
these three entities meet concurrently.
On 3 May 2021, following Court approval, the business of
Ulster Bank Limited was transferred into its immediate parent,
National Westminster Bank Plc (NWB Plc). This reorganisation
saw the Ulster Bank brand in Northern Ireland become a
trading name of NWB Plc and simplified the NatWest Group
by aligning the legal entity structure with the pre-existing
management structure. The simplification ensured continuity
of service under the Ulster Bank brand, with customers
continuing to receive the same products and services through
the same channels. Colleagues became employees of NWB Plc,
with their existing benefits and conditions of employment
remaining unchanged.
An integral part of NatWest Group’s governance arrangements
is the appointment of three double independent non-executive
directors (DINEDs) to the boards, and board committees, of the
NWH Sub Group. They are Francesca Barnes, Graham Beale,
and Ian Cormack.
The DINEDs are independent in two respects: (i) independent
of management as non-executives; and (ii) independent of
the rest of NatWest Group by virtue of their NWH Sub
Group-only directorships.
The DINEDs play a critical role in NatWest Group’s ring-fencing
governance structure, and are responsible for exercising
appropriate oversight of the independence and effectiveness
of the NWH Sub Group’s governance arrangements, including
the ability of each board to take decisions independently.
The DINEDs attend NatWest Group plc Board and relevant
Board Committee meetings in an observer capacity.
The governance arrangements for the boards and board
committees of NatWest Group plc and the NWH Sub Group
have been designed to enable NatWest Group plc to exercise
appropriate oversight and to ensure that, as far as is
reasonably practicable, the NWH Sub Group is able
to take decisions independently of the wider Group.
NatWest Markets supports NatWest Group’s corporate
and institutional customers through NatWest Markets Plc
and its subsidiaries.
RBS International serves retail, commercial and corporate
customers and financial institutions and operates through
The Royal Bank of Scotland International (Holdings) Limited
and its subsidiaries.
The Group Nominations and Governance Committee monitors
the governance arrangements of NatWest Group plc and its
subsidiaries and approves appointments to the boards of
principal and material regulated subsidiaries, as described in
the Group Nominations and Governance Committee report
on page 114.
2018 UK Corporate Governance Code
Throughout the year the company has applied the Principles
and complied with the Provisions of the Code, except in
relation to:
Provision 17 that the Group Nominations and Governance
Committee should ensure plans are in place for orderly
succession to both the board and senior management
positions and oversee the development of a diverse
pipeline for succession; and
Provision 33 that the Group Performance and Remuneration
Committee should have delegated responsibility for setting
remuneration for the Chairman and executive directors.
In both instances, the Board considers that these are matters
which should rightly be reserved for the Board, as set out in
more detail in our statement of compliance on page 181.
In addition, the Board has delegated two particular aspects
of the Code’s provisions to Board Committees, with regular
updates provided to the Board as appropriate:
The Group Audit Committee has delegated responsibility
for reviewing and monitoring NatWest Group’s
whistleblowing process.
The Group Sustainable Banking Committee has delegated
responsibility for reviewing key workforce policies and
practices (not related to pay) to ensure they are consistent
with NatWest Group’s values and support long-term
sustainable success.
For further information please refer to the remainder
of this report and the relevant Committee reports on the
following pages.
Further information on how the company has applied the
Principles and complied with the Provisions of the Code is
set out below under the Code’s five main section headings.
Board leadership and company purpose
Role of the Board
The Board is collectively responsible for promoting the
long-term sustainable success of the company, driving both
shareholder value and contribution to wider society. The
Board’s role is to provide leadership of the company within
a framework of prudent and effective controls which enables
risk to be assessed and managed. The Board establishes
NatWest Group’s purpose, values and strategy and leads the
development of NatWest Group’s culture. The Board sets the
strategic aims of the company and its subsidiaries, ensures that
the necessary resources are in place for NatWest Group to
meet its objectives, is responsible for the raising and allocation
of capital and reviews business and financial performance.
It ensures that the company’s obligations to its shareholders
and other key stakeholders are understood and met.
Corporate governance
continued
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The Board terms of reference include a formal schedule
of matters specifically reserved for the Board’s decision
and are reviewed at least annually. They are available at
natwestgroup.com. An internal review confirmed the Board
had fulfilled its remit as set out in its terms of reference
during 2021.
Board Committees
The Board has established a number of Board Committees
with particular responsibilities. Please refer to the Committee
Chairman reports for further details. Board Committee terms
of reference are available at natwestgroup.com.
Purpose, values, strategy and culture
In February 2020, and following an extensive period of
stakeholder engagement, the Board approved NatWest
Group’s purpose and strategy. Throughout 2021, our
purpose has continued to inform and drive our response to the
pandemic, acting as an important point of reference during
Board discussions, debate and decision-making.
The Board received its annual purpose update in December
2021 which summarised progress in becoming a purpose-led
bank against the three purpose focus areas of climate,
enterprise and learning. It highlighted the progress to
date on embedding purpose and delivering against public
commitments; the key areas of focus for 2022; and an update
on stakeholders’ perception of NatWest Group and its purpose
aligned to the Blueprint for Better Business framework.
Further information on progress against our purpose and
strategic priorities can be found in the Strategic report.
The Board assesses and monitors NatWest Group’s culture
in several ways, as illustrated by the diagram below.
NatWest Group plc – Board responsibilities in relation to culture
Leads the development of NatWest Group’s culture, values and standards.
Assesses and monitors culture.
Reviews and approves NatWest Group’s values.
Board reporting on culture
What did the Board receive?
When did it
receive it?
Key areas of focus
Banking Standards Board (BSB)
presentation (now FSCB)
February
BSB’s 2020 Survey Annual Report and its review of the embedding of purpose in
NatWest Group.
Colleague Advisory
Panel reports
March
June
December
Feedback on discussions from Colleague Advisory Panel meetings. Topics
covered included wellbeing support for colleagues, retail banking strategy,
purpose, remuneration (including executives and the wider workforce),
climate and ways of working.
One Bank Transformation
Programme spotlight on
organisation, skills and culture
April
October
Future of work and strategic workforce planning. This covered new ways of
working, colleague journeys, colleague experience, career development, skills
and capability, learning, wellbeing and inclusion.
Our View colleague survey
June
October
December
Insights from the colleague opinion surveys conducted in April and September
2021. Key measures included culture, purpose, building capability, inclusion,
engagement and leadership. A follow up paper was presented to the Board
in December to address an action from the Board on how to strengthen
engagement with middle and senior mangers on leading through transformation.
Culture spotlight
July
An update on the refresh of our values and the alignment to purpose and
strategy as well as an overview of cultural strengths, behavioural weaknesses,
operating model and future culture.
Culture measurement report
July
December
Insights and metrics to allow the Board to assess the status of NatWest Group’s
culture and understand future priorities. The reports used the Blueprint for
Better Business framework to report progress highlighting both positive trends
and areas for improvement.
Our values
December
The Board was asked to approve the refreshed values which had been updated
to ensure greater alignment to purpose and strategy.
Board business insights pack
Each meeting
Metrics to demonstrate how NatWest Group is delivering for colleagues
(culture, purpose and inclusion).
The activities described above have supported the Board in meeting the Code requirement to satisfy itself that the company’s
purpose, values, strategy and culture are aligned.
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Financial review
Governance
Risk and capital management
Additional information
Financial statements
Corporate governance
continued
Stakeholder
Group
How stakeholder
views have been
communicated
Examples of what was shared
How did the Board use that information?
Customers
Group CEO report
Business reviews
Ad hoc reports to
the Board
Updates on customer engagement activity and
customer sentiment.
Competition and Markets Authority service
quality results and Net Promoter Scores.
Allowed the Board to oversee and challenge business
performance more effectively and better understand
performance versus peers.
Colleagues
Group CEO report
Business reviews
Colleague specific
papers presented
to the Board
Ways of working updates.
Our View survey results.
Culture measurement reports.
Colleague input to the development of our
refreshed values.
Allowed the Board to better understand colleague
sentiment and levels of colleague engagement and, in
the case of the values refresh, how colleagues’ views
have been considered and influenced the final proposal.
Communities
Board training
Ad hoc reports to
the Board
Training materials on climate.
Launch of CareerSense.
The climate training session updated the Board on
progress against our climate ambitions, goals and
targets and supported a better understanding of
regulatory and investor expectations on climate.
The CareerSense update was a good example of our
purpose in action and NatWest Group’s support of
young people and communities across the UK.
Investors
Investor feedback
reports
Group CFO report
Detailed investor feedback (both equity market
reaction and fixed income market reaction)
was shared each quarter following each
results presentation.
Feedback on other investor presentations
by management.
External market perspectives.
Investor feedback reports provided the Board with
direct feedback from investors on NatWest Group’s
strategy and financial performance.
The Group CFO kept the Board updated on external
market perspectives which included share price
performance and trading activity, allowing the
Board to monitor investor activity.
Regulators
Regulatory
correspondence
Group CEO and
Group CFO reports
and business
reviews
Relevant regulatory correspondence that
regulators requested be shared with the
Board and, where applicable, proposed
management responses.
Updates on regulatory engagement.
Sharing the correspondence and proposed responses
allowed the Board to understand key matters being
raised by regulators and how management were
addressing those.
Kept the Board informed on key topics being discussed
by management with regulators, enhancing the Board’s
understanding of key regulatory priorities.
Suppliers
Business reviews
Regular updates on key supplier and
partnership relationships and initiatives
being undertaken with them.
Provided the Board with visibility on key supplier
activity and how this is supporting our purpose,
strategy, financial performance and our ambitions
on climate and the environment.
Stakeholder engagement
In February 2021, the Board approved its annual objectives
and confirmed the Board’s key stakeholder groups –
customers, colleagues, communities, investors, regulators,
and suppliers. The Board’s agenda and engagement plans
were structured to enhance the Board’s understanding of
stakeholders’ views and interests. This in turn has informed
Board discussions and decision-making.
Workforce engagement
NatWest Group’s Colleague Advisory Panel (CAP) was set up in
2018 to help promote colleague voices in the boardroom and
supports our compliance with Code requirements in relation
to Board engagement with the workforce.
Through the CAP, colleagues can engage directly with senior
management and the Board on topics which are important to
them, thereby strengthening the voice of colleagues in the
Boardroom. The CAP is made up of 28 colleagues who
represent employee-led networks, talent programmes,
employee representative bodies or are self-nominated.
In this way we ensure the panel is diverse, inclusive and
representative of the workforce.
The CAP met with representatives from the Board
three times in 2021 to discuss issues such as wellbeing,
remuneration (including executives and the wider workforce),
climate, retail banking strategy, sustainability and purpose.
The CAP continues to be highly regarded by those who
attend and has proven to be an effective way of establishing
two-way dialogue between colleagues and Board members.
In 2022 we are reviewing our approach to how the Board
engages with the workforce.
The Stakeholder engagement section of the Strategic report
on pages 14 to 17 includes examples of how the Board
engaged directly with stakeholders, and our section 172(1)
statement on pages 52 to 53 describes how stakeholder
interests have been considered in board decision-making,
including principal decisions.
Set out below is an overview of further ways in which
stakeholder views have been communicated to the Board,
which often takes place indirectly via management updates.
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The effectiveness of Board stakeholder engagement
mechanisms is considered during the annual Board evaluation.
Further details on NatWest Group’s approach to investing
in and rewarding its workforce can be found on pages 58 to 61
of the Strategic report.
Workforce policies and practices
As referred to above, the Board has delegated certain Code
provisions to Board Committees, with regular updates to the
Board on relevant issues.
In October 2021 the Group Sustainable Banking Committee
considered key workforce policies and practices as part of
its people and culture meeting, where a spotlight on living our
purpose included updates on reward, career development,
succession planning, recruitment, inclusion and learning
frameworks. At that time, it was acknowledged that a
refreshed set of values, aligned to our purpose, would be
presented to the Board in December 2021 for approval
and that workforce policies and practices would be updated
where required to ensure ongoing alignment to NatWest
Group’s values.
The Group Audit Committee retains responsibility for reviewing
and monitoring NatWest Group’s whistleblowing process.
Conflicts of interest
The Directors’ Conflicts of Interest policy sets out procedures
to ensure that the Board’s management of conflicts of
interest and its powers for authorising certain conflicts
are operating effectively.
Each director is required to notify the Board of any actual or
potential situational or transactional conflict of interest and
to update the Board with any changes to the facts and
circumstances surrounding such conflicts.
Situational conflicts can be authorised by the Board in
accordance with the Companies Act 2006 and the company’s
Articles of Association. The Board considers each request for
authorisation on a case-by-case basis and has the power to
impose conditions or limitations on any authorisation granted
as part of the process. Details of all directors’ conflicts of
interest are recorded in a register which is maintained by
the Chief Governance Officer and Company Secretary and
reviewed annually by the Board.
Division of responsibilities
The Board has 11 directors comprising the Chairman, two
executive directors and eight independent non-executive
directors, one of whom is the Senior Independent Director.
Director biographies and details of the Board Committees of
which they are members can be found on pages 98 to 101.
Non-executive director independence
The Board considers that the Chairman was independent on
appointment and that all current non-executive directors are
independent for the purposes of the Code.
Chairman and Group CEO
The role of Chairman is distinct and separate from that of
the Group CEO and there is a clear division of responsibilities,
with the Chairman leading the Board and the Group CEO
managing the business day to day.
Senior Independent Director
Throughout 2021, Mark Seligman, as Senior Independent
Director, acted as a sounding board for the Chairman, and
as an intermediary for other directors when necessary. He
was also available to shareholders to discuss any concerns
they may have had, as appropriate.
Non-executive directors
Along with the Chairman and executive directors, the
non-executive directors are responsible for ensuring the
Board fulfils its responsibilities under its terms of reference.
The non-executive directors combine broad business
and commercial experience with independent and objective
judgment. They provide constructive challenge, strategic
guidance, and specialist advice to the executive directors
and the executive management team and hold management
to account.
The balance between non-executive and executive directors
enables the Board to provide clear and effective leadership
across NatWest Group’s business activities and ensures no
one individual or small group of individuals dominates the
Board’s decision-making.
The Chairman and non-executive directors meet at least once
every year without the executive directors present.
Details of the key responsibilities of the Chairman, Group CEO,
Senior Independent Director and non-executive directors are
available at natwestgroup.com.
The performance of the Chairman and non-executive directors
is evaluated annually and further details of the process
undertaken can be found on page 113.
Chief Governance Officer and Company Secretary
The Chief Governance Officer and Company Secretary,
Jan Cargill, works closely with the Chairman to ensure
effective and efficient functioning of the Board and appropriate
alignment and information flows between the Board and
its Committees.
The Chief Governance Officer and Company Secretary
is responsible for advising the Board and individual directors
on all governance matters, and also facilitates Board induction
and directors’ professional development.
Executive management
The Group CEO is supported by Group ExCo, which considers
strategic, financial, capital, risk and operational issues affecting
NatWest Group and reviews relevant matters in advance of
Board submission. Group ExCo’s membership comprises the
Group CEO, Group CFO and the Group Chief Risk Officer; who
are also members of the wider executive management team.
Biographies of the executive management team can be found
at natwestgroup.com.
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Financial review
Governance
Risk and capital management
Additional information
Financial statements
Time commitment and external appointments
It is anticipated that non-executive directors will allocate
sufficient time to the company to discharge their responsibilities
effectively and will devote such time as is necessary to fulfil
their role. Directors have been briefed on the limits on the
number of other directorships that they can hold under the
requirements of the fourth Capital Requirements Directive.
The Code emphasises the importance of ensuring directors
have sufficient time to meet their board responsibilities. Prior to
appointment, significant commitments require to be disclosed
with an indication of the time involved. External appointments
require prior Board approval, with the reasons for permitting
significant appointments explained in the Annual Report
and Accounts.
Lena Wilson and Frank Dangeard both re-organised their
portfolios of appointments and took up new appointments in
2021. Ms Wilson was appointed as a non-executive director
and subsequently Chair of Picton Property Income Limited
and as a non-executive director and Chair of AGS Airports
Limited and Mr Dangeard was appointed Chairman of SPEAR
Investments I B.V. These appointments were approved by
the Board in advance and the Board considered both potential
conflicts and time commitment and was satisfied that each
would be able to continue to meet their commitments to
NatWest Group given the other changes to their
respective portfolios.
The Board continues to monitor the commitments of the
Chairman and directors and is satisfied that they are able to
allocate sufficient time to enable them to discharge their duties
and responsibilities effectively.
Information
All directors receive accurate, timely and clear information on
all relevant matters and have access to the advice and services
of the Chief Governance Officer and Company Secretary.
In addition, all directors are able, if necessary, to obtain
independent professional advice at the company’s expense.
Our Board and Committee paper template includes a
section for authors to explain how the proposal or update
aligns with our purpose and a separate section for them to
include an assessment of the relevant stakeholder impacts
for the directors to consider. This aligns with the directors’
duties under section 172(1) of the Companies Act 2006 and
further details on how the directors have complied with their
section 172(1) duties can be found on pages 52 to 53 of
the Strategic report.
Our directors are mindful that it is not always possible to
achieve an outcome which meets the requirements, needs
and/or expectations of all stakeholders who are, or may be,
impacted. For decisions which are particularly challenging
or complex, we introduced an additional page to our paper
template in 2021 which provides directors with further
information to support purposeful decision-making. This
additional page uses Blueprint for Better Business as a
base and is aligned to our broader purpose framework.
Induction and professional development
Each new director receives a formal induction on joining the
Board, which is coordinated by the Chief Governance Officer
and Company Secretary and tailored to suit the requirements
of the individual concerned. This includes visits to NatWest
Group’s major businesses and functions and meetings with
directors and senior management. Meetings with external
auditors, counsel and stakeholders are also arranged
as appropriate.
All new directors receive a copy of the NatWest Group
Director Handbook. The Handbook operates as a consolidated
governance support manual for directors of NatWest Group plc
and the NWH Sub Group, providing both new and current
directors with a single source of information relevant to their
role. It covers a range of topics including NatWest Group’s
corporate structure; the Board and Board Committee
operating model; Board policies and processes; and a range
of technical guidance on relevant matters including directors’
duties, conflicts of interest, and the UK Senior Managers
and Certification Regime. The Handbook forms part of
a wider library of reference materials available via our
resources portal.
Directors have access to a wide range of briefing and training
sessions and other professional development opportunities.
Internal training relevant to the business of NatWest Group is
also provided. Directors undertake the training they consider
necessary to assist them in carrying out their duties and
responsibilities. The non-executive directors discuss their
training and professional development with the Chairman
at least annually. Details of the training and development
undertaken by directors during 2021, which is co-ordinated by
the Chief Governance Officer and Company Secretary, can be
found on pages 104 to 105 (Board annual calendar for 2021).
Composition, succession and evaluation
Composition
The Board is structured to ensure that the directors provide
NatWest Group plc with the appropriate combination of skills,
experience, knowledge and diversity, as well as independence.
Given the nature of NatWest Group’s businesses, experience
of banking and financial services is clearly of benefit, and the
Board has a number of directors with substantial experience
in those areas. Our directors also possess substantial skills and
experience in the areas of Transformation, Financial Markets/
Investment Banking, and Environmental, Social and
Governance (including climate).
In December 2021 the Group Nominations and Governance
Committee reviewed, and the Board approved, a refreshed
version of our Board skills matrix, a summary view of which
is set out below.
The Board skills matrix reflects directors’ self-assessment of
the skills and experience they bring to Board discussions, in
line with pre-determined criteria aligned to current and future
strategic priorities, and will continue to be considered by the
Group Nominations and Governance Committee, and the
Board, at least once a year.
Corporate governance
continued
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Board skills and e
xp
erience
0
2
4
6
10
8
Risk management
Broad Financial Services
T
ransformation
Financial Mark
ets / Inves
tment Banking
Environment
al, Social and Governanc
e (incl climate)
CEO / Senior Executiv
e Management
Customer e
xperience
Government / r
egulatory / public sector
Retail / C
ommercial / Private Banking
Digital and Innov
ation
CFO / A
ccountant
T
echnology (infrastructure, cyber)
11
Skills and experience
Number of directors
Board Committees also comprise directors with a variety of
skills and experience so that no undue reliance is placed on
any one individual.
Succession
As set out in its terms of reference the Board is responsible
for ensuring adequate succession planning for the Board and
senior management, so as to maintain an appropriate balance
of skills and experience within NatWest Group and on the Board.
In 2021 the Board received two updates on talent and
executive succession planning which enabled them to
monitor the internal talent pipeline and provide feedback.
These updates included a detailed analysis of the diversity
of the talent pool, with a view towards continuing to improve
diversity over the longer term.
The Board also held a talent session with potential Executive
Committee successors, and members of the Group Sustainable
Banking Committee held an informal session with executive
talent. These sessions helped our non-executive directors to
get to know potential future leaders, through focused debates
on strategic topics.
The Group Nominations and Governance Committee supports
the Board on Board succession planning, including making
recommendations to the Board on Board appointments and
Board Committee membership.
In February 2021 (following review and recommendation
by the Group Nominations and Governance Committee),
the Board approved succession plans for the roles of Senior
Independent Director and Committee Chairs, covering
orderly transition plans for the short and medium term, and
contingency arrangements which could be implemented in
case of an emergency. These succession plans are reviewed
by the Group Nominations and Governance Committee and
approved by the Board at least once a year.
Further information on the role of the Group Nominations and
Governance Committee and its activities during 2021 can be
found in the Committee Chairman’s report on page 114.
Election and re-election of directors
In accordance with the provisions of the Code, all directors
stand for election or re-election by shareholders at the
company’s AGM.
In accordance with the UK Listing Rules, the election or
re-election of independent directors also requires approval
by a majority of independent shareholders.
Evaluation
In accordance with the Code, an evaluation of the
performance of the Board, its Committees, the Chairman
and individual directors takes place annually. The evaluation
is externally facilitated every three years, with internal
evaluations in the intervening years.
An external evaluation was conducted in 2018 by Independent
Board Evaluation (IBE), with internal evaluations taking place in
2019 and 2020. IBE returned in 2021 to facilitate their second
external Board and Committee evaluation for NatWest Group.
Further details on how IBE was selected in 2021, how the 2021
evaluation was conducted and the outcomes and actions
arising from that process are set out in this section.
Progress following the 2020 internal Board evaluation
A number of actions were progressed during 2021 in response to the findings of the 2020 internal Board evaluation.
2020 actions
2021 progress
Agree a shorter and more focused set of
Board objectives for 2021.
A more concise set of Board objectives was agreed for 2021, supporting effective
management of Board priorities and agenda planning.
Explore different options for directors to
engage with customers.
Through a customer engagement programme a number of non-executive directors
observed customer facing colleagues in action and heard customer feedback as
part of a focus group or customer listening surgery.
Review potential enhancements to Board
Management Information on customers
and suppliers
Board reporting was enhanced to include customer measures aligned to purpose
and transformation targets, and enhanced tracking of progress against customer
advocacy and satisfaction targets.
There was also a review and alignment of customer measures used across the
businesses, to ensure greater consistency of reporting.
Our business review template was updated to provide for more detailed reporting
on supplier relationships.
Enhance Board visibility of Executive
Committee successors.
Board visibility of the executive talent pipeline was enhanced through Board and
Group Sustainable Banking Committee talent sessions.
Senior executives below Executive Committee level continued to present papers
at Board meetings, further contributing to their profile in the Boardroom.
Details of progress made against the actions arising from the 2020 internal Committee evaluations can be found in the relevant
Committee Chairman Reports.
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Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Corporate governance
continued
2021 Board evaluation – outcomes and actions
The IBE report identified positive changes in Boardroom culture
and dynamics since the last external review in 2018. Board
relationships with management were more transparent, and
there was a better balance between support and challenge
from the Board. Care would be required to ensure this balance
was maintained. Whilst working remotely remained challenging
and directors missed the opportunity for informal interaction,
they were pleased at how quickly and effectively they had
been able to adapt.
After a period of stability in terms of Board composition, the
IBE report highlighted the importance of prioritising Board
succession planning in future. IBE highlighted scope to enhance
the Board’s technology experience, and the importance of
ensuring appropriate focus on diversity (with respect to age,
gender, experience and ethnicity). These are matters which
the Board and Group Nominations and Governance Committee
will keep under review during 2022.
IBE also observed that NatWest Group’s ring-fencing
governance arrangements, which had just been introduced
at the time of the 2018 evaluation, were now considered
to be operating effectively with no significant issues or
concerns raised.
2021 External Board Committee evaluation
IBE were engaged to facilitate the external evaluation in 2021. IBE had previously conducted the 2018 evaluation and at that time,
NatWest Group’s corporate governance arrangements were undergoing significant change in preparation for the implementation
of ring-fencing.
Following a recommendation from the Group Nominations and Governance Committee, the Board agreed that the 2021 evaluation
should be conducted externally in accordance with the Code and that IBE should be appointed again to provide important
continuity. The Board concluded that IBE’s appointment would also provide a helpful opportunity to review how ring-fencing
governance arrangements had embedded since the 2018 exercise.
IBE has no other connection with NatWest Group. The sections of this report which describe the process followed or which attribute
opinions to the external facilitator have been agreed with IBE prior to publication.
How the evaluation was conducted
Objectives and
scope
The Chairman, Group CEO and Chief Governance Officer and Company Secretary briefed IBE on the
objectives of the 2021 Board and Committee evaluation.
The NatWest Group plc and NWH Sub Group Boards and Board Committees were confirmed to be in scope
for a comprehensive performance review. Focus areas included Board culture, Board composition and
succession planning (including skills, diversity and experience), strategy (oversight and implementation),
Board focus and priorities, induction, risk management, stakeholder engagement, and quality of meetings
and papers.
Information
gathering
IBE held interviews with all of the directors, members of senior management, external advisers and auditors.
The lead evaluator observed the main Board and Committee meetings in October 2021.
The Chief Governance Officer and Company Secretary provided copies of Board and Committee papers and
other supporting materials to IBE.
Report preparation
IBE prepared draft reports for the Board and Board Committees.
IBE’s recommendations were based on best practice as described in the Code and other relevant guidelines.
Draft conclusions were discussed with the Chairman and Committee Chairmen in advance of
report circulation.
Review and action
planning
Board and Committee reports were presented and discussed at the December 2021 Board and
Committee meetings.
In February 2022, the Board agreed an action plan in response to the recommendations set out in
IBE’s report.
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In February 2022 the Board agreed a detailed action plan in response to the recommendations set out in IBE’s 2021 external Board
evaluation report, which included the following:-
Theme
2022 actions
Strategy
Introduce a new operating rhythm for Board engagement and oversight with more frequent sessions
during the year focused on key strategic topics.
Board focus and priorities
Agree a new set of Board objectives for 2022. Identify opportunities to streamline the Board agenda
and other Board activities to facilitate effective management of Board priorities.
Engagement with the
business and stakeholders
Identify further opportunities for non-executive directors to engage with the business and key
stakeholders either through participation in existing business initiatives or Board specific activity.
Colleague engagement
Review the Board’s overall approach to colleague engagement, including the role of the Colleague
Advisory Panel, to ensure it remains fit for purpose.
Implementation of the 2021 Board evaluation action plan will be overseen by the Group Nominations and Governance Committee
during 2022.
2021 Board Committee evaluations – outcomes
and actions
Details of the outcomes of the 2021 external Board Committee
evaluations can be found in the relevant Committee Chairman
reports. Progress against these actions will be tracked at
Committee level during 2022.
2021 Individual director and Chairman
effectiveness reviews
The Chairman met each director individually to discuss their
own performance and continuing professional development
and establish whether each director continues to contribute
effectively to the company’s long-term sustainable success.
The Chairman also shared peer feedback provided to IBE
as part of the evaluation process.
Separately, the Senior Independent Director, together with
the Senior Independent Director of the ring-fenced bank,
sought feedback on the Chairman’s performance from the
non-executive directors, executive directors and other key
internal and external stakeholders and discussed it with the
Chairman. This included peer feedback provided to IBE by
directors as part of the evaluation process.
Audit, risk & internal control
Information on how the company has applied the Principles
and complied with the Provisions set out in this section of
the Code can be found throughout the Annual Report and
Accounts. The following sections are of particular relevance:
the Group Audit Committee Chairman’s letter and the
report of the Committee (page 116) which sets out the
process undertaken to evaluate the effectiveness of both
the Internal Audit function and the external auditors in 2021,
and the principal findings thereof. It also explains the
approach taken to ensuring the integrity of financial and
narrative statements, and confirms that it supports the
Board in the assessment of NatWest Group’s disclosures
to be fair, balanced and understandable;
the viability statement (page 76) which details how the
Board has assessed the future prospects of NatWest
Group plc and the ways in which risks are considered
and managed in order to achieve its strategic objectives;
the Compliance report (page 181), which explains the
internal control framework in place; and
the Group Board Risk Committee Chairman’s letter and
report of the Committee (page 124) which explains how
the Board oversees the principal and emerging risks facing
NatWest Group and how management addresses these.
Remuneration
The Directors’ remuneration report on pages 136 to
139 provides information on the activities of the Group
Performance and Remuneration Committee, the decisions
taken on remuneration during the year and why the
Committee believes these are the right outcomes in the
circumstances. The report also details how the remuneration
policy for executive directors supports the delivery of the
company’s strategic goals and purpose, with significant
delivery in shares to provide long-term alignment with
shareholders. Information is also included on wider workforce
remuneration and the steps taken to engage with the
workforce around remuneration and ensure fair pay
and a healthy culture.
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Report of the Group Nominations
and Governance Committee
Corporate governance
continued
Dear Shareholder,
As Chairman of the Board and Chairman of the Group
Nominations and Governance Committee I am pleased to
present our report on the Committee’s activity during 2021.
Role and responsibilities
The Committee is responsible for reviewing the structure,
size and composition of the Board, and membership and
chairmanship of Board Committees and recommends
appointments to the Board. In addition, the Committee
monitors NatWest Group’s governance arrangements to
ensure that best corporate governance standards and
practices are upheld and considers developments relating
to banking reform and analogous issues affecting NatWest
Group. The Committee makes recommendations to the Board
in respect of any consequential amendments to NatWest
Group’s operating model.
The terms of reference of the Committee are reviewed
annually, approved by the Board and are available at
natwestgroup.com.
Principal activity during 2021
There were no changes to the composition of the Board during
2021. The Committee nevertheless acknowledges the tenure
of a number of current Board directors and therefore made
succession planning a priority in 2021. The Committee
reviewed the contribution of a number of Board members
under the Board Appointment Policy which sees non-executive
directors appointed for an initial three year term, subject to
annual re-election at the AGM. Following assessment by the
Committee, they may then be appointed for a further three
year term. Non-executive directors may continue to serve
beyond six years, subject to a maximum tenure of nine years.
The tenures of current Board directors is set out on page 81.
In addition to reviewing the structure, size and composition
of the NatWest Group plc Board, the Committee has also
continued to oversee work aimed at further enhancing
NatWest Group’s subsidiary governance framework. A number
of our material regulated subsidiaries made appointments to
their boards during 2021, which the Committee has overseen.
Spencer Stuart and Green Park have both been engaged
during the year to support NatWest Group’s subsidiary board
search activity. The firms are members of the retained
executive search panel of suppliers (managed by NatWest
Executive Search). Spencer Stuart also provide leadership
advisory and senior executive search and assessment services
to the Human Resources function within NatWest Group.
In addition to succession planning, the Committee has
overseen the process to reach agreement with the PRA in
respect of the renewal of regulatory modifications which
ensure the continuation of a governance model that is
compatible with ring-fencing legislation.
During the year the Committee continued to monitor
NatWest Group’s governance arrangements to ensure that
they remain appropriate by reference to best practices in
corporate governance (having regard to relevant legislation,
guidelines, industry practice and developments affecting
NatWest Group in the markets where it operates).
During 2021 the Committee considered a number of external
policy developments and the potential impacts on NatWest
Group’s corporate governance framework, including HM
Treasury’s independent review of ring-fencing and proprietary
trading, as well as discussion and consultation papers issued
by the FCA, PRA and Bank of England on proposals to
enhance diversity and inclusion in the financial sector.
Membership and meetings
Throughout 2021 the Committee comprised the Chairman
of the Board and four independent non-executive directors.
Graham Beale also observes meetings of the Committee in
his capacity as Senior Independent Director of NWH Ltd
and member of the NWH Ltd Nominations Committee.
The Committee holds a minimum of four meetings per year
and meets on an ad hoc basis as required. In 2021, there
were four meetings. Individual attendance by directors at
these meetings is shown in the table on page 103.
Letter from Howard Davies
Chairman of the Group Nominations
and Governance Committee
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Performance evaluation
The 2021 review of the effectiveness of the Board and its
senior Committees was facilitated by Independent Board
Evaluation, a specialist board evaluation consultancy. The
Committee has considered and discussed the outcomes of
the evaluation and accepts the findings, more information
on which can be found on page 112. Overall, the review
concluded that the Committee’s responsibilities had been
discharged effectively with no material recommendations
being identified for action. The Committee will continue to
ensure that the full Board is appropriately sighted on the work
of the Committee, including the Board succession activity
that will be a key priority for the Committee during 2022.
The outcomes of the evaluation have been reported to the
Board and the Committee will track progress during the year.
Boardroom Inclusion Policy
As noted on page 81, the Board operates a Boardroom
Inclusion Policy which reflects the most recent industry targets
and is aligned to the NatWest Group Inclusion Policy and
Principles applying to the wider bank. The policy currently
applies to the most senior NatWest Group boards: NatWest
Group plc, NWH Ltd, NWB Plc and RBS plc. A copy of the
Boardroom Inclusion Policy is available at natwestgroup.com/
who-we-are.
Objectives and targets
The Boardroom Inclusion Policy’s objectives ensure that the
Board, and any Committee to which it delegates nomination
responsibilities, follows an inclusive process when making
nomination decisions. That includes ensuring that the
nomination process is based on the principles of fairness,
respect and inclusion, that all nominations and appointments
are made on the basis of individual competence, skills and
expertise measured against identified objective criteria and
that searches for Board candidates are conducted with due
regard to the benefits of diversity and inclusion.
Monitoring and reporting
Throughout 2021 the Board met the recommendation of the
Parker Review with at least one member of the Board being
of Black, Asian or Minority Ethnic background and it intends
to continue to meet that recommendation.
At the end of 2021 the Board exceeded the recommendation
of the FTSE Women Leaders Review ((formerly the Hampton-
Alexander Report) 33% female representation on the boards),
with 36% of the Board being female.
The boards of NatWest Group plc and the NWH Group meet
consecutively and share a largely common membership.
When considered together, the director population across both
boards currently meets the Parker target and exceeds the
FTSE Woman Leaders target with a female representation
of 36%.
Diversity and inclusion progress, including information about
the appointment process, will continue to be reported in the
Group Nominations and Governance Committee’s report in
the NatWest Group plc Annual Report and Accounts.
The balance of skills, experience, independence, knowledge
and diversity on the Board, and how the Board operates
together as a unit, is reviewed annually as part of the Board
evaluation. Where appropriate, findings from the evaluation
will be considered in the search, nomination and appointment
process. Further details on NatWest Group’s approach to
diversity can be found on page 59.
Howard Davies
Chairman of the Group Nominations and
Governance Committee
17 February 2022
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Report of the Group
Audit Committee
Corporate governance
continued
Membership
Full biographical details of the members of the Committee
during 2021 are set out on pages 98 and 101. The members
are all independent non-executive directors who also sit on
other Board committees in addition to the GAC (as set out in
their biographies). This common membership helps facilitate
effective governance across all finance, risk and remuneration
matters and ensures that agendas are aligned and duplication
of responsibilities is avoided.
Members of the GAC are selected with a view to the expertise
and experience of the Committee as a whole and with proper
regard to the key issues and challenges facing NatWest Group.
As NatWest Group plc is a listed company on the London and
New York stock exchanges it has certain obligations as to the
expertise and qualifications of the Audit Committee. The Board
is satisfied that all GAC members have recent and relevant
financial experience and are independent as defined in the
SEC rules under the US Securities Exchange Act of 1934 (the
‘Exchange Act’) and related guidance. The Board has further
determined that Patrick Flynn, Mark Seligman and Robert
Gillespie are all ‘financial experts’ for the purposes of compliance
with the Exchange Act Rules and the requirements of the New
York Stock Exchange, and that they have competence in
accounting and/or auditing as required under the
Disclosure Guidance and Transparency Rules.
Dear Shareholder,
In 2021 the Group Audit Committee (GAC) has continued to
operate effectively, supporting NatWest Group to help people,
families and businesses to thrive. This report sets out the key
areas of focus for the GAC during the year and explains how
the Committee discharged its key responsibilities.
A core function of the Committee is to oversee and challenge
the processes undertaken by management in the preparation
of the published financial and relevant non-financial information.
The Committee also assists the NatWest Group Board in
carrying out its responsibilities relating to accounting policies
and internal control functions. More detail on the remit of the
Committee can be found in its terms of reference which are
reviewed annually and available at natwestgroup.com.
Scrutinising the integrity and quality of the financial results
released by NatWest Group over the course of the year
continued to be a priority for the Committee. As part of its
review of disclosures such as the quarterly, interim and full
year results, the Committee also considered detailed reports
from management on the judgments applied during the
preparation of the information and legal and regulatory
developments. Consideration was also given to management’s
assessment of the internal controls over financial reporting and
the GAC also received reports from both the internal auditors
on the internal control environment and the external auditors
on internal controls over financial reporting and key
accounting and judgmental matters.
The Committee reviewed the annual, interim and quarterly
supplements on climate, purpose and ESG matters, as well
as the annual Climate-related Disclosures Report. Particular
scrutiny was given to the controls and basis of preparation for
these releases. The Committee recognises such disclosures will
continue to evolve over time. The impact of climate-related
issues on financial statements more broadly was also
considered by the Committee during the year.
As the economic impacts of the COVID-19 pandemic and
measures taken by the Government in response persisted
throughout 2021, the Committee dedicated much time to
the consideration of accounting judgments. In particular the
Committee considered how the judgments were applied to
determining post-model adjustments, as well as the actual and
forecast impact on credit losses. The performance of internal
models used by management for these purposes continued
to improve following enhancements implemented in 2020.
Benchmarking data provided by the PRA and the external
auditor has again offered helpful context to the Committee
given the continued uncertain conditions.
The Committee oversight of the performance of the
Internal Audit function and ensuring its independence is a key
responsibility of the Committee. In February 2021 a new Chief
Audit Executive joined NatWest Group and I have supported
him in delivering enhancements to the operation and focus of
the Internal Audit function.
I have continued to be NatWest Group’s whistleblowing
champion, and the Committee maintains responsibility for
oversight of the independence, autonomy and effectiveness
of NatWest group’s whistleblowing policies and procedures.
In 2021 NatWest Group has continued to offer an effective
whistleblowing service to colleagues.
I welcomed the opportunity to respond to the consultation
launched by the Department for Business, Energy and
Industrial Strategy (BEIS) into audit and corporate governance.
Stakeholders were invited to share their views on a range of
proposals relating to the UK’s corporate governance framework
for major companies and the way they are audited. I shared
my views as Chairman of the GAC on the most pertinent
proposals, which were submitted alongside a detailed NatWest
Group-wide response. I would like to extend my thanks to
my fellow Committee members and attendees for their
contributions to the work of the GAC during 2021.
Patrick Flynn
Chairman of the Group Audit Committee
17 February 2022
Letter from Patrick Flynn
Chairman of the Group Audit
Committee
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Meetings and visits
Five scheduled meetings of the Committee were held in 2021,
four of which took place immediately prior to the release of
the financial results each quarter. During the year all members
attended the meetings, all of which were held virtually. All
meetings were also attended, in an observational capacity,
by the two non-executive directors of NatWest Holdings
who are members of that entity’s Audit Committee.
In conjunction with the Group and NWH Board Risk Committee
(BRC) and the NWH Audit Committee, the GAC undertook its
annual programme of visits to control functions. Constructive
and insightful discussions were held with members of
management from the Risk, Internal Audit and Finance teams.
Performance evaluations
In 2021 the annual review of the effectiveness of the Board
and its senior Committees, including the GAC, was conducted
externally by Independent Board Evaluation. It was determined
that the GAC had continued to operate effectively during 2021,
Financial and non-financial reporting
The GAC considered a number of accounting judgments and reporting issues in the preparation of NatWest Group’s financial
results throughout 2021. The Committee reviewed the quarterly, interim and full year results announcements, the annual reporting
suite of documents and other principal financial and non-financial releases for recommendation to the NatWest Group plc Board for
approval. This included the disclosures required by the TCFD and the quarterly Climate, Purpose and ESG measures supplements.
Consideration was given to the controls surrounding the preparation of these releases.
Matter
Role of Committee and
context of discussion
How the Committee addressed the matter
Expected
credit losses
To review and challenge
management’s judgements
in relation to credit
impairments and the
underlying assumptions,
methodologies and models
applied, and any post-model
adjustments required. To
also consider the impact of
macro-economic risks on
the credit environment.
The GAC focused on the key assumptions, methodologies and post-model
adjustments applied to provisions under IFRS 9. The continued economic
uncertainty during 2021 and the dislocation between the economics and
the credit impacts observed, led management to adopt a measured
approach to the release of IFRS 9 provisions in the year. In evaluating
management’s proposal to release £1.3 billion, the Committee considered
the previously implemented enhancements to the internal models and
the improvements in the economic environment during 2021. Industry
benchmarking data, particularly in the first half of the year, was also
helpful to the Committee and informed its considerations. The Committee
recognises that post-model adjustments should be limited to considerations
beyond model capability and so sought from management confirmation
of the criteria which would need to be satisfied to enable their release.
The Committee will continue to scrutinise the application of post-model
adjustments in 2022.
Treatment
of goodwill
To consider the treatment
of goodwill throughout
the year and ensure
the carrying value was
appropriate and suitable
disclosures were made.
Management did not identify any reason to undertake an out of
cycle reassessment of goodwill during 2021. Following discussion and
challenge, the Committee was satisfied that goodwill remained recoverable
throughout the year, and that appropriate disclosures were included in the
quarterly and interim financial releases. The Committee considered and
supported management’s proposed write down of £85 million of goodwill in
RBS (and at higher levels) on the basis of materiality at the end of the year.
Valuation
methodologies
To consider valuation
methodologies, assumptions
and judgments made
by management.
The GAC considered valuation methodologies and assumptions for
financial instruments carried at fair value and scrutinised judgments made
by management.
meeting its statutory duties. The outcomes of the evaluation
were considered by the Committee and subsequently reported
to the Board. The Committee will support management’s
consideration of the recommendation to review the leadership
structure of the Finance function, and this was discussed with
the Group CFO in the context of talent development and
longer term planning for the function. The Committee also
welcomed the recommendation to improve the diversity of
the Committee membership, and this will be reviewed by the
Nominations and Governance Committee as part of its ongoing
business. The depth of financial expertise of the Committee
was also recognised via the evaluation. The Committee is
satisfied it fulfilled its terms of reference in 2021.
The Committee continued to monitor the performance of the
external auditor and the Internal Audit function in 2021. Formal
assessments were undertaken at the end of the year via an
internal process and the Committee reviewed summaries of
the feedback provided by relevant stakeholders. Progress
made to address the recommendations of the previous
year’s evaluations was welcomed.
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Report of the Group Audit Committee
continued
Matter
Role of Committee and
context of discussion
How the Committee addressed the matter
Provisions and
disclosures
To consider the level of
provisions for regulatory,
litigation and conduct issues
throughout the year.
The Committee reviewed the levels of provisions during the year for
regulatory, litigation and conduct matters, and was satisfied these were
appropriate. The timing of certain litigation provisions was discussed with
management and the external auditor, and the Committee concluded
that it was only appropriate to record a provision once there was reliable
estimate as to the quantum. The Committee welcomed the conclusion of
a number of historic conduct and litigation matters during the year.
Viability statement
and the going
concern basis
of accounting
To review NatWest
Group’s going concern
and viability statements.
The GAC considered evidence of NatWest Group’s capital, liquidity and
funding position and considered the process to support the assessment
of principal risks. The GAC reviewed the company’s prospects in light of
its current position, the identified principal and emerging risks (including
climate risk) and the ongoing economic uncertainty resulting from the
pandemic. FRC guidance and reviews of peer disclosures were considered
as part of the preparation of the viability statement for NatWest Group.
The Committee recommended both the going concern assessment and
viability statement to the Board. (Refer to the Report of the directors for
further information.)
Fair, balanced and
understandable
To oversee the review
process which supports
the Committee and Board
in concluding that the
disclosures in the Annual
Report and Accounts and
other elements of the
year-end reporting suite
of documents, taken as a
whole, are fair, balanced
and understandable and
provide the information
necessary for shareholders
to assess the company’s
position and performance,
business model and strategy.
The Committee oversaw the review process for the year-end disclosures
which included: central coordination and oversight of the Annual Report
and Accounts and other disclosures led by the Finance function; review
of the documents by the Executive Disclosure Committee prior to
consideration by the GAC; and a management certification process of the
year-end reporting suite. The Committee considered whether the annual,
interim and quarterly disclosures met the UK Corporate Governance Code
requirements to be ‘fair, balanced and understandable’. It concluded each
time that the releases satisfied the necessary criteria. The external auditor
also considered the fair, balanced and understandable statement as part
of the year-end processes and supported NatWest Group’s position.
Non-financial
reporting
To review the principal
non-financial disclosures
made by NatWest Group
and to ensure appropriate
controls are in place to
support the preparation
of the information. These
disclosures include the
annual Climate-related
Disclosures Report and the
Climate, Purpose and ESG
measures supplement
published each quarter.
As NatWest Group’s non-financial reporting has continued to evolve
in 2021, the Committee has remained focused on ensuring robust
and appropriate controls supported the preparation of the disclosures,
which aligned with the existing measures in place in relation to financial
disclosures. The Committee discussed the merits of publishing this
information separately or as part of the interim and full-year results
announcements, and concluded that releasing separate documents
would be most useful for external stakeholders accessing the information.
Industry best-practice and the output of peer reviews were considered
to ensure NatWest Group is disclosing an appropriate and useful level
of information, and this will continue to be reviewed going forward. The
Committee considered the outcome of the reviews of the documents
by management via the Executive Disclosure Committee and its sub-
committee which focuses specifically on ESG disclosures. The Committee
welcomed the extension of the risk and control assessments and the
addition assurance work being undertaken by the external auditor.
The Committee was satisfied that appropriate steps had been taken
by management to limit the legal liability arising from the disclosure of
such non-financial information. It received advice from NatWest Group
Reputational Risk Committee as to the risk of reputational impacts in the
event of a misstatement or future change in methodology which could
give rise to suggestions of ‘greenwashing’.
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Systems of internal control
Systems of internal control relating to financial management, reporting and accounting issues is a key area of focus for the
Committee. In 2021 it received reports throughout the year on the topic and evaluated the effectiveness of NatWest Group’s
internal control systems, including any significant failings or weaknesses.
Matter
Role of Committee and
context of discussion
How the Committee addressed the matter
Sarbanes-Oxley Act
of 2002
To consider NatWest
Group’s compliance with the
requirements of section 404
of the Sarbanes-Oxley Act
of 2002.
The Committee received interim updates on the status of the bank’s
internal controls over financial reporting throughout 2021 enabling it to
monitor progress and support management’s conclusion at the year-end
that there were no Material Weaknesses for NatWest Group. Two
Significant Deficiencies were addressed by management during the year.
The Committee monitored progress and supported management’s
approach which allowed the matters to be downgraded prior to the
end of the year.
The Committee also reviewed the process undertaken to support the
Group CEO and Group CFO in providing the certifications required
under sections 302, 404 and 906 of the Sarbanes-Oxley Act of 2002.
Regulatory and
financial returns
To review the controls and
procedures established by
management of NatWest
Group for compliance with
regulatory and financial
reporting requirements.
In December 2019 the PRA announced an industry-wide review of
regulatory returns via means of a skilled persons report. In 2020, the
Committee approved the appointment of EY as the skilled person to
undertake the review for NatWest Group, given the external auditor’s
extensive knowledge of our internal systems and processes. The
Committee received regular updates on the review and while the skilled
person raised a number of findings, there were none which indicated
material errors with the regulatory returns. The Committee encouraged
management to work collaboratively across the bank to ensure the
necessary regulatory deadlines were met while ensuring business as
usual work continued to be delivered. Three industry-wide themes were
identified by the skilled person reviews: governance and ownership;
controls; and data and investment. The Committee reviewed the formal
remediation plans submitted to the PRA in response to the industry-wide
findings and those specific to NatWest Group. It received assurances from
management that appropriate resource was available to execute the plans
and that the timescales were manageable. On this basis it approved the
plans. The ongoing work to further strengthen the controls surrounding
the preparation of regulatory returns has also been closely monitored and
supported by the Committee throughout 2021; this will continue in 2022.
Control
Environment
Certification
To consider the control
environment ratings of the
businesses, functions and
material subsidiaries and
management’s actions to
ensure that the control
environment is maintained
or strengthened.
Management provided bi-annual reports on the Control Environment
Certification, which were supplemented by the views of the second and
third lines of defence. Changes in ratings during the year by certain
businesses and functions were noted and supported by the Committee.
Return to appetite plans have been developed by management for
all major areas which was welcomed by the Committee. The most
significant plans are regularly reviewed and challenged by the
relevant Board Committee.
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Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Matter
Role of Committee and
context of discussion
How the Committee addressed the matter
Notifiable
event process
To monitor control breaches
captured by the internal
notifiable event process.
The Committee received bi-annual updates on the volumes and nature of
the most significant control breaches escalated via the internal notifiable
event process and any common themes. Process-related issues accounted
for the majority of the most significant events in 2021, and the Committee
noted the high level of manual elements to processes across the bank.
It requested management report on how greater automation could be
implemented to NatWest Group’s key processes and systems. The work
launched by the Chief Transformation Officer in this respect in relation to
Customer Journeys was welcomed and will be monitored going forward.
Where process issues had not been the cause of control breaches the
Committee encouraged management to ensure the root causes of these
issues are remediated. The outcome of an internal review of the process to
ensure it was operating as expected was also presented to the Committee.
All Board directors were alerted to the most significant breaches
throughout the year.
Whistleblowing
To monitor the effectiveness
of the bank’s whistleblowing
policies and procedures.
The Committee chairman
is also the whistleblowers’
champion for
NatWest Group.
The GAC monitored the effectiveness of the bank’s whistleblowing process
and received updates on the volume of whistleblowing reports and any
common themes. The results of the annual Our View survey indicated that
colleagues’ awareness of how to raise concerns was high and that the
majority of respondents reported they felt safe to do so and that concerns
raised would be handled appropriately. The Committee considered the
output of Internal Audit’s annual review of the whistleblowing process,
and welcomed the largely positive results.
The GAC Chairman acts as NatWest Group’s Whistleblowers’ Champion,
in line with PRA and FCA regulations, and meets regularly with the
whistleblowing team. Whistleblowing is also discussed regularly with the
chairs of the principal subsidiary audit committees to ensure a common
and coordinated approach across the bank, and the Board is updated on
these and the GAC’s discussions as appropriate.
Legal and
regulatory reports
To note material legal
investigations (current and
emerging) and any impacts
on financial reporting; and to
monitor the bank’s
relationship with relevant
regulatory bodies including
the FCA and PRA.
Quarterly reports were presented to the Committee setting out updates on
new and existing major investigations and litigation cases. The Committee
considered provision levels and the impact on each quarterly financial
results disclosure and was satisfied in both respects. The Committee also
received updates on ongoing regulatory investigations, current and future
areas of regulatory focus and the nature of the relationships with the
primary regulators.
Other standards
of control
In addition, the Committee
receives regular updates on
matters pertinent to NatWest
Group’s standards of
internal control.
The Committee received an update on the bank’s tax position and
discussed matters including tax disclosures and provisions, NatWest
Group’s tax compliance status, the relationship with HMRC, the UK bank
levy and emerging and forthcoming tax issues (including the likely post-
COVID-19 tax environment and the impact on the OECD Pillar 2 rules
on NatWest Group).
The GAC reviewed the disclosure on internal control matters in conjunction
with the related guidance from the Financial Reporting Council.
Report of the Group Audit Committee
continued
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Internal Audit
The GAC is responsible for overseeing the Internal Audit function, monitoring its effectiveness and independence.
Matter
Role of Committee and
context of discussion
How the Committee addressed the matter
Quarterly opinions
To consider periodic
opinion reports prepared
by Internal Audit on the
overall effectiveness
of the governance, risk
management and internal
control framework, current
issues and the adequacy of
remediation activity.
Quarterly opinion reports were provided to the Committee by Internal
Audit, setting out its view of the overall effectiveness of NatWest Group’s
governance, risk management and internal control framework, current
issues and the adequacy of remediation activity. Internal Audit also
outlined material and emerging concerns identified through their audit
work. Over the course of the year Internal Audit reported a gradual
improvement in the bank’s control environment as the wider economic
recovery from the COVID-19 pandemic continued. The Committee
welcomed Internal Audit’s views on major programmes being undertaken
by the bank such as the remediation of financial crime matters, the
implementation of the Enterprise Wide Risk Management Framework and
delivery of the One Bank transformation programme. The importance of
increasing automation across the bank’s processes was also evident in
Internal Audit’s reports, and this was explored further by the Committee,
as noted above.
Annual plan
and budget
To approve Internal Audit’s
annual plan and budget
prior to the start of each
year as well as any
significant changes
required during the year.
The Committee considered and approved Internal Audit’s 2021 plan and
budget at the end of 2020. Following the appointment of a new Chief Audit
Executive (CAE) certain refinements to the focus of the plan were made
and these were discussed with the Committee throughout 2021. The
Committee encouraged the function to increase its focus on validating
the closure of prior findings by management. The Committee approved
an increase to Internal Audit’s budget for 2021 to support recruitment
to ensure there were appropriate resources available to deliver the plan.
In December 2021, the Committee approved Internal Audit’s 2022 plan
and budget.
Internal Audit
Charter and
independence
To approve the Internal
Audit Charter each year and
reviews the independence of
the CAE and function as
a whole.
The GAC reviewed and approved the Internal Audit Charter which was
consistent with prior years. The Committee noted the Independence
Statement and confirmed the independence of Internal Audit. In line with
the revised industry guidance issued in September 2017 and in order to
maintain the independence and perceived independence of both the role of
CAE and the wider Internal Audit function, a new CAE was appointed in
2020 and joined NatWest Group in February 2021.
Performance/
evaluation
To monitor and review,
at least annually, the
effectiveness of
Internal Audit.
In line with prior practice and industry guidance, the CAE continued to
report to the GAC Chairman in 2021, with a secondary reporting line to
the Group CEO for administrative purposes. The GAC assessed the annual
performance (including risk performance) of the function and CAE.
The 2021 evaluation of the Internal Audit function was carried out
internally. Key stakeholders across the bank, including the GAC members,
attendees and the external auditors provided feedback, identifying areas
of particular strength and those for enhancement. The overall findings
were positive, and the Internal Audit function was found to be operating
effectively with continued improvement in most areas being noted. Certain
areas for continued development were identified, including: the greater use
of integrated audits, increased use of digital tools, and building bench-
strength. Progress will be overseen by the GAC in 2022.
Visit
To undertake an annual
deep dive session with
members of the Internal
Audit leadership team.
In conjunction with the BRC, the GAC participated in a successful deep
dive session with members of the Internal Audit team in 2021. A variety of
issues impacting the Internal Audit function were discussed, including
succession planning and bench-strength of the function and its recent
work to fully implement integrated audits and extend its use of data
analytics. The Committee was very encouraged by the innovative
approach being taken in these areas and the clear benefits to both
the function and the wider business.
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Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Report of the Group Audit Committee
continued
External audit
The GAC has responsibility for monitoring the independence and objectivity of the external auditor, the effectiveness of the audit
process and for reviewing the bank’s financial relationship with the external auditor and fixing its remuneration. Ernst & Young LLP
(EY) has been NatWest Group’s external auditor since 2016, following a tender process carried out in 2014.
Matter
Role of Committee and
context of discussion
How the Committee addressed the matter
External
audit reports
To review reports prepared
by the external auditor in
relation to NatWest Group’s
financial results and
control environment.
The Committee received quarterly reports on the audit-related work
and conclusions of the external auditor. The reports included EY’s view
of the judgments made by management, compliance with international
financial reporting standards and the external auditor’s observations and
assessment of effectiveness of internal controls over financial reporting.
The GAC also received helpful benchmarking information from EY during
the course of the year and in particular relating to the accounting
treatment of the impacts of the COVID-19 pandemic. The Committee
received all communications from EY required by UK auditing standards,
SEC and NYSE rules, including 2021 audit quality and transparency
reports.
Audit plan and fees
To consider the scope and
planning of the external
auditor in relation to the
audit of NatWest Group.
It is also authorised by the
shareholders to fix the
remuneration of the
external auditor.
The GAC reviewed EY’s 2021 plan. It welcomed the external auditor’s
intention to make greater use of digital tools in its work. In line with the
authority granted to the Committee by shareholders at the 2021 Annual
General Meeting (AGM) to fix the remuneration of the external auditor,
the GAC approved the audit fees for the year including the fee for the 2021
interim results. The Committee received confirmation from the external
auditor that the fees were appropriate to enable delivery of the required
procedures to a high quality.
Annual evaluation
To review and monitor
the external auditor’s
independence and objectivity
and the effectiveness of the
audit process, taking into
consideration all relevant
professional and
regulatory requirements.
In 2021 an internal evaluation was carried out on behalf of the Committee
to assess the independence and objectivity of the external auditor and the
effectiveness of the audit process. The GAC members, attendees, finance
directors of customer businesses and functions, and key members of the
Finance team were consulted as part of the evaluation. The process
assessed the external auditor’s independence, engagement, provision of
robust challenge, bench-strength and reporting. The evaluation concluded
that the external auditor was operating effectively and with objectivity.
Respondents reported improvements in relation to the quality of
engagement and challenge in 2021, as well as enhancements in certain
aspects of the audit team’s bench-strength. Some suggested areas for
consideration to further strengthen effectiveness included: refining written
reports provided to senior Committees, exploring opportunities to leverage
the work undertaken by other teams within EY and Internal Audit, and to
continue to share its valuable insights on the emerging area of reporting on
climate metrics. Following the evaluation, the GAC recommended that the
Board seek the reappointment of EY as external auditor at the next AGM.
The Committee noted the positive results of the audit quality reviews of
EY’s 2020 audit by the FRC and PCAOB during 2021.
Audit partner
To oversee the lead audit
partner and resolution of
any points of disagreement
with management.
In February 2021 Micha Missakian succeeded Jonathan Bourne as EY’s
lead audit partner for NatWest Group, following the conclusion of Mr
Bourne’s five year term in role. Mr Missakian attended all meetings of the
Committee in 2021. The Committee members met in private session with
Mr Missakian twice during the year to ensure the external auditor had
an opportunity to raise any points of disagreement with management.
No such points were raised by the external auditor in 2021.
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Matter
Role of Committee and
context of discussion
How the Committee addressed the matter
Additional reports
prepared by the
external auditor
To review reports prepared
by the external auditor in
relation to NatWest Group.
During 2021 various additional reports prepared by the external auditor
were considered by the Committee. These included the results of the
external auditor’s assurance procedures on compliance with the FCA’s
Client Asset Rules for NatWest Group’s regulated legal entities for the year
ended 31 December 2021. The Committee also received the outcome of
EY’s written auditor report to the PRA under supervisory statement SS1/16
for the year ended 31 December 2021, noting that the matters identified
were already being addressed by management. The Committee Chairman
also contributed to a review of the process and its efficacy by the PRA.
Non-audit services
To review and approve,
at least annually, NatWest
Group’s policy in relation
to the engagement of the
external auditors to perform
audit and non-audit services
(the policy). All audit and
non-audit services are
approved by, or on behalf of,
the Committee to safeguard
the external auditor’s
independence
and objectivity.
The GAC reviewed and approved NatWest Group’s non-audit services
policy in 2021. Under the policy, audit-related services and permitted
non-audit service engagements may be approved by the Group CFO up to
certain financial thresholds. Engagements in excess of these limits require
the approval of the GAC chairman. Where the fee for a non-audit service
engagement is expected to exceed £100,000, a competitive tender process
must be held; where the fee is anticipated to be £250,000 or more approval
of all GAC members is required. The policy permits the external auditor to
undertake engagements which are required by law or regulation or which
relate to the provision of comfort letters in respect of debt issuances by the
NatWest Group, provided prior approvals are in place in accordance with
the policy. The policy also allows NatWest Group to receive services from
EY which result from a customer’s banking relationship, provided prior
approvals are in place in accordance with the policy. All such approvals
are subsequently reported to the GAC.
During 2021 the Committee approved, on an ad hoc basis, three significant
non-audit engagements (where the fees exceeded £100,000) to be
undertaken by the external auditor. These related to: assurance over
selected ESG metrics; the audit of client money and assets (CASS); and the
audit of LIBOR submissions. The latter two engagements are annual audits
required under UK regulations and in prior years had been approved as
part of the consideration of the total audit fees. Given the external
auditor’s knowledge of the emerging area of climate-related disclosures
and the alignment to other year-end reporting the Committee determined
that EY were best placed to undertake this work. The audit to non-audit
fee ratio for 2021 was 18%. Further details of the non-audit services policy
can be found at natwestgroup.com. Information on fees paid in respect of
audit and non-audit services carried out by the external auditor can be
found in Note 6 to the consolidated accounts.
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Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Corporate governance
continued
Dear Shareholder
I am pleased to present my second report as Chairman of
the Board Risk Committee (the Committee or BRC).
This report describes how the BRC has fulfilled its role
overseeing and advising the Board in relation to current
and potential future risk exposures and risk profile; and
in overseeing the effectiveness of risk management
frameworks. In carrying out this important role, the Committee
helps to ensure that NatWest Group is purpose-led in its
decision-making, building long-term value in the business.
More detail on the remit of the Committee can also be found
in its terms of reference which are reviewed annually and
available at natwestgroup.com.
During 2021 the committee ensured its time was prioritised to
focus on oversight of NatWest Group’s principal and emerging
risks, including improvements to the management of financial
crime risk, model risk improvements, and the risk impacts of
developments in the external environment as a result of
COVID-19. It has also maintained oversight of the continued
enhancement of the enterprise-wide risk management
framework and the development of regular risk reporting
to drive more insightful reporting to the Board.
It is expected that these will continue to be areas of focus
in 2022 as NatWest Group drives towards return to appetite
in a number of areas and further impact of COVID-19
is experienced.
Further information on key topics considered during the
year and areas of focus and challenge by the Committee
is provided on the following pages.
I would like to thank my fellow Committee members
for their continued commitment, support and challenge
throughout the year.
Morten Friis
Chairman of the Group Board Risk Committee
17 February 2022
Report of the Group
Board Risk Committee
Membership
BRC comprises four independent non-executive directors.
The details of the members and their skills and experience
are set out on pages 98 to 101.
Patrick Flynn is chairman of the Group Audit Committee
of which Robert Gillespie and I are also members. Robert is
also chairman of the Group Performance and Remuneration
Committee (RemCo) and Lena Wilson sits on this Committee.
This common membership across Committees helps to ensure
effective governance across the committees.
Regular attendees at BRC meetings include: the Group
Chairman, Group Chief Executive Officer, Group Chief
Financial Officer, Group Chief Risk Officer, Group Chief Legal
Officer and General Counsel, Group Chief Audit Executive
and the external auditor. External advice is sought by the
Committee where appropriate.
Two non-executive directors of NWH Ltd (the ring-fenced
bank) attended Committee meetings as observers in their
capacity as members of NWH Ltd’s BRC. Meetings of the
Group and NWH Ltd’s BRCs share much of a common
agenda and are generally run in parallel.
Meetings and visits
There were eight scheduled meetings of the Committee held in
2021 and one ad hoc meeting of members only was required
to discuss executive remuneration matters. The majority
of meetings were held virtually during the year due to the
pandemic but there was one in person meeting arranged
in the second half of the year when circumstances allowed.
Details of meeting attendance can be found on page 103.
Outside of formal meetings, the Committee also held an
additional meeting on financial crime and met with the Risk
Leadership Team to help build relationships and provide the
team with greater insights on the Committee’s perspectives.
Members of the Group and NWH Ltd’s BRCs also undertook
a programme of visits to the Risk, Internal Audit and Finance
functions, in conjunction with members of the Group and
NWH Ltd’s Audit Committees.
Letter from Morten Friis
Chairman of the Group Board
Risk Committee
“BRC has focused on oversight of
NatWest Group’s principal risks,
including financial crime risk
management and model risk
management, whilst also overseeing
improvements in the quality of
underlying risk management
frameworks and reporting.”
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Performance evaluation
Throughout the year the Committee acted in accordance with its terms of reference. The annual review of the effectiveness of the
Board and its Committees, including BRC, facilitated by Independent Board Evaluation, a specialist board evaluation consultancy.
Overall, the review concluded that the Committee operated effectively and had evolved in a positive way. Some areas for potential
enhancement were also identified which included streamlining reporting and driving action to address major issues of reputational
significant to NatWest Group. These will be areas of focus for 2022.
Key matters considered by the Committee in 2021
Matter
Context of discussion
How the Committee addressed the matter
Financial crime
Oversight of the
management and return to
appetite of financial crime
risk, which continues to be a
top risk for NatWest Group.
Given the critical importance of the management of financial crime, the
Committee held an additional focus session in January 2021 to discuss the
detailed return to appetite plans and proposed management information
requirements to ensure the Committee was provided with appropriate
reporting to track progress throughout the year. The Committee received
quarterly updates from all three lines of defence which included updates
on progress on return to appetite plans, transformation, emerging risks
and issues, and the Skilled Person’s report findings. In addition, the
Committee considered the Money Laundering Reporting Officer’s (MLRO’s)
report, from the newly appointed MLRO, and considered the enterprise-
wide financial crime risk assessment. The CRO reported on the financial
crime risk profile and progress on remediation as part of the risk
management report at each meeting. Throughout the year, the Committee
challenged management on return to appetite slippage, adequacy of
resource and external support, and the pace of transformation and
remediation to drive improvements in financial crime to ensure we
can protect our customers.
Model risk
BRC maintained close
oversight of management
activity to return to appetite
for model risk.
The Committee evaluated the appropriateness of the model risk
management framework, including required model changes, regulatory
approval thereof, and the return to appetite plan. The Committee
requested a number of additional spotlight sessions in March, July,
September and October 2021 to maintain close oversight of progress. In
intervening months, updates were given via the risk management report.
The Committee requested additional metrics to differentiate between
models where remediation and validation had been completed but
regulatory approval had not been obtained from those models where
management action was still underway and there was particular focus on
progress of IFRS9 and Internal Ratings Based (IRB) models. The Committee
held management to account in relation to return to appetite plans and
sought clarity on accountabilities. Specific consideration of the impact of
model weaknesses was considered as part of separate discussions
regarding capital distributions, ICAAPs and stress testing updates.
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Financial review
Governance
Risk and capital management
Additional information
Financial statements
Matter
Context of discussion
How the Committee addressed the matter
Enterprise Wide
Risk Management
Framework
(EWRMF)
enhancement
(including risk
appetite)
BRC monitored the
effectiveness of the risk
management framework
including further significant
enhancements to the risk
governance arrangements
of NatWest Group.
The EWRMF is NatWest Group’s primary risk management and risk
governance document providing a framework to deliver strategy in a safe
and sustainable way. A number of key enhancements to the EWRMF were
considered by BRC and recommended to Board during 2021, including: the
elevation of the EWRMF to a Board-approved framework; the assimilation
of and enhancement to the pre-existing Board-approved Risk Appetite
Framework within the EWRMF; transitioning all principal risk appetite
measures to Board approved measures; and requiring all principal risk
policies to be approved by the Committee. Further details of these changes
can be found in the Risk management section of the report on page 188.
These enhancements better align NatWest Group with peers and
regulatory expectations. The Committee considers the implementation
of the EWRMF to be of significant importance to NatWest Group’s robust
risk management and requested regular updates on the progress of the
implementation of the EWRMF via the risk management report.
The Committee oversaw the refresh of both qualitative risk appetite
statements and the quantitative risk appetite measures in line with the
enhanced EWRMF and monitored the risk profile of NatWest Group relative
to risk appetite via the risk management report. The risk appetite refresh
included the introduction of climate risk as a principal risk with associated
risk appetite statement and measures aligned to external climate
commitments and NatWest Group’s strategic ambition, acknowledging that
management of this long-term risk will continue to evolve. A more strategic
approach to reputational risk appetite was introduced and the Committee
challenged management to ensure conduct risk appetite is a key focus of
the Board, as well as more generally ensuring risk appetite triggers and
limits are appropriately set. Changes to the manner in which earnings
stability risk appetite is managed and monitored and the framework
to manage capital targets were reviewed by the Committee and
recommended for Board approval. The Committee also challenged
management to develop a more quantitative approach to risk appetite for
all non-financial risks, including conduct, compliance and operational risk
and these were introduced as part of the risk appetite refresh in December
2021. The Committee oversaw the enhancement of the approach to
ensure alignment between risk appetite measures. All of these changes
were subject to detailed review and challenge by the Committee. The
Committee received specific spotlights in respect of all principal risks
during the year.
Report of the Group Board Risk Committee
continued
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Matter
Context of discussion
How the Committee addressed the matter
Risk profile
and reporting
Time was spent at every
BRC meeting reviewing
NatWest Group’s current
and future risk profile
relative to risk appetite,
with a particular focus on
COVID-19 impacts, and
scrutinising management’s
actions to monitor and
control exposures.
Risk management reports – The Committee considered detailed analysis
on NatWest Group’s risk profile, including the UK and global economic
outlook, top and emerging risks and threats, and NatWest Group’s
performance against risk appetite at each of its meetings via risk
management reports. During 2021, the format and content of the
report evolved, including integration with the Nerve Centre management
information tool which provided additional optional detail to directors.
The Committee sought a number of changes to the report to drive
more insightful reporting, including more detail on actions being taken
to mitigate top risks, implementation of EWRMF, credit risk and the
Commercial Real Estate portfolio and this work will continue into 2022.
The ongoing impact of COVID-19 on the economy, our customers and
our colleagues was a key element of discussions throughout the year,
particularly the manner in which the better than expected recovery
was managed from a risk perspective. Other key areas of focus included
financial crime and model remediation; the control environment and issues
related thereto; regulatory compliance and conduct issues; embedding
climate risk; operational and change risk; and management of the
correlation of top risks. Reports on legal and regulatory developments
and litigation risks were considered quarterly. The CRO also reported
on key matters discussed at the Executive Risk Committee.
Updates from Subsidiary Risk Committees – Quarterly reports were
received from the Chairmen of the management risk committees of
the franchises and the board-level risk committees of material regulated
subsidiaries providing an overview of issues being overseen and a channel
for escalation of issues. The Chairmen of the Board Risk Committees of
material regulated subsidiaries were invited to join meetings throughout
the year, providing updates on key areas of focus.
Capital, funding
and liquidity risk
BRC completed a detailed
review of capital, funding
and liquidity requirements
and also reviewed the
capital distribution proposals.
ICAAPs, ILAAPs and budget stress tests – The BRC considered the
budget and budget stress test as well as the ILAAP and ICAAP for NatWest
Group and recommended them to the Board for approval. It challenged
management to ensure that prior regulatory feedback had been addressed
and that Risk and Internal Audit improvement recommendations would
be incorporated in 2022 submissions. The Committee reviewed and
recommended to the Board the scenarios to be used during 2022 for the
Budget, IFRS 9, Earnings Stability, the ICAAP and the ILAAP and noted that
management would continue to use this suite of scenarios throughout
2022, in response to prior feedback from the Committee.
Capital distributions – The Committee provided detailed review of
proposals to increase capital distributions to shareholders, prior to
approval by the Board, including creation of an on-market buyback plan,
following the improved projected capital position of NatWest Group in
comparison to the initial view of impacts from COVID-19. The Committee
challenged management on the CET1% target, the manner in which
capital would be deployed over the plan, and how excess capital would
be managed.
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Financial review
Governance
Risk and capital management
Additional information
Financial statements
Matter
Context of discussion
How the Committee addressed the matter
Stress testing
BRC reviewed in detail the
stress testing activity
undertaken by management
to identify and monitor risks
and threats and in relation
to the SST and CBES,
challenging and scrutinising
the outputs.
Stress testing capabilities – The Committee also received an update on
improvements in the stress testing capabilities and realignment of stress
testing activity and accountabilities within NatWest Group. This included
the development of enhanced scenario analysis capabilities to support
the calibration of risk appetite measures, earnings stability risk profile
and dynamic capital planning targets.
Bank of England stress tests – The BRC performed a detailed review of
the 2021 Bank of England Solvency Stress Test (SST) and the Biennial
Exploratory Stress Test, examining the impact on NatWest Group of
potential climate change scenarios (CBES) and recommended the results
of both stress tests to the Board. The Committee approved the scenarios
for these stress tests, under delegated authority from the Board, including
scenario expansion, and considered significant judgments, the impact of
model weaknesses, the results and proposed management actions. The
Committee acknowledged the limitations of the CBES in its preliminary
year and that NatWest Group will continue to develop its modelling and
data capabilities. To ensure directors had sufficient understanding of the
CBES activity in its introductory year, the Committee received a series of
supporting training video materials to help contextualise the process
and results.
Recovery plans and
the resolvability
self-assessment
BRC monitors and
challenges the development
of plans which would allow
NatWest Group to be dealt
with effectively in the event
of financial failure.
Recovery Plan – BRC performed the detailed review of the NatWest Group
Recovery Plan prior to approval by the Board. The Committee sought
confirmation from management that NatWest Group had adequate
capacity and capabilities in a recovery scenario and requested that the
dynamic nature of capital planning targets and their impact on CET1
recovery level thresholds be clarified.
Resolvability self-assessment – The Committee reviewed management’s
approach to its first Resolvability self-assessment and reviewed and
recommended the results of the self-assessment to the Board for approval.
The Committee discussed the risks to resolvability and sought comfort
on observations from Risk and Internal Audit regarding the limited
restructuring options. In advance of approval, the Board undertook
a training session on directors’ duties in Resolution.
Control
environment
BRC continued to monitor
the effectiveness of internal
controls required to
manage risk.
Control Environment Certification and oversight – The Committee
was provided with updates regarding the control environment ratings of
NatWest Group, franchises, functions, services, and legal entities. Particular
areas of focus were NatWest Markets and RBSI and the Committee sought
comfort from management on the key activities to improve ratings,
including financial crime, model risk and surveillance systems. The
Committee received regular updates on trends in the NatWest Group
Notifiable Event Process notifications and management focus on the
culture of escalating issues timeously. The Committee reviewed and
supported management’s report on the effectiveness of internal
controls required to manage risk.
Risk culture – To support the Board in its role, BRC received updates on
progress to align NatWest Group’s culture to its purpose and strategy,
which includes refreshing the approach to risk culture under the banner
‘Intelligent Risk Taking’ as a fundamental pillar within the One Bank
culture. This places emphasis on risk appetite alignment with strategic
goals, analytically supported decisions and behaviours such as openness,
challenge and raising issues early. The Committee encouraged
management to consider tolerance for failure and clarity on expectations
as the cultural behaviours were refined. It also sought clarity on how
the updated articulation of risk culture would align with other existing
employee tools and it was confirmed this has been considered.
Report of the Group Board Risk Committee
continued
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Matter
Context of discussion
How the Committee addressed the matter
Financial and
strategic risks
Regular monitoring of key
risks is a pivotal part of
BRC’s role both via routine
risk reporting and via
regular focused reports.
Credit and market risk – In addition to reporting on credit and market
risk within the risk management report, BRC received separate updates
in respect of the retail and wholesale credit risk portfolios, the single
name concertation framework, commercial real estate exposures, credit
decisions made by the Executive Credit Group and traded and non-traded
market risk. These updates provided insight into the sources of the risk,
including asset quality, risk management approach and risk appetite,
controls and testing and monitoring activity undertaken. The Committee
also received specific spotlights on Commercial Banking credit risk and
stewardship and preparation for expected increased levels of problem
debt due to COVID-19 and plans established to manage this increase.
Financial risk from climate change – BRC received quarterly updates on
management plans to address the financial and non-financial risks arising
from climate change, including the inclusion of climate related risks within
the existing EWRMF and the development of new risk appetite measures
to assist monitoring of NatWest Group’s risk profile. The Committee also
received assurance from management in relation to the NatWest Group
Climate Change Programme closure activity as NatWest Group transitions
to the integration of climate-related matters into business-as-usual activity.
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Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Matter
Context of discussion
How the Committee addressed the matter
Non-financial risks
BRC continued its oversight
of NatWest Group’s non-
financial risks, including
major change programmes
and strategic transformation
initiatives.
Transformation/major change programmes – BRC considered progress on
the delivery of NatWest Group’s transformation and change programme
and its position relative to risk appetite, including oversight of red rated
programmes and consideration of a new reporting style. It received
updates on key regulatory programmes, including LIBOR transition,
IRB models transformation, and GDPR readiness. BRC requested greater
visibility of how interdependencies between programmes were managed,
monitored how strategic risks were being managed and challenged
management on slippage of Objectives and Key Results, adequacy of
capabilities and budget prioritisation. The Committee also challenged
the proposed risk appetite measure which was subsequently changed.
Conduct risk and regulatory compliance risk – In addition to the review
of changes to risk appetite measures, the Committee received regular
updates on the conduct and regulatory compliance risk profile, the
elements driving the elevated conduct and compliance risk profile, both,
internally and externally, and actions being taken to return to appetite.
A spotlight on conduct and regulatory compliance highlighted the steps
being taken to embed regulatory compliance within the risk operating
model across NatWest Group. The Committee supported the Board in
overseeing management’s progress in embedding compliance with the UK
ring-fencing rules in support of the submission of its regulatory attestation.
Operational risk, resilience, and cyber security – BRC received regular
updates on NatWest Group’s operational risk profile and risk appetite, with
a particular focus on the impact of COVID-19 on operational resilience,
outsourcing and information and cyber security. The Committee
considered the bank’s preparation for compliance with the new
Operational Resilience Regulatory Policy and recommended a new list of
Important Business Services and associated impact tolerances to the Board
for approval. In addition, separate updates on information security were
reviewed and the BRC dedicated time to the consideration of cyber risk,
the external threat landscape, and the action being taken by management
in response. The Committee received confirmation that there was sufficient
investment in this area and there would continue to be focus on change
capacity and effective prioritisation. The Committee received a third-party
management dashboard to facilitate oversight of the identification
and management of third-party related risks. The Committee sought
additional clarity on the process for re-tender and management of
cloud service providers.
Data management and BCBS239 – BRC received reports on the data
management risk profile, including the risk implications of proposed data
strategy changes, required to support NatWest Group’s refreshed purpose-
led strategy. The Committee also received regular updates on compliance
with BCBS239, challenging management on its approach to assessment of
NatWest Group’s compliance status. Changes to the Risk Data Aggregation
& Reporting Framework were reviewed and approved by the Committee
under Board delegated authority.
Report of the Group Board Risk Committee
continued
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2021 Annual Report and Accounts
Matter
Context of discussion
How the Committee addressed the matter
Accountability
and remuneration
BRC continued to provide
oversight over the risk
dimension of performance
and remuneration
arrangements, working
closely with RemCo.
Accountability – The Committee regularly considered developments in
significant material events and investigations. This included resultant
accountability review recommendations, ensuring appropriateness of
the recommendations from a risk perspective.
Remuneration – The risk and control goals and associated long term
incentive performance measures of the NatWest Group Executive
Committee (ExCo) were reviewed, with additional focus on underlying
objectives for the Group Chief Risk Officer. In addition, the Committee
reviewed the risk management performance and long term incentive
performance conditions, pre-grant and pre-vest assessments for ExCo,
ensuring fair reflection of risk management performance in award and
vesting outcomes. More generally, the Committee considered and
recommended to RemCo adjustments to NatWest Group’s bonus
calculation, to reflect NatWest Group’s risk management performance.
Remuneration policy – Proposals for the 2022 Executive Director
Remuneration Policy were considered by the Committee and
recommended to RemCo from a risk management perspective.
The Committee also reviewed relevant changes to the Material
Risk Taker identification process.
Further detail on how risk is considered in remuneration decisions can
be found in the Report of the RemCo on page 136.
131
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Corporate governance
continued
Report of the Group
Sustainable Banking Committee
Dear Shareholder,
I am pleased to present my fourth report as Chairman of the
Group Sustainable Banking Committee (the Committee or SBC).
The journey towards being purpose-led
As the Group continues its journey towards being purpose-led,
the Committee has played an important oversight role. On
behalf of the Board, we have focused our efforts on NatWest
Group’s progress against our purposeful commitments
and ambitions.
In response to feedback arising from the 2021 performance
evaluation, it was agreed that the Committee should enhance
its focus on customer service and experience. This is now
reflected in our terms of reference and refreshed sustainable
banking pillars – Climate; Customers; Enterprise; People &
Culture; and Conduct & Ethics.
2021 Highlights
We held several spotlight sessions throughout the year,
covering our five SBC pillar topics. Committee members
challenged the actions taken by management to run the bank
as a sustainable business and sought the views of internal and
external stakeholders wherever possible. Meeting time is
prioritised towards meaningful debate and discussion.
Below are the key discussion points and outcomes for 2021.
Climate
At its annual climate spotlight session, the Committee
discussed external developments relating to climate and their
potential impact on NatWest Group, including key messages
emerging from an NGO roundtable and an update on COP26
preparations. The Committee also considered a detailed
update on progress against NatWest Group’s climate-related
goals and targets.
A franchise-led session on climate-related returns and
opportunities included deep dives on clean buildings and
voluntary carbon markets. Updates were also considered on
climate measurement and reporting; managing the financial
and non-financial risks arising from climate change; how
“The Committee has continued to
oversee the embedding of purpose
across NatWest Group, with enhanced
focus on customer service and
experience.”
NatWest Group was reducing its own carbon footprint;
and investor insights. Later in the year, the Committee
also received a deep dive session on NatWest Group’s first
carbon budget in the context of our carbon emission reduction
commitments. A key outcome was to challenge management
on climate transition activity, specifically to maintain a
opportunistic perspective and to consider the sustainable
business model and performance impacts of exiting climate
sectors as part of climate budgeting activity.
Discussion and questions focused on accelerating the transition
to net zero for customers in their daily lives and for businesses,
including creating new products, services, and sustainable
funding and financing. The Committee was impressed by the
excellent levels of collaboration demonstrated across NatWest
Group and noted the benefits of effective partnerships with
third parties on climate-related initiatives. There was debate
on how NatWest Group maintains a leadership position while
promoting industry-wide progress, and on fostering meaningful
partnerships. A key management action was to report back
on which ESG surveys and NGO reports were most valued
by NatWest Group’s influential investors, to direct
appropriate resources.
The discussion continued to build Board level knowledge on
the financial risks from climate change. The discussion should
influence future proposition and strategy design, particularly
around how NatWest Group helps customers to transition, the
approach to investor relations and future climate budgeting.
Customers (including enterprise)
The Committee received an update on customer service and
experience, focused on three key customer segments: Under
30s, Affluent, and Small and Medium-sized Enterprises (SMEs).
Franchise CEOs and their teams presented on the range of
measures which had been introduced to support customers
and communities because of the pandemic.
Discussion and questions focused on the impact of the
pandemic on customers’ needs for products and services.
Areas of debate included the steps being taken within each
segment to enhance customer service and experience, as
well as peer comparisons and broader industry trends.
An external speaker connected to a youth charity joined to
help us understand how young people had been hardest hit
by the economic crisis arising from the pandemic.
A key outcome was a greater understanding of how youth
opinions and expectations of banks had evolved as a result
of the pandemic, allowing both management and the Board
directors present to better consider the opportunities and
needs relating to this important customer segment during
future strategy design.
People & Culture
Reflecting an enhanced level of focus on culture at Board level,
the Committee’s People & Culture meeting concentrated on
the cultural change involved in building a purpose-led bank.
The meeting began with a ‘Living our purpose’ spotlight
session covering some of the diversity, equity and inclusion
Letter from Mike Rogers
Chairman of the Group Sustainable
Banking Committee
132
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2021 Annual Report and Accounts
initiatives which focused on community learning and social
mobility. We were joined by two guest speakers – one of
NatWest Group’s apprentices who joined the bank from
school, and charity partner of CareerSense (NatWest Group’s
employability programme which aims to support 13 to 24 year
olds to have the skills, knowledge and experience to take
control of their future) – who helped us understand how
these programmes are changing the lives of young people.
The Committee also discussed the results of the latest Our
View survey where employees respond to questions covering
wellbeing, purpose, building capability and leadership. Linked
to this was an update from Internal Audit on their Behavioural
Risk reviews, where team sub-cultures are assessed using
behavioural science for indicators of potential future
conduct issues.
Key areas of discussion and challenge were the need to
coordinate and potentially simplify the range of diversity,
equity and inclusion policies and practices, culture measurement
reporting improvements and assurance of management action
to address behavioural sub-culture findings.
A key outcome and example of constructive, Board level
challenge was the request for a further deep dive on the
branch culture findings, where the Committee felt more detail
and understanding was needed about behaviours, products
and practices involved, and the improvements planned for.
Conduct & Ethics
Following discussion at the People & Culture session, the
Committee received a deep dive presentation on branch
culture which focused on safe sales practices, the ongoing
branch transformation activity and culture improvement
plans which focus on customer feedback rather than product
targets. The report and presentation were well received
and demonstrated a robust management response to the
issues raised.
Spotlight sessions on customer trust, fraud and human rights
were also presented, followed by a group discussion with
external insights from a guest speaker who challenged
NatWest Group’s approach and shared practical suggestions
based on experience of leading on human rights activity for
a global consumer goods company.
Discussion and challenge focused on the social dimension of
the ESG agenda; an area in which interest and expectations
are increasing. The Committee listened to customer calls
about romance and cryptocurrency scams which prompted
discussion about some of the conduct and ethical dilemmas
NatWest Group and the wider industry are facing around
customer behaviour and responsibility.
A specific conduct-related action was for management to
provide data on colleague abuse and related support, given
the worrying trend seen in service industries generally.
Supporting long-term value creation
Given its purpose responsibilities, the Committee continues
to receive a purpose dashboard providing a useful snapshot
of NatWest Group’s progress against key purpose targets
and metrics.
The Committee also considered and provided advice to
the Group Performance and Remuneration Committee
on customer, strategy, people and culture targets and
performance, advocating for sustainable targets with
the incentive framework.
Committee members enjoyed meeting potential executive-level
successors in July 2021, when we explored with top talent how
NatWest Group can continue to support, build relationships,
and grow within the communities NatWest Group serves.
Membership, meetings and escalation
There were no changes to the Committee’s membership
during 2021. Membership of the SBC continues to comprise
three non-executive directors as members, with two non-
executive directors from NatWest Group’s ring-fenced bank
board observing, along with management attendees. More
details of membership and attendance for the SBC can be
found in the Corporate governance report.
The Committee’s operating rhythm, including the number
of scheduled meetings held in the year and escalation
mechanisms, has not changed since last year’s report. Two
ad hoc meetings were scheduled to accommodate executive
remuneration policy matters. Authority is delegated to the SBC
by the Board and a regular report of the Committee’s activities
is provided to the Board. The Committee’s terms of reference
are available at natwestgroup.com and these are reviewed
annually and approved by the Board.
Performance evaluation
The annual review of the effectiveness of the Board and its
senior Committees was conducted externally in 2021. The
report on the SBC was a positive one. I was pleased to read
that the agendas feel well-purposed and my fellow directors
enjoy the range of presentations and insights as much as I do.
We discussed recommendations relating to driving harder to
action and effecting change in the areas within our remit,
noting the successes and limitations of our current meeting
structure and schedule.
We agreed to maintain a keener eye on management actions
going forward which should support enhanced management
accountability. I would also like to continue to see customer
experience and service remain at the heart of each of
our sessions.
Areas of focus for 2022 will follow this year’s structure with
the same dedicated meeting themes. The structure will retain
some flexibility to allow us to respond to any emerging issues
within the Committee’s remit should something significant
arise. Challenging views and a diverse range of insights
will continue to be sought to support the 2022 meetings.
The Committee operated within its Terms of Reference during
the year.
Conclusion
As I envisaged in last year’s report, the Committee has
continued to oversee Purpose progress across the Group
during what has been a critical time of embedding, with
enhanced focus on customer service and experience.
We have continued to benefit from a broad range of internal
and external stakeholder perspectives, and our discussions
have been all the richer for it.
I would like to take this opportunity to thank everyone who has
contributed to the Committee’s activities during 2021, including
my fellow directors, attendees, and presenters, for their
commitment and dedication.
Mike Rogers
Chairman of the Group Sustainable Banking Committee
17 February 2022
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Corporate governance
continued
Report of the Technology and
Innovation Committee
Dear Shareholder,
I am delighted to present my second report as Chairman of the
Technology and Innovation Committee (the Committee or TIC).
Role and responsibilities
TIC is responsible for supporting the Board by overseeing,
monitoring, and challenging the actions being taken by
management in relation to technology and innovation.
In doing so, the Committee also gives due consideration
to NatWest Group’s purpose.
Authority is delegated to TIC by the Board and a regular report
of the Committee’s activities is provided to the Board. The terms
of reference are available at natwestgroup.com. These are
reviewed annually and approved by the Board.
Principal activity during 2021
During 2021, the Committee has played an important role in
helping to support and challenge management plans to use
technology and innovation as part of its journey to become
a relationship bank for a digital world. TIC focused on the
principal themes of digitising the core, future ready, innovation,
partnerships and ventures, and emerging threats and
opportunities. As agreed, as part of the 2020 Committee
evaluation, it deliberately focused on a smaller number of deep
dives into specific aspects of each theme, including competitor
position and link to purpose. Key highlights included:
Digitising the core
The Committee received a number of spotlight sessions on
the development of existing technology, architecture, and
processes to enhance customer experience and maintain
the health and resilience of IT systems.
The Committee considered management programmes
designed to automate pioneer customer journeys, including
Account Opening and Pay a Bill or Person, which impact 70 to
80% of customer interactions and the majority of the customer
base. The Committee considered how the activity would
improve customer experience, reduce cost, and utilise One
Bank capabilities to drive a consistent approach. Committee
discussions focused on digitising the front to back architecture;
the use of digital journeys in branch and telephony channels;
the benefits from immediate decisioning; and from simplifying
the product offering and supporting processes and technology.
“The Committee has played an
important role in helping to support
and challenge management plans to
use technology and innovation as part
of its journey to become a relationship
bank for a digital world.”
The Committee also discussed how predictive analytics, including
machine learning, was being used within the Retail and Private
Banking businesses, primarily to assist with identification of
potential customer needs and plans to extend the use of such
techniques to the Commercial Banking business.
TIC also considered how Open Finance was changing
the sector and the changes required to core systems and
architecture. The Committee noted the increased use of
Application Programming Interfaces (APIs) to improve the
NatWest Group’s internal architecture, maximise re-use of
assets and to improve customer experience. In addition, the
external consumption and monetisation of bank produced
APIs in conjunction with partners was also considered. The
Committee discussed potential opportunities presented by the
development of FreeAgent (integrated lending for NatWest
Group customers based on cashflow forecast), Payit (Open
Banking payments offering), and data sharing to support
new SME customers onboarding.
The Committee received an update regarding changes in
the use of technology by the Risk function. TIC discussed
technology and data transformation underway, including
the use of robotic process automation and workflow tools;
movement of risk engines to a cloud-based solution; data
transformation; and use of ‘Software as A Service’ applications
for solutions. The Committee discussed and challenged how
proposed changes to the logical data architecture could
improve regulatory reporting and noted that approach
reduced complexity via data consolidation and assigning
end to end ownership for such data.
The update on the use of technology and innovation as part
of NatWest Group’s security and cyber defences, included the
evolution of the threats faced by NatWest Group; the strength
of NatWest Group’s defences against such attacks to date; and
the continuous innovation approach being implemented. Mr
James Lyne, Head of Research and Development at the SANS
Institute and member of NatWest Group’s Technology Advisory
Board provided an external perspective on how NatWest
Group compared to competitors and challenges being
faced by the industry.
Future ready
The Committee considered a number of actions being taken
within the organisation to transform data and technology
capabilities and deploy forward-looking technology.
Letter from Yasmin Jetha
Chairman of the Technology and
Innovation Committee
134
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2021 Annual Report and Accounts
TIC received an update on how new technology was
empowering colleagues to adapt to a digital future by
providing modern software, such as Workday, which had seen
high adoption rates. Implementation of Ask Archie, NatWest
Group’s chatbot, and accelerated adoption of tools such as
Microsoft Office 365 and Zoom as a result of COVID-19 were
also considered. The Committee discussed and challenged the
mindset and behaviour changes needed to embrace adoption,
the technology challenges posed by legacy technology
platforms, and contention between tools which were
managed via One Bank design oversight.
The Committee discussed the manner in which potential
acquisitions would be considered from a technology and
innovation perspective. Discussion focussed on external
threats, lessons learned from prior acquisitions and
potential targets.
Innovation & partnerships and ventures
Being powered by innovations and partnerships is a key part
of NatWest Group’s strategy.
TIC considered an update on the framework and approach
to partnership working from a technology and innovation
perspective. This was supported by certain deep dives on
existing strategic relationships. TIC also discussed the
potential income threat from payments disruption and
potential opportunities to address this threat.
The Committee received updates regarding key Venture’s
initiatives, including Tyl and Rapidcash. In relation to Tyl, the
Committee noted that it extended beyond helping businesses
to receive payments by helping customers to run and grow
their business as well as giving back to the community. The
Committee discussed and challenged growth plans and how
the business was proposed to be scaled following reduced
growth, partly as a result of COVID-19. The competitive
environment, emergence of non-traditional payment providers,
and the potential to make greater use of merchant acquiring
data to help customers and drive further development was
also considered.
Regarding Rapidcash, TIC noted the transition of the business
into Commercial Banking as a market leading product with the
potential to disrupt the asset finance market by resolving issues
such as long onboarding times, links to customers’ accounting
software packages to provide ‘always on’ lending and use of
an invisible trust account to resolve customer pain points.
Emerging threats and opportunities
TIC considered the potential threats and opportunities
presented by big technology companies, including innovation
from China-based technology companies. The Committee
noted the collaborative approach taken by management
to deepen relationships beyond supplier relationships
into partnership working to solve customer needs.
The Committee discussed the evolution of digital currencies,
exploration of central bank digital currencies and growth of
tokenised assets and the potential threats and opportunities
presented. It was agreed that this would continue to
be monitored.
Membership and meetings
The Committee is comprised of three non-executive director
members, Frank Dangeard, Patrick Flynn, and me. More
details of membership and attendance at meetings can be
found on page 103 of the Corporate governance report.
The Committee is supported by management and the
Group CEO, Group CFO, Chief Administration Officer,
Chief Risk Officer, Director of Innovation, Director of Strategy
& Corporate Development and Chief Technology Officer are
all standing attendees.
External insights were also provided through the updates
provided by management.
The Committee held four scheduled meetings during 2021.
Performance evaluation
The annual review of the effectiveness of the Board and its
Committees, including TIC, was facilitated by Independent
Board Evaluation, a specialist board evaluation consultancy.
Throughout the year the Committee acted in accordance with
its terms of reference and, overall, the review concluded that
the Committee operated effectively, and had responded to
prior feedback regarding focus on a smaller number of
spotlight items.
The review suggested that, given the importance of technology
and innovation, the Committee could arrange its work in a way
that would be more accessible to all Board members. As a
result, it was agreed that appropriate agenda topics would be
opened to all Board Directors in future and that consideration
would be given to reducing the number of Committee meetings
held taking into account the sessions opened up to the full
Board in future years.
The outcomes of the evaluation have been reported to the
Board and the Committee will track progress during 2022.
Conclusion
I am delighted to chair this Committee as it continues to
support the Board in an area core to NatWest Group’s purpose
to champion potential, helping people, families, and businesses
to thrive.
Together with my fellow directors, we will retain our focus
on monitoring the future technology and innovation landscape
and its impact on NatWest Group in order to ensure continued
resilience and help NatWest Group become a relationship bank
in a digital world. The Committee will continue to shape
opportunities arising from management’s response to
both threats and opportunities that align with NatWest
Group’s purpose.
I want to take the opportunity to thank the Committee
members and attendees for their continued commitment
during 2021.
Yasmin Jetha
Chairman of the Technology and Innovation Committee
17 February 2022
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Directors’ remuneration report
Directors’
remuneration report
Dear Shareholder,
On behalf of the Board I am pleased to set out the Directors’
remuneration report for 2021. There continues to be
heightened public interest in pay, as the wider economy and
society attempts to recover from the impact of the COVID-19
pandemic. Economic conditions have improved, which has led
to an increasingly competitive external market for key talent
and skills. Many companies are having to manage higher than
usual attrition rates. Furthermore, the level of inflation in the
UK economy has increased significantly, as have forecasts of
its level in the coming year, which has given rise to heightened
expectations of general salary increases. For many individuals,
the experience of working from home has led to significant
changes in how working environments are now perceived.
As a result, we have had many important matters to
consider during the year.
As part of this report, we have set out proposals for a new
Directors’ Remuneration Policy (the Policy). Subject to approval
from shareholders, this will apply from the 2022 Annual General
Meeting (AGM), with the first awards being granted under the
new Policy in March 2023. This letter explains why we are
seeking approval for this new policy which is significantly
different from the existing policy which has been in force
since 2017. The report also details the remuneration
decisions we made under the existing Policy for 2021.
Summary of the year
NatWest Group has delivered a strong operating performance
in 2021, returning to profitability with an attributable profit of
£2,950 million. NatWest Group’s share price also saw a sharp
recovery throughout the year, increasing around 35% and
outperforming our UK peers. Our capital distribution plan has
helped return £3.8 billion to shareholders through buybacks,
both directed and on-market, and dividends. Our strong capital
position and continued capital generation mean that NatWest
Group is well placed to invest for growth, to provide the
support our customers need as the economy recovers
and to drive sustainable returns to shareholders.
We have also been acutely aware in our deliberations that
during 2021 the Financial Conduct Authority (FCA) imposed
a fine of £265 million on NatWest Bank Plc for breaches of
the Money Laundering Regulations 2007 over five years ago.
My report explains how we have taken this matter into
account in our pay decisions.
Wider workforce remuneration
The Committee has a very keen interest in wider workforce
remuneration. Our colleagues enable us to achieve our
purpose of helping people, families and businesses to thrive.
It is therefore vital they are paid fairly and in ways that
support our values and culture.
I met with the Colleague Advisory Panel (CAP) during the year
and we had a good discussion on our approach to executive
and wider workforce remuneration. We know how important
it is to have fair and transparent pay structures for all. One of
the suggestions from the CAP was to explore how our Fair Pay
Charter could receive a higher profile within the bank which
the Committee is taking forward. I also explained certain
challenges we have been facing with the current Policy for
executive directors, as described later in my letter. Further
details regarding my engagement with the CAP is set out
on page 154.
Over the year we have seen demand rise rapidly for certain skill
sets. This has put pressure on retaining talent within NatWest
Group. With the decisions we make as a Committee, we seek
to recognise these demands while meeting our commitment
to pay colleagues fairly, in line with our Fair Pay Charter.
I am pleased that the lowest level of pay for UK-based
colleagues at NatWest Group has exceeded the Living Wage
foundation benchmarks in the UK for several years. We take
a similar approach across our major hubs outside the UK. The
fixed pay investment we have made over the last few years
has typically been higher than the rate of inflation for that
period. This investment has been targeted primarily towards
our most junior and lowest paid colleagues, areas where
specialist skills are required leading to high attrition rates
and those lowest in their salary ranges.
I know from speaking to colleagues that they are concerned by
the economic conditions especially in our main hub in the UK.
Our 2022 pay discussions with our recognised trade unions
are still ongoing, but we believe the proposed salary increases,
which would provide an expected 3.6% on average across
the wider global workforce from April 2022, demonstrate a
materially improved pay position with fair outcomes for our
colleagues. For the most junior colleagues in the UK, the
minimum proposed salary increase would be £600 and the
majority of them would be in line to receive at least 4%.
Contents
136
Chairman’s introduction
140
Remuneration at a glance
143
The Directors’ Remuneration Policy
and wider workforce remuneration
158
The Annual remuneration report
175
Other remuneration disclosures
Letter from Robert Gillespie,
Chairman of the Group
Performance and
Remuneration Committee
136
NatWest Group
2021 Annual Report and Accounts
We have agreed a bonus pool of £298 million in respect of
2021 for those colleagues who are eligible to receive a bonus
award. This is 44% higher than the 2020 bonus pool, which
was significantly reduced to reflect the impact of COVID-19. It
is also 3% lower than the 2019 bonus pool, which was agreed
prior to COVID-19. We have followed a consistent process for
determining the bonus pool since 2014. When determining
the pool, we considered a balanced scorecard of strategically
important measures, including financial performance,
customer outcomes, colleague experience and risk performance.
In 2021, we included a new measure of progress against our
climate ambitions.
A material downward adjustment was applied to the 2021
bonus pool to reflect the fine imposed on NatWest Bank Plc
for breaches of the Money Laundering Regulations 2007
and ongoing financial crime remediation considerations.
This adjustment was apportioned across all business areas
to reflect the impact on the bank’s financial performance and
to reinforce to colleagues the need to ensure the effective
management of financial crime. Whilst progress has been
made in recent years on NatWest Group’s management of
financial crime, an all-colleague financial crime performance
goal has been introduced in 2022 so that it continues to receive
the appropriate focus. We have also initiated an accountability
review into the events that led to the breaches of the Money
Laundering Regulations 2007. The possible need for individual
pay adjustments to prior year awards, using the malus and
clawback provisions in the NatWest Group remuneration
construct, will be considered as part of the accountability process.
Revised remuneration policy for executive directors
The current Policy was introduced in 2017 and renewed in
2020. The Committee believes it has worked well in supporting
our culture of prudent risk taking, by introducing a significantly
restrained variable pay position for executive directors in
return for more consistent pay outcomes during a time of
significant transition for the organisation.
The Committee has been mindful that the current Policy is not
aligned to standard market practice and that some of its unique
features have been subject to challenge. Over the last year, we
have listened carefully to shareholders and other stakeholders.
We have also been mindful that the bank is nearing the end
of its long process of normalisation and the Government
continues to sell its shareholding which will result in a
normalised shareholder base. Finally, we have found the
operation of the pre-vest test more difficult than expected. We
have concluded in the light of all these factors that substantial
change to our existing Policy is required and that now is the
appropriate time for NatWest Group to transition to a more
market-standard remuneration model rather than waiting
until the next triennial vote on the Policy in 2023.
Under regulatory requirements, which have been in force for a
number of years, regulated banks may only offer variable pay
equal to 100% of fixed pay, unless shareholder approval is
obtained to increase the ratio to 200% of fixed pay. NatWest
Group did not seek shareholder approval and has operated
on a 1:1 structure. The Board is not seeking to change this
position as it believes the current construct supports our belief
in prudent risk taking and the maintenance of restrained
compensation levels. We do, however, believe that executives
should be incentivised using a structure that balances both
short-term and longer-term performance, while maintaining
our focus on prudent risk management. We are, therefore,
proposing that our current long-term incentive (LTI) construct
is replaced by a more widely accepted and competitive
construct based around annual bonus plus Restricted
Share Plan (RSP) awards.
In total, the changes set out in this report would result in
expected total compensation increasing by 19% for the CEO
and by 13% for the CFO, once the transition period is complete.
This would bring both executive directors closer to, but still
below, the average expected total compensation paid by
the other major UK banks.
We recognise that the move to a more normal construct
which involves an increase to total compensation represents a
material change and intend to make the transition to the new
Policy over two years. The phasing will mean that no more
than half of the increase will apply in year one.
The Committee is highly aware that any increase in
compensation will be closely scrutinised by shareholders. It is,
therefore, important for us to be clear on why we believe the
combination of annual bonus plus RSP represents the best
cultural and strategic fit for our organisation and why the
proposed opportunities under each element are appropriate.
By introducing a market-aligned annual bonus mechanism we
will increase the performance alignment within the package
to annual performance based on formulaic and weighted
measures and targets. This will provide greater transparency
on performance outcomes and a more direct link between pay
and the delivery of our strategic targets. The market-aligned
RSP will also ensure that we continue to retain a level of
balance within the package between annual performance
and longer-term alignment with the shareholder experience.
Delivering a remuneration package which is sufficiently
competitive both in structure and quantum to attract and
retain our senior team has been a significant consideration
in determining the proposed new arrangements. You can
find detailed information about the new Policy on pages 140
to 152 below.
The Committee has consulted widely with shareholders
and the final form of the proposals being put forward
for shareholder approval reflects much of the feedback
we have received. In my discussions with some of our
major shareholders, it has become clear that the current
management team is highly regarded and that it would be
imprudent to ignore this when setting an appropriate pay
scale. Further details of the consultation findings are set out
in this report.
The Board believes that these proposals are in the company’s
best interests as they move our remuneration policy into line
with market norms and provide a more competitive package
to our executive directors, which is a very important factor in
attracting and retaining highly talented colleagues. The Board,
therefore, recommends that shareholders vote in favour of the
new Policy.
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
2019 LTI award vesting outcome
Following an assessment of her performance in 2018, Ms Rose
received an LTI award over 2019, while CEO of Commercial &
Private Banking. Ms Murray was on a different remuneration
construct for the 2018 performance year and did not receive
an LTI award in 2019.
The Committee carried out a pre-vest assessment at the end
of 2021 for awards granted in 2019 which vest in 2022. This
involved considering whether anything had come to light since
grant that would change our original view of performance of
the beneficiaries of the award during the 2018 financial year.
We used a structured set of questions and evidence factors to
guide discussions. From the analysis, we agreed that customer
and risk were areas that merited further consideration.
Supported by external opinion, we concluded that although
customer performance had declined in one business area,
it was not due to factors within management’s reasonable
control. Therefore, no adjustment was made relating
to customer.
On risk performance, the pre-vest test confirmed there had
been no material deterioration in risk culture or profile over the
relevant period. However, management performance relating
to financial crime remediation over the 2018 performance year
was considered to be an area that merited further investigation
using the Risk & Control underpin.
The Group Board Risk Committee (BRC) concluded that,
while management had taken significant action to drive
delivery of the financial crime remediation programme,
there had not been a full appreciation of scale, complexity
and interdependencies of the programme at the time of the
2019 LTI grant, resulting in delays to the proposed return
to appetite.
The BRC recommended that an adjustment be considered and
as a result we applied a pre-vest reduction of 5% of Ms Rose’s
original maximum 2019 LTI award resulting in a reduction of
32,234 shares vesting. A pre-vest reduction of 5% of the
original maximum was also made to the 2019 LTI award
held by the former CEO, Ross McEwan.
The total adjustments made to their respective maximum 2019
LTI award levels, when combined with adjustments made
pre-grant, amounted to 17% for Ms Rose and 11% for Mr
McEwan. You can find full details of the pre-vest assessment
for both Ms Rose and Mr McEwan on page 159 to 160.
2019 LTI award to Alison Rose
Maximum
Granted
Shares to vest
Shares
644,672
568,829
536,595
Value
£1.7m
£1.5m
£1.197m
The £1.197 million value reflects an aggregate reduction of
17% of the maximum LTI award level for Ms Rose across
pre-grant and pre-vest stages. It also reflects the fall in
the share price over the performance period.
Directors’ remuneration report
continued
Executive director pay for 2021 and
salaries for 2022
Alison Rose
At the time of the last Policy renewal in 2020, we committed to
considering salary increases for Ms Rose during the life of the
Policy. No increases have been made since her appointment
in 2019. In December 2021, we noted the proposed average
salary increase for the wider global workforce and agreed
that a reduced rate of increase would be appropriate for the
executive directors. As a result, Ms Rose’s salary will increase
by 2% under the existing Policy from 1 April 2022.
In considering performance against the LTI targets for 2021,
we agreed that Ms Rose’s performance has been highly
impressive. Finance and climate performance was strong with
targets achieved and despite a marginal ‘miss’ on the ‘building
capability’ target, our people scores were good. Targets for
supporting enterprise were also met and customer performance
had improved in most areas. In terms of risk performance,
while there had been some progress, it was noted that
there was more work to do on the control environment.
External assessments of Ms Rose’s performance were
also very favourable, especially in relation to leadership on
COVID-19 schemes and COP26. Board members welcomed
Ms Rose’s frankness and transparency during the year.
Our overall assessment of Ms Rose’s performance for 2021 led
the Committee to agree that an LTI award of £1,598,000 would
be an appropriate outcome, which represents 145% of salary
and 83% of the maximum LTI award. In order to ensure parity
of treatment with the wider workforce, the LTI outcome
reflected an adjustment to mirror the downward adjustment to
the 2021 bonus pool for the fine imposed on NatWest Bank Plc
for breaches of the Money Laundering Regulations 2007 and
ongoing financial crime remediation considerations. Ms Rose’s
LTI award will be granted in March 2022.
Katie Murray
Ms Murray’s salary has remained unchanged since
her appointment to the Board in January 2019 and
the Committee agreed that an increase of 2% would be
appropriate. The increase will take effect from 1 April 2022.
In considering an LTI award for 2021, we agreed that Ms
Murray had also performed well during the year. Along with
the achievements noted against LTI targets for Ms Rose, Ms
Murray had successfully delivered the quarterly results, with
proactive investor engagement and made good progress on
refreshing the annual reporting process. Cost reduction
targets were also met for Finance and NatWest Group.
Our overall assessment of performance for 2021 led the
Committee to agree that an LTI award of £1,057,500 would be
an appropriate outcome, which represents 141% of salary and
71% of the maximum LTI award. In line with the approach
taken for Ms Rose, the LTI outcome reflected an adjustment to
mirror the downward adjustment to the 2021 bonus pool for
the fine imposed on NatWest Bank Plc for breaches of the
Money Laundering Regulations 2007 and ongoing financial
crime remediation. Ms Murray’s LTI award will be granted
in March 2022.
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While the performance cycle has completed, the shares
from this award will vest in tranches up to 2026. Malus and
clawback provisions help ensure that recipients maintain a
long-term focus in their decision-making and aligns with
regulatory expectations.
Approach to windfall gains
In my report last year, I highlighted that windfall gains had
become a focal point for shareholders due to share price
volatility as a result of the pandemic. When the LTI grants
were made in 2021, the share price had risen over the prior
year resulting in fewer shares being granted to satisfy a given
quantum of award. We, therefore, did not consider there were
any obvious potential windfall gains implications for award
levels that should be addressed at the time of grant. We
continue to believe that vesting, rather than at grant, is the
best time to consider any adjustments for windfall gains.
To guide our judgment, we continue to operate a framework
designed to assess whether windfall gains have arisen over the
period from grant to vest and the factors to be considered in
making any adjustments.
Gender and ethnicity pay reporting
The Committee considers gender and ethnicity pay gap
metrics to be another important indicator and full details can
be found in the Strategic report and at natwestgroup.com.
This is the fourth year that we have published ethnicity pay
gap information on a voluntary basis. We are confident that
colleagues are paid fairly and policies and processes are kept
under review to make sure this continues to be the case.
Climate in remuneration
From 2020, we have included a climate goal and related
measures in our executive director performance goals.
Climate will continue to be an integral part of the annual bonus
scorecard to be introduced under the new Policy proposals.
As mentioned above, the bonus pool agreed for the wider
workforce was also determined for 2021 having regard to
performance against strategically important measures,
including our climate ambition. This ensures that the work
of colleagues in supporting the transition to a low carbon
economy is being reflected in pay decisions.
Looking ahead
The Committee understands the expectations of shareholders,
colleagues and wider society relating to the oversight of
remuneration continue to evolve. It is also very aware that
the bank’s commitment to purpose, to equality of opportunity
and to fighting climate change must be fully reflected in
compensation outcomes for its employees in general and
its leaders in particular. I have referred to all these matters
throughout this letter and the Committee will continue to
focus on these and other emerging issues in the coming year.
The Committee is focused on ensuring the smooth transition to
the new Policy, assuming it is approved by shareholders at the
2022 AGM. Set out later in this document is the annual bonus
scorecard expected to be used in respect of 2022. We would
expect the bonus scorecard to continue to evolve to ensure
that it is incentivising progress against NatWest Group’s
purpose-led targets and wider societal needs.
We have committed to publish our climate transition plan
which will support alignment with the Paris Agreement. Future
climate targets will in turn evidence progress towards longer-
term climate objectives. We will also continue to engage with
colleagues to explain the alignment of our approaches to
executive and wider workforce remuneration and to listen
to their feedback.
This is my last report as the Chairman of the Committee
as I will have completed nine years as a director of NatWest
Group later this year. It has been a great privilege to perform
the role of Chairman of the Committee for the last five years.
I believe it is imperative for NatWest Group to be able to
motivate and retain colleagues of great ability at every level in
the firm and therefore to be able to evidence the link between
its remuneration policies, culture and purpose. I strongly
believe that the proposed changes to the Policy are an
important step in the evolution of NatWest Group to being
a purpose led organisation and hope shareholders will vote
for its approval at the forthcoming AGM.
Robert Gillespie
Chairman of the Group Performance and
Remuneration Committee
17 February 2022
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Delivering a restrained but fair level of pay for executive directors
Remuneration at a glance
Nat
W
est Group CEO tar
get variable pay
% of salary (£000 t
otal compensation (T
C) target)
8% increase
in compensation
9% increase
in compensation
50%
150%
85%
125%
200%
(TC: £4,626)
125%
43%
168%
(TC: £4,262)
140%
140%
(TC: £3,953)
Current Policy
Year 1 proposed
Year 2 onwards
Target variable pay (% of salary)
Bonus
RSP
Major UK banks average
LTI
Major UK
bank aver
age
226% (TC:£5,347)
Nat
W
est Group CEO maximum v
ariable pay
% of salary (£000 t
otal compensation (T
C) maximum)
9% increase
in compensation
Major UK
bank aver
age
433% (TC:£7,849)
9% increase
in compensation
Bonus
RSP
Major UK banks average
LTI
100%
150%
85%
125%
250%
(TC: £5,187)
125%
85%
144%
210%
(TC: £4,739)
175%
175%
(TC: £4,346)
Current Policy
Year 1 proposed
Year 2 onwards
Max variable pay (% of salary)
How does the new Policy ensure continued
shareholder alignment?
With the adoption of the RSP, we will replace our current
leaver terms with market aligned best practice leaver terms,
with pro-rating reintroduced in good-leaver scenarios for RSP
awards. Shareholding requirements will be increased from
400% to 500% of salary for the CEO and from 250% to 300%
of salary for the CFO and the fixed share allowance release
period will be extended from three to five years.
As is the case under the current Policy, around 67% of
expected remuneration would continue to be delivered under
the new Policy in shares, which will be subject to deferral and
retention requirements. Along with the proposed increase in
shareholding requirements, this will continue to ensure close
symmetry between executives, shareholders and the financial
health of the business.
Delivering a restrained but competitive level of pay
for executive directors which is aligned with our
cultural values
What is driving the move to a new Policy?
Under the current Policy we deliver variable pay through a
single long-term incentive arrangement, which operates in
a different way to those more commonly seen in the market,
particularly in the case of the main UK banks. The LTI-only
construct operates within a 1:1 variable to fixed pay ratio with
executive directors receiving a significantly restrained but more
predicable level of pay, thereby encouraging safe and secure
growth within appetite.
However, it has become apparent through our stakeholder
engagement process that certain shareholders continue to
have reservations with regard to the current Policy and its
unique features, in particular, the lack of formulaic, weighted
performance measures, and the removal of pro-rating. The
Committee has given considerable thought to how it should
address such feedback and, conscious that we are continuing
on a trajectory towards private ownership, believe now would
be an appropriate time to introduce a more market-aligned
annual bonus and RSP construct for executive directors.
Why are we increasing total compensation?
The Committee has also been mindful that while we have
successfully recruited highly talented executive directors under
the current Policy, our compensation levels are falling too far
behind our nearest competitors. The Board is very pleased with
the performance of the executive directors since appointment.
We believe that continuing an approach that is materially
behind our peers is imprudent and that a move towards a
more flexible remuneration structure, which delivers more
competitive levels of pay, is justified and in the best interests
of the business.
The new Policy will result in an increase to total compensation
for executive directors, with maximum variable pay set at
100% of base salary for annual bonus and 150% of base
salary for RSP awards. While this enables us to deliver more
competitive levels of pay, maximum compensation levels for
the CEO would still be the lowest compared with other major
UK banks and significantly lower than peers who continue to
operate traditional long-term incentive plan (LTIP) constructs,
demonstrating continued restraint on executive pay. The
increase in variable pay levels should also be viewed in the
context of us making further changes to the Policy which
will introduce less favourable leaver treatment, increased
shareholding requirements and longer holding periods for
the fixed share allowance.
We recognise moving to a more normal construct represents
a material change and intend to make the transition in two
phases. For the first year, maximum awards will be limited to
85% of base salary for annual bonus and 125% of salary for
the RSP. The charts opposite illustrate the transition for the
CEO from our current Policy and also show that compensation
levels will move closer to, but still below, the average maximum
and target compensation levels at the other major UK banks.
The CFO will also be below the average maximum and target
compensation levels at the other major UK banks.
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2021 Annual Report and Accounts
One of the principal areas of focus during meetings was the
transition to the new Policy including the new variable pay
structure with annual bonus and RSP awards. The Committee
Chairman explained that NatWest Group remained committed
to prudent yet competitive compensation levels that would
assess long-term performance and ensure alignment with
shareholder interests. Discussions also highlighted that
under the new Policy shareholders would expect continued
adherence to best practice and transparent remuneration
disclosures. The Committee acknowledged the need to ensure
the ongoing alignment of all aspects of the new Policy with
market best practice. A summary of the new Policy and how it
compares to the current Policy can be found on the next page,
followed by the main Policy tables which set out further details.
In addition to the above discussions, we also held three virtual
shareholder events with retail shareholders in 2021 to ensure
we heard from the wider shareholder base on matters of
importance. The event held in November 2021 focused on
climate and one of our shareholders asked how we link
executive pay to ESG measures including climate. Yasmin
Jetha, one of our directors who was present at the event,
confirmed that climate measures had been introduced for
executive directors in 2020 which assessed performance with
reference to progress towards climate positive operations, the
funding and financing of climate and sustainable finance, and
the setting of sector specific targets for emissions reduction.
Ms Jetha’s response also noted that executive director
performance had, for several years, also been assessed with
reference to social and governance measures, with diversity
and inclusion targets having been in place since 2017. Further
shareholder events are planned for 2022. Shareholders play
a vital role in helping us develop remuneration practices that
meet the needs of all our stakeholders and we are grateful for
their involvement in the process.
It is also now more important than ever that we listen to our
colleagues and use the insight we gain to attract, engage and
retain the talent we need for the future. In November 2021, the
Committee Chairman met with our Colleague Advisory Panel
to discuss executive and wider workforce pay. The outcome of
such discussion is summarised in more detail in the ‘colleague
listening strategy’ section later in this report.
Nat
W
est Group CEO v
ariable pay
% of salary (£000 t
otal compensation maximum)
50% reduction
in L
TIP
opportunity
Further discount
acknowledging res
trained
pay position
and rebalancing
tow
ards long term
Y
ear 1
implementation
limited to a
lower
award
Bonus
RSP
LTIP
100%
150%
85%
125%
250%
(£5,187)
210%
(£4,739)
192%
144%
336%
(£6,839)
192%
288%
480%
(£8,597)
Average for
other major UK
banks with LTIPs
Illustrative 50%
reduction
Proposed
Policy
Year 1
implementation
Max variable pay (% of salary)
With bonus expected to vest at 50% of maximum opportunity,
the combination of the RSP and bonus means that we are still
guiding towards an expected vesting level of 80% for variable
remuneration outcomes. This is aligned with the position under
our current LTI-only construct which is expected to vest at 80%
of maximum opportunity. However, in the case of the new
Policy, the expected vesting level of 80% depends on executive
directors achieving on-target performance across the annual
bonus scorecard.
How does the RSP operate in practice and does it satisfy
shareholder guidelines?
The Committee will be required to assess the performance
of executives under the RSP construct, both at the pre-grant
and pre-vest stage. The pre-grant test will measure whether
executives have achieved satisfactory performance over
the performance period prior to grant, using the existing
performance management processes that apply to all
colleagues across the bank.
RSP awards will also be subject to an underpin assessment at
pre-vest stage. The underpin assessment is designed to ensure
that sustainable performance has been achieved over the
course of the vesting period.
While RSP awards are expected to be granted and vest at
100% of maximum opportunity, the combination of the RSP
pre-grant and pre-vest tests enable the Committee to make
downward adjustments, potentially to zero, in order to guard
against payments for failure.
We know that shareholder guidelines normally expect an
appropriate discount, of at least 50%, to be applied when
introducing RSP awards compared to a traditional LTIP with
performance conditions. As our current Policy differs in a
number of ways to traditional practice and has already
delivered a more restrained pay position, with significantly
reduced maximum total compensation levels, it would not
be appropriate to apply the 50% discount to our current
LTI construct.
Recognising that the principle of a 50% discount to an LTIP
equivalent construct remains important to stakeholders, the
Committee is satisfied that the proposed move to the RSP is
aligned with the spirit of the guidelines as it delivers more than
a 50% reduction when the RSP construct is compared with
more traditional LTIP constructs envisaged by the guidance.
This is illustrated further in the chart opposite.
Engagement with stakeholders on
remuneration
Every year we undertake an engagement programme
with major shareholders and other stakeholders before the
Committee makes final decisions on pay awards. In late 2021
and early 2022, we met with several institutional shareholders,
UK Government Investments, proxy advisors and the UK
regulators to discuss our approach to remuneration for the
2021 performance year and our proposed policy amendments
for executive directors.
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Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Remuneration at a glance
continued
Comparing the new Policy with the current Policy
The main features of the Policy as applied in 2021 is summarised in the table below. The table also includes details of how the
Policy is intended to apply in 2022 if approved by shareholders at the 2022 AGM.
Timing
Key elements
Current Policy
Proposed Policy
Paid over
performance year
Fixed pay
Salary
Any increase will not normally be greater than the average salary increase for NatWest Group
employees over the period of the Policy.
Other than in exceptional circumstances, the salary of an executive director will not increase by
more than 15% over the course of this Policy.
Implementation in 2021:
CEO: £1,100,000
CFO: £750,000
Implementation in 2022:
2% increase under existing Policy from 1 April
CEO: £1,122,000
CFO: £765,000
Pension
Pension contribution, aligned to the wider workforce, at 10% of base salary.
Benefits
£26,250 standard benefit funding
Other benefits can be paid within the terms of the Policy.
Fixed Share
Allowance
100% of base salary
Shares released over three years.
100% of base salary
Shares released over five years.
Paid in the year after
the performance
year, share element
subject to 12-month
retention period.
Annual
bonus
Maximum
benefit
Not part of Policy for 2021
Maximum award: 100% of base salary
Phased maximum: 85% of base salary for first
awards in 2023 for performance year (PY)2022
Operation
Awarded upfront with a 50/50 split of cash
and shares.
Metrics
Annual bonus assessed based on a weighted
scorecard of strategic measures, as set out
below. A risk modifier will also apply, enabling
risk performance to be assessed and awards
reduced, potentially to zero.
Metrics
Weighting
RoTE
30%
Income growth
10%
Cost reduction
10%
Capital
10%
Climate
10%
Customer
10%
Purpose, Culture and People
10%
Enterprise and Capability
5%
Personal
5%
Paid over years three
to seven after grant
with a 12-month
retention period
after each vesting.
Long-term
incentives
LTI award
RSP award
Maximum
benefit
CEO: 175% of base salary
CFO: 200% of base salary
Final award in 2022 for PY2021.
Maximum award: 150% of base salary
Phased maximum: 125% of base salary
for first awards in 2023 for PY2022.
Operation
Delivered in shares, vesting in equal tranches over years three to seven with a 12-month
retention period following each vesting.
Metrics
Performance assessed over year before grant
with further tests before vesting.
Balanced scorecard in line with our strategic
aims, performance assessed in the round.
RSP awards subject to satisfactory
performance before grant and an underpin
assessment after three years to check
performance has been sustainable.
Ongoing
Share
ownership
Shareholding
requirements
CEO: 400% of salary
CFO: 250% of salary
CEO: 500% of salary
CFO: 300% of salary
Post-
employment
requirements
Equal to the lower of the shareholding requirement immediately prior to departure or the actual
shareholding on departure, to be held for a period of two years post departure.
Ongoing
Malus and
clawback
Operation
Any variable pay awarded is subject to malus prior to vesting and clawback for seven years
from grant, extended to ten years in certain circumstances. See page 157 for further details.
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2021 Annual Report and Accounts
Subject to approval from shareholders, the new Policy set out below will be effective from the date of the 2022 AGM. It will apply
for a period of three years, until the 2025 AGM, unless a revised Policy is approved by shareholders before then.
Fixed pay for executive directors
Purpose and link to strategy
Operation
Maximum potential value
Base salary
Providing fair levels of base
salary and other elements of
pay supports the recruitment
and retention of high-calibre
executives to develop and
deliver strategic priorities.
Base salary set at a
competitive level which
means there is less reliance
on variable pay. This helps
to discourage excessive
risk-taking.
Base salary is paid monthly in cash and reviewed annually.
Rates are determined based on the individual’s role,
skills and experience and are benchmarked against
market practice.
We use a peer group, which includes comparable roles in
other financial services groups of a similar size, to determine
the appropriate level of base salary. We amend this peer
group from time to time to ensure it remains relevant.
Salaries will be increased by 2% from 1 April 2022.
1 January 2022
1 April 2022
CEO
£1,100,000
£1,122,000
CFO
£750,000
£765,000
Any future salary increases will take
in-role performance into account
and will be considered against peer
companies. Any increase will not
normally be greater than the
average salary increase for NatWest
Group employees over the period
of the Policy.
Other than in exceptional
circumstances, an executive
director’s salary will not increase
by more than 15% over the course
of this Policy. See the recruitment
policy section for new directors.
Fixed share allowance
Additional fixed pay
that reflects the skills
and experience required
and the complexities and
responsibilities of the role.
It further supports the
delivery of a balanced
remuneration policy offering
a suitable mix of fixed and
variable pay.
This is a fixed allowance paid entirely in shares. Individuals
receive shares that vest immediately subject to any
deductions required for tax purposes. A retention period
will also apply. Shares will be released annually on a
pro-rata basis over five years from the date of award
(1)
.
As shares are held beneficially, the directors will be entitled
to any dividends paid on those shares.
The fixed share allowance will broadly be paid in arrears, in
four instalments per year or at any other frequency that the
Committee deems appropriate. The fixed share allowance is
not pensionable and no performance conditions apply.
An award of shares with an annual
value of up to 100% of base salary
at the time of award, or such higher
amount as represents this value
rounded up to the nearest
whole share.
(1)
If regulatory requirements emerge that prohibit allowances from being delivered in shares, or deem that such allowances will not qualify as fixed remuneration, then NatWest Group
reserves the right to provide the value of the allowance in cash in order to ensure compliance with such requirements.
The Directors’ Remuneration Policy
(the Policy)
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Financial review
Governance
Risk and capital management
Additional information
Financial statements
The Directors’ Remuneration Policy
continued
Purpose and link to strategy
Operation
Maximum potential value
Benefits
Providing a range of flexible
and market competitive
benefits that colleagues value
and that help them carry
out their duties effectively.
Executive directors can select from a range of standard
benefits including a company car, private medical cover,
life assurance and critical illness insurance.
Executive directors are also entitled to travel assistance
connected with company business including the use of a car
and driver. NatWest Group will meet the cost of any tax due
on the benefit. On rare occasions when executive directors
are accompanied by their spouse or partner to business
events, NatWest Group may also meet the costs and any
associated tax liability. Executive directors are also entitled
to holiday and sick pay.
NatWest Group may offer further benefits including, but not
limited to, relocation assistance in line with market practice.
We may also put in place certain security arrangements for
executive directors when that is deemed appropriate and
meet the cost of any tax due on these benefits.
A set level of funding for standard
benefits (currently £26,250 and
subject to periodic review).
We disclose the total value of
benefits provided each year in the
Annual Report on remuneration.
The maximum potential value of
benefits will depend on the type
of benefit and cost of providing it,
which will vary according to
market rates.
Any non-standard benefits are
subject to approval from the Board.
Pension
Encouraging planning
for retirement and
long-term savings.
This involves the provision of a monthly pension allowance
paid in cash and based on a percentage of salary.
Recipients have the opportunity to use the cash to
participate in a defined contribution pension scheme.
CEO – 10% of base salary
CFO – 10% of base salary
In compliance with the UK Corporate
Governance Code (the Code),
the pension allowance rates for
executive directors are aligned with
the rate for the wider workforce
(currently 10% of base salary)
(1)
.
This rate may be increased or
reduced to remain aligned with
the wider NatWest Group.
(1)
10% of base salary is in line with the rate applicable to the vast majority of the workforce. Over 99.64% of employees in the UK receive this rate.
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Variable pay for executive directors
Purpose and link to
strategy
Operation
Maximum potential value
Performance assessment
Annual bonus
To support a culture
where individuals are
rewarded for the delivery
of superior performance,
taking into account
NatWest Group’s
strategic objectives
and purpose.
Performance will be
assessed based on a
range of financial and
non-financial measures
that encourage long-term
value creation for
shareholders.
Part of the annual bonus
award is paid in shares
with a holding period.
Awards are also subject
to malus and clawback
adjustments to support
long-term decision-making.
Annual bonus awards will operate
as follows:
performance will be assessed
against a balanced scorecard
of measures to determine the
amount of any award for a
particular year;
awards will be paid 50% in shares
and 50% in cash;
awards will be paid in combination
with RSP awards to meet or
exceed the deferral period for
variable pay in order to comply
with regulatory requirements;
a post-vesting retention period will
apply to the amount delivered in
shares in line with regulations
(currently 12 months); and
malus provisions apply prior to
vesting and clawback applies for
seven (and potentially up to ten)
years from the date of award.
Awards will be subject to any other
terms as regulators require from
time to time.
We may calculate the number of
shares awarded using a share price
that is discounted to reflect the
absence of the right to receive
dividends or equivalents during the
vesting period. If regulations permit
the use of dividend equivalents in
future, awards may be eligible to
receive dividend equivalents instead.
The discounted share price will
be calculated with reference to
estimated dividend yields based on
market consensus and the length of
the vesting period. An independent
adviser will then review it. For the
avoidance of doubt, there is no
intention to reflect special
dividends in the calculation.
We will grant annual bonus awards
on a discretionary basis. They will be
delivered through one of NatWest
Group’s shareholder-approved
employee share plans.
The maximum value of
annual bonus awards will be
set at 100% of base salary
for executive directors (or
an amount which represents
such value rounded up to
the nearest whole share).
The value of awards can
also reflect a discount
for long-term deferral, in
line with the Prudential
Regulation Authority (PRA)
Rulebook and European
Banking Authority
(EBA) guidelines.
The level of the award to be
paid can vary between 10%
for threshold performance
and 100% for maximum
performance. Target
performance will pay
out at 50% of maximum
opportunity.
Threshold and maximum
targets will be disclosed at
the end of the performance
period in the 2022 Directors’
Remuneration Report,
alongside the actual level
of performance achieved.
The Committee will set and
assess performance against the
scorecard with weightings that
apply to each category. The
measures and targets we use
will reflect NatWest Group’s
strategic priorities for the year
and align with our purpose.
Financial measures will account
for between 50% and 60% of
the annual bonus opportunity.
A range of non-financial
measures will be included in a
strategic category accounting
for at least 30% of the overall
scorecard. Personal measures
may also be used up to a
maximum of 10% of the overall
scorecard. A risk modifier
will also apply, enabling risk
performance to be assessed
and awards reduced,
potentially to zero.
The Committee has discretion
to vary the performance
measures and weightings in
appropriate circumstances.
However, financial measures
will always account for at
least 50%.
The Committee also has
discretion to determine the
appropriate bonus outcome
when the assessment of
performance against the
formulaic measures and
targets would drive an
unrepresentative outcome
or when it is necessary to
consider strategic, economic,
or societal impacts that were
not or could not have been
accounted for at the point of
agreeing the bonus scorecard.
We will set out further details
on the performance measures
and weightings and a detailed
assessment of performance
against targets in the relevant
year’s Annual Report
on remuneration.
You can find the proposed
performance measures and
weightings for the 2022
financial year on page 166.
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Governance
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Additional information
Financial statements
Variable pay for executive directors continued
Purpose and link to
strategy
Operation
Maximum potential value
Performance assessment
RSP awards
To support sustainable
performance over a
multi-year period.
We will deliver awards
entirely in shares with
payments deferred over
many years. This creates
simple and effective
alignment with the
returns that shareholders
receive over the long term.
Awards are subject to
malus and clawback
adjustments to
discourage excessive
risk-taking and other
inappropriate behaviours.
RSP awards will operate as follows:
an award will be granted in shares
provided satisfactory performance
has been achieved in the prior year;
performance will be assessed
using our established performance
management processes that apply
to all colleagues across the bank;
after three years, performance
against pre-determined underpin
criteria will be used to ensure
there is no payment for failure;
subject to the underpin assessment,
awards will vest in combination with
annual bonus awards to meet or
exceed the deferral period for
variable pay under regulatory
requirements (currently between
years three to seven after grant);
a post-vesting retention period
will apply to the shares in line with
regulations (currently 12 months);
and
malus provisions can be applied
prior to vesting and clawback
applies for seven (and potentially
up to ten) years from the date
of award.
Awards will be subject to any other
terms regulators require from time
to time.
We may calculate the number
of shares awarded using a share
price that is discounted to reflect
the absence of the right to receive
dividends or equivalents during the
vesting period. If regulations permit
the use of dividend equivalents in
future, awards may be eligible to
receive dividend equivalents instead.
The discounted share price will be
calculated with reference to estimated
dividend yields based on market
consensus and the length of the
vesting period. An independent adviser
will then review it. For the avoidance
of doubt, there is no intention
to reflect special dividends in
the calculation.
We will grant RSP awards on a
discretionary basis. They will be
delivered through one of NatWest
Group’s shareholder-approved
employee share plans.
The maximum value of
RSP awards will be set at
150% of base salary for
executive directors (or an
amount which represents
such value rounded up to
the nearest whole share).
The value of awards can
also reflect a discount for
long-term deferral, in line
with the PRA Rulebook
and EBA guidelines.
Depending on the
Committee’s assessment of
the RSP underpin criteria,
the vesting level of the
award can vary between
0% and 100% of the
original number of
shares granted.
The expected vesting level
of the RSP award is 100%
of maximum opportunity.
Executive directors will
be granted an RSP award
provided performance over the
prior year is considered by the
Committee to be satisfactory,
when assessed using our
established performance
management processes.
Before vesting takes place,
the Committee will review
the outcomes of the business
against underpin criteria
determined by the Committee.
In the first year of operation,
the underpin criteria will
consider whether a sustainable
level of performance over the
period has been achieved with
reference to:
1.
the level of capital held
relative to the maximum
distributable amount;
2.
total distributions paid relative
to our distribution policy; and
3.
any material deterioration
in the risk or regulatory
compliance profile or control
environment of NatWest
Group, or a serious conduct
or reputational event.
Following the underpin
assessment, RSP awards may
vest in full, in part or lapse in
their entirety. The Committee
will also retain the right to
consider other factors and
apply discretion before deciding
on the final vesting outcome.
This will aim to mitigate
any potential unintended
consequences that might arise
and ensure that the outcome
is fair. You can find more
information on the RSP in
the implementation of Policy
for 2022 on page 167.
The Committee is committed
to transparency and will
explain its reasons for applying
discretion or for not doing so.
We also reserve the right to
change the underpin criteria
when granting new RSP
awards over the Policy period.
The Directors’ Remuneration Policy
continued
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Other elements of the Policy for executive directors
Purpose and link to strategy
Operation
Maximum potential value
Shareholding requirements
Executive directors must
build and continue to hold
a significant shareholding
both during and after
employment.
This helps to further align
their interests with returns
to shareholders over the
long term.
Shares held outright, including those acquired under the
fixed share allowance, qualify towards the shareholding
requirement. Unvested shares from annual bonus and
RSP awards count on a net-of-tax basis towards the
shareholding requirement once performance conditions
have been assessed. When any applicable retention periods
have passed, executive directors can dispose of up to 25%
of the net-of-tax shares received until the shareholding
requirement is met. Any shares purchased voluntarily will
count towards the requirement but are excluded from the
restriction on sale.
On leaving, executive directors are required to hold
shares of a value equal to the lower of their shareholding
requirement immediately prior to departure or the actual
shareholding on departure, for a period of two years. The
requirement includes vested and unvested shares that have
been assessed for performance but shares purchased
voluntarily are excluded from the post-employment
shareholding requirement. A fixed number of shares for
the post-employment requirement will be determined at
the date of departure.
Procedures are in place to help enforce the shareholding
requirements, both during and after employment. Executive
directors are required to agree to be bound by the terms of
the requirements and to use prescribed nominee accounts
to hold shares subject to restrictions.
CEO – 500% of salary.
CFO – 300% of salary.
Requirements may be reviewed
in future but are not expected to
be reduced.
Employee share plans
Providing an opportunity
for executive directors to
purchase shares in the
company voluntarily.
The plans provide an opportunity for executive directors to
contribute from salary and acquire shares under one or
more of NatWest Group’s all-employee share plans in
operation from time to time. In the UK, this currently includes:
the Sharesave plan where monthly savings over a fixed
period may be used to purchase shares at an agreed
option price; and
the Buy As You Earn plan where shares can be purchased
from pre-tax salary.
Executive directors may participate on the same basis as
other eligible employees. All-employee share plans are not
subject to performance conditions.
The statutory limits that are imposed
by HMRC in the UK or the limits
under the relevant share plan rules.
Legacy arrangements
To ensure NatWest Group
can continue to honour
payments due to
executive directors.
In approving this Policy, authority is given to honour any
previous commitments or arrangements entered into with
current or former directors. This includes any share awards
granted under the 2014 Employee Share Plan. For the
avoidance of doubt, all outstanding LTI awards granted
under previous policies will continue to vest in line with the
terms agreed at the time of grant. LTI awards are subject to
performance assessments prior to grant and again before
vesting. Awards are deferred over three to seven years and
a 12-month retention period applies after each vesting.
Authority is also given to honour arrangements agreed with
an employee prior to appointment as an executive director
that may have different terms or performance conditions.
In line with existing commitments
and arrangements.
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Governance
Risk and capital management
Additional information
Financial statements
The Directors’ Remuneration Policy
continued
Remuneration for the Chairman and non-executive directors
Purpose and link to strategy
Operation
Potential value
Fees
Competitive fixed
remuneration that reflects
the skills, experience and
time commitment required
for the role.
Fees are set at an
appropriate level to attract
individuals with the attributes
needed to oversee the
Board’s strategy.
Fees are paid monthly in cash. The Board retains discretion
to pay fees in cash, shares or a combination of the two.
The level of remuneration reflects the responsibility and time
commitment required, and the level of fees paid to directors
of comparable major UK companies. We review fees regularly,
and the Board may choose to apply an increase within the
limits of the Policy on an annual or less frequent basis.
The Chairman receives an all-inclusive fee. Non-executive
directors receive a basic Board fee with additional payments
when serving as a member or Chairman of a Board
Committee or performing an additional role such as the
Senior Independent Director. Non-executive directors may
also receive fees as directors of subsidiary companies.
Additional fees may be paid for new Board Committees
provided these are not greater than fees payable for the
existing Board Committees as detailed in the Annual
remuneration report.
No variable pay is provided, enabling the Chairman
and non-executive directors to maintain appropriate
independence, focus on long-term decision-making
and constructively challenge performance of the
executive directors.
The rates for the year ahead
are set out in the Annual Report
on remuneration.
Any increases to fees will not
normally be greater than the
average inflation rate or salary
increases for the wider workforce
over the period of the new Policy.
However, we take into account that
any change in responsibilities, role
or time commitment may merit a
larger increase.
Other than in exceptional
circumstances, fees will not increase
by more than 15% over the course of
this Policy.
Benefits
Providing a level of benefits
in line with market practice.
The Chairman and non-executive directors are also entitled
to travel assistance connected with company business,
including the use of a car and driver where deemed
appropriate. Where this is a taxable benefit for the recipient,
NatWest Group will meet the cost of any tax due on the
benefit. On rare occasions when directors are accompanied
by their spouse or partner to business events, NatWest
Group may also meet the costs and any associated tax
liability. We may also offer other benefits in line with
market practice.
In line with evolving working practices and our efforts to
discourage unnecessary travel and costs, the Board has
moved to a hybrid model where meetings take place both
‘in person’ and remotely. In light of the change, NatWest
Group will consider providing assistance and meeting
reasonable costs on a case-by-case basis to support the
Chairman and non-executive directors in the effective
undertaking of their roles from another location. If additional
tax liabilities arise from this practice, NatWest Group will
also meet these costs when deemed appropriate. The
Chairman is entitled to private medical cover and life
insurance cover provided the Board considers the
costs to be reasonable.
Reasonable expenses incurred in connection with
the performance of duties will also be reimbursed.
The value of the private medical and
life insurance cover provided to the
Chairman as well as other benefits
provided under the new Policy will
be in line with market rates and
disclosed in the Annual
remuneration report.
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Other policy elements for directors
Provisions
Operation
Recruitment policy
Our Boardroom Inclusion Policy is in place to ensure that NatWest Group can attract, motivate and
retain the best talent and avoid limiting potential caused by bias, prejudice or discrimination. When
recruiting new directors, our Policy aims to be competitive and to structure pay in line with the
framework applicable to current directors (as stated in the tables above), while recognising that
some adjustment to quantum may be necessary to secure the preferred candidate.
The pension allowance for new executive directors will be in line with that of the wider UK workforce.
We can continue to honour existing commitments in the event of an internal promotion. A buy-out
policy exists to replace awards forfeited or payments foregone, which is in line with regulatory
requirements. The Committee will minimise buy-outs wherever possible and ensure they are no
more generous than, and on substantially similar terms to, the original awards or payments they
are replacing. No sign-on awards will be offered on joining.
Any awards granted following recruitment may be made under such NatWest Group employee
share plans as are in place from time to time or otherwise in accordance with the relevant provisions
in the Listing Rules. We will disclose full details in the next remuneration report. The maximum level
of variable pay which may be granted to new executive directors will be guided by, but not limited to,
arrangements for existing executive directors. In any event this will not exceed the limit of one times
the level of fixed pay. The maximum level excludes any buy-out arrangements.
Notice and
termination provisions
Executive directors
As set out in our executive directors’ service contracts, NatWest Group or the executive director is
required to give 12 months’ notice to the other party to terminate the employment. The Committee
will ensure that any proposals relating to termination payments are fair and reasonable and
recognise that failure is not rewarded. There are no pre-determined provisions for compensation on
termination, other than when we determine that a redundancy payment is properly due under our
redundancy policy in place from time to time. There is discretion for NatWest Group to make a
payment in lieu of notice (based on salary only) which is released in monthly instalments. The
executive director must take all reasonable steps to find alternative work and any remaining
instalments will be reduced as appropriate to offset income from any such work.
Chairman and non-executive directors
Instead of service contracts, the Chairman and the non-executive directors have letters of
appointment that reflect their responsibilities and time commitments. There are no notice periods
and we will pay no compensation in the event of termination, other than standard payments for the
period served up to the termination date.
Under the Board Appointment Policy, non-executive directors are appointed for an initial term of
three years, subject to annual re-election by shareholders. At the end of this initial term, a further
three-year term may be agreed. Non-executive directors may be invited to serve beyond six years,
up to a maximum tenure of nine years. The Chairman is not subject to the Board Appointment Policy
but is subject to the Code’s requirements relating to the maximum tenure period for chairs. All
directors stand for annual election or re-election by shareholders at the NatWest Group’s AGM.
Effective dates of appointment for directors:
Howard Davies – 14 July 2015
Alison Rose – 1 November 2019
Katie Murray – 1 January 2019
Frank Dangeard – 16 May 2016
Patrick Flynn – 1 June 2018
Morten Friis – 10 April 2014
Robert Gillespie – 2 December 2013
Yasmin Jetha – 21 June 2017
(1)
Mike Rogers – 26 January 2016
Mark Seligman – 1 April 2017
Lena Wilson – 1 January 2018
(1)
Yasmin Jetha’s first appointment to the Board. In preparation for the ring-fencing regime, Ms Jetha stepped down from the Board in
2018 to serve solely as a director of some of our subsidiary companies before re-joining the Board on 1 April 2020.
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Governance
Risk and capital management
Additional information
Financial statements
Provisions
Operation
Treatment of outstanding
share plan awards
on termination
On termination, we will treat awards in accordance with the relevant plan rules or other terms on
which they were granted. Individuals will only qualify for good leaver treatment if they leave due
to ill-health, injury, disability, death, retirement (as agreed with NatWest Group), redundancy, the
employing company ceasing to be a member of NatWest Group, transfer of the employing business,
or any other reason if, and to the extent, the Committee decides in any case. Malus and clawback
provisions will continue to apply to all leavers, and could be used to adjust awards if subsequent
issues relating to executive directors’ performance come to light. In the event of a change of control,
outstanding awards will be treated in line with the provisions of the relevant plan rules, as approved
by shareholders.
Fixed share allowances
Shares will continue to be released over the applicable retention period helping to ensure that former
executive directors maintain an appropriate interest in shares. In all leaver circumstances, executive
directors will continue to be eligible to receive a pro-rated fixed share allowance to reflect the period
up to the termination date.
LTI awards (under the existing Policy)
LTI awards normally lapse on leaving unless the termination is for one of the specified good leaver
reasons. LTI awards held by good leavers will normally vest on the original vesting dates, subject to
the performance conditions being met and the rules of the relevant plan. No pro-rating applies after
grant for LTI awards granted from 2018 onwards.
The existing Policy allows good leaver retirement to be granted provided the individual is not leaving
to work in a capacity considered to be competing directly and materially with NatWest Group. The
new Policy introduces a more typical and less favourable definition of retirement that will not allow
good leaver retirement treatment where individuals take up a commensurate role elsewhere or a role
with a company providing banking services. The new Policy will also address the concerns from some
shareholders by introducing pro-rating for RSP awards in good leaver circumstances.
Annual bonus awards (for performance year 2022 and later years)
Any deferred bonus awards that are unvested will normally lapse on leaving unless good leaver
circumstances apply, in which case the awards will normally continue to vest on the original
vesting dates. Provided that individuals leave in good-leaver circumstances, they will be eligible
to be considered for an annual bonus award for their final year of employment.
RSP awards (for performance year 2022 and later years)
RSP awards that are unvested will normally lapse on leaving unless specified good-leaver
circumstances apply. For good leavers, awards are pro-rated for time served during the three-year
performance period and will normally continue to vest on the original vesting dates. Individuals will
not be eligible to be considered for an RSP award for the final year of employment.
Contractual provisions
Contracts include standard clauses covering remuneration arrangements and discretionary incentive
plans (as set out in this report). The contracts also reference: reimbursement of reasonable out-of-
pocket expenses; annual leave; redundancy terms and sickness absence; the performance review
process; directors’ and officers’ insurance; the disciplinary procedure; and terms for dismissal in
the event of personal underperformance or breaches of NatWest Group’s policies.
The Committee retains the discretion to make payments (including but not limited to professional
and outplacement fees) to: facilitate smooth handovers; mitigate against legal claims; and/or procure
reasonable assistance with investigations or claims, subject to any payments being made pursuant to
a settlement or release agreement.
The Directors’ Remuneration Policy
continued
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Summary of proposed changes for executive directors
Under the new Policy, LTI awards will be replaced with annual bonuses and RSP awards. This will provide a more market-aligned
and competitive remuneration package for executive directors, while incentivising growth and the delivery of our purpose-led
strategy. It will also align more closely to shareholder expectations, with pro-rating applying to RSP awards in good leaver
circumstances and annual bonus outcomes being determined with reference to weighted performance measures and robust
strategic targets. RSP awards will contribute to nearly 67% of expected pay being delivered in shares, further supporting the
delivery of sustainable long-term performance. The fixed share allowance retention period will also be extended from three to
five years, further aligning remuneration to the long term. The pay levels under the Policy were decided after considering relevant
market positioning for similar roles at comparable financial services companies. They remain relatively modest compared to other
major UK bank peers. We selected performance measures for annual bonus and RSP awards to reflect a cross section of our main
strategic deliverables. There will be greater transparency on the link between performance and pay outcomes through weighted
annual bonus measures with non-financial targets being set to reflect our purpose-led strategy.
Other changes under the new Policy for executive directors
Performance conditions
Leaver terms
Shareholding requirement
While LTI awards under the existing Policy
are based on assessing performance in
the round, we will base bonus awards
under the new Policy on a weighted
scorecard of annual measures and targets
aligned with our strategic priorities.
Financial measures will account for
at least 50% of the bonus scorecard
supported by strategic and
personal measures.
RSP awards will be based on a simpler
pre-grant test than the existing Policy
with an underpin assessment at the end
of three years to ensure there are no
payments for failure.
As is currently the case, any outstanding
awards will be forfeited on leaving unless
the individual leaves for a specified good
leaver reason. Under the existing Policy
no pro-rating applies to LTI awards after
grant in agreed good leaver circumstances.
RSP awards under the new Policy
will be subject to pro-rating in good
leaver circumstances.
In addition, we will adopt a more typical
definition of ‘retirement’, that is more in
line with shareholder expectations and
does not allow good leaver status where
individuals take up a commensurate role
elsewhere or a role with a company
providing banking services.
Shareholding requirements will increase
from 400% of salary to 500% of salary for
the CEO and from 250% of salary to 300%
of salary for the CFO.
This increase recognises that
shareholders expect executive directors
to have significant shareholdings where
RSP constructs are being introduced.
The change moves NatWest Group
towards the highest levels of market
practice on shareholder requirements
and reinforces the long-term alignment of
executive remuneration with shareholders.
Changes to the policy for the Chairman and non-executive directors
We reviewed the remuneration policy for the Chairman and the non-executive directors during 2021, following which only one
change will be made. To recognise working practices have changed, and also to discourage unnecessary travel, the Board has
moved to a hybrid model whereby meetings take place both in person and remotely. The change under the Policy will allow the
Chairman and non-executive directors to receive assistance when they are attending Board meetings from another location,
including meeting any costs that are considered reasonable and appropriate. Arrangements will be considered on a
case-by-case basis.
The Committee retains discretion to make minor amendments to the Directors’ Remuneration Policy that reflect changing legal or
regulatory requirements or guidelines. We will not make any material changes to the advantage of directors without first reverting
to shareholders for approval.
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Governance
Risk and capital management
Additional information
Financial statements
The Directors’ Remuneration Policy
continued
(1)
The charts above are for illustration only, with minimum representing fixed remuneration (base salary, fixed share allowance, pension and standard benefit funding).
(2)
The charts reflect remuneration receivable in the first year of the new Policy which, as noted earlier in this report, is being introduced on a phased basis. The maximum annual bonus
award will be limited to 85% of base salary in year one rising to 100% of base salary in year two. The maximum RSP award will be limited to 125% of base salary in year one rising to
150% of base salary in year two.
(3)
The expected value assumes annual bonus payments will be made at 50% of maximum opportunity and RSP awards will vest at 100% of maximum.
(4)
Maximum 1 in the charts assumes both annual bonus and RSP awards are paid and vest in full, at 100% of maximum. Maximum 2 extends this to show the impact of a 50% increase
in the share price for RSP awards over the period from grant to vest. The benefits figure includes standard benefit funding as outlined in the Policy but excludes any potential other
benefits under the Policy such as travel assistance in connection with company business. We will disclose the value of any taxable business expenses in the total remuneration table
each year.
Chief Ex
ecutive Officer
(£000’
s)
Chief Financial Offic
er
(£000’
s)
Base salary
Fixed share allowance
Pension & benefits
Annual bonus
RSP award (vesting value)
47%
47%
2,382
6%
26%
26%
11%
34%
4,262
3%
24%
24%
20%
29%
4,739
3%
21%
21%
17%
39%
5,440
2%
120%
Minimum
Expected
Maximum 1
Maximum 2
Fixed pay only
Bonus and RSP at
constant share price
RSP at 50% share
price increase
47%
47%
1,633
6%
26%
26%
11%
33%
2,914
4%
24%
24%
20%
29%
3,239
3%
21%
21%
17%
38%
3,717
3%
Minimum
Expected
Maximum 1
Maximum 2
Fixed pay only
Bonus and RSP at
constant share price
RSP at 50% share
price increase
Illustration of annual remuneration for executive directors under the new policy
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Directors’ remuneration report
Aligning executive pay with ESG performance and our purpose-led strategy
In addition to considering financial measures, the process to determine variable pay for executive directors under the new Policy
will continue to reflect progress against our Environmental, Social and Governance (ESG) priorities. The combined bonus scorecard
for 2022 and the assessment of satisfactory performance under the RSP will align with the five principles of a purpose-led business,
as set out in the Blueprint for Better Business (BfBB) framework. The five principles form part of our purpose framework and you
can find more details of this on page 13 of the Strategic report.
Five principles of a purpose-led business
A guardian for
future generations
Honest and fair
with customers
and suppliers
A good citizen
A responsible
and responsive
employer
Has a purpose which
delivers long-term
sustainable
performance
Variable
pay for
2022
Tackling climate
change is core to
our purpose.
Several climate
measures are
included in the
bonus scorecard for
executive directors.
The climate category
accounts for 10% of
annual bonus awards
for 2022. This
includes three
measures as follows:
1. Carbon emissions
from own operations
2. Funding and
financing committed
to climate and
sustainable finance
3. Develop climate
transition plan for
publication with
2022 annual results.
Putting customers at
the heart of what we
do will help people,
families and
businesses to thrive.
We target customer
satisfaction and
the likelihood that
customers will
recommend our
brands in annual
bonus decisions.
A weighted Net
Promoter Score (NPS)
will account for 10%
of the annual bonus
awards for 2022.
RSP awards will also
be assessed to ensure
that performance has
been sustainable
before the vesting
takes place.
We can only deliver
on our purpose-led
strategy by
continuing and
deepening our
relationships with
all our stakeholders.
There are targets to
encourage and grow
businesses and to
increase financial
capability.
The Committee
has discretion when
making decisions to
ensure outcomes are
fair and appropriate.
Variable pay can
also be recovered
from individuals
if we believe the
payments are no
longer justified.
We are committed
to creating a diverse
workforce with
an equitable and
inclusive culture.
This will also help us
in serving our diverse
range of customers
and communities in
the ways they need.
There are targets
to increase the
percentage of
females and Black,
Asian and Minority
Ethnic colleagues in
the top layers of the
organisation.
Together the
Purpose, Culture
and People targets
account for 10% of
annual bonus awards
for 2022.
A very high proportion
of pay is delivered in
shares over many
years. This encourages
executive directors to
think and act in the
best long-term interests
of all our stakeholders.
10% of the 2022 annual
bonus award will be
based on maintaining
efficient and safe
levels of capital.
If risk performance is
not at the required
level, annual bonus
awards can
be adjusted.
RSP awards also take
financial and risk
considerations into
account prior
to vesting.
ESG
alignment
E
S
G
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Governance
Risk and capital management
Additional information
Financial statements
Our ‘Colleague Listening Strategy’
It is more important than ever that we listen to colleagues and use the insight we gain to attract, engage and retain the talent we
need for the future. This helps us improve by assessing colleague
(1)
sentiment and our progress in creating a great place to work.
Regular engagement
Colleague Advisory Panel (CAP)
Twice a year, a colleague
opinion survey (Our View)
allows people to have a say
on what it feels like to work
at NatWest Group.
Just over 46,700 (81%) of
our colleagues participated
in the latest survey
and there is regular
engagement throughout
the year.
Question and answer
sessions take place
with senior executives
throughout the year.
Feedback from colleagues
forms part of the People
and Culture measures
that impact executive pay.
Engagement on
remuneration also takes
place with representatives
from Unite in Great Britain
and Offshore and the
Financial Services Union
in Northern Ireland and
the Republic of Ireland.
The CAP was established in 2018 to help us promote colleague voice in the boardroom. The CAP is
chaired by Lena Wilson, one of our non-executive directors, and allows colleagues to engage directly
with senior management and the Board on topics that are important to them. It includes colleagues
who volunteered to be involved, representatives from trade union bodies and works councils, the
colleague-led networks and junior management teams.
After each meeting, the Board receives a summary and a follow-up call is then held with the CAP
so that CAP members can hear how their views were shared and what happened as a result. The
CAP continues to be highly regarded by those who attend and has proven to be an effective way
of establishing two-way dialogue between colleagues and Board members. In November 2021, the
Committee Chairman met with the CAP to discuss executive and wider workforce remuneration.
There was a focus on fairness, simplicity, transparency and inclusion which runs through all
colleague remuneration.
Members were appreciative of the presentation, saying it was a very clear explanation of NatWest
Group’s approach to remuneration. They were keen to see how our Fair Pay Charter could receive
a higher profile and also discussed NatWest Group’s approach to salary increases and the impact
of the rising cost of living. The Committee Chairman explained that the combination of inflation and
higher living costs was something employers had not faced for some time. The COVID-19 pandemic
had also had a significant impact across society. Economic factors alongside the external pay
market and longer-term business affordability would all need to be taken in to account when
deciding our investment in fixed pay.
Climate was the overall theme of the November meeting and the Committee Chairman referred
to this in his presentation. He highlighted that executive directors had specific performance goals
and measures linked to climate cost, our climate footprint and colleague feedback, all of which was
considered when deciding their pay awards. New ways of working were also discussed, and the
Group Chief People and Transformation Officer highlighted that focus groups were being run to
understand the cost impact of working from home.
A number of actions were agreed at the meeting for further consideration and the Chair of the
CAP provided the Board with an update on the feedback received from colleagues.
(1)
Colleagues means all employees and, in some instances, other members of the wider workforce (including contractors and agency workers).
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Our View survey
The Our View colleague opinion survey compares responses from colleagues at NatWest Group against those from other
companies, known as the Global Financial Services Norm (GFSN). In general, the scores from the Reward category in Our
View have declined over the last year although they remain above the GFSN in all but one category. The reduction in scores was
anticipated as the impact of the global pandemic on our financial performance meant investment in fixed pay was constrained last
year and our bonus pool was reduced. Some colleagues also felt they had limited opportunity over the last year to use some of the
benefits they had purchased under our benefit scheme.
2021 favourable
score
Versus
2020
Versus
GFSN
Total Reward
(1)
76
-4
+4
Colleagues who think they are paid fairly for the work they do
67
-6
+4
Understand how their pay is determined
87
-2
+13
Understand how their bonus is determined
72
-5
-5
Believe NatWest Group’s benefit programme fits their needs
80
-1
+5
Manager regularly gives them recognition for work well done
87
no change
+5
(1)
NatWest Group Our View scores for 2021 exclude Ulster Bank RoI.
Pay gaps and pay ratio disclosures
Pay equality, including neutrality in respect of protected characteristics, is a core feature of our approach, to support equal pay for
equal work. You can find the latest gender and ethnicity pay gap reporting for NatWest Group together with the steps being taken
to address the position in the ‘Our Colleagues’ section of the Strategic Report and at natwestgroup.com. You can also see the
CEO-to-employee pay ratios and further information on remuneration for the wider workforce later in this report.
Further information on our wider workforce approach.
Fair reward is one of the key things we are committed to in order to provide a great place to work for everyone. Our Fair Pay
Charter is one of the ways we do this and you can find further information on our approach in our ESG Supplement. The ‘Our
Colleagues’ section of the Strategic Report also sets out how we helping colleagues to thrive and realise their potential, how
we support their wellbeing and how we create a diverse, equitable and inclusive culture.
How we align wider workforce and executive pay
Consistent with our approach to executive pay, our remuneration policy for all colleagues aims to be simple, transparent and
to promote the long-term success of NatWest Group. It encourages a culture where individuals are rewarded for sustained
performance in line with risk appetite and for demonstrating the right behaviours. These principles apply to everyone with
adjustments made where necessary to comply with local requirements. As set out on the previous page, the Committee Chairman
met with colleagues through the CAP in November 2021 to discuss how we take a consistent approach to workforce remuneration.
He also highlighted some of the challenges being faced with the existing Policy for executive directors. The proposed introduction
of annual bonus for executive directors under the new Policy will create closer alignment with the remuneration construct for the
wider workforce. A significant proportion of our colleagues are eligible to receive annual bonus awards, subject to performance.
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Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
All colleagues
Certain colleagues depending on location, grade or job
Senior executives only
Base salary and
pension funding
Benefits and share
plans
Role-based allowances
Annual bonus
RSP awards
A competitive level of
salary paid in cash and
reviewed annually. Set
to reflect the talents,
skills and competencies
that the individual brings
to the business.
Additional funding
is provided which
colleagues can use
to save in a company
pension scheme.
Colleagues in the UK
receive pension funding
at 10% of base salary.
The same rate applies
to executive directors.
Rates in other locations
reflect market practice
in those locations.
Some colleagues receive
funding which they can
use towards the cost of
benefits or take as cash.
Benefits offered include
private medical cover,
dental cover, personal
accident insurance, life
assurance and critical
illness insurance.
Individuals in some
jurisdictions can also join
share plans, providing
an efficient way to buy
NatWest Group plc
shares and align their
interests with our
shareholders.
Role-based allowances
reflect the skills and
experience required
for certain jobs.
These are part of
fixed remuneration for
regulatory purposes.
They are delivered in
cash and/or shares
depending on the level
of the allowance and the
seniority of the recipient.
Shares are released
in instalments over a
minimum three-year
period with a five-year
period applying to
executive directors.
This is a way of
rewarding individuals
for superior
performance.
The annual bonus pool
is based on a balanced
scorecard of measures
across our core
strategic areas
and our purpose.
Allocation from the
pool depends on the
performance of the
business area and
the individual.
Awards are made in
cash and/or shares
with larger amounts
paid out over
several years.
These encourage a
sustainable long-term
performance.
Awards are delivered
entirely in shares to provide
direct alignment with our
shareholders. We carry out
performance checks prior
to grant and again after
three years to ensure
satisfactory and sustained
performance has been
achieved.
Awards are paid out in
equal amounts across years
three to seven following
grant, followed by a
12-month retention period.
RSP participants are also
subject to shareholding
requirements.
Fixed pay
Variable pay
To drive consistency, we have agreed a set of NatWest Group-wide Remuneration Policy
Principles which are designed to:
1.
support a performance culture
– we recognise colleagues’
skills and experience, the responsibilities of their job and
their geographic location. Ultimately, we ‘pay for
performance’, underpinned by a robust performance
management process;
2.
be market facing
– we benchmark ourselves against a core
peer group and ensure our pay is fair, competitive and
affordable; and
3.
ensure compliance and governance
– our reward
design must be within policy, meet the expectations and
requirements of our regulators and be appropriately aligned
with the expectations of our shareholders and customers.
A simple and transparent pay policy supports colleagues in
doing the right thing.
Our more junior colleagues are typically paid through
fixed pay only, which was increased when variable pay
was removed.
This provides them with greater security and allows them
to fully focus on the needs of the customer.
Pay for executive directors is aligned with the wider workforce, with two main differences:
i.
the use of RSP awards; and
ii.
a requirement to maintain a holding of shares in NatWest Group, both during and after employment.
These differences are deliberate and recognise that it is in the best interests of our stakeholders for executive directors to have
a significant proportion of their remuneration paid in shares and subject to long-term holding requirements.
Base
Salary
Pension &
Benefit
Funding
+
Role-based
Allowances
Annual Bonus
RSP Awards
The Directors’ remuneration report
continued
+
Benefit funding
applies to
certain jobs
Provided to some
Material Risk
Takers (MRTs) only
Mainly manager grade and
above (including executive
directors under the new Policy).
Executive directors and
potentially some of the
CEO’s direct reports.
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Our approach to the UK Corporate Governance Code (the ‘Code’)
This table supplements other information in this report by demonstrating some of the ways in which we meet the requirements and
spirit of the Code. We continue to monitor and reflect on best practice when developing our remuneration practices. By introducing
weighted annual bonus measures, rather than assessing performance in the round, the new Policy for executive directors creates a
more direct link between the delivery of our strategy and pay and performance outcomes. We consider both the outcomes and how
they have been achieved to encourage and reward behaviours in line with our values. Malus and clawback provisions together with
long holding periods reinforce the need for recipients to act in the best interests of our stakeholders.
Provision
Our approach
Review workforce
remuneration
and alignment
with culture
Every year we consider how pay has been distributed across NatWest Group, analysing performance ratings
by grade and diversity categories. Checks are in place to ensure decisions are made fairly.
Over the last year, we also offered colleagues the opportunity to join Sharesave in the UK, Poland and India.
This simple savings plan encourages colleagues to think about their financial wellbeing and provides an
option to buy shares and align their interests with our shareholders.
We also review the annual spend on fixed pay (approximately two-thirds of the workforce receive fixed pay
only). We have targeted recent increases towards our most junior and lowest-paid colleagues, areas where
specialist skills are required leading to high attrition rates and those lowest in their salary range.
The Committee also approves, and reviews the implementation of, the Group-wide remuneration policy
principles, and approves the bonus pool for bonus-eligible colleagues across the wider workforce.
Targets exist to help build colleagues’ capability, strengthen our culture and build a diverse workforce within
an inclusive environment. These form part of the performance measures that are aligned with our strategy
and affect the pay of executive directors and bonus-eligible colleagues.
An accountability review process allows us to respond where new information would change our variable
pay decisions. The Committee works closely with other Board Committees to consider how to reflect
progress on culture in remuneration.
The governance of culture is clearly laid out with specific Senior Management Function roles having defined
accountabilities, which are taken into account in determining pay decisions for such roles.
When determining
the executive
director
remuneration
policy, we consider
factors including
clarity, simplicity,
risk, predictability,
proportionality and
alignment to culture
Most of the remuneration for executive directors is share-based and subject to deferral and retention
requirements, creating significant alignment with our shareholders.
There is clarity for executives on how performance will be assessed and the behaviours expected of them.
We provide detailed disclosure on decisions made to give our shareholders transparency.
We take risk into account at various stages of the performance assessment process, with underpins and
malus and clawback provisions providing us with further tools to adjust awards, if necessary.
We have set out scenarios of the possible rewards to executive directors under the new Policy on page 152
along with the impact of a 50% share price appreciation over the performance period for RSP awards.
Variable pay cannot be awarded above the level of fixed pay. We believe that this is a restrained and
proportionate approach to executive remuneration. RSP awards will be subject to a satisfactory and
sustainable level of performance having been achieved, having regard to our purpose-led strategic goals.
RSP awards will also be deferred over many years to encourage long-term thinking.
Discretion
We can apply discretion under our share plan rules where appropriate. The Committee has in the past
applied downwards discretion in determining variable pay outcomes and did so again this year in respect
of the 2019 LTI awards due to vest in March 2022.
The Committee can also determine whether an individual would qualify as a good leaver on departure and,
subject to meeting any regulatory requirements, decide that awards held by good leavers should vest earlier
than the normal vesting date.
Discretion is only used to ensure a fair outcome. We will disclose any use of discretion.
Further discretions include the ability to: treat variable pay awards in a range of ways in the event of a
change of control, but only within the terms of the share plan rules approved by shareholders; change any
performance measures, targets, and adjust awards if major events occur.
Scope to adjust
variable pay
through malus
and clawback
Malus allows us to reduce the amount of any unvested variable pay awards, potentially to zero, prior to
payment. Clawback allows the recovery of variable pay awards that have already vested.
The circumstances in which NatWest Group may apply malus or clawback include:
conduct which results in significant financial losses for NatWest Group;
an individual failing to meet appropriate standards of fitness and propriety;
an individual’s misbehaviour or material error;
NatWest Group or the individual’s business unit suffering a material failure of risk management; and
for malus and in-year bonus reduction only, circumstances where there has been a material downturn in
financial performance.
This list is not exhaustive and further circumstances may be considered where appropriate.
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Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Annual remuneration report
Annual
r
emuneration report
Single total figure of remuneration for executive directors for 2021 (audited)
Alison Rose
Katie Murray
2021
£000
2020
£000
2021
£000
2020
£000
Base salary
1,100
1,100
750
750
Fixed share allowance
(1)
1,100
674
750
750
Benefits
(2)
81
81
30
47
Pension
(3)
110
110
75
75
Total fixed remuneration
2,391
1,965
1,605
1,622
Annual bonus
n/a
n/a
n/a
n/a
Long-term incentive award
(4)
1,197
650
Total variable remuneration
1,197
650
Total remuneration
3,588
2,615
1,605
1,622
(1)
The fixed share allowance is based on 100% of salary and, as part of fixed remuneration, is not subject to any performance conditions. In April 2020, Ms Rose announced she would
forgo 25% of her fixed pay for the rest of the year. A reduction of £426,078 was applied to her fixed share allowance and NatWest Group made a comparable donation to the NET
Coronavirus Appeal.
(2)
Includes standard benefit funding at £26,250 per annum. In addition, Ms Rose received travel assistance in connection with company business (£25,314) and assistance with home
security (£29,703). Ms Murray also received travel assistance (£990) and home security arrangements (£2,519) for 2021.
(3)
The executive directors receive a monthly cash allowance and can choose to participate in the company’s defined contribution pension arrangements.
(4)
The 2021 value for Ms Rose relates to an LTI award granted in 2019, prior to becoming an executive director. The Committee assessed performance prior to vesting as set out below
and on the next page. No discretion was exercised as a result of the share price changing over the performance period. Ms Murray was not eligible for an LTI award in 2019.
Vesting of 2019 LTI award (audited)
The table summarises the number of shares due to vest to Ms Rose following the pre-grant and pre-vest performance assessments
and the estimated vesting value for the 2019 LTI award, shown in the single total figure of remuneration above. No dividend
equivalents were paid prior to vesting.
Alison Rose
2019 LTI award
Maximum shares
at grant
Reduction at
pre-grant test
Shares granted
Further
reduction at
pre–vest test
as a percentage
of original
maximum
Shares to vest
644,672
c.11.76%
568,829
5%
536,595
Maximum value
at grant
Reduction in
value from
pre-grant test
Value of Shares
granted
Reduction in
value at pre-vest
test
Reduction due to
fall in share price
Vesting value
(1)
£1,700,000
£200,000
£1,500,000
£85,000
£218,000
£1,197,000
(1)
Share price at grant was £2.637 and the vesting value was based on share price of £2.23, the average over the three-month period from October to December 2021.
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2019 LTI award – Pre-vest performance assessment framework
LTI awards were made in early 2019 following an assessment of performance over the 2018 financial year. Before vesting, the
Committee carries out a further review to consider whether anything has come to light which might call the original award into
question. Internal control functions and PwC, as independent advisers, the Group Board Risk Committee (BRC) and the Group
Sustainable Banking Committee (SBC) support the Committee in this assessment, with the outcome set out below.
Looking back to performance for 2018 and ‘knowing what we know now’, has NatWest Group
1. Remained safe and
secure, taking into
account financial results
and the capital position?
Has NatWest
Group breached
a minimum
capital ratio over
the period?
NO
NatWest Group
has remained
well capitalised
since 2018.
YES
Has there been
a material fall
in the NatWest
Group share
price over
the period?
NO
The share price
has risen by
4% since the
end of 2018.
Has Net
Promoter Score
(NPS) fallen
across the
business?
NO
for six segments.
YES
for one of the
five targeted
customer brands.
Have there
been indicators
of a material
deterioration in
the risk culture
or profile, taking
into account
annual
assessments by
the Risk function
and the BRC?
NO
No material
deterioration
in risk culture or
profile since 2018.
Has the
Financial
Services Culture
Board (FSCB)
(1)
survey position
fallen materially?
NO
Scores improved
consistently
since 2018.
Have colleague
engagement
scores fallen
materially?
NO
Engagement
Index has
increased
since 2018.
NO
2. Been a good bank for
customers taking into
account customer and
advocacy performance?
3. Operated in an
environment in which risk
is seen as part of the way
we work and think?
4. Operated in a way that
reflects its stated values?
Core questions
Where the answer is ‘Yes’, three further questions are considered:
1.
Is the underperformance due to factors within management’s reasonable control in the circumstances?
2.
Can the underperformance be linked back to the performance year to which the award relates, rather
than to performance developments since?
3.
Is it appropriate to reflect the underperformance in the current pre-vest test (i.e. if the underperformance
has not been adequately reflected in other ways such as subsequent pre-grant tests for awards granted in
the interim)?
If the answer to each of these questions is “Yes”, the Committee may decide that a further adjustment prior
to vesting is appropriate, and it has the discretion to decide the amount.
Further analysis
The areas of customer and risk were investigated with a specific focus on Financial Crime (FC) remediation.
Supported by external opinion, we concluded that while NPS had declined within Ulster Bank ROI over the
period, it was not considered to be due to factors which related to the 2018 award year or were within
management’s reasonable control.
Although on risk there had been no material deterioration in risk culture or profile over the period, it was
felt appropriate that the management performance relating to FC remediation should be assessed using
the Risk & Control underpin.
(1)
FSCB was formerly the Banking Standards Board. NatWest Group will cease to take part in the FSCB survey from 2022. Going forwards the LTI
pre vest test culture assessment will be assessed using Our View; NatWest Group’s internal colleague opinion survey.
Achievement of
‘threshold level
of sustainable
performance’ has
been evidenced.
No adjustment
proposed, subject
to the underpins
below.
Evidenced
by
Analysis
Potential underperformance?
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Financial review
Governance
Risk and capital management
Additional information
Financial statements
BRC assessment and recommendation to invoke the Risk & Control underpin
Following a detailed investigation by management, the BRC concluded that, while management had taken significant action to drive
delivery of the FC remediation programme, there had not been a full appreciation of the scale, complexity and interdependencies of
the programme at the time of the 2019 LTI grant which had resulted in technology and programme delays. This had led to target
dates being pushed out for critical deliverables to return within risk appetite, with such delays not being fully reflected at grant or
in subsequent grants. Following the steps above, the BRC recommended that the Committee consider applying the Risk & Control
underpin for the 2019 LTI awards.
Assessment by the Committee and final outcome (audited)
After considering the Risk & Control underpin and the organisational significance of the FC remediation programme alongside
the Group’s other priorities and performance in 2018, the Committee agreed that the awards of three individuals holding 2019 LTI
awards would be adjusted. Ross McEwan was viewed as having supervisory responsibility for the delivery of the FC remediation
programme and Alison Rose was considered to have had joint primary responsibility for the delivery of the programme, during
2018. The third individual, who is not currently an executive director and has not held such a role in the past, was also considered
to have joint primary responsibility for the programme in 2018. The Committee considered at length the differing level of
involvement of and responsibilities held by the three individuals, to ensure that fair and proportionate adjustments were made.
Mr McEwan received an LTI award of 625,712 shares out of a maximum of 663,633 shares in 2019 after the application of the
pre-grant performance assessment. Under the pre-vest assessment above, a further reduction of 5% of the maximum award was
applied using the Risk & Control underpin, resulting in a balance of 592,530 shares. Ms Rose received a 2019 LTI award of 568,829
shares following the pre-grant test, representing a 11.76% reduction from the maximum possible award. The Committee and the
Board agreed that a further reduction of 5% of Ms Rose’s 2019 LTI maximum award level would be appropriate using the Risk &
Control underpin, resulting in a balance of 536,595 shares. Applying a consistent reduction for Mr McEwan and Ms Rose was
considered to be appropriate as whilst Mr McEwan was not primarily responsible for the delivery of the programme, he continued
to play a significant role as Group CEO and was expected to provide clear line manager direction and oversight given the
importance of the FC remediation programme. These pre-vest reductions to the 2019 LTI awards of Mr McEwan and Ms Rose
resulted in a total reduction, based on their respective maximum 2019 LTI awards, of 11% for Mr McEwan and 17% for Ms Rose.
Further details on Mr McEwan’s arrangements can be found in the payments to past directors’ section.
Scheme interests – LTI awards granted during 2021 (audited)
Grant date
Face value
Award
price
Shares
awarded
(1)
Vesting levels
Performance requirements
Alison Rose
Between 0%
– 100% with
no set
minimum
vesting
The award was subject to a pre-grant assessment of
performance over 2020. A further assessment will take
place following the end of the 2023 financial year to
check that nothing has come to light that would
change the original decision. This assessment will
operate in a similar way to the framework for the 2019
LTI award pre-vest assessment, as set out above.
Katie
Murray
8 March
2021
£682,000
£1.6746
407,262
(1)
An indicative PY 2020 award of £899k was approved in principle for Ms Rose. However, as Ms Rose confirmed in April 2020 that she did not wish to be considered for a 2021 LTI
award, due to the impact of COVID-19, she declined this award. The conditional share award granted to Ms Murray equates to c.91% of base salary. The number of shares was
calculated taking into account performance and the maximum potential award for Ms Murray. The award price was based on the average share price over five business days prior
to grant. Subject to the pre-vest assessment, these awards will vest in equal amounts between years 2024 and 2028. Service conditions and malus provisions apply up until vest, and
clawback provisions apply for a period of at least seven years from the date of grant.
Pre-grant assessment of performance in 2021 (for LTI awards to be granted in 2022)
For each of the core performance areas, the Committee considers whether the executive directors have achieved what would
reasonably have been expected of them over the performance year prior to grant. We use a robust process to review performance
against pre-set goals relevant to NatWest Group’s strategic aims for that year, but apply our judgment without a formulaic range
for vesting or mechanistic weightings. Risk & Control and Stakeholder Perception underpins also apply, under which we can
consider if there are any other factors that would lead to a downwards adjustment. The CFO’s performance was assessed in line
with the framework set out below and also with reference to the performance of the Finance function.
A further performance assessment will take place in early 2025 before any vesting takes place. This will operate in a similar way to
the pre-vest framework in place for the 2019 LTI awards, as described in detail on page 159. It will consider whether anything has
come to light that would indicate the assessment below did not represent a correct view of performance at that time.
Annual remuneration report
continued
Risk & Control and Stakeholder Perception underpins
We use the underpins to give us scope to consider significant risk, stakeholder or reputational matters not already captured
in the performance assessment, taking into account advice from the BRC and the SBC. We can use the underpins to consider
events arising during the period between grant and the end of year three. Having reviewed the facts relating to management
performance with regard to FC remediation, and recognising its significance, BRC agreed it would be appropriate for the
Committee to consider an adjustment to 2019 LTI vest levels.
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Core strategic
areas
Measures and targets to assess pre-grant
performance
Performance against targets for 2021
Ratings
Scorecard
Financial &
Business Delivery
Purpose
alignment
Has a purpose
which delivers
long-term
sustainable
performance
Run a safe and secure bank
Achieve cost reduction target by reducing
other expenses, excluding operating lease
depreciation, by around 4% in comparison
to 2020.
Priority
Achieve CET1 ratio targets for NatWest
Group of 15.3% and NWH Group of 14.5%,
with appropriate repatriation of capital to
NatWest Group.
Priority
Above market rate net lending growth
across the retail and commercial businesses,
excluding UK Government financial support
schemes. Increase focus on climate lending.
Priority
Achieve RoTE target of 0.8% for NatWest
Group. Progress towards execution of
the NatWest Markets strategic review by
achieving the majority of the remaining RWA
reduction towards our medium-term target of
£20 billion by the end of 2021.
Priority
NatWest Group cost savings were £256 million or
4.0% meaning the target has been met.
NatWest Group CET1 was 18.2% at year end and
exceeded the target. In the year, NatWest Group
made significant shareholder distributions. NWH
Group CET1 was 15.9% with appropriate capital
repatriation to NatWest Group, which also
exceeded the target.
Across the UK and RBSI retail and commercial
businesses, and excluding UK Government
support schemes, net lending increased by 2.6%.
Mortgage growth exceeded the market, however
commercial lending was behind market as we
have sought to reduce certain exposures, through
targeted sector reductions and capital actions,
whilst continuing to focus on supporting
customers through sustainable lending.
Significant outperformance on RoTE which was
9.4% for the year, benefiting from a significant
impairment release.
NatWest Markets did not achieve its 2021 RWA
reduction target.
Partially
met
Scorecard
Risk & Control
Purpose
alignment
Has a purpose
which delivers
long-term
sustainable
performance
Maintain a robust control environment
NatWest Group and NWH Group to achieve
a control environment rating of ‘2’, with
evidence to support progress against
regulatory responsibilities and priorities.
Compliance with minimum controls under
ring-fencing rules.
Priority
The control environment rating across NatWest
Group and NWH Group remained a ‘3’, meaning
the target was not met.
NatWest Group is materially compliant with
ring-fencing requirements. Internal arrangements
including frameworks, processes and controls
have been developed to facilitate demonstration
of compliance with the ring-fencing regime
Not met
Material progress towards our desired
risk culture
NatWest Group and NWH Group to each
achieve a ‘2’ systematic risk culture rating
as a minimum, with key Enterprise Wide
Risk Management Framework (EWRMF)
milestones delivered and decisions made
through application of a ‘purpose’ lens.
Priority
NWH Group risk culture has improved to
systematic. However at NatWest Group level, risk
culture is still assessed as being proactive and as
such the target has not been met.
Group key risk policies and key components of the
non-financial risk framework were delivered for
implementation on 1 January 2022 meaning the
EWRMF element of the risk culture measure was
achieved in line with target.
Partially
met
Scorecard
Customer &
Stakeholder
Purpose
alignment
Honest and fair
with customers
and suppliers
A good citizen
Meaningful increase in customer advocacy
Achievement of targets across the top four
customer journeys prioritised for 2021.
Aiming for Net Promoter Score (NPS)
improvement of:
Six points for NatWest Account Opening
or be fourth or better;
Two points for NatWest Commercial
Lending;
Two points for NatWest Day-to-Day
Business Servicing.
Maintain NPS for NatWest Mortgages or
be second or better.
As at Q3 2021, customer NPS performance was
positive with targets met for two out of four
customer NPS journeys.
NatWest Account Opening NPS exceeded target
by six points, up 12 points year on year and
ranking third.
NatWest Lending NPS missed target by one point.
NatWest Day-to-Day Business Servicing has
exceeded its target by five points.
NatWest Mortgages NPS missed its target as a
result of dropping one point and dropping one
place to third.
Partially
met
161
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Core strategic
areas
Measures and targets to assess pre-grant
performance
Performance against targets for 2021
Ratings
Increase the likelihood that customers will
recommend our brands
Achievement of NPS targets for our core customer
facing businesses.
Priority
Aiming for NPS improvement of:
One point for NatWest Retail Main Bank or be fifth
or better;
Four points for NatWest Business Banking and be
third or better; and
Five points for Mid-Markets NPS or be first by
five points.
As at Q3 2021, customer NPS
performance has been positive with
targets met or exceeded for two out of
the three core customer facing businesses.
NatWest Retail main bank NPS exceeded
its target by five points, up six points year
on year. NatWest is now ranked third
compared to equal seventh a year ago.
NatWest Business Banking NPS missed
its target by two points and continues
to be ranked third. After a strong start
to the year, NPS flattened following
NatWest Group asking customers to pay
back their loans (in line with approach
advised by the Government), which
contributed to a change in sentiment.
NatWest Business Mid-Markets NPS
increased by four points but met target
by regaining first position and its lead
over the next best competitor.
Partially
met
Improve the financial capability of our customers,
colleagues and communities
Aiming to help an additional 500,000 customers to
start saving at least £100.
Priority
NatWest Group to reach 3.2 million individuals
through agreed financial capability interactions.
We have supported an additional
471,000 customers to start saving
at least £100.
We have reached 6.1 million individuals
through financial capability interactions.
Partially
met
Remove barriers to UK enterprise growth
Support removal of barriers to UK enterprise growth
through networking and funding interventions.
Support 35,000 businesses through enterprise
programmes with 200,000 customer interactions to
help them start, run and grow a business.
Priority
Support to be distributed:
75% to UK regions outside London and the
South East;
60% to females;
20% to Black, Asian and Minority Ethnic
individuals; and
10% to people intending to create
purpose-led businesses.
NatWest Group supported c.54,500
businesses through enterprise
programmes with c.200,000
(1)
customer interactions focused on
supporting businesses to start, run
and grow. Support was distributed:
79% to UK regions outside London
and the South East;
60% to females;
26% to Black, Asian and Minority
Ethnic individuals; and
52% to people intending to create
purpose-led businesses.
Met
A guardian for
future generations
To be a leading bank in helping to address the
climate challenge
Progress towards Climate Positive own operations
by 2025. Reduce carbon emissions from our direct
operational footprint by 25% of NatWest Group’s
2019 baseline position.
Providing £8 billion of funding and financing for
climate and sustainable finance in 2021.
Complete footprint estimate of 2019 total financed
emissions. Develop estimates aligned with the 2015
Paris Agreement for a further four sectors.
Priority
Progress has continued to be made
against the carbon emissions target,
with NatWest Group exceeding the
target with a 46% reduction in
emissions in 2021.
Funding and financing for climate and
sustainable finance totalled £17.5 billion,
meaning the target has been exceeded.
NatWest Group has completed its footprint
estimate of 2019 total financed emissions.
We developed 2019 financed emissions
estimates for a further eight sectors,
meaning the target has been exceeded.
Exceeded
(1)
Represents approximate number of interactions delivered by enterprise programmes during 2021 which is based upon data provided by third parties delivering these interactions
without further independent verification by NatWest Group.
Annual remuneration report
continued
162
NatWest Group
2021 Annual Report and Accounts
Core strategic
areas
Measures and targets to assess pre-grant performance
Performance against targets for 2021
Ratings
Scorecard
People & Culture
Purpose
alignment
A responsible
and responsive
employer
Build the capability of our colleagues to realise
their potential.
Achieving the capability targets as measured through
the ‘Our View’ colleague survey, NatWest Group to be
15 points above and NWH Group to be 16 points above
the Global Financial Services Norm.
NatWest Group and NWH Group
building capability scores both
missed the target by one point.
Not met
Build up and strengthen a healthy culture.
Achieving the culture targets as measured through the
Our View colleague survey. NatWest Group to be seven
points above and NWH Group to be eight points above
the FSCB.
Priority
NatWest Group and NWH Group
culture scores both exceeded
the target by two points.
Exceeded
Embed our shared purpose across the business
and brands
Achieving the shared purpose target as measured
through the ‘Our View’ colleague survey. NatWest
Group and NWH Group to be six points above the
FSCB.
Priority
NatWest Group and NWH Group
shared purpose scores exceeded
the target by three points and four
points respectively.
Exceeded
A diverse workforce and inclusive environment
To increase the percentage of females in the top three
layers of NatWest Group from 39% to 40% on aggregate.
To increase the percentage of Black, Asian and
Minority Ethnic UK employees in the top four layers
of NatWest Group from 10% to 11% on aggregate.
Achieving the inclusion target as measured through the
‘Our View’ colleague survey. NatWest Group and NWH
Group to be 13 points above the Global Financial
Services Norm.
The percentage of females in top
three layers of NatWest Group, in
aggregate, increased from 39% to 40%
as at Q3 2021, meaning the target has
been met.
The percentage of Black, Asian and
Minority Ethnic UK employees in the
top four layers of NatWest Group, in
aggregate, increased from 10% to 11%
as at Q3 2021, meaning the target has
been met.
The NatWest Group and NWH Group
inclusion index scores both exceeded
target by one point.
Met
Outcome of the pre-grant assessment for LTI awards to be granted in 2022 (audited)
In assessing performance against the above framework, the Committee also received advice from the BRC and the SBC in
making its final assessment. As part of its ‘performance in the round’ judgment, the Committee noted that targets had been met
or exceeded for five of the areas above, while five were partially met and two were missed, albeit narrowly in both cases. The
highlighted priority measures were a key focus for the Committee as it applied its judgment to assess performance for the year.
Alison Rose (audited)
Turning to individual performance, Ms Rose was considered to have had a strong year. NatWest Group’s underlying financial
performance was viewed as strong, which had resulted in significant shareholder distributions across 2021. Progress had been
made against NatWest Group’s Enterprise and Climate goals and NatWest Group’s contribution to COP26 was considered to have
been strong. People scores remained strong, despite a marginal ‘miss’ on building capability, and Customer scores were improved
in most areas. NatWest Group continued to be behind target on its Risk performance, although progress had been made in some
areas. Taking into account performance against the core goals as set out above, the Committee agreed an LTI award level of
£1,598,000 would be appropriate, which represents 145% of salary and 83% of the maximum LTI award. In order to ensure parity
of treatment with the wider workforce, the LTI outcome reflected an adjustment to mirror the downward adjustment to the 2021
bonus pool for the fine imposed by the FCA on NatWest Bank Plc for breaches of the Money Laundering Regulations 2007 and
ongoing FC remediation considerations.
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Katie Murray (audited)
Ms Murray’s performance was also considered to be strong in 2021, with highlights including her proactive engagement
with investors, the refresh of NatWest Group’s Annual Report and Accounts process and reporting frameworks and on scenario
modelling, with improvements having been delivered in forecasting capabilities. Ms Murray had shown excellent leadership on
the cost and investment agenda and had made progress on the Finance transformation agenda. In light of performance achieved,
the Committee agreed that an LTI award of £1,057,500 would be appropriate, which represents 141% of salary and 71% of the
maximum award available. In line with the approach taken for Ms Rose, the LTI outcome reflected an adjustment to mirror the
downward adjustment to the 2021 bonus pool for the fine imposed on NatWest Bank Plc for breaches of the Money Laundering
Regulations 2007 and ongoing FC remediation considerations.
Maximum award
Reduction
for pre- grant
performance
LTI award to be
made in 2022
Award level agreed
by Committee
(% of maximum)
Alison Rose
£1,925,000
£327,000
£1,598,000
83%
Katie Murray
£1,500,000
£442,500
£1,057,500
71%
Remuneration for the Chairman and non-executive directors
A change was made to the level of fees for the Group Performance and Remuneration Committee, with the Committee Chairman
receiving an increase from £60,000 to £68,000 per annum and members receiving an increase from £30,000 to £34,000 per an
num
with effect from 1 July 2021. Committee fees had not changed since 2014 and the review took place after considering the time
commitment against the other NatWest Group Board Committees and market practice. The number of meetings remained
consistently high and was not expected to change due to the heavily-regulated nature of remuneration at large banks. The annual
engagement with our stakeholders on remuneration also required a significant amount of work, particularly for the Committee
Chairman. After reflecting on current and expected future time commitment, it was agreed to bring the rates in line with those
currently paid for the BRC and the Group Audit Committee. No directors are involved in decisions regarding their own remuneration.
The temporary increase in the fees for the Chairman of the CAP, to reflect additional engagement with the workforce due to
COVID-19, came to an end on 1 April 2021 with fees reverting from £30,000 to £15,000 per annum. For NatWest Group plc Board
directors who also serve on the Boards and Committees of NatWest Holdings Limited, National Westminster Bank Plc, The Royal
Bank of Scotland plc and Ulster Bank Limited, the fees below reflect membership of all five boards and their respective Board
Committees. Directors may also receive fees for membership of other subsidiary company Boards and Committees, the value
of which is included below. No variable pay is provided to the Chairman and non-executive directors.
Total remuneration for the Chairman and non-executive directors in 2021 (audited)
Fees
Benefits
(1)
Total
Chairman (composite fee)
2021
£000
2020
£000
2021
£000
2020
£000
2021
£000
2020
£000
Howard Davies
750
750
13
12
763
762
Non-executive directors
Fees
Benefits
(2)
Total
Board
£000
N&G
£000
GAC
£000
BRC
£000
RemCo
£000
SBC
£000
TIC
£000
SID
£000
CAP
£000
Other
£000
2021
£000
2020
£000
2021
£000
2020
£000
2021
£000
2020
£000
Frank Dangeard
(3)
262
262
260
1
1
263
261
Patrick Flynn
80
15
68
34
30
227
227
1
3
228
230
Morten Friis
80
15
34
68
197
168
22
7
219
175
Robert Gillespie
80
15
34
34
64
227
221
2
3
229
224
Yasmin Jetha
80
30
60
170
128
1
171
128
Mike Rogers
80
32
60
172
170
2
172
172
Mark Seligman
80
15
34
32
30
191
189
1
1
192
190
Lena Wilson
80
34
32
30
19
195
180
5
4
200
184
(1)
The benefits column for Howard Davies, Chairman, includes private medical cover, life cover and expenses in connection with attendance at Board meetings. In April 2020, the
Chairman announced he would donate 25% of his fees for the rest of 2020 to the NET Coronavirus Appeal.
(2)
Non-executive directors are reimbursed expenses incurred in connection with travel and attendance at Board meetings.
(3)
Under the ‘Other’ column, Frank Dangeard received a composite fee as Chairman of the NatWest Markets Plc (NWM Plc) Board.
Key to table:
N&G
Group Nominations and Governance Committee
SBC
Group Sustainable Banking Committee
GAC
Group Audit Committee
TIC
Technology and Innovation Committee
BRC
Group Board Risk Committee
SID
Senior Independent Director
RemCo
Group Performance and Remuneration Committee
CAP
Colleague Advisory Panel
Annual remuneration report
continued
164
NatWest Group
2021 Annual Report and Accounts
Payments for loss of office and payments to past directors (audited)
There were no payments for loss of office made to directors in 2021. Ross McEwan stepped down from the Board as CEO in
October 2019. Mr McEwan qualified for good leaver treatment meaning his outstanding LTI awards continue to vest on their
scheduled vesting dates and pro-rating does not apply. All awards remain subject to a performance assessment prior to vesting
and the potential application of malus and clawback provisions.
As set out earlier in this report, Mr McEwan received an LTI award of 625,712 shares in 2019 which was reduced to 592,530 shares
following the application of the pre-vest assessment and Risk and Control underpin. The remaining shares are due to vest between
2022 and 2026, subject to good leaver criteria continuing to be met. The value of the shares is £1,321,342 based on the average
share price over October to December 2021. A further disclosure will be made in next year’s report following the pre-vest
assessment of the final LTI award granted to Mr McEwan in 2020. In addition, Mr McEwan received assistance with his UK tax
return for his final year of employment with NatWest Group and a payment was made in relation to taxes incurred as a result of a
business trip to California while in employment, with payments totalling £10,700. There are no other payments to past directors to
disclose for 2021.
Implementation of remuneration policy in 2022
Pay arrangements
Both executive directors will receive LTI awards in March 2022 in respect of the 2021 performance year. You can find details of
these awards on page 164. Under the existing Policy, a salary increase of 2% has been agreed for executive directors from 1 April
2022, which is below the expected average salary increase for the wider global workforce of 3.6%. Subject to the new Policy being
approved by shareholders at the 2022 AGM, the revised annual pay arrangements that will apply from the date of the AGM for the
2022 performance year are set out below.
Salary
(1 Jan 2022)
Salary
(1 April 2022)
Standard
benefits
(1)
Pension
Fixed share
allowance
(2)
Maximum bonus
award for 2022
(3)
Maximum RSP award
for 2022
(4)
Alison Rose
£1,100,000
£1,122,000
£26,250
10% of salary
100% of salary
85% of salary
125% of salary
Katie Murray
£750,000
£765,000
£26,250
10% of salary
100% of salary
85% of salary
125% of salary
(1)
Amounts shown relates to standard benefit funding. Executive directors are also entitled to travel assistance and security arrangements in line with the policy. We will disclose the value
of benefits received each year.
(2)
Fixed share allowance is payable broadly in arrears, currently in four instalments per year. The first payment for January to March 2022 will be made under the existing Policy, with the
shares released in equal amounts over a three-year period. The remaining instalments for 2022 will be made under the new Policy, with shares released in equal amounts over a
five-year period.
(3)
The maximum bonus award under the Policy is set at 100% of base salary, however, in the first year of implementation this will be limited to 85% of base salary as part of a phased
increase. The calculation of award maximum is based on salary earned over the year. As the salary increase is effective from 1 April, three months of the year will be based on existing
salary with nine months based on the post April salary. The annual bonus award is expected to vest at 50% where target performance is achieved across the scorecard.
(4)
The maximum RSP award under the Policy will be set at 150% of base salary, however, in the first year of implementation this will be limited to 125% of base salary as part of a phased
increase. As per above, the calculation of maximum is based on salary earned over the year. The RSP award is normally expected to vest in full, subject to underpin criteria that will
ensure there is no payment for failure.
Annual bonus and RSP
Subject to being approved by shareholders at the 2022 AGM, the Policy on pages 143 to 147 will apply to the executive directors
from 2022. The Committee intends to implement the new Policy as follows.
Annual bonus
The 2022 bonus scorecard will be based on weighted performance measures and appropriately stretching targets across financial
and non-financial areas that align with our purpose-led strategy. For 2022, these will be apportioned as follows:
Financial performance measures will represent 60% of the overall scorecard. Target ranges have been set in line with
the budget. A qualitative overlay will be applied to consider actual performance and how the outcome has been achieved.
Any M&A activity and performance versus the market will be considered in the final assessment;
Non-financial measures will be focused across Climate, Customer, Purpose, Culture and People, Enterprise and Capability.
For 2022, these areas will represent an aggregate of 35% of the scorecard;
Personal measures will represent 5% of the overall scorecard and the performance of each executive director will be based on
a discretionary assessment at year end; and
A downward Risk modifier will also apply, enabling risk performance to be assessed and awards reduced, potentially to zero,
as required. This will be based on an assessment of:
Annual risk performance assessment of Franchises/Functions/Legal Entities;
Annual assessment of individual performance against executive director risk and control goals; and
Qualitative behavioural observations from the Group Chief Risk Officer.
In the first year of implementation the annual bonus will be granted at a maximum value of 85% of base salary.
165
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Annual remuneration report
continued
Annual bonus performance assessment under the new Policy for 2022
Threshold and maximum targets will be disclosed retrospectively at the end of the performance period in the 2022 Directors’
Remuneration Report, alongside the actual level of performance achieved and associated narrative. No award will be made if
threshold performance, as determined by the Committee, is not achieved.
The level of the award to be paid will vary between 10% for threshold performance and 100% for maximum performance. Target
performance will pay out at 50% of maximum opportunity.
All assessments of performance are subject to the Committee’s judgment to determine the appropriate outcome. Discretion will
only be used by the Committee when the application of the formulaic performance outcome drives an unrepresentative outcome or
when it is necessary to take into account strategic, economic or societal impacts that were not or could not have been accounted
for at the point of agreeing the bonus scorecard.
Annual bonus performance measure and targets for 2022
Category
Performance measures
Target
Weighting
%
Financial
Go-forward group
(1)
ROTE.
Targets set and the extent of their achievement will be disclosed
in the 2022 Annual Report as the Committee considers them to
be commercially sensitive at this point in time.
30%
Financial
(60%)
Underlying income growth of the
Go-forward group.
Income excluding notable items to exceed £11.0 billion in the
Go-forward group.
10%
Go-forward group operating expenses,
excluding litigation and conduct costs.
Around 3% cost reduction.
10%
Progress to medium-term capital target.
CET1 ratio of around 14% post distributions.
10%
Non-Financial
Climate
Progress towards halving
emissions for own direct
operations by 2025.
Funding and financing
committed to climate and
sustainable finance.
Develop climate transition
plan for publication.
Maintain 40% reduction in carbon emissions from our direct
operational footprint against 2019 baseline.
£17.5 billion of funding and financing for climate and sustainable
finance in 2022.
Development of NWG climate transition plan for publication with
the 2022 annual results.
10%
Strategic
(35%)
Customer
Achieving Net Promoter
Score (NPS) targets on
an aggregated basis for
NatWest Group.
NPS improvement of:
One point for NatWest Retail Banking or be 2nd or better
Two points for NatWest Premier Banking
One point for Coutts
One point for NatWest Business Banking and be 3rd or better
Two points for RBSI
Maintain NPS for NatWest Commercial & Corporate Banking and
maintain 1st position.
Achieve a Customer Touchpoint Rating of 70 for NatWest Markets
(2)
.
10%
Purpose,
Culture
and
People
Progress against
purpose targets.
Progress against
culture targets.
Number of females in
senior roles.
Black, Asian and Minority
Ethnic representation.
Maintain current purpose score of 90.
Maintain current culture score of 83.
Progression towards the achievement of our externally published
long-term target (2030) for gender of 50%. Increase percentage
of females in top three layers of the organisation to 41%.
Progression towards the achievement of our externally published
medium-term target (2025) for ethnicity of 15%. Increase
percentage of Black, Asian and Minority Ethnic colleagues in top
four layers of the organisation to 12%.
10%
166
NatWest Group
2021 Annual Report and Accounts
Enterprise
&
Capability
Support a Springboard to
Sustainable Recovery and
prioritise support for harder
to reach groups.
Encourage youth participation
in enterprise.
Increase number of customers
to save at least £100.
Number of financial capability
interactions which require
active engagement, give
knowledge or skills or
change behaviour.
Support 35,000 businesses through enterprise programmes with
250,000 customer interactions to start, run and grow a business.
Support being distributed as follows:
75% support to UK regions outside London & South East;
60% support to females;
20% support to Black, Asian and Minority Ethnic individuals;
20% to people intending to create purpose-led businesses.
30,000 young adults engaged in enterprise and
entrepreneurship activity.
Help an additional 530,000 customers to start saving.
Reach 4 million people through financial capability interactions.
5%
Personal
(5%)
Discretionary assessment at year end for
both executive directors.
CEO performance is based on recommendation from Chairman
taking into account additional individual performance factors.
CFO performance is based on recommendation from CEO taking
into account individual performance goals and the performance of
the Finance function.
5%
Risk
(0-100%)
Risk performance assessment based on
Group, NatWest Holdings, Functional
(CFO only) and individual risk performance.
Discretionary downwards modifier.
0
-100%
(1)
Go-forward group excludes Ulster Bank RoI.
(2)
As NPS is not available for the NatWest Markets business, an internal Customer Touchpoint Rating is applied to assess NatWest Markets’ customer performance.
RSP performance assessment under the new Policy for 2022
The new tests are simpler than those currently operated under the existing LTI-only construct. The RSP is bolstered by the annual
bonus, which ensures that executive directors are also incentivised to deliver on the key strategic priorities of NatWest Group, with
robust weighted performance measures as set out on the previous page. After the pre-grant test and underpin, the RSP would be
expected to pay out at 100% in the vast majority of cases to deliver the expected value under the construct. In the first year of
implementation, the RSP will be granted at a maximum value of 125% of base salary. This will rise to 150% of base salary in
the second year of the new Policy.
Pre-grant test
The first RSP award will be granted in early 2023. Executive directors will be granted an RSP award provided the Committee
considers performance over 2022 has been satisfactory, based on an assessment against our performance management framework.
Pre-vest underpin
RSP awards will not be subject to further performance conditions. However, before vesting, the Committee will review the
outcomes of the business against the following underpin criteria.
A sustainable level of performance over the period will be considered with reference to:
1.
the level of capital held relative to the maximum distributable amount;
2.
total distributions paid relative to our distribution policy; and
3.
any material deterioration in the risk or regulatory compliance profile or control environment of NatWest Group, or a serious
conduct or reputational event.
The Committee will make an assessment at the end of the three-year performance period to determine whether sustainable
performance has been achieved. The Committee will refer to the above underpin criteria in determining whether this has been
the case. Following the Committee’s assessment, RSP awards may vest in full, in part or lapse in their entirety. The Committee will
also retain the right to consider other factors and apply discretion before making a decision on the final vesting outcome. This will
mitigate any potential unintended outcomes that might arise and ensure that there is a fair outcome. The Committee will explain
its reasons for applying discretion in either direction, or for not doing so. The Committee reserves the right to change the underpin
criteria when granting new RSP awards over the Policy period.
167
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Annual remuneration report
continued
Chairman and non-executive directors’ annual fees for 2022
Following a review of fees paid during 2021, the only change is to increase the fees for the Senior Independent Director role.
The rate will increase from £30,000 per annum to £34,000 per annum. This is closer to the fees paid for the equivalent role at
peer banks and also aligns with the rates currently being paid to members of the Group Board Risk Committee, the Group Audit
Committee and the Group Performance and Remuneration Committee. The change will apply from 1 January 2022 and is within
the limits allowed under the existing remuneration policy.
Fees for NatWest Group plc Board
(1)
Rates from
1 January 2022
Chairman (composite fee)
£750,000
Non-executive director basic fee
£80,000
Senior Independent Director
£34,000
Fees for NatWest Group plc Board Committees
(1)
Member
Chairman
Group Board Risk Committee
£34,000
£68,000
Group Audit Committee
£34,000
£68,000
Group Performance and Remuneration Committee
£34,000
£68,000
Group Sustainable Banking Committee
£30,000
£60,000
Technology and Innovation Committee
£30,000
£60,000
Group Nominations and Governance Committee
£15,000
Other fees for NatWest Group plc Board directors
Chairman of NatWest Markets Plc (composite fee to cover all boards and committees)
£264,000
Chairman of the Colleague Advisory Panel
£15,000
(1)
No additional fees are payable where the director is also a member of the boards and respective board committees of NatWest Holdings Limited, National Westminster Bank Plc and
The Royal Bank of Scotland plc. Where appropriate, directors receive additional fees for membership of other subsidiary company boards and committees including NatWest Markets
Plc. We will disclose the value of fees received in this report each year.
125% of
base salary
85% of
base salary
Annual
bonus
perf.
assessment
period
RSP
pre-grant
perf.
period
Cash
vesting
Share
vesting
Grant
Given 60% of variable is in the RSP, there would normally
be no deferral requirements for the bonus
210% of base salary
(maximum variable pay for 2022)
Base salary
Pension
FSA
RSP
Post-vesting retention period
Bonus
T
otal
Y
ear
2030
2031
2029
2027
2028
2026
2025
2024
2023
2022
100%
100%
10%
20%
20%
20%
20%
20%
20%
20%
Underpin
assessment
20%
Share
release
20%
20%
Structure and timing o
f p
ayments under the ne
w Policy f
or 2022
168
NatWest Group
2021 Annual Report and Accounts
Other external directorships
The Board must approve any additional appointments undertaken by directors outside NatWest Group. Steps are in place to
make sure that directors comply with regulatory limits on the number of directorships held. The Board also considers whether
it is appropriate for executive directors to retain any remuneration from any new external roles, depending on the appointment.
You can find details of current external appointments in the biographies section of the Corporate Governance report.
Annual change in directors’ pay compared to average change in employee pay
Remuneration for employees is based on salary, benefits and annual bonus. The CEO and CFO receive fixed share allowances
and are eligible for LTI awards rather than an annual bonus. The Chairman and non-executive directors receive fees rather than
salary and do not receive any variable pay. We regularly review membership of Board Committees and changes in membership will
impact the level of fees paid to non-executive directors from one year to the next. The benefits figures for non-executive directors
can also change significantly year on year depending on the amount of travel undertaken in connection with Board meetings.
2020 to 2021
2019 to 2020
Annual percentage change
Salary
Benefits
(1)
Annual Bonus
Salary
Benefits
(1)
Annual Bonus
UK employees
(2)
2.02%
4.68%
35.24%
2.86%
1.70%
-32.4%
Executive directors
Alison Rose
(3)
0%
0%
n/a
n/a
Katie Murray
0%
0%
n/a
0%
0%
n/a
Chairman and non-executive directors
Fees
Benefits
Annual Bonus
Fees
Benefits
Annual Bonus
Howard Davies
0%
8%
n/a
0%
9%
n/a
Frank Dangeard
1%
0%
n/a
0%
-75%
n/a
Patrick Flynn
0%
-67%
n/a
2%
-70%
n/a
Morten Friis
17%
214%
n/a
14%
-80%
n/a
Robert Gillespie
3%
-33%
n/a
-3%
-84%
n/a
Yasmin Jetha
(4)
33%
100%
n/a
n/a
Mike Rogers
1%
-100%
n/a
0%
-83%
n/a
Mark Seligman
1%
0%
n/a
-4%
-88%
n/a
Lena Wilson
8%
25%
n/a
16%
-64%
n/a
(1)
Standard benefit funding for executive directors has remained unchanged. The figures above excludes any other benefits to executive directors such as travel assistance in connection
with company business, the value of which is disclosed each year in the total remuneration table.
(2)
NatWest Group plc is a holding company and is not an employing entity. Therefore the disclosure above is made on a voluntary basis to compare any change in directors’ pay with all
employees based in the UK. The data above is based on full-year average salary costs of UK based employees of NatWest Group, excluding the CEO and the CFO. This is considered
to be the most representative comparator group, as it covers the majority of employees and the CEO and CFO are based in the UK.
(3)
Alison Rose, CEO, was appointed on 1 November 2019 and therefore the annual change comparison to 2020 is not relevant. No change has been made to Ms Rose’s salary over the
last two years.
(4)
Yasmin Jetha re-joined the Board on 1 April 2020, so there is no comparison for the 2019 to 2020 annual change.
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Annual remuneration report
continued
CEO to employee pay ratios
The ratios compare the total pay of the CEO against the pay of three UK employees, whose earnings represent the lower,
median and upper quartiles of the UK employee population. A significant proportion of the CEO’s pay is delivered in LTI awards.
As these are linked to performance and share price movements, this part of the ratio can fluctuate significantly from one year to
the next. None of the three employees identified this year received LTI awards. Information based on salary only is included as a
further comparison.
The pay ratios reflect the diverse range of roles and pay levels across NatWest Group as a large financial services company. The
median employee for 2021 works in Services and the median pay ratio is consistent with the pay, reward and progression policies
for UK employees taken as a whole. We are committed to paying each individual a fair rate for the role performed, using consistent
reward policies and offering opportunities for progression. We set out further information on our fair pay approach earlier in this
report and in the supporting ESG Supplement at natwestgroup.com. The change in the median pay ratio since 2018 is largely
driven by the more volatile nature of pay for the CEO. In April 2020, the CEO decided to forgo 25% of her fixed pay for the rest of
the year which also contributed to the ratio falling in 2020 before returning to more typical levels in 2021. Based on a comparison
of salary only, the trend is more stable.
Pay ratios
Remuneration values (£000)
Year
Methodology
P25
(LQ)
P50
(Median)
P75
(UQ)
Calculation
CEO
Y25
(LQ)
Y50
(Median)
Y75
(UQ)
2018
A
Total remuneration
143:1
97:1
56:1
Total remuneration
3,578
25
37
64
Salary only
44:1
30:1
19:1
Salary only
1,000
23
33
51
2019
A
Total remuneration
175:1
118:1
69:1
Total remuneration
4,517
26
38
66
Salary only
44:1
30:1
19:1
Salary only
1,017
23
34
52
2020
A
Total remuneration
99:1
66:1
39:1
Total remuneration
2,615
26
40
66
Salary only
46:1
31:1
20:1
Salary only
1,100
24
36
54
2021
A
Total remuneration
130:1
87:1
51:1
Total remuneration
3,588
28
41
70
Salary only
44:1
29:1
20:1
Salary only
1,100
25
37
55
Supplementary information on the pay ratio table:
(1)
The data for 2021 is based on remuneration earned by Alison Rose, as set out in the single figure of remuneration table in this report.
(2)
The employees at the 25th, 50th and 75th percentiles (lower, median and upper quartiles) were determined as at 31 December of the relevant year, based on full-time equivalent
remuneration for all UK employees. This includes fixed pay (salary, pension funding and where relevant benefit funding and other allowances) and also any variable pay (based on the
amount to be paid). For employees who work part-time, fixed pay is grossed up to the full-time equivalent.
(3)
‘Option A’ methodology was selected as this is considered the most statistically accurate method under the reporting regulations. UK employees receive a pension funding allowance
set as a percentage of salary. Some employees, but not the CEO, continue to participate in the defined benefit pension scheme. Under this, it would be possible to recognise a higher
value, which would in turn reduce the ratios. However, for simplicity and consistency with regulatory disclosures, we have included the pension funding allowance value in the
calculation for all employees.
(4)
The data for the three employees identified has been considered and fairly reflects pay at the relevant quartiles among the UK employee population. Each of the three individuals was
a full-time employee during the year and none received an exceptional award that would otherwise inflate their pay figure
Summary of r
emuneration le
vels for emplo
yees in 2021
49,171 employ
ees earned total r
emuneration up to £50,000
12,678 employ
ees earned total r
emuneration between £50,000 and £100,000
5,256 employ
ees earned total r
emuneration between £100,000 and £250,000
790 employ
ees earned total r
emuneration ov
er £250,000
(1)
For 2021, the disclosure of remuneration levels for employees includes anyone employed by NatWest Group during the year. This is a change of approach from previous years when
we only included colleagues employed at year end.
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2021 Annual Report and Accounts
Directors’ interests in NatWest Group plc shares (audited)
Under the existing shareholding requirements, the CEO and CFO need to build up and maintain shares to the value of 400% of
salary and 250% of salary respectively. The requirements apply both during employment and for two years after leaving, in line
with best practice. Procedures are in place to enforce the shareholding requirements, and you can find further details on page 147.
Subject to approval of the new Policy by shareholders at the 2022 AGM, the requirements will be increased to 500% of salary for
the CEO and 300% of salary for the CFO.
0
100
200
300
400
500
600
700
Alison Rose
Katie Murray
168%
316%
£1.1m
49%
267%
501%
59%
442%
Values as percentage
of salary
Shares held outright
Shares awards still subject
to performance
Shares awards that count
towards requirement
Shareholding requirement
Share interests held by directors
Alison
Rose
Katie
Murray
Howard
Davies
Frank
Dangeard
Patrick
Flynn
Morten
Friis
(2)
Robert
Gillespie
Yasmin
Jetha
Mike
Rogers
Mark
Seligman
(3)
Lena
Wilson
Shares held
(1)
2,155,298
886,232
100,000
5,000
20,000
20,000
25,000
30,000
20,000
30,000
20,000
Shareholding requirement
400% of
salary
250% of
salary
Position against requirement
501% of
salary
316% of
salary
(1)
Shares owned beneficially as at 31 December 2021 or at the date of stepping down from the Board if earlier. Includes shares held by persons closely associated with the directors. As
at 17 February 2022, there were no changes to the shares held as shown above. Share awards, as shown below, are also included for the purposes of the shareholding requirement
once any performance assessment has been completed. All share awards are included net-of-taxes due to be paid on vesting. The position against the requirement was calculated as
at 31 December 2021, at which point both executive directors exceeded the requirement based on the closing price of £2.257.
(2)
The share interest held is over 10,000 American Depositary Receipts representing 20,000 ordinary shares.
(3)
10,000 shares are held in the name of M Seligman & Co Limited, of which Mr Seligman and Louise Seligman are shareholders.
Share awards under share plans
Year
Awards held
1 Jan 2021
Awards
granted
Award price
£
Awards
vested
Awards
lapsed
Awards
forfeited
Awards held
31 Dec 2021
Expected vesting dates
Alison Rose
LTI award
2016
100,780
2.26
100,780
0
LTI award
2017
223,677
2.41
55,919
167,758
(1)
07.03.22 – 07.03.24
LTI award
2018
488,906
2.66
92,140
28,206
368,560
(1)
07.03.22 – 07.03.25
LTI award
2019
568,829
2.64
568,829
(2)
07.03.22 – 07.03.26
LTI award
2020
881,679
1.70
881,679
(2)
07.03.23 – 07.03.27
2,263,871
248,839
28,206
1,986,826
Total LTI awards subject to service
536,318
(1)
Total LTI awards subject to performance and service
1,450,508
(2)
Katie Murray
LTI award
2016
9,142
2.26
9,142
0
Deferred award
2017
34,171
2.41
17,087
17,084
(1)
07.03.22
LTI award
2017
62,382
2.41
31,191
31,191
(1)
07.03.22
Deferred award
2018
80,387
2.66
26,796
53,591
(1)
07.03.22 – 07.03.23
Deferred award
2019
226,388
2.64
17,443
208,945
(1)
07.03.22 – 07.03.26
LTI award
2020
646,565
1.70
646,565
(2)
07.03.23 – 07.03.27
Sharesave
2020
3,200
1.12
3,200
(3)
18.12.23
LTI award
2021
407,262
1.67
407,262
(2)
07.03.24 – 07.03.28
1,062,235
407,262
101,659
1,367,838
Total LTI and deferred awards subject to service
310,811
(1)
Total LTI awards subject to performance and service
1,053,827
(2)
Total Sharesave options
3,200
(3)
(1)
Performance assessment has taken place and awards remain subject to deferral and employment conditions before vesting. These awards count on a net of tax basis towards meeting
the shareholding requirement.
(2)
Awards are subject to the LTI pre-vest performance assessment along with deferral and employment conditions before vesting. See earlier in this report for the pre-vest assessment of
the 2019 LTI award. The first vesting of this award is due to take place in March 2022, which will be reflected in next year’s table together with the shares lapsed for performance.
(3)
Sharesave options enable colleagues to save from their salary with an option to buy shares at the end of the savings period. The award price is the price at which shares can be
bought. Sharesave options are normally exercisable for a period of six months from the maturity date at an option price that is discounted by up to 20% of the market value around the
time of the award.
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Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Annual remuneration report
continued
CEO pay over the same period
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
Total remuneration (£000s)
(1)
AR
1,401
2,615
3,588
RM
393
1,878
3,492
3,702
3,487
3,578
4,066
SH
1,646
1,235
Annual bonus against
maximum opportunity
SH
0%
0%
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
LTI vesting rates against
maximum opportunity
(2)
AR
60%
82%
83%
RM
73%
62%
56%
89%
41%
78%
SH
0%
0%
(1)
CEOs are Alison Rose (AR), Ross McEwan (RM) and Stephen Hester (SH) with figures based on the single figure of remuneration for the relevant year.
(2)
Maximum opportunity is set according to the approved policy and, for LTI awards granted in 2015 and onwards, the regulatory cap.
Relative importance of spend on pay
2021
£m
2020
£m
Change
Remuneration paid to all employees
(1,2)
3,156
3,324
-5.05%
Distributions to holders of ordinary shares
(3)
693
n/a
Distributions to holders of preference shares and paid-in equity
318
381
-16.5%
(1)
Remuneration paid to all employees represents total staff expenses as per Note 3 to the consolidated financial statements, exclusive of social security and other staff costs.
(2)
Comparative results have been re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the consolidated
financial statements.
(3)
Dividends proposed for payment during 2020 were withdrawn in line with regulatory requirements. The Board has confirmed its intention to pay a dividend of 7.5p per ordinary share
in respect of financial year 2021, subject to approval by shareholders at the Annual General Meeting on 28 April 2022.
Total Shareholder Return (TSR) performance
The graph compares the TSR performance of NatWest Group with companies comprising the FTSE 100 Index over the last
10 years. We have selected this index because it represents a cross-section of leading UK companies. We have added the TSR
for FTSE UK banks for the same period as a further comparison. Source: Datastream
250
200
150
100
50
0
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
FTSE 100
FTSE UK Banks
NatWest Group
Shareholder dilution and share sourcing
NatWest Group can use new issue, market-purchase or treasury shares to deliver shares that are required for employee share
plans. Best practice dilution limits are monitored and govern the number of shares that may be issued to satisfy share plan awards.
172
NatWest Group
2021 Annual Report and Accounts
Statement of shareholder voting
The tables below set out the latest resolutions to approve the Directors’ Remuneration Policy and the Annual remuneration report.
Directors’ Remuneration Policy – 2020
Annual remuneration report – 2021
Vote
Number of shares
Percentage
Vote
Number of shares
Percentage
For
39,142,662,676
90.14%
For
40,070,096,464
99.89%
Against
4,281,775,516
9.86%
Against
42,368,132
0.11%
Withheld
12,426,752
Withheld
1,371,168,504
The Group Performance and Remuneration Committee
Membership
All members of the Committee are independent non-executive directors. In order to be considered for the
role of Committee Chairman, an individual must first have served on a remuneration committee for at least
12 months. During 2021, Robert Gillespie was the Committee Chairman. Frank Dangeard, Mike Rogers, Mark
Seligman and Lena Wilson were members. The Committee held eight scheduled meetings in 2021 and a
further three ad hoc meetings. You can find further details on members and attendance in the Corporate
Governance report on page 103.
Role of the
Committee
The Committee is responsible for:
approving the remuneration policy for all colleagues and reviewing the effectiveness of its implementation;
reviewing performance and making recommendations to the Board on arrangements for
executive directors;
approving remuneration for a defined ‘in-scope’ population comprising members and attendees of the
Senior Executive Committees and direct reports of the CEO, control function heads and the Company
Secretary. The Committee also approves arrangements where individuals earn total compensation above
£1 million; and
setting the remuneration framework and principles for colleagues identified as Material Risk Takers
(MRTs). The terms of reference (ToR) of the Committee are reviewed annually and available on
natwestgroup.com
Main activities
One of the main
activities of the
Committee was to
reflect on stakeholder
feedback on the new
Policy for executive
directors, and
developing revised
proposals as set out in
this report.
Wider workforce
Executive remuneration
Governance and regulatory
Approving and overseeing
the NatWest Group-wide
Remuneration Policy.
Considering how pay has been
allocated across the workforce,
including analysis by colleague
level, geography and diversity.
Reviewing fixed pay proposals.
Approving Sharesave offers
to colleagues.
Reviewing performance over the
year and approving bonus pools
for the business areas.
Reviewing gender and ethnicity
pay gap reporting.
Reviewing performance
assessments and remuneration
arrangements for the
Committee’s ‘in scope’
population.
Setting performance objectives
for Senior Executives for the
year ahead.
Approving vesting and grant
levels for LTI awards.
Approving remuneration for
senior hires and arrangements
for any leavers.
Engaging with stakeholders
on our remuneration proposals.
Reviewing and approving the
Directors’ Remuneration Report.
Receiving benchmarking
data on executive pay and
peer practice.
Approving agenda planners
and ensuring the Committee is
meeting all its obligations under
its ToR.
Considering matters escalated
by other Board Committees and
subsidiary Performance and
Remuneration Committees.
Overseeing the MRT
identification process.
Approving submissions through
the year to the UK regulators.
Receiving quarterly updates
on accountability reviews and
approving accountability
decisions for the population
within its governance.
Carrying out the annual
evaluation of its performance.
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Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Annual remuneration report
continued
Operation of the
policy
The remuneration policy operated broadly as intended during the year, with adjustments made for
performance where appropriate. Some shareholders continued to express concerns with some parts of
the policy for executive directors, as explained earlier in this report, and the challenges in maintaining a
competitive level of pay for executive directors have heightened over the past year. This led the Committee
to believe that amendments should be proposed to shareholders at the 2022 AGM.
Managing conflicts
To mitigate potential conflicts of interest, directors are not involved in decisions regarding their own
remuneration and the Committee rather than management appoint remuneration advisers. Attendees
also play an important role in advising the Committee but are not present when their own remuneration is
discussed. The Group Chief People & Transformation Officer may be present when discussions take place on
senior executive pay, as there is considerable benefit from her participation. However, she is never present
for discussions on her remuneration.
Committee Advisers
PricewaterhouseCoopers LLP (PwC) was first appointed as remuneration adviser by the Committee in 2010
and reappointed in 2021, following an annual review of the quality of advice and the level of fees. PwC is a
signatory to the voluntary code of conduct in relation to remuneration consulting in the UK. The Committee
also took account of the views of the Chairman, the CEO, the CFO, the Group Chief HR Officer, the Group
Chief People & Transformation Officer, the Director of Reward & Employment, the Group Chief Risk Officer
and the Group Chief Audit Executive. The Committee also received input from the BRC, the GAC, the SBC
and the Performance and Remuneration Committees for the principal legal entities across NatWest Group.
The professional services PwC provides in the ordinary course of business include assurance, advisory,
tax and legal advice to NatWest Group subsidiaries. The Committee is satisfied that the advice received is
independent and objective. We also receive an annual statement setting out the protocols PwC has followed
to maintain independence. There are no connections between PwC and individual directors to be disclosed.
Fees paid to PwC for advising the Committee are based on a fixed fee structure with any exceptional items
charged on a time/cost basis. Fees for 2021 in relation to directors’ remuneration rose compared to last year
primarily due to additional work in relation to the new Policy, amounting to £211,041 in total excluding VAT
(2020 – £136,830 excluding VAT).
Performance
evaluation
The 2021 performance evaluation for the Committee was conducted externally by Independent Board
Evaluation. The Committee was considered to have managed a number of challenging items well in a
difficult year. It was noted there had been a number of unscheduled meetings, but on balance the
Committee recognised that additional discussions had been necessary.
The Committee requested the governance team to explore whether there was an opportunity to simplify
and streamline the remuneration governance framework, with it being noted that remuneration outcomes
currently flowed through a number of key legal entity performance and remuneration committees and board
risk committees.
Robert Gillespie
Chairman of the NatWest Group Performance and Remuneration Committee
17 February 2022
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2021 Annual Report and Accounts
Other remuneration disclosures
This section contains disclosures which are required in
accordance with UK regulatory requirements and the
Basel Committee on Banking Supervision Pillar 3 disclosure
requirements. They also take into account the European
Banking Authority (EBA) guidelines on sound remuneration
policies. It should be read in conjunction with the Directors’
remuneration report starting on page 136.
Remuneration policy for all colleagues
The remuneration policy supports the business strategy and is
designed to promote the long-term success of NatWest Group.
It aims to reward the delivery of good performance provided
this is achieved in a manner consistent with NatWest Group
values and within acceptable risk parameters.
The remuneration policy applies the same principles to
everyone, including Material Risk Takers (MRTs), with some
minor adjustments where necessary to comply with local
regulatory requirements. The main elements of the Policy
are set out below.
Base salary
The purpose is to provide a competitive level of fixed
cash remuneration.
Operation
We review base salaries annually to ensure they reflect the
talents, skills and competencies that the individual brings to
the business.
Role-based allowance
Certain MRT roles receive role-based allowances in order
to provide fixed pay that reflects the skills and experience
required for the role.
Operation
Role-based allowances are fixed allowances which form an
element of overall fixed remuneration for regulatory purposes.
They are based on the role the individual performs.
They are delivered in cash and/or shares depending on
the level of the allowance and the seniority of the recipient.
Shares are subject to a minimum three-year retention period.
Benefits and pension
The purpose is to provide a range of flexible and
competitive benefits.
Operation
In most jurisdictions, benefits or a cash equivalent are provided
from a flexible benefits account. Pension funding forms part
of fixed remuneration and NatWest Group does not provide
discretionary pension benefits.
Annual bonus
The purpose is to support a culture where individuals recognise
the importance of helping people, families and businesses to
thrive and are rewarded for superior performance.
Operation
The annual bonus pool is based on a balanced scorecard of
measures including financial and business delivery, customer,
people and culture, climate and risk and control measures.
Allocation from the pool depends on the performance of
the business area and the individual.
We use a structured performance management framework to
support individual performance assessment. This is designed to
assess performance against longer-term business requirements
across a range of financial and non-financial metrics. It also
evaluates adherence to internal controls and risk management.
We use a balanced scorecard to align with the business
strategy. Each individual will have defined measures of
success for their role.
We also take risk and conduct performance into account.
Control functions are assessed independently of the business
units that they oversee. Objectives and remuneration are set
according to the priorities of the control area, not the targets
of the businesses they support. The Group Chief Risk Officer
and the Chief Audit Executive have the authority to
escalate matters to Board level if management do
not respond appropriately.
Independent control functions exist for the main legal entities
outside the ring fence (NWM Plc and RBSI). Dual solid reporting
lines are in place into the respective legal entity CEOs and the
NatWest Group Control Function Heads.
Awards may be granted up to a maximum of 100% of fixed
pay. For awards made in respect of the 2021 performance
year, immediate cash awards continue to be limited to a
maximum of £2,000. In line with regulatory requirements for
MRTs, 40% of awards under £500,000 will be deferred over
four, five or seven years. This rises to 60% for awards over
£500,000. For MRTs, a minimum of 50% of any variable pay
is delivered in shares and a 12-month retention period applies
to the shares after vesting.
The deferral period is four years for standard MRTs and Risk
Manager MRTs who meet the ‘non-higher paid’ condition. It
rises to five years for ‘higher paid’ Risk Manager MRTs, FCA
Senior Management Functions (SMF) roles and PRA SMFs who
meet the ‘non-higher paid’ condition; and to seven years for
‘higher paid’ PRA SMFs. All awards are subject to malus and
clawback provisions.
Long-term incentive (LTI) awards
The purpose and operation of LTI awards is explained in detail
in the Directors’ remuneration report. Instead of an annual
bonus, NatWest Group provides executive directors and certain
members of NatWest Group’s senior executive committees with
LTI awards. Any awards made are subject to a performance
assessment prior to grant and again prior to vesting.
Shareholding requirements
The requirements promote long-term alignment between
senior executives and shareholders.
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Other remuneration disclosures
continued
Operation
Executive directors and certain members of NatWest Group’s
senior executive committees are required to build up and hold
a shareholding equivalent to a percentage of salary. There is
a restriction on the number of shares that individuals can sell
until this requirement is met.
Company share plans
The purpose is to provide an easy way for individuals to
hold shares in NatWest Group plc, which helps to encourage
long-term thinking and provides a direct involvement in
NatWest Group’s performance.
Operation
Colleagues in certain jurisdictions are offered the opportunity
to contribute from salary and acquire shares in NatWest Group
plc through company share plans. This includes Sharesave and
the Buy As You Earn plan in the UK. Any shares held are not
subject to performance conditions.
Criteria for identifying MRTs
The EBA has issued criteria for identifying MRT roles, which
includes those staff whose activities have a material influence
over NatWest Group’s performance or risk profile. These
criteria are both qualitative (based on the nature of the role)
and quantitative (based on the amount a colleague is paid).
In 2021, MRTs were identified for 11 legal entities (including
at parent holding company and consolidated levels) within
NatWest Group. The MRT criteria are applied for each of these
entities, and consequently many MRTs are identified in relation
to more than one entity.
The qualitative criteria can be summarised as: staff within
the management body; senior management; other staff with
key functional or managerial responsibilities including for
risk management; and staff who individually, or as part of a
Committee, have authority to approve new business products
or to commit to credit risk exposures and market risk
transactions above certain levels.
The quantitative criteria are: individuals earning £658,000
or more in the previous year; individuals earning less than
£658,000 in the previous year, but more than a threshold set
at the higher of £440,000 or the average total earnings of the
management body and senior management for the relevant
legal entity and who can impact the risk profile of a material
business unit; and individuals in the top 0.3% of earners of
the relevant legal entity for the previous year. In addition to
the qualitative and quantitative criteria, NatWest Group has
applied its own minimum standards to identify roles that are
considered to have a material influence over its risk profile.
Personal hedging strategies
The conditions attached to discretionary share-based awards
prohibit the use of any personal hedging strategies to lessen
the impact of a reduction in the value of such awards.
Recipients explicitly acknowledge and accept these
conditions when any share-based awards are granted.
Risk in the remuneration process
NatWest Group’s approach to remuneration promotes effective
risk management through having a clear distinction between
fixed remuneration (which reflects the role undertaken by an
individual) and variable remuneration (which is directly linked
to performance and can be risk-adjusted). Fixed pay is set at
an appropriate level to discourage excessive risk-taking and
which would allow NatWest Group to pay zero variable pay.
We achieve focus on risk through clear inclusion of risk in
performance goals, performance reviews, the determination
of variable pay pools, incentive plan design and the application
of malus and clawback. The Committee is supported in this by
the Group Board Risk Committee (BRC) and the Risk function,
as well as independent oversight by the Internal Audit function.
We use a robust process to assess risk performance. We
consider a range of measures, specifically: capital, liquidity and
funding risk; credit risk; market risk; pension risk; compliance
and conduct risk; financial crime; climate risk; operational risk;
business risk and reputational risk. We also consider our overall
risk culture.
Remuneration arrangements are in line with regulatory
requirements and we fully disclose and discuss the steps taken
to ensure appropriate and thorough risk adjustment with the
PRA and the FCA.
Variable pay determination
For the 2021 performance year, NatWest Group operated
a robust control function-led, multi-step process to assess
performance and determine the appropriate bonus pool by
business area and function. At multiple points throughout the
process, we made reference to NatWest Group-wide business
performance (from both affordability and appropriateness
perspectives) and the need to distinguish between ‘go-forward’
and ‘resolution’ activities.
The process uses financial, climate, customer and people
measures to consider a balanced scorecard of performance
assessments at the level of each business area or function.
We then undertake risk and conduct assessments at the same
level to ensure performance achieved without appropriate
consideration of risk, risk culture and conduct controls, is
not inappropriately rewarded.
BRC reviews any material risk and conduct events and, if
appropriate, an underpin may be applied to the individual
business and function bonus pools or to the overall bonus
pool. BRC may recommend a reduction of a bonus pool if it
considers that risk and conduct performance is unacceptable
or that the impact of poor risk management has yet to be fully
reflected in the respective inputs.
Following further review against overall performance
and conduct, taking into account input from the CFO on
affordability and capital and liquidity adequacy, the CEO will
make a final recommendation to the Committee, informed by
all the previous steps and her strategic view of the business.
The Committee will then make an independent decision on the
final bonus pool taking all of these earlier steps into account.
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2021 Annual Report and Accounts
The assessment process for LTI awards to executive directors
and other recipients is also founded on a balanced scorecard
approach. The scorecard is aligned with the multi-step bonus
pool process, reflecting a consistent risk management
performance assessment.
Remuneration and culture
NatWest Group continues to assess conduct and its impact
on remuneration as part of the annual Group-wide bonus pool
process and also via the accountability review framework.
Many colleagues receive fixed pay only, which provides them
with greater security and allows them to fully focus on the
needs of the customer. The Committee will continue to review
workforce remuneration and the alignment of incentives and
reward with culture.
The governance of culture is clearly laid out. SMF roles
have clearly defined accountabilities. The delivery of these
accountabilities is taken into account in their performance
and pay decisions. The Board and Group Sustainable Banking
Committee (SBC) also play essential roles in building cultural
priorities. Frameworks are in place to measure progress.
Accountability review process and
malus/clawback
We introduced the accountability review process in 2012 to
identify any material risk management, control and general
policy breach failures, and to ensure accountability for
those events.
This allows NatWest Group to respond to instances where new
information would change the variable pay decisions made in
previous years and/or the decisions to be made in the current
year. Potential outcomes under the accountability review
process are:
malus – to reduce (to zero if appropriate) the amount
of any unvested variable pay awards prior to payment;
clawback – to recover awards that have already vested;
and
in-year bonus reductions – to adjust variable pay that
would have otherwise been awarded for the current year.
As part of the acceptance of variable pay awards, colleagues
must agree to terms that state that malus and clawback may
be applied. Any variable pay awarded to MRTs is subject to
clawback for seven years from the date of grant. Since the
2016 performance year onwards, this period can be extended
to 10 years for MRTs who perform a SMF role under the
Senior Managers Regime where there are outstanding internal
or regulatory investigations at the end of the normal seven-
year clawback period. Awards to other colleagues (non-MRTs)
are subject to clawback for 12 months from each vesting date.
You can read more about the circumstances in which malus,
clawback or in-year bonus reduction may be applied on
page 157.
During 2021 a number of issues and events were considered
under the accountability review framework. The outcomes
covered a range of actions including reduction (to zero where
appropriate) of unvested awards through malus and the
suspension of awards pending further investigation.
Remuneration of MRTs
The quantitative disclosures below are made in accordance
with regulatory requirements in relation to 846 individuals who
have been identified as MRTs for one or more entities across
NatWest Group plc. The number of MRTs identified has
decreased since last year due to a reduction in credit
‘initiators’ and changes in credit authorities.
We have excluded two individuals from the tables below on
the basis that, although they have been identified as an MRT in
relation to a role within a subsidiary entity, they do not receive
any remuneration for this role and are not an MRT in relation
to their primary role for NatWest Group.
You can find details of remuneration paid to MRTs in Pillar 3
reporting on a consolidated, sub-consolidated and solo entity
level at natwestgroup.com.
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Other remuneration disclosures
continued
Total remuneration awarded to MRTs for the financial year
Other senior management and other MRTs
split by business area
NatWest
Group plc
NEDs
NatWest
Group plc
EDs
Other
senior
mngt.
Other
MRTs
NatWest
Holdings
NatWest
Markets
RBSI
Corporate
functions
Control
functions
Total
Fixed remuneration
(1)
Total number of MRTs
9
2
18
817
846
Other senior management – split by
business area
3
1
1
7
6
Other MRTs – split by business area
181
128
22
105
381
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Total fixed remuneration of MRTs
2.40
3.94
16.48
186.99
42.57
57.16
3.94
34.50
65.30
209.81
Cash-based
2.40
2.09
13.97
185.77
41.76
55.76
3.79
34.02
64.39
204.23
Share-based
1.85
2.51
1.22
0.81
1.39
0.15
0.48
0.91
5.58
Other instruments or forms
Variable remuneration
(2)
Total number of MRTs
2
16
661
679
Other senior management – split by
business area
3
1
1
7
4
Other MRTs – split by business area
142
94
17
79
329
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Total variable remuneration of MRTs
2.65
9.99
76.28
18.86
27.27
2.17
15.44
22.52
88.92
Cash-based
1.25
40.52
8.82
13.29
0.88
7.36
11.41
41.77
Of which: deferred cash
0.55
15.05
3.08
5.87
0.25
2.97
3.43
15.60
Share-based (annual bonus)
1.24
35.76
7.57
13.23
0.63
7.14
8.43
37.00
Of which: deferred shares
0.55
15.05
3.08
5.87
0.25
2.97
3.43
15.60
Share-based (LTI awards)
2.65
7.50
2.46
0.75
0.66
0.94
2.69
10.15
Of which: deferred shares
2.65
7.50
2.46
0.75
0.66
0.94
2.69
10.15
Other instruments or forms
Total remuneration of MRTs
2.40
6.59
26.47
263.27
61.43
84.43
6.11
49.94
87.82
298.73
(1)
Fixed remuneration consists of salaries, allowances, pension and benefit funding.
(2)
Variable remuneration consists of a combination of annual bonus and long-term incentive awards, deferred over a four to seven year period in accordance with regulatory
requirements. Under the NatWest Group bonus deferral structure, immediate cash awards are limited to £2,000 per person, with a further payment of cash and shares within Year 0.
(3)
Long-term incentive awards vest subject to the extent to which performance conditions were met and can result in zero payment.
(4)
Under CRD V regulations, a notional discount is available which allows variable pay to be awarded at a level that would otherwise exceed the 1:1 ratio, provided that variable pay is
delivered ‘in instruments’ (shares) and deferred over five years or more. The discount rate was not used for remuneration awarded in respect of the 2021 performance year.
Derogations
The regulations allow some flexibility not to apply certain requirements that would normally apply to MRTs where an individual’s
annual variable remuneration does not exceed £44,000 and does not represent more than one third of the individual’s total annual
remuneration (derogations permitted under point (b) of Article 94(3) of CRD V). We have used this flexibility to disapply MRT rules
relating to deferral and delivery of awards in shares for 274 MRTs in respect of the performance year 2021. Total remuneration
for these individuals in 2021 was £35.88 million (of which £31.16 million was fixed pay and £4.72 million was variable pay).
Ratio between fixed and variable remuneration
The variable component of total remuneration for MRTs at NatWest Group shall not exceed 100% of the fixed component (except
where local jurisdictions apply a lower maximum ratio for variable pay). The average ratio between fixed and variable remuneration
for 2021 was approximately 1 to 0.42. The majority of MRTs were based in the UK.
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2021 Annual Report and Accounts
Outstanding deferred remuneration
The table below includes deferred remuneration awarded or paid out in 2021 relating to prior performance years.
Deferred and retained remuneration
Total amount
of deferred
remuneration
awarded for
previous
performance
periods
£m
Of which: due
to vest in the
financial year
£m
Of which:
vesting in
subsequent
financial years
£m
Amount of
performance
adjustment
to deferred
remuneration
that was due to
vest in the
financial year
£m
Amount of
performance
adjustment
to deferred
remuneration
due to vest in
future financial
years
£m
Total amount
of adjustment
during the
financial year
due to ex post
implicit
adjustments
(1)
£m
Total amount
of deferred
remuneration
awarded before
the financial
year actually
paid out in the
financial year
£m
Total amount
of deferred
remuneration
awarded for
previous
performance
period that has
vested but is
subject to
retention
£m
NatWest Group plc NEDs
– No deferred or retained remuneration held
NatWest Group plc EDs
Cash-based
Shares or equivalent interests
7.23
0.88
6.36
(0.01)
(0.06)
1.93
0.86
0.36
Other instruments or forms
Other senior management
Cash-based
Shares or equivalent interests
18.46
3.08
15.37
4.96
3.09
2.04
Other instruments or forms
Other MRTs
Cash-based
Shares or equivalent interests
91.65
38.97
52.68
0.17
24.75
38.32
34.67
Other instruments or forms
Total amount
117.34
42.93
74.41
0.16
(0.06)
31.64
42.27
37.07
(1)
i.e. Changes of value of deferred remuneration due to the changes of prices of instruments.
(2)
Deferred remuneration reduced during the year relates to long-term incentives that lapsed when performance conditions were not met, long-term incentives and deferred awards
forfeited on leaving and malus adjustments of prior year deferred awards and long-term incentives.
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Guaranteed awards (including ‘sign-on’ awards) and severance payments
Special payments
NatWest Group
plc NEDs
NatWest Group
plc EDs
Other senior
management
Other MRTs
Guaranteed awards and sign on awards
Number of MRTs
1
2
£m
£m
£m
£m
Total amount
0.12
0.26
Of which: paid during the financial year that are not taken into account in the
bonus cap
Severance payments awarded in previous periods,
paid out during the financial year
Number of MRTs
2
10
£m
£m
£m
£m
Total amount
0.42
2.17
Severance payment awarded during the financial year
Number of MRTs
2
57
£m
£m
£m
£m
Total amount
0.26
12.10
Of which: paid during the financial year
0.26
11.31
Of which: deferred
0.79
Of which: paid during the financial year that are not taken into account in the
bonus cap
0.26
12.10
Of which: highest payment that has been awarded to a single person
0.16
0.77
(1)
NatWest Group does not offer sign-on awards. Guaranteed awards may only be granted for new hires in exceptional circumstances in compensation for awards forgone on their
previous company and are limited to first year of service.
(2)
Severance payments and/or arrangements can be made to colleagues who leave NatWest Group in certain situations, including redundancy. Such payments are calculated by a
pre-determined formula set out within the relevant social plans, policies, agreements or local laws. Where local laws permit, there is a cap on the maximum amount that can be paid.
(3)
No severance payments in excess of contractual payments, local policies, standards or statutory amounts were made to MRTs during the year, other than payments to five individuals
totalling £522,373. There were four non-standard payments totalling £443,973 in relation to litigation and one non compete payment of £78,410.
Total remuneration by band for all colleagues earning >€1million
2021
Number of MRTs
€1.0 million to below €1.5 million
42
€1.5 million to below €2.0 million
14
€2.0 million to below €2.5million
6
€2.5 million to below €3.0 million
€3.0 million to below €3.5 million
1
€3.5 million to below €4.0 million
More than €4.0 million
Total
63
(1)
Total remuneration in the table above includes fixed pay, pension and benefit funding and variable pay.
(2)
Where applicable, the table is based on an average exchange rate of €1.163 to £1 for 2021.
Colleagues who earned total remuneration of over €1 million in 2021 represent 0.09% of the workforce. These individuals include
those who manage major businesses and functions with responsibility for significant assets, earnings or areas of strategic activity
and can be grouped as follows:
The CEOs responsible for each area and their direct reports.
Those who manage large business areas.
Income generators responsible for high levels of income including those involved in managing trading activity and supporting
clients with more complex financial transactions, including financial restructuring.
Those responsible for managing balance sheet and liquidity and funding positions across the business.
Other remuneration disclosures
continued
180
NatWest Group
2021 Annual Report and Accounts
Compliance report
Statement of compliance
NatWest Group plc is committed to high standards of
corporate governance, business integrity and professionalism
in all its activities.
Throughout the year ended 31 December 2021, NatWest
Group plc has applied the Principles and complied with all of
the Provisions of the UK Corporate Governance Code issued
by the Financial Reporting Council dated July 2018 (the ‘Code’)
except in relation to:
Provision 17, in respect of the requirement that the Group
Nominations and Governance Committee should ensure
plans are in place for orderly succession to both the
Board and senior management positions and oversee
the development of a diverse pipeline for succession; and
Provision 33 that the Group Performance and Remuneration
Committee (Group RemCo) should have delegated
responsibility for setting remuneration for the Chairman
and executive directors.
In respect of Provision 17, whilst the Board is supported on
board succession by the Group Nominations and Governance
Committee, the Board considers this is a matter of significant
importance which should rightly be reserved for the full Board.
Adopting this approach ensures that all directors have an
opportunity to contribute to succession planning discussions
for Board and senior management, in support of achieving
an appropriate balance of skills, experience, knowledge and
diversity at senior levels within NatWest Group and on the
Board. It also means that all directors have an opportunity to
review, consider and become familiar with the next generation
of executive leaders.
The Board does not anticipate any changes to its approach on
these aspects of the Code.
Further information on how NatWest Group plc has applied the
Principles, and complied with the Provisions, of the Code can
be found in the Corporate governance section of this report,
which includes cross-references to relevant sections of the
Strategic report and other related disclosures.
NatWest Group plc has complied in all material respects with
the Financial Reporting Council Guidance on Audit Committees
issued in September 2012 and April 2016.
Under the US Sarbanes-Oxley Act of 2002, specific standards
of corporate governance and business and financial disclosures
and controls apply to companies with securities registered in
the US. NatWest Group plc complies with all applicable sections
of the US Sarbanes-Oxley Act of 2002, subject to a number of
exceptions available to foreign private issuers.
Internal control
The Board of Directors is responsible for the system of internal
controls that is designed to maintain effective and efficient
operations, compliant with applicable laws and regulations.
The system of internal controls is designed to manage, or
mitigate, risk to an acceptable residual level rather than
eliminate it entirely. Systems of internal control can only
provide reasonable and not absolute assurance against
material misstatement, fraud or loss.
Ongoing processes for the identification, evaluation and
management of the principal risks faced by NatWest Group
operated throughout the period from 1 January 2021 to 17
February 2022, the date the directors approved the Annual
Report and Accounts. These included the semi-annual Control
Environment Certification process, which requires senior
members of the executive and management to assess the
adequacy and effectiveness of their internal control
frameworks and certify that their business or function is
compliant with the requirements of Sarbanes-Oxley Section
404 and the UK Corporate Governance Code. The policies
that govern these processes – and reports on internal controls
arising from them – are reviewed by the Board and meet the
requirements of the Financial Reporting Council’s Guidance on
Risk Management Internal Control and Related Financial and
Business Reporting.
NatWest Group operates a three lines of defence model, which
provides an effective apportionment of responsibilities and
accountabilities across the organisation. As part of its second
line of defence role, the Risk oversight function exercises
oversight and challenge of the risk management activities
undertaken by the first line of defence, which is responsible for
designing, implementing and maintaining effective processes,
procedures and controls to mitigate risks within risk appetite.
The Internal Audit function, which is the third line of defence,
undertakes independent and objective assurance activities and
provides reports to the Board and executive management on
the quality and effectiveness of governance, risk management
and internal controls to monitor, manage and mitigate risks in
achieving NatWest Group’s objectives.
The effectiveness of NatWest Group’s internal controls is
reviewed regularly by the Board, the Group Audit Committee
and the Group Board Risk Committee. In addition, the Board
receives a risk management report at each scheduled Board
meeting. Executive management committees in each of
NatWest Group’s businesses also receive regular reports on
significant risks facing their business and how these are being
controlled. Details of the bank’s approach to risk management
are given in the Risk & Capital Management section of the
Annual Report and Accounts.
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2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
In respect of Provision 33, the Board also considers that this is
a matter which should rightly be reserved for the Board and
this is an approach the Board has adopted for a number
of years. Remuneration for the executive directors is first
considered by the Group RemCo which then makes
recommendations to the Board for consideration. This
approach allows all non-executive directors, and not just
those who are members of the Group RemCo, to participate
in decisions on the executive directors’ and the Chairman’s
remuneration and also allows the executive directors to input
to the decision on the Chairman’s remuneration. The Board
believes this approach is very much in line with the spirit of the
Code and no director is involved in decisions regarding his or
her own remuneration. A copy of the Code can be found at
frc.org.uk.
Compliance report
continued
While work continues to enhance the control environment
relating to financial crime risk, operational weaknesses
between 2012 and 2016 resulted in the inadequate monitoring
of a UK-incorporated NatWest Bank Plc customer. Regulations
require risk-sensitive ongoing monitoring of customers for the
purposes of preventing money laundering. NatWest Bank Plc
co-operated fully with the regulator’s investigation into this
case and, in October 2021, pleaded guilty to three breaches
of the Money Laundering Regulations 2007. NatWest Group
takes its responsibility to prevent and detect financial crime
extremely seriously and continues to make significant multi-
year investments to strengthen and improve its overall financial
crime framework with prevention systems and capabilities.
Almost £700 million has been invested in the last five years,
including upgrades to transaction monitoring systems,
automated customer screening and new customer due
diligence solutions.
NatWest Group continued to make enhancements to other
aspects of the wider control environment in 2021. This has
included the management of delivery of regulated programmes
such as the IRB programme, as required by Prudential
Regulatory Authority (PRA) and the European Banking
Authority (EBA). NWG continued to focus on the embedding of
a strong risk culture to support a robust control environment.
The remediation of known control issues continued to be an
important focus for both the Group Audit Committee and the
Board Risk Committee during 2021. For further information
on their oversight of remediation of the most significant issues,
please refer to the Report of the Group Audit Committee
and the Report of the Group Board Risk Committee. As part
of its activities, the Group Audit Committee has received
confirmation that management has taken, or is taking, action
to remedy significant failings or weaknesses identified through
NatWest Group’s control framework.
While not being part of the bank’s system of internal control,
the Group’s independent auditors present to the Group Audit
Committee reports that include details of any significant
internal control deficiencies they have identified. Further,
the system of internal controls is also subject to regulatory
oversight in the UK and overseas. Additional details of
regulatory oversight are given in the Risk & Capital
Management section.
While several planned activities designed to enhance the
control environment were disrupted by the extensive impact of
COVID-19 (thereby delaying the achievement of the NatWest
Group’s control environment target), the control environment
remained largely stable in 2021. There was continuing
management focus on the delivery of regulatory programmes
– including the internal transformation programme established
in response to updated IRB regulation from the Prudential
Regulatory Authority (PRA) and the European Banking
Authority (EBA) – as well as a review of the controls and
processes relating to certain regulatory reporting. There was
also significant focus on work to enhance controls relating to
financial crime risks – including ongoing work to strengthen
customer due diligence standards. The focus of the of NatWest
Group in establishing and maintaining a robust risk culture made
a valuable contribution to the overall control environment.
The remediation of known control issues remained a focus
of the Group Audit Committee and the Group Board Risk
Committee during 2021. For further information on their
oversight of remediation of the most significant issues, please
refer to the Report of the Group Audit Committee and the
Report of the Group Board Risk Committee. The Group Audit
Committee has received confirmation that management has
taken, or is taking, action to remedy significant failings or
weaknesses identified through NatWest Group’s control
framework. The Group Audit Committee and the Group Board
Risk Committee will continue to focus on such remediation
activity, particularly in view of the transformation agenda.
While not being part of the Group’s system of internal control,
the Group’s independent auditors present to the Group Audit
Committee reports that include details of any significant
internal control deficiencies they have identified. Further,
the system of internal controls is also subject to regulatory
oversight in the UK and overseas. Additional details of
regulatory oversight are given in the Risk and capital
management section.
Internal control over financial reporting
NatWest Group plc is required to comply with Section 404
of the US Sarbanes-Oxley Act of 2002 and assess the
effectiveness of internal control over financial reporting
as of 31 December 2021.
NatWest Group has assessed the effectiveness of its internal
control over financial reporting as of 31 December 2021 based
on the criteria set forth by the Committee of Sponsoring
Organizations of the Treadway Commission in the 2013
publication of ‘Internal Control – Integrated Framework’.
Based on its assessment, management has concluded that, as
of 31 December 2021, NatWest Group’s internal control over
financial reporting is effective.
NatWest Group’s auditors have audited the effectiveness of
NatWest Group’s internal control over financial reporting and
have given an unqualified opinion.
Management’s report on NatWest Group’s internal control
over financial reporting will be filed with the Securities and
Exchange Commission as part of the 2021 Annual Report
on Form 20-F.
Disclosure controls and procedures
As required by Exchange Act rules, management (including
the Group CEO and Group CFO) have conducted an evaluation
of the effectiveness and design of NatWest Group’s disclosure
controls and procedures (as defined in the Exchange Act rules)
as at 31 December 2021. Based on this evaluation,
management (including the Group CEO and Group CFO)
concluded that NatWest Group plc’s disclosure controls and
procedures were effective as of the end of the period covered
by this Annual Report and Accounts.
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2021 Annual Report and Accounts
Changes in internal control
There was no change in NatWest Group’s internal control over
financial reporting that occurred during the period covered by
this report that has materially affected, or is reasonably likely
to materially affect, NatWest Group’s internal control over
financial reporting.
The New York Stock Exchange
As a foreign private issuer with American Depository Shares
representing ordinary shares, preference shares and debt
securities listed on the New York Stock Exchange (the NYSE),
NatWest Group plc is not required to comply with all of the
NYSE governance standards applicable to US domestic
companies (the NYSE Standards) provided that it follows home
country practice in lieu of the NYSE Standards and discloses
any significant ways in which its corporate governance
practices differ from the NYSE Standards. NatWest Group plc
is also required to provide an Annual Written Affirmation to the
NYSE of its compliance with the mandatory applicable NYSE
Standards. In March 2021 NatWest Group plc submitted its
most recent Annual Written Affirmation to the NYSE which
confirmed NatWest Group plc’s full compliance with the
applicable provisions.
The Group Audit Committee fully complies with the mandatory
provisions of the NYSE Standards (including by reference to
the rules of the Exchange Act) that relate to the composition,
responsibilities and operation of audit committees. More
detailed information about the Group Audit Committee and
its work during 2021 is set out in the Group Audit Committee
report on pages 116 to 123.
The Board has reviewed its corporate governance
arrangements and is satisfied that these are consistent with
the NYSE Standards, subject to the following departures:
i.
NYSE Standards require the majority of the Board
to be independent. The NYSE Standards contain
different tests from the Code for determining
whether a director is independent. NatWest Group
plc follows the Code’s requirements in determining
the independence of its directors and currently has
eight independent non-executive directors, one
of whom is the Senior Independent Director.
ii.
The NYSE Standards require non-management
directors to hold regular sessions without
management present, and that independent
directors meet at least once a year. The Code
requires the Chairman to hold meetings with non-
executive directors without the executives present
and non-executive directors are to meet without the
Chairman present at least once a year to appraise
the Chairman’s performance and NatWest Group plc
complies with the requirements of the Code.
iii.
The NYSE Standards require that the nominating/
corporate governance committee of a listed company
be composed entirely of independent directors. The
Chairman of the Board is also the Chairman of the
Group Nominations and Governance Committee,
which is permitted under the Code (since the
Chairman was considered independent on
appointment). The terms of reference of the Group
Nominations and Governance Committee differ in
certain limited respects from the requirements set out
in the NYSE Standards, including because the Group
Nominations and Governance Committee does not
have responsibility for overseeing the evaluation
of management.
iv.
The NYSE standards require that the compensation
committee of a listed company be composed entirely
of independent directors. Although the members
of the Group RemCo are deemed independent in
compliance with the provisions of the Code, the Board
has not assessed the independence of the members
of the Group RemCo and Group RemCo has not
assessed the independence of any compensation
consultant, legal counsel or other adviser, in each
case, in accordance with the independence tests
prescribed by the NYSE Standards. The NYSE
Standards require that the compensation committee
must have direct responsibility to review and approve
the CEO’s remuneration. As stated at the start of this
Compliance report, in the case of NatWest Group plc,
the Board rather than the Group RemCo reserves
the authority to make the final determination of
the remuneration of the CEO.
v.
The NYSE Standards require listed companies to
adopt and disclose corporate governance guidelines.
Throughout the year ended 31 December 2021,
NatWest Group plc has complied with all of the
provisions of the Code (subject to the exception
described above) and the Code does not require
NatWest Group plc to disclose the full range of
corporate governance guidelines with which
it complies.
vi.
The NYSE Standards require listed companies to
adopt and disclose a code of business conduct and
ethics for directors, officers and employees, and
promptly disclose any waivers of the code for
directors or executive officers. NatWest Group has
adopted a code of conduct which is supplemented
by a number of key policies and guidance dealing
with matters including, among others, anti-bribery
and corruption, anti-money laundering, sanctions,
confidentiality, inside information, health, safety and
environment, conflicts of interest, market conduct and
management records. This code of conduct applies to
all officers and employees and is fully aligned to the
PRA and FCA Conduct Rules which apply to all
directors. The Code of Conduct is available to view
on NatWest Group’s website at natwestgroup.com.
This Compliance report forms part of the Corporate
governance report and the Report of the directors.
183
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
The directors present their report together with the audited
accounts for the year ended 31 December 2021.
Other information incorporated into this report by reference can
be found at:
Page/Note
Strategic report
2
Our colleagues
58
Climate-related financial disclosures
64
Stakeholder engagement
14, 52
Governance at a glance
80
Section 172(1) statement
52
Viability statement
76
Financial review
86
Board of directors and secretary
98
Corporate governance
103
Segmental analysis
Note 4
Share capital and other equity
Note 22
Post balance sheet events
Note 34
Risk factors
406
Group structure
During 2018, in preparation for ring-fencing a number of changes
were made to the NatWest Group structure. Following these
changes the company owns three main subsidiaries, NatWest
Holdings Limited (the parent of the ring-fenced group which
includes National Westminster Bank Plc, The Royal Bank of
Scotland plc and Ulster Bank Ireland DAC), NatWest Markets Plc
(the investment bank and the parent of NatWest Markets N.V.)
and The Royal Bank of Scotland International (Holdings) Limited
(the parent of The Royal Bank of Scotland International Limited).
Further details of the principal subsidiary undertakings are shown
in Note 33 of the consolidated financial statements and a full list of
subsidiary undertakings and overseas branches is shown in Note
12 of the parent company accounts.
Following placing and open offers in December 2008 and in April
2009, HM Treasury (HMT) owned approximately 70.3% of the
enlarged ordinary share capital of the company. In December
2009, the company issued a further £25.5 billion of new capital to
HMT in the form of B shares. HMT sold 630 million of its holding of
the company’s ordinary shares in August 2015. In October 2015
HMT converted its entire holding of 51 billion B shares into 5.1
billion new ordinary shares of £1 each in the company. HMT sold a
further 925 million of its holding of the company’s ordinary shares
in June 2018.
In March 2021, the company carried out an off-market purchase of
591 million of its ordinary shares from HMT.
In May 2021, HMT sold 580 million ordinary shares through
an accelerated book building process to institutional investors.
In July 2021, HMT announced its intention to sell part of its
shareholding over a 12 month period from August 2021 via
a trading plan, for up to 15% of the aggregate total trading volume.
At 31 December 2021, HMT’s holding in the total voting rights of
the company was 52.96%. The percentage was correct as at the
date of notification on 5 November 2021.
Activities
NatWest Group is engaged principally in providing a wide range
of banking and other financial services. Further details of the
organisational structure and business overview of NatWest Group,
including the products and services provided by each of its
operating segments and the markets in which they operate
are contained in the Business review. Details of the strategy
for delivering the company’s objectives can be found in the
Strategic report.
Results and dividends
UK company law provides that dividends can only be paid if a
company has sufficient distributable profits available to cover the
dividend. A company’s distributable profits are its accumulated,
realised profits not previously distributed or capitalised, less its
accumulated, realised losses not previously written off in a
reduction or re-organisation of capital. At 31 December 2021,
NatWest Group Plc’s distributable profits were £31 billion.
The profit attributable to the ordinary shareholders of NatWest
Group plc for the year ended 31 December 2021 amounted
to £2,950 million compared with a loss of £753 million for the
year ended 31 December 2020, as set out in the consolidated
income statement on page 300.
In 2021 NatWest Group paid an interim dividend of £347 million,
or 3.0p per ordinary share (2020 – nil).
The company has announced that the directors have recommended
a final dividend of £844 million, or 7.5p per ordinary share (2020
– £364 million or 3.0p per ordinary share). The final dividend
recommended by directors is subject to shareholders’ approval
at the Annual General Meeting on 28 April 2022.
If approved, payment will be made on 4 May 2022 to shareholders
on the register at the close of business on 18 March 2022. The
ex-dividend date will be 17 March 2022.
Subject to above mentioned condition, the payment of interim
dividends on ordinary shares is at the discretion of the Board.
Colleagues
As at 31 December 2021, NatWest Group employed 57,800 people
(excluding temporary staff). Details of all related costs are included
in Note 3 to the consolidated accounts.
Employment for disabled persons
For colleagues with disabilities NatWest Group supports them with
workplace adjustments so that they can succeed. If a colleague
becomes disabled NatWest Group will, wherever possible, make
adjustments to support them in their existing role or re-deploy
them to a more suitable alternative role.
With external recruitment, the NatWest Group Careers site gives
comprehensive insights into NatWest Group jobs, culture, locations
and application processes. It also hosts a variety of blog content
to portray stories of what it is like to work at NatWest Group. The
company also makes sure that candidates can easily request any
adjustments to help complete their application or assessment.
Going concern
NatWest Group’s business activities and financial position, the
factors likely to affect its future development and performance and
its objectives and policies in managing the financial risks to which
it is exposed and its capital are discussed in the Business review.
The risk factors which could materially affect NatWest Group’s
future results are set out on pages 406 to 426. NatWest Group’s
regulatory capital resources and significant developments in 2021
and anticipated future developments are detailed in the Capital,
liquidity and funding section on pages 249 to 265. This section also
describes NatWest Group’s funding and liquidity profile, including
changes in key metrics and the build up of liquidity reserves.
Report of
the directors
184
NatWest Group
2021 Annual Report and Accounts
Having reviewed NatWest Group’s principal risks, forecasts,
projections and other relevant evidence, the directors have a
reasonable expectation that the Group will continue in operational
existence for a period of 12 months from the date of this report.
Accordingly, the financial statements of NatWest Group and of
the company have been prepared on a going concern basis.
UK Code for Financial Reporting Disclosure
NatWest Group plc’s 2021 financial statements have been
prepared in compliance with the principles set out in the Code for
Financial Reporting Disclosure published by the British Bankers’
Association in 2010. The Code sets out five disclosure principles
together with supporting guidance. The principles are that NatWest
Group and other major UK banks will provide high quality,
meaningful and decision-useful disclosures; review and enhance
their financial instrument disclosures for key areas of interest to
market participants; assess the applicability and relevance of good
practice recommendations to their disclosures, acknowledging the
importance of such guidance; seek to enhance the comparability of
financial statement disclosures across the UK banking sector; and
clearly differentiate in their annual reports between information
that is audited and information that is unaudited.
Enhanced Disclosure Task Force (EDTF)
and Disclosures on Expected Credit Losses
(DECL) Taskforce recommendations
The EDTF, established by the Financial Stability Board, published
its report ‘Enhancing the Risk Disclosures of Banks’ in October
2012, with an update in November 2015 covering IFRS 9 expected
credit losses (ECL). The DECL Taskforce, jointly established by the
Financial Conduct Authority, Financial Reporting Council and the
Prudential Regulatory Authority, published its phase 2 report
recommendations in December 2019.
NatWest Group plc’s 2021 Annual Report and Accounts and
Pillar 3 Report reflect EDTF and have regard to DECL
Taskforce recommendations.
Authority to repurchase shares
At the Annual General Meeting in 2021 shareholders authorised
the company to make market purchases of up to 1,216,656,575
ordinary shares. The directors utilised the authority obtained
at the 2021 AGM to conduct a share buyback programme (the
‘Programme’) of up to £750 million, as announced to the market on
30 July 2021. The Programme’s purpose is to reduce the ordinary
share capital of NatWest Group.
Taking into account the reduction in issued ordinary share capital
which occurred as a result of the off-market buyback announced
on 19 March 2021, the maximum number of ordinary shares that
could be purchased by the company under the Programme was
1,157,583,542. The Programme commenced on 2 August 2021
and, as at 31 December 2021, 310,802,416 ordinary shares
(nominal value £310,802,416) had been purchased by the company
at an average purchase price of 217.5796p per ordinary share for
the total consideration of £676,242,656. A further 29,735,044
ordinary shares (nominal value £29,735,044) were purchased by
the company from 1 January to 18 January 2022 at an average
purchase price of 245.5264p per ordinary share for the total
consideration of £73,007,375. All of the purchased ordinary shares
were cancelled, representing 2.93% of the company’s issued
ordinary share capital. Shareholders will be asked to renew
this authorisation at the Annual General Meeting in 2022.
On 6 February 2019 the company held a General Meeting and
shareholders approved a special resolution to give the company
authority to make off-market purchases of up to 4.99% of its
ordinary share capital in issuance from HMT (or its nominee) at
such times as the directors may determine is appropriate. Full
details of the proposal are set out in the Circular and Notice of
General Meeting available at natwestgroup.com. This authority
was renewed at the Annual General Meeting in 2021 and
shareholders will be asked to renew the authority at the
Annual General Meeting in 2022.
The company utilised the authority it obtained at the 2020 AGM
to make an off-market purchase of 590,730,325 ordinary shares
(nominal value £590,730,325) in the company from HMT on 19
March 2021, at a price of 190.50p per ordinary share for the
total consideration of £1,125,341,269, representing 4.86% of the
company’s issued ordinary share capital. The company cancelled
390,730,325 of the purchased ordinary shares and held the
remaining 200,000,000 ordinary shares in treasury. The company
has used a total of 19,062,290 treasury shares to satisfy the
exercise of options and the vesting of share awards under the
employee share plans and the balance of ordinary shares held
in treasury as at 31 December 2021 was 180,937,710.
At the 2021 Annual General Meeting, shareholders authorised the
company to make an off-market purchase of preference shares in
the company. The company announced on 15 December 2021 that
it had utilised this authority to purchase 157,546 5.5% cumulative
preference shares (nominal value £157,546), representing 39.39%
of the share class, at a purchase price of 102%, for the total
consideration of £160,697 and 259,314 11.00% cumulative
preference shares (nominal value £259,314), representing 51.86%
of the share class, at a purchase price of 155%, for the total
consideration of £401,937. The company cancelled all of the
purchased preference shares.
Additional information
Where not provided elsewhere in the Report of the directors, the
following additional information is required to be disclosed by Part
6 of Schedule 7 to the Large and Medium-sized Companies and
Groups (Accounts and Reports) Regulations 2008.
The rights and obligations attached to the company’s ordinary
shares and preference shares are set out in our Articles of
Association, copies of which can be obtained from Companies
House in the UK or can be found at natwestgroup.com. Non-
cumulative preference share details are set out in Note 22 of
the consolidated accounts.
The cumulative preference shares represent less than 0.005% of
the total voting rights of the company, the remainder being
represented by the ordinary shares.
In a show of hands at a General Meeting of the company, every
holder of ordinary shares and cumulative preference shares, present
in person or by proxy and entitled to vote, shall have one vote.
On a poll, every holder of ordinary shares or cumulative
preference shares present in person or by proxy and entitled
to vote, shall have four votes for every share held. The notices
of Annual General Meetings and General Meetings specify the
deadlines for exercising voting rights and appointing a proxy or
proxies to vote in relation to resolutions to be passed at the meeting.
There are no restrictions on the transfer of ordinary shares in the
company other than certain restrictions which may from time to
time be imposed by laws and regulations (for example, insider
trading laws). At the 2021 Annual General Meeting, shareholders
gave authority to directors to offer a scrip dividend alternative on
any dividend paid up to the conclusion of the Annual General
Meeting in 2024. Pursuant to the UK Listing Rules, certain
employees of the company require the approval of the company
to deal in the company’s shares.
The rules governing the powers of directors, including in relation to
issuing or buying back shares and their appointment, are set out in
our Articles of Association. It will be proposed at the 2022 Annual
General Meeting that the directors’ authorities to allot shares under
the Companies Act 2006 (the Companies Act) be renewed. The
Articles of Association may only be amended by a special
resolution at a General Meeting of shareholders. The company is
not aware of any agreements between shareholders that may
result in restrictions on the transfer of securities and/or voting
rights. There are no persons holding securities carrying special
rights with regard to control of the company. A number of the
company’s employee share plans include restrictions on transfers
of shares while shares are subject to the plans. Note 3 sets out a
summary of the plans.
185
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Report of the directors
continued
Under the rules of certain employee share plans, voting rights are
exercised by the Trustees of the plan on receipt of participants’
instructions. If a participant does not submit an instruction to the
Trustee no vote is registered.
For shares held in the company’s other employee share trusts,
the voting rights are exercisable by the Trustees. However, in
accordance with investor protection guidelines, the Trustees
abstain from voting. The Trustees would take independent advice
before accepting any offer in respect of their shareholdings for the
company in a takeover bid situation. The Trustees have chosen
to waive their entitlement to the dividend on shares held by
the Trusts.
A change of control of the company following a takeover bid may
cause a number of agreements to which the company is party to
take effect, alter or terminate. All of the company’s employee
share plans contain provisions relating to a change of control.
In the context of the company as a whole, these agreements
are not considered to be significant.
Directors
The names and brief biographical details of the current directors
are shown on pages 98 to 101.
Howard Davies, Frank Dangeard, Patrick Flynn, Morten Friis,
Robert Gillespie, Yasmin Jetha, Katie Murray, Mike Rogers, Alison
Rose, Mark Seligman and Lena Wilson all served throughout the
year and to the date of signing of the financial statements.
All directors of the company are required to stand for election
or re-election annually by shareholders at the Annual General
Meeting and, in accordance with the UK Listing Rules, the election
or re-election of independent directors requires approval by all
shareholders and also by independent shareholders.
Directors’ interests
The interests of the directors in the shares of the company at
31 December 2021 are shown on page 171. None of the directors
held an interest in the loan capital of the company or in the
shares or loan capital of any of the subsidiary undertakings
of the company, during the period from 1 January 2021 to
17 February 2022.
Directors’ indemnities
In terms of section 236 of the Companies Act, Qualifying Third
Party Indemnity Provisions have been issued by the company to
its directors, members of the NatWest Group and NWH Executive
Committees, individuals authorised by the PRA/FCA, certain
directors and/or officers of NatWest Group subsidiaries and
all trustees of NatWest Group pension schemes.
Controlling shareholder
In accordance with the UK Listing Rules, the company has entered
into an agreement with HM Treasury (the ‘Controlling Shareholder’)
which is intended to ensure that the Controlling Shareholder
complies with the independence provisions set out in the UK
Listing Rules. The company has complied with the independence
provisions in the relationship agreement and as far as the company
is aware the independence and procurement provisions in the
relationship agreement have been complied with in the period
by the controlling shareholder.
Shareholdings
The table below shows shareholders that have notified NatWest
Group that they hold more than 3% of the total voting rights of the
company at 31 December 2021.
Ordinary
shares
(millions)
% of issued
share capital
with voting
rights held
1
Solicitor For The Affairs of
Her Majesty’s Treasury as Nominee
for Her Majesty’s Treasury
6,038
52.96
Norges Bank
348
3.07
(1)
Percentages provided were correct at the date of notification on 5 November 2021.
On 11 February 2022 a notification under Rule 5 of the Disclosure
and Transparency Rules (‘DTR’) was received from HMT notifying
that they held 5,735 million ordinary shares, representing 50.94% of
the issued share capital with voting rights.
As at 17 February 2022, no further notifications have been
received under Rule 5 of the DTR.
Listing rule 9.8.4
The information to be disclosed in the Annual Report and
Accounts under LR 9.8.4, is set out in this Directors’ report with the
exception of details of contracts of significance under LR 9.8.4 (10)
and (11) given in Additional information on page 427.
Political donations
At the Annual General Meeting in 2021, shareholders gave
authority under Part 14 of the Companies Act 2006, for a period of
one year, for the company (and its subsidiaries) to make political
donations and incur political expenditure up to a maximum
aggregate sum of £100,000. This authorisation was taken as a
precaution only, as the company has a longstanding policy of not
making political donations or incurring political expenditure within
the ordinary meaning of those words.
During 2021, NatWest Group made no political donations,
nor incurred any political expenditure in the UK or EU and it is not
proposed that NatWest Group’s longstanding policy of not making
contributions to any political party be changed. Shareholders will
be asked to renew this authorisation at the Annual General
Meeting in 2022.
Directors’ disclosure to auditors
Each of the directors at the date of approval of this report
confirms that:
(a) so far as the director is aware, there is no relevant audit
information of which the company’s auditors are unaware; and
(b) the director has taken all the steps that he/she ought to have
taken as a director to make himself/herself aware of any relevant
audit information and to establish that the company’s auditors are
aware of that information.
This confirmation is given and should be interpreted in accordance
with the provisions of section 418 of the Companies Act.
Auditors
Ernst & Young LLP (EY LLP) are the auditors and have
indicated their willingness to continue in office. A resolution to
re-appoint EY LLP as the company’s auditors will be proposed
at the forthcoming Annual General Meeting.
By order of the Board
Jan Cargill
Chief Governance Officer and Company Secretary
17 February 2022
NatWest Group plc
is registered in Scotland No. SC45551
186
NatWest Group
2021 Annual Report and Accounts
This statement should be read in conjunction with the responsibilities of the auditor set out in their report on pages 287 to 299.
The directors are responsible for the preparation of the Annual Report and Accounts. The directors are required to prepare Group
financial statements, and as permitted by the Companies Act 2006 have elected to prepare company financial statements, for each
financial year in accordance with UK adopted International Accounting Standards, International Financial Reporting Standards as
issued by the International Accounting Standards Board and IFRS as adopted by the European Union. They are responsible for
preparing financial statements that present fairly the financial position, financial performance and cash flows of NatWest Group.
In preparing those financial statements, the directors are required to:
select suitable accounting policies and then apply them consistently;
make judgments and estimates that are reasonable, relevant and reliable; and
state whether applicable accounting standards have been followed, subject to any material departures disclosed and explained
in the financial statements.
prepare the financial statements on a going concern basis unless it is inappropriate to presume that the company and Group will
continue in business.
The directors are responsible for keeping proper accounting records which disclose with reasonable accuracy at any time
the financial position of NatWest Group and to enable them to ensure that the Annual Report and Accounts complies with the
Companies Act 2006. They are also responsible for safeguarding the assets of NatWest Group and hence for taking reasonable
steps for the prevention and detection of fraud and other irregularities.
Under applicable law and regulations, the directors are also responsible for preparing a Strategic report, Directors’ report,
Directors’ remuneration report and Corporate governance statement that comply with that law and those regulations. The directors
are responsible for the maintenance and integrity of the corporate and financial information included on the company’s website.
The directors confirm that to the best of their knowledge:
the financial statements, prepared in accordance with UK adopted International Accounting Standards, International Financial
Reporting Standards as issued by the International Accounting Standards Board and IFRS as adopted by the European Union,
give a true and fair view of the assets, liabilities, financial position and profit or loss of the company and the undertakings
included in the consolidation taken as a whole; and
the Strategic report and Directors’ report (incorporating the Financial review) include a fair review of the development and
performance of the business and the position of the company and the undertakings included in the consolidation taken as
a whole, together with a description of the principal risks and uncertainties that they face.
In addition, the directors are of the opinion that the Annual Report and Accounts, taken as a whole, are fair, balanced and
understandable and provide the information necessary for shareholders to assess the company’s position and performance,
business model and strategy.
By order of the Board
Howard Davies
Chairman
Alison Rose-Slade
Group Chief Executive Officer
Katie Murray
Group Chief Financial Officer
17 February 2022
Board of directors
Chairman
Howard Davies
Executive directors
Alison Rose-Slade
Katie Murray
Non-executive directors
Frank Dangeard
Patrick Flynn
Morten Friis
Robert Gillespie
Yasmin Jetha
Mike Rogers
Mark Seligman
Lena Wilson
Statement of directors’ responsibilities
187
NatWest Group
2021 Annual Report and Accounts
Strategic report
Financial review
Governance
Risk and capital management
Additional information
Financial statements
Risk and
capital
management
188
Risk and capital management
189
Presentation of information
189
Update on COVID-19
189
Risk management framework
189
Introduction
189
Culture
190
Governance
192
Risk appetite
193
Identification and measurement
193
Mitigation
193
Testing and monitoring
193
Stress testing
197
Credit risk
197
Definition, sources of risk and key developments
197
Governance and risk appetite
197
Identification and measurement
197
Mitigation
198
Assessment and monitoring
199
Problem debt management
200
Forbearance
200
Impairment, provisioning and write-offs
203
Significant increase in credit risk and asset lifetimes
205
Economic loss drivers and UK economic uncertainty
211
Measurement uncertainty and ECL sensitivity analysis
213
Measurement uncertainty and ECL adequacy
214
Banking activities
245
Trading activities
249
Capital, liquidity and funding risk
249
Definitions and sources of risk
250
Capital, liquidity and funding management
251
Key points
252
Minimum requirements
253
Measurement
266
Market risk
266
Non-traded market risk
274
Traded market risk
277
Market risk – linkage to balance sheet
278
Pension risk
279
Compliance & conduct risk
279
Financial crime risk
280
Climate risk
281
Operational risk
284
Model risk
284
Reputational risk
Risk and ca
pital managem
ent
NatWest Group
A
nnual Repor
t and Accou
nts 2021
189
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Presentation of information
Where marked as audited in the se
ction header, certain
information in the Risk and cap
ital management section (pages
188 to 285) is within the scope of the Independen
t auditor’s
report.
Update on COVID-19
While the immediate disruption diminished duri
ng the year, the
ongoing impacts of the global p
andemic remained a significant
focus for risk management in 20
21 and uncertainty in the
operating environment continued. NatWes
t Group remained
committed to supporting its cus
tomers while operating safely
and soundly in line with its strategic objecti
ves.
Against the backdrop of a slowly
-recovering economy, the
credit risk profile remains heightened and there is an
expectation that the impacts of the pandemic
will continue to
be seen in the performance of NatWest G
roup’s portfolios for
some time. NatWest Group anti
cipates increased default levels
in 2022 as a result.
While the direct impact on NatWest Group’s operation
al risk
profile reduced, NatWest Group
continued to closely monitor
the second-order impacts on its transformation
agenda, with a
significant focus on managing res
ource to protect key
regulatory deliveries. The continued evolution of N
atWest
Group’s ways of working – to include lar
ge-scale working from
home – also required significant operational
risk focus,
particularly in terms of business resilie
nce.
As a result of its strong balanc
e sheet and prudent approach to
risk management, NatWest Group remains well pl
aced to
withstand these aftershocks as well as providing supp
ort to
customers when they need it most.
Risk management framework
Introduction
NatWest Group operates an enterprise-wide risk m
anagement
framework, which is centred around the embedding of
a strong
risk culture. The framework ensures the gove
rnance,
capabilities and methods are in place to facilitate risk
management and decision-making ac
ross the organisation.
The framework ensures that NatWest G
roup’s principal risks –
which are detailed in this section – are appropri
ately controlled
and managed. It sets out the standards and objec
tives for risk
management as well as defining the division of role
s and
responsibilities.
This seeks to ensure a consistent app
roach to risk management
across NatWest Group and its subsidiaries. It aligns
risk
management with NatWest Group’s over
all strategic objectives.
The framework, which is designed and m
aintained by NatWest
Group’s independent Risk funct
ion, is owned by the Chief Risk
Officer. It is reviewed and approved annually by t
he Board. The
framework incorporates risk governance, Nat
West Group’s
three lines of defence operating model and the Risk functi
on’s
mandate.
Risk appetite, supported by a robust set of p
rinciples, policies
and practices, defines the levels
of tolerance for a variety of
risks and provides a structured approach to risk-takin
g within
agreed boundaries.
While all NatWest Group colleagues are responsible for
managing risk, the Risk function provides ove
rsight and
monitoring of risk management activities, includin
g the
implementation of the framework and adherence to its
supporting policies, standards and ope
rational procedures. The
Chief Risk Office
r plays an int
egral role in providin
g the Board
with advice on NatWest Group’
s risk profile, the performance of
its controls and in providing challenge whe
re a proposed
business strategy may exceed risk tolerance
.
In addition, there is a process to identify and man
age top risks,
which are those that could hav
e a significant negative impact
on NatWest Group’s ability to meet its strategic objec
tives. A
complementary process operates
to identify emerging risks.
Both top and emerging risks may incorporate
aspects of – or
correlate to – a number of principal risks
and are reported
alongside them to the Board on a regular basis.
Culture
Risk culture is at the heart of NatWest G
roup’s risk
management framework and its risk manage
ment practice.
The risk culture target is to mak
e risk part of the way
employees work and think.
A focus on leaders as role models
and action to build clarity,
develop capability and motivate e
mployees to reach the
required standards of behaviour are key to achieving
the risk
culture target. Colleagues are expected
to:
Take personal resp
onsibility for underst
anding and proacti
vely
managing the risks as
sociated with indi
vidual roles.
Respect risk manag
ement and the part
it plays in daily work.
Understand the risks
associated
with individual roles.
Align decision-maki
ng to NatWest
Group’s risk appetite.
Consider risk in all
actions and de
cisions.
Escalate risks
and issues early; taking actio
n to mitigate risks
and learning from
mistakes and near-
misses.
Challenge others’ at
titudes, ideas
and actions.
Report and comm
unicate risks tr
ansparently.
The target risk culture behaviours are embedde
d in NatWest
Group’s Critical People Capabilities and are clea
rly aligned to
the core values of “serving cust
omers”, “working together”,
“doing the right thing” and “thinking long te
rm”. These act as
an effective basis for a strong risk culture because the C
ritical
People Capabilities
form the ba
sis of all recruitment and
selection processes
.
Training
Enabling employees to have th
e capabilities and confidence to
manage risk is core to NatWest Group’s le
arning strategy.
NatWest Group offers a wide r
ange of learning, both technical
and behavioural, across the ris
k disciplines. This training can be
mandatory, role-specific or for personal develop
ment.
Mandatory learning for all staff is f
ocused on keeping
employees, customers and NatWest Group safe. This is e
asily
accessed online and is assigned to each perso
n according to
their role and business area. The
system allows monitoring at
all levels to ensure completion.
Our Code
NatWest Group’s conduct guidance, Our Code,
provides
direction on expected behaviour and sets out the st
andards of
conduct that support the values
. The code explains the effect of
decisions that are taken and describes the p
rinciples that must
be followed.
These principles cover conduct-related issues
as well as wider
business activities. They focus
on desired outcomes, with
practical guidelines to align the values wit
h commercial
strategy and actions. The emb
edding of these principles
facilitates sound decision-making and a clear focus on
good
customer outcomes.
Where appropriate, if conduct falls short of Na
tWest Group’s
required standards, the accoun
tability review process is used to
assess how this should be reflec
ted in pay outcomes for the
individuals concerned (for more
information on this process
refer to page 155). The NatWest Group remune
ration policy
ensures that the remuneration arrangements for
all employees
reflect the principles and standards prescribed by the PRA
rulebook and the FCA handbook. Any e
mployee falling short of
the expected standards would also be subject
to internal
disciplinary policies and procedures. If appro
priate, the relevant
authority would be notified.
Risk and capital m
anageme
nt continued
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Governance
Risk and capital management
Additional information
Financial review
Risk management framework
continu
ed
Governance
Committee structure
The diagram shows NatWest Group’s risk com
mittee structure in 2021 and the main purpose
s of each committee.
(1)
The Group Executive Risk Committee
is chaired by the Group Chief Executive Officer and supports her (and other accountable executives) in discharging risk management
accountabilities.
(2)
The Group Executive Committee is chaired by th
e Group Chief Executive Officer and supports her in discharging her individual accountabilities in accordance with the authority
delegated to her by the Board.
(3)
The Group Asset & Liability Management Committee is
chaired by the Group Chief Financial Officer and supports her in discharging her individual accountabilities relating to
treasury and balance sheet management.
(4)
In addition, the Group Technical Asset & Liability Manag
ement Committee, chaired by the Group Treasurer, provides oversight of capital and balance sheet management in line with
approved risk appetite under normal and stress con
ditions. Reviews and challenges the financial strategy, risk management, balance sheet and remuneration and policy implications
of the Group’s pension schemes.
(5)
The Group Executive Disclosure Committee is cha
ired by the Group Chief Financial Officer and supports her in discharging her accountabilities relating to the production and
integrity of the Group’s financial information an
d disclosures.
NatWest Group p
lc Board
Gr
oup B
oar
d Ri
sk
Committee
Provides ov
ersight
and
advice to
the Board o
n
current and
future r
isk
exposures, r
isk pro
file, ri
sk
appetite
and risk c
ulture.
Reviews the
design
and
implement
ation of th
e risk
management
framework
and provi
des inpu
t to
remuneratio
n decis
ions.
Gro
up
Asse
t &
Lia
bil
ity
Man
age
men
t
Committee
(3, 4)
Supports the Group CF
O in
overseeing the effect
ive
management of t
he Group’s
current and future
balance
sheet in line wit
h Board-
approved strateg
y and
risk appetite.
Group Executive R
isk
Committee
(1)
Reviews, challenges a
n
d
debates
all material risk and
control matters across
the
Group. Supports t
he CEO and
other accountable e
xecutives in
discharging risk ma
nagement
accountabilitie
s. Considers the
Group’s risk profile rela
tive to
current and future
strategy and
oversees impleme
ntation of the
risk manageme
nt framework.
Gro
up
Exe
cutiv
e
Committee
(2)
Supports the Group CE
O in
discharging her i
ndividual
accountabilitie
s including matters
relating to strategy, fi
nancials,
capital, risk and operati
o
nal
issues. Monitors the
implementation of cultu
re
change. Supports the
Group CEO
in forming recomme
ndations to
the Board and to rele
vant Board
committees.
Gr
oup A
udi
t
Committee
Assists
the Board in carrying
out its accounting, i
nternal
control and financial
reporting responsibil
ities.
Reviews the effective
ness of
internal controls s
ystems
relating to fina
ncial
management and
compliance wit
h financial
reporting, asse
t
safeguarding and
accounting standards
.
Considers material risks
and approves,
as appropriate, acti
ons recommended
by the Group Board
Risk Committee.
Monitors performance
against ris
k appetite. Reviews and ap
proves the risk
appetite
framework and q
ualitative
statements of risk app
etite for
all key risks
.
Gro
up
Exe
cutiv
e
Di
sclo
sure
Committee
(5)
Ensures that NatWe
st Group
and relevant subsid
iary
disclosures are accu
rate,
complete and fair. Sup
ports the
Group CRO in re
viewing and
evaluating all significa
nt
expected credit losse
s and the
Group CFO in re
viewing and
evaluating related pr
ovisions
and valuations.
.
Risk and capital m
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nt continued
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Risk and capital management
Additional information
Financial review
Risk management framework
continu
ed
Risk management structure
The diagram shows NatWest Group’s risk m
anagement structure in 2021 and key risk m
anagement responsibilities.
(1)
The Group Chief Executive Officer a
lso performs the NWH Chief Executive Officer role.
(2)
The Group Chief Risk Off
icer also performs the NWH Chief Risk Officer role.
(3)
The NWH Risk function provides risk
management services across NWH, including to the NWH Chief Risk Officer and – where agreed – to NWM and R
BSI Chief Risk Officers. These
services are managed, as appropriate, through s
ervice level agreements.
(4)
The NWH Risk function is independent of the NW
H customer-facing franchises and support functions. Its structure is divided into three parts (Directors of Risk, Specialist Risk
Directors and Chief Operating Officer) to facilitate effective management of the risks
facing NWH. Risk committees in the customer businesses oversee risk exposures arising from
management and business activities and focus on
ensuring that these are adequately monitored and controlled. The Directors of Risk, (Retail Banking; Commercial Banking; wea
lth
businesses; Financial & Strategic Risk; Non-Financial Risk
& Frameworks and Compliance & Conduct) as well as the Director, Financial Crime Risk NatWest Holdings and the Chief
Operating Officer report to the NWH Chief Risk Officer. The Director of R
isk, Ulster Bank I
reland DA
C reports to the Ulster Bank Ireland DAC Chief Executive. He also has a
reporting line to the NWH Chief Risk Officer and to the Chair of the Ulster Bank Ireland DAC
Board Risk Committee.
(5)
The Chief Risk Officers for NWM and RBSI have d
ual reporting lines into the Group Chief Risk Officer and the respective Chief Executive Officers of their entities. There are
additional reporting lines to the NWM and RBSI Board Risk Committee
chairs and a right of access to the respective Risk Committees.
NWM
Chief Ris
k
Of
f
ic
er
NWH
Chief Risk
Officer
Leads the NatWest Group Risk fu
nction. Defines and delivers
the risk, conduct, compliance and financial crime st
rategies.
Defines overall risk service provision requiremen
ts to enable
delivery of NatWest Group strategies, including policies,
governance, frameworks, oversight and challenge,
risk
culture and risk reporting. Contributes to the
development of
strategy, transformation and culture as a me
mber of the
Executive Committee.
RBSI
Chief Executive
Officer
NWH
Chief
Exe
cu
ti
ve
Of
fi
cer
NWM
Chief Exec
utive
Offic
er
RBS Chief
Executive
Group
Chief Risk
Officer
RBSI
Chief Risk
Officer
Group
Chief Exe
cutive
Officer
Leads the NWH Risk function. Re
sponsibilities include policy,
governance, frameworks, oversight and challenge,
risk
culture and reporting. Delivers risk services ac
ross NatWest
Group governed by appropriate se
rvice level agreements.
Contributes to NWH strategy as
a member of the NWH
Executive Committee.
Leads the NWM Risk function. Responsibilities include p
olicy,
governance, frameworks, oversight and challenge,
risk
culture and reporting. Contributes to NWM strategy
as a
member of the NWM Executive Committee.
Leads the RBSI Risk function. R
esponsibilities include policy,
governance, frameworks, oversight and challenge,
risk
culture and reporting. Contributes to RBSI strategy
as a
member of the RBSI Executive Committee.
Risk and capital m
anageme
nt continued
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Risk and capital management
Additional information
Financial review
Risk management framework
continu
ed
Three lines of defence
NatWest Group uses the industry-standard th
ree lines of
defence model to articulate accountabilities a
nd responsibilities
for managing risk. This supports the embedding of eff
ective risk
management throughout the organisation. All roles below
the
CEO sit within one of the three l
ines. The CEO ensures the
efficient use of resources and the eff
ective management of
risks as stipulated in the risk management framewo
rk and is
therefore considered to be outs
ide the three lines of defence
principles.
First line of defence
The first line of defence incorporates most roles in N
atWest
Group, including those in the customer-facing f
ranchises,
Technology and Services as well as support func
tions such as
Human Resources, Legal and Finance.
The first line of defence is emp
owered to take risks within the
constraints of the risk management framework and policie
s as
well as the risk appetite stateme
nts and measures set by the
Board.
The first line of defence is responsible for managing its di
rect
risks. With the support of specialist functio
ns such as Legal,
Human Resources and Technology, it is also
responsible for
managing its consequential risks
by identifying, assessing,
mitigating, monitoring and reporting risks.
Second line of defence
The second line of defence comprises
the Risk function and is
independent of the first line.
The second line of defence is empowered to design
and
maintain the risk management
framework and its components.
It undertakes proactive risk oversight and con
tinuous
monitoring activities to confirm that NatWest Group eng
ages in
permissible and sustainable risk-taking activities.
The second line of defence advis
es on, monitors, challenges,
approves, escalates and reports
on the risk-taking activities of
the first line, ensuring that thes
e are within the constraints of
the risk management framework and policies as well
a
s the risk
appetite statements and measures set by the Board.
Third line of defence
The third line of defence is the Internal Audi
t function and is
independent of the first and se
cond lines.
The third line of defence is responsible for providing
independent and objective assu
rance to the Board, its
subsidiary legal entity boards and executive
management on
the adequacy and effectiveness of ke
y internal controls,
governance and the risk management in place
to monitor,
manage and mitigate the key ris
ks to NatWest Group and its
subsidiary companies achieving their objectives.
The third line of defence executes its duties freel
y and
objectively in accordance with the Charte
red Institute of
Internal Auditors’ Code of Ethics and Internation
al Standards.
Risk appetite
Risk appetite defines the type and aggregate level of
risk
NatWest Group is willing to accept in pursuit of i
ts strategic
objectives and business plans. Ris
k appetite supports sound risk
taking, the promotion of robust risk practices and
risk
behaviours, and is calibrated annually.
For certain principal risks, risk
capacity defines the maximum
level of risk NatWest Group can assume before b
reaching
constraints determined by regulatory capital
and liquidity
requirements, the operational environment, and fr
om a conduct
perspective. Establishing risk capacity helps dete
rmine where
risk appetite should be set, ensuring there is a
buffer between
internal risk appetite and NatWest Group’s ultima
te capacity to
absorb losses.
Risk appetite framework
The risk appetite framework supports eff
ective risk
management by promoting sound risk-taking t
hrough a
structured approach, within agreed bounda
ries. It also ensures
emerging risks and risk-taking activities that
might be out of
appetite are identified, assessed, es
calated and addressed in a
timely manner.
To facilitate this, a detailed annu
al review of the framework is
carried out. The review includes:
Assessing the adequacy of the f
ramework when compared
to internal and external expectations.
Ensuring the framework remains ef
fective and acts as a
strong control environment for
risk appetite.
Assessing the level of embedding of risk
appetite across the
organisation.
The Board approves the risk appe
tite framework annually.
Establishing risk appetite
In line with NatWest Group’s risk appetite framewo
rk, risk
appetite is maintained across NatWest G
roup through risk
appetite statements. These are in place for
all principal risks
and describe the extent and type of
activities that can be
undertaken.
Risk appetite statements consist of quali
tative statements of
appetite supported by risk limits and triggers tha
t operate as a
defence against excessive risk-taking. Risk
measures and their
associated limits are an integral part of the risk a
ppetite
approach and a key part of embedding risk a
ppetite in day-to-
day risk management decisions. A cle
ar tolerance for each
principal risk is set in alignment with busi
ness activities.
The annual process of reviewing and upd
ating risk appetite
statements is completed alongside the business an
d financial
planning process. This ensures that plans and risk
appetite are
appropriately aligned.
The Board sets risk appetite for
all principal risks to help ensure
NatWest Group is well placed to meet its priorities and lo
ng-
term targets even in challenging economic enviro
nments. This
supports NatWest Group in remaining resilie
nt and secure as it
pursues its strategic business objec
tives.
NatWest Group’s risk profile is frequently
reviewed and
monitored. Management focus is
concentrated on all principal
risks as well as the top and emerging risk issue
s which may
correlate to them. Risk profile re
lative to risk appetite is
reported regularly to senior management and
the Board.
NatWest Group policies directly support the quali
tative aspects
of risk appetite. They define the qualitative ex
pectations,
guidance and standards that stipulate the nature
and extent of
permissible risk taking and are consistently a
pplied across
NatWest Group and its subsidiaries.
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Risk and capital management
Additional information
Financial review
Risk management framework
continu
ed
Identification and measuremen
t
Identification and measurement
within the risk management
process comprises:
Regular assessment of the overall risk profile, inco
rporating
market developments and trends, as well as ex
ternal and
internal factors.
Monitoring of the risks associat
ed with lending and credit
exposures.
Assessment of trading and non
-trading portfolios.
Review of potential risks in new business
activities and
processes.
Analysis of potential risks in any complex and unusu
al
business transactions.
The financial and non-financial risks that NatWest
Group faces
are detailed in its Risk Directory
. This provides a common risk
language to ensure consistent terminology is use
d across
NatWest Group. The Risk Directory is subject
to annual review
to ensure it continues to fully ref
lect the risks that NatWest
Group faces.
Mitigation
Mitigation is a critical aspect of ensuring that risk
profile
remains within risk appetite. Risk mitigation st
rategies are
discussed and agreed within NatWest G
roup.
When evaluating possible strategies
, costs and benefits, residual
risks (risks that are retained) and secondary risks (
those that
arise from risk mitigation actions themselves) are also
considered. Monitoring and review processes are in place t
o
evaluate results. Early identification, an
d effective management
of changes in legislation and regulation are cri
tical to the
successful mitigation of compliance an
d conduct risk. The
effects of all changes are managed to ensure the timely
achievement of compliance. Those c
hanges assessed as having
a high or medium-high impact are managed mo
re closely.
Emerging risks that could affect future
results and performance
are also closely monitored. Action is taken
to mitigate potential
risks as and when required. Further in-depth an
alysis, including
the stress testing of exposures, is
also carried out.
Testing and monitoring
Targeted risk processes and controls – including con
trols within
the scope of Section 404 of the Sarbanes-Oxley Act 200
2 – are
subject to independent testing and moni
toring.
This activity is carried out to confirm to both internal
and
external stakeholders – including the Board, senior
management, the customer-facing franchises, Intern
al Audit and
NatWest Group’s regulators – that such processes
and controls
are being correctly implemented and operate adequ
ately and
effectively. A consistent testing
and monitoring methodology is
in place across NatWest Group.
Testing and monitoring activity f
ocuses on processes and
controls relating to credit risk, f
inancial crime risk, operational
resilience, and compliance and conduct
risk. However, a range
of controls and processes relating to othe
r risk types is also
subject to testing and monitoring activity as
deemed appropriate
within the context of a robust control environment.
The Risk Testing & Monitoring Forum assesses
and validates the
annual plan as well as the ongoing prog
ramme of reviews.
Stress testing
Stress testing – capital management
Stress testing is a key risk managemen
t tool and a fundamental
component of NatWest Group’s approach to c
apital
management. It is used to quan
tify and evaluate the potential
impact of specified changes to risk factors on the fina
ncial
strength of NatWest Group, including its capital position.
Stress testing includes:
Scenario testing, which examines
the impact of a
hypothetical future state to define changes in risk f
actors.
Sensitivity testing, which exami
nes the impact of an
incremental change to one or more risk factors.
The process for stress testing consists of four bro
ad stages:
Define
scenarios
Identify macro and NatWest Group
specific vulnerabilities and risks.
Define and calibrate scenarios to
examine risks and vulnerabilitie
s.
Formal governance process to
agree
scenarios.
Assess
impact
Translate scenarios into risk drivers.
Assess impact to current and projected
P&L and balance sheet across NatWest
Group.
Calculate
results and
assess
implications
Aggregate impacts into overall results.
Results form part of the risk
management process.
Scenario results are used to inf
orm
business and capital plans.
Develop and
agree
management
actions
Scenario results are analysed by
subject matter experts. Appropria
te
management actions are then
developed.
Scenario results and manageme
nt
actions are reviewed by the relevant
Executive Risk Committees and B
oard
Risk Committees and agreed by the
relevant
Boards.
Stress testing is used widely across NatWest Grou
p. The
diagram below summarises key areas of focus.
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Financial review
Risk management framework
continu
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Specific areas that involve capi
tal management include:
Strategic financial and capital planning
– by asse
ssing the
impact of sensitivities and scenarios on the capital pl
an and
capital ratios.
Risk appetite
– by gaining a better understanding of t
he
drivers of, and the underlying risks
associated with, risk
appetite.
Risk monitoring
– by monitoring the risks a
nd horizon
scanning events that could potentially affect NatWest
Group’s financial strength and capital posi
tion.
Risk mitigation
– by identifying actions to
mitigate risks, or
those that could be taken, in the e
vent of adverse changes
to the business or economic environment. Key
risk
mitigating actions are documented in NatWest Gr
oup’s
recovery plan.
Reverse stress testing is also ca
rried out in order to identify
circumstances that may lead to
specific, defined outcomes such
as business failure. Reverse stres
s testing allows potential
vulnerabilities in the business model to be exami
ned more fully.
Capital sufficiency – going concern forward-looking view
Going concern capital requireme
nts are examined on a
forward-looking basis – including as part of t
he annual
budgeting process – by assessing the resilience
of capital
adequacy and leverage ratios under hypothe
tical future states.
These assessments include assumptions about regula
tory and
accounting factors (such as IFRS 9). The
y incorporate
economic variables and key ass
umptions on balance sheet and
P&L drivers, such as impairmen
ts, to demonstrate that NatWest
Group and its operating subsidiaries main
tain sufficient capital.
A range of future states are tested. In pa
rticular, capital
requirements are assessed:
Based on a forecast of future busines
s performance, given
expectations of economic and market conditio
ns over the
forecast period.
Based on a forecast of future busines
s performance under
adverse economic and market conditions over
the forecast
period. Scenarios of different severity may be exa
mined.
The potential impact of normal and
adverse economic and
market conditions on capital requirements is asse
ssed through
stress testing, the results of which are not only us
ed widely
across NatWest Group but also by the regulators to se
t specific
capital buffers. NatWest Group takes part in st
ress tests run by
regulatory authorities to test industry-wide vulne
rabilities under
crystallising global and domestic sy
stemic risks.
Stress and peak-to-trough mov
ements are used to help assess
the amount of capital NatWest Group nee
ds to hold in stress
conditions in accordance with the capital risk appe
tite
framework.
Internal assessment of capital adequacy
An internal assessment of material risks is c
arried out annually
to enable an evaluation of the
amount, type and distribution of
capital required to cover these risks. T
his is referred to as the
Internal Capital Adequacy Assess
ment Process (ICAAP). The
ICAAP consists of a point-in-time assess
ment of exposures and
risks at the end of the financial y
ear together with a forward-
looking stress capital assessment. The ICAAP is a
pproved by
the Board and submitted to the PRA.
The ICAAP is used to form a vie
w of capital adequacy
separately to the minimum regulatory requiremen
ts. The ICAAP
is used by the PRA to assess NatWest Group’s specific
capital
requirements through the Pillar 2 f
ramework.
Capital allocation
NatWest Group has mechanisms to allocate capital ac
ross its
legal entities and businesses. These aim to optimise the use of
capital resources taking into account applicable regul
atory
requirements, strategic and business objec
tives and risk
appetite. The framework for allocating ca
pital is approved by
the CFO with support from the Asse
t & Liability Management
Committee.
Governance
Capital management is subject to substantial
review and
governance. The Board approves the capital pl
ans, including
those for key legal entities and busines
ses as well as the results
of the stress tests relating to those
capital plans.
Stress testing – liquidity
Liquidity risk monitoring and contingency planning
A suite of tools is used to monitor, limit and st
ress test the risks
on the balance sheet. Limit frameworks are in place t
o control
the level of liquidity risk, asset and liability mism
atches and
funding concentrations. Liquidity
risks are reviewed at
significant legal entity and business
levels daily, with
performance reported to the A
sset & Liability Management
Committee on a regular basis. Liquidity Con
dition Indicators are
monitored daily. This ensures any build-up of s
tress is detected
early and the response escalate
d appropriately through
recovery planning.
Internal assessment of liquidity
Under the liquidity risk management fra
mework, NatWest
Group maintains the Internal Liquidity Adequ
acy Assessment
Process. This includes assessme
nt of net stressed liquidity
outflows under a range of severe but plausible stress
scenarios.
Each scenario evaluates either an idiosyncratic, marke
t-wide or
combined stress event as described in the table bel
ow.
Type
Description
Idiosyncratic
scenario
The market perceives NatWest Group to be
suffering from a severe stress event, which
results in an immediate assump
tion of
increased credit risk or concerns over
solvency.
Market-wide
scenario
A market stress event affecting
all
participants in a market through contagion,
potential counterparty failure and other
market risks. NatWest Group is affe
cted under
this scenario but no more severely than any
other participants with equivalent exposure.
Combined
scenario
This scenario models the combined impact of
an idiosyncratic and market str
ess occurring
at once, severely affecting funding markets
and the liquidity of some assets.
NatWest Group uses the most severe outco
me to set the
internal stress testing scenario
which underpins its internal
liquidity risk appetite. This complements the regulatory liquidi
ty
coverage ratio requirement.
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ed
Stress testing – recovery and resolution plan
ning
The NatWest Group recovery plan explains ho
w NatWest Group
and its subsidiaries – as a consolidated g
roup – would identify
and respond to a financial stress event and restore its fin
ancial
position so that it remains viable on an ongoing b
asis.
The recovery plan ensures risks that could del
ay the
implementation of a recovery strategy are highligh
ted and
preparations are made to minimise the impac
t of these risks.
Preparations include:
Developing a series of recovery indica
tors to provide early
warning of potential stress eve
nts.
Clarifying roles, responsibilities and escal
ation routes to
minimise uncertainty or delay.
Developing a recovery playbook to provide a concise
description of the actions required during recovery.
Detailing a range of options to address diff
erent stress
conditions.
Appointing dedicated option owners to reduce the risk of
delay and capacity concerns.
The plan is intended to enable NatWest G
roup to maintain
critical services and products it provides to i
ts customers,
maintain its core business lines and operate wi
thin risk appetite
while restoring NatWest Group’
s financial condition. It is
assessed for appropriateness on an ongoin
g basis and is
updated annually. The plan is reviewed and ap
proved by the
Board prior to submission to the PRA each ye
ar. Individual
recovery plans are also prepared for NatWest Holdin
gs Limited,
NatWest Markets Plc, RBS International (Holdi
ngs) Limited,
Ulster Bank Ireland DAC and NatWest Ma
rkets N.V.. These
plans detail the recovery options, recovery indic
ators and
escalation routes for each entity.
Fire drill simulations of possible recovery even
ts are used to
test the effectiveness of NatWest Group and individu
al legal
entity recovery plans. The fire drills are designed to
replicate
possible financial stress conditions and allow seni
or
management to rehearse the res
ponses and decisions that may
be required in an actual stress event. The results a
nd lessons
learnt from the fire drills are use
d to enhance NatWest Group’s
approach to recovery planning.
Under the resolution assessment part of the
PRA rulebook,
NatWest Group is required to carry out an assess
ment of its
preparations for resolution, sub
mit a report of the assessment
to the PRA and publish a summary of this repo
rt.
Resolution would be implement
ed if NatWest Group was
assessed by the UK authorities to have failed a
nd the
appropriate regulator put it into resolution. T
he process of
resolution is owned and implemented by the B
ank of England
(as the UK resolution authority). A multi-year program
me is in
place to further develop resolution capability in line wit
h
regulatory requirements.
Stress testing – market risk
Non-traded market risk
Non-traded exposures are reported to the PRA on
a quarterly
basis. This provides the regulator with an ove
rview of NatWest
Group’s banking book interest rate exposu
re. The report
includes detailed product information analysed by in
terest rate
driver and other characteristics, including
accounting
classification, currency and counterparty type.
Scenario analysis based on hypothetic
al adverse scenarios is
performed on non-traded exposures as part of
the Bank of
England and European Banking
Authority stress test exercises.
NatWest Group also produces an in
ternal scenario analysis as
part of its financial planning cycles
.
Non-traded exposures are capitalised through
the ICAAP. This
covers gap risk, basis risk, credit spread risk, pipeline risk,
structural foreign exchange risk, prepayment risk, e
quity risk
and accounting volatility risk. The ICAA
P is completed with a
combination of value and earni
ngs measures. The total non-
traded market risk capital requirement is
determined by adding
the different charges for each sub risk type. The ICAAP
methodology captures at least ten years of his
torical volatility,
produced with a 99% confidence
level. Methodologies are
reviewed by NatWest Group Model Risk and the
results are
approved by the NatWest Group T
echnical Asset & Liability
Management Committee.
Non-traded market risk stress res
ults are combined with those
for other risks into the capital plan p
resented to the Board. The
cross-risk capital planning proce
ss is conducted once a year,
with a planning horizon of five
years. The scenario narratives
cover both regulatory scenarios and macroecono
mic scenarios
identified by NatWest Group.
Vulnerability-based stress testing begins
with the analysis of a
portfolio and expresses its key vulnerabilities in
terms of
plausible, vulnerability scenarios
under which the portfolio
would suffer material losses. These
scenarios can be historical,
macroeconomic or forward-looking/hypothetical. Vulner
ability-
based stress testing is used for internal man
agement
information and is not subject to limits. The resul
t
s for relevant
scenarios are reported to senio
r management.
Traded market risk
NatWest Group carries out regul
ar market risk stress testing to
identify vulnerabilities and potential losses in excess
of, or not
captured in, value-at-risk. The calculated stresses measu
re the
impact of changes in risk factors on the fai
r values of the
trading portfolios.
NatWest Group conducts histor
ical, macroeconomic and
vulnerability-based stress testing. Historical s
tress testing is a
measure that is used for intern
al management. Using the
historical simulation framework e
mployed for value-at-risk, the
current portfolio is stressed usi
ng historical data since 1
January 2005. This methodology
simulates the impact of the
99.9 percentile loss that would be incur
red by historical risk
factor movements over the period, assuming variable hol
ding
periods specific to the risk factors and the busine
sses.
Risk and capital m
anageme
nt continued
NatWest Group
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Strategic report
Governance
Risk and capital management
Additional information
Financial review
Risk management framework
continu
ed
Historical stress tests form part of the m
arket risk limit
framework and their results are reported re
gularly to senior
management. Macroeconomic stress tests are ca
rried out
periodically as part of the bank-wide, cross-risk ca
pital
planning process. The scenario narratives are tra
nslated into
risk factor shocks using historical events a
nd insights by
economists, risk managers and the first line.
Market risk stress results are combined wit
h those for other
risks into the capital plan presented to the Boa
rd. The cross-
risk capital planning process is
conducted once a year, with a
planning horizon of five years. The sc
enario narratives cover
both regulatory scenarios and
macroeconomic scenarios
identified by NatWest Group.
Vulnerability-based stress testing begins
with the analysis of a
portfolio and expresses its key vulnerabilities in
terms of
plausible, vulnerability scenarios
under which the portfolio
would suffer material losses. These
scenarios can be historical,
macroeconomic or forward-looking/hypothetical. Vulner
ability-
based stress testing is used for internal man
agement
information and is not subject to limits. The resul
t
s for relevant
scenarios are reported to senio
r management.
Internal scenarios
During 2021, NatWest Group continuously
refined and reviewed
a series of internal scenarios – benchmarked against
the Bank
of England’s illustrative scenario – as the imp
act of COVID-19
evolved, including actual and potential ef
fects on economic
fundamentals. These scenarios
included:
The impact of travel restrictions, social distancing policie
s,
self-isolation and sickness on GDP, employmen
t and
consumer spending.
The impacts on business investment in critical secto
rs.
The effect on house prices, commercial real estate values
and major project finance.
The effect of government interventions such
as the Job
Retention Scheme and the Coronavirus Busines
s
Interruption Loan Scheme.
Applying the macro-scenarios to NatWes
t Group’s earnings,
capital, liquidity and funding positions did not result in
a breach
of any regulatory thresholds.
Internal scenarios were also used to assess the p
otential
impacts of severe weather events on NatWes
t Group’s
operations in the UK and India.
Regulatory stress testing
In 2021, NatWest Group participated in the
regulatory stress tests conducted by the Bank of
England following their suspension in
2020 as a result of COVID-19. The s
cenario was hypothetical in nature and does not represent a fo
recast of NatWest Group’s
future business or profitability. T
he results of regulatory stress tests are carefully asse
ssed and form part of the wider risk
management of NatWest Group. Follo
wing the UK’s exit from the European Union on 31 Dec
em
ber 2020, only relevant European
subsidiaries of NatWest Group will take part in
the European Banking Authority stress tes
ts going forward. NatWest Group itself will
not participate.
NatWest Group also took part in the Bank of England’s
Climate Biennial Exploratory Scenario (CB
ES). This exercise was designed
to assess the resilience of the largest UK banks and insu
rers to the physical and transition ris
ks associated with climate change.
The CBES used three 30-year scenarios to explore t
he risks – Early Action (in which the trans
ition to a net-zero emissions economy
gets underway with carbon taxes and associ
ated policies intensifying gradually), Late Action (i
n which the transition is delayed
until 2031, with a sudden increase
in the intensity of carbon taxes and cli
mate policy leading to a recession) and No Addition
al
Action (in which no new climat
e policies are introduced and the
physical impacts of climate change are most severe). The B
ank of
England is expected to publish aggregate findings in 20
22 though, given the exploratory natu
re of the exercise, it will not use
CBES
to set capital requirements.
Bank of England
stress test
Scenario
Designed to assess the resilience
of major UK banks to reasonable worst-case stress in
the current
environment. The severity of the test is related to policym
akers’ assessments of risk levels ac
ross
markets and regions.
The 2021 stress test assess
ed the impact of a severe economic path from 2021 to 2025
on top of the
economic shocks arising from the pandemic. The s
cenario implied a cumulative th
ree-year loss of 37%
of 2019 UK GDP and 31% of 201
9 global GDP with the UK’s trading partners expe
riencing severe and
synchronised slowdowns, a decline in equity p
rices and a rise in bond spreads. The sce
nario also
included a 33% fall in UK residential
property prices and a rise in UK unemploymen
t of 5.6 percentage
points to peak at 11.9%.
The stress was based on an end-of-202
0 balance sheet starting position.
Results
Under the 2021 Bank of England solvency s
tress test, on an IFRS 9 transitional basis, the
CET1 ratio
reached a low point of 10.4%. This was above the
reference rate of 7%.
Tier 1 leverage ratio was projected to be 4.4
% under stress. This was above the reference r
ate of 3.6%
On an IFRS 9 non-transitional basis, the CET1 ratio reac
hed a low point of 10.3%. This was above the
reference rate of 7%. Tier 1 leve
rage ratio was projected to be 4.4% under s
tress. This was above the
reference rate of 3.6%
What does this
mean?
The 2021 Bank of England solve
ncy stress result demonstrated that the b
alance sheet continues to be
robust with a strong capital position.
Risk and capital m
anageme
nt continued
NatWest Group
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Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk
Definition
(audited)
Credit risk is the risk that custo
mers and counterparties fail to
meet their contractual obligatio
n to settle outstanding amounts.
Sources of risk
(audited)
The principal sources of credit risk for NatWest
Group are
lending, off-balance sheet products, derivati
ves and securities
financing, and debt securities. NatWest G
roup is also exposed
to settlement risk through foreign exchange, t
rade finance and
payments activities.
Key developments in 2021
The outlook for credit risk and asset quali
ty improved
during 2021 with the economic recovery from
the disruption
caused by COVID-19 being faster than initially forec
ast.
The overall expected credit loss (ECL) decre
ased materially
as a result, with lower than expe
cted defaults and
exposures moving from Stage 2 into Stage 1. S
tage 3 ECL
charges remained low, reflecting the effe
ct of government
support schemes mitigating against defaul
ts.
In Personal, lending criteria and underwri
ting standards,
which had been tightened during 20
20 in response to
COVID-19, were selectively relaxed as economic co
nditions
improved and portfolio performance stabilis
ed following the
conclusion of payment holidays.
In Wholesale, sector specific risk appetite continued t
o be
closely monitored and appropriately adjus
ted during the
year for those sectors most aff
ected by COVID-19. As in
Personal, a selective relaxation
of lending criteria and
underwriting standards was poss
ible as economic
conditions improved and portfolio performance sta
bilised.
NatWest Group continued to progress embed
ding climate
change considerations in credit asse
ssment and monitoring,
including scenario analysis to asse
ss the materiality of
climate change risks. For further information
refer to the
2021 Climate-related disclosures report.
Governance
(audited)
The Credit Risk function provid
es oversight and challenge of
frontline credit risk management activities.
Governance activities include:
Defining credit risk appetite me
asures for the management
of concentration risk and credit
policy to establish the key
causes of risk in the process of
providing credit and the
controls that must be in place to mitiga
te them.
Approving and monitoring operational limits for busine
ss
segments and credit limits for c
ustomers.
Oversight of the first line of defence to ensure that credi
t
risk remains within the appetite
set by the Board and that
controls are being operated ade
quately and effectively.
Assessing the adequacy of ECL provisions i
ncluding
approving key IFRS 9 inputs (su
ch as significant increase in
credit risk (SICR) thresholds) an
d any necessary in-model
and post model adjustments through Nat
West Group and
business unit provisions and model com
mittees.
Development and approval of credit gr
ading models.
Risk appetite
Credit risk appetite aligns to th
e strategic risk appetite set by
the Board and is set and monit
ored through risk appetite
frameworks tailored to NatWes
t Group’s Personal and
Wholesale segments.
Personal
The Personal credit risk appetite
framework sets limits that
control the quality and concentration of both e
xisting and new
business for each relevant busines
s segment.
These risk appetite measures consider the se
gments’ ability to
grow sustainably and the level of losses
expected under stress.
Credit risk is further controlled through o
perational limits
specific to customer or product characteristics.
Wholesale
For Wholesale credit, the framework has been desi
gned to
reflect factors that influence the
ability to operate within risk
appetite. Tools such as stress te
sting and economic capital are
used to measure credit risk volatility
and develop links between
the framework and risk appetite limits.
Four formal frameworks are use
d, classifying, measuring and
monitoring credit risk exposure across single na
me, sector and
country concentrations and product and asset cl
asses with
heightened risk characteristics.
The framework is supported by a suite of t
ransactional
acceptance standards that set out the risk par
ameters within
which businesses should operate
.
Credit policy standards are in p
lace for both the Wholesale and
Personal portfolios. They are expressed as a set of m
andatory
controls.
Identification and measuremen
t
Credit stewardship
(audited)
Risks are identified through relationship man
agement and
credit stewardship of customers
and portfolios. Credit risk
stewardship takes place throughout the custo
mer relationship,
beginning with the initial approval. It includes the ap
plication of
credit assessment standards, c
redit risk mitigation and
collateral, ensuring that credit documen
tation is complete and
appropriate, carrying out regular portfolio o
r customer reviews
and problem debt identification and ma
nagement.
Asset quality
(audited)
All credit grades map to an ass
et quality (AQ) scale, used for
financial reporting. This AQ scale is based on Basel p
robability
of defaults. Performing loans are de
fined as AQ1-AQ9 (where
the probability of default (PD) is less
than 100%) and defaulted
non-performing loans as AQ10 or Stage 3 under IFRS 9 (
where
the PD is 100%). Loans are defined as defaul
ted when the
payment status becomes 90 day
s past due, or earlier if there is
clear evidence that the borrower is unlikely to repay, for
example bankruptcy or insolvency
.
Counterparty credit risk
Counterparty credit risk arises from the obli
gations of
customers under derivative and secu
rities financing
transactions.
NatWest Group mitigates counte
rparty credit risk through
collateralisation and netting agreements, w
hich allow amounts
owed by NatWest Group to a counterparty to be net
ted against
amounts the counterparty owe
s NatWest Group.
Mitigation
Mitigation techniques, as set out in the ap
propriate credit
policies and transactional acceptance s
tandards, are used in
the management of credit portfolios across N
atWest Group.
These techniques mitigate credit concent
rations in relation to
an individual customer, a borrower group or a collec
tion of
related borrowers. Where possible, cus
tomer credit balances
are netted against obligations. Mitigation tools c
an include
structuring a security interest in a physical
or financial asset,
the use of credit derivatives including credit default sw
aps,
credit-linked debt instruments and securi
tisation structures, and
the use of guarantees and similar ins
truments (for example,
credit insurance) from related and third parties
.
Risk and capital m
anageme
nt continued
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Risk and capital management
Additional information
Financial review
Credit risk continued
Property is used to mitigate credit risk across
a number of
portfolios, in particular residential mortga
ge lending and
commercial real estate (CRE).
The valuation methodologies for collater
al in the form of
residential mortgage property and CRE are detailed below.
Residential mortgages
NatWest Group takes colla
teral in the
form of residential property to mitigate the credit risk
arising
from mortgages. NatWest Grou
p values residential property
individually during the loan underwriting proce
ss, either by
obtaining an appraisal by a suitably qualified
appraiser (for
example, Royal Institution of Chartered Surveyo
rs (RICS)) or
using a statistically valid model.
In both cases,
a sample of the
valuation outputs are periodically reviewed by an
independent
RICS qualified appraiser. NatWest Group updates
residential
property values quarterly using the relevant
residential
property index namely:
Region
Index used
UK (including
Northern Ireland)
Office for National Statistics House
Price Index
Republic of Ireland
Central Statistics Office Re
sidential
Property Price Index
The current indexed value of th
e property is a component of
the ECL provisioning calculation.
Commercial real estate valuations
– NatWest Group has
an
actively managed panel of chartered survey
ing firms that cover
the spectrum of geography and property sectors in w
hich
NatWest Group takes collateral
. Suitable RICS registered
valuers for particular assets are
typically contracted through a
service agreement to ensure consistency of quality
and advice.
Valuations are generally commiss
ioned when an asset is taken
as security; a material increase in a facility is reques
ted; or a
default event is anticipated or has occur
red. In the UK, an
independent third-party market indexation is
applied to update
external valuations once they are mo
re than a year old and
every three years, a formal independent valuation
review is
commissioned. In the Republic of Ireland, assets are
revalued in
line with the Central Bank of Ire
land threshold requirements,
which permits indexation for lower value residential assets, bu
t
demands regular valuations for higher value assets.
Assessment and monitoring
Practices for credit stewardship – including cre
dit assessment,
approval and monitoring as well as the identification a
nd
management of problem debts
– differ between the Personal
and Wholesale portfolios.
Personal
Personal customers are served through a lendin
g approach
that entails offering a large number of small-value lo
ans. To
ensure that these lending decisions are ma
de consistently,
NatWest Group analyses internal credi
t information as well as
external data supplied by credit reference a
gencies (including
historical debt servicing behaviour of custo
mers with respect to
both NatWest Group and other le
nders). NatWest Group then
sets its lending rules accordingl
y, developing different rules for
different products.
The process is then largely automated, wi
th each customer
receiving an individual credit score that reflects bo
th internal
and external behaviours and th
is score is compared with the
lending rules set. For relatively high-value, com
plex personal
loans, including some residential mortgage lending, s
pecialist
credit managers make the final lending decisions. These
decisions are made within spec
ified delegated authority limits
that are issued dependent on the
experience of the individual.
Underwriting standards and portfolio performance a
re
monitored on an ongoing basis to ensure the
y remain adequate
in the current market environment and are not weakened
materially to sustain growth. The
actual performance of each
portfolio is tracked relative to o
perational limits. The limits
apply to a range of credit risk-rel
ated measures including
projected credit default rates across products
and the loan-to-
value (LTV) ratio of the mortgage portfolios. Whe
re operational
limits identify areas of concern management action is
taken to
adjust credit or business strategy
.
Wholesale
Wholesale customers – including corporates, b
anks and other
financial institutions – are grouped by industry secto
rs and
geography as well as by product/asset class and
are managed
on an individual basis. Customers are aggregated
as a single
risk when sufficiently interconnected.
A credit assessment is carried out before credit facilities
are
made available to customers. The
assessment process is
dependent on the complexity of the t
ransaction. Credit
approvals are subject to environmental, social
and governance
risk policies which restrict expos
ure to certain highly carbon
intensive industries as well as those with poten
tially heightened
reputational impacts. Customer specif
ic climate risk
commentary is now mandatory
.
In response to COVID-19, a new framework was int
roduced to
categorise clients in a consistent manne
r across the Wholesale
portfolio, based on the effect of CO
VID-19 on their financial
position and outlook in relation
to the sector risk appetite. This
framework has been retained and updated to co
nsider viability
impacts beyond those directly related to COVID-19
and
classification via the framework is
now mandatory and must be
refreshed annually. The framework extends t
o all Wholesale
borrowing customers and supple
ments the Risk of Credit Loss
framework in assessing whethe
r customers exhibit a SICR, if
support is considered to be granting forbe
arance and the time
it would take for customers to return to ope
rating within
transactional acceptance standards. Tailored appro
aches were
also introduced for business banking, co
mmercial real estate
and financial institution customers.
For lower risk transactions below spec
ific thresholds, credit
decisions can be approved through self
-sanctioning within the
business. This process is facilitated through an au
to-decision
making system, which utilises s
corecards, strategies and policy
rules. Such credit decisions mus
t be within the approval
authority of the relevant busine
ss approver.
For all other transactions, credit is only g
ranted to customers
following joint approval by an approver f
rom the business and
the credit risk function or by two credit of
ficers. The joint
business and credit approvers act wi
thin a delegated approval
authority under the Wholesale Credit Authorities F
ramework
Policy. The level of delegated a
uthority held by approvers is
dependent on their experience
and expertise with only a small
number of senior executives holding the highest
approval
authority. Both business and credit approvers are acc
ountable
for the quality of each decision taken, although
the credit risk
approver holds ultimate sanctioning authority.
Transactional acceptance standards provide de
tailed
transactional lending and risk a
cceptance metrics and
structuring guidance. As such, these
standards provide a
mechanism to manage risk appetite at the
customer/transaction level and are supplementary
to the
established credit risk appetite.
Risk and capital m
anageme
nt continued
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Risk and capital management
Additional information
Financial review
Credit risk continued
Credit grades (PD) and loss give
n default (LGD) are reviewed
and if appropriate reapproved annually. The
review process
assesses borrower performance, including reconfir
mation or
adjustment of risk parameter estimates; the adequacy of
security; compliance with terms and conditions; and refin
ancing
risk.
Problem debt management
Personal
Early problem identification
Pre-emptive triggers are in place to help iden
tify customers
that may be at risk of being in financial diff
iculty. These triggers
are both internal, using NatWes
t Group data, and external
using information from credit ref
erence agencies. Proactive
contact is then made with the customer to establish if t
hey
require help with managing their finances. By
adopting this
approach, the aim is to prevent a customer’s financial p
osition
deteriorating which may then require intervention fro
m the
Collections and Recoveries teams.
Personal customers experienci
ng financial difficulty are
managed by the Collections team. If the Collec
tions team is
unable to provide appropriate s
upport after discussing suitable
options with the customer, managemen
t of that customer
moves to the Recoveries team.
If at any point in the collections
and recoveries process, the custome
r is identified as being
potentially vulnerable, the customer will be se
parated from the
regular process and supported by a specialist tea
m to ensure
the customer receives appropriate suppor
t for their
circumstances.
Collections
When a customer exceeds an agreed limi
t or misses a regular
monthly payment the customer is contacted by Na
tWest Group
and requested to remedy the position. If the situ
ation is not
regularised then, where approp
riate, the Collections team will
become more involved and the
customer will be supported by
skilled debt management staff who endeavour to
provide
customers with bespoke solutions. Solutions include s
hort-term
account restructuring, refinance loans and forbearance w
hich
can include interest suspension
and ‘breathing space’. In the
event that an affordable/sustainable agreement wi
th a
customer cannot be reached, the debt will transiti
on to the
Recoveries team. For provisioning pu
rposes, under IFRS 9,
exposure to customers managed by the Collecti
ons team is
categorised as Stage 2 and sub
ject to a lifetime loss
assessment, unless it is 90 days past due
or has an interest
non-accrual status, in which case it is categorised as S
tage 3.
In the Republic of Ireland, the re
lationship may pass to a
specialist support team prior to any transfer to
recoveries,
depending on the outcome of c
ustomer financial assessment.
Recoveries
The Recoveries team will issue a notice of intenti
on to default to
the customer and, if appropriate
, a formal demand, while also
registering the account with cr
edit reference agencies where
appropriate. Following this, the c
ustomer’s debt may then be
placed with a third-party debt collec
tion agency, or
alternatively a solicitor, in order to agree an aff
ordable
repayment plan with the customer. An option that
may also be
considered, is the sale of unsecured debt. Exposu
res subject to
formal debt recovery are defaul
ted and, under IFRS 9,
categorised as Stage 3.
Wholesale
Early problem identification
Each segment and sector have defined early w
arning indicators
to identify customers experiencing financial difficulty, a
nd to
increase monitoring if needed. Ea
rly warning indicators may be
internal, such as a customer’s bank account activity, o
r
external, such as a publicly-liste
d customer’s share price. If
early warning indicators show a custo
mer is experiencing
potential or actual difficulty, or if relationship
managers or
credit officers identify other signs of f
inancial difficulty, they
may decide to classify the customer within the Risk of C
r
edit
Loss framework.
Risk of Credit Loss framework
The framework focuses on Wholesale customers whose credi
t
profiles have deteriorated materially since origin
ation. Expert
judgment is applied by experience
d credit risk officers to
classify cases into categories that
reflect progressively
deteriorating credit risk to Nat
West Group. There are two
classifications in the framework that apply to non-
defaulted
customers – Heightened Monitoring and Risk of C
redit Loss. For
the purposes of provisioning, all exposures subject
to the
framework are categorised as Stage 2 and subjec
t to a lifetime
loss assessment. The framewor
k also applies to those
customers that have met NatWes
t Group’s default criteria
(AQ10 exposures). Defaulted exposures are ca
tegorised as
Stage 3 impaired for provisioni
ng purposes.
Heightened Monitoring customers are perfor
ming customers
that have met certain characteristics, which ha
ve led to
significant credit deterioration. C
ollectively, characteristics
reflect circumstances that may
affect the customer’s ability to
meet repayment obligations. Characte
ristics include trading
issues, covenant breaches, mate
rial PD downgrades and past
due facilities.
Heightened Monitoring customers require pre-e
mptive actions
(outside the customer’s normal trading patte
rns) to return or
maintain their facilities within NatWest Group’s cu
rrent risk
appetite prior to maturity.
Risk of Credit Loss customers a
re performing customers that
have met the criteria for Heighte
ned Monitoring and also pose
a risk of credit loss to NatWest Group in the next 12
months
should mitigating action not be taken or not be succ
essful.
Once classified as either Heightened Monitoring o
r Risk of
Credit Loss, a number of mandatory actions a
re taken in
accordance with policies. Actions include
a review of the
customer’s credit grade, facility
and security documentation
and the valuation of security. De
pending on the severity of the
financial difficulty and the size of the exposu
re, the customer
relationship strategy is reassesse
d by credit officers, by
specialist credit risk or relationship m
anagement units in the
relevant business, or by Restructuring.
Agreed customer management strategies a
re regularly
monitored by both the business and credit tea
ms. The largest
Risk of Credit Loss exposures are regularly re
viewed by a Risk
of Credit Loss forum. The forum members are expe
rienced
credit, business and restructuring specialists. The pu
rpose of
the forum is to review and challe
nge the strategies undertaken
for customers that pose the largest risk of credit loss t
o
NatWest Group.
Risk and capital m
anageme
nt continued
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Credit risk continued
Appropriate corrective action is taken whe
n circumstances
emerge that may affect the custome
r’s ability to service its debt
(refer to Heightened Monitoring characteristics). Co
rrective
actions may include granting a c
ustomer various types of
concessions. Any decision to approve a concess
ion will be a
function of specific appetite, the c
redit quality of the customer,
the market environment and the
loan structure and security. All
customers granted forbearance are classifie
d Heightened
Monitoring as a minimum.
Other potential outcomes of the
relationship review are to:
remove the customer from the Risk
of Credit Loss framework,
offer additional lending and continue monitorin
g, transfer the
relationship to Restructuring if appropriate, or e
xit the
relationship.
The Risk of Credit Loss framework does not apply t
o problem
debt management for business banking customers. Thes
e
customers are, where necessary, managed by speci
alist
problem debt management tea
ms, depending on the size of
exposure or by the business banking recoveries tea
m where a
loan has been impaired.
Restructuring
Where customers are categoris
ed as Risk of Credit Loss and
the lending exposure is above £1 million, relationships a
re
supported by the Restructuring team. The o
bjective of
Restructuring is to protect NatWes
t Group’s capital.
Restructuring does this by working with corpo
rate and
commercial customers in financial difficulty to hel
p them
understand their options and how their restructu
ring or
repayment strategies can be de
livered. Helping the customer
return to financial health and re
storing a normal banking
relationship is always the preferred outco
me, however, where a
solvent outcome is not possible, insolvency may
be considered
as a last resort.
Restructuring will always aim to recover capital fai
rly and
efficiently. Throughout Restructuring’s involvemen
t, the
mainstream relationship manager will remain a
n integral part
of the customer relationship. Restructuring’s work
helps
NatWest Group remain safe and sustainable, contributin
g to its
ability to champion potential.
Forbearance
(audited)
Forbearance takes place when a conces
sion is made on the
contractual terms of a loan/debt in response to
a customer’s
financial difficulties.
The aim of forbearance is to support and resto
re the customer
to financial health while minimising risk. To ensure t
hat
forbearance is appropriate for the
needs of the customer,
minimum standards are applied when asses
sing, recording,
monitoring and reporting forbearance.
A credit exposure may be forborne more tha
n once, generally
where a temporary concession has been granted
and
circumstances warrant another temporary o
r permanent
revision of the loan’s terms.
Loans are reported as forborne u
ntil they meet the exit criteria
as detailed in the appropriate r
egulatory guidance. These
include being classified as performing fo
r two years since the
last forbearance event, making regular repaymen
ts and the
loan/debt being less than 30 day
s past due.
Types of forbearance
Personal
In the Personal portfolio, forbearance
may involve payment
concessions and loan rescheduli
ng (including extensions in
contractual maturity), capitalisation of a
rrears and, in the
Republic of Ireland only, temporary inte
rest-only or partial
capital and interest arrangements. Forbear
ance support is
provided for both mortgages and unsecured lendi
ng.
Wholesale
In the Wholesale portfolio, forbe
arance may involve covenant
waivers, amendments to margi
ns, payment concessions and
loan rescheduling (including extensions in contrac
tual maturity),
capitalisation of arrears, and de
bt forgiveness or debt-for-
equity swaps.
Monitoring of forbearance
Personal
For Personal portfolios, forborne loans are separate
d and
regularly monitored and reported while the fo
rbearance
strategy is implemented, until they
exit forbearance.
Wholesale
In the Wholesale portfolio, customer PDs
and facility LGDs are
reassessed prior to finalising any f
orbearance arrangement.
The ultimate outcome of a forbearance str
ategy is highly
dependent on the co-operation of the bo
rrower and a viable
business or repayment outcome. Where forbe
arance is no
longer appropriate, NatWest Group will consider o
ther options
such as the enforcement of security, insol
vency proceedings or
both, although these are options of
last resort.
Provisioning requirements on f
orbearance are detailed in the
Provisioning for forbearance sec
tion.
Credit grading models
Credit grading models is the colle
ctive term used to describe all
models, frameworks and methodologies used to c
alculate PD,
exposure at default (EAD), LGD
, maturity and the production of
credit grades.
Credit grading models are designed to provide:
An assessment of customer and transaction characteristics.
A meaningful differentiation of credit risk.
Accurate internal default rate, loss and exposure estimates
that are used in the capital calc
ulation or wider risk
management purposes.
Impairment, provisioning and write-offs
(audited)
In the overall assessment of cre
dit risk, impairment provisioning
and write-offs are used as key indica
tors of credit quality.
NatWest Group’s IFRS 9 provisioning models, which use
existing
Basel models as a starting point, inco
rporate term structures
and forward-looking information. Regulatory conse
rvatism
within the Basel models has been removed as app
ropriate to
comply with the IFRS 9 requirement fo
r unbiased ECL
estimates.
Risk and capital m
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nt continued
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Credit risk continued
Five key areas may materially influence
the measurement of
credit impairment under IFRS 9 – two of these relate to
model
build and three relate to model application:
Model build:
The determination of economic indica
tors that have most
influence on credit loss for each portfolio
and the severity of
impact (this leverages existing s
tress testing models which
are reviewed annually).
The build of term structures to extend the deter
mination of
the risk of loss beyond 12 mont
hs that will influence the
impact of lifetime loss for exposures in Stage 2.
Model application:
The assessment of the SICR an
d the formation of a
framework capable of consistent application.
The determination of asset lifetimes that refl
ect behavioural
characteristics while also repre
senting management actions
and processes (using historical data and expe
rience).
The choice of forward-looking economic scenarios a
nd their
respective probability weights.
Refer to Accounting policy 11 for fur
ther details.
IFRS 9 ECL model design principles
(audited)
Modelling of ECL for IFRS 9 follows the conventio
nal approach
to divide the estimation of credit losse
s into its component parts
of PD, LGD and EAD.
To meet IFRS 9 requirements, the PD, LGD and EA
D
parameters differ from their Pillar 1 in
ternal ratings based
counterparts in the following aspects:
Unbiased – material regulatory conservatism
has been
removed from IFRS 9 parameters to produce unbiased
estimates.
Point-in-time – IFRS 9 parameters reflec
t actual economic
conditions at the reporting date instead of lo
ng-run average
or downturn conditions.
Forward-looking – IFRS 9 PD e
stimates and, where
appropriate, EAD and LGD estimates refle
ct forward-
looking economic conditions.
Lifetime measurement – IFRS 9 PD, L
GD and EAD are
provided as multi-period term structures up
to exposure
lifetimes instead of over a fixed one-ye
ar horizon.
IFRS 9 requires that at each repor
ting date, an entity shall
assess whether the credit risk on an accoun
t has increased
significantly since initial recognition. Part of this asse
ssment
requires a comparison to be made between the cur
rent lifetime
PD (i.e. the PD over the remaining life
time at the reporting
date) and the equivalent lifetime PD as de
termined at the date
of initial recognition.
For assets originated before IFRS 9 was introduced,
comparable lifetime origination PDs did no
t exist. These have
been retrospectively created using the relevan
t model inputs
applicable at initial recognition.
PD estimates
Personal models
Personal PD models use the Exogenous, Maturity and Vin
tage
(EMV) approach to model default rates. The EMV
approach
separates portfolio default risk
trends into three components:
vintage effects (quality of new busi
ness over time), maturity
effects (changes in risk relating to time on book)
and
exogenous effects (changes in
risk relating to changes in
macro-economic conditions). The EMV methodology h
as been
widely adopted across the industry because it en
ables forward-
looking economic information to be sys
tematically incorporated
into PD estimates.
Wholesale models
Wholesale PD models use a point-in-time/th
rough-the-cycle
framework to convert one-year
regulatory PDs into point-in-
time estimates that reflect economic conditions at
the reporting
date. The framework utilises cr
edit cycle indices (CCIs) for a
comprehensive set of region/industry seg
ments. Further detail
on CCIs is provided in the Economic loss d
rivers section.
One year point-in-time PDs are e
xtended to forward-looking
lifetime PDs using a conditional transition matrix
approach and
a set of econometric forecasting models.
LGD estimates
The general approach for the IFRS 9 LGD models is
to leverage
corresponding Basel LGD models with bespoke adjust
ments to
ensure estimates are unbiased and, where
relevant, forward-
looking.
Personal
Forward-looking information has only been inco
rporated for the
secured portfolios, where change
s in property prices can be
readily accommodated. Analysi
s has shown minimal impact of
economic conditions on LGDs for the othe
r Personal portfolios.
Wholesale
Forward-looking economic information is inco
rporated into
LGD estimates using the existing CCI framewo
rk. For low
default portfolios, including sovereigns and b
anks, loss data is
too scarce to substantiate estimates
that vary with economic
conditions. Consequently, for th
ese portfolios, LGD estimates
are assumed to be constant throughout the p
rojection horizon.
EAD estimates
Personal
The IFRS 9 Personal modelling approach for
EAD is dependent
on product type.
Revolving products use the existing Basel models as a
basis,
with appropriate adjustments incorpor
ating a term
structure based on time to default.
Amortising products use an amortising schedule, whe
re a
formula is used to calculate the e
xpected balance based on
remaining terms and interest r
ates.
There is no EAD model for Pers
onal loans. Instead, debt
flow (i.e. combined PD x EAD) is
modelled directly.
Analysis has indicated that there is
minimal impact on EAD
arising from changes in the economy for all Pe
rsonal portfolios
except mortgages. Therefore, f
orward-looking information is
only incorporated in the mortgage EAD model (through
forecast changes in interest rates
).
Wholesale
For Wholesale, EAD values are projected using produc
t specific
credit conversion factors (CCFs), closely f
ollowing the product
segmentation and approach of the respective B
asel model.
However, the CCFs are estimate
d over multi-year time horizons
and contain no regulatory conse
rvatism or downturn
assumptions.
No explicit forward-looking information is inco
rporated, on the
basis of analysis showing the temporal varia
tion in CCFs is
mainly attributable to changes in exposure ma
nagement
practices rather than economic conditions.
Risk and capital m
anageme
nt continued
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Credit risk continued
Governance and post model adjustm
ents
(audited)
The IFRS 9 PD, EAD and LGD models are subject to Na
tWest
Group’s model risk policy that stipulates
periodic model
monitoring, periodic re-validation and define
s approval
procedures and authorities according to mo
del materiality.
Various post model adjustments were applied whe
re
management judged they were
necessary to ensure an
adequate level of overall ECL p
rovision. All post model
adjustments were subject to formal approval throu
gh
provisioning governance, and
were categorised as follows
(business level commentary is
provided below):
Deferred model calibrations – EC
L adjustments where PD
model monitoring indicated that actual defaul
ts were below
estimated levels but where it was judged
that an implied
ECL release was not supportable
due to the influence of
government support schemes. As a consequence, any
potential ECL release was deferred and ret
ained on the
balance sheet.
Economic uncertainty – ECL adjustments primarily a
rising
from uncertainties associated with multiple economic
scenarios (also for 2020) and credit outco
mes as a result of
the effect of COVID-19 and the consequences
of
government support schemes. In both cases
, management
judged that additional ECL was required until furthe
r credit
performance data became available on the behaviou
ral and
loss consequences of COVID-19
.
Other adjustments – ECL adjustments where it w
as judged
that the modelled ECL required to be amended.
Post model adjustments will re
main a key focus area of NatWest
Group’s ongoing ECL adequacy asse
ssment process. A holistic
framework has been established including reviewi
ng a range of
economic data, external benchmark inform
ation and portfolio
performance trends, particularl
y with more observable
outcomes from the unwinding
of COVID-19 support schemes. A
key part of the assessment is also understandi
ng the current
levels of ECL coverage (portfolio by portfolio) ag
ainst pre-
COVID-19 levels, recognising changes in f
ranchise
portfolio/sector mix.
ECL post model adjustments
The table below shows ECL post model adjust
ments.
Retail Banking
Wholesale
Ulster Ban
k RoI
Mortgages
Other
Commercial
Other
Mortgages
Other
Total
2021
£m
£m
£m
£m
£m
£m
£m
Deferred model calibrations
58
97
62
2
219
Economic uncertainty
60
99
373
23
6
23
584
Other adjustments
37
2
3
156
198
Total
155
196
437
26
162
25
1,001
Of which:
-
Stage 1
9
5
13
2
4
1
34
- Stage 2
126
164
424
24
7
26
771
- Stage 3
20
27
151
(2)
196
2020
Deferred model calibrations
25
9
13
2
49
Economic uncertainty
79
79
526
18
113
63
878
Other adjustments
20
19
3
26
68
Total
124
88
558
21
139
65
995
Of which:
-
Stage 1
21
8
37
2
15
83
- Stage 2
93
78
521
19
47
65
823
- Stage 3
10
2
77
89
(1)
2021 data excludes £49 million of p
ost model adjustments (mortgages – £4 million; other – £45 million) for Ulster Bank RoI disclosed as discontinued operations.
While in aggregate the post mo
del adjustments have only seen
a modest increase since 31 December 2020
, there was an
increase on the proportion of ECL and notable shifts ac
ross and
within categories. These reflect:
Changes in profile in Ulster Bank RoI to reflect both
the
portfolio performance and the s
trategic shift to exit the
market.
A modest reduction in the judgmental uncertainty post
model adjustments in the Whole
sale portfolios, which was
directionally in line with the portfolio quality an
d some
reduction in uncertainty about recovery in affe
cted sectors
in the economy.
In the Retail Banking portfolio, t
o reflect a risk that default
levels were being unsustainably
suppressed due to the
various temporary government le
d support schemes (with
the sustainability requiring further outcome d
ata),
management effected a hold back of further modelle
d
releases judgmentally through t
he deferred model
calibrations category.
Retail Banking
– The post model
adjustment for deferred model
calibrations increased to £155
million from £34 million at 31
December 2020. This reflected manageme
nt’s continued
judgment that the implied ECL
decreases that continued to
manifest themselves through the
standard PD model monitoring
process during the year, were not fully s
upportable.
Management retained this view on the basis that u
nderlying
portfolio performance is believed to be unde
rpinned by
government support schemes and further ou
tcome data is
required on the level of default suppression.
Risk and capital m
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nt continued
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Credit risk continued
The post model adjustment for economic uncertainty
remained
elevated at £159 million. The total included an ECL uplift
of £26
million on a subset of customers
who had accessed payment
holiday support where their risk profile was identifie
d as
relatively high risk. In addition, NatWest Group continued
to
retain a holdback of a modelled ECL release of £
69 million,
again due to the delayed default emer
gence reflective of the
various customer support schemes (£15 million rel
ated to
mortgages and £54 million related to unse
cured lending). The
year end overlay position also included an ECL uplift
on buy-to-
let mortgages of £12 million to mitigate the risk of
a
disproportionate credit deterioration in challen
ging economic
circumstances.
Other judgmental overlays incre
ased due to the introduction of
a new post model adjustment of £
14 million to capture the
impact of potential cladding risk in the portfoli
o.
Commercial Banking
– The post model adjustmen
t for
economic uncertainty reduced f
rom £526 million to £373 million
during the year. It included an overlay of £328
million (£360
million across NatWest Group’s Wholesale po
rtfolio) reflecting
continued concern that the unprecedented natu
re of COVID-19
might indicate that default level may be higher in f
uture periods
above that currently expected. In addition, it refle
cted a risk
that government support schemes during CO
VID-19 could have
suppressed defaults that may materialise in futu
re periods
above expected default levels. The reduction during t
he year
was mainly due to a sustained improvement in un
derlying
credit metrics which resulted in a decrease in St
age 2 assets
and reduced levels of uncertainty around economic ou
tcome.
The post model adjustment also included an ove
rlay of £7
million in respect of elevated concerns aroun
d borrowers’
ability to refinance facilities at the end of the contractu
al term.
The post model adjustment for deferred model cali
brations on
the business banking portfolio increased to £6
2 million during
the year. This reflected manag
ement’s judgment that the
continued beneficial modelling impact, and i
mplied ECL
decrease, remained unsupportable while portfolio perfo
rmance
was being underpinned by the various suppo
rt schemes.
Other adjustments included an overlay of £2 million to
mitigate
the effect of operational timing
delays in the identification and
flagging of a SICR. This reduced from £19
million at 31
December 2020, mainly as a resu
lt of a significantly reduced
Stage 2 population and lower de
faults across the portfolio.
Ulster Bank RoI
– Similar to Commercial Banki
ng, the post
model adjustment for economic
uncertainty included an
adjustment of £12 million reflecting concerns that the
unprecedented nature of COVID-19 could resul
t in longer debt
recovery periods and lower value
s than history suggested. It
also included an adjustment of £9 million deferring
the benefits
of improvements in economic forecasts
given ongoing
uncertainty as well as an adjustment of £9 millio
n in the SME
portfolio, reflective of the elevated risk fo
r this sector. Other
judgmental overlays increased to £156 million from £2
6 million
reflected management opinion that con
tinuing actions on the
phased withdrawal of Ulster Bank RoI from the I
rish market will
lead to higher, and/or earlier, crystallisation
of losses.
Other
– The post model adjust
ments held in other businesses
were for similar reasons as those
described above.
Significant increase in credit risk (SICR)
(audited)
Exposures that are considered significantly c
redit deteriorated
since initial recognition are classifie
d in Stage 2 and assessed
for lifetime ECL measurement (e
xposures not considered
deteriorated carry a 12 month ECL). NatWest
Group has
adopted a framework to identify deterioration b
ased primarily
on relative movements in lifetime PD suppo
rted by additional
qualitative backstops. The princ
iples applied are consistent
across NatWest Group and align to c
redit risk management
practices, where appropriate.
The framework comprises the following elements:
IFRS 9 lifetime PD assessment (
the primary driver) –
on
modelled portfolios, the assessment is base
d on the relative
deterioration in forward-lookin
g lifetime PD and is assessed
monthly. To assess whether credit dete
rioration has
occurred, the residual lifetime PD at balance she
et date
(which PD is established at date of initial recogni
tion (DOIR))
is compared to the current PD. If the current lifeti
me PD
exceeds the residual origination PD by mo
re than a
threshold amount, deterioration is assu
med to have
occurred and the exposure transferred into Stage 2 fo
r a
lifetime loss assessment. For Whole
sale, a doubling of PD
would indicate a SICR subject to a minimum PD uplift
of
0.1%. For Personal portfolios, the criteria vary by
risk band,
with lower risk exposures needing to deterior
ate more than
higher risk exposures, as outline
d in the following table:
Qualitative high-risk backstops –
the PD assessmen
t is
complemented with the use of qualitative high-risk
backstops to further inform whe
ther significant
deterioration in lifetime risk of default has occur
red. The
qualitative high-risk backstop ass
essment includes the use
of the mandatory 30+ days past due backstop, as
prescribed by IFRS 9 guidance, and other featu
res such as
forbearance support, Wholesale e
xposures managed within
the Risk of Credit Loss framework, and adverse c
redit
bureau results for Personal cus
tomers. Where a Personal
customer was granted a payment holiday (also
referred to
as a payment deferral) in response to COVI
D-19, they were
not automatically transferred in
to Stage 2. However, a
subset of Personal customers who had accessed p
ayment
holiday support, and where their risk profile w
as identified
as relatively high risk, were collectively migrated to St
age 2
(if not in Stage 2 already). Any support provide
d beyond
completion of the second payme
nt holiday was considered
forbearance.
Persistence (Personal and busine
ss banking customers only)
the persistence rule ensures that accounts which
have
met the criteria for PD driven d
eterioration are still
considered to be significantly deteriorated for
three months
thereafter. This additional rule e
nhances the timeliness of
capture in Stage 2. The persiste
nce rule is applied to PD
driven deterioration only.
Personal
risk bands
PD bandings (based
on
residual lifetime
PD calculated at
DOIR)
PD deterioration
threshold criteria
Risk band A
<0.762%
PD@DOIR + 1%
Risk band B
<4.306%
PD@DOIR + 3%
Risk band C
>=4.306%
1.7 x PD@DOIR
Risk and capital m
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nt continued
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Credit risk continued
The criteria are based on a significant amount of e
mpirical
analysis and seek to meet thre
e key objectives:
Criteria effectiveness –
the criteria should be e
ffective in
identifying significant credit deterioration and p
rospective
default population.
Stage 2 stability –
the criteria should not in
troduce
unnecessary volatility in the Stage 2 popul
ation.
Portfolio analysis –
the criteria should produce results
which
are intuitive when reported as part of the wider credi
t
portfolio.
Provisioning for forbearance
(audited)
Personal
The methodology used for provis
ioning in respect of Personal
forborne loans will differ depen
ding on whether the loans are
performing or non-performing and which business
is managing
them due to local market conditions.
Granting forbearance will only change
the arrears status of the
loan in specific circumstances, which ca
n include capitalisation
of principal and interest in arrears, where t
he loan may be
returned to the performing book if the custome
r has
demonstrated an ability to meet regul
ar payments and is likely
to continue to do so.
The loan would continue to be reported as forborne un
til it
meets the exit criteria set out by
the appropriate regulatory
guidance.
Additionally, for some forbearance types, a loa
n may be
transferred to the performing b
ook if a customer makes
payments that reduce loan arrears below 90 days
(Retail
Banking collections function).
For ECL provisioning, all forborne but performing exposures
are categorised as Stage 2 and are subject to a lif
etime loss
provisioning assessment. Where the forbear
ance treatment
includes the cessation of interest on the custome
r balance (i.e.
non-accrual), this will be treated as a Stage 3 default.
For non-performing forborne lo
ans, the Stage 3 loss
assessment process is the sam
e as for non-forborne loans.
In the absence of any other forbearance or SICR
triggers,
customers granted COVID-19 re
lated payment holidays were
not considered forborne. However, any support pro
vided
beyond completion of a second payment holiday is conside
r
ed
forbearance.
Wholesale
Provisions for forborne loans are
assessed in accordance with
normal provisioning policies. Th
e customer’s financial position
and prospects – as well as the likely
effect of the forbearance,
including any concessions granted, and revised PD or L
GD
gradings – are considered in or
der to establish whether an
impairment provision increase i
s required.
Wholesale loans granted forbearance
are individually credit
assessed in most cases. Performing loans subject to
forbearance treatment are cate
gorised as Stage 2 and subject
to a lifetime loss assessment.
Forbearance may result in the value of the outst
anding debt
exceeding the present value of the es
timated future cash flows.
This difference will lead to a cus
tomer being classified as non-
performing.
In the case of non-performing f
orborne loans, an individual loan
impairment provision assessment generally t
akes place prior to
forbearance being granted. The amount of the
loan impairment
provision may change once the terms of the forbea
rance are
known, resulting in an addition
al provision charge or a release
of the provision in the period the f
orbearance is granted.
The transfer of Wholesale loans f
rom impaired to performing
status follows assessment by re
lationship managers and credit.
When no further losses are anticipated and the custo
mer is
expected to meet the loan’s revise
d terms, any provision is
written-off or released and the balance of
the loan returned to
performing status. This is not d
ependent on a specified time
period and follows the credit risk manager’s
assessment.
Customers seeking COVID-19 related support, includi
ng
payment holidays, who were not subject to any
wider SICR
triggers and who were assessed as having
the ability in the
medium term post-COVID-19 to be viable
and meet credit
appetite metrics, were not consi
dered to have been granted
forbearance.
Asset lifetimes
(audited)
The choice of initial recognition and asse
t duration is another
critical judgment in determining the quantu
m of lifetime losses
that apply.
The date of initial recognition re
flects the date that a
transaction (or account) was firs
t recognised on the
balance sheet; the PD recorded
at that time provides the
baseline used for subsequent de
termination of SICR as
detailed above.
For asset duration, the approach applied (in line
with IFRS 9
requirements) is:
Term lending – the contractual maturity date, reduced
for behavioural trends where a
ppropriate (such as,
expected prepayment and amo
rtisation).
Revolving facilities – for Person
al portfolios (except
credit cards), asset duration is based on behaviour
al
life and this is normally greater than contr
actual life
(which would typically be overnight). Fo
r Wholesale
portfolios, asset duration is based on annual cust
omer
review schedules and will be set to the nex
t review
date.
In the case of credit cards, the most significan
t judgment is to
reflect the operational practice of card reissuance a
nd the
associated credit assessment as
enabling a formal re-
origination trigger. As a conseq
uence, a capped lifetime
approach of up to 36 months is us
ed on credit card balances. If
the approach was uncapped the ECL impact is esti
mated at
approximately £70 million (2020 – £11
0 million). However,
credit card balances originated under the 0% b
alance transfer
product, and representing approximately 13
% of performing
card balances, have their ECL calculated on a be
havioural
lifetime approach as opposed to being capped
at a maximum
of three years.
The capped approach reflects NatWest G
roup practice of a
credit-based review of custome
rs prior to credit card issuance
and complies with IFRS 9. Benchmarking inf
ormation indicates
that peer UK banks use behavioural approaches in t
he main for
credit card portfolios with average durations betwee
n three
and ten years. Across Europe, durations are sho
rter and are, in
some cases, as low as one year.
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Economic loss drivers
(audited)
Introduction
The portfolio segmentation and se
lection of economic loss
drivers for IFRS 9 follow closely the approach used in
stress
testing. To enable robust modelling the fo
recasting models for
each portfolio segment (defined by pro
duct or asset class and
where relevant, industry sector
and region) are based on a
selected, small number of econ
omic factors, (typically three to
four) that best explain the temporal varia
tions in portfolio loss
rates. The process to select economic loss d
rivers involves
empirical analysis and expert judgment.
The most material economic loss drivers are shown in
the table
below.
Portfolio
Economic loss drivers
UK retail
mortgages
UK unemployment rate, sterling swap
rate, UK house price index, UK
household debt to income
UK retail
unsecured
UK unemployment rate, sterling swap
rate, UK household debt to income
UK large
corporates
World GDP, UK unemployment
rate,
sterling swap rate, stock price index
UK commercial
UK GDP, UK unempl
oyment rate, sterling
swap rate
UK commercial
real estate
UK GDP, UK commercial property price
index, sterling swap rate, stock price
index
RoI retail
mortgages
RoI unemployment rate, Europe
an
Central Bank base rate, RoI house
price
index
(1)
This is not an exhaustive list of econ
omic loss drivers but shows the most material
drivers for the most significant portfolios.
Economic scenarios
At 31 December 2021, the range
of anticipated future economic
conditions was defined by a set of four inte
rnally developed
scenarios and their respective probabilities. In
addition to the
base case, they comprised upside
, downside and extreme
downside scenarios. The scenarios primarily
reflected a range
of outcomes for the path of COVID-19 as well as reco
very, and
the associated effects on labour and asset
markets.
The four economic scenarios a
re translated into forward-looking
projections of CCIs using a set of e
conometric models.
Subsequently the CCI projections for the indivi
dual scenarios are
averaged into a single central CCI projection accor
ding to the
given scenario probabilities. The ce
ntral CCI projection is then
overlaid with an additional mean reversion assum
ption i.e. that
after reaching their worst forec
ast position the CCIs start to
gradually revert to their long-run average of
zero.
Upside
– This scenario assumes a very stron
g recovery through
2022 as consumers dip into excess
savings built up over the last
two years. The labour market remains resilie
nt, with the
unemployment rate falling below pre-COVID-19 levels. Infl
ation
is higher than the base case but eventu
ally comes back close to
the target. The strong economic recovery enable
s tightening to
be quicker than the base case. The housing market c
ontinues its
recent strong performance.
Base case
– COVID-19 related risks remain contai
ned. After a
strong recovery in 2021, the gr
owth moderates in 2022. Most of
the furloughed workers can go back to their existin
g job or find
a new job very quickly, with the
unemployment rate reaching
4.1% by the end of 2022. Inflation initi
ally increases but retreats
over 2022. Interest rates are rais
ed, starting in early 2022.
There is a gradual cool down in the housing marke
t but activity
is still at healthy levels.
Downside
– This scenario assumes a reve
rsal in recovery as
inflation build up leads to a less
ening of expectations. Interest
rates are raised aggressively to counter
the inflation risks.
However, starting in 2023, the interest hikes
are reversed to
assist the recovery. Unemployment is higher
than the base case
and there is a modest decline in house
prices.
Extreme downside
– This scenario assu
mes a resurgence of
COVID-19 related risks. There is a renewed downturn wi
th
declines in consumer spending
and business investment. Interest
rates are reduced into negative territory to -0.5
%. There is wide-
spread job shedding in the labour market while asse
t prices see
deep corrections, with housing market falls hi
gher than those
seen during previous episodes. The recovery is tepid
throughout
the five-year period, meaning only a gradual decline in
joblessness.
The approach of using four scenarios is s
imilar to that as at 31
December 2020. Previously, NatWest Grou
p used five discrete
scenarios to characterise the dis
tribution of risks in the
economic outlook. For 2021, the f
our scenarios were deemed
appropriate in capturing the uncertainty in econo
mic forecasts
and the non-linearity in outcom
es under different scenarios.
These four scenarios were deve
loped to provide sufficient
coverage across potential rises in unemployment, inf
lation, asset
price falls and the degree of permanent dama
ge to the
economy, around which there remains pronounce
d levels of
uncertainty.
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Economic loss drivers
(audited)
The tables and commentary be
low provide details of the key economic loss drive
rs under the four scenarios.
The main macroeconomic variables for each of the fou
r scenarios used for ECL modelling ar
e set out in the main macroeconomic
variables table below. The compound annu
al growth rate (CAGR) for GDP is shown. It also shows the five-ye
ar average for
unemployment and the Bank of England base r
ate. The house price index and commerci
al real estate figures show the total
change in each asset over five ye
ars.
Main macroeconomic variables
2021
2020
Extreme
Extreme
Upside
Base ca
se
Downside
downside
Upside
Bas
e case
Down
side
d
ownside
Five-year summary
%
%
%
%
%
%
%
%
UK
Republic of Ireland
GDP
-
CAGR
4.4
3.7
2.9
1.6
4.2
3.5
3.0
1.6
Unemployment - average
4.2
5.2
6.8
9.3
5.6
7.5
9.3
11.2
House price index - total change
30.3
23.4
16.3
4.6
21.0
13.3
6.8
(7.0)
European Central Bank base rate - ave
rage
0.8
0.1
0.2
0.1
World GDP - CAGR
3.5
3.2
2.6
0.6
3.5
3.4
2.9
2.8
Probability weight
30.0
45.0
20.0
5.0
20.0
40.0
30.0
10.0
(1)
The five year period starts after Q3 2021 for 2021 and Q3 2020 for 2020
.
(2)
The Republic of Ireland unemployment rate
in the table above and the tables that follow corresponds to the mid-point of the Irish Central Statistics Office lower and upper bound
unemployment rate measures.
Probability weightings of scenarios
NatWest Group’s approach to IFRS 9 mul
tiple economic
scenarios (MES) involves selec
ting a suitable set of discrete
scenarios to characterise the dis
tribution of risks in the
economic outlook and assigning appropriate p
robability weights.
The scale of the economic impact of COVID-19 an
d the range of
recovery paths necessitates a change of appro
ach to assigning
probability weights from that used in recent updates
. Prior to
2020, GDP paths for NatWest Group’s scena
rios were compared
against a set of 1,000 model runs, following which
a percentile
in the distribution was established that most closely
corresponded to the scenario.
Instead, NatWest Group has subjectively applie
d probability
weights, reflecting expert views
within NatWest Group. The
probability weight assignment was judged
to present good
coverage to the central scenarios and the po
tential for a robust
recovery on the upside and exceptionally challenging ou
tcomes
on the downside. A 30% weighting was applied to the upside
scenario, a 45% weighting applie
d to the base case scenario, a
20% weighting applied to the downside sce
nario and a 5%
weighting applied to the extreme downside sce
nario. NatWest
Group assessed the downside r
isk posed by COVID-19 to be
diminishing over the course of 2
021, with the vaccination roll-
out and positive economic data being observed since t
he
gradual relaxing of lockdown res
trictions.
NatWest Group therefore judged it w
as appropriate to apply a
higher probability to upside-bias
ed scenarios than at 31
December 2020. However, compare
d to 31 December 2020, the
base case has a higher weight reflec
ting reduction in
uncertainty as the path of economy recove
ry became clearer.
The 25% weighting to the two downside scena
rios gives
appropriate consideration to the threats posed to the recove
ry,
including inflation, supply and COVID-19-rel
ated risks. Balanced
against that is the adaptability of the UK economy to succe
ssive
waves of COVID-19, and the re
silience of labour and asset
markets. The potential for further better than e
xpected
outcomes is reflected in the 30% p
robability weighting applied to
the upside scenario.
GDP - CAGR
2.4
1.7
1.4
0.6
3.6
3.1
2.8
1.3
Unemployment - average
3.5
4.2
4.8
6.7
4.4
5.7
7.1
9.7
House price index - total change
22.7
12.1
4.3
(5.3)
12.5
7.6
4.4
(19.0)
Bank of England base rate - av
erage
1.5
0.8
0.7
(0.5)
0.2
(0.1)
(0.5)
Commercial real estate price - total cha
nge
18.2
7.2
5.5
(6.4)
4.3
0.7
(12.0
)
(31.5)
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Economic loss drivers
75
80
85
90
95
100
105
110
115
Q4 2019
Q4 2020
Q4 2021
Q4 2022
Q4 2023
Q4 2024
Q
4 2025
Q4 2026
UK gross domestic product
Upside
Base
Downside
Extreme downside
-0.75
-0.50
-0.25
0.00
0.25
0.50
0.75
1.00
1.25
1.50
1.75
2.00
Q4 2019
Q
4 2020
Q4 2021
Q4 2022
Q4 2023
Q4 2024
Q4 2025
Q4 2026
%
Bank of England base rate
Upside
Base
Downside
Extreme downside
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Economic loss drivers
(audited)
Annual figures
GDP - annual growth
Extreme
Extreme
Upside
Base case
Downside
downside
Upside
Base case
Downside
downside
UK
%
%
%
%
Republic of Ireland
%
%
%
%
2021
7.0
7.0
7.0
7.0
2021
15.1
15.1
15.1
15.1
2022
8.1
5.0
1.5
(3.6)
2022
8.9
6.8
2.9
(4.9)
2023
2.1
1.6
2.4
4.1
2023
5.8
4.1
3.8
5.3
2024
1.2
0.9
1.6
1.2
2024
3.0
3.1
3.3
3.1
2025
1.2
1.3
1.4
1.4
2025
2.9
3.1
3.1
3.2
2026
1.2
1.5
1.6
1.5
2026
2.8
2.7
2.7
3.1
Unemployment rate
-
annual average
Extreme
Extreme
Upside
Base case
Downside
downside
Upside
Base case
Downside
downside
UK
%
%
%
%
Republic of Ireland
%
%
%
%
2021
4.6
4.6
4.6
4.6
2021
11.2
11.2
11.2
11.2
2022
3.5
4.1
5.1
8.3
2022
4.5
5.5
8.8
13.7
2023
3.3
4.0
5.2
8.8
2023
4.1
5.3
7.2
10.2
2024
3.4
4.1
4.7
6.6
2024
4.0
5.1
6.3
8.4
2025
3.4
4.2
4.5
5.2
2025
4.0
5.0
5.7
7.5
2026
3.6
4.2
4.5
4.9
2026
4.0
5.0
5.5
7.0
House price index
-
four quarter
growth
Extreme
Extreme
Upside
Base case
Downside
downside
Upside
Base case
Downside
downside
UK
%
%
%
%
Republic of Ireland
%
%
%
%
2021
6.9
6.9
6.9
6.9
2021
12.9
12.9
12.9
12.9
2022
7.9
1.6
(2.9)
(20.4)
2022
12.2
5.1
(3.3)
(17.8)
2023
4.2
1.6
(0.2)
(2.6)
2023
3.4
4.0
2.0
(4.7)
2024
3.1
2.9
1.7
13.0
2024
2.6
3.3
4.1
16.1
2025
3.0
2.7
3.0
4.7
2025
3.4
3.4
5.9
6.8
2026
3.0
2.7
3.0
3.6
2026
3.3
3.0
4.4
4.9
Commercial real estate price
-
four quarter
growth
Bank of England base rate
-
annual average
Extreme
Extreme
Upside
Base case
Downside
downside
Upside
Base case
Downside
downside
UK
%
%
%
%
UK
%
%
%
%
2022
1.02
0.63
1.06
(0.40)
2023
3.4
1.9
4.2
17.2
2023
1.58
1.00
1.06
(0.50)
2024
1.7
0.2
1.7
5.2
2024
1.75
1.00
0.50
(0.50)
2025
0.6
(0.8)
0.3
3.5
2025
1.75
0.90
0.50
(0.50)
2026
(0.8)
(0.8)
(0.2)
3.2
2026
1.75
0.75
0.50
(0.50)
Worst points
31 December 2021
31 December 2020
Extreme
Extreme
Downside
downside
Downside
downside
UK
%
Quarter
%
Quarter
%
Quarter
%
Quarter
GDP
(1.8)
Q1 2022
(7.9)
Q1 2022
(5.1)
Q1 2021
(10.4)
Q1 2021
Unemployment rate (peak)
5.4
Q1 2023
9.4
Q4 2022
9.4
Q4 2021
13.9
Q3 2021
House price index
(3.0)
Q3 2023
(26.0)
Q2 2023
(11.2)
Q2 2021
(32.0)
Q4 2021
Commercial real estate price
(2.5)
Q1 2022
(29.8)
Q3 2022
(28.9)
Q2 2021
(40.4)
Q2 2021
Bank of England base rate
1.5
Q4 2022
(0.5)
Q2 2022
(0.1)
Q3 2021
(0.5)
Q1 2021
Republic of Ireland
Unemployment rate (peak)
9.4
Q2 2022
15.1
Q2 2022
16.5
Q2 2020
18.1
Q4 2020
House price index
(0.1)
Q4 2022
(25.1)
Q2 2023
(13.3)
Q3 2021
(27.0)
Q4 2021
(1)
For the unemployment rate
, the figures show the peak levels. For the Bank of England base rate, the figures show highest or lowest levels. For other parameters, the figures show
falls relative to the starting period.
The calculations are performed over five years
, with a starting point of Q3 2021 for 31 December 2021 scenarios.
2021
8.4
8.4
8.4
8.4
GDP
(0.7)
Q1 2022
(8.9)
Q2 2022
(5.5)
Q1 2021
(13.8)
Q1 2021
2021
0.10
0.10
0.10
0.10
2022
10.2
4.4
(2.7)
(29.8)
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Economic loss drivers
(audited)
Use of the scenarios in Personal lending
Personal lending follows a discrete sc
enario approach. The PD
and LGD values for each discrete sce
nario are calculated using
product specific econometric models. Each accoun
t has a PD
and LGD calculated as probability weighted ave
rages across
the suite of economic scenarios.
Use of the scenarios in Wholesale lending
The Wholesale lending ECL met
hodology is based on the
concept of credit cycle indices (CC
Is). The CCIs represent,
similar to the exogenous comp
onent in Personal, all relevant
economic loss drivers for a region/industry se
gment
aggregated into a single index value that describes the loss
rate conditions in the respective
segment relative to its long-run
average. A CCI value of zero corresponds t
o loss rates at long-
run average levels, a positive CC
I value corresponds to loss
rates below long run average levels and a nega
tive CCI value
corresponds to loss rates above long-run ave
rage levels.
The four economic scenarios a
re translated into forward-
looking projections of CCIs using a set of econo
metric models.
Subsequently the CCI projections for the indivi
dual scenarios
are averaged into a single central CCI projec
tion according to
the given scenario probabilities. T
he central CCI projection is
then overlaid with an additional mean reversion
assumption i.e.
that after one to two years into the forecast ho
rizon the CCIs
start to gradually revert to their long-run ave
rage of zero.
Finally, ECL is calculated using a Monte Carlo a
pproach by
averaging PD and LGD values arising from many CCI p
aths
simulated around the central CCI projection.
The rationale for the Wholesale approach is
the long-standing
observation that loss rates in Wholesale portfolios ten
d to follow
regular cycles. This allows NatWes
t Group to enrich the range
and depth of future economic conditions e
mbedded in the final
ECL beyond what would be obtained fro
m using the discrete
macro-economic scenarios alo
ne.
Business banking, while part of the Wholesale seg
ment, for
reporting purposes, utilises the Personal lending
rather than the
Wholesale lending methodology.
UK economic uncertainty
Treatment of COVID-19 relief mechanisms
Use of COVID-19 relief mechan
isms (for example, payment
holidays, CBILS and BBLS) does not automatically me
rit
identification of a SICR and trigger a Stage 2
classification in
isolation. However, a subset of Personal c
ustomers who had
accessed payment holiday support, and whe
re their risk profile
was identified as relatively high risk conti
nue to be collectively
migrated into Stage 2 (if not alre
ady captured by other SICR
criteria).
For Wholesale customers, NatWest Group continues t
o provide
support, where appropriate, to existing customers. Those w
ho
are deemed either (a) to require a prolonged timescale
to
return to within NatWest Group’s risk ap
petite, (b) not to have
been viable pre-COVID-19, or (c) not to be
able to sustain their
debt once COVID-19 is over, will trigger
a SICR and, if
concessions are sought, be categorised as forbo
rne, in line with
regulatory guidance. Payment holiday extensions bey
ond an
aggregate of 12 months in an 1
8 month period to cover
continuing COVID-19 business interruption are ca
tegorised as
forbearance, including for customers where no othe
r SICR
triggers are present.
In February 2021, the British Busi
ness Bank announced details
of Pay As You Grow (PAYG) options for borrowers of B
BLS.
The scheme options include the extension of lendi
ng terms,
periods of reduced repayments and six
month payment
holidays. PAYG options are a fe
ature of BBLS rather than a
concession granted by NatWest Group. It is the
refore not
automatically considered significant credit deterio
ration and a
Stage 2 trigger. NatWest Group relies on both custo
mer
attestations and existing credit monitoring procedu
res to
identify significant financial difficu
lty. Should signs of financial
stress be identified, a review is performed. If credit
deterioration is confirmed, existing problem debt
management
journeys are followed and forbe
arance (if a concession is
granted) is marked in line with
existing processes. This will
result in Stage 2 transfer.
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Economic loss drivers
(audited)
Model monitoring and enhancement
The severe economic impact from COVI
D-19 and the ensuing
government support schemes have disru
pted the normal
relationships between key economic loss drivers
and credit
outcomes. While most governm
ent support schemes have now
been phased out and economic conditions a
re normalising, the
effect of this disruption is still evident in model
monitoring and
accounted for in judgments applied to
the use and
recalibrations of models.
Most significantly, latest PD model moni
toring shows general
overprediction across all key portfolios, i.e., obse
rved default
rates still at or even below pre-CO
VID-19 levels despite
increased PD estimates from a deteriora
tion in several key
economic variables. Model rec
alibrations to adjust for this
overprediction have been deferred base
d on the judgment that
default rate actuals are distorted due to
government support.
In addition, to account for residual model unce
rtainty and the
risk of eventual default emergence hitherto sup
ressed by
government support, lag assumptions of up to 12 m
onths are
applied in the models. These assumptions are consistent
with
and unchanged from previous disclosures in 2
021, although
their effective impact gradually reduces over time.
Industry sector detail – Wholesale only
The economic impact of COVID-19 is highly diff
erentiated by
industry sector, with hospitality and other contact
-based
leisure, service, travel and pass
enger transport activities
significantly more affected than the overall econo
my. On the
other hand, the corporate and commercial econo
metric
forecasting models used in Wholesale are secto
r agnostic.
Sector performance was monitored throughou
t the year and
additional post model adjustments were
recognised where a
risk of higher than expected future default levels, includi
ng their
timing and value, was identified.
Scenario sensitivity – Personal only
For the Personal lending portfolio, the forwa
rd-looking
components of the IFRS 9 PD models con
tinue to be modified,
leveraging existing econometric
models used in stress testing to
ensure that PDs appropriately re
flect the forecasts for
unemployment and house prices
in particular.
Additionally, post model ECL a
djustments were made in
Personal to account for known model weaknes
ses pre-dating
COVID-19, pending the systematic
re-development of the
underlying models.
Government guarantees
In April 2021, the UK governme
nt launched the Recovery Loan
Scheme, replacing previous support schemes which a
re now
closed. Consistent with CBILS and the Coron
avirus Large
Business Interruption Loan Scheme (CLB
ILS), the government
guarantee is 80%. NatWest Group recognises lowe
r LGDs for
these lending products as a result, with 0%
applied to the
government-guaranteed part of the exposure. Nat
West Group
does not directly adjust the measurement of P
D due to the
government guarantee and continues to move ex
posures into
Stage 2 and Stage 3 where a si
gnificant deterioration in credit
risk or a default is identified.
Wholesale support schemes*
The table below shows the sect
or split for the Bounce Back Loan Sche
me (BBLS) as well as associated debt spli
t by stage.
Associated debt refers to the n
on-BBLS lending to customers who also have BBLS lendin
g.
Gross Carrying A
mount
Associated
BBL and
Of which:
BBL
debt
associated debt
Stage 1
Stage 2
Stage 3
31 December 2021
£m
£m
£m
£
m
£m
£
m
Wholesale
Property
1,797
1,452
3,249
2,712
383
154
Financial institutions
39
32
71
41
26
4
Soverign
8
2
10
7,070
1,795
417
Of which:
Airlines and aerospace
7
2
9
6
2
1
Automotive
373
160
533
429
81
23
Health
266
431
697
519
158
20
Land transport and logistics
231
85
316
237
58
21
Leisure
883
600
1,483
1,072
331
80
Oil and gas
11
4
15
11
3
1
Retail
956
445
1,401
1,110
236
55
Total
7,474
5,138
12,612
9,832
2,205
575
*Not within audi
t scope.
9
1
Corporate
5,630
3,652
9,282
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Credit risk continued
Economic loss drivers
(audited)
Gross Carrying Amount
Associated
BBL and
Of which:
BBL
debt
associated debt
Stage 1
Stage 2
Stag
e 3
31 December 2020
£m
£m
£m
£m
£m
£m
Wholesale
Property
1,996
1,801
3,797
2,603
1,146
48
Financial institutions
49
35
84
47
37
Soverign
11
2
13
12
1
Corporate
6,242
4,105
10,347
7,390
2,861
96
Of which:
Airlines and aerospace
7
3
10
7
3
Automotive
416
177
593
472
119
2
Health
314
510
824
470
343
11
Land transport and logistics
255
112
367
275
83
9
Leisure
989
712
1,701
1,191
477
33
Oil and gas
9
4
13
11
2
Retail
1,078
512
1,590
1,207
374
9
Total
8,298
5,943
14,241
10,052
4,045
144
(1)
The Recovery Loan Scheme, a successor to the
closed BBLS was launched on 6 April 2021. Uptake of the new scheme was minimal with 527 customers having drawn down £54
million as at 31 December 2021
Measurement uncertainty and ECL sensitivity
analysis
(audited)
The recognition and measurement of ECL is co
mplex and
involves the use of significant judgment and esti
mation,
particularly in times of economi
c volatility and uncertainty. This
includes the formulation and inc
orporation of multiple forward-
looking economic conditions into ECL to meet the measu
rement
objective of IFRS 9. The ECL provision is sensi
tive to the model
inputs and economic assumptions u
nderlying the estimate.
The focus of the simulations is
on ECL provisioning
requirements on performing exposures in S
tage 1 and Stage 2.
The simulations are run on a stand-alone basis and a
re
independent of each other; the potential
ECL impacts reflect
the simulated impact at 31 Dece
mber 2021. Scenario impacts
on SICR should be considered when evaluating t
he ECL
movements of Stage 1 and Stage 2. In all scenarios
the total
exposure was the same but exposure by st
age varied in each
scenario.
Stage 3 provisions are not subje
ct to the same level of
measurement uncertainty – default is an observed eve
nt as at
the balance sheet date. Stage 3 provisions therefo
re have not
been considered in this analysis.
The impact arising from the bas
e case, upside, downside and
extreme downside scenarios has bee
n simulated. These
scenarios are three of the four discrete sce
narios used in the
methodology for Personal multiple economic scena
rios as
described in the Economic loss drivers section. In the
simulations, NatWest Group ha
s assumed that the economic
macro variables associated with these sc
enarios replace the
existing base case economic ass
umptions, giving them a 100%
probability weighting and therefore serving as a sin
gle
economic scenario.
These scenarios have been applied to all modelled
portfolios in
the analysis below, with the simulation impacting both P
Ds and
LGDs. Modelled post model adjustments present i
n the
underlying ECL estimates are also sens
itised in line with the
modelled ECL movements, but those that were judg
mental in
nature, primarily those for deferred model c
alibrations and
economic uncertainty, were not (refer to the Go
vernance and
post model adjustments section). As expected, the s
cenarios
create differing impacts on EC
L by portfolio and the impacts
are deemed reasonable. In this
simulation, it is assumed that
existing modelled relationships between key
economic variables
and loss drivers hold, but in practice other f
actors would also
have an impact, for example, potential custo
mer behaviour
changes and policy changes by lenders that might i
mpact on
the wider availability of credit.
NatWest Group’s core criterion to identify a SICR is fou
nded on
PD deterioration, as discussed
above. Under the simulations,
PDs change and result in expos
ures moving between Stage 1
and Stage 2 contributing to the ECL impact.
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nt continued
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Credit risk continued
Measurement uncertainty and ECL sensitivity an
alysis
(audited)
Extreme
2021
Actual
Bas
e case
Upside
Downside
downside
Stage 1 modelled exposure (£m)
Retail Banking - mortgages
157,456
157,803
159,093
153,018
128,673
Retail Banking - unsecured
7,386
7,435
7,675
6,939
5,975
Wholesale
-
property
28,047
28,137
28,181
27,995
26,074
Wholesale - non-property
103,604
104,080
104,309
103,749
92,645
296,493
297,455
299,258
291,701
253,367
Stage 1 modelled ECL (£m)
Retail Banking - mortgages
13
12
11
14
22
Retail Banking - unsecured
112
109
107
107
95
Wholesale - property
24
22
26
21
20
Wholesale
-
non
-
property
112
113
112
114
98
261
256
256
256
235
Stage 2 modelled exposure (£m)
Retail Banking - mortgages
10,728
10,381
9,091
15,166
39,511
Retail Banking - unsecured
2,934
2,885
2,645
3,381
4,345
Wholesale - property
3,220
3,130
3,086
3,272
5,193
Wholesale - non-property
16,908
16,432
16,203
16,763
27,867
33,790
32,828
31,025
38,582
76,916
Stage 2 modelled ECL (£m)
Retail Banking - mortgages
155
152
135
177
379
Retail Banking - unsecured
435
435
413
475
562
Wholesale - property
109
105
99
110
191
Wholesale - non-property
701
674
666
680
989
1,400
1,366
1,313
1,442
2,121
Stage 1 and Stage 2 modelled exposure (£m)
Retail Banking - mortgages
168,184
168,184
168,184
168,184
168,184
Retail Banking - unsecured
10,320
10,320
10,320
10,320
10,320
Wholesale - property
31,267
31,267
31,267
31,267
31,267
Wholesale - non-property
120,512
120,512
120,512
120,512
120,512
330,283
330,283
330,283
330,283
330,283
Stage 1 and Stage 2 modelled ECL (£m)
Retail Banking - mortgages
168
164
146
191
401
Retail Banking - unsecured
547
544
520
582
657
Wholesale - property
133
127
125
131
211
Wholesale - non-property
813
787
778
794
1,087
1,661
1,622
1,569
1,698
2,356
Stage 1 and Stage 2 coverage (%)
Retail Banking - mortgages
0.10%
0.10%
0.09%
0.11%
0.24%
Retail Banking - unsecured
5.30%
5.27%
5.04%
5.64%
6.37%
Wholesale - property
0.43%
0.41%
0.40%
0.42%
0.67%
Wholesale - non-property
0.67%
0.65%
0.65%
0.66%
0.90%
0.50%
0.49%
0.48%
0.51%
0.71%
Reconciliation to Stage 1 and Stage 2 ECL (£m)
ECL on modelled exposures
1,661
1,622
1,569
1,698
2,356
ECL on Ulster Bank RoI modelle
d exposures
74
74
74
74
74
ECL on non-modelled exposures
45
45
45
45
45
Total Stage 1 and Stage 2 ECL
1,780
1,741
1,688
1,817
2,475
Variance
(lower)/higher to ac
tual total Stage 1 and Stage 2
ECL
(39)
(92)
37
695
(1)
Variations in future undrawn exposure values a
cross the scenarios are modelled, however the exposure position reported is that used to calculate modelled ECL as at 31 December
2021 and therefore does not include variation in f
uture undrawn exposure values.
(2)
Reflects ECL for all modelled exp
osure in scope for IFRS 9. The analysis excludes non-modelled portfolios and exposure relating to bonds and cash
.
(3)
Exposures related to Ulster
Bank RoI continui
ng operations have not been included
in the simulations, the current Ulster Bank RoI ECL has been included across all scenarios to
enable reconciliation to other disclosures.
(4)
All simulations are run on a stand-alone bas
is and are independent of each other, with the potential ECL impact reflecting the simulated impact as at 31 December 2021.
The
simulations change the composition of Stage 1 and Stage
2 exposure but total exposure is unchanged under each scenario as the loan population is static.
(5)
Refer to the Economic loss drivers s
ection for details of economic scenarios.
(6)
Refer to the NatWest Group 2020 Ann
ual Report and Accounts for 2020 comparatives.
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Credit risk continued
Measurement uncertainty and ECL adequacy
(audited)
During 2021, both the Stage 2 size and overall modelled ECL
reduced as a result of the improved economic outlo
ok and
scenario weightings, together with stable p
ortfolio
performance. Judgmental ECL post model a
djustments,
although reduced, continued to refle
ct residual economic
uncertainty with the expectation of increased defaults la
ter
in 2022 and beyond, now represe
nting 26% of total ECL
(2020 – 16%). These combined f
actors, in conjunction with a
less severe suite of economics in the 2021
extreme downside
scenario, contributed to a smalle
r range of ECL sensitivities
at 31 December 2021 compared to the 20
20 year end.
If the economics were as negative as observed in the
extreme downside, total Stage
1 and Stage 2 ECL was
simulated to increase by £0.7 bil
lion (approximately 39%). In
this scenario, Stage 2 exposure increased signific
antly and
was the key driver of the simulated ECL rise. The mo
vement
in Stage 2 balances in the other simulations was les
s
significant.
In th
e Wholesale po
rtfolios, the outcome range of scenarios,
except for the extreme downside, was
relatively narrow.
This was due to the combined eff
ect of the assumption that
government support schemes will delay defaults, mea
n
reversion of CCIs and that only
in the extreme downside
CCIs do deteriorate beyond their year-end starting
point.
The lower modelled ECL in the downside scenario for
Wholesale compared to the actual cent
ral scenario reflected
the net effect of the MES weightings towards
the downside
for ECL.
Single factor sensitivity
In addition to scenario sensitivit
y, NatWest Group uses single
factor analysis to support its evaluation and govern
ance. This
covers changes such as the variation of an individu
al input
parameter (economic or credit) or a change of sce
nario
weightings. The application of single f
actor analysis recognises
the limitation that it is not normal for one
single factor to vary in
isolation, but can help identify possible risks in t
he credit
portfolios.
At 31 December 2021, NatWest Group conside
red the effect of
moving the unemployment peak in the b
ase case from 4.1% to
7.5% in 2022 but without changing expectations in subseque
nt
years. This had the effect of inc
reasing ECL requirement by
approximately 4.5% and 2.5% for the UK Ret
ail and Wholesale
portfolios respectively.
The lower effect on the Wholes
ale portfolio reflected that
unemployment is not a significant loss d
river for property
exposures nor some of NatWest Group’s specialised len
ding
areas.
The improvement in the economic outlook an
d scenarios used in
the IFRS 9 MES framework in 202
1 resulted in a release of
modelled ECL. Given that continued uncertain
ty remains due to
COVID-19 despite the improve
d economic outlook, NatWest
Group utilised a framework of quantit
ative and qualitative
measures to support the directional change
and levels of ECL
coverage, including economic data, credi
t performance insights
and problem debt trends. This was particula
rly important for
consideration of post model adjustments.
As government support schem
es continued to conclude during
2021, NatWest Group anticipate
s further credit deterioration in
the portfolios. However, the income statement ef
fect of this will
be mitigated by the forward-looking provisions
retained on the
balance sheet as at 31 December 202
1.
There are a number of key factors that could d
rive further
downside to impairments, through deteriorating econo
mic and
credit metrics and increased stage migr
ation as credit risk
increases for more customers.
A key factor would be a more
adverse deterioration in GDP a
nd unemployment in the
economies in which NatWest Group ope
rates, but also, among
others:
The ongoing trajectory of lockdown restrictions within the
UK and the Republic of Ireland,
and any future repeated
lockdown requirements.
The progress of the COVID-19 vaccination roll-out and its
effectiveness against new variants.
The long-term efficacy of the various government support
schemes in terms of their ability to defray cust
omer defaults
is yet to be proven over an ext
ended period.
The effect on customer affordability in the event of sust
ained
inflationary pressures.
The level of revenues lost by corporate clients and p
ace of
recovery of those revenues may
affect NatWest Group’s
clients’ ability to service their borrowing, e
specially in those
sectors most exposed to the effec
ts of COVID-19.
Movement in ECL provision*
The table below shows the mai
n ECL provision movements.
ECL provision
£m
At 1 January 2021
6,186
Transfers to disposal groups
(166)
Changes in economic forecasts
(611)
Changes in risk metrics and exposure: Stage 1 a
nd Stage 2
(931)
Changes in risk metrics and exposure: Stage 3
374
Judgmental changes: changes in post model
adjustments for Stage 1, Stage 2 and Stage 3
6
Write-offs and other
(1,052)
At 31 December 2021
3,806
At 1 January 2020
3,792
2020 movements
2,394
At 31 December 2020
6,186
*Not within audi
t scope.
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nt continued
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Additional information
Financial review
Credit risk – Banking activities
Introduction
This section details the credit risk profile of NatWest Grou
p’s banking activities. Refer to Accounting policy 1
1 and Note 15 to the
consolidated financial statements for policies
and critical judgments relating to impai
rment loss determination.
Presentation of discontinued operations and assets and liabili
ties of disposal groups
Two legally binding agreements f
or the sale of the UBIDAC business were announce
d in 2021 as part of the phased withdrawal
from the Republic of Ireland: The s
ale of commercial lending to Allied Irish B
anks p.l.c. and the performing non-tracker mort
gages,
performing micro-SME loans, UB
IDAC’s asset finance business and 25 of its branch locations to Permanent TSB p.l.c.. T
he business
activities relating to these sales that meet the
requirements of IFRS 5 are presented as a disco
ntinued operation and as a disposal
group on 31 December 2021. The
Ulster Bank RoI operating segment continues to be
reported separately and reflects the res
ults
of its continuing operations.
Refer to Note 8 to the consolidated financial s
tatements for further details.
Financial instruments within the scope of the IFRS 9 ECL framework
(audited)
Refer to Note 10 to the consolidated financial statemen
ts for balance sheet analysis of financ
ial assets that are classified as
amortised cost or fair value through other comprehensive i
ncome (FVOCI), the starting point f
or IFRS 9 ECL framework
assessment. The table below excludes loans in
disposal group of £9.1
billion.
Financial assets
31 December 2021
31 December 2020
Gross
ECL
Net
Gross
ECL
Net
£bn
£bn
£bn
£bn
£bn
£bn
Balance sheet total gross amortised cost and
FVOCI
596.1
555.0
In scope of IFRS 9 ECL framework
590.9
548.8
% in scope
99%
99%
Loans to customers - in scope -
amortised cost
361.9
3.7
358.2
365.5
6.0
359.5
Loans to customers - in scope -
FVOCI
0.3
0.3
Loans to banks - in scope - amortised cost
7.6
7.6
6.8
6.8
Total loans - in scope
369.8
3.7
366.1
372.3
6.0
366.3
Stage 1
330.8
0.3
330.5
287.1
0.5
286.6
Stage 2
34.0
1.4
32.6
78.9
3.0
75.9
Stage 3
5.0
2.0
3.0
6.3
2.5
3.8
Other financial assets - in scope - amortised cost
184.4
184.4
132.1
132.1
Other financial assets - in scope - FVOCI
36.7
36.7
44.4
44.4
Total other financial assets - in scope
221.1
221.1
176.5
176.5
Stage 1
220.8
220.8
175.5
175.5
Stage 2
0.3
0.3
1.0
1.0
Out of scope of IFRS 9 ECL framework
5.2
na
5.2
6.2
na
6.2
Loans to customers - out of sco
pe - amortised cost
0.8
na
0.8
1.0
na
1.0
Loans to banks - out of scope - amortised cos
t
0.1
na
0.1
0.1
na
0.1
Other financial assets - out of scope - amortised cost
4.0
na
4.0
4.6
na
4.6
Other financial assets - out of scope - FVOCI
0.3
na
0.3
0.5
na
0.5
na = not appli
cable
The assets outside the scope of IFRS 9 ECL framewo
rk were as
follows:
Settlement balances, items in the course of collection, c
ash
balances and other non-credit risk asse
ts of £3.7 billion
(2020 – £4.1 billion). These we
re assessed as having no ECL
unless there was evidence that they were defaul
ted.
Equity shares of £0.3 billion (2020 – £0.3
billion) as not
within the IFRS 9 ECL framework by definition.
Fair value adjustments on loans and debt securities hedged
by interest rate swaps, where the u
nderlying loan was
within the IFRS 9 ECL scope – £0
.8 billion (2020 – £1.4
billion).
NatWest Group originated securitisations, where ECL was
captured on the underlying loans of £
0.4 billion (2020 – £0.4
billion).
Contingent liabilities and commitments
In addition to contingent liabilitie
s and commitments disclosed
in Note 27 to the consolidated financial statemen
ts,
reputationally-committed limits are also included in
the scope of
the IFRS 9 ECL framework. These
were offset by £0.8 billion
(2020 – £0.2 billion) out of scope balances prima
rily related to
facilities that, if drawn, would not be classified as
amortised
cost or FVOCI, or undrawn limits relating
to financial assets
exclusions. Total
contingent lia
bilities (including financial
guarantees) and commitments within IFRS 9 ECL scope of
£127.9 billion (2020 – £1
33.6 billion) comprised Stage 1 £119.5
billion (2020 – £107.4 billion); Stage 2 £7.8
billion (2020 – £25.2
billion); and Stage 3 £0.6 billion
(2020 – £1.0 billion).
The ECL relating to off balance s
heet exposures is £0.1 billion
(2020 - £0.2 billion). The total ECL in the re
mainder of the
credit risk section of £3.8 billion included ECL fo
r both on and
off balance sheet exposures for continuing opera
tions.
Risk and capital m
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nt continued
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Credit risk – Banking activities continued
Segment analysis – portfolio summary
(audited)
The table below shows gross loans and ECL,
by segment and stage, within the scope of
the IFRS 9 ECL framework.
Go
-
forward group
Total
Ulster
Retail
Private
Commercial
RBS
NatWest
Central items
excluding
Bank
Banking
Banking
Banking
International
Markets
& other
Ulster Ban
k RoI
RoI
Total
2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
Loans - amortised cost and FV
OCI
Stage 1
168,013
17,600
82,893
16,185
8,290
32,283
325,264
5,560
330,824
Stage 2
13,594
967
17,853
477
147
90
33,128
853
33,981
Stage 3
1,884
270
1,820
162
99
4,235
787
5,022
Of which: individual
270
631
162
91
1,154
61
1,215
Of which: collective
1,884
1,189
8
3,081
726
3,807
Subtotal excluding
disposal group loans
183,491
18,837
102,566
16,824
8,536
32,373
362,627
7,200
369,827
Disposal group loans
9,084
9,084
Total
16,284
378,911
ECL provisions
(1)
Stage 1
134
12
116
7
6
17
292
10
302
Stage 2
590
29
758
23
3
11
1,414
64
1,478
Stage 3
850
37
651
25
75
1,638
388
2,026
Of which: individual
37
221
25
67
350
13
363
Of which: collective
850
430
8
1,288
375
1,663
Subtotal excluding ECL provisions
on disposal group loans
1,574
78
1,525
55
84
28
3,344
462
3,806
ECL on disposal group loans
109
109
Total
571
3,915
ECL provisions coverage
(2)
Stage 1 (%)
0.08
0.07
0.14
0.04
0.07
0.05
0.09
0.18
0.09
Stage 2 (%)
4.34
3.00
4.25
4.82
2.04
12.22
4.27
7.50
4.35
Stage 3 (%)
45.12
13.70
35.77
15.43
75.76
38.68
49.30
40.34
ECL provisions coverage excluding
disposal group loans
0.86
0.41
1.49
0.33
0.98
0.09
0.92
6.42
1.03
ECL provisions coverage on
disposal group loans
1.20
1.20
Total
3.51
1.03
Impairment (releases)/losses
ECL (release)/charge
(3)
(36)
(54)
(1,073)
(52)
(35)
(1,250)
(28)
(1,278)
Stage 1
(387)
(45)
(818)
(39)
(15)
(3)
(1,307)
(70)
(1,377)
Stage 2
157
(15)
(272)
(16)
(11)
3
(154)
(33)
(187)
Stage 3
194
6
17
3
(9)
211
75
286
Of which: individual
6
19
3
(6)
22
(2)
20
Of which: collective
194
(2)
(3)
189
77
266
Continuing operations
(36)
(54)
(1,073)
(52)
(35)
(1,250)
(28)
(1,278)
Discontinued operations
(57)
(57)
Total
(85)
(1,335)
Amounts written-off
220
6
467
28
67
788
88
876
Of which: individual
6
378
28
43
455
455
Of which: collective
220
89
24
333
88
421
For the notes to this table refer to the following pa
ge.
Risk and capital m
anageme
nt continued
NatWest Group
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216
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Segment analysis – portfolio summary
(audited)
Go
-
forward group
Total
Ulster
Retail
Private
Commercial
RBS
NatWest
Central
items
excluding
Bank
Banking
Banking
Banking
International
Markets
& other
Ulster Bank RoI
RoI
Total
2020
£m
£m
£m
£m
£m
£m
£m
£m
£m
Loans - amortised cost and FV
OCI
Stage 1
139,956
15,321
70,685
12,143
7,780
26,859
272,744
14,380
287,124
Stage 2
32,414
1,939
37,344
2,242
1,566
110
75,615
3,302
78,917
Stage 3
1,891
298
2,551
211
171
5,122
1,236
6,358
Of which: individual
298
1,578
211
162
2,249
43
2,292
Of which: collective
1,891
973
9
2,873
1,193
4,066
174,261
17,558
110,580
14,596
9,517
26,969
353,481
18,918
372,399
ECL provisions
(1)
Stage 1
134
31
270
14
12
13
474
45
519
Stage 2
897
68
1,713
74
49
15
2,816
265
3,081
Stage 3
806
39
1,069
48
132
2,094
492
2,586
Of which: individual
39
607
48
124
818
13
831
Of which: collective
806
462
8
1,276
479
1,755
1,837
138
3,052
136
193
28
5,384
802
6,186
ECL provisions coverage
(2)
Stage 1 (%)
0.10
0.20
0.38
0.12
0.15
0.05
0.17
0.31
0.18
Stage 2 (%)
2.77
3.51
4.59
3.30
3.13
13.64
3.72
8.03
3.90
Stage 3 (%)
42.62
13.09
41.91
22.75
77.19
40.88
39.81
40.67
1.05
0.79
2.76
0.93
2.03
0.10
1.52
4.24
1.66
Impairment (releases)/losses
ECL (release)/charge
(3,4)
792
100
1,927
107
40
26
2,992
139
3,131
Stage 1
(36)
25
(
58)
8
(2)
10
(53)
(36)
(89)
Stage 2
619
60
1,667
71
54
15
2,486
115
2,601
Stage 3
209
15
318
28
(12)
1
559
60
619
Of which: individual
15
166
28
(3)
206
(12)
194
Of which: collective
209
152
(9)
1
353
72
425
Continuing operations
792
100
1,927
107
40
26
2,992
139
3,131
Discontinued operations
111
111
Total
250
3,242
Amounts written
-
off
378
5
321
3
11
718
219
937
Of which: individual
5
172
3
11
191
191
Of which: collective
378
149
527
219
746
(1)
Includes £5 million (2020 – £6 million) related t
o assets classified as FVOCI.
(2)
ECL provisions coverage is calculated as
ECL provisions divided by loans – amortised cost and FVOCI. It is calculated on third party loans and total ECL provisions.
(3)
Includes a £3 million charge (2020
– £12 million charge) related to other financial assets, of which £2 million release (2020 – £2 million charge) related to assets classified as FVOCI;
and £34 million release (2020 – £28 million charge)
related to contingent liabilities.
(4)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the
consolidated
financial statements.
(5)
The table shows gross loans only and
excludes amounts that are outside the scope of the ECL framework. Refer to the Financial instruments within the scope of the IFRS 9 ECL
framework section for further details. Other financial assets
within the scope of the IFRS 9 ECL framework were cash and balances at central banks totalling £176.3 billion (2020 –
£122.7 billion) and debt securities of £44.9 billion (2020 – £53.8 billion).
Stage 1 and Stage 2 ECL reduc
ed significantly during 2021,
with sustained improvement in underlying risk me
trics
mainly due to the improved economic outlook and
underpinned by various government suppor
t schemes.
The Stage 2 population reduce
d reflecting lower underlying
PDs, resulting in migration of cases back into Stage 1.
However, the Stage 2 population remained
above pre-
COVID-19 levels.
Stage 3 loans and ECL balances
reduced, mainly due to
write-off, repayment of defaulted debt and
portfolio sale of
defaulted debt. To date, the various COVI
D-19 related
government support schemes have mi
tigated new flows into
default. It is expected that defa
ults will increase as the
effect of the various government support schemes unwin
ds.
The table below shows Ulster Bank RoI dispos
al groups for Personal and Wholesale, by stage,
for gross loans, off-balance sheet
exposures and ECL. The tables in the res
t of the Credit risk section are shown on a continuin
g basis and therefore exclude these
exposures.
Loans - amortised cos
t
Off-balance sh
eet
and FVOCI
Loan
Contingent
ECL provisions
Stage 1
Stage 2
Stage 3
Total
commitments
liabilities
Stage
1
Stag
e 2
Stag
e 3
Total
2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Personal
5,547
210
34
5,791
4
6
7
17
Wholesale
2,647
639
7
3,293
1,665
115
10
78
4
92
Total
8,194
849
41
9,084
1,665
115
14
84
11
109
Risk and capital m
anageme
nt continued
NatWest Group
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217
Financial
statements
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Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Segmental loans and impairmen
t metrics
(audited)
The table below shows gross loans and ECL
provisions, by days past due, by se
gment and stage, within the scope of the ECL
framework.
Gross loans
ECL provisions
(2)
Stage 2
(1)
Stage 2
(1)
Not past
Not past
Stage 1
due
1
-
30 DPD
>30 DPD
Total
Stage 3
Total
Stage 1
due
1
-
30 DPD
>30 DPD
Total
Stage 3
Total
2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Retail Banking
168,013
12,275
863
456
13,594
1,884
183,491
134
516
38
36
590
850
1,574
Private Banking
17,600
902
27
38
967
270
18,837
12
29
29
37
78
Personal
14,350
137
24
11
172
232
14,754
6
2
2
18
26
Wholesale
3,250
765
3
27
795
38
4,083
6
27
27
19
52
Commercial
Banking
82,893
16,792
437
624
17,853
1,820
102,566
116
724
23
11
758
651
1,525
RBS International
16,185
431
18
28
477
162
16,824
7
23
23
25
55
Personal
2,647
21
17
11
49
57
2,753
2
1
1
10
13
Wholesale
13,538
410
1
17
428
105
14,071
5
22
22
15
42
NatWest Markets
8,290
12
9
18
147
99
8,536
6
3
3
75
84
Ulster Bank RoI
5,560
74
7
58
48
853
787
7,200
10
58
3
3
64
388
462
Personal
5,165
510
52
46
608
609
6,382
7
15
3
3
21
301
329
Wholesale
395
237
6
2
245
178
818
3
43
43
87
133
Central items
& other
32,283
90
90
32,373
17
11
11
28
Total loans
330,824
31,366
1,403
1,212
33,981
5,022
369,827
302
1,364
64
50
1,478
2,026
3,806
Of which:
Personal
190,175
12,943
956
524
14,423
2,782
207,380
149
534
41
39
614
1,179
1,942
Wholesale
140,649
18,423
447
688
19,558
2,240
162,447
153
830
23
11
864
847
1,864
2020
Retail Banking
139,956
30,714
1,080
620
32,414
1,891
174,261
134
762
70
65
897
806
1,837
Private Banking
15,321
1,908
17
14
1,939
298
17,558
31
67
1
68
39
138
Personal
12,799
116
17
11
144
263
13,206
7
2
2
19
28
Wholesale
2,522
1,792
3
1,795
35
4,352
24
65
1
66
20
110
Commercial Banking
70,685
36,451
589
304
37,344
2,551
110,580
270
1,648
44
21
1,713
1,069
3,052
RBS International
12,143
2,176
46
20
2,242
211
14,596
14
72
1
1
74
48
136
Personal
2,676
18
17
14
49
70
2,795
3
1
1
11
15
Wholesale
9,467
2,158
29
6
2,193
141
11,801
11
71
1
1
73
37
121
NatWest Markets
7,780
1,457
109
1,566
171
9,517
12
49
49
132
193
Ulster Bank RoI
14,380
2,964
144
194
3,302
1,236
18,918
45
227
15
23
265
492
802
Personal
11,117
1,500
115
130
1,745
1,064
13,926
27
74
9
13
96
392
515
Wholesale
3,263
1,464
29
64
1,557
172
4,992
18
153
6
10
169
100
287
Central items & other
26,859
110
110
26,969
13
15
15
28
Total loans
287,124
75,780
1,876
1,261
78,917
6,358
372,399
519
2,840
130
111
3,081
2,586
6,186
Of which:
Personal
166,548
32,348
1,229
775
34,352
3,288
204,188
171
839
79
78
996
1,228
2,395
Wholesale
120,576
43,432
647
486
44,565
3,070
168,211
348
2,001
51
33
2,085
1,358
3,791
2019
Retail Banking
144,513
11,921
1,034
603
13,558
1,902
159,973
114
375
45
47
467
823
1,404
Private Banking
14,956
478
63
46
587
207
15,750
7
6
1
7
29
43
Personal
11,630
180
60
41
281
192
12,103
3
2
1
3
23
29
Wholesale
3,326
298
3
5
306
15
3,647
4
4
4
6
14
Commercial Banking
88,100
10,837
254
262
11,353
2,162
101,615
152
195
12
7
214
1,021
1,387
RBS International
14,834
520
18
7
5
45
121
15,500
4
6
6
21
31
Personal
2,799
27
17
6
50
65
2,914
1
1
1
12
14
Wholesale
12,035
493
1
1
495
56
12,586
3
5
5
9
17
NatWest Markets
9,273
176
4
180
169
9,622
10
5
5
131
146
Ulster Bank RoI
15,409
1,405
104
133
1,642
2,037
19,088
29
39
6
8
53
693
775
Personal
10,858
944
96
105
1,145
1,877
13,880
12
20
6
6
32
591
635
Wholesale
4,551
461
8
28
497
160
5,208
17
19
2
21
102
140
Central items & other
15,282
3
3
15,285
6
6
Total loans
302,367
25,340
1,477
1,051
27,868
6,598
336,833
322
626
63
63
752
2,718
3,792
Of which:
Personal
169,800
13,072
1,207
755
15,034
4,036
188,870
130
398
51
54
503
1,449
2,082
Wholesale
132,567
12,268
270
296
12,834
2,562
147,963
192
228
12
9
249
1,269
1,710
For the notes to this table refer to the following pa
ge.
Risk and capital m
anageme
nt continued
NatWest Group
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nnual Repor
t and Accou
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218
Financial
statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Segmental loans and impairmen
t metrics
(audited)
The table below shows ECL and ECL provisio
ns coverage, by days past due, by segment and
stage, within the scope of the ECL
framework.
ECL provisions covera
ge
ECL
Stage 2
(1,2)
Total
Not past
(release) /
Amounts
Stage 1
due
1
-
30 DPD
>30 DPD
Total
Stage 3
Total
charge
(3)
written
-
off
2021
%
%
%
%
%
%
%
£m
£m
Retail Banking
0.08
4.20
4.40
7.89
4.34
45.12
0.86
(36)
220
Private Banking
0.07
3.22
3.00
13.70
0.41
(54)
6
Personal
0.04
1.46
1.16
7.76
0.18
1
3
Wholesale
0.18
3.53
3.40
50.00
1.27
(55)
3
Commercial Banking
0.14
4.31
5.26
1.76
4.25
35.77
1.49
(1,073)
467
RBS International
0.04
5.34
4.82
15.43
0.33
(52)
28
Personal
0.08
4.76
2.04
17.54
0.47
1
Wholesale
0.04
5.37
5.14
14.29
0.30
(52)
27
NatWest Markets
0.07
2.33
2.04
75.76
0.98
(35)
67
Ulster Bank RoI
0.18
7.76
5.17
6.25
7.50
49.30
6.42
(28)
88
Personal
0.14
2.94
5.77
6.52
3.45
49.43
5.16
(7)
76
Wholesale
0.76
18.14
17.55
48.88
16.26
(21)
12
Central items & other
0.05
12.22
12.22
0.09
Total loans
0.09
4.35
4.56
4.13
4.35
40.34
1.03
(1,278)
876
Of which:
Personal
0.08
4.13
4.29
7.44
4.26
42.38
0.94
(42)
300
Wholesale
0.11
4.51
5.15
1.60
4.42
37.81
1.15
(1,236)
576
2020
Retail Banking
0.10
2.48
6.48
10.48
2.77
42.62
1.05
792
378
Private Banking
0.20
3.51
7.14
3.51
13.09
0.79
100
5
Personal
0.05
1.72
1.39
7.22
0.21
(5)
1
Wholesale
0.95
3.63
33.33
3.68
57.14
2.53
105
4
Commercial Banking
0.38
4.52
7.47
6.91
4.59
41.91
2.76
1,927
321
RBS International
0.12
3.31
2.17
5.00
3.30
22.75
0.93
107
3
Personal
0.11
5.56
2.04
15.71
0.54
4
3
Wholesale
0.12
3.29
3.45
16.67
3.33
26.24
1.03
103
NatWest Markets
0.15
3.36
3.13
77.19
2.03
40
11
Ulster Bank RoI
0.31
7.66
10.42
11.86
8.03
39.81
4.24
139
219
Personal
0.24
4.93
7.83
10.00
5.50
36.84
3.70
98
212
Wholesale
0.55
10.45
20.69
15.63
10.85
58.14
5.75
41
7
Central items & other
0.05
13.64
13.64
0.10
26
Total loans
0.18
3.75
6.93
8.80
3.90
40.67
1.66
3,131
937
Of which:
Personal
0.10
2.59
6.43
10.06
2.90
37.35
1.17
889
594
Wholesale
0.29
4.61
7.88
6.79
4.68
44.23
2.25
2,242
343
2019
Retail Banking
0.08
3.15
4.35
7.79
3.44
43.27
0.88
393
235
Private Banking
0.05
1.26
2.17
1.19
14.01
0.27
(6)
1
Personal
0.03
1.11
2.44
1.07
11.98
0.24
5
1
Wholesale
0.12
1.34
1.31
40.00
0.38
(11)
Commercial Banking
0.17
1.80
4.72
2.67
1.88
47.22
1.36
391
450
RBS International
0.03
1.15
1.10
17.36
0.20
2
5
Personal
0.04
3.70
2.00
18.46
0.48
5
Wholesale
0.02
1.01
1.01
16.07
0.14
2
NatWest Markets
0.11
2.84
2.78
77.51
1.52
(51)
16
Ulster Bank RoI
0.19
2.78
5.77
6.02
3.23
34.02
4.06
(6)
85
Personal
0.11
2.12
6.25
5.71
2.79
31.49
4.57
11
69
Wholesale
0.37
4.12
7.14
4.23
63.75
2.69
(17)
16
Central items & other
0.04
0.04
1
Total loans
0.11
2.47
4.27
5.99
2.70
41.19
1.13
724
792
Of which:
Personal
0.08
3.04
4.23
7.15
3.35
35.90
1.10
409
310
Wholesale
0.14
1.86
4.44
3.04
1.94
49.53
1.16
315
482
(1)
30 DPD – 30 days past due, the mandatory 30 days past d
ue backstop as prescribed by IFRS 9 for a SICR.
(2)
ECL provisions on contingent liab
ilities and com
mitments are included within th
e Financial assets section so as not to distort ECL coverage ratios.
(3)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the
consolidated
financial statements.
Risk and capital m
anageme
nt continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
219
Financial
statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Segmental loans and impairmen
t metrics
(audited)
Retail Banking
– Balance sheet growth during 20
21 was
mainly due to mortgages. In lin
e with the market, mortgage
demand was strong during the year, supported by the
extension of the stamp duty holiday and ove
rall
improvements in economic conditions. The improved
economic outlook captured in the
updated MES scenarios,
including a more positive forecast on unemploy
ment levels,
resulted in reduced account level PDs. Unsecured len
ding
balances decreased as customer spend and dema
nd for
borrowing were subdued as a result of CO
VID-19
restrictions, particularly in the first quarter of 2021
. Lending
criteria were cautiously relaxed during 202
1 to support
growing demand as lockdown res
trictions eased.
Portfolio performance remained stable, for further details
refer to the Personal portfolio se
ction. Arrears levels in both
the mortgage and unsecured portfolios remained lo
w
overall. However, a small number of customers who u
tilised
their full payment holiday, did migrate into late ar
rears
during the second half of the year. With COVID-19 p
ayment
holidays complete, this trend stabilised by the ye
ar end and
new inflows to arrears were below pre-COVID-19
levels.
ECL in Stage 2 decreased due to migrations back in
to
Stage 1, following the effects of improving econo
mic
scenarios during 2021 and cont
inued stable portfolio
performance supporting improved risk metrics.
However,
the ECL coverage on remaining Stage 2 e
xposures
increased simply due to the relative underlying risk p
rofile
of the remaining Stage 2 expos
ures.
The various COVID-19
related customer support schemes (for example, loan
repayment holidays, government job reten
tion scheme)
mitigated actual portfolio deteri
oration in the short-term,
with the arrears levels and flows into Stage 3 yet
to be
materially affected. Total ECL coverage
reduced further in
the fourth quarter of 2021, overall mirroring the posi
tive
trajectory of the COVID-19 vaccinations, labour
market
trends and portfolio performance
, whilst maintaining
coverage for the key portfolios
above pre-COVID-19 levels
given the persisting sources of unce
rtainty, including the
Omicron variant and inflationar
y pressures on customers.
Commercial Banking
– Balance shee
t reduction was mainly
as a result of repayments of both COVI
D-19 government
lending schemes and conventio
nal borrowing where
demand was lower, particularly in the second
half of the
year. Strategic reduction was achie
ved in high risk sectors.
The improved economic outlook, including sig
nificant
increases in GDP and commercial real estate valua
tions,
resulted in lower IFRS 9 PDs. Conseque
ntly, compared to
2020, a smaller proportion of the
exposures exhibited a
SICR, which resulted in a migration of assets f
rom Stage 2
into Stage 1. As a result, the ECL requirement
reduced.
Reflecting the continued level of uncertainty caused
by
COVID-19, management judged that certain ECL p
ost
model adjustments remained nec
essary, refer to the
Governance and post model adjus
tments section for further
details. The increase in Stage 2 e
xposures that were past
due greater than 30 days was mainly due to the
commencement of repayments of governmen
t scheme debt
with some borrowers failing to
meet scheduled repayments.
The lower coverage of this population was driven by the
guaranteed nature of government support sche
mes.
Conventional bank debt did not s
ee a significant increase in
past due balances.
The various COVID-19 related customer suppo
rt schemes
and economic recovery continued to mitigate agai
nst flows
into default. The reduction in coverage in Stage 1 a
nd
Stage 2 was mainly due to the decrease in ECL
during
2021, primarily as a result of the
improved economic
outlook. There was a reduction in Stage 3 c
overage as
balances reduced and were not replaced by new flo
ws,
write-offs of existing debt were also higher in the ye
ar.
Coverage remained above pre-COVID-19 levels
. The loss
rate was significantly lower than in the prior year.
Other
– The reasons for the increased ECL require
ment
were similar to those described above.
Risk and capital m
anageme
nt continued
NatWest Group
A
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t and Accou
nts 2021
220
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Sector analysis – portfolio summary
(audited)
The table below shows financial assets and off
-balance sheet exposures gross of ECL
and related ECL provisions, impairment
and
past due by sector, asset quality and geogr
aphical region.
Personal
Wholesale
Mortgages
Credit
Other
(1)
cards
personal
Total
Property
Corporate
FI
Sovereign
Total
Total
2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Loans by geography
194,011
3,947
9,422
207,380
32,522
70,851
53,041
6,033
162,447
369,827
- UK
187,847
3,877
9,253
200,977
31,574
62,952
39,086
4,542
138,154
339,131
- RoI
6,164
70
147
6,381
130
1,222
116
4
1,472
7,853
- Other Europe
439
3,831
5,066
840
10,176
10,176
-
RoW
22
22
379
2,846
8,773
647
12,645
12,667
Loans by stage
194,011
3,947
9,422
207,380
32,522
70,851
53,041
6,033
162,447
369,827
- Stage 1
180,418
2,924
6,833
190,175
28,679
53,803
52,263
5,904
140,649
330,824
- Stage 2
11,543
933
1,947
14,423
3,101
15,604
732
121
19,558
33,981
- Stage 3
2,050
90
642
2,782
742
1,444
46
8
2,240
5,022
- Of which: individual
269
19
288
329
583
7
8
927
1,215
- Of which: collective
1,781
90
623
2,494
413
861
39
1,313
3,807
Loans - past due analysis
(3,4)
194,011
3,947
9,422
207,380
32,522
70,851
53,041
6,033
162,447
369,827
-
Not past due
190,834
3,834
8,619
203,287
31,391
68,630
52,285
6,030
158,336
361,623
- Past due 1-30 days
1,217
28
124
1,369
521
1,081
732
2
2,336
3,705
- Past due 31-89 days
592
25
73
690
256
448
19
1
724
1,414
- Past due 90-180 days
367
22
61
450
91
215
1
307
757
- Past due >180 days
1,001
38
545
1,584
263
477
4
744
2,328
Loans - Stage 2
11,543
933
1,947
14,423
3,101
15,604
732
121
19,558
33,981
- Not past due
10,259
899
1,785
12,943
2,725
14,870
708
120
18,423
31,366
- Past due 1-30 days
843
16
97
956
125
318
4
447
1,403
-
Past due 31
-
89 days
441
18
65
524
251
416
20
1
688
1,212
Weighted average life*
-
ECL measurement (years)
8
2
5
5
5
6
3
1
6
6
Weighted average 12 months
PDs*
- IFRS 9 (%)
0.16
4.84
2.73
0.36
0.76
1.85
0.14
0.14
1.00
0.65
- Basel (%)
0.76
3.31
3.22
0.91
1.20
1.74
0.14
0.16
1.04
0.97
ECL provisions by geography
768
260
914
1,942
374
1,411
57
22
1,864
3,806
- UK
449
258
904
1,611
331
1,124
47
18
1,520
3,131
- RoI
319
2
10
331
19
107
3
1
130
461
- Other Europe
20
77
4
1
102
102
-
RoW
4
103
3
2
112
112
ECL provisions by stage
768
260
914
1,942
374
1,411
57
22
1,864
3,806
- Stage 1
32
59
58
149
24
96
14
19
153
302
- Stage 2
174
141
299
614
111
713
39
1
864
1,478
- Stage 3
562
60
557
1,179
239
602
4
2
847
2,026
- Of which: individual
19
12
31
69
261
2
332
363
- Of which: collective
543
60
545
1,148
170
341
4
515
1,663
ECL provisions coverage (%)
0.40
6.59
9.70
0.94
1.15
1.99
0.11
0.36
1.15
1.03
- Stage 1 (%)
0.02
2.02
0.85
0.08
0.08
0.18
0.03
0.32
0.11
0.09
-
Stage 2 (%)
1.51
15.11
15.36
4.26
3.58
4.57
5.33
0.83
4.42
4.35
- Stage 3 (%)
27.41
66.67
86.76
42.38
32.21
41.69
8.70
25.00
37.81
40.34
ECL (release)/charge
(58)
(14)
30
(42)
(477)
(724)
(38)
3
(1,236)
(1,278)
- UK
(52)
(14)
31
(35)
(457)
(647)
(12)
3
(1,113)
(1,148)
- RoI
(6)
-
(1)
(7)
(5)
(24)
2
(27)
(34)
- Other Europe
(7)
(7)
(21)
(35)
(35)
- RoW
(8)
(46)
(7)
(61)
(61)
Amounts written-off
85
74
141
300
271
271
34
-
576
876
*Not within audit scope.
For the notes to this table refer to page 223
.
Risk and capital m
anageme
nt continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
221
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Sector analysis – portfolio summary
(audited)
Personal
Wholesale
Credit
Other
Mortgages
(1)
cards
personal
Total
Property
Corporate
FI
Sover
eign
Total
Total
2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Loans by residual maturity
194,011
3,947
9,422
207,380
32,522
70,851
53,041
6,033
162,447
369,827
-
<1 year
3,611
2,532
3,197
9,340
7,497
22,593
41,195
2,809
74,094
83,434
- 1-5 year
12,160
1,415
5,393
18,968
16,293
33,301
10,969
1,967
62,530
81,498
- 5 year
178,240
832
179,072
8,732
14,957
877
1,257
25,823
204,895
Other financial assets by asset
quality
(2)
55
11
11,516
209,553
221,135
221,135
-
AQ1
-
AQ4
11
10,974
209,551
220,536
220,536
- AQ5-AQ8
55
542
2
599
599
Off
-
balance sheet
16,827
15,354
8,230
40,411
16,342
52,033
17,898
1,212
87,485
127,896
- Loan commitments
16,827
15,354
8,170
40,351
15,882
49,231
16,906
1,212
83,231
123,582
- Financial guarantees
60
60
460
2,802
992
4,254
4,314
Off-balance sheet by asset quality
(2)
16,827
15,354
8,230
40,411
16,342
52,033
17,898
1,212
87,485
127,896
- AQ1-AQ4
14,792
248
6,591
21,631
12,550
30,417
16,192
1,064
60,223
81,854
- AQ5-AQ8
2,028
14,804
1,625
18,457
3,757
21,262
1,703
148
26,870
45,327
- AQ9
9
3
12
6
48
1
55
67
-
AQ10
7
293
11
311
29
306
2
337
648
For the notes to this table refer to page 223
.
Risk and capital m
anageme
nt continued
NatWest Group
A
nnual Repor
t and Accou
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222
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Sector analysis – portfolio summary
(audited)
Personal
Wholesale
Credit
Other
Mortgages
(1)
cards
person
al
Total
Property
Corpora
te
FI
Sovereign
Tota
l
Total
2020
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Loans by geography
190,516
3,895
9,777
204,188
38,076
77,533
47,643
4,959
168,211
372,399
- UK
176,866
3,816
9,580
190,262
35,617
65,968
34,847
3,776
140,208
330,470
- RoI
13,650
79
197
13,926
1,241
4,056
348
30
5,675
19,601
-
Other Europe
772
4,132
4,535
538
9,977
9,977
- RoW
446
3,377
7,913
615
12,351
12,351
Loans by stage
190,516
3,895
9,777
204,188
38,076
77,533
47,643
4,959
168,211
372,399
- Stage 1
158,387
2,411
5,750
166,548
23,733
48,090
44,002
4,751
120,576
287,124
- Stage 2
29,571
1,375
3,406
34,352
13,021
27,716
3,624
204
44,565
78,917
- Stage 3
2,558
109
621
3,288
1,322
1,727
17
4
3,070
6,358
- of which: individual
308
26
334
987
958
9
4
1,958
2,292
- of which: collective
2,250
109
595
2,954
335
769
8
1,112
4,066
Loans - past due analysis
(3,4)
190,516
3,895
9,777
204,188
38,076
77,533
47,643
4,959
168,211
372,399
-
Not past due
186,592
3,770
8,868
199,230
36,818
75,690
47,195
4,689
164,392
363,622
- Past due 1-30 days
1,482
29
192
1,703
348
990
328
270
1,936
3,639
- Past due 31-89 days
863
26
135
1,024
260
251
113
624
1,648
- Past due 90-180 days
456
20
66
542
161
67
228
770
- Past due >180 days
1,123
50
516
1,689
489
535
7
1,031
2,720
Loans - Stage 2
29,571
1,375
3,406
34,352
13,021
27,716
3,624
204
44,565
78,917
- Not past due
27,893
1,340
3,115
32,348
12,708
27,036
3,484
204
43,432
75,780
- Past due 1-30 days
1,038
18
173
1,229
160
457
30
647
1,876
-
Past due 31
-
89 days
640
17
118
775
153
223
110
486
1,261
Weighted average life*
- ECL measurement (years)
9
2
5
6
4
6
4
5
5
Weighted average 12 months PDs*
- IFRS 9 (%)
0.72
6.17
4.82
1.03
3.99
3.70
0.51
0.13
2.73
1.81
- Basel (%)
0.85
3.40
3.82
1.03
1.66
2.51
0.32
0.15
1.54
1.25
ECL provisions by geography
1,005
354
1,036
2,395
1,175
2,478
121
17
3,791
6,186
- UK
506
351
1,024
1,881
1,069
1,907
60
12
3,048
4,929
- RoI
499
3
12
514
41
277
3
1
322
836
- Other Europe
53
125
46
1
225
225
- RoW
12
169
12
3
196
196
ECL provisions by stage
1,005
354
1,036
2,395
1,175
2,478
121
17
3,791
6,186
-
Stage 1
51
53
67
171
123
188
23
14
348
519
- Stage 2
319
225
452
996
507
1,487
90
1
2,085
3,081
- Stage 3
635
76
517
1,228
545
803
8
2
1,358
2,586
- of which: individual
18
12
30
360
436
3
2
801
831
- of which: collective
617
76
505
1,198
185
367
5
557
1,755
ECL provisions coverage (%)
0.53
9.09
10.60
1.17
3.09
3.20
0.25
0.34
2.25
1.66
- Stage 1 (%)
0.03
2.20
1.17
0.10
0.52
0.39
0.05
0.29
0.29
0.18
- Stage 2 (%)
1.08
16.36
13.27
2.90
3.89
5.37
2.48
0.49
4.68
3.90
-
Stage 3 (%)
24.82
69.72
83.25
37.35
41.23
46.50
47.06
50.00
44.23
40.67
ECL
(release)/charge
(5)
276
191
422
889
733
1,407
95
7
2,242
3,131
- UK
181
190
420
791
703
1,276
48
6
2,033
2,824
- RoI
95
1
2
98
(1)
54
53
151
- Other Europe
21
34
38
93
93
- RoW
10
43
9
1
63
63
Amounts written-off
221
95
278
594
54
287
2
343
937
*Not within audit scope.
For the notes to this table refer to the following pa
ge.
Risk and capital m
anageme
nt continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
223
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Sector analysis – portfolio summary
(audited)
Personal
Wholesale
Credit
Other
Mortgages
cards
personal
Total
Property
Corporate
FI
Sovereign
Total
Total
2020
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Loans by residual maturity
190,516
3,895
9,777
204,188
38,076
77,533
47,643
4,959
168,211
372,399
- <1 year
3,831
2,557
3,249
9,637
8,669
23,015
38,203
2,196
72,083
81,720
- 1-5 year
12,193
1,338
5,509
19,040
20,029
36,640
8,340
1,590
66,599
85,639
-
5 year
174,492
1,019
175,511
9,378
17,878
1,100
1,173
29,529
205,040
Other financial assets by asset
quality
(2)
98
116
11,093
165,209
176,516
176,516
- AQ1-AQ4
116
10,734
165,184
176,034
176,034
- AQ5-AQ8
98
359
25
482
482
Off-balance sheet
14,557
14,262
10,186
39,005
17,397
58,635
17,011
1,587
94,630
133,635
- Loan commitments
14,554
14,262
10,144
38,960
16,829
55,496
15,935
1,585
89,845
128,805
- Financial guarantees
3
42
45
568
3,139
1,076
2
4,785
4,830
Off-balance sheet by asset quality
(2)
14,557
14,262
10,186
39,005
17,397
58,635
17,011
1,587
94,630
133,635
-
AQ1
-
AQ4
13,610
148
8,008
21,766
12,917
33,939
15,460
1,404
63,720
85,486
- AQ5-AQ8
937
13,809
2,152
16,898
4,372
24,065
1,544
183
30,164
47,062
- AQ9
1
8
9
18
13
76
1
90
108
- AQ10
9
297
17
323
95
555
6
656
979
(1)
Includes a portion of Private Banking lending secured ag
ainst residential real estate, in line with ECL calculation methodology. Private Banking and RBS International mortgages are
reported in UK, which includes crown dependencies, reflecting
the country of lending origination.
(2)
AQ bandings are based on Basel PDs and map
ping is as follows:
Internal asset
quality band
Probability of
default range
Indicative
S&P rating
AQ1
0%
-
0.034%
AAA to AA
AQ2
0.034% - 0.048%
AA
to AA-
AQ3
0.048%
-
0.095%
A+ to A
AQ4
0.095%
-
0.381%
BBB+ to BBB
-
AQ5
0.381%
-
1.076%
BB+ to BB
AQ6
1.076%
-
2.153%
BB
-
to B+
AQ7
2.153%
-
6.089%
B+ to B
AQ8
6.089%
-
17.222%
B
-
to CCC+
AQ9
17.222%
-
100%
CCC to C
AQ10
100%
D
£0.3 billion (2020 – £0.3 billion) of AQ10 Personal ba
lances primarily relate to loan commitments, the drawdown of which is effectively prohibited. AQ10 includes £0.2 billion (2020 –
£0.4 billion) of RoI mortgages which are not currently considered d
efaulted for capital calcul
ation purposes f
or RoI but are included in Stage 3.
(3)
30 DPD – 30 days past due, the mandatory 30 days past d
ue backstop as prescribed by IFRS 9 for a SICR.
(4)
Days past due – Personal prod
ucts: at a high level,
for amortising prod
ucts, the number of days past due is derived from the arrears amount outstanding and the monthly
repayment instalment. For credit cards, it is bas
ed on payments missed, and for current accounts the number of continual days in excess of borrowing limit. Wholesale products: the
number of days past due for all products is the number of continua
l days in excess of borrowing limi
t.
(5)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the
consolidated
financial statements.
Risk and capital m
anageme
nt continued
NatWest Group
A
nnual Repor
t and Accou
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224
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Sector analysis – portfolio summary
(audited)
The table below shows ECL by stage, for the Person
al portfolios and key sectors of the Wholesale portfolios, t
hat continue to be
affected by COVID-19.
Off-balance sh
eet
Loans
-
amortised cost and FVOCI
Loan
Contingent
ECL provisions
Stage 1
Stage 2
Stage 3
Total
commitments
liabilities
Stage 1
Stage 2
Stage 3
Total
2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Personal
190,175
14,423
2,782
207,380
40,351
60
149
614
1,179
1,942
Mortgages
180,418
11,543
2,050
194,011
16,827
32
174
562
768
Credit cards
2,924
933
90
3,947
15,354
59
141
60
260
Other personal
6,833
1,947
642
9,422
8,170
60
58
299
557
914
Wholesale
140,649
19,558
2,240
162,447
83,231
4,254
153
864
847
1,864
Property
28,679
3,101
742
32,522
15,882
460
24
111
239
374
Financial institutions
52,263
732
46
53,041
16,906
992
14
39
4
57
Sovereign
5,904
121
8
6,033
1,212
19
1
2
22
Corporate
53,803
15,604
1,444
70,851
49,231
2,802
96
713
602
1,411
Of which:
Airlines and aerospace
779
668
44
1,491
1,528
221
1
39
15
55
Automotive
5,133
1,304
38
6,475
3,507
65
9
32
10
51
Health
3,818
1,235
133
5,186
799
9
9
58
48
115
Land transport and logistics
3,721
833
39
4,593
3,069
188
4
53
12
69
Leisure
3,712
4,050
340
8,102
1,874
107
11
247
133
391
Oil and gas
1,482
141
52
1,675
1,126
453
1
14
28
43
Retail
6,380
1,342
180
7,902
4,872
410
8
29
66
103
Total
330,824
33,981
5,022
369,827
123,582
4,314
302
1,478
2,026
3,806
2020
Personal
166,548
34,352
3,288
204,188
38,960
45
171
996
1,228
2,395
Mortgages
158,387
29,571
2,558
190,516
14,554
3
51
319
635
1,005
Credit cards
2,411
1,375
109
3,895
14,262
53
225
76
354
Other personal
5,750
3,406
621
9,777
10,144
42
67
452
517
1,036
Wholesale
120,576
44,565
3,070
168,211
89,845
4,785
348
2,085
1,358
3,791
Property
23,733
13,021
1,322
38,076
16,829
568
123
507
545
1,175
Financial institutions
44,002
3,624
17
47,643
15,935
1,076
23
90
8
121
Sovereign
4,751
204
4
4,959
1,585
2
14
1
2
17
Corporate
48,090
27,716
1,727
77,533
55,496
3,139
188
1,487
803
2,478
Of which:
Airlines and aerospace
753
1,213
41
2,007
1,888
215
2
42
25
69
Automotive
4,383
1,759
161
6,303
4,205
102
17
63
17
97
Health
2,694
2,984
131
5,809
616
14
13
164
48
225
Land transport and logistics
2,868
1,823
111
4,802
3,782
197
8
98
32
138
Leisure
3,299
6,135
385
9,819
2,199
125
22
439
204
665
Oil and gas
1,178
300
83
1,561
2,225
346
4
20
59
83
Retail
6,702
2,282
187
9,171
5,888
512
18
112
101
231
Total
287,124
78,917
6,358
372,399
128,805
4,830
519
3,081
2,586
6,186
Wholesale forbearance
(audited)
The table below shows Wholesale forbearance, Heigh
tened Monitoring and Risk of Credit Los
s by sector. Personal forbearanc
e is
disclosed in the Personal portfolio sec
tion. This table show current exposure but reflects risk tr
ansfers where there is a guarantee
by another customer.
Property
FI
Other corporate
Total
2021
£m
£m
£m
£m
Forbearance (flow)
709
27
3,894
4,630
Forbearance (stock)
1,033
35
5,659
6,727
Heightened Monitoring and Risk of Credit Loss
1,225
83
4,492
5,800
2020
Forbearance (flow)
1,597
68
4,201
5,866
Forbearance (stock)
1,744
92
4,983
6,819
Heightened Monitoring and Risk of Credit Loss
1,600
155
5,771
7,526
Risk and capital m
anageme
nt continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
225
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Sector analysis – portfolio summary
(audited)
Loans by geography
– In Personal, expos
ures continued to
be concentrated in the UK and heavily weigh
ted to
mortgages and the vast majority
of exposures in the
Republic of Ireland was also mostly in mortgages
. Balance
sheet growth during the year was mainly in mor
tgages.
Unsecured lending balances were subdued as n
oted
previously. In Wholesale, exposures were m
ainly in the UK.
Balance sheet reduction was primarily due to
repayments
of both COVID-19 government
lending schemes and
conventional borrowing where demand w
as lower.
Strategic reduction was achieved in high risk secto
rs.
Loans by stage
– In both Wholes
ale and Personal, the
improved economic outlook resulted in reduced I
FRS 9 PDs
compared to 2020. This, alongside continued be
nign credit
performance of the portfolio, resulted in a s
maller
proportion of accounts exhibiti
ng a SICR and thereby an
associated migration of exposures f
rom Stage 2 into Stage
1. In the absence of any other forbearance or
SICR triggers,
customers granted COVID-19 re
lated payment holidays
were not considered forborne and did not result in a
n
automatic trigger into Stage 2. However, a subset of
Personal customers who had acces
sed payment holiday
support, and where their risk profile was iden
tified as
relatively high, continued to be collectively mig
rated into
Stage 2. In Wholesale, BBLS customers grante
d PAYG
options, including the extension of le
nding terms, periods of
reduced repayments and six m
onth payment holidays, were
not automatically considered significan
tly credit
deteriorated. PAYG options are a feature of BB
LS rather
than a concession granted by NatWest G
roup.
Loans – Past due analysis
– The various COVID-19
related
customer support schemes (capital repay
ment holidays,
government job retention scheme, gove
rnment supported
lending schemes) are mitigating actual po
rtfolio
deterioration in the short-term, although
there have been
some small increases in past du
e exposures.
Weighted average 12 months PDs
– In Perso
nal, the Basel II
point-in-time PDs improved slightly during 202
1. The
forward-looking IFRS 9 PDs reduced significantly
during
2021 reflecting the improved economics. PD reductio
ns
were most evident in Personal mortgages due to benign
arrears performance (catalysed by CO
VID-19 support
schemes) combined with the improved economic
outlook,
which is connected to the need for collective S
ICR
migration and judgmental post model adjust
ments. In
Wholesale, the Basel II PDs wer
e based on a through-the-
cycle approach and decreased les
s than the forward-
looking IFRS 9 PDs which redu
ced, reflecting the improved
economic outlook. For further details
refer to the Asset
quality section.
ECL provision by geography
– In line with the p
oint relating
to loans by geography above, the vast majority of
ECL
related to exposures in the UK and the Republic of
Ireland.
ECL provisions by stage
– Stage 1
and Stage 2 provisions
reduced reflecting the improved economic ou
tlook. As
outlined above, Stage 3 provisions have yet
to be materially
affected, underpinned by the various customer su
pport
schemes noted previously.
ECL provisions coverage
– Ove
rall provisions coverage
reduced, mainly due to the improvement in economic
outlook and scenario weightings. T
he base economic
scenario improved reflecting the
faster than expected
vaccination roll-out, better than expected actual econ
omic
data and strong government support. Stage 2
coverage
increased during the period for some po
rtfolios and notably
on certain Wholesale sectors due
to the inclusion of the
recovery risk overlay and lower Stage 2 b
alances.
The ECL charge and loss rate
– Refle
cting the improved
economic outlook, the impairment charge was significa
ntly
lower, with a material reduction in the annualise
d loss rate.
Loans by residual maturity –
In mortgages, as ex
pected, the
vast majority of exposures wer
e greater than five years. In
unsecured lending – cards and other – exposu
res were
concentrated in less than five years. In Wholesale,
with the
exception of financial institutions where lending was
concentrated in less than one ye
ar, the majority of lending
was for residual maturity of one to five ye
ars, with some
greater than five years in line with lending under
the
government support schemes.
Other financial assets by asset quality –
Consis
ting almost
entirely of cash and balances at cent
ral banks and debt
securities, held in the course of treasu
ry related
management activities, these ass
ets were mainly within the
AQ1-AQ4 bands.
Off-balance sheet exposures by asse
t quality –
In Personal,
undrawn exposures were reflective of available c
redit lines
in credit cards and current accounts. Addition
ally, the
mortgage portfolio had undrawn e
xposures, where a formal
offer had been made to a customer but had not ye
t drawn
down; the value increased in line
with the pipeline of offers.
There was also a legacy portfol
io of flexible mortgages
where a customer had the righ
t and ability to draw down
further funds. The asset quality was ali
gned to the wider
portfolio. In Wholesale, undrawn exposures declined i
n line
with muted credit demand, with customers rep
aying
revolving credit and working capital facilities
to optimise
liquidity. In addition, sector appe
tite adjustments in high risk
sectors reduced off-balance she
et exposures to these
sectors.
Wholesale forbearance –
Custo
mers seeking COVID-19
related support, including paym
ent holidays, who were not
subject to any wider SICR triggers and who we
re assessed
as having the ability in the medium term post-COVI
D-19 to
be viable and meet credit appetite me
trics, were not
considered to have been grante
d forbearance. Customers
seeking a payment holiday exte
nsion beyond an aggregate
of 12 months in an 18 month period we
re considered to
have been granted forbearance
and were classed as
heightened monitoring. This classifi
cation did not apply to
customers with BBLS taking a PAYG pay
ment holiday
option. For Wholesale, forbearance
flow decreased in the
second half of 2021 following t
he lifting of most COVID-19
restrictions. The leisure sector represented the l
argest
share of forbearance flow throughout 2021 due
to
disruption caused by the periodic presence of C
OVID-19
restrictions and resultant consumer uncertainty. P
ayment
holidays and covenant waivers were the
most common
forms of forbearance granted.
Heightened Monitoring and Risk of Credit Loss
Inflows
decreased during 2021 compar
ed to 2020. The reduction in
value was mainly due to the lower nu
mber of inflows as
well as a small number of high value customers who mo
ved
out of the framework as economic conditions i
mproved.
While noting the reduced flows into Heightened Moni
toring
and Risk of Credit Loss and the i
mproved stock position, the
volume and value of cases remained higher than p
re-
COVID-19 levels. The sector bre
akdown of exposures
remained consistent with prior periods.
Risk and capital m
anageme
nt continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
226
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Credit risk enhancement and mi
tigation
(audited)
The table below shows exposures
of modelled portfolios within the scope of the
ECL framework and related credit risk
enhancement and mitigation (CREM).
Gross
Maximum credit risk
CREM by type
CREM coverage
Exposure post
CREM
exposure
ECL
Total
Stage 3
Financial
(1)
Property
Other (2)
Total
Stage
3
Total
Stage 3
2021
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
Financial assets
Cash and balances at central banks
176.3
176.3
176.3
Loans - amortised cost
(3)
369.8
3.7
366.1
3.0
41.1
232.7
23.5
297.3
2.7
68.8
0.3
Personal
(4)
207.4
1.9
205.5
1.6
1.3
192.6
193.9
1.5
11.6
0.1
Wholesale
(5)
162.4
1.8
160.6
1.4
39.8
40.1
23.5
103.4
1.2
57.2
0.2
Debt securities
44.9
44.9
44.9
Total financial assets
591.0
3.7
587.3
3.0
41.1
232.7
23.5
297.3
2.7
290.0
0.3
Contingent liabilities and commitments
Personal
(6,7)
40.4
40.4
0.3
0.5
4.9
5.4
35.0
0.3
Wholesale
87.5
0.1
87.4
0.3
3.2
7.9
3.9
15.0
0.1
72.4
0.2
Total off-balance sheet
127.9
0.1
127.8
0.6
3.7
12.8
3.9
20.4
0.1
107.4
0.5
Total exposure
718.9
3.8
715.1
3.6
44.8
245.5
27.4
317.7
2.8
397.4
0.8
2020
Financial assets
Cash and balances at central banks
122.7
122.7
122.7
Loans - amortised cost
(3)
372.4
6.0
366.4
3.8
38.6
232.7
23.7
295.0
3.3
71.4
0.5
Personal
(4)
204.2
2.4
201.8
2.1
0.3
189.5
189.8
1.9
12.0
0.2
Wholesale
(5)
168.2
3.6
164.6
1.7
38.3
43.2
23.7
105.2
1.4
59.4
0.3
Debt securities
53.8
53.8
53.8
Total financial assets
548.9
6.0
542.9
3.8
38.6
232.7
23.7
295.0
3.3
247.9
0.5
Contingent liabilities and commitments
Personal
(6,7)
39.0
39.0
0.3
4.1
4.1
34.9
0.3
Wholesale
94.6
0.2
94.4
0.6
3.3
7.6
4.6
15.5
0.1
78.9
0.5
Total off-balance sheet
133.6
0.2
133.4
0.9
3.3
11.7
4.6
19.6
0.1
113.8
0.8
Total exposure
682.5
6.2
676.3
4.7
41.9
244.4
28.3
314.6
3.4
361.7
1.3
(1)
Includes cash and securities
collateral.
(2)
Includes guarantees, charges over trade debtors, ot
her asset finance related physical collateral as well as the amount by which credit risk exposure is reduced through netting
arrangements, mainly cash management pooling, which give
NatWest Group a legal right to set off the financial asset against a financial liability due to the same counterparty.
(3)
NatWest Group holds collateral in resp
ect of i
ndividual loans
– amortised cost to banks and customers. This collateral includes mortgages over property (both personal and
commercial); charges over business assets such as plant and equipment; inventories and trade d
ebtors; and guarantees of lending from parties other than the borrower. NatWest
Group obtains collateral in the form of securities in reverse repurchase agreements. Collatera
l values are capped at the value of the loan.
(4)
Stage 3 mortgage exposures have relatively limited uncovered exposure
reflecting the security held. On unsecured credit cards and other personal borrowing, the residual
uncovered amount reflects historical experience of continued cash
recovery post default through ongoing engagement with customers.
(5)
Stage 3 exposures post cred
it risk enhancement and mitigation in Wholesale mainly represent enterprise value and the impact of written down collatera
l values; an individual
assessment to determine ECL will consider multiple scenarios a
nd in some instances allocate a probability weighting to a collateral value in excess of the written down value.
(6)
£0.3 billion (2020
£0.3 billion) Personal Stage 3 balances primarily relate to loan commitments, the draw down of which is effectively prohibited
.
(7)
The Personal gross exposure value includes £11.8 billion (2020
£10.0 billion) in respect of pipeline mortgages wh
ere a committed offer has been made to a customer but where
the funds have not yet been drawn down. When drawn down, the exp
osure would be covered by a security over the borrower’s property.
Risk and capital m
anageme
nt continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
227
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Personal portfolio
(audited)
Disclosures in the Personal port
folio section include drawn exposure (g
ross of provisions).
2021
2020
Retail
Private
RBS
Ulster
Retail
Private
RBS
Ulster
Personal lending
Banking
Banking
International
Bank RoI
Total
Banking
Banking
International
Bank RoI
Total
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Mortgages
172,707
12,781
2,444
6,164
194,096
163,107
10,910
2,517
13,678
190,212
Of which:
Owner occupied
158,059
11,219
1,597
5,563
176,438
148,614
9,601
1,676
12,781
172,672
Buy-to-let
14,648
1,562
847
601
17,658
14,493
1,309
841
897
17,540
Interest only - variable
4,348
4,889
346
120
9,703
5,135
4,375
347
159
10,016
Interest only - fixed
14,255
5,957
209
3
20,424
13,776
4,758
233
10
18,777
Mixed
(1)
8,616
1
17
34
8,668
7,321
1
20
56
7,398
Impairment provisions
(2)
429
7
8
318
762
483
5
9
499
996
Other personal lending
(3)
10,829
1,974
305
218
13,326
11,116
1,613
279
276
13,284
Impairment provisions
(2)
1,140
19
2
11
1,172
1,348
20
1
15
1,384
Total personal lending
183,536
14,755
2,749
6,382
207,422
174,223
12,523
2,796
13,954
203,496
Mortgage LTV ratios
-
Total portfolio
54%
59%
57%
50%
54%
56%
58%
57%
59%
57%
- Stage 1
54%
59%
56%
48%
54%
55%
58%
57%
57%
55%
- Stage 2
52%
59%
62%
57%
52%
66%
61%
64%
65%
66%
- Stage 3
49%
64%
77%
56%
53%
53%
64%
75%
67%
60%
- Buy-to-let
50%
57%
53%
52%
51%
52%
56%
53%
59%
53%
- Stage 1
50%
58%
53%
51%
51%
51%
56%
53%
55%
52%
- Stage 2
52%
55%
50%
56%
52%
60%
59%
53%
69%
61%
- Stage 3
51%
53%
60%
66%
56%
56%
54%
61%
74%
62%
Gross new mortgage lending
(4)
35,290
2,874
340
40
38,544
30,551
2,148
249
910
33,858
Of which:
Owner occupied
33,630
2,583
206
40
36,459
29,608
1,922
167
908
32,605
Weighted average LTV
66%
65%
67%
57%
66%
69%
66%
66%
74%
69%
Buy-to-let
1,660
292
134
2,086
943
227
82
2
1,254
Weighted average LTV
62%
65%
63%
53%
63%
62%
62%
63%
54%
62%
Interest only - variable rate
25
832
37
894
81
1,082
7
1,170
Interest only - fixed rate
2,388
1,563
36
3,987
1,501
695
35
2,231
Mixed
(1)
2,256
7
2,263
1,630
2
1,632
Mortgage forbearance
Forbearance flow
316
19
4
50
389
550
50
10
127
737
Forbearance stock
1,156
3
8
944
2,111
1,293
18
10
1,627
2,948
Current
727
5
616
1,348
648
13
9
1,070
1,740
1-3 months in arrears
146
2
1
58
207
360
3
105
468
> 3 months in arrears
283
1
2
270
556
285
2
1
452
740
(1)
Includes accounts which have an
interest only
sub-a
ccount and a capital and interest sub-account to provide a more comprehensive view of interest only exposures.
(2)
Retail Banking excludes a non-mat
erial amount of provisions held on relatively small legacy portfolios.
(3)
Comprises unsecured lend
ing except for Private Banking, which includes both secured and unsecured lending. It excludes loans that are commercial in nature.
(4)
Retail Banking excludes additiona
l lending to existing customers.
The mortgage portfolio grew strongly during 202
1, assisted
by the UK stamp duty reduction.
LTV ratios improved as high demand increased house p
rices
during the year.
The existing mortgage stock and new business were closely
monitored against agreed risk appetite par
ameters. These
included LTV ratios, buy-to-let
concentrations, new-build
concentrations and credit quality. Le
nding criteria were
cautiously relaxed during the ye
ar as demand returned and
economic conditions improved.
Demand for mortgages was mostly within owner occupie
r
mortgages, consequently there has been a reducti
on in the
proportion of interest only and buy
-to-let mortgages.
In th
e Retail Ba
nking mortgage portfolio, 37% of the stock of
lending was in Greater London and the South East
(2020 –
37%). The weighted average loan-to-value for
these regions
was 53% (2020 – 54%) compared to all regions
54%.
In th
e Retail Ba
nking mortgage portfolio, 92% of customer
balances were on fixed rates (6
2% of these on five-year
deals). In addition, 97% of all new mortgage completi
ons
were fixed rate deals (56% of these on five-y
ear deals).
Forbearance flows and arrears levels remained low
relative
to historic norms, with custome
rs able to utilise payment
holidays during the first half of the year.
Unsecured lending overall reduced during the yea
r as
demand was subdued with lowe
r levels of consumer
spending.
As noted previously, the improved economic outlook
including a more positive forecast on unemploy
ment and
house prices, resulted in reduced ECL.
Risk and capital m
anageme
nt continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
228
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Personal portfolio
(audited)
Mortgage LTV distribution by stage
The table below shows gross mortgage lending and
related ECL by LTV band. Mortgage lending no
t within the scope of IFRS 9
ECL reflected portfolios carried at fair value.
Mortgages
ECL provisions
ECL provisions covera
ge (2)
Not within
Of
IFRS 9
which;
Retail Banking
ECL
gross new
Stage 1
Stage 2
Stage 3
scope
Total
lending
Stage 1
Stage 2
Stage 3
Total (1)
Stage 1
Stage 2
Stage 3
Total
2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
%
%
%
%
≤50%
61,233
4,548
644
63
66,488
5,845
7
60
140
207
1.3
21.7
0.3
>50% and ≤70%
68,271
4,674
483
9
73,437
12,397
10
64
84
158
1.4
17.4
0.2
>70% and ≤80%
24,004
1,255
93
1
25,353
10,964
3
18
15
36
1.4
16.1
0.1
>80% and
≤90%
5,983
250
22
1
6,256
4,985
1
8
5
14
3.2
22.7
0.2
>90% and ≤100%
1,125
58
10
1,193
1,098
5
3
8
8.6
30.0
0.7
>100%
14
18
6
38
1
2
3
5.6
33.3
7.9
Total with LTVs
160,630
10,803
1,258
74
172,765
35,289
21
156
249
426
1.4
19.8
0.2
Other
14
1
1
16
1
Total
160,644
10,804
1,259
74
172,781
35,290
21
156
249
426
1.4
19.8
0.2
2020
≤50%
50,170
5,009
554
124
55,857
4,207
4
43
107
154
0.0
0.8
19.4
0.3
>50% and ≤70%
55,263
7,416
488
35
63,202
9,083
7
66
81
154
0.0
0.9
16.5
0.2
>70% and ≤80%
19,994
9,555
141
8
29,698
11,060
7
56
26
89
0.0
0.6
18.5
0.3
>80% and ≤90%
8,029
5,552
52
6
13,639
5,175
3
52
11
66
0.0
0.9
20.3
0.5
>90% and ≤100%
368
137
13
2
520
865
5
3
8
0.1
3.4
26.8
1.6
>100%
48
99
20
2
169
6
5
11
0.0
6.1
25.0
6.5
Total with LTVs
133,872
27,768
1,268
177
163,085
30,390
21
228
233
482
0.0
0.8
18.5
0.3
Other
17
4
1
22
161
1
1
0.1
3.6
71.9
3.3
Total
133,889
27,772
1,269
177
163,107
30,551
21
228
234
483
0.0
0.8
18.5
0.3
Ulster Ban
k RoI
2021
≤50%
2,660
221
274
3,155
13
4
6
138
148
0.2
2.7
50.4
4.7
>50% and ≤70%
1,497
172
128
1,797
16
2
5
59
66
0.1
2.9
46.1
3.7
>70% and ≤80%
484
67
60
611
9
1
2
28
31
0.2
3.0
46.7
5.1
>80% and ≤90%
231
51
55
337
1
1
2
26
29
0.4
3.9
47.3
8.6
>90% and
≤100%
82
26
37
145
1
1
19
20
3.8
51.4
13.8
>100%
33
16
41
90
1
23
24
6.3
56.1
26.7
Total with LTVs
4,987
553
595
6,135
40
8
1
7
293
318
0.2
3.1
49.2
5.2
Other
25
4
29
Total
5,012
553
599
6,164
40
8
1
7
293
318
0.2
3.1
48.9
5.2
2020
≤50%
4,156
504
354
5,014
78
10
24
105
139
0.2
4.8
29.7
2.8
>50% and ≤70%
3,453
453
230
4,136
194
8
2
3
66
97
0.2
5.1
28.7
2.3
>70% and ≤80%
1,569
232
114
1,915
346
4
1
2
40
56
0.3
5.2
35.1
2.9
>80% and ≤90%
1,214
190
105
1,509
286
3
1
1
40
54
0.2
5.8
38.1
3.6
>90% and ≤100%
372
145
88
605
1
1
9
40
50
0.3
6.2
45.5
8.3
>100%
183
151
165
499
5
1
1
2
90
103
0.5
7.9
54.5
20.6
Total with LTVs
10,947
1,675
1,056
13,678
910
27
91
381
499
0.2
5.4
36.1
3.6
(1)
Excludes a non-material amount of provisions held on relatively small legacy
portfolios.
(2)
ECL provisions coverage is ECL provisions divided by mortgages.
ECL coverage rates increased through the LTV bands
with both Retail Banking and Ul
ster Bank RoI having only
limited exposures in the highest L
TV bands. The
relatively high coverage level in
the lowest LTV band for
Retail Banking included the effect of time-discoun
ting on
expected recoveries and reflects a modell
ing approach
that captures losses expected from both reposs
ession
and also other recovery action.
The improved economic outlook resulted in decreased
account level IFRS 9 PDs. Consequently, compa
red to the
2020 year end, a lower proportion of accounts exhibi
ted
a SICR with an associated migration of exposu
res from
Stage 2 into Stage 1.
Risk and capital m
anageme
nt continued
NatWest Group
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229
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Personal portfolio
(audited)
Retail Banking mortgage LTV distri
bution by region
The table below shows gross mortgage lending by
LTV band for Retail Banking, by geographical region.
Weighted
≤50%
50%
≤80%
80%
≤100%
>100%
Total
average LTV
Other
Total
Total
2021
£m
£m
£m
£m
£m
%
£m
£m
%
South East
13,160
18,298
886
1
32,345
53
3
32,348
19
Greater London
13,308
16,716
1,477
1
31,502
53
3
31,505
18
Scotland
4,493
6,529
559
2
11,583
54
1
11,584
7
North West
6,598
9,212
654
3
16,467
53
2
16,469
10
South West
6,140
8,619
499
1
15,259
53
2
15,261
9
West Midlands
4,323
7,449
553
1
12,326
55
1
12,327
6
East of England
7,467
11,679
820
1
19,967
54
2
19,969
12
Rest of the UK
10,937
20,278
2,001
26
33,242
56
2
33,244
19
Total
66,426
98,780
7,449
36
172,691
54
16
172,707
100
2020
South East
10,980
17,217
2,365
4
30,566
56
5
30,571
19
Greater London
13,044
14,505
1,638
2
29,189
52
5
29,194
18
Scotland
3,594
6,636
1,148
1
11,379
58
1
11,380
7
North West
4,849
9,745
1,402
3
15,999
58
3
16,002
10
South West
5,086
8,551
882
3
14,522
55
2
14,524
9
West Midlands
3,366
7,080
1,265
4
11,715
59
1
11,716
7
East of England
6,487
10,294
1,588
2
18,371
56
2
18,373
11
Rest of the UK
8,451
18,869
3,873
151
31,344
60
3
31,347
19
Total
55,857
92,897
14,161
170
163,085
56
22
163,107
100
Commercial real estate (CRE)*
The CRE portfolio comprises exposures to entities involved in
the development of, or investme
nt in, commercial and residential
properties (including house builders but e
xcluding housing associations, const
ruction and the building materials sub-sector).
The
sector is reviewed regularly by senior executive co
mmittees. Reviews include portfolio c
redit quality, capital consumption and
control frameworks. The CRE tables in this secti
on include information on exposures which a
re out of scope of ECL calculations or
part of disposal groups.
2021
2020
By geography and sub-sector (1)
UK
RoI
Other
Total
UK
R
oI
Other
Total
£m
£m
£m
£m
£
m
£m
£m
£m
Investment
Residential
(2)
4,422
341
19
4,782
4,507
360
14
4,881
Office
(3)
3,037
190
10
3,237
3,386
226
28
3,640
Retail
(4)
4,207
81
4,288
5,423
6
8
118
5,609
Industrial
(5)
2,760
13
106
2,879
2,773
1
8
202
2,993
Mixed/other
(6)
1,185
113
50
1,348
2,688
154
74
2,916
15,611
738
185
16,534
18,777
826
436
20,039
Development
Residential
(2)
1,775
76
2
1,853
2,685
200
3
2,888
Office
(3)
79
33
112
123
3
0
153
Retail
(4)
48
48
126
126
Industrial
(5)
67
1
68
125
2
127
Mixed/other
(6)
20
2
22
24
2
26
1,989
112
2
2,103
3,083
234
3
3,320
Total
17,600
850
187
18,637
21,860
1,060
439
23,359
*Not within audi
t scope.
(1)
Geograp
hical splits are based on country of collateral risk.
(2)
Properties
including houses, flats and student accommodation.
(3)
Properties
including offices in central business districts, regional headquarters and business parks.
(4)
Properties
including high street retail, shopping centres, restaurants, bars and gyms.
(5)
Properties
including distribution centres, manufacturing and warehouses.
(6)
Properties
that do not fall within the other categories above. Mixed generally relates to a mixture of retail/office with resident
ial.
Risk and capital m
anageme
nt continued
NatWest Group
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230
Financial statements
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Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Commercial real estate (CRE)
CRE LTV distribution by stage
(audited)
The table below shows CRE cu
rrent exposure and related ECL by LT
V band.
Current expos
ure (gross of provisions)
(1,2)
ECL
provisions
ECL provisions covera
ge
(4)
Not within
IFRS 9 ECL
Stage 1
Stage 2
Stage 3
scope (3)
Total
Stage
1
Stage 2
Stage 3
Total (1)
Sta
ge 1
Stage 2
Stage
3
Tota
l
2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
%
%
%
%
≤50%
6,767
388
34
268
7,457
5
7
9
21
0.1
1.8
26.5
0.3
>50% and ≤70%
4,367
470
46
469
5,352
3
13
20
36
0.1
2.8
43.5
0.7
>70% and ≤100%
377
192
1
27
9
705
9
32
41
4.7
25.2
5.8
>100%
215
7
86
4
312
2
28
30
28.6
32.6
9.6
Total with LTVs
11,726
1,057
29
3
750
13,826
8
31
89
128
0.1
2.9
30.4
0.9
Total portfolio
average LTV%
48%
58%
88%
52%
50%
Other
(5)
2,271
293
61
83
2,708
4
13
28
45
0.2
4.4
45.9
1.7
Development
(6)
1,736
228
62
77
2,103
3
6
34
43
0.2
2.6
54.8
2.0
Total
15,733
1,578
41
6
910
18,637
15
50
151
216
0.1
3.2
36.3
1.2
2020
≤50%
4,918
4,538
13
8
9,594
46
145
24
215
0.9
3.2
17.4
2.2
>50% and ≤70%
2,815
3,266
22
6
6,307
32
112
63
207
1.1
3.4
27.9
3.3
>70% and ≤100%
169
283
1
24
576
3
23
51
77
1.8
8.1
41.1
13.4
>100%
50
64
29
5
409
6
113
119
9.4
38.3
29.1
Total with LTVs
7,952
8,151
78
3
16,886
81
286
251
618
1.0
3.5
32.1
3.7
Total portfolio
average LTV%
45%
47%
93%
48%
Other
(5)
1,776
511
1
59
707
3,153
6
40
93
139
0.3
7.8
58.5
5.7
Development
(6)
1,362
1,767
16
1
30
3,320
15
58
70
143
1.1
3.3
43.5
4.3
Total
11,090
10,429
1,103
737
23,359
102
384
414
900
0.9
3.7
37.5
4.0
(1)
Comprises gross lending, interest rate hedging derivatives and oth
er assets carried at fair value that are managed as part of
the overall CRE portfolio.
(2)
The exposure in Stage 3 mainly relates to legacy assets
.
(3)
Includes exposures relating to non
-
modelled portfolios and other exposures carried at fair value, including derivatives.
(4)
ECL provisions coverage is ECL provisions divided by
current exposure.
(5)
Relates mainly to business banking, rate risk manag
ement products and unsecured corporat
e lending.
(6)
Relates to the development of commercial and residential properties. LTV
is not a meaningful measure for this type of lending
activity.
Overall
– The majority of the CRE portfolio was located
and
managed in the UK. Business appetite and strategy w
as
aligned across NatWest Group.
2021 trends
– The continued reduction in the
real estate
exposure was a consequence of active portfolio
management to rebalance the size and comp
osition of the
CRE portfolio. In addition, customer appeti
te to borrow was
muted, particularly amongst larger customers. At
a sub-
sector level, the residential market had a positive out-tu
rn
over the year; the retail sector e
xhibited mixed performance
in line with changing consumer
habits; the industrial market
performed very strongly; with uncertainty con
tinuing in the
office sub-sector as occupiers moved
to a more flexible way
of working.
Credit quality
– NatWest Group
entered the COVID-19
period with a conservatively positioned CR
E portfolio, which
helped to mitigate the effect of COVID-19. The majori
ty of
the defaults during 2021 were in the retail sector,
particularly in the fashion-led shopping centre sub-secto
r.
NatWest Group completed a strategic sale of
a portfolio of
these loans during 2021. Customers expe
rienced reduced
rent collections during COVID-19 albeit rental paymen
ts
have now normalised. Outside of retail, the
re was limited
distress as noted, uncertainty still remains, pa
rticularly in
relation to the office sub-sector and
the portfolio continues
to be actively reviewed and ma
naged.
Risk appetite
– Lending appetite
was gradually and
selectively increased by sub-sec
tor, particularly towards the
end of 2021, albeit these remain below pre-COVI
D-19 levels.
Risk and capital m
anageme
nt continued
NatWest Group
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231
Financial statements
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Governance
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Additional information
Financial review
Credit risk – Banking activities continued
Flow statements
(audited)
The flow statements that follow show the main ECL
and related
income statement movements. T
hey also show the changes in
ECL as well as the changes in r
elated financial assets used in
determining ECL. Due to differences
in scope, exposures may
differ from
those reported in other tables, p
rincipally in relation
to exposures in Stage 1 and Stage 2. T
hese differences do not
have a material ECL effect. Other points to note:
Financial assets include treasury liquidity portfolios,
comprising balances at central banks and deb
t securities,
as well as loans. Both modelled and non-modelled p
ortfolios
are included.
Stage transfers (for example, exposures
moving from Stage
1 into Stage 2) are a key feature of
the ECL movements,
with the net re-measurement cost of t
ransitioning to a
worse stage being a primary driver of income s
tatement
charges. Similarly, there is an ECL benef
it for accounts
improving stage.
Changes in risk parameters shows the
reassessment of the
ECL within a given stage, including any ECL ove
rlays and
residual income statement gains or losses
at the point of
write-off or accounting write-d
own.
Other (P&L only items) includes any subsequent changes in
the value of written-down assets
(for example, fortuitous
recoveries) along with other dire
ct write-off items such as
direct recovery costs. Other (P&
L only items) affects the
income statement but does not affe
ct balance sheet ECL
movements.
Amounts written-off represent
the gross asset written-down
against accounts with ECL, including the net
asset write-
down for any debt sale activity.
There were flows from Stage 1 into Stage 3
including
transfers due to unexpected de
fault events. The small
number of write-offs in Stage 1 and Stage 2
reflect the
effect of portfolio debt sales and also stagin
g at the start of
the analysis period.
The effect of any change in pos
t model adjustments during
the year is typically reported under ch
anges in risk
parameters, as are any effects arising fro
m changes to the
underlying models. Refer to the section on Governance
and
post model adjustments for further details.
All movements are captured monthly and
aggregated.
Interest suspended post default is
included within Stage 3
ECL with the movement in the value of su
spended interest
during the year reported under c
urrency translation and
other adjustments.
Stage 1
Stage 2
Stage 3
Total
Financial
Financial
Financial
Financial
assets
ECL
assets
ECL
assets
ECL
assets
ECL
NatWest Group total
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January 2021
446,666
519
81,667
3,081
6,524
2,586
534,857
6,186
Currency translation and other adjustments
(4,111)
(1)
(246)
(6)
48
(89)
(4,309)
(96)
Transfers from Stage 1 to Stage 2
(35,307)
(160)
35,307
160
Transfers from Stage 2 to Stage 1
62,702
1,322
(62,702)
(1,322)
Transfers to Stage 3
(390)
(2)
(2,628)
(285)
3,018
287
Transfers from Stage 3
241
21
1,352
188
(1,593)
(209)
Net re-measurement of ECL on stage transfer
(1,114)
869
310
65
Changes in risk parameters
(343)
(566)
244
(665)
Other changes in net exposure
84,331
84
(15,657)
(496)
(1,795)
(148)
66,879
(560)
Other (P&L only items)
(3)
5
(120)
(118)
Income statement (releases)/charges
(1,376)
(188)
286
(1,278)
Transfers to disposal groups
(7,954)
(
24)
(1,511)
(120)
(113)
(22)
(9,578)
(166)
Amounts written-off
(25)
(25)
(851)
(851)
(876)
(876)
Unwinding of discount
(82)
(82)
At 31 December 2021
546,178
302
35,557
1,478
5,238
2,026
586,973
3,806
Net carrying amount
545,876
34,079
3,212
583,167
At 1 January 2020
428,604
322
28,630
752
7,135
2,718
464,369
3,792
2020 movements
18,062
197
53,037
2,329
(611)
(132)
70,488
2,394
At 31 December 2020
446,666
519
81,667
3,081
6,524
2,586
534,857
6,186
Net carrying amount
446,147
78,586
3,938
528,671
Risk and capital m
anageme
nt continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
232
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Flow statements
(audited)
Stage 1
Stage 2
Stage 3
Total
Financial
Financial
Financial
Financial
assets
ECL
assets
ECL
assets
ECL
assets
ECL
Retail Banking - mortgages
£m
£m
£m
£m
£m
£
m
£m
£m
At 1 January 2021
132,390
23
28,079
227
1,291
236
161,760
486
Currency translation and other adjustments
10
10
10
10
Transfers from Stage 1 to Stage 2
(10,957)
(3)
10,957
3
Transfers from Stage 2 to Stage 1
25,468
162
(25,468)
(
162)
Transfers to Stage 3
(17)
(574)
(
19)
591
19
Transfers from Stage 3
11
343
25
(354)
(
25)
Net re-measurement of ECL on stage transfer
(156)
117
9
(30)
Changes in risk parameters
(1)
(9)
58
48
Other changes in net exposure
13,071
(1)
(2,589)
(
27)
(263)
(
19)
10,219
(47)
Other (P&L only items)
(1)
1
(26)
(26)
Income statement (releases)/charges
(159)
82
22
(55)
Amounts written-off
(8)
(8)
(8)
(8)
Unwinding of discount
(30)
(30)
At 31 December 2021
159,966
24
10,748
155
1,267
250
171,981
429
Net carrying amount
159,942
10,593
1,017
171,552
At 1 January 2020
135,625
12
10,283
86
1,289
215
147,197
313
2020 movements
(3,235)
11
17,796
141
2
21
14,563
173
At 31 December 2020
132,390
23
28,079
227
1,291
236
161,760
486
Net carrying amount
132,367
27,852
1,055
161,274
Despite the strong portfolio growth during 20
21, ECL levels
for mortgages reduced during the same period. The
decrease in ECL was primarily a result of reduced P
Ds and
LGDs reflecting the improved economic outlook
and stable
portfolio performance. This resulted in lowe
r levels of SICR
identification and ECL requirement.
More specifically, the reduced PDs alongside
muted
portfolio deterioration resulted in a net
migration of assets
from Stage 2 into Stage 1, with
an associated decrease
from lifetime ECL to a 12 month ECL.
With various customer support s
chemes available and the
revised economic outlook, Stage 3
ECL remained stable as
new inflows remaining subdued.
The relatively small ECL
cost for net re-measurement on stage transfer inclu
ded the
effect of risk targeted ECL adjustments, when previously in
Stage 2. Refer to the Governance
and post model
adjustments section for further
details.
Write-off occurs once the reposse
ssed property has been
sold and there is a residual shortfall balance re
maining
outstanding. This would typically be within five yea
rs from
default but can be longer. Given the moratoriu
m on
repossession activity until later in 20
21, write-offs remained
at a subdued level.
Risk and capital m
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nt continued
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Flow statements
(audited)
Stage 1
Stage 2
Stage 3
Total
Financial
Financial
Financial
Financial
assets
ECL
assets
ECL
assets
ECL
assets
ECL
Retail Banking - credit cards
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January 2021
2,250
52
1,384
220
114
75
3,748
347
Currency translation and other adjustments
(1)
(1)
(1)
(1)
Transfers from Stage 1 to Stage 2
(951)
(48)
951
48
Transfers from Stage 2 to Stage 1
1,119
143
(1,119)
(143)
Transfers to Stage 3
(17)
(84)
(35)
101
35
Transfers from Stage 3
9
5
(9)
(5)
Net re-measurement of ECL on stage transfer
(88)
184
28
124
Changes in risk parameters
(19)
(65)
8
(76)
Other changes in net exposure
339
18
(194)
(73)
(41)
(2)
104
(57)
Other (P&L only items)
(4)
(4)
Income statement (releases)/charges
(89)
46
30
(13)
Amounts written-off
(73)
(73)
(73)
(73)
Unwinding of discount
(5)
(5)
At 31 December 2021
2,740
58
947
141
91
60
3,778
259
Net carrying amount
2,682
806
31
3,519
At 1 January 2020
2,804
38
1,246
131
127
88
4,177
257
2020 movements
(554)
14
138
89
(13)
(13)
(429)
90
At 31 December 2020
2,250
52
1,384
220
114
75
3,748
347
Net carrying amount
2,198
1,164
39
3,401
The overall decrease in ECL w
as mainly due to the
reduction in Stage 2 ECL reflecting the improved ec
onomic
outlook and stable portfolio per
formance, causing PDs to
decrease. This resulted in reduce
d levels of SICR
identification and ECL requirement.
More specifically, the reduced PDs alongside
muted
portfolio deterioration resulted in a net
migration of assets
from Stage 2 into Stage 1, with
an associated decrease
from lifetime ECL to a 12 month ECL.
Cards balances remained broadly f
lat compared with the
2020 year end. In line with indu
stry trends in the UK, credit
card balances decreased durin
g the first half of the year
but then increased as lockdown restrictions e
ased and
borrowing demand increased.
With various customer support s
chemes available and the
improved economic outlook, Stage 3 inflows re
mained
subdued and therefore Stage 3 ECL movement
was
minimal.
Charge-off (analogous to partial write-off) typic
ally occurs
after 12 missed payments.
Risk and capital m
anageme
nt continued
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Flow statements
(audited)
Stage 1
Stage 2
Stage 3
Total
Financial
Financial
Financial
Financial
assets
ECL
assets
ECL
assets
ECL
assets
ECL
Retail Banking
-
other personal u
nsecured
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January 2021
3,385
59
3,487
450
596
495
7,468
1,004
Currency translation and other adjustments
2
2
2
2
Transfers from Stage 1 to Stage 2
(1,715)
(39)
1,715
39
Transfers from Stage 2 to Stage 1
2,034
164
(2,034)
(164)
Transfers to Stage 3
(10)
(339)
(120)
349
120
Transfers from Stage 3
5
7
96
60
(101)
(67)
Net re-measurement of ECL on stage transfer
(133)
161
111
139
Changes in risk parameters
(18)
(47)
60
(5)
Other changes in net exposure
849
12
(958)
(85)
(79)
(26)
(188)
(99)
Other (P&L only items)
(3)
(3)
Income statement (releases)/charges
(139)
29
142
32
Amounts written
-
off
(138)
(138)
(138)
(138)
Unwinding of discount
(17)
(17)
At 31 December 2021
4,548
52
1,967
294
629
540
7,144
886
Net carrying amount
4,496
1,673
89
6,258
At 1 January 2020
5,417
63
2,250
252
608
518
8,275
833
2020 movements
(2,032)
(4)
1,237
198
(12)
(23)
(807)
171
At 31 December 2020
3,385
59
3,487
450
596
495
7,468
1,004
Net carrying amount
3,326
3,037
101
6,464
The overall decrease in ECL w
as mainly due to the reduction
in Stage 2 ECL reflecting the improved economic ou
tlook
and stable portfolio performance, causing PDs to de
crease.
This resulted in reduced levels of SICR identificati
on and ECL
requirement.
More specifically, the reduced PDs alongside
muted portfolio
deterioration resulted in a net migration of assets f
rom
Stage 2 into Stage 1, with an as
sociated decrease from
lifetime ECL to a 12 month ECL.
In line with industry trends in th
e UK, unsecured balances
reduced, amplifying the ECL reductions wi
thin the portfolio.
This has stabilised as UK lockdown restric
tions have eased
and borrowing demand increase
d.
With various customer support s
chemes available and the
improved economic outlook, Stage 3 inflows re
mained
subdued and therefore Stage 3 ECL movement
was minimal.
Write-off occurs once recovery activity wit
h the customer
has been concluded or there are no further reco
veries
expected, but no later than six years after default.
Risk and capital m
anageme
nt continued
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Credit risk – Banking activities continued
Flow statements
(audited)
Stage 1
Stage 2
Stage 3
Total
Financial
Financial
Financial
Financial
Commercial Banking - commercial
assets
ECL
assets
ECL
assets
ECL
assets
ECL
real estate
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January 2021
17,269
90
10,380
364
1,118
428
28,767
882
Currency translation and other adjustments
(10)
1
(2)
(1)
(1)
(26)
(13)
(26)
Inter-group transfers
Transfers from Stage 1 to Stage 2
(2,687)
(17)
2,687
17
Transfers from Stage 2 to Stage 1
7,872
219
(7,872)
(219)
Transfers to Stage 3
(55)
(327)
(16)
382
16
Transfers from Stage 3
71
2
82
7
(153)
(
9)
Net re-measurement of ECL on s
tage transfer
(176)
41
21
(114)
Changes in risk parameters
(119)
(68)
8
(179)
Other changes in net exposure
(107)
16
(2,746)
(74)
(666)
(54)
(3,519)
(112)
Other (P&L only items)
Income statement (releases)/charges
(279)
(101)
(25)
(405)
Amounts written
-
off
(235)
(235)
(235)
(235)
Unwinding of discount
(4)
(4)
At 31 December 2021
22,353
16
2,202
51
445
145
25,000
212
Net carrying amount
22,337
2,151
300
24,788
At 1 January 2020
25,556
31
2,218
28
895
306
28,669
365
2020 movements
(8,287)
59
8,162
336
223
122
98
517
At 31 December 2020
17,269
90
10,380
364
1,118
428
28,767
882
Net carrying amount
17,179
10,016
690
27,885
Stage 1 and Stage 2 ECL reduc
ed significantly due to the
improvement in the economic outlook, causin
g both PDs
and LGDs to decrease.
The updated economics also resulted in a mig
ration of
assets from Stage 2 into Stage 1 as imp
roved underlying
PDs meant assets no longer met Stage 2 cri
teria.
Flows into Stage 3 remained low as govern
ment support
schemes combined with the economic
recovery, suppressed
a higher level of flows into Stage 3.
The reduction in Stage 3 balances was largely a result
of a
portfolio sale of non-performing exposure.
Performing exposure reduced due to repaymen
ts of existing
borrowing with limited appetite f
or new lending to replace
it.
Risk and capital m
anageme
nt continued
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Credit risk – Banking activities continued
Flow statements
(audited)
Stage 1
Stage 2
Stage 3
Total
Financial
Financial
Financial
Financial
assets
ECL
assets
ECL
assets
ECL
assets
ECL
Commercial Banking - business banking
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January 2021
12,122
41
2,184
145
250
173
14,556
359
Currency translation and other adjustments
(7)
(5)
(7)
(5)
Transfers from Stage 1 to Stage 2
(3,641)
(13)
3,641
13
Transfers from Stage 2 to Stage 1
2,622
144
(2,622)
(144)
Transfers to Stage 3
(75)
(470)
(27)
545
27
Transfers from Stage 3
12
3
38
9
(50)
(12)
Net re-measurement of ECL on stage transfer
(135)
171
38
74
Changes in risk parameters
(11)
(23)
9
(25)
Other changes in net exposure
252
(2)
(498)
(28)
(33)
(5)
(279)
(35)
Other (P&L only items)
(36)
(36)
Income statement (releases)/charges
(148)
120
6
(22)
Amounts written-off
(37)
(37)
(37)
(37)
Unwinding of discount
(10)
(10)
At 31 December 2021
11,292
27
2,273
116
668
178
14,233
321
Net carrying amount
11,265
2,157
490
13,912
At 1 January 2020
6,338
28
767
45
257
200
7,362
273
2020 movements
5,784
13
1,417
100
(
7)
(27)
7,194
86
At 31 December 2020
12,122
41
2,184
145
250
173
14,556
359
Net carrying amount
12,081
2,039
77
14,197
At a total level, exposure remained rela
tively stable with
reduction mainly due to the repayment
of government
scheme debt.
The updated economics resulte
d in an improvement in
underlying credit metrics resulting in migration of exp
osure
from Stage 2 into Stage 1 with
a consequential reduction
from lifetime ECL to a 12 month ECL calculatio
n. However,
the transfer of exposure from Stage 1 in
to Stage 2
outweighed the positive migration and was largely
related
to customers with government s
cheme borrowing.
Flows of defaulted exposure into Stage 3 were mainly a
result of government scheme lending rather th
an
conventional debt. This was refle
cted in the lower ECL
associated with the Stage 3 transf
ers.
The portfolio continued to bene
fit from cash recoveries post
write-off, which are reported as other (P&L only items
).
Write-off occurs once recovery activity wit
h the customer
has been concluded or there are no further reco
veries
expected, but no later than five y
ears after default.
Risk and capital m
anageme
nt continued
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Credit risk – Banking activities continued
Flow statements
(audited)
Stage 1
Stage 2
Stage 3
Total
Financial
Financial
Financial
Financial
assets
ECL
assets
ECL
assets
ECL
assets
ECL
Commercial Banking - other
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January 2021
39,279
139
25,981
1,204
1,249
468
66,509
1,811
Currency translation and other adjustments
(262)
(70)
77
21
(255)
21
Inter-group transfers
105
105
Transfers from Stage 1 to Stage 2
(7,206)
(29)
7,206
29
Transfers from Stage 2 to Stage 1
13,581
350
(13,581)
(
350)
Transfers to Stage 3
(80)
(558)
(
42)
638
42
Transfers from Stage 3
30
6
528
41
(558)
(47)
Net re-measurement of ECL on stage transfer
(306)
160
87
(59)
Changes in risk
parameters
(119)
(286)
(7)
(412)
Other changes in net exposure
1,271
32
(5,003)
(
165)
(386)
(35)
(4,118)
(168)
Other (P&L only items)
1
(8)
(7)
Income statement (releases)/charges
(393)
(290)
37
(646)
Amounts written-off
(195)
(
195)
(195)
(195)
Unwinding of discount
(6)
(6)
At 31 December 2021
46,718
73
14,503
591
825
328
62,046
992
Net carrying amount
46,645
13,912
497
61,054
At 1 January 2020
53,722
94
8,788
143
1,386
516
63,896
753
2020 movements
(14,443)
45
17,193
1,061
(137)
(48)
2,613
1,058
At 31 December 2020
39,279
139
25,981
1,204
1,249
468
66,509
1,811
Net carrying amount
39,140
24,777
781
64,698
The decrease in ECL across Stage 1 and
Stage 2 was
primarily due to improvement in the econo
mic outlook,
causing both PDs and LGDs to reduce.
The updated economics also resulted in the
migration of
assets from Stage 2 into Stage 1 with a conse
quential
decrease from a lifetime ECL to
a 12 month ECL calculation.
For flows into Stage 3, defaults remained suppress
ed,
reflecting both the effect of increased liquidity from
government customer support s
chemes and the improving
economic environment.
Other changes in net exposure
decreased following the
commencement of repayments of governmen
t scheme debt
and strategic reduction in high risk se
ctors.
Risk and capital m
anageme
nt continued
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Credit risk – Banking activities continued
Flow statements
(audited)
Stage 1
Stage 2
Stage 3
Total
Financial
Financial
Financial
Financial
assets
ECL
assets
ECL
assets
ECL
assets
ECL
NatWest Markets
(1)
£m
£m
£
m
£m
£m
£m
£m
£m
At 1 January 2021
33,327
12
1,671
49
168
132
35,166
193
Currency translation and other adjustments
(799)
(38)
(1)
(4)
(9)
(841)
(10)
Inter-group transfers
(105)
(105)
Transfers from Stage 1 to Stage 2
(881)
(1)
881
1
Transfers from Stage 2 to Stage 1
1,762
9
(1,762)
(9)
Transfers to Stage 3
(1)
1
Net re-measurement of ECL on stage transfer
(7)
4
(3)
Changes in risk parameters
(7)
(9)
(2)
(18)
Other changes in net exposure
79
(530)
(8)
(27)
(3)
(478)
(11)
Other (P&L only items)
1
(4)
(3)
Income statement (releases)/charges
(14)
(12)
(9)
(35)
Amounts written-off
(24)
(24)
(43)
(43)
(67)
(67)
At 31 December 2021
33,383
6
197
3
95
75
33,675
84
Net carrying amount
33,377
194
20
33,591
At 1 January 2020
32,892
10
188
5
183
131
33,263
146
2020 movements
435
2
1,
483
44
(15)
1
1,
903
47
At 31 December 2020
33,327
12
1,671
49
168
132
35,166
193
Net carrying amount
33,315
1,622
36
34,973
(1)
Reflects the NatWest Markets segment and includes NWM N.V..
Consistent with other Wholesale portfolios, Stage 1 an
d
Stage 2 ECL reduced due to the
improved economic
outlook which led to a reductio
n in underlying PDs and
LGDs.
The Stage 2 population reduce
d materially with the
improved economic outlook improving c
redit metrics and
resulting in migration of assets into Sta
ge 1.
Stage 1
Stage 2
Stage 3
Total
Financial
Financial
Financial
Financial
assets
ECL
assets
ECL
assets
ECL
assets
ECL
Ulster Bank RoI - mortgages
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January 2021
10,919
27
1,682
91
1,061
381
13,662
499
Currency translation and other adjustments
(342)
(1)
(72)
(4)
(57)
(55)
(471)
(60)
Transfers from Stage 1 to Stage 2
(488)
(2)
488
2
Transfers from Stage 2 to Stage 1
1,164
54
(1,164)
(
54)
Transfers to Stage 3
(8)
(65)
(7)
73
7
Transfers from Stage 3
19
2
172
33
(191)
(35)
Net re-measurement of ECL on stage transfer
(51)
(3)
10
(44)
Changes in risk parameters
(8)
(18)
82
56
Other changes in net exposure
(618)
(1)
(109)
(2)
(115)
(3)
(842)
(6)
Other (P&L only items)
(1)
(12)
(13)
Income statement (releases)/charges
(61)
(23)
77
(7)
Transfers to disposal groups
(1)
(5,610)
(
13)
(373)
(
20)
(95)
(14)
(6,078)
(47)
Amounts written-off
(1)
(1)
(72)
(72)
(73)
(73)
Unwinding of discount
(7)
(7)
At 31 December 2021
5,036
7
558
17
604
294
6,198
318
Net carrying amount
5,029
541
310
5,880
At 1 January 2020
10,603
11
1,084
30
1,875
581
13,562
622
2020 movements
316
16
598
61
(
814)
(200)
100
(123)
At 31 December 2020
10,919
27
1,682
91
1,061
381
13,662
499
Net carrying amount
10,892
1,591
680
13,163
(1)
Reflects balance of disposal groups at 1 January 2021
.
The reduction in balances across
all stages was primarily a
result of the agreed sale of mortgages to Pe
rmanent TSB
p.l.c..
A further reduction in Stage 2 balances was mainly due
to
the cessation of the collective migration of high-
risk
mortgage accounts which were in receipt of COV
ID-19
payment support during 2020 due to post-payment sup
port
performance. Economic uncertainty post model a
djustments
also decreased significantly during the year.
Like previous years, portfolio improvements an
d debt sale
activity resulted in deceases in
the Stage 3 portfolio.
Write-offs were mainly a result of
the execution of the final
tranche of the 2019 debt sale.
Risk and capital m
anageme
nt continued
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Credit risk – Banking activities continued
Stage 2 decomposition – arrears status and contributi
ng factors
The
tables
below show Stage 2 decomposition for the Personal and Wholesale po
rtfolios.
UK mortgages
RoI mortgages
Credit cards
Other
Total
Loans
ECL
Loans
ECL
Loans
ECL
Loans
ECL
Loans
ECL
2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Personal
Currently >30 DPD
397
9
38
3
11
6
50
13
496
31
Currently <=30 DPD
10,593
148
515
14
922
135
1,897
286
13,927
583
- PD deterioration
2,400
56
58
4
549
96
970
174
3,977
330
- PD persistence
3,088
38
21
1
270
23
770
91
4,149
153
- Other driver (adverse credit, forbearance etc)
5,105
54
436
9
103
16
157
21
5,801
100
Total Stage 2
10,990
157
553
17
933
141
1,947
299
14,423
614
2020
Personal
Currently >30 DPD
426
19
109
11
10
6
75
25
620
61
Currently <=30 DPD
27,477
209
1,559
80
1,365
219
3,331
427
33,732
935
- PD deterioration
13,136
163
664
42
901
167
2,242
354
16,943
726
-
PD persistence
9,977
22
46
2
350
32
966
57
11,339
113
- Other driver (adverse credit, forbearance etc)
4,364
24
849
36
114
20
123
16
5,450
96
Total Stage 2
27,903
228
1,668
91
1,375
225
3,406
452
34,352
996
The improved economic outlook, including fo
recast
increases in unemployment, resulted in dec
reased account
level IFRS 9 PDs during the year. Consequently, co
mpared
to 2020, a smaller proportion of accounts ex
hibited
significant PD deterioration causing Stage 2 e
xposures to
decrease significantly and increase the proportion of cases
in Stage 2 for other reasons.
During the year, a subset of cus
tomers who had accessed
payment holiday support and where thei
r risk profile was
identified as relatively high risk,
were collectively migrated
into Stage 2. For mortgages, in Retail Banking,
approximately £0.8 billion of exposures were colle
ctively
migrated from Stage 1 into Stage 2. T
he impact of
collective migrations on unsecured lending was much
more
limited.
As expected, ECL coverage was higher in accoun
ts that
were more than 30 days past du
e than those in Stage 2 for
other reasons.
Property
Corporate
Financial institutions
Sovereign
Total
Loans
ECL
Loans
ECL
Loans
ECL
Loans
ECL
Loans
ECL
2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Wholesale
Currently >30 DPD
239
3
390
8
19
648
11
Currently <=30 DPD
2,862
108
15,2
14
705
713
39
121
1
1
8,910
853
- PD deterioration
896
57
10,391
549
595
36
84
1
11,966
643
- PD persistence
139
8
552
32
6
1
698
40
- Other driver (forbearance, RoCL etc)
1,827
43
4,271
124
112
3
36
6,246
170
Total Stage 2
3,101
111
15,6
04
713
732
39
121
1
1
9,558
864
2020
Wholesale
Currently >30 DPD
136
6
215
28
110
461
34
Currently <=30 DPD
12,885
501
27,501
1,459
3,514
90
204
1
44,104
2,051
- PD deterioration
11,765
450
23,268
1,229
3,182
85
97
38,312
1,764
-
PD persistence
162
5
623
20
7
792
25
- Other driver (forbearance, RoCL etc)
958
46
3,610
210
325
5
107
1
5,000
262
Total Stage 2
13,021
507
27,716
1,487
3,624
90
204
1
44,565
2,085
The improved economic outlook, including u
pgrades in GDP
and commercial real estate valu
ations, resulted in a
reduction of IFRS 9 PDs. Conse
quently, compared to 2020,
a large proportion of exposure no longe
r exhibited a SICR
and migrated back into Stage 1
resulting in a reduction in
Stage 2 exposure.
PD deterioration remained the
primary trigger for
identifying a SICR and Stage 2
treatment, although there
was also an increase in arrears and other drivers.
The increase in arrears greater than 30 days was
partially a
result of the commencement of payments on gover
nment
scheme debt with some custome
rs unable to make
scheduled repayments.
There was a decrease in flows on to the Risk of Credi
t Loss
framework. At a total level, exposure on the Risk of
Credit
Loss framework remained above pre-COVI
D-19 levels.
Risk and capital m
anageme
nt continued
NatWest Group
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Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Stage 2 decomposition – by a significant in
crease in credit risk trigger
UK mortgages
RoI mortgages
Credit cards
Other
Total
2021
£m
%
£m
%
£m
%
£m
%
£m
%
Personal trigger
(1)
PD movement
2,707
24.6
83
14.9
560
60.1
1,008
51.8
4,358
30.2
PD persistence
3,103
28.2
21
3.8
270
28.9
771
39.6
4,165
28.9
Adverse credit bureau recorded with credi
t
reference agency
3,657
33.3
60
6.4
73
3.7
3,790
26.3
Forbearance
support provided
178
1.6
6
1.1
2
0.2
28
1.4
214
1.5
Customers in collections
82
0.8
33
6.0
3
0.3
15
0.8
133
0.9
Collective SICR and other reasons
(2)
1,197
10.9
409
74.0
38
4.1
46
2.4
1,690
11.7
Days past due >30
66
0.6
1
0.2
6
0.3
73
0.5
10,990
100
553
100
933
100
1,947
100
14,423
100
2020
Personal trigger
(1)
PD movement
13,520
48.4
751
45.0
911
66.2
2,310
67.8
17,492
51.0
PD persistence
9,977
35.8
46
2.8
350
25.5
968
28.4
11,341
33.0
Adverse credit bureau recorded with credi
t
reference agency
2,936
10.5
51
3.7
46
1.4
3,033
8.8
Forbearance support provided
138
0.5
7
0.4
1
0.1
9
0.3
155
0.5
Customers in
collections
131
0.5
30
1.8
2
0.1
14
0.4
177
0.5
Collective SICR and other reasons
(2)
1,165
4.2
832
49.9
60
4.4
55
1.6
2,112
6.1
Days past due >30
36
0.1
2
0.1
4
0.1
42
0.1
27,903
100
1,668
100
1,375
100
3,406
100
34,352
100
For the notes to this table refer to the following pa
ge.
The improved economic outlook, including
a more optimistic
forecast for unemployment, resulted in dec
reased account
level IFRS 9 PDs. Consequently,
compared to 2020, a
smaller proportion of accounts e
xhibited significant PD
deterioration at 31 December 20
21.
Since the 2020 year end, large populations of Sta
ge 2 were
migrated into Stage 1 reflecting
continued reductions in PDs
as a result of the improved economic outlook
alongside
stable portfolio performance during the year.
However, a subset of customer
s who had accessed
payment holiday support, and where thei
r risk profile was
identified as relatively high risk,
were collectively migrated
into Stage 2. In Retail Banking (primarily mo
rtgages),
approximately £0.8 billion of exposures were colle
ctively
migrated from Stage 1 into Stage 2. T
he effect of collective
migrations on unsecured lending was much more li
mited.
PD movement made up a smalle
r proportion of Stage 2 for
UK mortgages than at the 2020 ye
ar end, supporting the
use of the collective SICR migration approach desc
ribed
above.
Risk and capital m
anageme
nt continued
NatWest Group
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Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Stage 2 decomposition – by a significant in
crease in credit risk trigger continued
Property
Corporate
Financial institutions
Sovereign
Total
2021
£m
%
£m
%
£m
%
£m
%
£m
%
Wholesale trigger
(1)
PD movement
942
30.3
10,553
67.7
595
81.3
84
69.4
12,174
62.2
PD persistence
139
4.5
553
3.5
6
0.8
1
0.8
699
3.6
Risk of Credit Loss
962
31.0
2,626
16.8
71
9.7
34
28.1
3,693
18.9
Forbearance support provided
101
3.3
489
3.1
6
0.8
596
3.0
Customers in collections
27
0.9
88
0.6
1
0.1
116
0.6
Collective SICR and other reasons
(2)
762
24.6
1,189
7.6
35
4.8
2
1.7
1,988
10.2
Days past due >30
168
5.4
106
0.7
18
2.5
292
1.5
3,101
100
15,604
100
732
100
121
100
19,558
100
2020
Wholesale trigger
(1)
PD movement
11,849
91.1
23,403
84.3
3,183
87.9
97
47.6
38,532
86.6
PD persistence
16
2
1.2
624
2.3
7
0.2
793
1.8
Risk of Credit Loss
394
3.0
2,106
7.6
66
1.8
39
19.1
2,605
5.8
Forbearance support provided
73
0.6
133
0.5
27
0.7
233
0.5
Customers in collections
30
0.2
115
0.4
1
146
0.3
Collective SICR and other reasons
(2)
462
3.5
1,262
4.6
231
6.4
68
33.3
2,023
4.5
Days past due >30
51
0.4
73
0.3
109
3.0
233
0.5
13,021
100
27,716
100
3,624
100
204
100
44,565
100
(1)
The table is prepared on a
hierarchical basis from top to bottom, for example, accounts with PD deterioration may also trigger backstop(s) but are only
reported under PD
deterioration.
(2)
Includes customers where a PD assessment cannot be undertaken due to
missing PDs.
PD deterioration continued to be the primary trigge
r of
migration of exposures from St
age 1 into Stage 2. As the
economic outlook improved during 202
1, there was a
reduction in cases triggered into Stage 2
exposure.
Moving exposures on to the Risk of
Credit Loss framework
remained an important backstop indicator of a
SICR. The
exposures classified under the Stage 2 Risk of
Credit Loss
framework trigger increased ove
r the period as less
exposures were captured under the PD deterioration
Stage
2 trigger.
PD persistence related to the bu
siness banking portfolio
only.
Stage 3 vintage analysis
The table below shows estimat
ed vintage analysis of the material Stage 3 portfolios.
2021
2020
Retail Banking
Ulster Ban
k RoI
Retail Banking
Ulster Bank RoI
mortgages
mortgages
Wholesale
mortgages
mortgages
Wholesale
Stage 3 loans (£bn)
1.2
0.6
2.1
1.3
1.1
2.9
Vintage (time in default):
<1 year
26%
11%
19%
25%
6%
46%
1
-
3 years
30%
15%
20%
32%
18%
16%
3-5 years
13%
8%
7%
11%
23%
7%
5-10 years
17%
40%
54%
22%
36%
31%
>10 years
14%
26%
10%
17%
100%
100%
100%
100%
100%
100%
Retail
Banking and Ulster Ba
nk RoI mortgages
– The
proportion of the Stage 3 defaulted population whic
h have
been in default for over five years refle
cted NatWest Group’s
support for customers in financi
al difficulty. When customers
continue to engage constructive
ly with NatWest Group,
making regular payments,
NatWest G
roup continues to
support them.
Wholesale
– The reduction in
the proportion of loans in Stage
3 for less than one year was m
ainly due to lower flows into
default during 2021 with customers suppor
ted by
government support schemes and a positive econo
mic
recovery trajectory. Exposures which we
re in Stage 3 for in
excess of five years, were mainly
related to customers being
in a protracted formal insolvency process or subject
to
litigation or a complaints proce
ss.
Risk and capital m
anageme
nt continued
NatWest Group
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nnual Repor
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Credit risk – Banking activities continued
Asset quality
(audited)
The table below shows asset quality b
ands of gross loans and ECL, by stage, for
the Personal portfolio.
Gross loans
ECL provisions
ECL provisions covera
ge
Stage 1
Stage 2
St
age 3
T
otal
Stage 1
Stage 2
St
age 3
Total
Stage 1
Stage 2
St
age 3
Total
2021
£m
£m
£m
£
m
£m
£m
£m
£m
%
%
%
%
UK mortgages
AQ1-AQ4
93,956
3,157
97,113
8
40
48
0.01
1.27
0.05
AQ5-AQ8
81,160
7,325
88,485
17
103
120
0.02
1.41
0.14
AQ9
290
508
798
14
14
2.76
1.75
AQ10
1,451
1,451
269
269
18.54
18.54
175,406
10,990
1,451
187,847
25
157
269
451
0.01
1.43
18.54
0.24
RoI mortgages
AQ1-AQ4
3,669
226
3,895
5
5
10
0.14
2.21
0.26
AQ5-AQ8
1,335
176
1,511
2
6
8
0.15
3.41
0.53
AQ9
8
151
159
6
6
3.97
3.77
AQ10
599
599
293
293
48.91
48.91
5,012
553
599
6,164
7
17
293
317
0.14
3.07
48.91
5.14
Credit cards
AQ1-AQ4
44
1
45
1
1
2.27
2.22
AQ5-AQ8
2,874
894
3,768
58
130
188
2.02
14.54
4.99
AQ9
6
38
44
11
11
28.95
25.00
AQ10
90
90
60
60
66.67
66.67
2,924
933
90
3,947
59
141
60
260
2.02
15.11
66.67
6.59
Other personal
AQ1-AQ4
831
88
919
6
19
25
0.72
21.59
2.72
AQ5
-
AQ8
5,950
1,723
7,673
51
243
294
0.86
14.10
3.83
AQ9
52
136
188
1
37
38
1.92
27.21
20.21
AQ10
642
642
557
557
86.76
86.76
6,833
1,947
642
9,422
58
299
557
914
0.85
15.36
86.76
9.70
Total personal
AQ1-AQ4
98,500
3,472
101,972
20
64
84
0.02
1.84
0.08
AQ5-AQ8
91,319
10,118
101,437
128
482
610
0.14
4.76
0.60
AQ9
356
833
1,189
1
68
69
0.28
8.16
5.80
AQ10
2,782
2,782
1,179
1,179
42.38
42.38
190,175
14,423
2,782
207,380
149
614
1,179
1,942
0.08
4.26
42.38
0.94
Risk and capital m
anageme
nt continued
NatWest Group
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nnual Repor
t and Accou
nts 2021
243
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Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Asset quality
(audited)
Gross loans
ECL provisions
ECL provisions coverage
Stage 1
Stag
e 2
Stage 3
Total
Stage 1
Stage 2
Stage 3
Total
Stage 1
Stage 2
Stage 3
T
otal
2020
£m
£m
£m
£m
£m
£m
£m
£m
%
%
%
%
UK mortgages
AQ1-AQ4
108,869
6,634
115,503
10
33
43
0.01
0.50
0.04
AQ5-AQ8
38,347
20,254
58,601
14
146
160
0.04
0.72
0.27
AQ9
240
1,015
1,255
49
49
4.83
3.90
AQ10
1,507
1,507
254
254
16.85
16.85
147,456
27,903
1,507
176,866
24
228
254
506
0.02
0.82
16.85
0.29
RoI mortgages
AQ1-AQ4
8,247
777
9,024
20
38
58
0.24
4.89
0.64
AQ5-AQ8
2,677
560
3,237
7
34
41
0.26
6.07
1.27
AQ9
7
331
338
19
19
5.74
5.62
AQ10
1,051
1,051
381
381
36.25
36.25
10,931
1,668
1,051
13,650
27
91
381
499
0.25
5.46
36.25
3.66
Credit cards
AQ1-AQ4
23
4
27
1
2
3
4.35
50.00
11.11
AQ5-AQ8
2,384
1,329
3,713
52
208
260
2.18
15.65
7.00
AQ9
4
42
46
15
15
35.71
32.61
AQ10
109
109
76
76
69.72
69.72
2,411
1,375
109
3,895
53
225
76
354
2.20
16.36
69.72
9.09
Other personal
AQ1-AQ4
1,234
59
1,293
8
9
17
0.65
15.25
1.31
AQ5
-
AQ8
4,461
3,020
7,481
58
336
394
1.30
11.13
5.27
AQ9
55
327
382
1
107
108
1.82
32.72
28.27
AQ10
621
621
517
517
83.25
83.25
5,750
3,406
621
9,777
67
452
517
1,036
1.17
13.27
83.25
10.60
Total personal
AQ1-AQ4
118,373
7,474
125,847
39
82
121
0.03
1.10
0.10
AQ5-AQ8
47,869
25,163
73,032
131
724
855
0.27
2.88
1.17
AQ9
306
1,715
2,021
1
190
191
0.33
11.08
9.45
AQ10
3,288
3,288
1,228
1,228
37.35
37.35
166,548
34,352
3,288
204,188
171
996
1,228
2,395
0.10
2.90
37.35
1.17
In the Personal portfolio, the majority of e
xposures were in
AQ4 and AQ5 within the mortg
age portfolios. Overall,
personal asset quality improved slightly wi
th migration in
assets from AQ4 to AQ5 in mortgages off
set by migration
from AQ9 into better quality ba
nds. As expected, mortgage
exposures had a higher proportion in A
Q1-AQ4 than
unsecured borrowing.
As noted previously, significant migration from S
tage 2 into
Stage 1 across all AQ bands was observed
, as IFRS PDs
reduced.
In other personal, the relatively high level of exposu
res in
AQ10 reflected that impaired as
sets can be held on the
balance sheet, with commensurate ECL p
rovision, for up to
six years after default.
Risk and capital m
anageme
nt continued
NatWest Group
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nnual Repor
t and Accou
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Financial statements
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Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Asset quality
(audited)
The table below shows asset quality b
ands of gross loans and ECL, by stage, for
the Wholesale portfolio.
Gross loans
ECL provisions
ECL provisions covera
ge
Stage 1
Stage 2
Stage 3
Total
Stage 1
St
age 2
Stage 3
Total
Stage 1
St
age 2
Stage 3
Total
2021
£m
£m
£m
£m
£
m
£m
£m
£m
%
%
%
%
Property
AQ1-AQ4
13,529
223
13,752
3
7
10
0.02
3.14
0.07
AQ5
-
AQ8
15,126
2,742
17,868
21
94
115
0.14
3.43
0.64
AQ9
24
136
160
10
10
7.35
6.25
AQ10
742
742
239
239
32.21
32.21
28,679
3,101
742
32,522
24
111
239
374
0.08
3.58
32.21
1.15
Corporate
AQ1-AQ4
18,378
1,027
19,405
8
48
56
0.04
4.67
0.29
AQ5-AQ8
35,351
13,922
49,273
88
621
709
0.25
4.46
1.44
AQ9
74
655
729
44
44
6.72
6.04
AQ10
1,444
1,444
602
602
41.69
41.69
53,803
15,604
1,444
70,851
96
713
602
1,411
0.18
4.57
41.69
1.99
Financial institutions
AQ1-AQ4
50,121
63
50,184
7
1
8
0.01
1.59
0.02
AQ5-AQ8
2,138
667
2,805
7
38
45
0.33
5.70
1.60
AQ9
4
2
6
AQ10
46
46
4
4
8.70
8.70
52,263
732
46
53,041
14
39
4
57
0.03
5.33
8.70
0.11
Sovereign
AQ1-AQ4
5,787
35
5,822
19
1
20
0.33
2.86
0.34
AQ5-AQ8
117
86
203
AQ9
AQ10
8
8
2
2
25.00
25.00
5,904
121
8
6,033
19
1
2
22
0.32
0.83
25.00
0.36
Total
AQ1
-
AQ4
87,815
1,348
89,163
37
57
94
0.04
4.23
0.11
AQ5-AQ8
52,732
17,417
70,149
116
753
869
0.22
4.32
1.24
AQ9
102
793
895
54
54
6.81
6.03
AQ10
2,240
2,240
847
847
37.81
37.81
140,649
19,558
2,240
162,447
153
864
847
1,864
0.11
4.42
37.81
1.15
2020
Property
AQ1-AQ4
12,694
2,079
14,773
20
40
60
0.16
1.92
0.41
AQ5-AQ8
10,785
10,780
21,565
103
450
553
0.96
4.17
2.56
AQ9
254
162
416
17
17
10.49
4.09
AQ10
1,322
1,322
545
545
41.23
41.23
23,733
13,021
1,322
38,076
123
507
545
1,175
0.52
3.89
41.23
3.09
Corporate
AQ1-AQ4
17,757
2,726
20,483
20
51
71
0.11
1.87
0.35
AQ5-AQ8
29,405
24,430
53,835
167
1,374
1,541
0.57
5.62
2.86
AQ9
928
560
1,488
1
62
63
0.11
11.07
4.23
AQ10
1,727
1,727
803
803
46.50
46.50
48,090
27,716
1,727
77,533
188
1,487
803
2,478
0.39
5.37
46.50
3.20
Financial institutions
AQ1-AQ4
42,222
1,985
44,207
13
13
26
0.03
0.65
0.06
AQ5-AQ8
1,776
1,453
3,229
10
39
49
0.56
2.68
1.52
AQ9
4
186
190
38
38
20.43
20.00
AQ10
17
17
8
8
47.06
47.06
44,002
3,624
17
47,643
23
90
8
121
0.05
2.48
47.06
0.25
Sovereign
AQ1-AQ4
4,731
106
4,837
14
1
15
0.30
0.94
0.31
AQ5
-
AQ8
17
98
115
AQ9
3
3
AQ10
4
4
2
2
50.00
50.00
4,751
204
4
4,959
14
1
2
17
0.29
0.49
50.00
0.34
Total
AQ1-AQ4
77,404
6,896
84,300
67
105
172
0.09
1.52
0.20
AQ5
-
AQ8
41,983
36,761
78,744
280
1,863
2,143
0.67
5.07
2.72
AQ9
1,189
908
2,097
1
117
118
0.08
12.89
5.63
AQ10
3,070
3,070
1,358
1,358
44.23
44.23
120,576
44,565
3,070
168,211
348
2,085
1,358
3,791
0.29
4.68
44.23
2.25
Risk and capital m
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Additional information
Financial review
Credit risk – Banking activities continued
Asset quality
(audited)
Across the Wholesale portfolio, the asset quality band
distribution differed, reflective of the underlying qu
ality of
counterparties within each seg
ment.
Asset quality improvement was observed across
most
segments as the economy recovered from the
effects of
COVID-19.
The reduction in AQ10 exposur
e in property was largely due
to a portfolio sale of commercial real est
ate.
Within the Wholesale portfolio, customer credit grades we
re
reassessed as and when a request for financing was m
ade,
a scheduled customer credit revie
w was undertaken or a
material event specific to that customer occur
red.
ECL provisions coverage showed the expected
trend with
increased coverage in the poor
er asset quality bands, and
also by stage.
The low provision coverage for Stage 3 l
oans in financial
institutions for 2021 reflected the secu
red nature of one
exposure classified AQ10.
Credit risk – Trading activities
This section details the credit risk profile of NatWest Grou
p’s trading activities.
Securities financing transactions and collateral
(audited)
The table below shows securiti
es funding transactions in NatWest Markets and Treasu
ry. Balance sheet captions include ba
lances
held at all classifications under IFRS 9.
Reverse Repos
Repos
Total
Of which
can be offset
Outside nett
ing
arrangements
Total
Of which can be
offset
Outside nett
ing
arrangements
2021
£m
£
m
£m
£m
£m
£m
Gross
78,909
78,259
650
73,858
7
2,712
1,146
IFRS offset
(32,016)
(32,016)
(32,016)
(32,016)
Carrying value
46,893
46,243
650
41,842
4
0,696
1,146
Master netting arrangements
(900)
(900)
(900)
(900)
Securities collateral
(45,271)
(45,271)
(39,794)
(39,794)
Potential for offset not recognised under IFRS
(46,171)
(46,171)
(40,694)
(40,694)
Net
722
72
650
1,148
2
1,
146
2020
Gross
80,388
80,025
363
66,493
64,793
1,700
IFRS offset
(35,820)
(35,820)
(35,820)
(
35,820)
Carrying value
44,568
44,205
363
30,673
28,973
1,700
Master netting arrangements
(929)
(
929)
(929)
(929)
Securities collateral
(43,204)
(43,204)
(28,044)
(
28,044)
Potential for offset not recognised under IFRS
(44,133)
(44,133)
(28,973)
(
28,973)
Net
435
72
363
1,700
1,700
Risk and capital m
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nt continued
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Additional information
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review
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Strategic report
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Risk and capital management
Additional information
Financial review
Credit risk – Trading activities contin
ued
Derivatives
(audited)
The table below shows derivatives
by type of contract. The master netting agreements and c
ollateral shown do not result in a net
presentation on the balance she
et under IFRS. A significant proportion (more than 90%
) of the derivatives relate to trading
activities in NatWest Markets. The table also includes he
dging derivatives in Treasury.
2021
2020
Notional
GBP
USD
Euro
Other
Total
Assets
Liabilities
Notional
A
ssets
Liabilities
£bn
£bn
£bn
£bn
£bn
£m
£m
£bn
£m
£m
Gross exposure
114,100
109,403
177,330
172,245
IFRS offset
(7,961)
(8,568)
(10,807)
(11,540)
Carrying value
3,512
3,270
4,092
1,226
12,100
106,139
100,835
14,047
166,523
160,705
Of which:
Interest rate
(1)
3,191
1,878
3,536
314
8,919
67,458
61,206
10,703
114,115
105,214
Exchange rate
319
1,388
548
912
3,167
38,517
39,286
3,328
52,239
55,107
Credit
2
4
8
14
154
343
15
161
376
Equity and commodity
10
1
8
8
Carrying value
12,100
106,139
100,835
14,047
166,523
160,705
Counterparty mark-to-market
netting
(85,006)
(85,006)
(137,086)
(137,086)
Cash collateral
(15,035)
(9,909)
(19,608)
(15,034)
Securities collateral
(2,428)
(2,913)
(5,053)
(4,921)
Net exposure
3,670
3,007
4,776
3,664
Banks
(2)
393
413
206
557
Other financial institutions
(3)
1,490
1,584
1,436
1,931
Corporate
(4)
1,716
938
2,985
1,082
Government
(5)
71
72
149
94
Net exposure
3,670
3,007
4,776
3,664
UK
1,990
1,122
2,914
1,627
Europe
714
1,028
1,091
1,118
US
645
653
470
644
RoW
321
204
301
275
Net exposure
3,670
3,007
4,776
3,664
Asset quality of uncollateralised
derivative assets
AQ1-AQ4
2,939
3,464
AQ5-AQ8
674
1,283
AQ9-AQ10
57
29
Net exposure
3,670
4,776
(1)
The notional amount of interest rate derivat
ives includes £6,173 billion (2020 – £7,390 billion) in respect of contracts cleared through central clearing counterparties.
(2)
Transactions with certain counter
parties with whom NatWest Group has netting arrangements but collateral is not posted on a daily basis; certain transactions with spe
cific terms that may
not fall within netting and collateral arrangements; der
ivative positions in certain jurisdictions for example China where the collateral agreements are not deemed to be legally e
nforceable.
(3)
Includes transactions with secur
itisation vehicles and funds where collateral posting is contingent on NatWest Group’s external rating.
(4)
Mainly large corporates
with whom NatWest Group may have netting arrangements in place, but operational capability does not support collateral posting.
(5)
Sovereigns and supranation
al entities with no collateral arrangements, collateral arrangements that are not considered enforceable, or one-way collateral agreements in their favour.
Risk and capital m
anageme
nt continued
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Additional information
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Credit risk – Trading activities contin
ued
Derivatives: settlement basis and central coun
terparties
(audited)
The table below shows the third party de
rivative notional and fair value by trading and set
tlement method.
Notional
Traded over th
e counter
Asset
Liability
Traded on
Settled
Not settled
Traded on
Traded
Trade
d on
Traded
recognised
by centra
l
b
y central
recognised
over the
recognised
over the
exchanges
counterpa
rties
co
unterparties
Total
exchanges
counter
exchanges
counter
2021
£bn
£bn
£bn
£bn
£m
£m
£m
£m
Interest rate
723
6,173
2,023
8,919
67,458
61,206
Exchange rate
2
3,165
3,167
38,517
39,286
Credit
14
14
154
343
Equity and commodity
10
Total
725
6,173
5,202
12,100
106,139
100,835
2020
Interest rate
1,032
7,390
2,281
10,703
114,115
105,214
Exchange rate
2
3,326
3,328
52,239
55,107
Credit
15
15
161
376
Equity and commodity
1
1
8
8
Total
1,034
7,390
5,623
14,047
166,523
160,705
Debt securities
(audited)
The table below shows debt securities held at manda
tory fair value through profit or loss by i
ssuer as well as ratings based on the
lowest of Standard & Poor’s, Moody’s and Fi
tch. A significant proportion (more than 95%) of t
hese positions are trading securities in
NatWest Markets.
Central and local g
overnment
Financial
institutions
UK
US
Other
Corporate
Total
2021
£m
£m
£m
£
m
£
m
£m
AAA
2,011
838
2,849
AA to AA+
3,329
3,145
1,401
62
7,937
A to AA-
6,919
1,950
308
57
9,234
BBB- to A-
3,792
346
517
4,655
Non-investment grade
31
163
82
276
Unrated
3
3
6
Total
6,919
3,329
10,929
3,059
721
24,957
Short positions
(9,790)
(56)
(12,907)
(2,074)
(137)
(24,964)
2020
AAA
3,114
1,113
4,227
AA to AA+
5,149
3,651
576
49
9,425
A to AA-
4,184
1,358
272
81
5,895
BBB- to A-
8,277
444
656
9,377
Non-investment grade
36
127
53
216
Unrated
150
5
155
Total
4,184
5,149
16,436
2,682
844
29,295
Short positions
(5,704)
(
1,123)
(18,135)
(
1,761)
(56)
(26,779)
Risk and capital m
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nt continued
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Credit risk – Cross border exposure
Cross border exposures compri
se both banking and trading activities, including
reverse repurchase agreements. Exposures
comprise loans and advances, including fin
ance leases and instalment credit
receivables, and other monetary assets, such as de
bt
securities. The geographical br
eakdown is based on the country of domicile of
the borrower or guarantor of ultimate risk. Cross
border exposures include non-local cur
rency claims of overseas offices
on local residents but exclude exposures to local residents
in local currencies. The table shows cross border exp
osures greater than 0.5% of NatWest Gr
oup’s total assets.
Short
Net of short
Government
Banks
Other
Total
positions
positions
2021
£m
£m
£m
£
m
£m
£m
Western Europe
17,206
6,968
17,177
41,351
13,603
27,748
Of which: France
5,391
1,258
3,825
10,474
2,919
7,555
Germany
3,164
3,640
1,835
8,639
3,111
5,528
Italy
3,040
210
797
4,047
3,449
598
United States
10,345
3,548
8,539
22,432
1,862
20,570
2020
Western Europe
23,651
9,232
21,091
53,974
18,756
35,218
Of which: France
5,098
1,574
6,270
12,942
2,465
10,477
Germany
4,913
4,020
2,343
11,276
3,833
7,443
Italy
4,985
319
791
6,095
3,583
2,512
Spain
2,980
731
1,120
4,831
3,773
1,058
United States
12,430
4,316
7,186
23,932
1,239
22,693
Risk and capital m
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Additional information
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Risk and capital management
Additional information
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Capital, liquidity and fundin
g risk
NatWest Group continually ensures a comprehensi
ve approach
is taken to the management of capital, liquidity an
d funding,
underpinned by frameworks, ris
k appetite and policies, to
manage and mitigate capital, liquidity and fundi
ng risks. The
framework ensures the tools and capability a
re in place to
facilitate the management and mitigation of risk ensu
ring
NatWest Group operates within its regul
atory requirements and
risk appetite.
Definitions
(audited)
Regulatory capital consists of r
eserves and instruments issued
that are available, have a degree
of permanency and are
capable of absorbing losses. A number of strict con
ditions set
by regulators must be satisfied to be eligible
as capital.
Capital adequacy risk is the risk that there is or
will be
insufficient capital and other loss-absorbing
debt
instru
ments to
operate effectively including me
eting minimum regulatory
requirements, operating within B
oard approved risk appetite
and supporting its strategic goals.
Liquidity consists of assets that can be readily con
verted to
cash within a short timeframe at a reliable value. Liqui
dity risk
is the risk of being unable to me
et financial obligations as and
when they fall due.
Funding consists of on-balance shee
t liabilities that are used to
provide cash to finance assets.
Funding risk is the risk of not
maintaining a diversified, stable and cost-effe
ctive funding
base.
Liquidity and funding risks arise in a nu
mber of ways, including
through the maturity transformation role
that banks perform.
The risks are dependent on factors such
as:
Maturity profile;
Composition of sources and uses of
funding;
The quality and size of the liquidity portfolio;
Wholesale market conditions; a
nd
Depositor and investor behaviour.
Sources of risk
(audited)
Capital
The eligibility of instruments and financial resou
rces as
regulatory capital is laid down by applic
able regulation. Capital
is categorised under two tiers (
Tier 1 and Tier 2) according to
the ability to absorb losses, degree of permanency a
nd the
ranking of absorbing losses on either a going or gone conce
rn
basis. There are three broad categories of ca
pital across these
two tiers:
CET1 capital -
CET1 capital must be perpetual
and capable
of unrestricted and immediate use
to cover risks or losses
as soon as these occur. This includes ordinary sh
ares issued
and retained earnings.
Additional Tier 1 (AT1) capital -
T
his is the second type of
loss absorbing capital and must be capable of abso
rbing
losses on a going concern basis. The
se instruments are
either written down or converted into CET1 c
apital when
the CET1 ratio falls below a pre-specifi
ed level.
Tier 2 capital -
Tier 2 capital is supplementary c
apital and
provides loss absorption on a gone concern basis. Tie
r 2
capital absorbs losses after Tier 1 capital. It typically
consists of subordinated debt se
curities with a minimum
maturity of five years at the point of issu
ance.
Minimum requirement for own funds and eligible
liabilities (MREL)
In addition to capital, other spec
ific loss-absorbing instruments,
including senior notes issued by NatWest G
roup, may be used
to cover certain gone concern c
apital requirements, which is
referred to as MREL. Gone concern refers to the si
tuation in
which resources must be available to enable an o
rderly
resolution, in the event that the Bank of Englan
d (BoE) deems
that NatWest Group has failed or is likely
to fail.
Liquidity
NatWest Group maintains a prudent app
roach to the definition
of liquidity resources. NatWest Group m
anages its liquidity to
ensure it is always available whe
n and where required, taking
into account regulatory, legal and othe
r constraints. Following
ring-fencing legislation, liquidity is no longe
r considered
fungible across NatWest Group. Principal liquidity por
tfolios are
maintained in the UK Domestic Liquidity Sub-Group
(UK
DoLSub) (primarily in NatWest B
ank Plc), UBIDAC, NatWest
Markets Plc, RBS International L
imited and NWM N.V.. Some
disclosures in this section where
relevant are presented, on a
consolidated basis, for NatWest Group, the UK DoLSub
and on
a solo basis for NatWest Markets Plc.
Liquidity resources are divided into primary and secon
dary
liquidity as follows:
Primary liquid assets include cash and bal
ances at central
banks, Treasury bills and other high quality govern
ment
and supranational securities.
Secondary liquid assets are elig
ible as collateral for local
central bank liquidity facilities. T
hese assets include own-
issued securitisations or whole loans tha
t are retained on
balance sheet and pre-positione
d with a central bank so
that they may be converted into additional sources of
liquidity at very short notice.
Funding
NatWest Group maintains a dive
rsified set of funding sources,
including customer deposits, wholes
ale deposits and term debt
issuance. NatWest Group also retains access to central b
ank
funding facilities.
For further details on capital constituents an
d the regulatory
framework covering capital, liquidity and fu
nding requirements,
please refer to the NatWest Group Pillar 3 Report 2021
Capital,
liquidity and funding section.
Risk and capital m
anageme
nt continued
NatWest Group
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Governance
Risk and capital management
Additional information
Financial review
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Strategic report
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Risk and capital management
Additional information
Financial review
Capital, liquidity and fundin
g risk continued
Capital management
Capital management ensures that there is suffici
ent capital and
other loss-absorbing instrumen
ts to operate effectively
including meeting minimum regulatory requi
rements, operating
within Board-approved risk appe
tite, maintaining its credit
rating and supporting its strategic goals.
Capital management is critical in suppo
rting the businesses and
is enacted through an end-to-end framework ac
ross businesses
and legal entities. Capital is managed within the o
rganisation at
the following levels; NatWest Group consolidated, NW
H Group
sub consolidated, NatWest Marke
ts Plc, NatWest Markets N.V.
and RBS International Limited. The
banking subsidiaries within
NWH Group are governed by t
he same principles, processes
and management as NatWest Group. Note
that although the
aforementioned entities are reg
ulated in line with Basel III
principles, local implementation of the framewo
rk differs across
geographies.
Capital planning is integrated into NatWest G
roup’s wider
annual budgeting process and is asse
ssed and updated at least
monthly. Regular returns are submitted to the
PRA which
include a two-year rolling forecast view. Other elemen
ts of
capital management, including risk appetite
and stress testing,
are set out on pages 192 and 193
.
Produce
capital
plans
Capital plans are produced for N
atWest Group, its
key operating entities and its business
es over a
five year planning horizon under expected an
d
stress conditions. Stressed capi
tal plans are
produced to support internal stress testing in the
ICAAP for regulatory purposes.
Shorter term forecasts are deve
loped frequently
in response to actual performance, changes in
internal and external business e
nvironment and
to manage risks and opportunitie
s.
Assess
capital
adequacy
Capital plans are developed to maintain capital
of
sufficient quantity and quality to support NatWest
Group’s business, its subsidiaries and strategic
plans over the planning horizon within approved
risk appetite, as determined via stress testing, and
minimum regulatory requireme
nts.
Capital resources and capital re
quirements are
assessed across a defined planning horizon.
Impact assessment captures input from ac
ross
NatWest Group including from businesse
s.
Inform
capital
actions
Capital planning informs potent
ial capital actions
including buy backs, redemptions, dividen
ds and
new issuance to external invest
ors or via internal
transactions.
Decisions on capital actions will be influence
d by
strategic and regulatory requir
ements, risk
appetite, costs and prevailing market conditions.
As part of capital planning, Nat
West Group will
monitor its portfolio of external capital securities
and assess the optimal blend a
nd most cost
effective means of financing.
Capital planning is one of the tools that NatWest
Group uses to
monitor and manage capital ris
k on a going and gone concern
basis, including the risk of exce
ssive leverage.
Liquidity risk management
NatWest Group manages its liq
uidity risk taking into account
regulatory, legal and other cons
traints to ensure sufficient
liquidity is available where required to cover li
quidity stresses.
The principal levels at which liq
uidity risk is managed are:
NatWest Group
NatWest Holdings Group
UK DoLSub
UBIDAC
NatWest Markets Plc
NatWest Markets Securities Inc.
RBS International Limited
NWM N.V.
The UK DoLSub is PRA regulated and comprises NatWe
st
Group’s four licensed deposit-taking U
K banks: National
Westminster Bank Plc (NWB Plc), The Royal Bank of Sc
otland
plc (RBS plc), Coutts & Company
and Ulster Bank Limited. On 3
May 2021, the Ulster Bank Limited business
transferred to
National Westminster Bank Plc.
Ulster Bank Limited was
removed from the UK DoLSub ef
fective 1 January 2022. The
planned removal of the Ulster B
ank Limited license remains
subject to regulatory applicatio
ns and approvals.
NatWest Group categorises its liquidity po
rtfolio, including its
locally managed liquidity portfolios, into pri
mary and secondary
liquid assets. The size of the liqu
idity portfolios are determined
by referencing NatWest Group’s liquidity risk appe
tite. NatWest
Group retains a prudent approach to setting the co
mposition of
the liquidity portfolios, which is s
ubject to internal policies
applicable to all entities and limits over quali
ty of counterparty,
maturity mix and currency mix.
RBS International Limited, NWM N.V. and UBIDAC
hold locally
managed portfolios that comply
with local regulations that may
differ from PRA rules.
The liquidity value of the portfolio is deter
mined by taking
current market prices and applying a discount o
r haircut, to
give a liquidity value that represe
nts the amount of cash that
can be generated by the asset.
Funding risk management
NatWest Group manages funding risk through
a comprehensive
framework which measures and monito
rs the funding risk on
the balance sheet including quantitative and qualit
ative analysis
of the behavioural aspects of its asse
ts and liabilities as well as
the funding concentration.
Risk and capital m
anageme
nt continued
NatWest Group
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nnual Repor
t and Accou
nts 2021
251
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Capital, liquidity and fundin
g risk continued
Key points
CET1 ratio (CRR end
-
point)
The CET1 ratio de
creased 30 basis
points over the period, d
ue to a £2.9 billio
n
decrease in CET1
and a £13.3 bill
ion decrease in RWAs.
The CET1 decrease
of c.£2.9 billion is ma
inly driven by:
the directed buy back a
n
d associa
ted pension contributio
n of £1.2 b
illion;
the on-market share b
uy back progra
mmes of £1.5 bil
lion (two £750 milli
on
programmes);
foreseeable divide
nds and associat
ed pension contributio
ns of £1.2 billion;
a £1.1 billion decreas
e in the IFRS
9 transitional adjustme
nt; and
other reserve moveme
nts.
These reductions were
offset by the £3.0
billion attributab
le profit in the
period.
Loss
-
absorbing capital
Loss absorbing capit
al decreased by
£1.5 billion to £62.4
billion primarily due to
a £2.9
billion decrease i
n CET1 (explained
above), new issua
nce of £3.2 bil
lion Senior debt,
AT1 issuances of £0.9
billion, and Tier 2 iss
uances of £1.6
billion. These we
re offset by
the redemption of a $2.
65 billion A
T1 instrument and c.£2.0
billion red
emption of Tier
2 instruments, foreign
exchange
movements and Tier 2
regulatory amortisati
on.
RWA
T
otal RWAs decrea
sed by £13.3 billion or 7.8
% to £157.0 billio
n mainly reflecting:
a reduction in credit risk RWA
s of £9.8 billion due t
o repayments a
nd expired
facilities in Commercia
l Banking
and additional decreas
es within Ul
ster Bank RoI
due to repayments
and facility maturiti
es.
M
arket ris
k RWAs decreased
by £1.4 billion drive
n by the transitio
n from LIBOR to
alternative risk-free
rates.
Coun
terpa
rty credit risk RWAs d
ecreased
by £1.2 billion as a result
of lower
exposures in NatWest
Markets and the strengt
h
ening of Sterling ag
ainst the euro
over the period.
Operational risk RWAs
reduced by £0.9 bi
llion following the a
nnual recalculatio
n in
Q1 2021.
UK leverage
The UK leverage rati
o decreased
by c.60 basis points drive
n by a £
4.0 billion decrease
in Tier 1 capital.
Liquidity portfolio
The liquidity portfolio
increased by
£24.1 billion to £286.4
billion, with primary liquid
ity
increasing by £38.2 bi
llion to £208.6 b
illion. The increase in
primary liquid
ity is driven
by customer surplus
and drawdown fr
om the Term Fundi
ng Scheme wit
h additional
incentives for S
MEs (TFSME). The
reduction in secondary liq
uidity is
due to a
reduction in the pre-
positioned c
ollateral at the Bank
of England.
Liquidity coverage ratio
The Liquidity Coverage
Ratio (LCR)
increased to 172
% during the y
ear driven by an
increase in the liquid
ity portfolio offset
by a lower level of i
ncreased net outf
lows.
The
increased liquidit
y portfolio was primarily
driven by significa
nt growth in custome
r
deposits in NatWe
st Holdings which outst
ripped growth in c
ustomer lending d
uring the
year.
NSFR
The net stable fu
nding ratio (NSFR
) was 157% compared t
o 151% in prior year.
The
increase is mainly d
ue to deposits gro
wth.
2021
157%
2021 18.2%
2020 18.5%
2020
165%
2021
172%
2021
£157.0bn
2020
£170.3bn
2020
151%
2020 £63.9bn
2021 £62.4bn
2021
5.8%
2020
6.4%
2020
£262.3bn
2021
£286.4bn
Risk and capital m
anageme
nt continued
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Additional information
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Additional information
Financial review
Capital, liquidity and fundin
g risk continued
Minimum requirements
Maximum Distributable Amount (MDA) and Minimum Capital
Requirements
NatWest Group is subject to minimum c
apital requirements relative to RWAs. The table below s
ummarises the minimum capital
requirements (the sum of Pillar
1 and Pillar 2A), and the additional capital buffe
rs which are held in excess of the regul
atory
minimum requirements and are us
able in stress.
Where the CET1 ratio falls below the sum of the minimu
m capital and the combined buffer
requirement, there is a subseque
nt
automatic restriction on the amount avail
able to service discretionary payments (inclu
ding AT1 coupons), known as the M
DA. Note
that different capital requireme
nts apply to individual legal entities or sub-groups an
d the table shown does not reflect
any
incremental PRA buffer requirements, which a
re not disclosable.
The current capital position pro
vides significant headroom above both our mini
mum requirements and our MDA threshold
requirements.
Type
CET1
Total T
ier 1
Tota
l capital
Pillar 1 requirements
4.5%
6.0%
8.0%
Pillar 2A requirements
2.0%
2.7%
3.6%
Minimum Capital Requirements
6.5%
8.7%
11.6%
Capital conservation buffer
2.5%
2.5%
2.5%
Countercyclical capital buffer
(1)
MDA threshold
(2)
9.0%
n/
a
n/a
Subtotal
9.0%
11.2%
14.1%
Capital ratios at 31 December 202
1
18.2%
20.7%
24.1%
Headroom
(3)
9.2%
9.5%
10.0%
(1)
In response to COVID
-19, many countries reduced their
CCyB rates. In December 2021, the Financial Policy Committee announced an increase in the UK CCyB rate from 0% to 1%.
This rate will come into effect from December 2022 in line with the 12 month implementation
period. The CBI continues to mai
ntain the rate at 0% with an announcement of a gradual
increase of the CCyB expected in 2022.
(2)
Pillar 2A requirements for NatWest Group are currently set on a nominal capital basis. From 2022
, all firms will be set Pilla
r 2A as a variable amount with the exception of some fixed
add
-ons.
(3)
The headroom does not reflect excess distributable capital
and may vary over time.
Leverage ratios
The table below summarises the
minimum ratios of capital to leverage exposure unde
r the binding PRA UK leverage f
ramework
applicable for NatWest Group.
Type
CET1
T
otal Tier 1
Minimum ratio
2.4375%
3.2500%
Countercyclical leverage ratio buffe
r
(1)
Total
2.4375%
3.2500%
(1)
The countercyclical leverage ratio buffer is set at
35% of NatWest Group’s CCyB. As noted above the UK CCyB will increase fro
m 0% to 1% effective from December 2022. Foreign
exposures may be subject to different CCyB rates depending
on the rate set in thos
e jurisdictions.
(2)
Following the publication of the new UK leverage f
ramework on 8 October 2021, certain NatWest Group legal entities that are n
ot currently in scope of the minimum leverage ratio
capital requirements will be expected to manage th
eir lev
erage ratio at the same level as firms in scope from 1 January 2022 and will be subject to the minimum requirement from 1
January 2023.
Liquidity and funding ratios
The table below summarises the
minimum requirements for key liquidity and funding me
trics, under the relevant legislative
framework.
Type
Liquidity coverage ratio (LCR)
100%
Net stable funding ratio (NSFR)
(1)
(1)
Net stable funding ratio (NSFR)
reported in line with CRR2 regulations finalised in June 2019. Following the publication of PS 22/21 on 14 October 2021, a binding NSFR minimum
requirement of 100% will be effective from January 2022
.
Risk and capital m
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nt continued
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Capital, liquidity and fundin
g risk continued
Measurement
Capital, risk-weighted assets and leverage: Key metrics
The table below sets out the key capital and lever
age ratios. Refer to Note 26 to the consolidated financial st
atements for a more
detailed breakdown of regulatory capital.
2021
2020
End-point
PRA t
ransitional
End-point
PRA transitional
CRR basis
(1)
basis
CRR basis (1)
basis
£m
£m
£m
£m
CET1
28,596
28,596
31,447
31,447
Tier1
32,471
33,042
36,430
37,260
Total
37,873
38,748
41,685
43,733
RWAs
£m
£m
£m
£m
Credit risk
120,116
120,116
129,914
129,914
Counterparty credit risk
7,907
7,907
9,104
9,104
Market risk
7,917
7,917
9,362
9,362
Operational risk
21,031
21,031
21,930
21,930
Total RWAs
156,971
156,971
170,310
170,310
Capital adequacy ratios
%
%
%
%
CET1
18.2
18.2
18.5
18.5
Tier 1
20.7
21.0
21.4
21.9
Total
24.1
24.7
24.5
25.7
Leverage ratios
£m
£m
£m
£m
Tier 1 capital
32,471
33,042
36,430
37,260
UK Average Tier 1 capital
(2)
33,233
33,804
36,397
37,231
UK Average leverage exposure
(2)
568,802
568,802
576,906
576,906
UK Average leverage ratio (%)
(2)
5.8%
5.9%
6.3%
6.5%
UK leverage ratio (%)
(3)
5.8%
5.9%
6.4%
6.5%
(1)
CRR as implemented by the
Prudential Regulation Authority in the UK. End-point CRR basis includes an IFRS 9 transitional uplift to capital of £0.6 billion (31 December 2020 - £1
.7
billion). Excluding this adjustment, the CET1 ratio would b
e 17.8% (31 December 2020 – 17.5%). The amended article for the prudential treatment of software assets was
implemented in December 2020. Excluding this a
djustment the CET1 ratio at 31 December 2021 would be 18.0% (31 December 2020 – 18.2%).
(2)
Based on the daily averag
e of on-balance sheet items and three month-end average of off-balance sheet items.
(3)
Presented on CRR end-point Tier 1 cap
ital (inclu
ding IFRS 9 transit
ional adjustment). The UK leverage ratio excludes central bank claims from the leverage exposure where deposits
held are denominated in the same currency and
of contractual maturity that is equal or longer than that of the central bank claims. Excluding an IFRS 9 transitional adjustment, the
UK leverage ratio would be 5.7% (31 December 2020
– 6.1%). The amended article for the prudential treatment of software assets was implemented in December 2020. Excluding
this adjustment, the UK leverage ratio at 31 December 2021 would be 5.7% (31 December 2020
– 6.3%).
On 1 January 2022 the CET1 ratio
was 15.9% including the impact of RWA inflation, 200 basis
points, the removal of the soft
ware
development cost capital benefit, 20 basis poin
ts, and the tapering of IFRS 9 transitional
relief of 10 basis points. RWAs increa
sed
by £18.8 billion, including £14.8 billion associated with
mortgage risk weight changes.
Risk and capital m
anageme
nt continued
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Capital, liquidity and fundin
g risk continued
Capital flow statement
The table below analyses the movement in CRR CET1
, AT1 and Tier 2 capital for the year.
CET1
AT1
Tier 2
Total
£m
£m
£m
£m
At 1 January 2021
31,447
4,983
5,255
41,685
Attributable profit for the period
2,950
2,950
Ordinary interim dividend paid
(348)
(348)
Directed buy back and associate
d dividend linked contribution
(1,231)
(1,
231)
On-market ordinary share buy back programme
(1,500)
(1,
500)
Foreseeable ordinary dividends
(846)
(846)
Foreseeable pension contributions
(365)
(365)
Foreign exchange reserve
(403)
(403)
FVOCI reserve
(91)
(91)
Own credit
22
22
Share capital and reserve movements in
respect of employee share
schemes
87
87
Goodwill and intangibles deduction
(130)
(130)
Deferred tax assets
(1)
(1)
Prudential valuation adjustments
12
12
New issues of capital instruments
933
1,635
2,568
Redemption of capital instruments
150
(2,041)
(1,580)
(3,471)
Net dated subordinated debt in
struments
20
20
Foreign exchange movements
15
15
Adjustment under IFRS 9 transitional arrangements
(1,126)
(1,
126)
Other movements
(31)
57
26
At 31 December 2021
28,596
3,875
5,402
37,873
The CET1 decrease of c.£2.9 billion is mainly driven by the
directed buy back and associated dividend linked
contribution of £1.2 billion, the
on-market share buy back
programmes of £1.5 billion, forese
eable dividends and
associated pension contributions
of £1.2 billion, a £1.1 billion
decrease in the IFRS 9 transitional adjustmen
t and other
reserve movements. These reductions were offset by
the
£3.0 billion attributable profit in the period.
At H1 2021, an on-market ordinary share buy back
programme of £750 million was announced resulting in
a
foreseeable charge to capital, of which £675
million has
been executed by 31 December 202
1. The outstanding £75
million remains as a foreseeable
charge together with £750
million recognised in Q4 2021 for an additional on-ma
rket
ordinary share buy back programme.
AT1 reflects the £400 million 4.5% Reset Perpetual
Subordinated Contingent Conve
rtible Notes issued in March
2021 and $750 million 4.600
% Reset Perpetual Subordinated
Contingent Convertible notes in June 20
21. It also reflects a
$2.7 billion redemption of 8.625% Perpetual Subordinated
Contingent Convertible Additional notes in Au
gust 2021.
The Tier 2 movement is primarily due to the redemption of
own debt of £1.5 billion in Marc
h 2021, a £1.0 billion
issuance of subordinated Tier 2
notes in May 2021 and a
€750 million issuance of subord
inated Tier 2 notes in
September 2021.
Risk and capital m
anageme
nt continued
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nts 2021
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Capital, liquidity and fundin
g risk continued
Risk-weighted assets
The table below analyses the movement in RWAs duri
ng the year, by key drivers.
Counterparty
Credit risk
credit risk
Market risk
Operational risk
Total
£bn
£bn
£bn
£bn
£bn
At 1 January 2021
129.9
9.1
9.4
21.9
170.3
Foreign exchange movement
(1.1)
(0.2)
(1.3)
Business movements
(4.9)
(0.9)
1.5
(0.9)
(5.2)
Risk parameter changes
(1)
(2.2)
(0.1)
(2.3)
Methodology changes
0.1
0.3
0.4
Model updates
(0.5)
(3.3)
(3.8)
Other movements
(2)
(0.9)
(0.9)
Acquisitions and disposals
(3)
(0.2)
(0.2)
At 31 December 2021
120.2
7.9
7.9
21.0
157.0
The table below analyses the movement in RWAs by se
gment during the year.
Go
-
forward group
Total
Central
excluding
Retail
Private
Commercial
RBS
NatWest
items
Ulster
Ulster
Banking
Banking
Banking
International
Markets
& other
Bank RoI
Bank RoI
Total
Total RWAs
£bn
£bn
£bn
£
bn
£bn
£bn
£bn
£bn
£bn
At 1 January 2021
36.7
10.9
75.1
7.5
26.9
1.4
158.5
11.8
170.3
Foreign exchange movement
(0.3)
(0.4)
(0.7)
(0.6)
(1.3)
Business movements
0.4
0.4
(
6.0)
0.1
0.8
0.4
(3.9)
(1.3)
(5.2)
Risk parameter changes
(1)
(0.4)
(1.2)
(0.1)
(1.7)
(0.6)
(2.3)
Methodology changes
0.1
0.3
0.4
0.4
Model updates
(0.5)
(3.3)
(3.8)
(3.8)
Other movements
(2)
(0.8)
(0.1)
(0.9)
(0.9)
Acquisitions and disposals
(3)
(0.2)
(0.2)
At 31 December 2021
36.7
11.3
66.4
7.5
24.2
1.8
147.9
9.1
157.0
Credit risk
29.4
9.9
58.0
6.5
6.4
1.8
112.0
8.2
120.2
Counterparty credit risk
0.2
0.1
0.3
7.3
7.9
7.9
Market risk
0.1
0.1
7.7
7.9
7.9
Operational risk
7.0
1.3
8.0
1.0
2.8
20.1
0.9
21.0
Total RWAs
36.7
11.3
66.4
7.5
24.2
1.8
147.9
9.1
157.0
(1)
Risk parameter changes relate t
o changes in credit quality metrics of customers and counterparties (such as probability of default and loss given default) as well as internal ratings
based model changes relating to counterpa
rty credit risk.
(2)
The movements in other include the following:
(a)
R
WA benefit of £0.8 billion as a result of the CRR COVID-19 amendment for
Infrastructure Supporting Factor.
(b)
A
sset transfers from NatWest Markets to Commercial.
(3)
The movement in acquisitions & disposals
refl
ected a portf
olio sale of non-performing loans in Ulster Bank RoI.
Total RWAs decreased to £157.0
billion during the period due to
the following:
Credit risk RWAs decreased by £
9.8 billion due to
repayments and expired facilitie
s in Commercial Banking
and additional decreases within Ulster Bank RoI due
to
repayments and facility maturities
. Operational risk RWAs
decreased by £0.9 billion follow
ing the annual recalculation
in Q1 2021.
Counterparty credit risk RWAs reduced by £1
.2 billion,
mainly reflecting reduced IMM e
xposures in NatWest
Markets.
Market risk RWAs decreased by £1
.4 billion primarily driven
by a decrease in modelled market risk reflectin
g a reduction
in tenor basis risk in sterling flow rates, related
to the
transition from LIBOR to alternative risk-free r
ates.
Risk and capital m
anageme
nt continued
NatWest Group
A
nnual Repor
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nts 2021
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Capital, liquidity and fundin
g risk continued
Leverage exposure
2021
2020
£m
£m
Cash and balances at central banks
177,757
124,489
Trading assets
59,158
68,990
Derivatives
106,139
166,523
Financial assets
412,817
422,647
Other assets
17,106
16,842
Assets of disposal groups
9,015
Total assets
781,992
799,491
Derivatives
- netting and variation margin
(110,204)
(172,658)
-
potential future exposu
res
35,035
38,171
Securities financing transactions gross up
1,397
1,179
Undrawn commitments
(1)
44,240
45,853
Regulatory deductions and other adjustmen
ts
(8,980)
(8,943)
Claims on central banks
(174,148)
(122,252)
Exclusion of bounce back loans
(7,474)
(8,283)
UK leverage exposure
(2)
561,858
572,558
(1)
Leverage exposure includes a
commitment treated as external for the purposes of the regulatory consolidation, which is treated as internal within the weighted undrawn
commitments table below.
(2)
The UK leverage ratio excludes cent
ral bank claims from the leverage exposure where deposits held are denominated in the same currency and of contractual maturity that is equal
or longer than that of the central bank claims.
Liquidity key metrics
The table below sets out the key liquidity and rel
ated metrics monitored by NatWest Group.
2021
2020
NatWest Group
UK DoLSub
NatWest Group
UK DoLSub
Liquidity coverage ratio
(1)
172%
169%
165%
152%
Stressed outflow coverage
(2)
194%
195%
183%
168%
Net stable funding ratio
(3)
157%
151%
151%
144%
(1)
The published LCR excludes Pillar 2 add-ons. NatW
est Group calculates the LCR using its own interpretations of the EU LCR Delegated Act, which may change over time and may
not be fully comparable with those of other financial institutions.
(2)
NatWest Group’s stressed outflow
coverage (SOC) is an internal measure calculated by reference to liquid assets as a percentage of net stressed contractual and behavioural
outflows over three months under the worst of t
hree severe stress scenarios of a market-wide stress, an idiosyncratic stress and a combination of both as per ILAAP. This
assessment is performed in accordance with PRA guidance.
(3)
Following the publication of PS 22
/21 on 14 October 2021, a binding NSFR minimum requirement of 100% will be effective from January 2022.
Weighted undrawn commitments
The table below provides a breakdown of weigh
ted undrawn commitments.
2021
2020
£bn
£bn
Unconditionally cancellable cre
dit cards
1.8
1.8
Other unconditionally cancellable items
3.1
3.2
Unconditionally cancellable items
(1)
4.9
5.0
Undrawn commitments <1 year which m
ay not be cancelled
1.7
1.9
Other off-balance sheet items with 20% credit c
onversion factor (CCF)
0.3
0.4
Items with a 20% CCF
2.0
2.3
Revolving credit risk facilities
27.5
28.4
Term loans
3.3
3.6
Mortgages
Other undrawn commitments >1
year which may not be cancelled & of
f-balance sheet
1.1
1.2
Items with a 50% CCF
31.9
33.2
Items with a 100% CCF
5.3
5.4
Total
44.1
45.9
(1)
Based on a 10% CCF.
Risk and capital m
anageme
nt continued
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Capital, liquidity and fundin
g risk continued
Loss-absorbing capital
The following table illustrates the c
omponents of estimated loss-absorbing capital (LAC) i
n NatWest Group plc and operatin
g
subsidiaries and includes external issuances only. The t
able is prepared on a transitional
basis, including the benefit of regul
atory
capital instruments issued from operating c
ompanies, to the extent they meet MREL c
riteria.
The roll-off profile relating to s
enior debt and subordinated debt instru
ments is set out on page 259.
2021
2020
Balance
Balan
ce
Par
sheet
Regulatory
LAC
Par
sheet
Regulatory
LAC
value (1)
value
value (2)
value (3)
value
value
value
value
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
CET1 capital
(4)
28.6
28.6
28.6
28.6
31.4
31.4
31.4
31.4
Tier 1 capital: end-point CRR compli
ant AT1
of which: NatWest Group plc (holdco)
3.9
3.9
3.9
3.9
5.0
5.0
5.0
5.0
of which: NatWest Group plc operating
operating subsidiaries (opcos)
3.9
3.9
3.9
3.9
5.0
5.0
5.0
5.0
Tier 1 capital: end-point CRR non compliant
of which: holdco
0.6
0.6
0.5
0.5
0.7
0.7
0.7
0.5
of which: opcos
0.1
0.1
0.1
0.1
0.1
0.1
0.7
0.7
0.5
0.5
0.8
0.8
0.8
0.6
Tier 2 capital: end-point CRR compli
ant
of which: holdco
7.1
7.1
4.9
6.0
6.9
7.2
4.8
5.7
of which: opcos
0.3
0.3
0.4
0.4
0.1
0.1
7.4
7.4
4.9
6.0
7.3
7.6
4.9
5.8
Tier 2 capital: end-point CRR non compliant
of which: holdco
0.1
0.1
0.1
0.1
of which: opcos
0.6
0.9
0.3
0.1
1.6
1.9
1.1
1.0
0.6
0.9
0.3
0.1
1.7
2.0
1.2
1.1
Senior unsecured debt securities
of which: holdco
22.8
23.4
22.8
19.6
20.9
19.6
of which: opcos
22.7
22.6
20.9
21.5
45.5
46.0
22.8
40.5
42.4
19.6
Tier 2 capital
Other regulatory adjustments
0.5
0.5
0.4
0.4
0.5
0.5
0.4
0.4
Total
86.7
87.5
38.7
62.4
86.7
89.2
43.7
63.9
RWAs
157.0
170.3
UK leverage exposure
561.9
572.6
LAC as a ratio of RWAs
39.8%
37.5%
LAC as a ratio of UK leverage e
xposure
11.1%
11.2%
(1)
Par value reflects the nominal value of securities issued.
(2)
Regulatory capital instruments issued from operating companies are
included in the transitional LAC calculation; to the extent they meet the current MREL criteria.
(3)
LAC value reflects NatWest Group’s
interpretation of the Bank of England’s approach to setting a minimum requirement for own funds and eligible liabilities (MREL), published in
June 2018. MREL policy and requirements remain subject to
further potential development, as such NatWest Group’s estimated position remains subject to potential change.
Liabilities excluded from LAC include instruments with less than one yea
r remaining to maturity, structured debt, operating company senior debt, and other instruments that do not
meet the MREL criteria. The LAC calculation includes T
ier 1 and Tier 2 securities before the application of any regulatory caps or adjustments.
(4)
Corresponding shareholders’ equity
was £41.8 billion (2020 - £43.9 billion).
(5)
Regulatory amounts reported for AT1, Tier 1 an
d Tier 2 instruments are before grandfathering restrictions imposed by CRR.
Risk and capital m
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Capital, liquidity and fundin
g risk continued
Loss-absorbing capital
The following table illustrates the c
omponents of the stock of outstanding issuance in N
atWest Group and its operating subsidiaries
including external and Internal issuances
.
NatWest
NatWest
NWM
RBS
NatWest
Holdings
Markets
Sec
urities
International
Group plc
Limited
NWB Plc
RBS plc
U
BIDAC
NWM Plc
N.V.
Inc.
Limited
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
Tier 1 (inclusive of AT1)
Ext
ernally issu
ed
4.5
0.1
Tier 1 (inclusive of AT1)
Internally issued
3.7
2.4
1.0
0.9
0.2
0.3
4.5
3.7
2.5
1.0
0.9
0.2
0.3
Tier 2
Externally issued
7.1
0.1
0.1
0.4
0.5
Tier 2
Internally issued
4.6
3.1
1.4
0.4
1.5
0.1
0.3
7.1
4.6
3.2
1.4
0.5
1.9
0.6
0.3
Senior unsecured
Externally issued
23.4
Senior unsecured
I
nternally issued
11.3
5.7
0.4
0.5
3.9
23.4
11.3
5.7
0.4
0.5
3.9
Total outstanding issuance
35.0
19.6
11.4
2.8
1.0
6.7
0.8
0.3
0.3
(1)
The balances are the IFRS balance sheet ca
rrying amounts, which may differ from the amount which the instrument contributes to regulatory capital. Regulatory balan
ces exclude,
for example, issuance costs and fair value movements, wh
ile dated capital is required to be amortised on a straight-line basis over the final five years of maturity.
(2)
Balance sheet amounts reported for AT1
, Tier 1 and Tier 2 instruments are before grandfathering restrictions imposed by CRR.
(3)
Internal issuance for NWB
Plc, RBS plc and UBI
DAC repres
ents AT1, Tier 2 or Senior unsecured issuance to NatWest Holdings Limited and for NWM N.V. and NWM SI to NWM Plc.
(4)
Senior unsecured debt does not
include CP, CD and short term/medium term notes issued from NatWest Group operating subsidiaries.
(5)
Tier 1 (inclusive of AT1) does not
include CET1 numbers.
Risk and capital m
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Capital, liquidity and fundin
g risk continued
Roll-off profile
The following table illustrates the roll-off p
rofile and weighted average spreads of NatWest
Group’s major wholesale fundi
ng
programmes.
As at and
for year ended
Roll
-
off profile
Senior debt roll-off profile
(1)
31 December 2021
H1 2022
H2 2022
2023
2024
2025 & 2026
2027 & later
NatWest Group plc
- amount (£m)
23,424
7
6,814
1,956
6,086
8,561
- weighted average rate spread (bps)
181
224
224
164
178
153
NWM Plc
- amount (£m)
17,360
3,978
2,959
2,359
2,909
4,469
686
- weighted average rate spread (bps)
77
38
58
107
88
92
133
NatWest Bank Plc
- amount (£m)
3,399
3,248
151
- weighted average rate spread (bps)
1
1
(2)
NWM N.V.
- amount (£m)
1,109
576
533
- weighted average rate spread (bps)
13
15
11
NWM S.I.
- amount (£m)
225
4
81
75
65
- weighted average rate spread (bps)
130
64
98
137
168
RBSI
- amount (£m)
460
383
77
- weighted average rate spread (bps)
89
84
103
Securitisation
- amount (£m)
867
289
578
- weighted average rate spread (bps)
5
10
3
Covered bonds
- amount (£m)
2,887
751
2,136
- weighted average rate spread (bps)
129
44
160
Total notes issued
-
amount (£m)
49,731
8,185
3,731
9,924
7,082
10,919
9,890
Weighted average rate spread (bps)
121
24
51
182
130
137
143
Subordinated debt instruments roll-off
profile
(2)
NatWest Group plc (£m)
7,094
981
1,429
1,525
1,953
1,206
NWM Plc (£m)
417
275
119
21
2
NatWest Bank Plc (£m)
87
87
NWM N.V. (£m)
548
104
444
UBIDAC (£m)
73
73
Total (£m)
8,219
275
1,068
1,652
1,525
1,974
1,725
(1)
Based on final contractual instrument maturity.
(2)
Based on first call date of
instrument, however this does not indicate NatWest Group’s strategy on capital and funding management. The tab
le above does not include debt
accounted Tier 1 instruments although those inst
ruments form part of the total subordinated debt balance.
(3)
The weighted average spread reflects the average n
et funding cost to NatWest Group and is calculated on an indicative basis.
(4)
The roll-off table is based on sterling-eq
uivalent balance sheet values.
Risk and capital m
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Capital, liquidity and fundin
g risk continued
Liquidity portfolio
(audited)
The table below shows the liquidity po
rtfolio by product, with primary liquidity aligned
to internal stressed outflow coverage
and
regulatory LCR categorisation. Secondary liquidi
ty comprises assets eligible for discount
at central banks, which do not for
m part
of the liquid asset portfolio for LCR or stress
ed outflow purposes.
Liquidity va
lue
2021
2020
NatWest
Group
(1)
NWH
Group
(2)
UK DoL
Sub
(3)
NatWest
Group
NWH
Group
UK DoL
Sub
£m
£m
£m
£m
£m
£m
Cash and balances at central banks
(4)
174,328
140,562
136,154
115,820
86,575
86,575
AAA to AA- rated governments
31,073
21,710
21,123
50,901
37,086
35,875
A+ and lower rated governments
25
79
Government guaranteed issuers, public sector entities
and
government sponsored entities
307
295
174
272
272
141
International organisations and multil
ateral development
banks
2,720
1,807
1,466
3,140
2,579
2,154
LCR level 1 bonds
34,125
23,812
22,763
54,392
39,937
38,170
LCR level 1 assets
208,453
164,374
158,917
170,212
126,512
124,745
LCR level 2 assets
117
124
Non-LCR eligible assets
Primary liquidity
208,570
164,374
158,917
170,336
126,512
124,745
Secondary liquidity
(5)
77,849
77,660
76,573
91,985
91,761
88,774
Total liquidity value
286,419
242,034
235,490
262,321
218,273
213,519
(1)
NatWest Group includes the UK Domestic L
iquidity Sub-Group (UK DoLSub), NatWest Markets Plc and other significant operating subsidiaries that hold liquidity portfolios. These
include The Royal Bank of Scotland International L
imited, NWM N.V. and Ulster Bank Ireland DAC who hold managed portfolios that comply with local regulations that may differ
from PRA rules.
(2)
NWH Group comprises UK DoLSub and
Ulster Bank Ireland DAC who hold managed portfolios that comply with local regulations that may differ from PRA rules.
(3)
UK DoLSub comprises NatWest Group’s f
our licensed deposit-taking UK banks within the ring-fenced bank: NWB Plc, RBS plc, Coutts & Company and Ulster Bank Limited. Ulster
Bank Limited was removed from the UK DoLSub effective 1
January 2022.
(4)
Following a change
in methodology in our internal stressed outflow coverage metric, cash placed at Central Bank of Ireland within UBIDAC is now reported in the liquidity portfolio.
(5)
Comprises assets eligible for discounting at the Ban
k of England and other central banks.
(6)
NatWest Markets Plc liquidity portfolio is reported in th
e NatWest Markets Plc Annual Report and Accounts.
Risk and capital m
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Capital, liquidity and fundin
g risk continued
Funding sources
(audited)
The table below shows the carrying values of t
he principal funding sources based on contract
ual maturity. Balance sheet captions
include balances held at all clas
sifications under IFRS 9.
2021
2020
Short-term
Long-t
erm
Short-term
Long-term
less than
more t
han
less than
more than
1 year
1 year
Total
1 year
1 year
Total
£m
£m
£m
£m
£m
£m
Bank Deposits
Repos
7,912
7,912
6,470
6,470
Other bank deposits
(1)
5,803
12,564
18,367
5,845
8,291
14,136
13,715
12,564
26,279
12,315
8,291
20,606
Customer Deposits
Repos
14,541
14,541
5,167
5,167
Non-bank financial institutions
57,885
67
57,952
53,475
147
53,622
Personal
230,525
829
231,354
208,046
1,183
209,229
Corporate
175,850
113
175,963
163,595
126
163,721
478,801
1,009
479,810
430,283
1,456
431,739
Trading liabilities
(2)
Repos
(3)
19,389
19,389
19,036
19,036
Derivatives collateral
17,718
17,718
23,229
23,229
Other bank and customer deposits
849
704
1,553
819
985
1,804
Debt securities in issue
-
medium term notes
178
796
974
527
881
1,408
38,134
1,500
39,634
43,611
1,866
45,477
Other financial liabilities
Customer deposits
568
568
616
180
796
Debt securities in issue:
Commercial paper and certificates of deposi
t
9,038
115
9,
153
7,086
168
7,254
Medium term notes
6,401
29,451
35,852
4,648
29,078
33,726
Covered bonds
53
2,833
2,886
53
2,967
3,020
Securitisation
867
867
1,015
1,015
16,060
33,266
49,326
12,403
33,408
45,811
Subordinated liabilities
1,375
7,054
8,429
365
9,597
9,962
Total funding
548,085
55,393
603,478
498,977
54,618
553,595
Of which: available in resolutio
n
(4)
29,624
28,823
(1)
Includes £12.0 billion (2020 – £5.0 billion) relating to Term Fund
ing Scheme with additional incentives for Small and Medium-sized Enterprises participation and nil (2020 – £2.8
billion) relating to NatWest Group’s participation in
central bank financing operations under the European Central Bank’s targeted long-term financing operations.
(2)
Excludes short positions of £25
.0 billion (2020 – £26.8 billion).
(3)
Comprises central & other bank
repos of £0.8 billion (2020 – £1.0 billion), other financial institution repos of £17.0 billion (2020 – £16.0 billion) and other corporate repos of £1.6
billion (2020 – £2.0 billion).
(4)
Eligible liabilities (as d
efined in the Banking Act 2009 as amended from time to time) that meet the eligibility criteria set out in the regulations, rules, policies, guidelines, or
statements of the Bank of England including the Statement of Policy published b
y the Bank of England in June 2018. The balance consists of £23.4 billion (2020 – £20.9 billion) under
debt securities in issue (senior MREL) and £6.2 billion (2020 – £7.9 b
illion) under subordinated liabilities.
Risk and capital m
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Capital, liquidity and fundin
g risk continued
Contractual maturity
(audited)
This
table
shows
the
residual
maturity
of
financial
instrum
ent
s,
based
on
contractual
date
of m
aturity
of
NatWest
Group’s
banking
activities,
including
hedging
d
erivatives. Tra
ding
activities,
comprising
mandatory
fair
value
through
profit
or
loss
(MFVTPL)
assets
and
held-for-trading
(HFT)
liabilities
have
been
excluded
from
the
maturity
analysis
due
t
o
their
short-term
natur
e
and
are
shown
in total in the table below.
Banking activities
Less than 1
1-3
3-6
6 months
3-5
More than
Trading
month
months
mont
hs
-
1 year
Subtotal
1-3 years
years
5 years
Total
activities
Total
2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Cash and balances
177,757
177,757
177,757
177,757
at central banks
Trading assets
59,158
59,158
Derivatives
4
8
5
13
30
10
2
2
44
106,095
106,139
Settlement balances
2,141
2,141
2,141
2,141
Loans to banks -
amortised cost
5,584
220
1,615
6
7,425
20
237
7,682
7,682
Loans to customers
-
amortised cost
(1)
45,553
23,071
16,517
22,238
107,379
53,767
36,481
165,053
362,680
362,680
Personal
4,565
2,416
3,386
6,443
16,810
23,446
21,437
145,453
207,146
207,146
Corporate
28,527
10,116
5,106
7,218
50,967
23,881
13,876
18,853
107,577
107,577
Non-bank financial
institutions
12,461
10,539
8,025
8,577
39,602
6,440
1,168
747
47,957
47,957
Other financial assets
2,502
1,705
1,573
5,439
11,219
9,251
7,558
17,800
45,828
317
46,145
Total financial assets
233,541
25,004
19,710
27,696
305,951
63,048
44,041
183,092
596,132
165,570
761,702
2020
Total financial assets
167,371
20,237
21,478
26,907
235,993
74,266
52,380
192,431
555,070
235,860
790,930
2021
Bank deposits
excluding repos
4,930
454
285
134
5,803
564
12,000
18,367
18,367
Bank repos
6,251
1,661
7,912
7,912
7,912
Customer repos
3,532
11,009
14,541
14,541
14,541
Customer deposits
excluding repos
445,811
12,944
3,200
2,305
464,260
918
69
22
465,269
465,269
Personal
225,623
1,664
1,822
1,416
230,525
829
231,354
231,354
Corporate
168,090
5,908
1,160
692
175,850
36
55
22
175,963
175,963
Non
-
bank financial
institutions
52,098
5,372
218
197
57,885
53
14
57,952
57,952
Settlement balances
2,068
2,068
2,068
2,068
Trading liabilities
64,598
64,598
Derivatives
1
1
1
10
13
92
20
(5)
120
100,715
100,835
Other financial liabilities
1,602
5,547
5,020
3,891
16,060
15,840
9,533
7,893
49,326
49,326
CPs and CDs
1,523
2,864
2,266
2,385
9,038
105
10
9,153
9,153
Medium term notes
28
2,683
2,352
1,338
6,401
12,902
9,234
7,315
35,852
35,852
Covered bonds
50
3
53
2,833
2,886
2,886
Securitisations
289
578
867
867
Customer deposits DFV
1
399
168
568
568
568
Subordinated liabilities
37
272
1,066
1,375
3,165
1,959
1,930
8,429
8,429
Notes in circulation
3,047
3,047
3,047
3,047
Lease liabilities
26
49
72
91
238
220
165
640
1,263
1,263
Total financial liabilities
467,268
31,702
8,850
7,497
515,317
20,799
23,746
10,480
570,342
165,313
735,655
2020
Total financial liabilities
428,632
17,297
10,730
7,106
463,765
23,319
19,708
11,354
518,146
232,831
750,977
(1)
Loans to customers excludes £3.7 billion (2020
£6.0 billion) of impairment provisions.
Risk and capital m
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nt continued
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Capital, liquidity and fundin
g risk continued
Senior notes and subordinated liabilities - residual ma
turity profile by instrument type
(audited)
The table below shows NatWest Group’s de
bt securities in issue and subordinated liabilities by
r
esidual maturity.
Trading
liabilities
Other finan
cial liabilities
Debt securities in iss
ue
Debt securities
Commercial
in issue
paper
Covered
Subordinated
Total notes
MTNs
and CDs
MTNs
bonds
Securitisation
liabilities
Total
in issue
2021
£m
£m
£m
£m
£m
£m
£m
£m
Less than 1 year
178
9,038
6,401
53
1,375
16,867
17,045
1-3 years
335
105
12,902
2,833
3,165
19,005
19,340
3-5 years
112
10
9,234
289
1,959
11,492
11,604
More than 5 years
349
7,315
578
1,930
9,823
10,172
Total
974
9,153
35,852
2,886
867
8,429
57,187
58,161
2020
Less than 1 year
527
7,086
4,648
53
365
12,152
12,679
1-3 years
169
165
13,349
749
3,854
18,117
18,286
3-5 years
240
3
8,538
2,218
296
3,349
14,404
14,644
More than 5 years
472
7,191
719
2,394
10,304
10,776
Total
1,408
7,254
33,726
3,020
1,015
9,962
54,977
56,385
The table below shows the curr
ency breakdown.
GBP
USD
EUR
Other
Total
2021
£m
£m
£m
£m
£m
Commercial paper and CDs
2,692
2,743
3,718
9,153
MTNs
2,471
19,032
13,718
1,605
36,826
Covered bonds
1,820
1,066
2,886
Securitisation
867
867
Subordinated liabilities
2,234
4,825
1,370
8,429
Total
10,084
26,600
19,872
1,605
58,161
2020 total
8,933
25,051
19,917
2,484
56,385
Risk and capital m
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nt continued
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Capital, liquidity and fundin
g risk continued
Funding gap: maturity and segment analysis
The contractual maturity of balance she
et assets and liabilities reflects the maturity
transformation role banks perform, lending
long-term but mainly obtaining f
unding through short-term liabilities such as custo
mer deposits. In practice, the behavioural p
rofiles
of many liabilities show greater
stability and longer maturity than the contractual
maturity. This is particularly true of
many types
of retail and corporate deposits which, despi
te being repayable on demand or at sho
rt notice, have demonstrated very stabl
e
characteristics even in periods of acute st
ress.
In its analysis to assess and manage asset and liabili
ty maturity gaps, NatWest Group deter
mines the expected customer behaviour
through qualitative and quantitative
techniques. These incorporate observed cus
tomer behaviours over long periods of time.
This
analysis is subject to governance
through NatWest Group ALCo Tec
hnical committee down to a segment level. The net behaviou
ral
funding surplus/(gap) and contractual matu
rity analysis is set out below.
Contractual mat
urity
Behavioural maturity
Loans to customers
Customer accounts
Net surplus/(gap)
Net surplus/(gap)
Less
than
1 year
1-
5
years
Greater
than 5
years
Tota
l
Less
than 1
year
1-
5
years
Greater
than 5
years
Tota
l
Less
than 1
year
1-5 years
Greater
than 5
years
T
otal
Less
than 1
year
1-
5
years
Greater
than 5
years
Tota
l
2021
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£
bn
£
bn
£bn
£bn
£b
n
£bn
£bn
£bn
Retail Banking
12
39
131
182
188
1
189
176
(38)
(131)
7
(7)
18
(4)
7
Private Banking
3
6
9
18
39
39
36
(6)
(9)
21
(1)
9
13
21
Commercial Banking
50
33
18
101
178
178
128
(33)
(18)
77
4
79
(6)
77
RBS International
7
6
3
16
38
38
31
(6)
(3)
22
5
6
11
22
NatWest Markets
12
4
1
17
13
1
14
1
(3)
(1)
(3)
1
(4)
(3)
Central items & other
2
2
1
1
(1)
(1)
(1)
(1)
Total excluding
Ulster Bank RoI
86
88
162
336
457
2
459
371
(86)
(162)
123
1
108
14
123
Ulster Bank RoI
1
2
4
7
18
18
17
(2)
(4)
11
10
1
11
Total
87
90
166
343
475
2
477
388
(88)
(166)
134
11
109
14
134
2020
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£
bn
£
bn
£bn
£bn
£b
n
£bn
£bn
£bn
Total
75
104
169
348
438
2
440
363
(102)
(169)
92
22
58
12
92
(1)
Loans to customers and customer a
ccounts inclu
de trad
ing assets and trading liabilities respectively and excludes reverse repos and repos.
The net customer funding surplus has increase
d by £42
billion during 2021 to £134 billion drive
n by a £37 billion
growth in deposits and a £5 billion decline in lo
ans to
customers.
Customer deposits and loans to cu
stomers are broadly
matched from a behavioural perspective.
The net funding surplus in 2021 is mainly concen
trated in
the longer dated buckets, reflecting stable characte
ristics of
customer deposits.
Risk and capital m
anageme
nt continued
NatWest Group
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Additional
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Capital, liquidity and fundin
g risk continued
Encumbrance
(audited)
NatWest Group evaluates the extent to which assets c
an be
financed in a secured form (encumbrance), but certai
n asset
types lend themselves more readily to encu
mbrance. The typical
characteristics that support encumbrance are a
n ability to
pledge those assets to another counterparty o
r entity through
operation of law without necessarily requiring prior notifica
tion,
homogeneity, predictable and measurable cash flo
ws, and a
consistent and uniform underwriting and collectio
n process.
Retail assets including residential mortgages, credit c
ard
receivables and personal loans display many of t
hese features.
NatWest Group categorises its asse
ts into four broad groups,
those that are:
Already encumbered and used to support funding cu
rrently
in place through own-asset securitisations, co
vered bonds
and securities repurchase agreements.
Pre-positioned with central banks as part of fundi
ng
schemes and those encumbered under such sche
mes.
Ring-fenced to meet regulatory requirements, where
NatWest Group has in place an operational continuity in
resolution (OCIR) investment mandate wherein the PRA
requires critical service providers to hold seg
regated liquidity
buffers covering at least 50% of their annual fixed
overheads.
Not currently encumbered. In this c
ategory, NatWest Group
has in place an enablement programme which see
ks to
identify assets capable of being e
ncumbered and to identify
the actions to facilitate such encumbrance w
hilst not
affecting customer relationships or servicing.
Programmes to manage the use of asse
ts to actively support
funding are established within UK DoLSub, UBI
DAC and
NatWest Markets Plc.
Balance sheet encumbrance
The table shows the retained encumbrance asse
ts of NatWest Group.
Encumbered as a res
ult of
transactions with
Unencumbered a
ssets not
counterparties
Collateral
pre-positioned
other than central
banks
Pre-positioned
ring-fenced
with central
banks
Covered
SFT,
& en
cumbered
to meet
debts &
derivatives
a
ssets held
regulatory
Readily
Other
Cannot
securitisa-
and similar
Total
at cent
ral
requirement
available
available
be used
tions (1)
(2,3)
(4)
ba
nks (5)
(6)
(7)
(8)
(9)
Total
Total (10)
2021
£bn
£bn
£bn
£bn
£
bn
£b
n
£bn
£
bn
£bn
£bn
Cash and balances at central
banks
-
5.1
5.1
-
-
172.7
-
-
172.7
177.8
Trading assets
-
36.7
36.7
-
-
0.8
0.9
20.8
22.5
59.2
Derivatives
-
-
-
-
-
-
-
106.1
106.1
106.1
Settlement balances
-
-
-
-
-
-
-
2.1
2.1
2.1
Loans to banks
-
amortised cost
-
0.1
0.1
-
-
6.7
0.6
0.3
7.6
7.7
Loans to customers - amortised
cost
11.8
1.8
13.6
122.4
-
58.1
116.5
48.4
223.0
359.0
- residential mortagages
- UK
8.3
-
8.3
119.7
-
44.4
14.2
-
58.6
186.6
- Rol
1.2
-
1.2
2.7
-
2.0
-
-
2.0
5.9
-
credit cards
-
-
-
-
-
3.5
0.4
-
3.9
3.9
- personal loans
-
-
-
-
-
5.1
2.4
1.4
8.9
8.9
- other
2.3
1.8
4.1
-
-
3.1
99.5
47.0
149.6
153.7
Other financial assets
-
15.4
15.4
-
2.0
27.7
0.4
0.6
28.7
46.1
Intangible assets
-
-
-
-
-
-
-
6.7
6.7
6.7
Other assets
-
-
-
-
-
-
1.9
6.4
8.3
8.3
Assets of disposal groups
0.1
-
0.1
3.8
-
1.9
3.2
-
5.1
9.0
Total assets
11.9
59.1
71.0
126.2
2.0
267.9
123.5
191.4
582.8
782.0
2020
Total assets
14.8
70.8
85.6
134.0
2.2
203.7
123.1
250.9
577.7
799.5
(1)
Covered debts and securitisations include securitisations, conduits, covered bonds and s
ecured notes.
(2)
Repos and other secured deposits, cash, coin and
nostro balance held with the Bank of England as collateral against deposits
and notes in circulation are included here rather than
within those positioned at the central bank as they are part of normal banki
ng operations. Securities financing transactions (SFT) include collateral given to secure d
erivative liabilities.
(3)
Derivative cash collateral of £12.0 billion (2020
-
£18.8 billion) has been included in the encumbered assets basis the regulatory requir
ement.
(4)
Total assets encumbered as a result of transactions with counterparties oth
er than central banks are those that have been ple
dged to provide security and are therefore not available
to secure funding or to meet other collatera
l needs.
(5)
Assets pre
-
positioned at the central banks include loans provided as security as part of funding s
chemes and those encumbered under such
schemes.
(6)
Ring
-
fenced to meet regulatory requirement includes assets ring fenced to meet operational continuity in
resolution (OCIR) investment mandate.
(7)
Readily available for encumbrance: including assets that have been enabled for use with centra
l banks but not pre
-
positioned; cash and high quality debt securities that form part of
NatWest Group’s liquidity por
tfolio and unencumbered debt securities.
(8)
Other assets that are capable of being encumbered are th
ose assets on the balance sheet that are available for funding and co
llateral purposes but are not readily realisable in their
current form. These assets include loans that could b
e pre
-positioned with central banks but have not been subject to internal and external documentation
review and diligence work.
(9)
Cannot be used includes:
(a)
Derivatives, reverse repurchase agreements and trading related settlement balances.
(b)
Non
-
financial assets such as intangibles, prepayments and deferred tax.
(c)
Loans that cannot be pre
-
positioned with central banks based on criteria set by the central banks, including those relating to date of origination and
level of documentation.
(d)
Non
-
recourse invoice financing balances and certain shipping loans
whose terms and structure prohibit their use as collateral.
(10)
In accordance with market practice, NatWest Group
employs securities recognised on the balance sheet, and securities received
under reverse repo transactions as collateral for repos.
Risk and capital m
anageme
nt continued
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266
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Risk and capital management
Additional information
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Additional informatio
n
Financial review
Market risk
(audited)
NatWest Group is exposed to n
on-traded market risk through
its banking activities and to traded m
arket risk through its
trading activities. Non-traded and traded m
arket risk exposures
are managed and discussed separately. The non
-traded market
risk section begins below. The traded market risk se
ction
begins on page 274. Pension-re
lated activities also give rise to
market risk. Refer to page 278 for more info
rmation on risk
related to pensions.
Non-traded market risk
Definition
(audited)
Non-traded market risk is the risk to the value of
assets or
liabilities outside the trading book, or the risk
to income, that
arises from changes in market prices suc
h as interest rates,
foreign exchange rates and eq
uity prices, or from changes in
managed rates.
Sources of risk
(audited)
The key sources of non-traded market risk are interest
rate
risk, credit spread risk, foreign exchange risk, equity
risk and
accounting volatility risk.
For detailed qualitative and quantitative info
rmation on each of
these risk types, refer to the separate sub-se
ctions following
the VaR table below.
Key developments in 2021
As inflationary pressures increas
ed in 2021, market
expectations regarding the future path of interest
rates
changed. The five-year sterling overnight index in
terest rate
swap rate rose from -0.01% at 31
December 2020 to 1.05%
at 31 December 2021. The corres
ponding ten-year rate
rose from 0.16% to 0.95%. At 31 December 2021 ma
rket
rates implied several increases in the UK base rate from
0.25%; at 31 December 2020 the
y had implied potential cuts
to the rate from 0.1%.
The sensitivity of net interest earnings to a 25 basis p
oint
upward shift in the market-implied yie
ld curve was a
cumulative £1,183 million over three years at 31
December
2021, down from £1,455 million at 31 December 202
0. The
decrease partly reflected the higher impact of cent
ral bank
policy rates in the market-implied curve at 31 Dece
mber
2021.
NatWest Group’s structural hedge of
equity and deposits
provides some protection again
st volatility in interest rates.
Notably, the product structural hedge notional, which
captures deposits in the Retail and Comme
rcial Banking
franchises, increased from £169 billion at 31 Dece
mber
2020 to £206 billion at 31 December 2021 as more b
alances
were included in the hedging prog
ramme. This increase
mainly reflected the significant growth in custo
mer deposits
during the pandemic.
Although swap rates began to
rise in H2 2021, the yield on
the structural hedge fell from 1.0
6% to 0.75%. This mainly
resulted from maturing of swaps
and increased hedging.
Increased volumes are initially hedged at sho
rter dates to
ensure an evenly amortising risk profile. The reducti
on in
fixed yield also, in part, reflects the transition f
rom LIBOR to
the SONIA benchmark. New hedges are indexed
against
SONIA, which is a risk-free ben
chmark and therefore has a
lower outright coupon.
Sterling strengthened against the euro, to 1.19 a
t 31
December 2021 compared to 1.11
at 31 December 2020. It
weakened slightly against the US dollar,
to 1.35 at 31
December 2021 compared to 1.37
at 31 December 2020.
Structural foreign currency exposures decreased, in s
terling
equivalent terms, over the year, mainly
driven by increased
hedging of NatWest Holdings’ investment in UBI
DAC.
Governance
(audited)
Responsibility for identifying, measuring, monito
ring and
controlling market risk arising from non-tradi
ng activities lies
with the relevant business. Oversight is provided
by the
independent Risk function.
Risk positions are reported regularly to the
Executive Risk
Committee and the Board Risk C
ommittee, as well as to the
Asset & Liability Management Committee. Non-t
raded market
risk policy sets out the governance
and risk management
framework.
Risk
appetite
NatWest Group’s qualitative appetite is set out in t
he non-
traded market risk appetite statement.
Its quantitative appetite is expresse
d in terms of value-at-risk
(VaR), stressed value-at-risk (SVaR), sensiti
vity and stress limits,
and earnings-at-risk limits.
The limits are reviewed to reflect changes i
n risk appetite,
business plans, portfolio composition and the
market and
economic environments. To ensure approved limi
ts are not
breached and that NatWest Group remains wi
thin its risk
appetite, triggers have been set and are actively
managed. For
further information on risk appetite and risk cont
rols, refer to
pages 192 and 193.
Risk and capital m
anageme
nt continued
NatWest Group
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267
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Risk and capital management
Additional information
Financial review
Non-traded market risk continued
Risk measurement
(audited)
Non-traded internal VaR (1-day 99%)
The following table shows one-day inte
rnal banking book value-at-risk (VaR) at a 9
9% confidence level, split by risk type. Va
R
values for each year are calculated based on one-d
ay values for each of the 12 month-en
d reporting dates.
NatWest Group’s VaR metrics a
re explained on page 269. Each of the key
risk types are discussed in greater detail in thei
r
individual sub-sections following this table.
2021
2020
Average
Maximum
Minimum
Period end
Average
Maximum
Minimum
Period end
£m
£m
£m
£m
£m
£m
£m
£m
Interest rate
10.2
13.7
6.4
8.6
14.1
17.7
8.0
12.3
Credit spread
102.9
113.5
92.4
100.9
103.2
121.1
63.7
111.5
Structural foreign exchange rat
e
11.4
13.2
9.2
12.0
10.8
14.7
9.1
8.9
Equity
12.4
14.6
11.1
14.3
28.5
35.4
24.9
11.6
Pipeline risk
(1)
0.5
1.2
0.3
1.2
0.5
0.7
0.3
0.3
Diversification
(2)
(12.9)
(35.6)
(18.9)
4.2
Total
124.5
147.1
101.4
101.4
138.2
159.9
70.8
148.8
(1)
Pipeline risk is the risk of loss arising from persona
l customers owning an option to draw down a loan – typically a mortgage – at a committed rate, where interest rate changes
may result in greater or fewer customers than anticipated ta
king up the committed offer.
(2)
NatWest Group benefits from diversification across
various financial instrument types, currencies and markets. The extent of the diversification benefit depends on the correlation
between the assets and risk factors in the portfolio at a part
icular time. The diversification factor is the sum of the VaR on individual risk types less the total portfolio VaR.
On an average basis, non-traded VaR was broadly stable
over 2021. Period-end VaR refle
cts the completion of the
transition from LIBOR to risk-free benchmarks.
The decrease in equity VaR, on an average basis, reflects the
disposal of SABB in 2020.
Risk and capital m
anageme
nt continued
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nts 2021
268
Financial statements
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Risk and capital management
Additional information
Financial review
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Strategic report
Governance
Risk and capital management
Additional information
Financial revie
w
Financial statements
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Governance
Risk and capital management
Additional information
Financial review
Non-traded market risk
continued
Interest rate risk
Non-traded interest rate risk (NT
IRR) arises from the provision
to customers of a range of banking p
roducts with differing
interest rate characteristics. Whe
n aggregated, these products
form portfolios of assets and lia
bilities with varying degrees of
sensitivity to changes in market
interest rates. Mismatches can
give rise to volatility in net intere
st income as interest rates
vary.
NTIRR comprises the following three primary risk types:
Gap risk: arises from the timing of
rate changes in non-
trading book instruments. The extent of gap risk depen
ds
on whether changes to the term structu
re of interest rates
occur consistently across the yie
ld curve (parallel risk) or
differentially by period (non-parallel risk).
Basis risk: captures the impact of relative chan
ges in
interest rates for financial instruments that have simila
r
tenors but are priced using different interest
rate indices, or
on the same interest rate indice
s but with different tenors.
Option risk: arises from option derivative p
ositions or from
optional elements embedded in asse
ts, liabilities and/or off-
balance sheet items, where NatWes
t Group or its customer
can alter the level and timing of their cash flows. Optio
n
risk also includes pipeline risk.
To manage exposures within its risk appetite, N
atWest Group
aggregates interest rate positions and hedges its
residual
exposure, primarily with interest rate sw
aps.
Structural hedging aims to red
uce gap risk and the sensitivity
of earnings to interest rate shocks. It also provides s
ome
protection against prolonged p
eriods of falling rates. Structural
hedging is explained in greater detail belo
w, followed by
information on how NatWest Group measures NTIRR f
rom both
an economic value-based and an earnings-based pe
rspective.
Structural hedging
NatWest Group has a significant pool of stable,
non and low interest-bearing liabilities, princip
ally comprising equity and money
transmission accounts. These balances are usually hedged
, either by investing directly in long
er-term fixed-rate assets (such as
fixed-rate mortgages or UK government gilts) o
r by using interest rate swaps, which are gen
erally booked as cash flow hedges of
floating-rate assets, in order to provide a consis
tent and predictable revenue stream.
After hedging the net interest rate exposu
re externally, NatWest Group allocates income to e
quity or products in structural hedges
by reference to the relevant interest rate swa
p curve. Over time, this approach has provided a basis fo
r stable income attribution
to products and interest rate returns. The program
me aims to track a time series of medium-t
erm swap rates, but the yield will be
affected by changes in product
volumes and NatWest Group’s capital compositi
on.
The table below shows the total income and tot
al yield, incremental income relative
to short-term cash rates, and the period
-end
and average notional balances allocated to e
quity and products in respect of the s
tructural hedges managed by NatWest Group.
2021
2020
Incremental
Total
Period end
Average
Total
Increment
al
T
otal
Period end
Average
Total
income
income
notional
notional
y
ield
income
income
notional
notiona
l
yield
£m
£m
£bn
£bn
%
£m
£m
£bn
£bn
%
Equity structural hedging
426
448
21
22
2.05
478
580
23
24
2.43
Product structural hedging
744
861
161
145
0.59
543
958
125
115
0.83
Other structural hedges
139
115
24
23
0.51
119
150
21
20
0.73
Total
1,309
1,
424
206
190
0.75
1,140
1,688
169
159
1.06
Equity structural hedges refer to income alloca
ted primarily to equity and reserves. At 31
D
ecember 2021, the equity structural
hedge notional was allocated between NWH
Group and NWM Plc in a ratio of app
roximately 80/20 respectively.
Product structural hedges refer to income alloc
ated to customer products by NWH Group Tre
asury, mainly current accounts
and
customer deposits in Commercial Banking an
d UK Retail Banking. Other structural hedges refe
r to hedges managed by UBIDAC,
Private Banking, Ulster Bank Limited and RBS In
ternational. Hedges associated with Uls
ter Bank Limited were moved from
other
structural hedges to product hedges in H1 202
1 as Ulster Bank Limited products migrated to NatWest B
ank Plc.
At 31 December 2021, approximately
93% by notional of total structural hedges were s
terling-denominated.
Risk and capital m
anageme
nt continued
NatWest Group
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Additional information
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Risk and capital management
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Risk and capital management
Additional information
Financial review
Non-traded market risk
continued
The following table presents th
e incremental income associated with product s
tructural hedges at segment level.
2021
2020
£m
£
m
Retail Banking
346
251
Commercial Banking
398
292
Total
744
543
The increase in hedge notional, on a period-e
nd basis,
mainly resulted from increased hedging of Person
al and
Commercial deposits. This refle
cted the increase in
underlying customer deposit ba
lances.
The five-year sterling swap rate rose to 1.05% at t
he end of
December 2021 from -0.01% at the end of
December 2020.
The ten-year sterling swap rate also rose, fr
om 0.16% to
0.95%. Despite the swap rate rises
, the yield of the
structural hedge fell. This was partly due to the ful
l-year
impact of hedges booked in 202
0 and the impact of hedging
balance growth, where new hedges may be
booked initially
at shorter maturities than five o
r ten years and therefore
attract a lower coupon than the
five or ten-year swap rate.
During 2021, sterling-denominated structural hedges
were
migrated from LIBOR to a SONIA index. US dolla
r-
denominated structural hedges were migrated from L
IBOR
to a SOFR index. Because SONIA and SOFR are
risk-free
benchmarks, as maturing hedges
are replaced the yield
going forward will increasingly reflec
t the lack of risk
premium. Euro-denominated hedges remain inde
xed
against EURIBOR.
NTIRR can be measured using value-based or e
arnings-based approaches. Value-based a
pproaches measure the change in value
of the balance sheet assets and liabilities including
all cash flows. Earnings-based approache
s measure the potential impact on the
income statement of changes in interest r
ates over a defined horizon, generally one to three
years.
NatWest Group uses VaR as its value-base
d approach and sensitivity of net interest earnings
as its earnings-based approach.
These two approaches provide complementary views of t
he impact of interest rate risk on the
balance sheet at a point in time. T
he
scenarios employed in the net interest earni
ngs sensitivity approach may incorporate
assumptions about how NatWest Group and
its customers will respond to a
change in the level of interest rates. In cont
rast, the VaR approach measures the se
nsitivity of the
balance sheet at a point in time. Capturing all cas
h flows, VaR also highlights the impact of du
ration and repricing risks beyond the
one-to-three-year period shown in earnings sensiti
vity calculations.
Value-at-risk
VaR is a statistical estimate of the potential ch
ange in the market value of a portfolio (
and, thus, the impact on the income
statement) over a specified time
horizon at a given confidence level.
NatWest Group’s standard VaR metrics
– which assume a time horizon of one trading day an
d a confidence level of 99% – are
based on interest rate repricing
gaps at the reporting date. Daily rate moves are modelled usi
ng observations from the last 500
business days. These incorporate customer p
roducts plus associated funding and hedging t
ransactions as well as non-financial
assets and liabilities. Behaviour
al assumptions are applied as appropriate.
The non-traded interest rate risk
VaR metrics for NatWest Group’s retail and commercial b
anking activities are included in the
banking book VaR table presented earlie
r in this section. The VaR captures the risk resu
lting from mismatches in the reprici
ng
dates of assets and liabilities.
It also includes any mismatch be
tween the maturity profile of external hedges and N
atWest Group’s target maturity profile for
the
hedge.
Risk and capital m
anageme
nt continued
NatWest Group
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270
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Additional information
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Additional information
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Non-traded market risk continued
Sensitivity of net interest earnings
Net interest earnings are sensitive to ch
anges in the level of
interest rates, mainly because ma
turing structural hedges are
replaced at higher or lower rate
s and changes to coupons on
managed rate customer products do not always matc
h changes
in market rates of interest or central bank policy
rates.
Earnings sensitivity is derived from a market-implied fo
rward
rate curve, which will incorporate expected changes
in central
bank policy rates such as the Bank of England b
ase rate. A
simple scenario is shown that p
rojects forward earnings based
on the 31 December 2021 balance shee
t, which is assumed to
remain constant. An earnings projection is
derived from the
market-implied curve, which is
then subject to interest rate
shocks. The difference between the ma
rket-implied projection
and the shock gives an indication of underlying sensitivi
ty to
interest rate movements.
Reported sensitivities should not be conside
red a forecast of
future performance in these rate
scenarios. Actions that could
reduce interest earnings sensitivity include ch
anges in pricing
strategies on customer loans and deposi
ts as well as hedging.
Management action may also be
taken to stabilise total income
also taking into account non-interest income.
Three-year 25-basis-point sensitivity table
The table below shows the sensitivity of net interes
t earnings –
for both structural hedges and managed
rate accounts – on a
one, two and three-year forwa
rd-looking basis to an upward or
downward interest rate shift of 2
5 basis points.
In the upward rate scenario, yie
ld curves were assumed to
move in parallel, at both year-ends.
The downward rate scenario at both year-en
ds allows interest
rates to fall to negative rates.
+25 basis points
upward shift
-25 basis points down
ward shift
Year 1
Year 2 (1)
Year
3 (1)
Year 1
Year 2 (1)
Y
ear 3 (1)
2021
£m
£m
£m
£m
£m
£m
Structural hedges
43
144
235
(43)
(144)
(235)
Managed margin
282
220
2
55
(255)
(209)
(187)
Other
4
(5)
Total
329
364
4
90
(303)
(353)
(422)
2020
Structural hedges
37
118
199
(37)
(118)
(199)
Managed margin
319
380
387
(258)
(285)
(
292)
Other
15
(20)
Total
371
498
586
(315)
(403)
(
491)
(1)
The projections for Year 2 and Year 3 consider only th
e main drivers of earnings sensitivity, namely structural hedging and m
argin management.
(2)
The assumption of a constant balance sheet means that UBIDAC balances are held
constant. UBIDAC contributes
a relatively small proportion of NatWest Group’s overall
earnings sensitivity. For example, UBIDAC contributes app
roximately 6% to NatWest Group’s overall sensitivity to an upward 25-basis-point rate shift over three years.
The increase in structural hedge
sensitivity at 31 December
2021 reflects the increase in the hedge notional since 31
December 2020.
The reduction in managed mar
gin sensitivity in the upward
and downward 25-basis-point rate shifts as well as in
the
upward 100-basis-point shift partly reflects the higher level
of interest rates at 31 December 20
21 compared to 31
December 2020. In the market-implied projecti
on, the UK
base rate is projected to rise se
veral times from 0.25% over
the three years from 31 December 2021
. The UK base rate
had been projected to fall below 0.1
% over the three years
from 31 December 2020. When interest
rates are higher,
the pricing response to further une
xpected shifts in rates
differs from the response when rates are ve
ry low or
negative.
One-year 25 and 100-basis-point sensitivity table
The following table analyses the one-y
ear scenarios by currency and, in addition, shows the i
m
pact over one year of a 100-
basis-
point upward shift in all interest rates
.
2021
2020
Shifts in yield curve
Shifts in yield curve
+25
-
25
+100
+25
-
25
+100
basis points
basis points
basis points
basis points
basis points
basis points
£m
£m
£m
£m
£m
£m
Euro
20
(3)
129
7
(6)
99
Sterling
267
(264)
969
336
(287)
1,109
US dollar
40
(33)
143
26
(22)
102
Other
2
(3)
1
0
2
7
Total
329
(303)
1,251
371
(315)
1,317
Risk and capital m
anageme
nt continued
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Risk and capital management
Additional information
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Non-traded market risk continued
Sensitivity of fair value through other comprehensive income (FVOCI) and cash
flow hedging reserves to interest rate
movements
NatWest Group holds most of the bonds in its liquidi
ty portfolio at fair value. Valuation change
s that are not hedged (or not in
effective hedge accounting relationships) a
re recognised in FVOCI reserves.
Interest rate swaps are used to implement the s
tructural hedging programme and also hedgin
g of some personal and commercial
lending portfolios, primarily fixed-rate
mortgages. Generally, these
swaps are booked in hedge accounting relationships. Ch
anges
in the valuation of swaps that are in eff
ective cash flow hedge accounting relationships a
re recognised in cash flow hedge
reserves.
The table below shows the sensitivity of FVOCI reserves
and cash flow hedge reserves to a parallel shift in all
rates. In this analysis,
interest rates have not been floored at zero. Cash f
low hedges are assumed to be fully ef
fective and interest rate hedges of bonds
in the liquidity portfolio are also assumed t
o be subject to fully effective hedge accounting. He
dge accounting ineffectiveness would
result in some deviation from the results below,
with some gains or losses recog
nised in P&L instead of reserves. Hedge
ineffectiveness P&L is monitored, and the effec
tiveness of cash flow and fair value hedge rela
tionships is regularly tested in
accordance with IFRS requirements. Note tha
t a movement in the FVOCI reserve would have
an impact on CET1 capital but a
movement in the cash flow hedge reserve woul
d not be expected to do so. Volatility in both re
serves affects tangible net asset
value.
2021
2020
+25 basis points
-
25 basis points
+100 basis points
-
100 basis points
+25 basis points
-
25 basis points
+100 basis points
-
100 basis points
£m
£m
£m
£m
£m
£m
£m
£m
FVOCI reserves
(46)
45
(187)
174
(50)
48
(207)
181
Cash flow hedge reserves
(210)
2
14
(82
0)
877
(108)
109
(421)
447
Total
(256)
2
59
(1,007)
1,
051
(158)
157
(628)
628
The main driver of the increase in NatWes
t Group’s cash flow hedge reserve sensitivity w
as the increase in interest rate swaps
that form part of the structural hedge. T
he increase in the hedge was driven by higher cus
tomer deposits during the COVID
-19
pandemic.
Risk and capital m
anageme
nt continued
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Additional information
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Strategic report
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Risk and capital management
Additional informati
on
Financial review
Non-traded market risk continued
Credit spread risk
Credit spread risk arises from the potential
adverse economic
impact of a change in the spread betwee
n bond yields and
swap rates, where the bond portfolios are accounted
at fair
value through equity.
NatWest Group’s bond portfolios primarily co
mprise high-quality
securities maintained as a liquidity buffer to e
nsure it can
continue to meet its obligations in the event
that access to
wholesale funding markets is re
stricted. Additionally, other high-
quality bond portfolios are held for collater
al purposes and to
support payment systems.
Credit spread risk is monitored daily through sens
itivities and
VaR measures. The dealing aut
horities in place for the bond
portfolios further mitigate the risk by imposing const
raints by
duration, asset class and credit rating. Exposures a
nd limit
utilisations are reported to senior managemen
t on a daily basis.
Foreign exchange risk
Non-traded foreign exchange risk arises from three mai
n
sources:
Structural foreign exchange rat
e risk – arises from the
capital deployed in foreign subsidiaries, branches and join
t
arrangements and related currency
funding where it differs
from sterling.
Non-trading book foreign exchange rate risk – arises
from
customer transactions and profits and losses
that are in a
currency other than the functional currency.
Forecast earnings or costs in foreign cu
rrencies – NatWest
Group assesses its potential exposure to forecast f
oreign
currency income and expenses. N
atWest Group hedges
forward some forecast expenses.
The most material non-traded open currency positio
ns are the
structural foreign exchange exposures a
rising from investments
in foreign subsidiaries, branches and associ
ates and their
related currency funding. These
exposures are assessed and
managed to predefined risk appetite levels under
delegated
authority agreed by the CFO with suppor
t from
the Asset &
Liability Management Committe
e. NatWest Group seeks to limit
the potential volatility impact on its CET1 ratio f
rom exchange
rate movements by maintaining a structural open cur
rency
position. Gains or losses arising from the retransla
tion of net
investments in overseas operati
ons are recognised in equity
reserves and reduce the sensitivity of capi
tal ratios to foreign
exchange rate movements primarily arising from
the
retranslation of non-sterling denominated
RWAs. Sensitivity is
minimised where, for a given currency, the r
atio of the
structural open position to RW
As equals the CET1 ratio.
The sensitivity of this ratio to exchange rates is mo
nitored
monthly and reported to the Ass
et & Liability Management
Committee at least quarterly. Foreign exc
hange exposures
arising from customer transactions are sol
d down by businesses
on a regular basis in line with NatWest G
roup policy.
Foreign exchange risk
(audited)
The table below shows structural foreign cu
rrency exposures.
Structural foreign
R
esidual
currency
Structural
Net investment
s
Net
exposures
foreign
in foreign
investment
pre-economic
Economic
currency
operations
hedges
hedges
hedges
(1)
exposures
2021
£m
£m
£m
£m
£m
US dollar
1,275
(260)
1,015
(1,015)
Euro
6,222
(2,6
69)
3,553
3,553
Other non-sterling
990
(421)
569
569
Total
8,487
(3,3
50)
5,137
(1,015)
4,122
2020
US dollar
1,299
(3)
1,296
(1,296)
Euro
6,485
(829)
5,656
5,656
Other non-sterling
1,077
(350)
727
727
Total
8,861
(1,182)
7,679
(1,296)
6,383
(1)
Economic hedges of US dollar net invest
ments in foreign operations represent US dollar equity securities that do not qualify as net investment hedg
es for accounting purposes. They
provide an offset to structural foreign exchange
exposures to the extent that there are net assets in overseas operations available.
The decrease in net investments
in foreign operations was
partly driven by sterling strengthening against t
he euro.
The increase in the sterling value of ne
t investment hedges
was mainly driven by increased hedging of Nat
West
Holdings’ investment in UBIDAC.
During the year, NatWest Group also inc
reased net
investment hedging in US dollar and other n
on-sterling
currencies to reduce the potential impact on RWAs of
changes to its regulatory foreign exchange he
dging
permission.
Changes in foreign currency exchange rates aff
ect equity in
proportion to structural foreign currency exposure. Fo
r
example, a 5% strengthening or weakening in fo
reign
currencies against sterling would result in a gain o
r loss of
£0.3 billion in equity respectivel
y.
Risk and capital m
anageme
nt continued
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Additional information
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Additiona
l information
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Additional
information
Financial review
Non-traded market risk continued
Equity risk
(audited)
Non-traded equity risk is the potential variation in inco
me and reserves arising from changes i
n equity valuations. Equity exposures
may arise through strategic acquisitions, venture c
apital investments and restructuring a
rrangements.
Investments, acquisitions or dis
posals of a strategic nature are refe
rred to the Acquisitions & Disposals Committee. Once a
pproved
by the CFO with support from the Acquisitions & Disp
osals Committee for execution, such tra
nsactions are referred for approval to
the Board, the Executive Committee, the Chief Execu
tive, the Chief Financial Officer or as otherwise requi
red. Decisions to acquire
or hold equity positions in the non-trading book tha
t are not of a strategic nature, such as customer restructu
rings, are taken by
authorised persons with delega
ted authority.
Equity positions are carried at fair value on
the balance sheet based on market prices whe
re available. If market prices are not
available, fair value is based on appropriate valuation tech
niques or management estimates.
The table below shows the balance sheet ca
rrying value of equity positions in the banking book.
2021
2020
£m
£m
Exchange-traded equity
16
14
Private equity
160
160
Other
66
78
242
252
The exposures may take the form of (i) equity shares listed
on a recognised exchange, (ii) priv
ate equity shares defined as un
listed
equity shares with no observab
le market parameters or (iii) other unlisted equi
ty shares.
2021
2020
£m
£m
Net realised gains arising from disposals
8
(248)
Unrealised gains included in Tier 1 or Tier 2 c
apital
88
82
(1)
Includes gains or losses on FVOCI instruments on
ly.
The losses on disposals in 2020 mainly
reflected the disposal of SABB.
Accounting volatility risk
Accounting volatility risk arises when an e
xposure is accounted
for at amortised cost but econo
mically hedged by a derivative
that is accounted for at fair value. Although this is no
t an
economic risk, the difference in accounting be
tween the
exposure and the hedge creates volatility in t
he income
statement.
Accounting volatility can be mitigated throug
h hedge
accounting. However, residual volatility will remain in cases
where accounting rules mean that hedge accounting is no
t an
option, or where there is some hedge ineffe
ctiveness.
Accounting volatility risk is reported to the Ass
et & Liability
Management Committee monthly and c
apitalised as part of the
Internal Capital Adequacy Assess
ment Process (ICAAP).
Risk and capital m
anageme
nt continued
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Traded market risk
Definition
(audited)
Traded market risk is the risk arising from ch
anges in fair value
on positions, assets, liabilities or commitmen
ts in trading
portfolios as a result of fluctuations in market prices.
Sources of risk
(audited)
Traded market risk mainly aris
es from NatWest Group’s trading
activities. These activities provide a range of fin
ancing, risk
management and investment se
rvices to clients − including
corporations and financial instit
utions − around the world. From
a market risk perspective, activities are focused on
rates;
currencies; and traded credit. NatWest G
roup undertakes
transactions in financial instruments includi
ng debt securities,
as well as securities financing and deriva
tives.
All material traded market risk resi
des in NatWest Markets. The
key categories are interest rate risk, credit spre
ad risk and
foreign currency price risk.
Trading activities may also give rise to coun
terparty credit risk.
For further detail refer to the C
redit risk section.
Key developments in 2021
The UK, US and eurozone economies rebounded st
rongly in
2021 following the rollout of COVID-19 v
accines. However,
inflation rose in H2 2021, in part due to global supply
disruptions. This led to further market volatili
ty, particularly
in Rates, due to significant shifts
in inflation expectations.
Traded VaR remained within appetite,
with an average-
basis year-on-year reduction d
riven by de-risking activity in
line with the strategic focus on RWA reduc
tion.
Governance
(audited)
Market risk policy statements set out the gove
rnance and risk
management framework. Responsibility for identifying,
measuring, monitoring and controlling market risk
arising from
trading activities lies with the re
levant trading business. The
Market Risk function independently advises
on, monitors and
challenges the risk-taking activi
ties undertaken by the trading
business ensuring these are within the co
nstraints of the
market risk framework, policies, and
risk appetite statements
and measures.
Risk appetite
NatWest Group’s qualitative appetite for traded m
arket risk is
set out in the traded market risk appetite statemen
t.
Quantitative appetite is expressed in terms of exposu
re limits.
The limits at NatWest Group level comprise value-
at-risk (VaR)
and stressed value-at-risk (SVaR). More details o
n these are
provided on the following pages.
For each trading business, a document known
as a dealing
authority compiles details of all applicable limits an
d trading
restrictions. The desk-level mandates
comprise qualitative limits
related to the product types wit
hin the scope of each desk, as
well as quantitative metrics spec
ific to the desk’s market risk
exposures. These additional limits and metrics ai
m to control
various risk dimensions such as exposure size, aged in
ventory,
currency and tenor.
The limits are reviewed to reflect changes i
n risk appetite,
business plans, portfolio composition and the
market and
economic environments and rec
alibrated to ensure that they
remain aligned to NatWest Group RWA targets. Limi
t reviews
focus on optimising the alignment between t
raded market risk
exposure and capital usage.
To ensure approved limits are not breached an
d that NatWest
Group remains within its risk appetite, tri
ggers have been set
such that if exposures exceed a specified le
vel, action plans are
developed by the relevant business and the Ma
rket Risk
function and implemented. For more detail on risk
appetite and
risk controls, refer to pages 19
2 and 193.
Monitoring and mitigation
Traded market risk is identified and asse
ssed by gathering,
analysing, monitoring and reporting market risk info
rmation at
desk, business, franchise and NatWest G
roup-wide levels.
Industry expertise, continued sy
stem developments and
techniques such as stress testing are also used to en
hance the
effectiveness of the identification and assessment of
all material
market risks.
Traded market risk exposures are monitored ag
ainst limits and
analysed daily. A daily report summarising the
position of
exposures against limits at desk, business, f
ranchise and
NatWest Group levels is provided to senior managemen
t and
market risk managers across the function. Limit
reporting is
supplemented with regulatory capital a
nd stress testing
information as well as ad-hoc re
porting.
A risk review of trading busines
ses is undertaken weekly with
senior risk and front office staff. This includes
a review of profit
and loss drivers, notable position concentrations
and other
positions of concern.
Business profit and loss performance is
monitored
automatically through loss trigge
rs which, if breached, require
a remedial action plan to be agreed between
the Market Risk
function and the business. The loss triggers are se
t using both a
fall-from-peak approach and an absolu
te loss level. In addition,
regular updates on traded market risk positions a
re provided to
the Executive Risk Committee
and Board Risk Committee.
Measurement
NatWest Group uses VaR, SVaR and the incremen
tal risk
charge to measure traded marke
t risk. Risks that are not
adequately captured by VaR or SVaR are captu
red by the Risks
Not In VaR (RNIV) framework to ensure that Nat
West Group is
adequately capitalised for market risk. In additio
n, stress testing
is used to identify any vulnerabilities and poten
tial losses.
The key inputs into these measurement met
hods are market
data and risk factor sensitivities. Sensitivities ref
er to the
changes in trade or portfolio value that result f
rom small
changes in market parameters that are subject t
o the market
risk limit framework. Revaluatio
n ladders are used in place of
sensitivities to capture the impact of la
rge moves in risk factors
or the joint impact of two risk factors.
These methods have been designed to c
apture correlation
effects and allow NatWest Group to form an
aggregated view
of its traded market risk across
risk types, markets and
business lines while also taking into account the ch
aracteristics
of each risk type.
Value-at-risk
For internal risk management purposes, VaR assu
mes a time
horizon of one trading day and
a confidence level of 99%.
The internal VaR model – which captures all tradin
g book
positions including those products approved by the
regulator –
is based on a historical simulation, utilising m
arket data from
the previous 500 days on an equ
ally-weighted basis.
Risk and capital m
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nt continued
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Traded market risk continued
The model also captures the potential imp
act of interest rate
risk; credit spread risk; foreign currency price risk; equi
ty price
risk; and commodity price risk.
When simulating potential move
ments in such risk factors, a
combination of absolute, relativ
e and rescaled returns is used.
The performance and adequacy of the VaR model
are tested
regularly through the following processes:
Back-testing: Internal and regul
atory back-testing is
conducted on a daily basis. (Information on inter
nal back-
testing is provided in this section. Information on
regulatory
back-testing appears in the Pillar 3 Report).
Ongoing model validation: VaR
model performance is
assessed both regularly, and on an ad-hoc basis, if
market
conditions or portfolio profile change sig
nificantly.
Model Risk Management revie
w: As part of the model
lifecycle, all risk models (including the VaR model)
are
independently reviewed to ensure the model is
still fit for
purpose given current market conditions and po
rtfolio
profile. For further detail on the
independent model
validation carried out by Model
Risk Management refer to
page 284. More information relating to pricing a
nd market
risk models is presented in the Pillar 3 Repor
t.
One-day 99% traded internal VaR
Traded VaR (1-day 99%)
(audited)
The table below shows one-day 9
9% internal VaR for NatWest Group’s trading portfolios, spli
t by exposure type.
2021
2020
Average
Maximum
Minimum
Period end
Average
Maximum
Minimum
Period end
£m
£m
£m
£m
£m
£m
£m
£m
Interest rate
10.4
25.3
4.5
8.9
8.7
20.2
4.8
6.3
Credit spread
11.3
13.4
9.4
10.7
15.3
27.2
8.7
10.3
Currency
3.4
9.4
1.7
2.2
4.2
8.4
2.1
3.0
Equity
0.4
0.8
0.2
0.6
2.0
0.2
0.7
Commodity
0.1
0.5
0.1
0.6
0.2
Diversification
(1)
(12.3)
(10.5)
(12.8)
(10.3)
Total
13.3
23.9
9.3
11.5
16.1
25.7
10.1
10.2
(1)
Nat
West Group benefits from diversification across various financial instrument types, currencies and market
s. The extent of the diversification benefit depends on the correlation
between the assets and risk factors in the portfolio at a part
icular time. The diversification factor is the sum of the VaR on individual risk types less the total portfolio VaR.
Traded VaR increased in the first half of 2021
reflecting a
rise in tenor basis risk in sterling flow trading. This
related
to the transition from LIBOR to alterna
tive risk-free rates.
A regulator-approved update to the VaR mo
del was applied
in the second half of the year, to address the i
mpact of this
transition.
On an average basis, traded VaR decreased in 202
1
compared to 2020. This was driven by de-risking ac
tivity in
line with the strategic focus on RWA reduc
tion.
0
5
10
15
20
25
30
Jan
Feb
M
ar
Apr
May
J
un
Jul
Aug
Sep
Oct
Nov
Dec
£m
Total Trading Va
R
I
nterest Ra
te VaR
Credit VaR
FX VaR
Equity VaR
Commodity VaR
Risk and capital m
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nt continued
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Traded market risk
VaR back-testing
The main approach employed to asses
s the VaR model’s
ongoing performance is back-testing, which coun
ts the number
of days when a loss exceeds the c
orresponding daily VaR
estimate, measured at a 99% c
onfidence level.
Two types of profit and loss (P&L) are used in back-testi
ng
comparisons: Actual P&L and Hy
pothetical P&L. For more
details on the back-testing approach, refer to the
Pillar 3
Report.
The table below shows internal back-tes
ting exceptions in the major NatWest Ma
rkets businesses for the 250-business-day p
eriod
to 31 December 2021. Internal back-tes
ting compares one-day 99% traded internal VaR wi
th Actual and Hypothetical (Hypo) P&L.
Back
-
testing exceptions
Actual
Hypo
Rates
1
2
Currencies
1
1
Credit
xVA
The exceptions in the Rates bu
siness were mainly driven by
market moves in sterling, euro and US doll
ar rates.
The exceptions in the Currenci
es business were mainly
driven by market moves related to the Turkish li
ra.
Stressed VaR (SVaR)
As with VaR, the SVaR methodology produces e
stimates of the potential change in the market value of a portfolio, o
ver a specified
time horizon, at a given confide
nce level. SVaR is a VaR-based measure using histo
rical data from a one-year period of stress
ed
market conditions.
A simulation of 99% VaR is run
on the current portfolio for each 250-day period from 20
05 to the current VaR date, moving
forward one day at a time. The SVaR is the wo
rst VaR outcome of the simulated results.
This is in contrast with VaR, which is based on
a rolling 500-day historical data se
t. A time horizon of ten trading days is assu
med
with a confidence level of 99%.
The internal traded SVaR mode
l captures all trading book positions.
2021
2020
Average
Maximum
Minimum
Period end
Average
Maximum
Minimum
Period end
£m
£m
£m
£m
£m
£m
£m
£m
Total internal traded SVaR
95
175
46
66
97
196
59
87
Traded SVaR increased in the first half of 2
021, reflecting a
rise in tenor basis risk in sterling flow trading. This
related
to the transition from LIBOR to alterna
tive risk-free rates.
Traded SVaR subsequently decreased in
the second half of
the year following changes to the treatment of tenor
basis
risk in the VaR model.
Risks Not In VaR (RNIVs)
The RNIV framework is used to identify and quantify m
arket
risks that are not fully captured by the intern
al VaR and SVaR
models.
RNIV calculations form an integral part of ongoin
g model and
data improvement efforts to capture all marke
t risks in scope
for model approval in VaR and
SVaR.
For further qualitative and quantitative disclos
ures on RNIVs,
refer to the Market risk section of the Pillar 3 Repo
rt.
Stress testing
For information on stress testing, refer to pa
ge 193.
Incremental risk charge (IRC)
The IRC model quantifies the impact of r
ating migration and
default events on the market value of instruments with
embedded credit risk (in particular, bonds and c
redit default
swaps) held in the trading book
. It further captures basis risk
between different instruments, ma
turities and reference
entities. For further qualitative and quan
titative disclosures on
the IRC, refer to the Market risk s
ection of the Pillar 3 Report.
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Additional
information
Financial review
Market risk – linkage to balance sheet
The table below analyses NatWest Group’s b
alance sheet by non-trading and trading busines
s.
2021
2020
Non-trading
Trading
Non-trading
T
rading
Total
business
business
Total
business
business
£bn
£bn
£bn
£b
n
£bn
£bn
Primary market risk factor
Assets
Cash and balances at central
banks
177.8
177.8
124.5
124.5
Interest rate
Trading assets
59.2
0.7
58.5
69.0
0.3
68.7
Reverse repos
20.7
20.7
19.4
19.4
Interest rate
Securities
25.0
25.0
29.2
29.2
interest rate, credit spreads, equity
Other
13.5
0.7
12.8
20.4
0.3
20.1
Interest rate
Derivatives
106.1
1.6
104.5
166.5
2.3
164.2
Interest rate, credit spreads, equity
Settlement balances
2.1
0.2
1.9
2.3
0.1
2.2
Settlement
Loans to banks
7.7
7.6
0.1
7.0
6.9
0.1
Interest rate
Loans to customers
359.0
358.9
0.1
360.5
360.4
0.1
Interest rate
Other financial assets
46.1
46.1
55.1
55.1
Interest rate,
credit spreads, equity
Intangible assets
6.7
6.7
6.7
6.7
Interest rate, credit spreads, equity
Other assets
8.3
8.3
7.9
7.9
Assets of disposal groups
9.0
9.0
Total assets
782.0
616.9
165.1
799.5
564.2
235.3
Liabilities
Bank deposits
26.3
26.3
20.6
20.6
Interest rate
Customer deposits
479.8
479.8
431.7
431.7
Interest rate
Settlement balances
2.1
2.1
5.5
3.3
2.2
Settlement
Trading liabilities
64.6
0.1
64.5
72.3
72.3
Repos
19.4
19.4
19.0
19.0
Interest rate
Short positions
25.0
25.0
26.8
26.8
Interest rate, credit spreads
Other
20.2
0.1
20.1
26.5
26.5
Interest rate
Derivatives
100.8
3.6
97.2
160.7
5.2
155.5
Interest rate, credit spreads
Other financial liabilities
49.3
48.9
0.4
45.8
45.1
0.7
Interest rate
Subordinated liabilities
8.4
8.4
10.0
10.0
Interest rate
Notes in circulation
3.0
3.0
2.7
2.7
Interest rate
Other liabilities
5.9
5.9
6.4
6.4
Total liabilities
740.2
576.0
164.2
755.7
525.0
230.7
(1)
Non-trading businesses a
re entities that primarily
have exp
osures that are not classified as trading book. For these exposures, with the exception of pension-related activities, the
main measurement methods are sensitivity analysis of net interest
income, internal non-traded VaR and fair value calculations. For more information refer to the non-traded market
risk section.
(2)
Trading businesses are entities that primarily have
exposures that are classified as trading book under regulatory rules. For these exposures, the main methods used by NatWest
Group to measure market risk are detailed in the traded market risk section.
(3)
Foreign exchange risk affects all non-sterling den
ominated exposures on the balance sheet across trading and non-trading businesses, and therefore has not been listed in the
above tables.
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Risk and capital management
Additional information
Financial review
Pension risk
Definition
Pension risk is the risk to NatWes
t Group caused by its
contractual or other liabilities to, or with respect to, a
pension
scheme (whether established for its e
mployees or those of a
related company or otherwise). It is also the
risk that NatWest
Group will make payments or other contributions to
, or with
respect to, a pension scheme because
of a moral obligation or
because NatWest Group conside
rs that it needs to do so for
some other reason.
Sources of risk
NatWest Group has exposure to pension
risk through its
defined benefit schemes worldwide. The Main sectio
n of The
NatWest Group Pension Fund (t
he Main section) is the largest
source of pension risk with £52.0
billion of assets and £42.0
billion of liabilities at 31 December 202
1 (2020 – £51.3 billion of
assets and £43.9 billion of liabilities). Refe
r to Note 5 to the
consolidated financial statements, for fur
ther details on
NatWest Group’s pension oblig
ations, including sensitivities to
the main risk factors.
Pension scheme liabilities vary with changes in l
ong-term
interest rates and inflation as we
ll as with pensionable salaries,
the longevity of scheme members and legisl
ation. Pension
scheme assets vary with changes
in interest rates, inflation
expectations, credit spreads, exchange rates, a
nd equity and
property prices. NatWest Group is exposed to the
risk that the
schemes’ assets, together with future returns and addi
tional
future contributions, are estimated to be insuff
icient to meet
liabilities as they fall due. In such circumstances, N
atWest
Group could be obliged (or might choose) to
make additional
contributions to the schemes or be
required to hold additional
capital to mitigate this risk.
Key developments in 2021
There were no material changes to NatWest Group’s
exposure to pension risk during the year, and the ove
rall
position of the main defined be
nefit schemes that NatWest
Group sponsors has improved.
The triennial actuarial valuation for the Main secti
on, with
an effective date of 31 Decembe
r 2020, was completed on
14 December 2021. As the Main sec
tion was in surplus at
this date, no deficit repair contributions we
re required,
although there was a small incre
ase in the level of
contributions in relation to ongoing accrual of be
nefits.
In line with the Memorandum of
Understanding signed with
the Trustee of the Main section
in April 2018, a £500 million
lump sum contribution was paid into the M
ain section,
following the share buyback in 2
021.
NatWest Group has exposure to a number of
defined
benefit pension schemes in the Republic of I
reland.
Following the announcement to commence a ph
ased
withdrawal from the Republic of
Ireland, an agreement was
reached with each of the schemes’ Trustees
, on a
timeframe for discussions on the
future support
arrangements for the schemes
on completion of the phased
withdrawal, with all parties sharing the objective of
having
new support arrangements in place by the end of 202
2.
Following the changes to Ulster B
ank Limited, it no longer
participates in any of NatWest Group’s defined benef
it
pension schemes. In particular, NatWest Bank Plc
assumed
responsibility as Principal Employer and the only
participating employer in The Uls
ter Bank Pension Scheme
in Northern Ireland. This will not affect Na
tWest Group’s
overall exposure to the Scheme.
As part of the transition of framework c
omponents to align
to the requirements of the NatWes
t Group enterprise-wide
risk management framework, an updated pension risk
policy and risk appetite statement were develo
ped in 2021.
Governance
Chaired by the Chief Financial O
fficer, the Group Asset &
Liability Management Committe
e is a key component of
NatWest Group’s approach to managing pension risk. I
t
considers the pension impact of the capital plan fo
r NatWest
Group and reviews performance
of NatWest Group’s material
pension funds and other issues
material to NatWest Group’s
pension strategy. It also consid
ers investment strategy
proposals from the Trustee of the Main sectio
n.
For further information on governance
, refer to page 190.
Risk appetite
NatWest Group maintains an in
dependent view of the risk
inherent in its pension funds. NatWest G
roup has an annually
reviewed pension risk appetite
statement incorporating defined
metrics against which risk is me
asured.
Policies and standards are in place to provide for
mal controls
for pension risk reporting, modelling, governance and s
tress
testing. A pension risk policy, which sits wi
thin the NatWest
Group enterprise-wide risk management framework, is
also in
place and is subject to associate
d framework controls.
Monitoring and measurement
Pension risk is monitored by the Executive Risk Co
mmittee and
the Board Risk Committee by way of the
monthly Risk
Management Report.
NatWest Group also undertakes stress tests on i
ts material
defined benefit pension schemes each year. These
tests are
also used to satisfy the requests
of regulatory bodies such as
the Bank of England.
The stress testing framework inclu
des pension risk capital
calculations for the purposes of
the Internal Capital Adequacy
Assessment Process as well as
additional stress tests for a
number of internal management pu
rposes. The results of the
stress tests and their consequential impact on Na
tWest Group’s
balance sheet, income statement and ca
pital position are
incorporated into the overall NatWest G
roup stress test results.
NatWest Bank Plc (a subsidiary of NatWest G
roup) is the
principal employer of the Main
section and could be required to
fund any deficit that arises.
Mitigation
Following risk mitigation measures taken
by the Trustee in
recent years, the Main section is now well protec
ted against
interest rate and inflation risks and is being run on
a low
investment risk basis with relatively s
mall equity risk
exposure.
The Main section also uses derivatives to
manage the
allocation of the portfolio to diffe
rent asset classes and to
manage risk within asset classes.
The potential impact of climate change is one of
the factors
considered in managing the asse
ts of the Main section. The
Trustee monitors the risk to its investments fro
m changes in the
global economy and invests, where return justifies t
he risk, in
sectors that reduce the world’s reliance on fossil f
uels, or that
may otherwise promote environmental benefits.
Further details
regarding the Main section Trustee
’s approach to managing
climate change risk can be fou
nd in its Responsible Ownership
Policy and its net zero commitment. The Trustee h
as reported
in line with the Task Force on Climate-related Financi
al
Disclosures in its Annual Report and Accoun
ts.
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Risk and capital management
Additional information
Financial review
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Compliance & conduct risk
Definition
Compliance risk is the risk that
the behaviour of NatWest Group
towards customers fails to comply with laws,
regulations, rules,
standards and codes of conduc
t. Such a failure may lead to
breaches of regulatory requirements, organisa
tional standards
or customer expectations and could result in legal o
r regulatory
sanctions, material financial loss or reputation
al damage.
Conduct risk is the risk that the c
onduct of NatWest Group and
its subsidiaries and its staff towards custome
rs – or in the
markets in which it operates – leads to unfair or in
appropriate
customer outcomes and results in reputational
damage,
financial loss or both.
Sources of risk
Compliance and conduct risks exist ac
ross all stages of
NatWest Group’s relationships with its custome
rs and arise
from a variety of activities inclu
ding product design, marketing
and sales, complaint handling,
staff training, and handling of
confidential inside information.
As set out in Note 27 to the
consolidated financial statements, mem
bers of NatWest Group
are party to legal proceedings and are subject to in
vestigation
and other regulatory action in the UK, the U
S and other
jurisdictions.
Key developments in 2021
A new Ring-Fencing Hub was se
t up to provide an
aggregated view of ring-fencing compliance a
nd risk
management. Oversight of the work to co
mplete NatWest
Group’s attestation of compliance was also a ke
y focus.
Risk appetite statements and measures were updated
with
an enhanced focus to provide better visibility of key
risks
across NatWest Group.
Delivered a digital platform to facilitate risk-based
rules
mapping to regulatory obligations. This will e
nable more
efficient management of regulatory compli
ance matters and
support intelligent risk taking.
Continued collaboration across NatWest Group
to deliver
good customer outcomes with a focus
on enhancing
forbearance strategies.
There was ongoing monitoring and mitigation of ele
vated
conduct risks resulting from the phased withdrawal f
rom
the Republic of Ireland including data-dri
ven risk profile
reporting.
Oversight and management of
major compliance
programmes including work to upgrade NatWest
Group’s
internal ratings based approach for credit
risk in order to
build better outcomes for customers.
Provided strategic oversight and advice to NatWest G
roup’s
LIBOR transition programme.
Governance
NatWest Group defines appropriate standards of co
mpliance
and conduct and ensures adherence to those stand
ards
through its risk management framework. Relevant co
mpliance
and conduct matters are escalated through Executive Ris
k
Committee and Board Risk Committee.
Risk appetite
Risk appetite for compliance an
d conduct risks is set at Board
level. Risk appetite statements articulate the levels of risk t
hat
legal entities, businesses and fu
nctions work within when
pursuing their strategic objectives and business plans. A
range
of controls is operated to ensur
e the business delivers good
customer outcomes and is conducted in
accordance with legal
and regulatory requirements. A suite of policies
addressing
compliance and conduct risks set appropri
ate standards across
NatWest Group. Examples of the
se include the Complaints
Management Policy, Client Assets &
Money Policy, and Product
Lifecycle Policy as well as policies relating to cus
tomers in
vulnerable situations, cross-border activities
and market abuse.
Continuous monitoring and targeted assur
ance is carried out as
appropriate.
Monitoring and measurement
Compliance and conduct risks are measured
and managed
through continuous assessment and repo
rting to NatWest
Group’s senior risk committees and at Board level. The
compliance and conduct risk framewo
rk facilitates the
consistent monitoring and measurement of co
mpliance with
laws and regulations and the de
livery of consistently good
customer outcomes. The first line of
defence is responsible for
effective risk identification, reporting and
monitoring, with
oversight, challenge and review by the second line
. Compliance
and conduct risk management is
also integrated into NatWest
Group’s strategic planning cycle.
Mitigation
Activity to mitigate the most-material compliance
and conduct
risks is carried out across NatWe
st Group with specific areas of
focus in the customer-facing business
es and legal entities.
Examples of mitigation include consideration of
customer needs
in business and product planni
ng, targeted training, complaints
management, as well as independent monitoring
activity.
Internal policies help support a strong custo
mer focus across
NatWest Group. Independent as
sessments of compliance with
applicable regulations are also carried out at a leg
al entity
level.
Financial crime risk
Definition
Financial crime risk is presented by cri
minal activity in the form
of money laundering, terrorist financing, b
ribery and
corruption, sanctions and tax evasion, as well as fr
aud risk
management.
Sources of risk
Financial crime risk may be prese
nted if NatWest Group’s
customers, employees or third parties under
take or facilitate
financial crime, or if NatWest Group’s pro
ducts or services are
used to facilitate such crime. Fi
nancial crime risk is an inherent
risk across all lines of business.
Key developments in 2021
While work continues to enhance
the control environment
relating to financial crime risk, operational weakne
sses
between 2012 and 2016 resulted in the inadequate
monitoring of a UK incorporated cus
tomer. NatWest Group
co-operated fully with the regulator’s investiga
tion into this
case and, in October 2021, NWB Plc pleaded guil
ty to three
breaches of the Money Laundering Regulations 200
7.
Significant investment continued to be made to suppor
t
delivery of the multi-year transformation plan across
financial crime risk management.
Enhancements were made to technology and dat
a analytics
to improve the effectiveness of sys
tems used to monitor
customers and transactions.
A new financial crime and fraud goal was introduced fo
r
NatWest Group’s most senior 1
50 employees to further
embed financial crime risk managemen
t culture,
behaviours, and accountabilities.
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nt continued
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Strategic report
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Risk and capital management
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Financial review
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Strategic report
Governance
Risk and capital management
Additional information
Financial review
Financial crime risk continued
Governance
The Financial Crime Executive Steering G
roup, which is jointly
chaired by the Chief Risk Officer and t
he Chief Administrative
Officer, is the core governance
committee for financial crime
(excluding fraud). It oversees f
inancial crime risk management,
operational performance, and transfo
rmation matters including
decision-making and escalations
to Executive Risk Committee,
Board Risk Committee and NatWest Group
Executive
Committee.
Risk appetite
There is no appetite to operate in an environmen
t where
systems and controls do not enable the identifica
tion,
assessment, monitoring, management
and mitigation of
financial crime risk. NatWest Group’s sys
tems and controls
must be comprehensive and proportion
ate to the nature, scale
and complexity of its businesse
s. There is no tolerance to
systematically or repeatedly breach relevant financial c
rime
regulations and laws.
NatWest Group operates a framework of preven
tative and
detective controls designed to mitigate
the risk that it could
facilitate financial crime. These cont
rols are supported by a
suite of policies, procedures and guidance to ensu
re they
operate effectively.
Monitoring and measurement
Financial crime risks are identifi
ed and reported through
continuous risk management and regular repo
rting to NatWest
Group’s senior risk committees and the NatWest
Group Board.
Quantitative and qualitative data is reviewed
and assessed to
measure whether financial crime risk is within
risk appetite.
Mitigation
Through the financial crime framework, releva
nt policies,
systems, processes and controls are used to miti
gate and
manage financial crime risk. This includes the use
of dedicated
screening and monitoring syste
ms and controls to identify
people, organisations, transactions and behaviours
that may
require further investigation or other actio
ns. Centralised
expertise is available to detect and disrupt threa
ts to NatWest
Group and its customers. Intelligence is s
hared with law
enforcement, regulators and government bodies to s
trengthen
national and international defences against those
who would
misuse the financial system for
criminal motives.
Climate risk
Definition
Climate risk is the threat of fina
ncial loss or adverse non-
financial impacts associated with clim
ate change and the
political, economic and environmental respo
nses to it.
Sources of risk
Physical risks may arise from cl
imate and weather-related
events such as heatwaves, droughts, floo
ds, storms and sea
level rises. They can potentially result in fin
ancial losses,
impairing asset values and the creditworthiness of bo
rrowers.
NatWest Group could be exposed to physical risks di
rectly by
the effects on its property portfolio and, indirectly, by t
he
impacts on the wider economy
as well as on the property and
business interests of its customers.
Transition risks may arise from the proce
ss of adjustment
towards a low-carbon economy. Changes in policy
, technology
and sentiment could prompt reasses
sment of customers’
financial risk and may lead to falls in the v
alue of a large range
of assets. NatWest Group could be e
xposed to transition risks
directly through the costs of adaptation wi
thin economic
sectors and markets as well as supply chain disrup
tion leading
to financial impacts on it and its customers. Poten
tial indirect
effects include the erosion of NatWest G
roup’s competitiveness,
profitability, or reputation damage.
Key developments in 2021
A principles-based climate risk policy
was approved by the
Board Risk Committee and intr
oduced in April 2021.
In December 2021, the Board a
pproved a number of first-
generation quantitative climate risk appetite measures.
These will enable reporting of clima
te risk appetite and link
business-as-usual risk management to NatWest
Group’s
strategic goals and priorities.
NatWest Group participated in the B
ank of England’s
Climate Biennial Exploratory Sc
enario (CBES) exercise. In
doing so, NatWest Group’s capabilities rega
rding climate
scenario analysis were strengthened in 20
21 with increased
coverage across the balance shee
t.
A new Climate Centre of Excellence
was established to
provide strategic horizon scanning, guidance and specialis
t
climate expertise across NatWest Group.
Wholesale credit risk: qualitative
assessment of climate risk
was made mandatory for the majority of the Wholes
ale
portfolio. This was supported by enhancements to
Transaction Acceptance Standards (TA
S) criteria, with the
inclusion of sector-specific climate conside
rations for the
heightened risk sectors and ge
neric climate considerations
for all other TAS documents.
Personal credit risk: operational measures we
re developed.
These will help to monitor the pe
rformance of the Personal
mortgage portfolio.
Governance
The Board is responsible for monitoring and oversee
ing
climate-related risk within NatWes
t Group’s overall business
strategy and risk appetite. The poten
tial impact, likelihood and
preparedness of climate-related risk is reported regul
arly to the
Board Risk Committee and the B
oard.
The Chief Risk Off
icer shar
es accountability with the
CEO
under the Senior Managers and Certification Regime for
identifying and managing the financial risks a
rising from
climate change. This includes ensuring th
at the financial risks
from climate change are adequately reflected in
risk
management frameworks, and that NatWest Group ca
n
identify, measure, monitor, manage, and
report on its exposure
to these risks.
The Climate Change Executive Steering Group is
responsible
for overseeing the direction of
and progress against NatWest
Group’s climate-related commitments. During 20
21, the
Executive Steering Group focused on overseeing
the Group
Climate Change Programme (G
CCP), which was tasked with
continuing to deliver both NatWe
st Group’s climate strategy
and the climate-related mandatory ch
ange agenda. The GCCP
will close and transition activity into business-
as-usual
operations across NatWest Group’s f
ranchises and functions.
The Executive Steering Group will continue
to supervise
strategic implementation and d
elivery, supported by the
Climate Centre of Excellence.
Risk appetite
NatWest Group’s ambition is to be a leading b
ank in the UK in
helping to address climate change. The
climate ambition is
underpinned by activity to reduce
the climate impact of
financing activity by at least 50% by 203
0 and to do what is
necessary to achieve alignment with
the 2015 Paris Agreement.
Risk and capital m
anageme
nt continued
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Strategic report
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Financial review
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Climate risk continued
Work continued in 2021 to integrate climate-
related risk into
the risk management framework, includin
g the development of
appropriate risk appetite metrics. In Decembe
r 2021, the
NatWest Group Board approved the adoption of th
ree first-
generation climate risk appetite measures into the e
nterprise-
wide risk management framework, for integration i
nto
business-as-usual risk management.
Combined with franchise specific operational limi
ts, this suite of
metrics will enable reporting of c
limate risk appetite to senior
risk management forums and li
nks risk management to
NatWest Group’s strategic goals and prio
rities.
Monitoring and measurement
NatWest Group has focused on developing the ca
pabilities to
use scenario analysis to identify
the most material climate risks
and opportunities for its customers, seeki
ng to harness insights
to inform risk management practices and
maximise the
opportunities arising from a transition to a low ca
rbon
economy.
Scenario analysis allows NatWest Group to test
a range of
possible future climate pathwa
ys and understand the nature
and magnitude of the risks they
present. The purpose of
scenario analysis is not to forec
ast the future but to understand
and prepare to manage risks that could a
rise.
In 2021, activity was dominated by the Bank of En
gland’s CBES
exercise. In accordance with B
ank of England guidance,
NatWest Group used three scenarios as the foundation fo
r its
analysis. These were broadly consistent with scen
arios
published by the Network of Ce
ntral Banks and Supervisors for
Greening the Financial System:
No Additional Action: no new policy action takes pl
ace to
reduce greenhouse gas emissions. T
his leads to more than 3°C
of warming and severe physical risks. The f
requency and
severity of extreme weather ev
ents such as flooding and
tropical cyclones increases, and there are chronic c
hanges in
labour and land productivity.
Early Action: global temperature
increases are limited to 1.5°C
by 2100 as a result of stringent c
limate policies and innovation
starting in 2021. Carbon prices increase steadily
between 2021-
2050, which drives significant d
ecarbonisation. Coal use falls by
98% between 2021 and 2050, and the sh
are of low-carbon
energy in the global energy mix increases fro
m 17% to 73%
over the same period. Global CO
2 emissions reach net zero
around
2050.
Late Action: strong climate policie
s successfully limit warming
to 1.8°C by 2100, but decisive policy action is delaye
d until
2031. Carbon prices increase rapidly betwe
en 2031-2050.
Global greenhouse gas emissions fall by 80
% between 2030 and
2050 leading to a higher level of
transition risk during the
period.
In 2021 for the CBES, NatWest Group applied t
hese three
climate scenarios to quantify climate risk ac
ross its balance
sheet, including the full portfolio of wholesale custo
mers and its
entire UK commercial real estate and residenti
al (retail)
mortgage portfolio.
To ensure that climate risk is fa
ctored into the capital planning
and budgeting process, NatWes
t Group is leveraging the CBES
scenarios and analytics to supp
ort the business-as-usual
scenario analysis processes, for
example the base case is
consistent with the Early Action CB
ES scenario. In addition,
climate risks consistent with th
e Late Action CBES scenario
have been integrated into one of
the Internal Capital Adequacy
Assessment Process scenarios.
NatWest Group regularly considers existin
g and emerging
regulatory requirements related to climate chan
ge. It continues
to participate in several industry-wide initiatives
to develop
consistent risk measurement methodologies. Nat
West Group is
a founding signatory of the Uni
ted Nations Environment
Programme Finance Initiative Principles for Res
ponsible
Banking, which aims to promote s
ustainable finance around the
globe. In addition, NatWest Group is also represented o
n the
Climate Financial Risk Forum es
tablished by the PRA and FCA
to shape the financial service indus
try’s response to the
challenges posed by climate risk.
Operational risk
Definition
Operational risk is the risk of los
s resulting from inadequate or
failed internal processes, people and systems, o
r external
events. It arises from day-to-da
y operations and is relevant to
every aspect of the business.
Sources of risk
Operational risk may arise from a failure to
manage operations,
systems, transactions and assets appropriately. T
his can take
the form of human error, an inability to deliver cha
nge
adequately or on time, the non-availability of
technology
services, or the loss of customer data. Systems failu
re, theft of
NatWest Group property, information loss and
the impact of
natural, or man-made, disasters – as well as the threa
t of cyber
attacks – are sources of operational
risk. Operational risk can
also arise from a failure to acc
ount for changes in law or
regulations or to take appropriate measures to
protect assets.
Key developments in 2021
Aligned to the implementation of the enterprise-wi
de risk
management framework, a new operational
risk policy was
approved in April 2021. T
he new policy sets out the
qualitative expectations, guidanc
e and standards that
stipulate the nature and extent of
permissible risk-taking for
operational risk.
Operational risk appetite was enhanced usin
g a quantitative
modelling approach to determine a meaningful quan
titative
expression of the maximum level of operation
al risk
NatWest Group is willing to accept.
Oversight of NatWest Group’s transformatio
n agenda –
particularly in relation to the se
cond-order impacts of
COVID-19 – remained a significant area of focus with
activity being closely monitored and managed to
protect
key regulatory deliveries.
There was also a continued focus on oper
ational resilience
to ensure planning, controls and operational activities
remained robust and appropriate, with conti
nuing attention
on the potential operational risks arising fro
m changes in
working practices.
The security threat and the pote
ntial for cyber-attacks on
NatWest Group and its supply chain continue t
o be closely
monitored. During 2021, there was further investmen
t in
NatWest Group’s defences in response to the e
volving
threat. There was also continui
ng focus on assuring the
security of the supply chain.
There was sustained focus on r
educing the risks associated
with data use, particularly in terms of
assuring data quality.
This was aligned to the NatWest Group
data strategy,
designed to identify and imple
ment enhancements to the
effective use of data across NatWest Group.
Risk and capital m
anageme
nt continued
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Operational risk continued
Governance
The risk governance arrangements in place fo
r operational risk
are aligned to the requirements set out in the Boa
rd approved
enterprise-wide risk management fr
amework and are
consistent with achieving safety
, soundness and sustainable
risk outcomes.
Aligned to this, a strong operational risk mana
gement oversight
function is vital to support Nat
West Group’s ambitions to serve
its customers better. Improved
management of operational risk
against defined appetite is vital for stability and
reputational
integrity.
Risk appetite
Operational risk appetite supports effec
tive management of all
operational risks. It expresses the
level and types of operational
risk NatWest Group is willing to accept
to achieve its strategic
objectives and business plans. N
atWest Group’s operational risk
appetite statement encompasses
the full range of operational
risks faced by its legal entities, businesse
s and functions.
Mitigation
The Control Environment Certification (CEC) pr
ocess is a half-
yearly self-assessment by the CEOs of NatWes
t Group’s
principal businesses, functions and legal entities. It
provides a
consistent and comparable view on the adequ
acy and
effectiveness of the internal control environ
ment.
CEC covers material risks and the underlying key con
trols,
including financial, operational and compliance con
trols, as well
as supporting risk management frameworks. The CEC
outcomes, including forward-looking assessments fo
r the next
two half-yearly cycles and progress on control en
vironment
improvements, are reported to Group Audit Com
mittee and
Board Risk Committee. They
are also shared with external
auditors.
The CEC process helps to ensure compliance with
the NatWest
Group Policy Framework, Sarbanes-O
xley 404 requirements
concerning internal control over financial reporting (as
referenced in the Compliance report on page 181
), and certain
requirements of the UK Corporate Govern
ance Code.
Risks are mitigated by applying ke
y preventative and detective
controls, an integral step in the
risk assessment methodology
which determines residual risk e
xposure. Control owners are
accountable for the design, exe
cution, performance and
maintenance of key controls. Ke
y controls are regularly
assessed for adequacy and tested for eff
ectiveness. The results
are monitored and, where a material change in
performance is
identified, the associated risk is re-evalu
ated.
Monitoring and measurement
Risk and control assessments are use
d across all business
areas and support functions to
identify and assess material
operational and conduct risks and key
controls. All risks and
controls are mapped to NatWest Group’s Risk
Directory. Risk
assessments are refreshed at least annually t
o ensure they
remain relevant and capture a
ny emerging risks and also
ensure risks are reassessed.
The process is designed to conf
irm that risks are effectively
managed in line with risk appet
ite. Controls are tested at the
appropriate frequency to verify
that they remain fit-for-purpose
and operate effectively to reduce identified risks.
NatWest Group uses the standardised app
roach to calculate its
Pillar 1 operational risk capital requirement. This is b
ased on
multiplying three years’ average historical g
ross income by
coefficients set by the regulator based on
business line. As part
of the wider Internal Capital Ade
quacy Assessment Process an
operational risk economic capital model is use
d to assess Pillar
2A, which is a risk-sensitive add-on
to Pillar 1. The model uses
historical loss data (internal and external) and forward-looki
ng
scenario analysis to provide a risk-se
nsitive view of NatWest
Group’s Pillar 2A capital require
ment.
Scenario analysis is used to asse
ss how severe but plausible
operational risks will affect Nat
West Group. It provides a
forward-looking basis for evaluating and man
aging operational
risk exposures.
Refer to the Capital, liquidity and fu
nding risk section for
operational risk capital requirement figures.
Operational resilience
NatWest Group manages and monitors oper
ational resilience
through its risk and control asse
ssment methodology. This is
underpinned by setting and monitoring risk indic
ators and
performance metrics for key busi
ness services. Progress
continues on the response to regulator expectations o
n
operational resilience, with invol
vement in a number of
industry-wide operational resilie
nce forums. This enables a
more holistic view of the operati
onal resilience risk profile and
the pace of ongoing innovation and change, bot
h internally and
externally.
Risk and capital m
anageme
nt continued
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Strategic report
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Risk and capital management
Additional information
Financial review
Operational risk continued
Event and loss data management
The operational risk event and l
oss data management process
ensures NatWest Group captures
and records operational risk
financial and non-financial events that meet defined c
riteria.
Loss data is used for regulatory and indust
ry reporting and is
included in capital modelling w
hen calculating economic capital
for operational risk. The most s
erious events are escalated in a
simple, standardised process to
all senior management, by way
of an Early Event Escalation Proce
ss.
All financial impacts and recove
ries associated with an
operational risk event are repo
rted against the date they were
recorded in NatWest Group’s fi
nancial accounts. A single event
can result in multiple losses (or recoveries) that may t
ake time
to crystallise. Losses and recove
ries with a financial accounting
date in 2021 may relate to events that occur
red, or were
identified in, prior years. NatWest Group purchase
s insurance
against specific losses and to comply wi
th statutory or
contractual requirements.
Percentage and value of events
At 31 December 2021, events aligned to the clients, pr
oducts
and business practices event category accoun
ted for 80% of
NatWest Group’s operational risk losse
s, which reflected a
significant increase on 2020. In 202
0, several large provision
releases were recorded (that is, previously reco
rded provisions
were released back to cashflow as they we
re no longer
required). The value of these outweighed the p
rovisions taken
for other conduct-related matte
rs, hence a negative movement
was recorded in the clients, pro
ducts and business practices
category.
Value of events
Volume of ev
ents (1)
£m
Proportion
Proportion
2021
2020
2021
2020
2021
2020
Fraud
74
85
17%
82%
87%
81%
Clients, products and business practices
341
(68)
80%
(66%)
3%
7%
Execution, delivery and process manage
ment
8
15
2%
15%
7%
8%
Employment practices and workplace safety
2
2
2%
2%
2%
Technology and infrastructure failures
3
70
1%
68%
1%
2%
Disasters and public safety
(1)
(1%)
428
103
100%
100%
100%
100%
(1)
Based on the volume and value of ev
ents (the proportion and cost of operational risk events to NatWest Group) where the associated loss
is more than or equal to £10,000.
Risk and capital m
anageme
nt continued
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Additional information
Financial review
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Strategic report
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Risk and capital management
Additional information
Financial review
Model risk
Definition
Model risk is the potential for adverse consequences a
rising
from inaccurate financial assessments o
r decisions made as a
result of incorrect or misused model ou
tputs and reports.
NatWest Group defines a model as a quantitative
method,
system, or approach that applie
s statistical, economic, financial,
accounting, mathematical or data science
theories, techniques
and assumptions to process input data into
quantitative
estimates.
Sources of risk
NatWest Group uses a variety of models in the course of its
business activities. Examples include the use of model ou
tputs
to support customer decisionin
g, measuring and assessing risk
exposures (including credit, market, and climate risk),
as well
as calculating regulatory capital and liquidity
requirements.
Model applications may give ris
e to different risks depending on
the franchise in which they are us
ed. Model risk is therefore
assessed separately for each fr
anchise in addition to the overall
assessment made for NatWest Group.
Key developments in 2021
Improvements to models were made in 2021 resultin
g in a
significant reduction of out-of-a
ppetite models across
NatWest Group. Enhancements
to models will continue in
2022 to bring NatWest Group back wit
hin model risk
appetite.
Embedding and enhancement
of the Model Risk
frameworks.
Governance
A governance framework is in place to ensure policies
and
processes relating to models ar
e appropriate and effective.
Two roles are key to this – Model Risk O
wners and Model Risk
Officers. Model Risk Owners ar
e responsible for model approval
and ongoing performance monitoring. Model Ris
k Officers, in
the second line, are responsible f
or oversight, including
ensuring that models are independently valida
ted prior to use
and on an ongoing basis aligned to the model’s risk rati
ng.
Model risk matters are escalated to senio
r management in
several ways. These include model risk oversight com
mittees,
as well as the relevant business and func
tion model
management committees. The Group Model Risk Ove
rsight
Committee provides a direct escalation route to the
Group
Executive Risk Committee and, where applicable
, onwards to
the Group Board Risk Committe
e.
Risk appetite
Model risk appetite is set in order to limit
the level of model risk
that NatWest Group is willing to accept in the cou
rse of its
business activities. It is approved by relevant
Executive Risk
Committees. Business areas are responsible for
monitoring
performance against appetite and remediating models ou
tside
appetite.
Risk controls
Policies and procedures related to the develop
ment, validation,
approval, implementation and use
and ongoing monitoring of
models are in place to ensure adequate co
ntrol across the
lifecycle of an individual model.
Validation of material models is conducted by an i
ndependent
risk function comprised of skilled, well-informed subjec
t matter
experts. This is completed for new models o
r amendments to
existing models and as part of an ongoing perio
dic programme
to assess model performance.
The frequency of periodic
validation is aligned to the risk rating of the model. T
he
independent validation focuses on a variety of mo
del features,
including modelling approach, the nature of the
assumptions
used, the model’s predictive ability and c
omplexity, the data
used in the model, its implementation and its compliance wi
th
regulation.
Risk monitoring and measuremen
t
The level of risk relating to an individual model is asse
ssed
through a model risk rating. A quantitative
approach is used to
determine the risk rating of each model,
based on the model’s
materiality and validation rating. This appro
ach provides the
basis for model risk appetite me
asures and enables model risk
to be robustly monitored and managed across Na
tWest Group.
Ongoing performance monitoring is conduc
ted by the first line
and overseen by the second line
to ensure parameter estimates
and model constructs remain fit for purpose
, model
assumptions remain valid and that models are bein
g used
consistently with their intended purpose. This allows ti
mely
action to be taken to remediate poor mo
del performance
and/or any control gaps or weaknesse
s.
Risk mitigation
By their nature – as approximations of reality –
model risk is
inherent in the use of models. It
is managed by refining or
redeveloping models where appropriate – eit
her due to
changes in market conditions, busine
ss assumptions or
processes – and by applying adjustments to
model outputs
(either quantitative or based on expert opinion).
Enhancements
may also be made to the proces
s within which the model
output is used in order to furthe
r limit risk levels.
Reputational risk
Definition
Reputational Risk is defined as the risk of dam
age to
stakeholder trust due to negative consequence
s arising from
internal actions or external events.
Sources of risk
Reputational risks originate fro
m internal actions and external
events. The three primary drivers of reputation
al risk have
been identified as: failure in inte
rnal execution; a conflict
between NatWest Group’s values and the public agend
a; and
contagion (when NatWest Group’s reputati
on is damaged by
failures in the wider financial sector).
Key developments in 2021
Reputation risk registers were introduced at NatWest
Group
level in order to enhance monit
oring of the most material
reputational risks.
An updated reputational risk appetite state
ment was
introduced with a specific focus on public
trust.
The correlation between reputational risk and cli
mate
change issues remained a significant area of f
ocus during
2021. Enhancements were made to the Environment
al,
Social & Ethical risk management framework
to mitigate
reputational risk arising from exposure
to carbon-intensive
sectors and to support the trans
ition to a lower carbon
economy.
Risk and capital m
anageme
nt continued
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Financial review
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Strategic report
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Risk and capital management
Additional information
Financial review
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Reputational risk continued
Governance
A reputational risk policy supports reputational
risk
management across NatWest Group. Reputational risk
committees review relevant issue
s at an individual business or
entity level, while the Reputational Risk Commi
ttee – which has
delegated authority from the Execu
tive Risk Committee –
opines on cases, issues, sectors and themes t
hat represent a
material reputational risk. The
Board Risk Committee oversees
the identification and reporting of reputational
risk. The
Sustainable Banking Committee
has a specific focus on
environmental, social and ethical issue
s.
Risk appetite
NatWest Group manages and articulates its appetite f
or
reputational risk through a qualitative repu
tational risk appetite
statement and quantitative measures. Na
tWest Group seeks to
identify, measure and manage
risk exposures arising from
internal actions and external events. This
is designed to ensure
that stakeholder trust is retained. Howeve
r, reputational risk is
inherent in NatWest Group’s operating environment
and public
trust is a specific factor in setting reputa
tional risk appetite.
Monitoring and measurement
Relevant internal and external facto
rs are monitored through
regular reporting to the reputational
risk committees at
business or entity level and escalated, whe
re appropriate, to
the Reputational Risk Committee, B
oard Risk Committee or the
Sustainable Banking Committee
.
Mitigation
Standards of conduct are in place across NatWest
Group
requiring strict adherence to p
olicies, procedures and ways of
working to ensure business is transacted in a way
that meets –
or exceeds – stakeholder expectations.
External events that could caus
e reputational damage are
identified and mitigated through NatWest Group’s
top and
emerging risks process as well as through the N
atWest Group
and franchise-level risk registers
.
NatWest Group has in recent y
ears been the subject of
investigations and reviews by a
number of regulators and
governmental authorities, some
of which have resulted in past
fines, settlements and public censure. Refer to the Litig
ation
and regulatory matters section of Note 27
to the consolidated
financial statements for details of
material matters currently
affecting NatWest Group.
NatWest Group
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286
286
Financial statements
287
Independent auditor’s report
300
Consolidated income statement
301
Consolidated statement of comprehensive income
302
Consolidated balance sheet
303
Consolidated statement of changes in equity
305
Consolidated cash flow statement
307
Accounting policies
313
Notes on the consolidated accounts
313
Net interest income
314
Non-interest income
315
Operating expenses
318
Segmental analysis
322
Pensions
327
Auditor’s remuneration
327
Tax
331
Discontinued operations and assets and liabilities
of disposal groups
332
Earnings per share
332
Financial instruments - classification
337
Financial instruments - valuation
346
Financial instruments - maturity analysis
348
Trading assets and liabilities
349
Derivatives
355
Loan impairment provisions
356
Other financial assets
357
Intangible assets
358
Other assets
358
Other financial liabilities
359
Subordinated liabilities
360
Other liabilities
361
Share capital and other equity
363
Leases
365
Structured entities
366
Asset transfers
367
Capital resources
368
Memorandum items
374
Analysis of the net investment in business
interests and intangible assets
375
Analysis of changes in financing during the year
375
Analysis of cash and cash equivalents
376
Directors’ and key management remuneration
376
Transactions with directors and key management
377
Related parties
377
Post balance sheet events
378
NatWest Group plc financial statements and notes
Financial
statements
Independent
auditors’
report to t
he members of
NatWest Gro
up plc
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Risk and capital management
Additional information
Financial review
Opinion
In our opinion:
the financial statements of NatWes
t Group plc (the ‘Parent Company’) and its subsidiaries (to
gether, the ‘Group’) give a true and
fair view of the state of the Grou
p’s and of the Parent Company’s aff
airs as at 31 December 2021 and of the Group’s prof
it for
the year then ended;
the Group financial statements have been properly p
repared in accordance with UK adopted
international accounting
standards, International Financial Repo
rting Standards (‘IFRS’) as adopted by the
European Union and IFRS as issued by the
International Accounting Standards Board (‘IA
SB’);
the Parent Company financial statements have been p
roperly prepared in accordance wit
h UK adopted international
accounting standards as applied in accord
ance with section 408 of the Companies Act 200
6, IFRS as adopted by the EU and as
issued by the IASB; and
the financial statements have be
en prepared in accordance with the requirements of
the Companies Act 2006.
We have audited the financial statements (see t
able below) of the Parent Company and the Group for
the year ended 31 December
2021 which comprise:
Group
Parent Company
Consolidated balance sheet as
at 31 December 2021;
Consolidated income statement f
or the year then ended;
Consolidated statement of comprehensive inco
me for
the year then ended;
Consolidated statement of changes i
n equity for the year
then ended;
Consolidated cash flow statement for the year then
ended;
Accounting policies;
Related Notes 1 to 34 to the fin
ancial statements;
Annual Remuneration Report identified as ‘audited’;
Risk and capital management se
ction identified as
‘audited’
The Capital Requirements (Country-by-Country
Reporting) Regulations report identified as ‘
audited’.
Balance sheet as at 31 Decembe
r 2021;
Statement of changes in equity for the yea
r then ended;
Cash flow statement for the year
then ended; and
Related notes 1 to 12 to the financial s
tatements including a
summary of critical accounting policies.
The financial reporting fr
amew
ork that has been applied in their pr
epa
ration is applic
able law and UK a
dopted interna
tional
accounting st
an
dar
ds, I
FRS as adopted by
the European Union and as issue
d by the IA
SB, and as r
egards the P
a
re
nt Compan
y
financial stat
ements, as
applied in accor
dance with s
ection 408 o
f the Companies
Act 2006.
Basis for opinion
W
e conducted our audi
t in accor
da
nce with Int
ernational Stand
ards on
Auditing (UK) (IS
As (UK
)) and applicable law
. Our
responsibilities under those
standar
ds are f
urther described in the
Auditor’
s re
sponsibilities for the audit of the fin
ancial st
atements
section of our r
epo
rt. W
e believ
e that the audit evidenc
e w
e ha
ve obt
ained is sufficient and appr
opriate to
pro
vide a basis for our
opinion.
Independence
W
e are independent of the
Group and P
arent Compan
y in acc
ordance wi
th the ethical re
quire
ments that are r
elev
ant to our audit
of the financial st
atements in th
e UK, including the FRC’
s Ethic
al Standar
d as applied to lis
ted public inter
est entities, and w
e hav
e
fulfilled our other ethic
al responsibilities in acc
ordanc
e with the
se requir
ement
s.
The non-audit servic
es prohibit
ed by the FRC’
s Ethical St
andard w
ere not pro
vided to the Gr
oup or the Parent
Compan
y and we
remain independent of the
Gro
up and the Pare
nt Co
mpany in c
onducting the audit.
Independent a
uditors’ report to the
member
s of NatWest Gr
oup plc continued
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Additional information
Financial review
Conclusions r
elating to going co
ncern
In auditing the financial st
atements, w
e hav
e concluded that the dir
ectors
use of the going conc
ern basis of ac
counting in the
prepar
ation of the financial st
at
ements is appropriat
e. Our e
valuation of
the director
s
assessment of the Gr
oup and P
arent
Company
s ability to con
tinue to adopt the going c
oncern basis o
f accounting included:
In conjunction with our w
alkthr
ough of the Gr
oup
s financial close proce
ss, w
e confir
med our underst
anding of management
s
Going Conce
rn assessment pr
ocess and also engaged with management early t
o ensure all
ke
y factors w
ere c
on
sidere
d in their
assessment;
W
e ev
a
luated management
s going concer
n assessment which inclu
ded re
viewing
their ev
aluation of l
ong-term business and
str
ategic plans, c
ap
ital adequac
y, liquidity and funding positions. It also
assessed the
se positions consider
ing internal stre
ss te
sts
which included consider
ation of
principal and emerging ris
ks. T
he Group
s risk pro
file and risk management pr
actices w
ere
consider
ed including cre
dit risk, mark
et risk, com
pliance and c
onduct risk, climate risk and oper
at
ional risk;
W
e ev
a
luated management
s assessment b
y considering the Gr
oup
s ability to continue in oper
a
tion and meets its liabilities un
der
differ
ent scenarios including
the impact of the Group
s strategi
c plans and the continued ec
onomic imp
act of C
OVID-19. W
e used
economic specialists in asses
sing the macroecon
omic assumptions in the f
orec
ast thr
ough benchmarking to insti
tutional
forec
a
sts
, HM
T consensus
and peer c
omparative ec
onomic fore
casts. W
e also consider
ed other commitments of the Gr
oup
including those in r
espect of its subsidiaries
;
Consider
ed the r
esults of the Bank’
s str
ess tes
ting and Bank of England 2021 solv
ency stress t
est, as well as the Gr
oup
s results
in the Bank of England Climate
Biennial E
xplora
tory Sce
nario (CBES); and
W
e re
view
ed t
he Gr
oup
s going concer
n disclosures include
d in the annual report in or
der to assess that the disclosur
es were
appropriate an
d in conformi
ty with the r
eporting standar
d
s.
Based on the w
ork w
e hav
e pe
rformed, w
e hav
e not
identified
any material unc
ertainties r
elating to ev
ents or conditions
that,
individually or collectiv
ely, may c
ast significant doubt on
the Gr
oup and Par
ent Co
mpany
s ability to continue as a
going conce
rn
ov
er the twelv
e months from the date
when the financial stat
ements are
authorised f
or issue.
In relation to
the group a
nd parent compan
y’
s r
eporting on how the
y hav
e applied the UK Co
rporate Go
vernance C
ode, we ha
ve
nothing material to
add or dra
w attention to in rela
tion to the dir
ectors
statement in the financial st
atements about whether the
direct
ors consider
ed it appro
priate to adopt the
going concer
n basis of acc
ounting.
Our r
esponsibilities and the responsibilities o
f the director
s with r
espect to going conc
ern are
described in the rele
vant sections o
f
this report. H
ow
eve
r
, because not all future ev
ents or conditions c
a
n be predicte
d, this state
ment is not a guaran
tee as to the
Group
s ability to con
tinue as a going conce
rn.
An ov
erview of the s
cope of
the Par
ent Company and Group audits
T
ailoring the sco
pe
Our assessment of audi
t risk, our ev
aluat
ion of mater
iality and our alloca
tion of performance
materiality deter
mine our audit sc
ope
for each company
within the Gr
oup. T
aken
together
, this enables us t
o form an opinion on the c
on
solidated fin
ancial state
m
ents.
W
e tak
e into ac
count the size a
nd risk pro
file of the c
omponent and its activities, the or
ganisation of the Gr
oup and effectiv
eness of
group-wide c
ontrols
, changes in the business envir
o
nment and other f
actors such as r
ecent i
nternal audit res
ults when assessing
the lev
el of w
ork to be performed at each component.
In assessing the risk o
f material misst
atement to
the Group fin
ancial statement
s, and to ensur
e we had adequate qu
antitativ
e
co
verage of
significant account
s in the financial state
ments, o
f the fiv
e reporting components o
f the Group
, w
e selected four
components based on size and
risk, which repr
esent the principal reporting legal entities within the Gr
oup.
The scoping f
or the curre
nt yea
r is as follo
ws
:
Component
S
cope
Ke
y locations
Nat
W
est Holdings (NWH)
Full
United Kingdom
Nat
W
est Mark
ets (NWM)
Full
United
Kingdom,
United
S
tates
,
and
Netherlands
RBS International
Specific
Channel Islands
RBS
AA H
oldings
Specific
United Kingdom
The
t
able
below
illustrates
the
coverage
o
btained
from
the
work
performed
by
our
audit
teams.
W
e
con
sidered
total
a
sse
ts,
total
equity and total income to verify we
had appropriate overall coverage.
Full scope
(1)
Specific scope
(2)
Other procedur
es
(3)
T
o
tal
T
otal assets
95
%
5%
-
10
0%
T
otal equity
89%
8%
3%
100%
T
otal income
92%
7%
1%
100%
(1)
Full scop
e: audit procedures on all significant accounts.
(2)
Spe
cific scope: audit procedures on selected accounts.
(3)
Ot
her procedures: considered in analytical procedures.
The audit scope o
f the specific scope c
omponents may not ha
ve
included testing of all signific
ant
acc
o
unts within the co
mponents.
Ho
wev
er, the testing will ha
ve c
ontributed to the tot
al co
ver
a
ge o
f significant acc
ounts tes
ted for the o
verall Gr
oup.
As a r
esult of the c
ontinued impact of the C
O
VID-19 outbre
ak and resulting lock
down res
t
rictions for part of
the year in all o
f the
countries wher
e full or specifi
c scope audit procedur
es ha
ve been per
formed, we ha
ve modified our audit strate
gy to allo
w for the
audit to be performed r
emotely at both the Group
and component locations
. This appr
oach was su
pported through r
emote us
er
acce
ss to the Group
s financial s
yste
ms and the use o
f EY softw
a
re c
olla
boration platf
orms for the secur
e and
timely deliv
ery o
f
reques
ted audit evi
dence.
Independent a
uditors’ report to the
member
s of NatWest Gr
oup plc continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
289
Financial statements
Strate
gic report
Governance
Risk and capital management
Additional information
Financial review
Inv
olvement with co
mponen
t teams
In establishing our o
ver
all approach to the Gr
oup audit, w
e determined the type o
f wor
k that needed to be undertak
en at each o
f
the components b
y us, as the p
rimary audit engagement team, or
by c
o
mponent auditors fr
om other EY global network f
irms
operating under our instruc
tion.
The primary audit engagement te
am interact
ed regul
arly with the component audit tea
ms wher
e appropriat
e throughout the
course o
f t
he audit, which included holdi
ng planning meetings,
maintaining regular c
omm
unic
ations on the status o
f the audits,
re
viewing k
ey w
orking papers and taking responsibili
ty for the sc
ope and direction of t
he audit process
. The primary audit t
eam
continued to follo
w a program
me of o
versight visits that has been designed to ensur
e th
at the Senior Sta
tutory
Auditor
, or another
Group audit partner
, visits all full scope and specific scope loca
tions outside the United Kingdo
m. During the current y
ear’
s audit
cy
cle, due to continued C
OVID-19
restrictions
, the visits undert
aken b
y th
e primary audi
t team w
ere necess
arily virtual visits. Thes
e
visits inv
olved video call meetin
gs with local management, and discussions on
the audit approach wi
th the component team
and
any iss
ues arising from
their work
. The primary team inter
acted regularly with the c
omponent teams and maint
ained a continuous
and open dialogue with component teams
, as w
ell as holding formal closing meetings quart
erly, to ensur
e that the primary team
we
re fully
awar
e of their progress and r
esults of their pr
ocedur
es. T
he primary team also r
eview
ed key w
orking pap
ers and w
ere
responsible for
the scope and dir
ection
of the audit
process
. This
, together with the additional
procedur
es at Group l
ev
el, gave us
appropriate e
vidence for our opinion on the Gr
o
up financial st
a
tements
Climate change
There
has been increasing inter
est from s
tak
ehold
ers as t
o ho
w climate change will impact c
o
mpanies. The Gr
oup
has deter
mined
that the most signific
ant future impacts fr
om
climate c
hange on its operatio
ns will be fro
m credit risk, oper
ational risk, reput
ational
risk, conduct risk and r
egulator
y compliance ris
k. These are
ex
plained in the requir
ed T
ask For
ce for Climate re
lated Financial
Disclosur
es in the Strate
gic Rep
ort, and in the Climate Risk s
ection within the Risk and c
apital management
section, which form
part of the
“Other information
. Our proce
dures on these di
sclosur
es consist
ed solely of c
on
sidering whether t
hey ar
e materially
inconsisten
t with the financial s
tatements or our kno
wledge obtained in the course o
f the audit or otherwi
se appear to be mater
ially
misstated.
As e
xpla
ined in the
Acc
o
unting P
olicy note, the Group mak
es use of r
easonable and supportable information
to mak
e acc
ounting
judgments and estimate
s, including the ob
serv
able effect of t
he ph
ysic
al and transition risk
s o
f climate change on the curr
ent
creditw
o
rthiness of borr
owe
rs, asset v
alues and mark
et indica
tors
,
as we
ll as their effec
t on the Group
s competitivenes
s and
prof
itability. Man
y of the impacts arising will be longer term in nature
, with an inher
ent lev
el of uncertainty,
and hav
e limited e
ffect
on accoun
ting judgments and esti
mates for the curr
ent
period under the re
quirements of UK
adopted int
ernational acc
ounting
standar
d
s, IFRS
as adopted by
the European Union
and as issued by
the IA
SB. In the
Ac
counting P
olicy note, e
xplanation of the
impact of cert
ain transition and
phy
sical risk
s w
ere pr
ovided for the k
ey assu
mptions and signific
ant judgements and estimate
s.
Our audit effor
t in considering climate ch
ange was focus
ed on ensuring that the effe
cts of mat
erial climate risk
s as disclos
ed in the
A
ccounting P
olicy note ha
ve been appropr
iately re
flected in th
e asset and liability v
aluations and the nature
and timing of fut
ure
cash flo
w
s. Det
ails of our pr
ocedures and r
esults on e
xp
ected cr
edit
loss pro
visions and impairment of goodwill are included in our
k
ey audit matter
s below
. W
e also challenged the Dir
ectors
considerations of climate ch
ange in their assessmen
t of going co
ncern
and viability and associated di
sclosur
es.
Whilst the Group
has state
d its c
ommitment to the aspir
ations of
the Paris
Agr
eement to achie
ve net zero emissions b
y 2050, as
state
d abov
e the impacts arising will be longer term in nature
, and there
is an inherent le
ve
l of unce
rtainty in determining
the full
future e
conomic impact on their business model, operational
plans and cust
omers.
K
ey audit matters
Key audit matters are those matters that, in
our professional judgment, were of most significa
nce in our audit of the financial
statements of the current period and include t
he most significant assessed risks of mate
rial misstatement (whether or not due
to
fraud) that we identified. These matters included those
which had the greatest effect on: the overall audi
t strategy, the allocation of
resources in the audit; and dire
cting the efforts of the engagement team. These matters we
re addressed in the context of o
ur audit
of the financial statements as a
whole, and in our opinion thereon, and we do not provide a s
eparate opinion on these matte
rs.
Independent a
uditors’ report to the
member
s of NatWest Gr
oup plc continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
290
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Risk
Our response to the risk
Expected Credit L
oss Provision
s
A
t 31 December 2
021 the Group
report
ed total gross loans o
f £369.8
billion (2020: £372.4
billion) and £3.8
billion of e
x
pected cr
edit losses (ECL)
(2020: £6.2 billion).
Management
s judgments and
estimates ar
e especially subjectiv
e
due to significan
t uncertainty
associated with the assumption
s used.
Uncert
ainty related with
the path to
rec
o
very fr
om
C
OVID-19 a
nd the
impact of climate change w
a
s
consider
ed in our risk assessment.
Aspects with incre
ased comple
xity in
respec
t of the timing and
measurement o
f ECL include:
Staging -
Allocation of assets to
stage 1, 2, or 3 on a timely basi
s
using criteria in accordance with
IFRS 9;
Model estimations -
Accounting
interpretations, modelling
assumptions and data used to build
and run the Probability of Defau
lt
(‘PD’), Loss Given Default (‘LGD’)
and Exposure at Default (‘EAD’)
models that calculate the ECL;
Economic scenarios -
Inputs,
assumptions and weightings used
to estimate the impact of multi
ple
economic scenarios particularly
those influenced by COVID-19
including any changes to scena
rios
required through 31 December
2021;
Adjustments -
Appropriateness,
completeness and valuation of
model adjustments which repres
ent
approximately 26% of total ECL
including any COVID-19 specific
adjustments due to the ongoing
uncertainty which increases the
risk of management override; and
Individual provisions -
Measurement of individual
provisions including the assessment
of multiple scenarios considering
the impact of COVID-19 on exit
strategies, collateral valuations and
time to collect.
Controls testing
- We evaluated the design
and operating effectiveness of cont
rols
across the processes relevant to ECL, includi
ng the judgments and estimates noted.
These controls, among others, included those
over:
the allocation of assets into stage
s including management’s monitoring of s
tage
effectiveness;
model governance including m
onitoring and model validation;
data accuracy and completeness;
credit monitoring;
multiple economic scenarios;
the governance and review of post-model adjust
ments;
individual provisions; and
production of journal entries and disclosures.
In evaluating the governance process
, we observed the executive finance and risk
committee meetings where the inputs, assu
mptions and adjustments to the ECL were
discussed and approved, among other p
rocedures.
Overall assessment
- We performed an overall assess
ment of the ECL provision levels
by stage to determine if they we
re reasonable by considering the overall credit quali
ty
of the Group’s portfolios, risk p
rofile, impact of COVID-19, government support
measures and climate change on the Group’s custo
mers. We also considered the
appropriateness of provisions applied to govern
ment supported lending such as bounce
back loans and CBILs which inc
luded assessing the compliance with the eligibility
criteria with the involvement of our EY legal specialists.
We performed peer
benchmarking where available to assess overall staging
and provision coverage levels.
For a higher risk industry, we also assess
ed the ECL against an independently
developed methodology estimating unsus
tainable debt levels.
Based on our assessment of the
key judgments we used EY specialists to support the
audit team in the areas of economics, model
ling and collateral and business valuations.
Staging
- We evaluated the crite
ria used to allocate a financial asset to stage 1, 2 o
r 3
in accordance with IFRS 9; this included peer benc
hmarking to assess staging levels
.
We recalculated the assets in stage 1, 2 and 3 to assess
if they were allocated to the
appropriate stage and performed sensitivity analysis to
assess the impact of different
criteria on the ECL and also considered the imp
act of performing collective staging
downgrades to industries and ge
ographic regions particularly impacted by cli
mate
change.
To test credit monitoring which drives the probability of def
ault estimates used in the
staging calculation, we recalculated the risk ratings fo
r a sample of performing loans
and focused our testing on high risk indus
tries. We also assessed the timing of the
annual review performed by management on each
wholesale loan exposure to evalu
ate
whether it appropriately conside
red risk factors by considering independent publicly
available information.
Model estimations
- We perfor
med a risk assessment on all models involved i
n the ECL
calculation to select a sample of models to
test. We involved EY modelling specialists to
assist us to test this sample of ECL models by testing
the assumptions, inputs and
formulae used. This included a combination of assess
ing model design and formulae,
alternative modelling techniques, recalcula
ting the PD, LGD and EAD, and model
implementation. We also considered the results of the
Group’s internal model validation
results.
To evaluate data quality, we agreed a sample of
ECL calculation data points to sou
rce
systems, including balance she
et date data used to run the models and histo
ric loss data
to monitor models. We also tested the ECL dat
a points from the calculation engine
through to the general ledger and disclosures.
Independent a
uditors’ report to the
member
s of NatWest Gr
oup plc continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
291
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Risk
Our response to the risk
Expected Credit L
oss Provision
s continued
Economic scenarios
- We i
nvolved EY economic specialists to a
ssist us in evaluating the
base case and alternative economic scenarios, includi
ng evaluating probability weights
and considering contrary evidence by compari
ng these to other scenarios from a
variety of external sources. This asses
sment included the latest developments related to
COVID-19 at 31 December 2021
. We assessed whether forecasted macroeconomic
variables were complete and appropriate, such
as GDP, unemployment rate, interest
rates and the House Price Inde
x. With the support of our modelling specialists we
evaluated the correlation and translation of the
macroeconomic factors to the ECL.
Adjustments
- We tested materi
al post-model adjustments including those which
continued to be applied as a re
sult of COVID-19 uncertainty. With our modelling
specialists, we assessed the risk of bias and the comple
teness of these adjustments by
considering the data, judgments
, methodology, sensitivities, and governance
of these
adjustments as well as considering model s
hortcomings.
Individual provisions
- We recalculated and ch
allenged the scenarios, assumptions and
cash flows for a sample of individual p
rovisions including the alternative scenarios
and
evaluating probability weights assigned, in
volving EY valuation specialists whe
re
appropriate. The sample was based on a nu
mber of factors, including higher risk
sectors such as commercial re
al estate, agriculture, oil and gas, mining, retail, leisu
re
and aviation, and materiality. We considered the im
pact COVID-19 and climate change
had on collateral valuations and time to collect as well as w
hether planned exit
strategies remained viable.
Disclosure
- We tested the data flows use
d to populate the disclosures and assessed the
adequacy of disclosures for compliance with the
accounting standards and regulatory
considerations.
Key observations communicated to the
Group Audit Committee
We are satisfied that provisions f
or the impairment of loans were reasonable and recognised i
n accordance with IFRS 9. We
highlighted the following matters to the Group Audit Co
mmittee:
Overall provision levels were reasonable which
also considered available peer information and our understan
ding of the credit
environment;
Our testing of models and mod
el assumptions identified some instances of ove
r and under estimation. We aggregated
these
differences and were satisfied that the overall esti
mate recorded was reasonable;
The post-model adjustments recorded were within
a reasonable range to refle
ct risk in the portfolios;
We recalculated the staging of retail and wholesale ex
posures in material portfolios and noted
no material differences. We also
performed sensitivity analysis o
n the staging criteria and noted that substan
tial changes would be needed to the criteria to
result in a material difference;
For individually assessed impairments, in a few instances we
reported judgmental differences in respect of the exten
t of the
impairment identified, however, none of these diffe
rences were considered material; and
There is inherent uncertainty in
predicting the longer-term impact of COVID-19, govern
ment support schemes and climate
change on the Group’s borrowers, their abili
ty to make payments as they fall due and t
he recoverability of loans. The G
roup
should continue to make use of
reasonable and supportable information to co
nsider the long and short term i
mpacts of these
matters on accounting judgments and es
timates.
Relevant references in the A
nnual Report and Accounts
Report of the Group Audit Committee
Credit Risk section of the Risk a
nd capital management section
Accounting policies
Note 15 to the financial statements
Independent a
uditors’ report to the
member
s of NatWest Gr
oup plc continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
292
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Risk
Our response to the
risk
Impairment of goodwill and, in the Parent Company’s acc
ounts, investments in group undertakings.
A
t 31 December 2
021, the Group had
report
ed goo
dwill of £5.5 billion
(2020: £5.6
billion) and parent comp
any has r
eported
inv
estment
s in gr
oup undertaki
ngs of £48.8
billion (2020: £46.2 billion).
The re
cognition and carrying v
a
lue of
goodwill and, in the Paren
t Compan
y’
s
accounts
, inv
estments in group
undertakings ar
e based on estimates o
f
future pr
ofitability, which re
quire
significant
management judgment and include the ris
k
of management bias
.
Judgments and especially challenging,
comple
x and subjectiv
e assumptions that
are difficult to au
dit due to the f
o
rw
ard-
looking nature and inher
ent unce
rtainties
associated with such assumptio
ns include:
Revenue forecasts including the
impacts
of climate change
which are impacted
by delivery of the Group’s Strategy;
Cost forecasts
given the intention to
significantly reduce costs over time;
Macroeconomic and model ass
umptions
used in the recoverability and valuation
assessments (discount rates, growth
rates, macroeconomic assumpt
ions)
including assumptions regarding the
economic consequences of COVID -19
and other political development
s over an
extended period; and
Disclosure
adequacy including key
assumptions, the sensitivity of changes
to these assumptions as well as
an
explanation of the impairment te
sting
performed.
Controls
testing
: W
e ev
aluated the design and oper
ating effe
ctiv
eness of c
ontrols
ov
er the preparation and re
view of
the forec
asts
, and the signific
ant assumptions
(such as discount r
ate and long-term gr
owth r
ate) inputs, c
alculations,
methodologies and judgments used in the v
alue-in-use model. T
his included
testing c
ontrols o
ver the selection of
macroeconomic assum
ptions in addition to
controls o
ver the pr
eparation and r
evie
w
of the r
ev
enue and cost pr
ojections
. In
evaluating the governance proc
esses we reviewed the Board meeting materi
als
and minutes where forecasts were discus
sed and approved, and we observed the
committee meetings where the value-in-use model an
d outcomes were discussed
and approved.
Macroec
onomic and model assumptions
:
With the support of our internal
economic specialists
, we
tested
whether macroecono
mic assumptions, i
ncluding
the continued impact of C
OVID-19 as at 31 Dec
em
ber 2021
, used in the Group
s
forec
a
sts w
er
e reason
able by c
omparing these to other scenarios from a variety
of external sources. We evaluated how the discou
nt rates and long-term growth
rates used by management compared to our ranges w
hich were developed using
peer practice, external market data and calcul
ations performed by our valuation
specialists. We also assessed changes to valu
ation methodology and benchmarked
this against industry practice with the assi
stance of our valuation specialists.
Re
venue for
ecasts
: W
e ev
a
luate
d
the underlying business str
ategies, c
omparing to
e
xpected marke
t trends and c
onsidering anticipated balance
sheet gro
w
th. W
e
obtained an underst
a
nding of t
he Group
s strategy
including their
consider
ation of
the impact of climate change, a
nd considere
d its e
xpected impact on the
forec
a
sts
and
the e
xtent to which decisions had been fact
ored
into
the
forec
a
sts
,
where
appropriate,
in
accor
da
nce wi
th the rele
van
t acc
ounting
standar
d
s.
W
e
also
inspected the findings fr
om the r
evie
w
perfor
med by
management including their o
w
n sensitivity analy
sis of the
forec
asts.
Cos
t forec
asts
: W
e tested ho
w previous m
anagement for
ecas
ts, including the
impact of cost r
eduction pr
o
gra
mmes, co
mpared to actual r
esults to ev
aluate the
accur
acy of the for
ecasting pr
ocess
. W
e also teste
d the rea
sonableness of
ke
y
performance indic
ators agains
t peers with the help of our v
aluation specialists to
assess the re
asonableness o
f the Group
s cost forec
ast.
Sensitivity analysis
: W
e evaluat
ed how management co
n
sidere
d alternativ
e
assumptions and performed our o
wn sensitivity and scenario analy
ses on c
ertain
assumptions such as cost
and r
ev
enue forecast
s, disc
o
unt r
ate, long-term
gro
wth
rate an
d other k
ey per
formance indic
ators on both the detaile
d forec
asts and on
an ov
erall basis.
Disclosur
e
: W
e ev
alua
ted the a
dequacy of disclosur
es in the financial statemen
ts
including the appropria
teness of
assumptions and sensitivities disclo
sed. W
e tested
the data and calcul
ations included in the disclosur
es.
Key observations communicated to the
Group Audit Committee
W
e are sa
tisfied that management methodologies, ju
dgments and assumptions supporting the c
arrying value o
f go
odw
ill and, in
the Par
ent Compan
y’
s accounts
, in
vestments in gr
o
up undertak
ings, w
ere
reaso
nable and in acc
o
rdance
with IFRS. W
e
highlighted the follo
wing matters to the Gr
oup
Audit Co
mmittee:
There
is inherent unc
ertainty in pr
edicting re
v
enue and costs o
ver the fiv
e-year fore
cast period, particularly with respect to the
impact of CO
VID-19, the achiev
ement of new str
ategic objectiv
es, e
xecution risk in the planne
d cost r
eductions
, the impact of
regulator
y and climate change
dev
elopments, a
nd the impact of c
ompetition and disruption in banking business models ov
er
an exte
nded period.
W
e are sa
tisfied with management
s conclusion that the goodwill re
lated to a legacy mort
gage pr
oduct reported under
the
ret
ail CGU is i
mpaired due to th
e decision to wind do
wn the book of business
. The goodwill in the remaining r
etail and
commercial C
GUs remains r
ecov
erable as at 31 December 202
1 and management hav
e a
deq
uately disclosed r
easonably
possible alternative
scenarios r
elating
to t
he ke
y assumptions that could r
esult in an impairment.
Management impaired
Nat
W
est Group
s inv
estm
ent in NWM, in
addition they r
ecognised
a re
v
ersal in acc
umulated impairments
in NWH due to the signific
ant headr
oom as a result of
the impro
ved ec
onomic outlook. The sensitivity analys
es we
re
view
ed,
and our independent proce
dure
s supported these assessmen
ts.
W
e are sa
tisfied that the disclosur
es appropriat
ely r
eflect the s
ensitivity of the carry
ing value o
f in
ves
tments in group
undertakings and goodwill to c
ertain re
asonable alternativ
e outc
o
mes.
As there
are a numbe
r of other possible outc
om
es and
it would be impr
acticable to e
stimate
the effect of
all of them, the dir
ectors hav
e disclosed the
uncert
ainty that other possible
outcomes within t
he next
financial year c
ould requir
e a
n adjus
tment to the c
arrying amount of in
vestments in group
undertakings and goodwill.
Relevant references in the A
nnual Report and Accounts
A
ccounting policies
Note 1
7 to the Gr
oup financial state
ments and Not
e 9 to the P
a
re
nt Company f
inancial state
m
ents
Independent a
uditors’ report to the
member
s of NatWest Gr
oup plc continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
293
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Risk
Our
response to the risk
Pro
v
isions for cust
om
er r
edress
, litigation and other regulator
y matters
A
t 31 December 2
021, the Group has
report
ed £1.3 billion (2020: £1.9 billion) of
pro
v
isions for liabilities an
d charges
,
including £0.8 billion (2020: £1
.1 billion) for
customer r
edres
s, litigation and
other
regulator
y matters as det
ailed in Not
e 21
of the financial st
atements
.
Re
gulatory scrutin
y and the co
ntinued
litigious envir
o
nment giv
e rise t
o a high
lev
el of management judgment in
determining appro
priate pro
visions and
disclosures
for specific cust
omer r
edress
,
litigation and other re
gulatory matter
s.
Management judgment is need
ed to
determine whether a pr
esent o
bligation
e
xists and a pro
vision should be rec
orded
at 31 December 2
021 in acc
ordance with
the accoun
ting criteria set out u
nder IA
S
37.
The most significan
t areas o
f judgment are:
Judgment and risk of manage
ment bias
-
A
uditing the adequacy of
these
pro
v
isions is comple
x because judgment
is in
volv
ed in
the selection and use o
f
assumptions in the estimation o
f
material pro
v
isions and ther
e is a ris
k of
management bias in the deter
mination
of whether an outflo
w in
re
spect of
identified material cust
omer re
dress
,
litigation and other re
gulatory matter
s
is probable and can be es
timated
reliably;
and
Disclosur
e
-
Judgment is requir
ed to
assess the adequacy o
f disclosur
es of
pro
v
ision for con
tingent liabilities giv
en
the underlying estimation unc
ertainty in
the pro
visions,
and other uncertainties
and assumptions.
Controls
testing
: W
e ev
aluated the design and oper
ating effe
ctiv
eness of c
ontrols
ov
er the identification, estimation, monitoring and disc
losure o
f provisions and
other uncert
ainties and assumptions re
lated to cust
om
er r
edress
, lit
igation and
other regulator
y matters c
onsidering the potential for man
agement ov
erride of
controls
. The controls te
sted, a
mong others, included
those to
identify and
monitor claims,
determine when a pr
ovision is r
equired and to
ensure
the
completeness and
accurac
y of data
used to esti
mate pr
ovision
s.
Ex
amination of r
egulatory corr
espondence
: W
e ex
am
ined the r
elevant r
egulatory
and legal corr
espondence to as
sess de
velopments in c
ertain c
ases. W
e also
consider
ed regulator
y dev
elopments to i
dentify actual or possible non-complianc
e
with law
s and re
gulations that might ha
ve a mate
rial effec
t on the financial
state
ments. F
or cases whic
h we
re settled during the per
iod, we c
ompared the
actual outflow
s with
the pr
ovisi
on that had been rec
orded, c
onsidere
d whether
further risk e
xisted, and ev
aluated the le
vel o
f disclosur
es pro
vided.
Inquiry of legal counse
l
: For sig
nificant legal matter
s, w
e rece
ived confirmations
from
the Group
s e
xternal legal c
o
unsel to e
valu
ate the lik
elihoo
d of the obligation
and management’
s es
timate of the outflo
w
at year-e
nd. W
e also conduct
ed
inquiries with internal legal c
ounsel o
ver the e
xistence o
f t
he legal obligations and
relate
d pro
vision. W
e performed a tes
t for unr
ecor
ded pro
visions to asses
s if there
we
re c
ases not considere
d in the pr
ovision esti
mate by as
sessing against e
xternal
legal confirmations and discu
ssing with internal c
ounsel.
T
esting of assumptions
: Wher
e appropriate, w
e involv
ed our conduct risk and
forensic
s specialists to assist
us in ev
aluating the pro
vision for specific cust
omer
redr
ess, litigation and other reg
ulatory matters
. W
e test
ed the underly
ing data
and assumptions used in the de
termination of the pr
ovisions r
ecor
ded, including
e
xpected claim rat
es, legal co
sts
, and the timing of set
tlement. W
e evaluate
d the
accur
acy of management
s hist
orical estimate
s by c
om
paring the actual
settlement to the pr
ovisio
n and c
onsidered peer
bank settlement in similar cases
.
W
e assessed the r
ea
sonablenes
s of the assumptions use
d by m
anagement by
comparing to the r
esults of our independently perf
ormed benchmarking and
sensitivity analy
sis. W
e also dev
eloped our own range o
f reaso
nable alternative
estimates and c
ompared them
to management
s pro
vision. W
e test
ed utilisations
of r
emaining pro
v
isions during the y
ear and
assesse
d the sufficienc
y of the
remaining pr
ovisions y
et to be paid for specific customer r
edr
ess, litigation and
other regulator
y matters
.
Disclosur
e
: W
e ev
alua
ted the di
sclosure
s pro
vided on custo
mer redr
ess, litigation
and other regulator
y matters
to assess whether the
y complied
with acc
ounting
standar
d
s.
Key observations communicated to the
Group Audit Committee
W
e are sa
tisfied that pro
visions for cust
omer r
edres
s, litigation and other r
egulatory matt
ers ar
e r
easonable and rec
o
gnised in
accor
d
ance with
IFRS. W
e concurr
ed with the rec
o
gnition, measur
ement and lev
el of disclosur
es of pr
ovisions r
ela
ting to
customer r
edres
s, litigation and
other regulatory
matters. W
e did not identify an
y materi
al unrec
o
rded pr
o
visions. W
e highlighted
the followin
g matters to
the Gr
oup
A
udit Committ
ee:
The lev
el of pro
visions by their nature incorpor
ates significa
nt judgments to be made and ma
y change as a r
esult of futur
e
dev
elopments.
Continued vigilanc
e in assessing c
onduct risks
from the i
mpact of C
OVID-19
, which may no
t manifest until w
ell after the
pandemic has passed.
Relevant references in the A
nnual Report and Accounts
Report of the Group Audit Committee
Accounting policies
Note 21 and 27 to the financial statements
Independent a
uditors’ report to the
member
s of NatWest Gr
oup plc continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
294
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Risk
Our response to the
risk
V
aluation of financial instrumen
ts with higher risk charact
eristi
cs including relate
d income fr
om trading activities
As reported in note 11 to the financial
statements, as at 31 December 202
1 the
company held financial instrume
nts with
higher risk characteristics. This included (but
is not limited to) reported level 3
assets of
£2.0 billion (2020: £1.7
billion) and level 3
liabilities of £0.6 billion (2020: £0.9
billion)
whose value is dependent upon
unobservable inputs.
The valuation of those financial i
nstruments
with higher risk characteristics can include
both significant judgment and the risk of
inappropriate revenue recognition through
incorrect pricing as outlined below. The
fair
value of these instruments can
involve
complex valuation models and significant
fair value adjustments, both of which may
be reliant on inputs where there is
limited
market observability.
Management’s estimates which
required
significant judgment include:
Complex models
- Complex model-
dependent valuations of financial
instruments, which include interest rate
swaps linked to pre-payment be
haviour
and interest rate and foreign exchange
options with exotic features;
Illiquid inputs
- Pricing inputs and
calibrations for illiquid instruments,
including debt securities and loans.
Additionally, the valuation of derivative
instruments is dependent on discount
rates associated with complex collateral
arrangements;
Fair value adjustments
- The
appropriateness and completene
ss of fair
value adjustments made to derivatives
valuations including Funding Valuation
Adjustments (FVA), Credit Valuation
Adjustments (CVA), and material product
and deal specific adjustments o
n long
dated derivative portfolios; and
The manipulation of revenue re
cognition
is most likely to arise through t
he
inappropriate valuation of these
instruments given the level of judgment
involved.
Controls testing
: We evaluated the design and oper
ating effectiveness of
controls relating to financial ins
trument valuation and related income statement
measurement including independent price verific
ation, valuation models
governance, collateral management, income st
atement analysis, and the
associated controls over relevant info
rmation technology systems. We also
observed the Valuation Commit
tees where valuation inputs, assumptions and
adjustments were discussed and approved.
We involved our financial instru
ment valuation and modelling specialists to
assist us in performing procedures including the followi
ng:
Complex models
: Testing complex model-dependen
t valuations by
performing independent revaluation to asse
ss the appropriateness of models
and the adequacy of assumptions and inputs used
by the Group;
Illiquid inputs
: Independently re-pricing instrume
nts that had been valued
using illiquid pricing inputs, using alte
rnative pricing sources where available,
to evaluate management’s valuation;
Fair value adjustments
: Comparing fair v
alue adjustment methodologies to
current market practice and as
sessing the appropriateness and adequacy of
the valuation adjustment framework in light of e
merging market practice and
changes in the risk profile of th
e underlying portfolio; and revaluing a sample
of counterparty level FVA and CVA, comparing fundi
ng spreads to third
party data, independently chall
enging illiquid CVA inputs, and testing
material product and deal specif
ic adjustments on long-dated derivative
portfolio.
Throughout our audit procedure
s we considered the appropriateness of
modelling changes in relation to IBOR transiti
on and impact of climate change
on the valuation of financial ins
truments, particularly in relation to long-dated
illiquid positions.
In addition, we asse
ssed wheth
er there w
ere an
y indicators o
f aggregate
bias in
financial instrument marking a
nd methodology assumptions.
W
e performed back-testing ana
lysis o
f rec
ent
trade activity an
d asset disposals
to ev
alua
te
the driver
s of signific
ant differe
nces betw
een book value and trade
value and to
assess the impact on the
fair value o
f similar instr
uments within
the portfolio. W
e performed an analysis o
f significant collater
al discrepancies
with counter
parties to assess the pote
ntial impact on the fair v
alue of the
underlying (and similar) financial ins
truments.
Key observations communicated to the
Group Audit Committee
We are satisfied that the assum
ptions used by management to reflect the fai
r value of financial instruments with higher risk
characteristics and the recognition of related income is
reasonable and in accordance with IFRS. We hig
hlighted the following
matters to the Group Audit Committee:
Complex-model dependent valuations were approp
riate based on the output of our independent re
valuations, analysis of
trade activity, assessment of the
output of the independent price verification process
, inspection of collateral disagreements
and peer benchmarking;
The fair value estimates of hard-to-price fin
ancial instruments appropriately reflected pricing
information available at 31
December 2021; and
Valuation adjustments applied to derivative
portfolios for credit, funding and othe
r risks were recorded in accordance with
the requirements of IFRS considering trade activi
ty for positions with common risk characteri
stics, analysis of market data
and peer benchmarking.
Relevant references in the A
nnual Report and Accounts
Report of the Group Audit Committee
Accounting policies
Note 11 to the financial statements
Independent a
uditors’ report to the
member
s of NatWest Gr
oup plc continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
295
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Risk
Our response to the
risk
Pension valuation and net pension asset
The Group operates a number of def
ined
benefit schemes which in aggregate are
significant in the context of the overall
balance sheet. At 31 December 2
021, the
Group reported a net pension ass
et of £488
million (2020: £602 million) com
prising £602
million of schemes in surplus and £114
million of schemes in deficit (2020: £
723
million and £121 million respectively
). The
net pension asset is sensitive to changes in
the key judgments and estimates, which
include:
Assumptions
-
Actuarial assumptions and
inputs including discount rate, i
nflation,
pension payment and longevity
to
determine the valuation of retire
ment
benefit liabilities;
Valuations
-
Pricing inputs and
calibrations for illiquid or comple
x model-
dependent valuations of certain
investments held by the schemes
; and
Augmentation cap
-
Quantification of
trustee’s rights to unilaterally augment
benefits (Augmentation cap) to determine
the recognition of surplus.
Controls testing
-
We evaluated the design
and operating effectiveness of
controls over the actuarial assu
mptions setting process, the data inputs used in
the actuarial calculation and the
measurement of the fair value of the schemes’
assets.
Assumptions
-
We involved our actuarial s
pecialists to evaluate the actuarial
assumptions by comparing them to independently ob
tained third party sources
and market practice. We asses
sed the impact on pension liabilities due to
changes in financial, demographic and longevi
ty assumptions over the year,
including the continued effects of CO
VID-19, and whether these were supported
by objective external evidence and ration
ales.
Valuations
- We involved our valuation specialists t
o assess the appropriateness
of management’s valuation methodology inclu
ding the judgments made in
determining significant assumptions used in
the valuation of complex and illiquid
pension assets. We tested the fair value of scheme asse
ts by independently
calculating fair value for a sample of the assets held. Ou
r sample included cash,
equity and debt instruments, derivative fina
ncial instruments and illiquid assets.
Augmentation cap and equalisation adjus
tments
- We involved our actuarial
specialists to test the estimation of the augmen
tation cap including the inputs
used in the calculation. We also assess
ed the methodology and judgments made
in calculating these estimates and the associate
d accounting treatment in
accordance with IAS 19 and IFRIC 14.
Disclosure
-
We assessed the adequacy of the disclosu
res made in the financial
statements, including the appropriateness
of the assumptions and sensitivities
disclosed.
Key observations communicated to the
Group Audit Committee
We
ar
e
satisfied
th
at
the
valuation
and
disclosure
of
the
net
pension
ba
lance
are
r
easonable
and
in
accordance
w
ith
IFRS.
We
highlighted the following matters to the Group Audit Co
mmittee:
Our
bench
marking
of
key
actuarial
assu
mptions
inclu
ding
the
discount
rate,
inflation,
longevity
and
pension
payments
concluded that assumptions we
re within a reasonable range;
No material differences were identified through our i
ndependent valuation testing for a sampl
e of pension assets; and
Management’s
estimate
of
the
impact
of
t
he
augmentation
cap
was
materially
consistent
with
our
independent
estimate
using our own model.
Relevant references in the A
nnual Report and Accounts
Accounting policies
Note 5 to the financial statements
Independent a
uditors’ report to the
member
s of NatWest Gr
oup plc continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
296
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Risk
Our response to the
risk
IT access management
The IT environment is complex and
pervasive to the operations of the Group
due to the large volume of transactions
processed in numerous locations on a daily
basis with extensive reliance on automated
controls.
Appropriate IT controls are
required to ensure that applications process
data as expected and that cha
nges are
made in an appropriate manner. This risk is
also impacted by the greater d
ependency
on third parties, increasing use of cl
oud
platforms, decommissioning of l
egacy
systems, and migration to new sys
tems.
Such controls contribute to mitigating the
risk of potential fraud or errors as a resul
t
of changes to applications and data.
The Group has implemented use
r access
management controls across IT
applications,
databases and operating systems. We have
identified user access-related de
ficiencies in
the past and whilst the number of
deficiencies has reduced year o
ver year, the
risk of inappropriate access remains.
We evaluated the design and operating effectiveness
of IT general controls over
the applications, operating systems and databases th
at are relevant to financial
reporting. During our planning and test of design
phases, we performed
procedures to determine whethe
r changes in restrictions in different global
locations, as a result of the ongoing global COVID-19 p
andemic had caused
material changes in IT processes or controls and o
bserved no such changes
that would result in an increased IT risk.
Controls testing
We tested user access by assess
ing the controls in place for in-scope
applications, in particular testin
g the addition and periodic recertification of
users’ access. We continue to f
ocus on key controls enforced by the Group’s
user access management tools, including
the completeness of use
r data,
automated identification of mo
vers and leavers and the adequacy of the ove
rall
control environment. Our testing included the G
roup’s additional attestation and
leaver checks enhancing its identity and
access control environment.
A number of systems are outsourced to thi
rd party service providers. For these
systems, we tested IT general controls through evalu
ating the relevant Service
Organisation Controls reports (where available). This include
d assessing the
timing of the reporting, the controls tes
ted by the service auditor and whether
they address relevant IT risks.
We also tested required complementary user
entity controls performed by management.
Where
a SOC report was not
available we identified and reviewed compensating business
controls to address
this risk. Several systems have been migrated to a cloud
-hosted infrastructure
model, access management proce
sses and controls remain in-house which
formed part of our testing.
Where control deficiencies wer
e identified, we tested remediation activities
performed by management and compens
ating controls in place and assesse
d
what additional testing procedu
res were necessary to mitigate any residu
al risk.
We also performed a further analysis of acces
s management deficiencies
identified by EY, Management and Inte
rnal Audit to revalidate our overall
approach to access management testing.
Key observations communicated to the
Group Audit Committee
We are satisfied that IT controls impacting financial
reporting are designed and operating effe
ctively. The following matters were
reported to the Group Audit Committee:
We have seen an overall reduction in the
number of discrete IT control deficiencie
s identified compared to prior year.
Improvements
were
m
ade
to
further
standardise
access
m
anagement
p
rocesses
and
controls
across
the
Group,
which
was
one of the drivers for the reduce
d number of deficiencies.
Particular
att
ention
should
continue
to
be
paid
t
o
controls
over
user
access
management
in
cluding
ensuring
the
completeness
and
accu
racy
of
the
data
used
t
o
perform
a
ccess
controls.
Where
issues
w
ere
noted
in
relation
t
o
acces
s
management, these
were r
emediated by
year end
or mitigated
by
compensating controls. We
performed additional
testing in
response to deficiencies identified, where
required.
Our application of materiality
W
e apply the conce
pt of materiality in planni
ng and performing the audit, in e
valuatin
g the effect of
identified misstat
ements on the
audit and in forming our audit opinion.
Materiality
The magnitude o
f an omission or misst
atement that
, individually or in the aggr
egat
e, could r
e
as
onably be expect
e
d t
o inf
luence
the
economic decisions o
f
the users
of the financial s
t
at
ement
s. Mat
e
rialit
y pro
vides a b
asis f
or de
t
ermining the nat
ure and e
xt
ent of our
audit proc
edures
.
W
e determined mater
iality for the Group t
o
be £157 million (2020: £
160 million), which is 5% (2020
: 5%) of the prof
it before t
ax of
the Group o
f £4,032 million (2020: loss
before t
ax of the Group
including discon
tinued operations o
f £351 million) adjuste
d for loan
impairment releases ari
sing fr
om C
OVID-1
9 economic re
co
ve
ry, normalised loan impairment charges
, loss on redemption of
own
debt, non-recurr
ing conduct and str
a
tegic c
osts and cer
tain non-r
ecurring tr
ansactions. W
e believ
e removing ite
ms that would
otherwise hav
e a disproportionate impact on materiali
ty refle
cts the most use
ful measure f
or users o
f the financial st
atements and
is consiste
nt with the prior ye
ar
.
The 5% basis used for
Group materi
ality is consist
ent with the wider industry
, and is the sta
ndard
for listed
and regulate
d entities.
W
e determined mater
iality for the P
arent Co
mpany to be £1
57 million (2020: £160 million) which is 0.3
% (2020: 0.4%) of
equity of
the Par
ent Compan
y and
is con
sistent with the prior y
ear. W
e believe this r
eflects the most u
seful measur
e for user
s of the fi
nancial
state
ments as the Par
ent Co
mpany
s primary purpose is to act as a holding c
ompany with in
vestments in the Gr
oup
s subsidiaries,
not to gener
ate opera
ting prof
its and theref
ore a profit b
ased measure i
s not rele
vant.
Independent a
uditors’ report to the
member
s of NatWest Gr
oup plc continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
297
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Per
formance materiality
The application o
f mat
e
rialit
y at the individual ac
count or balanc
e lev
e
l. It is s
et at an amo
unt to r
educe to a
n appropriat
ely low le
vel
the probabilit
y that the aggregat
e of uncorr
ect
ed and unde
t
ect
ed miss
tat
ements e
xceeds mat
erialit
y.
On the basis of our
risk assessments, t
ogether with our assessment o
f the Group
s o
ver
a
ll contr
ol envir
onment, our judgment w
a
s
that performance mater
iality w
as 75% (2020: 50%) o
f our planning materiality, namely £1
18 million (2020: £80 million). W
e hav
e
increased
the perc
entage of perf
ormance materiality
from the
prior ye
ar considering that the number and amount of iden
tified
misstatemen
ts has decr
eased and to r
eflect the continued impr
ove
ments in the effectiv
eness of the c
ontrol en
viro
nment and other
factors aff
ecting the entity and its financi
al reporting.
Audit w
ork at component te
ams for the
purpose of obtaining au
dit cov
erage
ov
er significant financial state
ment accoun
ts is undertak
en based on a per
centage o
f total per
formance materi
ality. The
performance materiali
ty set for
each component is based on the r
elat
ive
scale and risk o
f the c
omponent to the Group
as a whole
and our assessment of
the risk of misst
atement at that c
omponent. In the curr
ent ye
ar, the r
ange of performance mater
iality
allocated to c
omponents was £
35 million to £106 million (2020:
£30 million to £72 million
).
Re
porting th
res
hold
An amount below which id
entified misst
atement
s are
consider
ed as being clearly trivial.
W
e agreed with the
Audit C
ommittee t
hat we w
ould report to them all uncorr
ected audit differ
ences in e
xcess o
f £8 million (
2020:
£8 million), which is set at 5%
of planning materialit
y, as well a
s differ
ences belo
w t
hat threshold that, in our vie
w, warra
nted
reporting on qualita
tive gr
ounds.
W
e ev
a
luate an
y uncorr
ected mis
statements agai
nst both the quantitativ
e measur
es of materia
lity discussed abo
ve
and in light of
other rele
vant qualitative
consider
a
tions in for
ming our opinion.
Other information
The other information comprises the information i
ncluded in the Annual Report and Accounts,
including the Strategic Report,
Financial Review, Corporate Governance, Report of
the Group Nominations and Governance
Committee, Report of the Group Audit
Committee, Report of the Group Board Risk Com
mittee, Report of the Group Sustain
able Banking Committee, Report of the
Technology and Innovation Co
mmittee, Report of the directors, Risk and c
apital management, Non-IFRS financial measure
s, Risk
factors, Material contracts, and Additional info
rmation, other than the financial st
atements and our auditor’s report thereon.
The
directors are responsible for the
other information contained within the annual repo
rt.
Our opinion on the financial st
atements does not co
ver the other information and, e
xc
ept to the e
xtent otherwise e
xplicitly st
a
ted in
this report, w
e do not e
xpress
any f
orm of assur
ance conclusi
o
n thereon.
Our responsibility is to read the other infor
mation and, in doing so, consider whet
her the other information is materially
inconsistent with the financial statements or ou
r knowledge obtained in the course of the audi
t, or otherwise appears to be
materially misstated. If we identify
such material inconsistencies or apparent material misst
atements, we are required to determine
whether this gives rise to a material misstatement in the fin
ancial statements themselves. If, b
ased on the work we have
performed, we conclude that there is a material
misstatement of the other info
rmation, we are required to report that fact.
We have nothing to report in th
is regard.
Opinions on other matters pr
escribed by the C
omp
anies A
ct 2006
In our opinion, the part of the D
irect
ors
Remuner
a
tion R
eport to be audited h
as been properly prepar
ed in accor
dance with the
Companies
Act 2006.
In our opinion, based on the w
ork undert
aken in t
he course o
f the audit:
the information give
n in the Str
a
tegic r
eport and the Report o
f the dire
ctors for
the financial y
ear for which the financial
state
ments are pr
epared is c
onsiste
nt with the financial state
ments; and
the Strategic r
eport and the Report of the dir
ectors ha
ve been prepar
ed in accor
dance with applicable legal r
equirements.
Matters o
n which we are
required to
report by
ex
ception
In the light of the kno
wledge and underst
an
ding of t
he Group a
nd the Pare
nt C
ompany and its en
vironment obtained in the c
ourse
of the audit, w
e hav
e not id
entif
ied material misst
atements in the Str
ategic r
eport or the Re
port of the dir
ectors
.
We have nothing to report in respect of the followi
ng matters in relation to which the Compa
nies Act 2006 requires us to report to
you if, in our opinion:
adequate acc
ounting rec
o
rds h
av
e not b
een k
ept by the P
a
re
nt Compan
y, or r
eturns adequate f
or our audit hav
e not been
rec
eiv
ed from br
anches not visit
ed by
us; or
the Par
ent Compan
y financia
l s
tatements and the part of
the Dir
ectors
Remuner
ation Report to be audite
d are not i
n
agreement with the
accounting
rec
o
rds and r
eturns
; or
cert
ain disclosures o
f direct
ors
remuner
a
tion specified b
y la
w are not made; or
we
hav
e not rec
eiv
ed all the information and e
xplanations w
e re
quire for our
audit.
Independent a
uditors’ report to the
member
s of NatWest Gr
oup plc continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
298
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Corporat
e Gover
nance State
ment
We have reviewed the directors’ statement in rela
tion to going concern, longer-term viabili
ty and that part of the Corporate
Governance Statement relating
to the group and company’s compliance with the provisions o
f the UK Corporate Governanc
e Code
specified for our review by the
Listing Rules.
Based on the w
ork undertak
en as part of our audit, we ha
ve c
oncluded that each of the follo
wing elements of the Corpor
ate
Gov
ernance Statement is mate
rially consist
ent with the financi
al statemen
ts or our knowle
dge obtained during the au
dit:
Dire
ctors
statement with regar
d
s to the appr
op
riateness o
f adopting the going co
ncern basis of
accounting and an
y mater
ial
uncert
ainties identified;
Dire
ctors
explanation as to its assessment of
the company
s pr
ospects, the period this assess
ment cov
ers and why the period is
appropriate;
Dire
ctors
statement on fair
, balanced and under
standable;
Director’s statement on whether
it has a reasonable
expectation that
the group will be able
to continue in
operation and meet
s its liabilities;
Board’
s c
onfirmation that it has c
arried out a robust
assessment of the emer
ging and principal risks
;
The section of the
annual report that descr
ibes the re
view of
effectiv
eness of risk management and inter
nal control s
ystems
;
and;
The section descr
ibing the work o
f the audit committee
.
R
esponsibilities of direct
ors
As explained more fully in the Statemen
t of directors’ responsibilities, the directors are respo
nsible for the preparation of the
financial statements and for being satisfied
that they give a true and fair view, and for such in
ternal control as the directors
determine is necessary to enable the preparation of f
inancial statements that are free from m
aterial misstatement, whether due to
fraud or error.
In preparing the financial statements, the di
rectors are responsible for assessing the Group and Paren
t Company’s ability to
continue as a going concern, disclosing, as applicable, m
atters related to going concern and us
ing the going concern basis of
accounting unless the directors e
ither intend to liquidate the Group or the Parent Company o
r to cease operations, or have n
o
realistic alternative but to do so.
A
uditor’
s responsibilities for the audit of the financial stat
ements
Our objectiv
es are t
o obtain reason
able assur
ance about whether the financial s
tatements
as a whole are fr
ee from mater
ial
misstatemen
t, whether due to f
raud or err
or, and to issue
an auditor’
s report that includes our opinion. R
easonable assuranc
e is a
high lev
el of assur
a
nce, bu
t is not a guar
antee that an audit conduct
ed in acc
ordanc
e with IS
As (UK) will alwa
ys det
ect a mate
rial
misstatemen
t when it e
xists.
Misstate
m
ents can arise
fr
om fr
aud or err
or and are c
onsidered
material if, indivi
dually or in the
aggregate, t
hey c
ould rea
sonably be e
xpected to influence the ec
onomic decisions of users t
aken on the basis of the
se financial
state
ments.
Explanation as to what e
xtent the audit w
as considered c
apable of detect
ing irregu
larities, including
fraud
Irregularities
, including fr
aud
, ar
e instances o
f non-compliance
with law
s and regula
tions. W
e design procedure
s in line with our
responsibilities
, outlined below
, to detec
t irregularities
, including fr
a
ud.
The ris
k of not detecting a mater
ial misst
atement due to
fraud is hi
gher than the risk o
f not detecting one r
esulting fr
om err
or
, as frau
d may in
v
olve deliber
a
te c
oncealment by,
for e
xample,
forger
y or intentional misre
pre
sentations
, or thr
ough collusion.
The e
xtent to which our pr
o
ced
ures ar
e capable of det
ecting
irre
gularities, including fr
aud is det
ailed below
.
Ho
wev
er, the primary r
esponsibility for the pre
ve
ntion and detection of
frau
d rests
with both those char
ged with gov
ernance of the
company and ma
nagement.
W
e obtained an underst
a
nding o
f the legal and regul
atory fr
amew
orks th
at are applic
able to
the Group and dete
rmined that the
most significant
are the r
egulations
, licence
conditions and supervisory
requir
em
ents of the Pr
udential Regula
tion
Aut
hority
(PRA) and the Financial Co
nduct
Authority (FC
A); Companies
Act 2006; and the Sarbanes Oxle
y
Act (SO
X).
W
e understood how
the Group is
complying with those f
r
amew
orks b
y making
inquiries o
f management, inter
nal audit and
those responsible f
or legal and c
ompliance matters
. W
e also re
view
ed correspondence
between the Gr
oup and regul
atory
bodies; re
view
ed minutes of the Board
and Risk Commit
tees; a
nd gained an underst
anding of the Gr
oup
s gov
ernance
fra
mew
ork.
W
e assessed the susc
ept
ibility o
f the Group
s financial sta
tements to m
aterial misst
a
tement, inclu
ding how fr
a
ud might occur
by
considering the con
trols est
a
blished to addr
ess risks identified t
o pre
vent or det
ect fr
aud. W
e also identifie
d the risks o
f fr
aud in
our k
ey audit m
atters as describe
d abov
e and identified areas that w
e consider
ed when perfor
ming our fraud pr
o
cedur
es, su
ch
as cyberse
curity, the impact of r
emote wor
king, implementation of
new go
ver
nment supported lending pr
oducts, and the
appropriatene
ss of sour
ces u
sed when performing co
nfirmation tes
ting on acc
ounts such as c
ash, loans and securities
.
Based on this unders
tanding w
e designed our audit proce
dure
s to identify non-com
pliance with such la
ws and
regulations
. Our
procedur
es in
volv
ed inquiries of legal counsel, e
xecutiv
e management, and inter
nal audit. W
e also test
ed contr
ols and
performed proce
dures to r
espond to the fraud risk
s a
s identified in our k
ey audit matter
s. The
se proce
dures w
ere performed b
y
both the primary team and co
mponent teams with o
ver
sight fr
om the primary team.
The Group oper
ates in the banking industry
which is a highly r
egulated en
vironment.
As such, the Senior St
atutory
Auditor
consider
ed the exper
ience and e
xpertise of the engagement team to e
nsure that the t
eam had the appro
priate compete
nce and
capabilities, in
volvin
g specialists wher
e ap
pro
priate.
A further description of our responsibilities fo
r the audit of the financial statements is located
on the Financial Reporting Council’s
website at frc.org.uk/auditorsresponsibilities. This
d
escription forms part of our a
uditor’s report.
Independent a
uditors’ report to the
member
s of NatWest Gr
oup plc continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
299
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
meeting on 4 Ma
y 2016 t
o audit the financial statemen
ts for the y
ear ending 31 Dec
ember 2016 and subsequent financial
periods.
The audit opinion is consis
tent with
the additional report to th
e Group
Audit C
ommittee.
This re
port is made solely to the c
ompany
s members, as a body, in acc
ordanc
e with Chapter 3
of P
art 16 of the C
ompanies
A
ct
2006. Our audit wor
k has been undertak
en so that w
e might state to the c
ompany
s members those matters
we ar
e re
quired to
Other matters we are required to address
Follo
wing
the rec
ommendation f
rom the Gr
oup A
udit Committe
e, we w
ere appointed by
the Group at its annual gene
ral
Use of our r
eport
The period of total uninter
rupted engagement includin
g previ
ous r
enew
als an
d re
appointments is 6 y
ears, c
over
ing perio
ds fr
om
our appointment through 31 D
ec
ember 2021.
state t
o them in an auditor’
s r
eport and for no other
purpose. T
o the fullest exte
nt permitted b
y law, w
e do not accept or as
sume
responsibility to an
yone other than the compan
y and the c
ompany
s members as a bod
y, for
our audit wor
k, for this r
eport, or for
the opinions we
hav
e formed.
Micha Missakian (Senior s
tatutor
y auditor)
for and on behalf of Erns
t & Y
oung LLP
, Statutory
A
uditor
London, United
Kingdom
17
February
2022
C
on
soli
d
at
ed income
st
at
ement f
or the y
ea
r ended
31 Dec
emb
er 2021
NatWest Group
A
nnual Repor
t and Accou
nts 2021
300
Financial statements
Strategic report
 
Governance
 
Risk and capital management
 
Additional information
 
Financial review
 
 
Note
2021
2020
(1)
2019
(1)
£m
£m
£m
Interest receivable
 
9,313
9,798
11,127
Interest payable
(1,699)
(2,322)
(3,328)
Net interest income
1
7,614
7,476
7,799
Fees and commis
sions receivable
 
2,698
2,722
3,345
Fees and commis
sions payable
(574)
(722)
(848)
Income from trading act
ivities
323
1,125
932
Other operating i
ncome
 
451
(93)
2,759
Non-interest income
2
2,898
3,032
6,188
Total income
10,512
10,508
13,987
Staff costs
(3,676)
(3,878)
(3,976)
Premises and equip
ment
 
(1,133)
(1,222)
(1,258)
Other administrat
ive expenses
(2,026)
(1,845)
(2,828)
Depreciation and a
mortisation
(923)
(913)
(1,218)
Operating expenses
3
(7,758)
(7,858)
(9,280)
Profit before impairme
n
t releases/(losses)
2,754
2,650
4,707
Impairment releas
es/(losses)
15
1,278
(3,131)
(724)
Operating profit/
(loss) before tax
4,032
(481)
3,983
Tax charge
 
7
(996)
(74)
(439)
Profit/(loss) from co
ntinuing opera
tions
 
3,036
(555)
3,544
Profit from discontin
ued operatio
ns, net of tax
(2)
8
276
121
256
Profit/(loss) for the year
3,312
(434)
3,800
 
 
Attributable to:
 
Ordinary sharehold
ers
2,950
(753)
3,133
Preference share
holders
19
26
39
Paid-in equity h
olders
 
299
355
367
Non
-
controlli
ng interests
 
44
(62)
261
 
 
3,312
(434)
3,800
 
 
Earnings per ordi
nary share - continui
ng operations
9
23.0p
(7.2p)
23.9p
Earnings per ordi
nary share - dis
continued operatio
ns
9
2.4p
1.0p
2.1p
Total earnings per s
hare attributa
ble to ordinary shareh
olders - bas
ic
9
25.4p
(6.2p)
26.0p
Earnings per ordi
nary share - fully dil
uted continuing operati
ons
9
22.9p
(7.2p)
23.8p
Earnings per ordi
nary share - fully dil
uted discontinued operatio
ns
9
2.4p
1.0p
2.1p
Total earnings per s
hare attributa
ble to ordinary shareh
olders - fully dilute
d
9
25.3p
(6.2p)
25.9p
 
(1)
Comparative results have been
re-presented from those previously published to reclassify certain items as discontinued operations as des
cribed in Note 8 to the consolidated
financial statements.
(2)
The results of discontinued operations, comprising th
e post-tax profit is shown as a single amount on the face of the income statement. An analysis of this amount is presented in
Note 8 to the consolidated financial statements.
The accompanying notes on pages 31
3 to 377, the Accounting policies on pages 307 to 312
and the audited sections of the
Financial review and Risk and capital man
agement sections on pages 84 to 95 and 1
88 to 285 form an integral part of these
financial statements.
C
on
soli
d
at
ed st
a
t
ement o
f c
ompr
ehensiv
e
inco
me
f
or the
y
ear ended 31 D
ecember 20
21
NatWest Group
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nnual Repor
t and Accou
nts 2021
301
Financial statements
Strategic report
 
Governance
 
Risk and capital management
 
Additional information
 
Financial review
 
 
 
 
2021
2020
2019
 
£m
£m
 
£m
Profit/(loss) for the year
3,312
(434)
3,800
Items that do not qualify for rec
lassification
Remeasurement of retirement benefit schemes
 
 
 
- other movements
(1)
 
(669)
4
(142)
Loss on fair value of credit in financial liabili
ties
 
designated at FVTPL due to own credit risk
 
(29)
(52)
(189)
FVOCI financial assets
13
(64)
(71)
Tax
164
42
28
 
 
(521)
(70)
(374)
 
 
Items that do qualify for reclassif
ication
FVOCI financial assets
(100)
44
(14)
Cash flow hedges
(848)
271
294
Currency translation
(382)
276
(1,836)
Tax
 
 
213
(89)
(170)
 
 
(1,117)
502
(1,726)
Other comprehensive (loss)/income afte
r tax
(1,638)
432
(2,100)
Total comprehensive income/(loss) for the ye
ar
1,674
(2)
1,700
 
 
Attributable to:
Ordinary shareholders
1,308
(338)
1,044
Preference shareholders
19
26
39
Paid
-
in
equity holders
 
299
355
367
Non-controlling interests
48
(45)
250
 
 
 
1,674
(2)
1,700
 
(1)
Following the purchase
of ordinary shares from
UKGI in Ma
rch 2021, NatWest Group contributed £500 million to its main pension scheme in line with the memorandum of
understanding announced on 17 April 2018. After tax relief, this contribution
reduced total equity by £365 million.
There w
as also a pre-tax loss of £192 million (€224 million) in
relation to the re-measurement of the Group’s Republic of Ireland pension schemes, p
rimaril
y as a result of significant movements in underlying a
ctuarial assumptions (2020: pre-tax
gain of £72 million (€81 million)). In line with our policy, the present value of defined ben
efit obligations and the fair value of plan assets at the end of the reporting period, are
assessed to identify significant market fluctuations and one
-off events since the end of the prior financial year.
 
The accompanying notes on pages 31
3 to 377, the Accounting policies on pages 307 to 312
and the audited sections of the
Financial review and Risk and capital man
agement sections on pages 84 to 95 and 1
88 to 285 form an integral part of these
financial statements.
C
on
soli
d
at
ed balance shee
t as at 31 Dec
e
mber 2021
NatWest Group
A
nnual Repor
t and Accou
nts 2021
302
Financial statements
Strategic report
 
Governance
 
Risk and capital management
 
Additional information
 
Financial review
 
 
Note
2021
2020
 
£m
£m
 
Assets
 
Cash and balances at central banks
10
177,757
124,489
 
Trading assets
13
59,158
68,990
 
Derivatives
 
14
106,139
166,523
 
Settlement balances
2,141
2,297
 
Loans to banks - amortised cost
10
7,682
6,955
 
Loans to customers - amortised cost
10
358,990
360,544
 
Securities subject to repurchas
e agreements
11,746
11,542
 
Other financial assets excluding secu
rities subject to repurchase agreements
34,399
43,606
 
Other financial assets
16
46,145
55,148
 
Intangible assets
17
6,723
6,655
 
Other assets
18
8,242
7,890
 
Assets of disposal groups
 
8
9,015
 
Total assets
781,992
799,491
 
 
 
 
Liabilities
 
Bank deposits
10
26,279
20,606
 
Customer deposits
10
479,810
431,739
 
Settlement balances
2,068
5,545
 
Trading liabilities
13
64,598
72,256
 
Derivatives
 
14
100,835
160,705
 
Other financial liabilities
19
49,326
45,811
 
Subordinated liabilities
20
8,429
9,962
 
Notes in circulation
3,047
2,655
 
Other liabilities
21
5,797
6,388
 
Total liabilities
740,189
755,667
 
 
 
 
Ordinary shareholders' interests
37,412
38,367
 
Other owners' interests
4,384
5,493
 
Owners’ equity
22
41,796
43,860
 
Non
-
controlling interests
 
7
(36)
 
Total equity
41,803
43,824
 
 
 
 
Total liabilities and equity
781,992
799,491
 
 
The accompanying notes on pages 31
3 to 377, the Accounting policies on pages 307 to 312
and the audited sections of the
Financial review and Risk and capital man
agement sections on pages 84 to 95 and 1
88 to 285 form an integral part of these
financial statements.
The accounts were approved by the Board of di
rectors on 17 February 2022 and signed on it
s behalf by:
 
 
 
 
Howard Davies
Alison Rose-Slade
Katie Murray
NatWest Group plc
Chairman
G
roup Chief Executive Off
icer
Group Chief Financial Officer
Registered No. SC4555
1
 
 
C
on
soli
d
at
ed st
a
t
ement o
f changes in e
quit
y f
or the
y
ea
r
ended 31 D
ec
ember 2021
NatWest Group
A
nnual Repor
t and Accou
nts 2021
303
Financial statements
Strategic report
 
Governance
 
Risk and capital management
 
Additional information
 
Financial review
 
2021
2020
2019
£m
 
£m
 
£m
 
Called
-
up share capital
-
 
at 1 January
 
 
12,129
12,094
12,049
Ordinary shares issued
37
35
45
Share cancellation
(1,5)
 
(698)
At 31 December
11,468
12,129
12,094
 
 
Paid-in equity - at 1 January
4,999
4,058
4,058
Redeemed
(1,277)
Reclassified
 
(2)
 
(2,046)
Securities issued during the period
937
2,218
At 31 December
3,890
4,999
4,058
 
 
Share premium - at 1 January
1,111
1,094
1,027
Ordinary
shares issued
 
50
17
67
At 31 December
 
 
1,161
1,111
1,094
 
 
Merger reserve - at 1 January
and 31 December
10,881
10,881
10,881
 
 
FVOCI reserve
- at 1 January
360
138
343
Unrealised gains/(losses)
 
32
76
(107)
Realised (gains)/losses
(3)
 
(122)
152
(90)
Tax
(1)
(6)
(8)
At 31 December
269
360
138
 
 
Cash flow hedging reserve - at 1 January
229
35
(191)
Amount recognised in equity
 
 
(687)
321
573
Amount transferred from equity
to earnings
(161)
(50)
(279)
Tax
224
(77)
(68)
At 31 December
(395)
229
35
 
 
Foreign exchange reserve
-
 
at 1 January
 
 
1,608
1,343
3,278
Retranslation of net assets
(484)
297
(428)
Foreign currency gains/(losses) on hedges of net asse
ts
88
(55)
83
Tax
(17)
6
(110)
Recycled to profit or loss on disposal of businesse
s
10
17
(1,480)
At 31 December
1,205
1,608
1,343
 
 
Capital redemption reserve - at 1
January
Share cancellation
(1)
 
698
Redemption of preference shar
es
24
At 31 December
722
 
Retained earnings - at 1 January
12,567
13,946
14,312
Implementation of IFRS 16 on 1 January 20
19
(187)
Profit/(loss) attributable to ordinary shareholders
and other equity owners
- continuing operations
2,992
(493)
3,283
 
-
 
discontinued operations
 
276
121
256
Equity preference dividends paid
(19)
(26)
(39)
Paid-in equity dividends paid
(299)
(355)
(367)
Ordinary dividends paid
(693)
(3,018)
Shares repurchased during the ye
ar
 
(1,5)
 
(1,423)
Unclaimed dividend
2
Redemption of preference shar
es
(24)
Redemption/reclassification of paid-in equity
(2,6)
 
150
(355)
Realised gains/(losses) in period on FVOCI equi
ty shares
 
-
 
gross
 
3
(248)
112
- tax
Remeasurement of the retirement benefit schemes
 
 
 
- other movements
(4)
 
(669)
4
(142)
- tax
(4)
 
168
22
24
Changes in fair value of credit in fi
nancial liabilities designated at FVTPL
 
 
 
- gross
(29)
(52)
(189)
- tax
3
8
20
Shares issued under employee share schemes
8
(11)
(6)
Share-based payments
(7)
 
(45)
4
(113)
At 31 December
12,966
12,567
13,946
For the notes to this table refer to the following pa
ge.
 
Consolidated statem
ent of
changes in equity f
or the year end
ed 31 Decembe
r 2021 co
ntinued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
304
Financial statements
Strategic report
 
Governance
 
Risk and capit
al management
Additional information
 
Financial review
 
2021
2020
201
9
£m
£
m
£
m
Own shares held - at 1 January
(24)
(42)
(21)
Shares issued under employee share schemes
 
36
95
39
Own shares acquired
(1)
 
(383)
(77)
(60)
At 31 December
(371)
(24)
(42)
 
Owners’ equity at 31 December
41,796
43,860
43,547
 
Non-controlling interests - at 1 January
(36)
9
754
Currency translation adjustments and othe
r movements
4
17
(11)
Profit/(loss) attributable to non-controlling i
nterests
44
(62)
261
Dividends paid
(5)
(5)
Equity raised
45
Equity withdrawn and disposals
 
(1,035)
At 31 December
7
(36)
9
 
 
 
Total equity at 31 December
41,803
43,824
43,556
 
 
 
Attributable to:
 
Ordinary shareholders
37,412
38,367
38,993
Preference shareholders
494
494
496
Paid
-
in equity holders
 
3,890
4,999
4,058
Non-controlling interests
7
(36)
9
 
 
41,803
43,824
43,556
 
(1)
In March 2021, there was an agreement with HM Treasury to buy 591
million ordinary shares in the Company from UK Government Investments Ltd (UKGI), at 190.5p per share for
the total consideration of £1.13 billion. NatWest Group cancelled 391 million of the purchased ordinary shares, amounting to £744
million excluding fees, and held the remaining 200
million in own shares held, amounting to £381 million excluding fees. T
he nominal value of the share cancellation has been transferred to the capital redemption reserve.
(2)
In July 2021, paid-in equity
reclassified to liabili
ties as th
e result of a call in August 2021 of US$2.65 billion AT1 capital notes.
(3)
In 2020, the completion of the Ala
wwal bank merger resulted in the derecognition of the associate investment in Alawwal bank and recognition of a new investment in SABB h
eld at
fair value through other comprehensive income (FVOCI).
(4)
Following the purchase
of ordinary shares from
UKGI in Ma
rch 2021, NatWest Group contributed £500 million to its main pension scheme in line with the memorandum of
understanding announced on 17 April 2018. After tax relief, this contribution
reduced total equity by £365 million.
There w
as also a pre-tax loss of £192 million (€224 million) in
relation to the re-measurement of the Group’s Republic of Ireland pension schemes, p
rimaril
y as a result of significant movements in underlying a
ctuarial assumptions (2020: pre-tax
gain of £72 million (€81 million)). In line with our policy, the present value of defined ben
efit obligations and the fair value of plan assets at the end of the reporting period, are
assessed to identify significant market fluctuations and one
-off events since the end of the prior financial year.
(5)
In line with the announcement in July 2021
, NatWest Group plc repurchased and cancelled 310.8 million shares for total consideration of £676.2 million excluding fees. Of the 310.8
million shares bought back, 2.8 million sha
res were settled and cancelled in January 2022. The nominal value of the share cancellations has been transferred to the capital
redemption reserve with the share premium element to retained earnings.
(6)
The redemption of pa
id-in equity includes a tax credit of £16 million.
(7)
Share-based payments includes a tax
credit of £10 million.
 
The accompanying notes on pages 31
3 to 377, the Accounting policies on pages 307 to 312
and the audited sections of the
Financial review and Risk and capital man
agement sections on pages 84 to 95 and 1
88 to 285 form an integral part of these
financial statements.
C
on
soli
d
at
ed cash fl
o
w st
at
ement fo
r the y
e
ar ended 31
Dec
e
mber 2021
NatWest Group
A
nnual Repor
t and Accou
nts 2021
305
Financial statements
Strategic report
 
Governance
 
Risk and
capital managemen
t
Additional information
 
Financial review
 
 
 
2021
2020
2019
Note
£m
£m
£
m
Cash flows from operating activities
 
 
 
 
Operating profit/(loss) before tax from continuing
operations
 
(1)
 
 
4,032
(481)
3,983
Operating profit before tax from discon
tinued operations
 
279
130
249
Adjustments for:
 
Impairment (releases)/losses
 
(1,335)
3,242
696
Amortisation of discounts and premiums of othe
r financial assets
 
203
267
255
Depreciation and amortisation
 
923
914
1,220
Change in fair value taken to profit or loss of ot
her financial assets
 
 
1,771
(1,474)
(280)
Change in fair value taken to profit or loss on o
ther financial liabilities and subordi
nated
liabilities
 
(1,083)
962
856
Elimination of foreign exchange diff
erences
 
2,446
(2,497)
949
Other non-cash items
 
(164)
(2)
(272)
Income receivable on other financial asse
ts
 
(581)
(518)
(854)
(Profit)/loss on sale of other financial
assets
 
 
 
(118)
(96)
22
(Profit)/loss on sale of subsidiarie
s and associates
 
(48)
16
(2,224)
Share of (profit)/loss of associates
 
(216)
30
14
Loss/(profit) on sale of other asse
ts and net assets/liabiltiies
 
23
(16)
(58)
Interest payable on MRELs and subordina
ted liabilities
 
964
1,182
1,151
Loss on sale of MRELs and subordinated liabilities
 
 
145
324
Charges and releases on provisions
 
478
296
1,243
Defined benefit pension schemes
 
215
215
188
Net cash flows from trading act
ivities
 
7,934
2,494
7,138
Decrease/(increase) in trading asse
ts
 
7,751
4,147
(659)
Decrease/(increase) in derivative assets
 
59,697
(16,173)
(16,680)
Decrease/(increase) in settlement balance
assets
 
156
2,090
(1,459)
(Increase)/decrease in loans to banks
 
(252)
(554)
3,563
Decrease/(increase) in loans to c
ustomers
 
2,721
(33,748)
(22,642)
(Increase)/decrease in other financial
assets
 
 
(128)
221
924
(Increase)/decrease in other asse
ts
 
(57)
8
707
Increase in assets of disposal groups
 
(9,015)
Increase/(decrease) in banks de
posits
 
5,673
113
(2,804)
Increase in customer deposits
 
48,071
62,492
8,333
(Decrease)/increase in settlement balance li
abilities
 
(350)
(1,652)
1,003
(Decrease)/increase in trading liabilities
 
 
(7,658)
(1,693)
1,599
(Decrease)/increase in derivative liabilities
 
(59,870)
13,826
17,982
Increase/(decrease) in other financial li
abilities
 
938
(1,085)
2,871
Increase/(decrease) in notes in circulation
 
392
546
(43)
Decrease in other liabilities
 
(1,463)
(1,723)
(2,634)
Changes in operating assets and liabili
ties
 
46,606
26,815
(9,939)
Income taxes paid
 
(856)
(214)
(278)
Net cash flows from operating activi
ties
(2)
 
 
53,684
29,095
(3,079)
 
For the notes to this table refer to the following pa
ge.
 
Consolidated ca
sh flow statem
ent for the year en
ded 31 D
ecember 202
1 continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
306
Financial statements
Strategic report
 
Governance
 
Risk and capital management
 
Additional
information
Financial review
 
 
 
2021
2020
2019
Note
£m
 
£m
£m
Cash flows from investing activities
 
Sale and maturity of other financial assets
 
16,859
25,952
19,990
Purchase of other financial assets
 
(10,150)
(18,825)
(21,345)
Income received on other financial assets
 
581
518
854
Net movement in business interests and intangible
assets
 
 
28
 
(3,489)
(70)
(84)
Sale of property, plant and equipment
 
165
348
428
Purchase of property, plant and equipmen
t
 
(901)
(376)
(559)
Net cash flows from investing activities
 
3,065
7,547
(716)
 
 
 
Cash flows from financing activities
 
Movement in MRELs
 
2,736
636
1,927
Movement in subordinated liabilities
 
(3,452)
(2,381)
(1,064)
Ordinary shares issued
 
 
17
Share cancellation
 
(1,806)
(2)
(21)
Dividends paid
 
(1,016)
(381)
(3,429)
Issue of paid-in equity
 
937
2,218
Net cash flows from financing
activities
 
(2,601)
90
(2,570)
Effects of exchange rate changes
on cash and cash equivalents
 
(2,641)
1,879
(1,983)
 
 
 
Net increase/(decrease) in cash and c
ash equivalents
 
51,507
38,611
(8,348)
Cash and cash equivalents at 1 January
 
 
139,199
100,588
108,936
Cash and cash
equivalents at 31
December
 
30
 
190,706
139,199
100,588
 
(1)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the
consolidated
financial statements.
(2)
Includes interest received of £9,696
mill
ion (2020 - £10,007 million, 2019 - £11,245
million) and interest paid of £1,668 million (2020 - £2,414 million, 2019 - £3,318 million).
 
The accompanying notes on pages 31
3 to 377, the Accounting policies on pages 307 to 312
and the audited sections of the
Financial review and Risk and capital man
agement sections on pages 84 to 95 and 1
88 to 285 form an integral part of these
financial statements.
 
 
Accounting
policies
NatWest Group
A
nnual Repor
t and Accou
nts 2021
307
Financial statements
Strategic report
 
Governance
 
Risk and capital management
 
Additional information
 
Financial review
 
This section includes the basis
of preparation of the financial statements and the significa
nt accounting policies used to prep
are the
financial statements.
Our accounting policies are the s
pecific principles, bases, conventions, rules, and pr
actices we apply in preparing and present
ing
the financial statements. Further information is provided
where judgment and estimation is ap
plied to critical accounting policie
s
and key sources of estimation unce
rtainty.
Future accounting developmen
ts details new or amendments to existing accounting s
tandards, when they are effective from and
where the NatWest Group is as
sessing their impact on future financial statemen
ts.
1. Presentation of financial statements
NatWest Group plc is incorporated in the UK a
nd registered in
Scotland. The financial statements are presen
ted in the
functional currency, pounds sterling.
NatWest Group plc’s consolidated financial s
tatements
incorporate the results of NatWest Group plc
and the entities it
controls. Control arises when NatWest Group plc has
the
power to direct the activities of an entity so as
to affect the
return from the entity. Control is
assessed by reference to our
ability to enforce our will on the other entity, typically th
rough
voting rights. The consolidated f
inancial statements are
prepared under consistent accountin
g policies.
Transactions and balances betwee
n Group companies are
eliminated in the consolidated financial statemen
ts to show only
those transactions and balances e
xternal to the NatWest
Group.
The audited financial statements are set out on pages 30
0 to
394 and the audited sections of Ris
k and capital management
on pages 97 to 285. The directors have pre
pared the financial
statements on a going concern basis after assess
ing the
principal risks, forecasts, projections and other
relevant
evidence over the twelve months f
rom the date the financial
statements are approved (see the Report of the directo
rs, page
183) and in accordance with UK adopted In
ternational
Accounting Standards (IAS), Internation
al Financial Reporting
Standards (IFRS) as issued by the Inte
rnational Accounting
Standards Board (IASB) and IFRS as adopted by the
European
Union. The significant accounting policies and rel
ated
judgments are set out below.
Except for certain financial instruments as described in
Accounting policies 10 and 15 and inves
tment property, the
financial statements are presen
ted on a historical cost basis.
Accounting policy changes effective 1 January 202
1.
The IASB amended IFRS 16 Leases with “COVI
D-19
amendments on lease modifications – A
mendments to IFRS 16
– Leases (IFRS 16)”. The ef
fect of the amendment on NatWest
Group’s financial statements is i
mmaterial.
2. Revenue recognition
Interest income and expense are
recognised in the income
statement using the effective interest
rate method for: all
financial instruments measured at
amortised cost, debt
instruments measured as fair value th
rough other
comprehensive income and the ef
fective part of any related
accounting hedging instrument
s. Finance lease income is
recognised at a constant periodic rate of return bef
ore tax on
the net investment on the lease. N
egative interest on financial
assets is presented in interest payable and neg
ative interest on
financial liabilities is presented in interest receiva
ble.
Other interest relating to financial instruments measu
red at fair
value is recognised as part of the movement in f
air value and is
reported in income from trading activities or other ope
rating
income as relevant. Fees in respect of services a
re recognised
as the right to consideration accrues through the pe
rformance
of each distinct service obligation to the custo
mer. The
arrangements are generally contractual and the cost of
providing the service is incurred as the service is
rendered. The
price is usually fixed and always determinable.
3. Discontinued operations, Held for sale and Disposal
group
The results of discontinued operations (co
mprising the post-tax
profit or loss of discontinued operations and t
he post-tax results
of either the ongoing measurement at fair v
alue less costs to
sell or disposal of the discontinued operation) a
re excluded
from the results of continuing operations and
are presented as
a single amount as profit/(loss) f
rom discontinued operations,
net of tax in the income statement. Compa
ratives are
represented for the income state
ment, cash flow statement,
statement of changes in equity and
related notes.
An asset or disposal group (assets and liabilities
) is classified as
held for sale if NatWest Group will recover its ca
rrying amount
principally through a sale transaction rathe
r than through
continuing use. These are measured at the lower of its
carrying amount or fair value less
cost to sell unless scoped out
of IFRS 5 in which case the existing measure
ment provisions of
IFRS apply. These are presented as single amounts,
comparatives are not represented.
4. Staff costs
Employee costs, such as salaries, paid absence
s, and other
benefits are recognised over the
period in which the employees
provide the related services to NatWest Group.
Employees may
receive variable compensation in cash, in defe
rred cash or debt
instruments of NatWest Group or in ordina
ry shares of
NatWest Group plc. NatWest Group operates a numbe
r of
share-based compensation schemes under which it
grants
awards of NatWest Group plc shares and share o
ptions to its
employees. Such awards are subject to vesting conditi
ons.
Variable compensation that is se
ttled in cash or debt
instruments is charged to the income statemen
t on a straight-
line basis over the period during which services are
provided,
taking account of forfeiture an
d clawback criteria. The value of
employee services received in exchange fo
r NatWest Group plc
shares and share options is recognised as an expense o
ver the
vesting period, subject to defer
ral. clawback and forfeiture
criteria with a corresponding increase in equity. The fai
r value
of the instruments granted is based on ma
rket prices at the
grant date.
Defined contribution pension scheme
A scheme where NatWest Grou
p pays fixed contributions and
there is no legal or constructive obligation to pay furthe
r
contributions or benefits. Contributions are
recognised in the
income statement as employee service costs acc
rue.
Defined benefit pension scheme
A scheme that defines the ben
efit an employee will receive on
retirement and is dependent on one or more f
actors such as
age, salary, and years of service
. The net of the recognisable
scheme assets and obligations is
reported on the balance sheet
in other assets or other liabilities. T
he defined benefit obligation
is measured on an actuarial bas
is. The charge to the income
statement for pension costs (m
ainly the service cost and the
net interest on the net defined
benefit asset or liability) is
recognised in operating expenses
.
Actuarial gains and losses (i.e.
gains and/or losses on re-
measuring the net defined ben
efit asset or liability due to
changes in actuarial measurement assumptions) a
re recognised
in other comprehensive income in full in the pe
riod in which
they arise, and not subject to re
cycling to the income
statement.
Accounting polici
es continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
308
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
The difference between scheme
assets and scheme liabilities,
the net defined benefit asset or liability, is
recognised on the
balance sheet if the criteria of the asse
t ceiling test are met.
This requires the net defined benef
it surplus to be limited to
the present value of any economic benefits a
vailable to
NatWest Group in the form of re
funds from the plan or reduced
contributions to it.
NatWest Group will recognise a
liability where a minimum
funding requirement exists for any of its defined benefit
pension
schemes. This reflects agreed minimum funding and
the
availability of a net surplus as d
etermined as described above.
When estimating the liability for minimum fundi
ng requirements
NatWest Group plc only include cont
ributions that are
substantively or contractually agreed and do not include
discretionary features, including dividend-linked co
ntributions
5. Intangible assets and goodwill
Intangible assets are identifiable
non-monetary assets without
physical substance acquired by NatWest G
roup are stated at
cost less accumulated amortisa
tion and impairment losses.
Amortisation is a method to spr
ead the cost of such assets over
time to the income statement. This
is charged to the income
statement over the assets' estimated useful e
conomic lives
using methods that best reflect the pattern of econo
mic
benefits. The estimated useful ec
onomic lives are:
Computer software
3 to 12 years
Other acquired intangibles
5 to 10 years
Expenditure on internally generated goodwill an
d brands is
charged to the income statement as incur
red.
Direct costs relating to the development of internal-use
computer software are reported on the bal
ance sheet after
technical feasibility and economic viability h
ave been
established. These direct costs include payroll, t
he costs of
materials and services, and dir
ectly attributable overheads.
Capitalisation of costs ceases when the softwa
re can operate
as intended.
During and after development, accumulated costs
are reviewed
for impairment against the ben
efits that the software is
expected to generate.
Costs incurred prior to the establishment of technic
al feasibility
and economic viability are expe
nsed to the income statement
as incurred, as are all training costs and gener
al overheads.
The costs of licences to use computer software
that are
expected to generate economic benef
its beyond one year are
also reported on the balance shee
t
Goodwill on the acquisition of a
subsidiary is the excess of the
fair value of the consideration paid, the fair value of
any
existing interest in the subsidiar
y and the amount of any non-
controlling interest measured ei
ther at fair value or at its share
of the subsidiary’s net assets ove
r the net fair value of the
subsidiary’s identifiable assets, l
iabilities, and contingent
liabilities.
Goodwill is measured at initial cost less
any subsequent
impairment losses. The gain or loss on the disposal of a
subsidiary includes the carrying value of any
related goodwill
when such transactions occur.
6. Impairment of non-financial ass
ets
At each balance sheet date, NatWest Grou
p assesses whether
there is any indication that its intangible assets or p
roperty,
plant and equipment are impaired. If any such in
dication exists,
NatWest Group estimates the recoverable amount of
the asset
and compares it to its balance s
heet value to calculate if an
impairment loss should be charged to the inco
me statement.
The balance sheet value of the asset is reduced by
the amount
of the impairment loss. A reversal of an impairment loss o
n
intangible assets or property, pl
ant and equipment is
recognised in the income statement pro
vided the increased
carrying value is not greater than it would have been h
ad no
impairment loss been recognised.
Goodwill is tested for impairment annually o
r more frequently if
events or changes in circumstances indicate that it mig
ht be
impaired. Impairment losses on
goodwill are not reversed
The recoverable amount of an asset that does not
generate
cash flows that are independent from those of othe
r assets or
groups of assets, is determined as part of the cash-gener
ating
unit to which the asset belongs. A cash-generati
ng unit is the
smallest identifiable group of asse
ts that generates cash inflows
that are largely independent of the cash inflows f
rom other
assets or groups of assets. For the purposes of
impairment
testing, goodwill acquired in a busines
s combination is allocated
to NatWest Group’s cash-generating units or groups
of cash-
generating units expected to be
nefit from the combination. The
recoverable amount of an asset or cash-generating u
nit is the
higher of its fair value less cost to sell or i
ts value in use. Value
in use is the present value of fu
ture cash flows from the asset
or cash-generating unit discounted at a rate t
hat reflects
market interest rates adjusted for risks specific to
the asset or
cash-generating unit that have not been considered in
estimating future cash flows.
7. Foreign currencies
Foreign exchange differences arising on the set
tlement of
foreign currency transactions and from the transla
tion of
monetary assets and liabilities are reported in income fr
om
trading activities except for differences
arising on cash flow
hedges and hedges of net investments in foreign ope
rations.
Non-monetary items denominated in foreign currencies
that
are stated at fair value are translated into the fu
nctional
currency at the foreign exchange rates ruling at the d
ates the
values are determined. Translation differences are recog
nised
in the income statement except for differences arisi
ng on non-
monetary financial assets classif
ied as fair value through other
comprehensive income.
Income and expenses of foreign subsidia
ries and branches are
translated into sterling at avera
ge exchange rates unless these
do not approximate the foreign e
xchange rates ruling at the
dates of the transactions. Foreign exchange differences a
rising
on the translation of a foreign
operation are recognised in
other comprehensive income. The amount accumulated in
equity is reclassified from equity to the income st
atement on
disposal of a foreign operation.
8. Provisions and contingent liabilities
NatWest Group recognises a provision for a p
resent obligation
resulting from a past event when it is more likely
than not that
it will be required to pay to settle
the obligation and the amount
of the obligation can be estimated reliably.
Provision is made for restructuri
ng costs, including the costs of
redundancy, when NatWest Group has a const
ructive
obligation. An obligation exists when NatWest
Group has a
detailed formal plan for the restructuring and h
as raised a valid
expectation in those affected either by s
tarting to implement
the plan or by announcing its main features.
NatWest Group recognises any onerous cost of
the present
obligation under a contract as
a provision. An onerous cost is
the unavoidable cost of meeting its contractu
al obligations that
exceed the expected economic benefits. When Na
tWest Group
intends to vacate a leasehold property o
r right of use asset, the
asset would be tested for impairment and a provisi
on may be
recognised for the ancillary contractual occupa
ncy costs, such
as rates.
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Contingent liabilities are possible obligations arising f
rom past
events, whose existence will be
confirmed only by uncertain
future events, or present obligations arising from pas
t events
that are not recognised because e
ither an outflow of economic
benefits is not probable, or the
amount of the obligation cannot
be reliably measured. Continge
nt liabilities are not recognised
but information about them is d
isclosed unless the possibility of
any outflow of economic benefits in settle
ment is remote.
9. Tax
Tax encompassing current tax
and deferred tax is recognised
in the income statement except when taxable items
are
recognised in other comprehensive income or equity. T
ax
consequences arising from servicing financial inst
ruments
classified as equity are recogni
sed in the income statement in
line with IAS 12.
Current tax is tax payable or re
coverable in respect of the
taxable profit or loss for the year arisin
g in the income
statement, other comprehensive income or equity. P
rovision is
made for current tax at rates enacted, or subs
tantively
enacted, at the balance sheet date.
Deferred tax is the tax expected to be
payable or recoverable
in respect of temporary difference
s between the carrying
amount of an asset or liability for accountin
g purposes and the
carrying amount for tax purposes. Defe
rred tax liabilities are
generally recognised for all taxable temporary diff
erences and
deferred tax assets are recogni
sed to the extent their recovery
is probable.
Deferred tax is not recognised
on temporary differences that
arise from initial recognition of an asset or
a liability in a
transaction (other than a busines
s combination) that at the time
of the transaction affects neither accounting nor taxa
ble profit
or loss. Deferred tax is calculat
ed using tax rates expected to
apply in the periods when the a
ssets will be realised or the
liabilities settled, based on tax rates and la
ws enacted, or
substantively enacted, at the b
alance sheet date.
Deferred tax assets and liabilities are offse
t where NatWest
Group has a legally enforceable right to offset
and where they
relate to income taxes levied by the same
taxation authority
either on an individual NatWest Group company
or on NatWest
Group companies in the same tax group th
at intend, in future
periods, to settle current tax liabilities an
d assets on a net basis
or on a gross basis simultaneous
ly.
Accounting for taxes is judgmental and c
arries a degree of
uncertainty because tax law is subject to inter
pretation, which
might be questioned by the rele
vant tax authority. NatWest
Group recognises the most likel
y current and deferred tax
liability or asset, assessed for unce
rtainty using consistent
judgments and estimates. Current and deferre
d tax assets are
only recognised where their recovery is deemed probable,
and
current and deferred tax liabilities are recognise
d at the
amount that represents the best estimate of the proba
ble
outcome having regard to their acceptance
by the tax
authorities.
10. Financial instruments
Financial instruments are meas
ured at fair value on initial
recognition on the balance sheet.
Monetary financial assets are classifie
d into one of the following
subsequent measurement categories (subject to busi
ness model
assessment and review of contractual cash flow for the
purposes of sole payments of p
rincipal and interest where
applicable):
amortised cost
measured at cost using the ef
fective interest
rate method, less any impairment allowance;
fair value through other compr
ehensive income (FVOCI)
measured at fair value, using the e
ffective interest rate
method and changes in fair valu
e through other
comprehensive income;
mandatory fair value through profit or loss (M
FVTPL)
measured at fair value and cha
nges in fair value reported in
the income statement; or
designated at fair value through profit or loss
(DFV)
measured at fair value and cha
nges in fair value reported in
the income statement .
Classification by business model refle
cts how NatWest Group
manages its financial assets to generate cash flows. A busi
ness
model assessment helps to asce
rtain the measurement
approach depending on whethe
r cash flows result from holding
financial assets to collect the contractual cash f
lows, from
selling those financial assets, or both.
Business model assessment of asse
ts is made at portfolio level,
being the level at which they are managed to achie
ve a
predefined business objective. T
his is expected to result in the
most consistent classification of assets because it aligns wi
th
the stated objectives for the portfolio, its risk
management,
manager’s remuneration and the ability to monit
or sales of
assets from a portfolio.
The contractual terms of a financial asset;
any leverage
features; prepayment and exte
nsion terms; and triggers that
might reset the effective rate of
interest; are considered in
determining whether cash flows
are solely payments of
principal and interest.
Certain financial assets may be designa
ted at fair value
through profit or loss (DFV) upon initial recognition if s
uch
designation eliminates, or significantly reduces
, accounting
mismatch
.
Equity shares are measured at fair value throug
h profit or loss
unless specifically ele
cted as at fair value through other
comprehensive income (FVOCI).
Upon disposal, the cumulative gains or losses
in fair value
through other comprehensive income reserve are
recycled to
the income statement for monetary asse
ts and non-monetary
assets (equity shares) the cumulative gains o
r losses are
transferred directly to retained e
arnings.
Regular way purchases of financ
ial assets classified as
amortised cost are recognised on the set
tlement date; all other
regular way transactions in fin
ancial assets are recognised on
the trade date.
Financial liabilities are classified
into one of following
measurement categories:
amortised cost
measured at cost using the ef
fective interest
rate method;
held for trading
measured at fair value and c
hanges in fair
value reported in income statement; or
designated at fair value through profit or loss
measured at
fair value and changes in fair value repo
rted in the income
statement except changes in fair value attributable to
the
credit risk component recognis
ed in other comprehensive
income when no accounting mismatch occurs.
11. Impairment: expected credit losses (ECL)
At each balance sheet date eac
h financial asset or portfolio of
financial assets measured at amortised cost or
at fair value
through other comprehensive income, issued fi
nancial
guarantee and loan commitment (other than those cl
assified as
held for trading) is assessed for impair
ment. Any change in
impairment is reported in the income statemen
t. Loss
allowances are forward-looking
, based on 12-month ECL
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where there has not been a significant increase in c
redit risk
rating, otherwise allowances are
based on lifetime expected
losses.
ECL are a probability-weighted e
stimate of credit losses. The
probability is determined by the risk of def
ault which is applied
to the cash flow estimates. In the
absence of a change in credit
rating, allowances are recognised when there is a
reduction in
the net present value of expected cash flows. Followin
g a
significant increase in credit risk, ECL a
re adjusted from 12
months to lifetime. This will lead to a higher impai
rment charge.
Judgment is exercised as follows:
Models
in certain low default portfolios, B
asel parameter
estimates are also applied for IFRS 9.
Non-modelled portfolios
,
mainly in Private Banking, RBSI
and Lombard, use a standardised capital requirement un
der
Basel II. Under IFRS 9, they have bespoke treatmen
ts for
the identification of significant increase in c
redit risk.
Benchmark PDs, EADs and LGDs are reviewed
annually for
appropriateness. The ECL calculation is based o
n expected
future cash flows, which is typic
ally applied at a portfolio
level.
Multiple economic scenarios (MES)
– the central, or base,
scenario is most critical to the ECL calcula
tion, independent
of the method used to generate a range of
alternative
outcomes and their probabilities
.
Significant increase in credit risk
-
IFRS 9 requires that at
each reporting date, an entity s
hall assess whether the
credit risk on an account has increased significa
ntly since
initial recognition. Part of this asse
ssment requires a
comparison to be made between the current
lifetime PD
(i.e. the current probability of def
ault over the remaining
lifetime) with the equivalent lifetime PD as deter
mined at
the date of initial recognition.
On restructuring where a financial asset is no
t derecognised,
the revised cash flows are used
in re-estimating the credit loss.
Where restructuring causes derecognition of the o
riginal
financial asset, the fair value of
the replacement asset is used
as the closing cash flow of the original asset.
Where in the course of the ord
erly realisation of a loan, it is
exchanged for equity shares or property, the exch
ange is
accounted for as the sale of the
loan and the acquisition of
equity securities or investment property. Where Na
tWest
Group’s acquired interest is in equity shares, relevan
t policies
for control, associates and joint ventures apply.
Impaired financial assets are written off and the
refore
derecognised from the balance shee
t when NatWest Group
concludes that there is no longer any
realistic prospect of
recovery of part, or all, of the loan. For fin
ancial assets that are
individually assessed for impairment,
the timing of the write-off
is determined on a case-by-cas
e basis. Such financial assets
are reviewed regularly and write
-off will be prompted by
bankruptcy, insolvency, re-neg
otiation, and similar events.
The typical time frames from initial impair
ment to write-off for
NatWest Group’s collectively assess
ed portfolios are:
Retail mortgages: write-off usually occurs within five ye
ars,
or earlier, when an account is clos
ed, but can be longer
where the customer engages constructively;
Credit cards: the irrecoverable amount is typically w
ritten
off after twelve arrears cycles or at four years pos
t default
any remaining amounts outstanding are wri
tten off;
Overdrafts and other unsecured loans: write-off occurs
within six years;
Commercial loans: write-offs are
determined in the light of
individual circumstances; and Busines
s loans are generally
written off within five years.
12. Derecognition
A financial asset is derecognised (removed f
rom the balance
sheet) when the contractual right to receive cash flows f
rom
the asset has expired or when it has been transfer
red and the
transfer qualifies for derecognition. Conve
rsely, an asset is not
derecognised in a contract under which N
atWest Group retains
substantially all the risks and rewards of owne
rship.
A financial liability is removed from the balance s
heet when the
obligation is paid, or is cancelled, or expires. Cance
llation
includes the issuance of a substitute inst
rument on substantially
different terms.
13. Netting
Financial assets and financial li
abilities are offset, and the net
amount presented on the balance
sheet when, and only when,
NatWest Group currently has a
legally enforceable right to set
off the recognised amounts and it intends eithe
r to settle on a
net basis or to realise the asset and settle the li
ability
simultaneously. NatWest Group is party to a nu
mber of
arrangements, including master netting
agreements, that give it
the right to offset financial assets and financi
al liabilities, but
where it does not intend to settle
the amounts net or
simultaneously, the assets and liabilities conce
rned are
presented separately on the ba
lance sheet.
14. Capital instruments
NatWest Group classifies a fina
ncial instrument that it issues as
a liability if it is a contractual obligation to delive
r cash or
another financial asset, or to exchange financi
al assets or
financial liabilities on potentially unfavourable ter
ms and as
equity if it evidences a residual interest in the
assets of NatWest
Group after the deduction of liabilities. Inc
remental costs and
related tax that are directly attributable to an e
quity
transaction are deducted from equity.
The consideration for any ordin
ary shares of NatWest Group
plc purchased by NatWest Group (known as
treasury shares or
own shares held) is deducted from equity. On the cancell
ation
of treasury shares their nominal value is removed fr
om equity
and any excess of consideration over nominal value i
s treated
in accordance with the capital maintena
nce provisions of the
Companies Act 2006.
On the sale or re-issue of treasu
ry shares the consideration
received and related tax are cre
dited to equity, net of any
directly attributable incremental costs.
15. Derivatives and hedging
Derivatives are reported on the balance she
et at fair value.
NatWest Group uses derivative
s as part of its trading activities,
to manage its own risk such as i
nterest rate, foreign exchange,
or credit risk or in certain custo
mer transactions. Not all
derivatives used to manage risk are in he
dge accounting
relationships (an IFRS method to reduce accoun
ting mismatch
from changes in the fair value of the derivatives repo
rted in the
income statement).
Gains and losses arising from changes in the fai
r value of
derivatives that are not in hedge relationships are reco
gnised in
the income statement in Income f
rom trading activities except
for gains and losses on those d
erivatives that are managed
together with financial instruments designated a
t fair value;
these gains and losses are included in Othe
r operating income.
Hedge accounting
NatWest Group enters into three
types of hedge accounting
relationships (see later)). Hedge accounting
relationships are
designated and documented at inception in line with t
he
requirements of IAS 39 Financi
al instruments – Recognition and
Measurement. The documentation identifies the
hedged item,
the hedging instrument and details of the risk
that is being
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hedged and the way in which eff
ectiveness will be assessed at
inception and during the period of
the hedge.
Fair value hedge
- the gain or loss on the hedging instrumen
t
and the hedged item attributable to the hedged risk is
recognised in the income statement.
Where the hedged item is
measured at amortised cost, the balance sheet
amount of the
hedged item is also adjusted.
Cash flow hedge
- the effective portion of the design
ated hedge
relationship is recognised in other comprehensive inco
me and
the ineffective portion in the in
come statement. When the
hedged item (forecasted cash flows) results in the
recognition
of a financial asset or financial liability, the cumul
ative gain or
loss is reclassified from equity to the income s
tatement in the
same periods in which the hedged forecas
ted cash flows affect
the income statement.
Hedge of net investment in a foreign operation
-
In the hedge
of a net investment in a foreign
operation, the effective portion
of the designated hedge relationship is recognise
d in other
comprehensive income. Any ine
ffective portion is recognised in
profit or loss. Non-derivative financial li
abilities as well as
derivatives may be designated as a hedging instrument
in a net
investment hedge.
Discontinuation of hedge accounting
Hedge accounting is discontinue
d if the hedge no longer meets
the criteria for hedge accounting i.e. the hedge is n
ot highly
effective in offsetting changes in f
air value or cash flows
attributable to the hedged risk, consistent with
the documented
risk management strategy; the he
dging instrument expires or is
sold, terminated or exercised; or if hedge design
ation is
revoked.
For fair value hedging any cumulative adjust
ment is amortised
to the income statement over t
he life of the hedged item.
Where the hedge item is no longer on the balance sheet
the
adjustment to the hedged item is reported in
the income
statement.
For cash flow hedging the cum
ulative unrealised gain or loss is
reclassified from equity to the income statemen
t when the
hedged cash flows occur or, if the forecast transac
tion results
in the recognition of a financial
asset or financial liability, when
the hedged forecast cash flows affec
t the income statement.
Where a forecast transaction is no longer expected to occu
r,
the cumulative unrealised gain or loss is reclassified fro
m equity
to the income statement immediately.
For net investment hedging on disposal or partial disposal
of a
foreign operation, the amount accumulated in equi
ty is
reclassified from equity to the income statemen
t.
16. Investment in Group undertakings
NatWest Group plc’s investmen
ts in its Group undertakings
(subsidiaries) are stated at cost less
any impairment.
Critical accounting policies and key sources of estimation
uncertainty
The reported results of NatWest Group are sensiti
ve to the
accounting policies, assumptions and esti
mates that underlie
the preparation of the financial s
tatements. The accounting
standards used in the preparati
on of the financial statements
(see presentation of financial statemen
ts above) require the
directors, in preparing NatWest Group's financial s
tatements, to
select suitable accounting policies
, apply them consistently and
make judgments and estimates that are reas
onable and
prudent. In the absence of accounting guid
ance, standards
used in the preparation of the fi
nancial statements require the
directors to develop and apply an accounting policy t
hat results
in relevant and reliable information in the ligh
t of the
requirements and guidance in IFRS de
aling with similar and
related issues and the IASB's ’Conceptual F
ramework for
Financial Reporting’.
The judgments and assumptions involved in NatWes
t Group's
accounting policies that are considered by
the Board to be the
most important to the portrayal of
its financial condition are
noted below. The use of estimates, assumptions o
r models that
differ from those adopted by NatWest G
roup would affect its
reported results. Estimation unce
rtainty continues to be
affected by the COVID-19 pandemic. The
COVID-19 pandemic
continued to cause significant economic and soci
al disruption
during 2021. Key financial estimates are b
ased on
management's latest five-year revenue an
d cost forecasts.
Measurement of goodwill, deferred tax and expected c
redit
losses are highly sensitive to reasonably possible cha
nges in
those anticipated conditions. Other reasona
bly possible
assumptions about the future inc
lude a prolonged financial
effect of the COVID-19 pandemic on the economy of the U
K
and other countries or greater economic effe
ct as countries
and companies implement plans to counter climate
risks.
How Climate risk affects our accounting judgments and
estimates
NatWest Group makes use of reasonable
and supportable
information to make accounting judg
ments and estimates. This
includes information about the observable ef
fects of the
physical and transition risks of c
limate change on the current
creditworthiness of borrowers, asset values and
market
indicators. It also includes the eff
ect on NatWest Group’s
competitiveness and profitability. Many of the effe
cts arising
from climate change will be longer term in nature, with
an
inherent level of uncertainty
,
and
have limite
d
effect on
accounting judgments and estimates
for the current period
.
Some physical and transition risk
s can manifest in the shorter
term. The following items represe
nt the most significant effects:
The classification of financial instruments linked to clim
ate,
or other sustainability indicators: consideration is given t
o
whether the effect of climate related terms preven
t the
instrument cashflows being sole
ly payments of principal and
interest.
The measurement of expected
credit loss considers the
ability of borrowers to make pay
ments as they fall due.
Future cashflows are discounte
d, so long dated cashflows
are less likely to affect current expectations on credi
t loss.
NatWest Group’s assessment of s
ector specific risks, and
whether additional adjustments are required, inclu
de
expectations on the ability of those
sectors to meet their
financing needs in the market. Changes in c
redit
stewardship and credit risk appetite that s
tem from climate
considerations, such as oil and gas, will directly
affect our
positions.
The assessment of asset impairment
and deferred tax are
based upon value in use. This represents the value of f
uture
cashflows and uses the Group’
s five-year forecast and the
expectation of long term economic g
rowth beyond this
period. The five-year forecast takes account of
management’s current expectations on co
mpetitiveness
and profitability, including near term effects of cli
mate
transition risk. The long term growth rate refle
cts external
indicators which will include market expectations o
n climate
risk. NatWest Group did not consider any additional
adjustments to this indicator.
The use of market indicators as i
nputs to fair value is
assumed to include current information an
d knowledge
regarding the effect of climate risk.
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Changes in judgments and assumptions could
result in a
material adjustment to those es
timates in the next reporting
periods. Consideration of this source of e
stimation uncertainty
has been set out in the notes below (as applic
able).
Critical accounting policy
Note
Deferred tax
7
Fair value
-
financial instruments
11
Loan impairment provisions
15
Goodwill
17
Provisions for liabilities and charges
21
Future accounting developments
International Financial Reporting Standards
Effective 1 January 2022
Onerous Contracts – Cost of Fulf
illing a Contract
(Amendments to IAS 37);
Property, Plant and Equipment: Proceeds before
Intended
Use (Amendments to IAS 16);
Reference to Conceptual Framework (A
mendments to IFRS
3); and
Fees in the “10 per cent” test for Derecognition of
Financial
Liabilities (Amendments to IFRS 9
).
Other new standards and amendments that
are effective for
annual periods beginning after 1 January 20
23, with earlier
application permitted, are set out below.
Effective 1 January 2023
IFRS 17 Insurance Contracts (Amend
ments to IFRS 17
Insurance Contracts);
Classification of Liabilities as Current or Non-cu
rrent
(Amendments to IAS 1);
Deferred Tax related to Assets
and Liabilities arising from a
Single Transaction (Amendmen
ts to IAS 12);
Definition of Accounting Estimates
(Amendments to IAS 8);
and
Disclosure of Accounting Policie
s (Amendments to IAS 1
and IFRS Practice Statement 2).
NatWest Group is assessing the e
ffect of adopting these
standards and amendments on its f
inancial statements but does
not expect the effect to be material.
Notes to
the consolidate
d financial statem
ents
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1 Net interest income
Net interest income is the differe
nce between the interest NatWest Group earns from its inte
rest-bearing assets, such as loa
ns,
balances with central banks and other financial assets,
and the interest paid on its interest-b
earing liabilities, such as deposits and
subordinated liabilities.
Interest receivable on financial instruments cl
assified as amortised cost, debt instruments clas
sified as FVOCI and the interest
element of the effective portion of
any designated hedging relationships are measured usi
ng the effective interest rate, which
allocates the interest receivable or interest p
ayable over the expected life of the financi
al instrument at the rate that exactly
discounts all estimated future cash flows to e
qual the financial instrument's initial ca
rrying amount. Calculation of the effec
tive
interest rate takes into account fee
s payable or receivable that are an integral part of the fin
ancial instrument’s yield, premiums or
discounts on acquisition or issue, early redemption fe
es and transaction costs. All contractual terms of
a financial instrument are
considered when estimating future cash flows. Neg
ative interest on financial
assets is present
ed in interest payable and negative
interest on
financial liabilities is
presented in interest receivable.
Included
in
interest
receivable
is
finance
lease
income
which
is
recognised
at
a
constant
p
eriodic
rate
of
retur
n
before
tax
on
the
net investment.
For accounting policy information se
e Accounting policies note 2.
2021
2020 (1)
2019 (1)
Continuing operations
£m
£m
£m
Balances at central banks
99
90
321
Loans to banks - amortised cost
346
246
405
Loans to customers - amortised cost
8,615
8,979
9,547
Other financial assets
253
483
854
Interest receivable
9,313
9,798
11,127
Balances with banks
204
144
319
Customer deposits
556
911
1,256
Other financial liabilities
670
846
1,102
Subordinated liabilities
267
402
483
Internal funding of trading business
es
2
19
168
Interest payable
1,699
2,322
3,328
Net interest income
7,614
7,476
7,799
(1)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8.
Notes to the c
onsolidated fi
nancial statement
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2 Non-interest income
There are three main categories
of non-interest income: net fees and commissions, inc
ome from trading activities, and other
operating income.
Net fees and commissions is the diffe
rence between fees received from customers for se
rvices provided by Natwest Group, s
uch as
credit card annual fees, mortgage arrangemen
t fees, underwriting fees, payment ser
vices, brokerage fees, trade finance,
investment management fees, trustee and fiducia
ry services, and fees incurred in the provisio
n of those services, such as credit
card interchange fees, custome
r incentives, loan administration, foreign currency
transaction charges, brokerage fees
, and
mortgage valuation reports.
Income from trading activities is earned from shor
t-term financial assets and financial liabilitie
s to either make a spread between
purchase and sale price or held to take advantage
of movements in prices and yie
lds.
Other operating income includes revenue from othe
r operating activities which are not related to the principal
activities of the
company, such as share of profit or loss f
rom associate, operating lease income, the profit or l
oss on the sale of a subsidiary or
property, plant and equipment, profit or loss on own debt,
and changes in the fair value of fin
ancial assets and liabilities designated
at fair value through profit or loss
.
For accounting policy information se
e Accounting policies note 2.
2021
2020 (1)
2019 (1)
Continuing operations
£m
£m
£m
Net fees and commissions
(2)
2,124
2,000
2,497
Income from trading activities
Foreign exchange
364
569
448
Interest rate
(130)
541
532
Credit
83
3
32
Changes in fair value of own de
bt and derivative liabilities attributable to own cre
dit risk
- debt securities in issue
6
(24)
(60)
-
derivative liabilities
(20)
Equities, commodities and other
36
323
1,125
932
Other operating income
Loss on redemption of own debt
(145)
(324)
Operating lease and other rental income
225
232
250
Changes in fair value of financial assets and liabilities des
ignated at fair value
(8)
(54)
(17)
through profit or loss
(3)
Changes in fair value of other financial asse
ts at fair value through profit or loss
(4)
5
2
58
Hedge ineffectiveness
25
24
48
(Loss)/profit on disposal of amortised cost assets
(15)
(18)
42
Profit/(loss) on disposal of fair value through othe
r comprehensive income assets
117
96
(22)
(Loss)/profit on sale of property, plant and equip
ment
(5)
(30)
13
58
Share of profits/(losses) of associated en
tities
216
(30)
(14)
Profit/(loss) on disposal of subsidiaries and associates
(6)
48
(16)
2,224
Other income
(7,8)
13
(18)
132
451
(93)
2,759
2,898
3,032
6,188
(1)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8.
(2)
Refer to Note 4 for further analysis.
(3)
Including related derivatives
.
(4)
Includes instruments that hav
e failed Solely payments of principal and interest testing under IFRS 9.
(5)
Includes £44 million loss on the purchase of freeholds for propert
ies where the Group was the primary leaseholder.
(6)
2019 includes a gain of £444 million (€523
mil
lion), a legacy liability release
of £256 million and an FX recycling gain of £290 million on completion of the Alawwal bank merger in
June 2019; In 2019, £1,102 million of FX recycling gains arising on the liquidation of R
FS Holdings BV and £67 millio
n in relat
ion to a capital repayment by UBIDAC. The recycling
gains and capital repayment have been calculated
using the step-by-step method in IFRIC 16 and by reference to the proportion of equity applied to the FX translation reserve.
(7)
Includes income from activities
other than banking.
(8)
2020 includes £58 million loss on a
cquisition of a £3.0 billion prime UK mortgages portfolio from Metro Bank plc.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
315
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
3 Operating expenses
Operating expenses are expenses N
atWest Group incurs for operation of the business such a
s salaries, bonus awards, pension
costs, depreciation and other a
dministrative expenses. Operating expenses a
re expenses NatWest Group incurs in the runni
ng of
the business such as all personnel expenditure (fo
r example salaries, bonus awards, pension
costs and social security costs),
premises and equipment costs (that
arise from the occupation of premises and the use
of equipment), depreciation and
amortisation and other adminis
trative expenses.
For accounting policy information se
e Accounting policies note 4.
2021
2020 (1)
2019 (1)
Continuing operations
£m
£m
£m
Salaries
2,295
2,494
2,477
Bonus awards
267
232
299
Temporary and contract costs
240
258
401
Social security costs
300
316
296
Pension costs
354
340
301
-
defined benefit schemes (see
Note 5)
215
215
188
- defined contribution schemes
139
125
113
Other
220
238
202
Staff costs
3,676
3,878
3,976
Premises and equipment
(2)
1,133
1,222
1,258
UK bank levy
(3)
99
167
134
Depreciation and amortisation
(4,5)
923
913
1,218
Other administrative expenses
(6)
1,927
1,678
2,694
Administrative expenses
4,082
3,980
5,304
7,758
7,858
9,280
(1)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8.
(2)
2021 includes cost of £33 million including accelerated d
epreciation of £41 million (2020 - £144 million including £71 million accelerated depreciation; 2019 - £161 million including
£40 million accelerated depreciation) in relation to the planned red
uction of the property portfolio (2021 – freehold £3 million; leasehold £30 million; 2020 - freehold £1 million;
leasehold £143 million; 2019 – freehold £4 million; leasehold £15
7 millio
n).
(3)
2019 includes a rebate
of £31 mill
ion relating t
o prior periods.
(4)
2021 includes a £58 million charge relating to t
he reduction in property portfolio, leasehold £48 million and freehold £10 million (2020 - £107 million charge, leasehold £86 million and
freehold £21 million; 2019 - £287 million charge, leasehold £37 million and freeh
old £250 million).
(5)
Includes impairment of goodwill of £85 million.
(6)
Includes litigation and conduct
costs, net of amounts recovered. Refer to Notes 21 and 27 for further details.
The average number of persons e
mployed, rounded to the nearest hundred, during the yea
r, excluding temporary staff, was
59,200 (2020 - 61,4
00; 2019 - 64,200). The average number of temporary employee
s during 2021 was 2,500 (20
20 – 3,200; 2019 -
4,100).
The number of persons employe
d at 31 December, excluding temporary staff, by re
portable segment, was as follows:
Continuing operatio
ns
2021
2020
2019
Retail Banking
15,800
17,200
19,600
Private Banking
1,900
1,900
1,700
Commercial Banking
8,400
9,700
9,700
RBS International
1,400
1,500
1,600
NatWest Markets
1,600
2,100
5,000
Central items & other
27,000
24,900
22,600
Ulster Bank RoI
(1)
1,700
1,900
2,000
Total
57,800
59,200
62,200
UK
40,600
42,500
44,600
USA
300
300
400
India
13,500
13,200
13,500
Poland
1,400
1,200
1,300
Republic of Ireland
1,200
1,400
1,500
Rest of the World
800
600
900
Total
57,800
59,200
62,200
(1)
Total number of persons employe
d in Ulster Bank RoI of 2,400 (202
0 – 2,600; 2019 – 2,700) includes 700 people employed
in
discontinued operations at 31 December 2021 (20
20 – 700; 2019 – 700
).
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
316
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
3 Operating expenses continued
Share-based payments
As described in the Remunerati
on report, NatWest Group grants share-based awards to em
ployees principally on the followi
ng
bases:
Award plan
Eligible employees
Nature of award
Vesting
conditions (1)
Settlement
Sharesave
UK, Channel Islands,
Gibraltar, Isle of Man,
Poland and India.
Option to buy shares
under employee savings
plan
Continuing employment or
leavers in certain circumstances
2022 to 2026
Deferred performance
awards
All
Awards of ordinary shares
and conditional shares
Continuing employment or
leavers in certain circumstances
2022 to 2028
Long-term incentives
(2)
Senior employees
Awa
rds of ordinary shares
and conditional shares
Continuing employment or
leavers in certain circumstances
and/or satisfaction of the pre-
vest assessment and underpins
2022 to 2028
(1)
All awards have vesting conditions which
may not be met.
(2)
Long-term incentives include buy-out awa
rds offered to compensate certain new hires for the loss of forfeited awards from their previous employment. All awards are granted
under the Employee Share Plan.
The fair value of Sharesave options grante
d in 2021 was determined using a pricing
model that included: expected volatility of
shares determined at the grant date based on histo
rical volatility over a period of up to five ye
ars; expected option lives that equal
the vesting period; expected dividends on equi
ty shares; and risk-free interest rates determin
ed from UK gilts with terms matching
the expected lives of the options.
The exercise price of options and the fair value on g
ranting awards of fully paid shares is th
e average market price over the f
ive
trading days (three trading days for Sharesave) precedi
ng grant date. When estimating the fa
ir value of the award, the numbe
r of
shares granted, and the prevailing market price (as defi
ned on pages 146-147
) are used. The fair value of the award is recognised
as services are provided over t
he vesting period.
Sharesave
2021
2020
20
19
Average
Shares
Average
Shares
Average
Shares
exercise price
under option
exercise price
under option
exercise price
under
option
£
(million)
£
(million)
£
(million)
At 1 January
1.64
96
2.01
84
2.18
75
Granted
1.80
24
1.12
35
1.78
25
Exercised
1.76
(10)
1.83
2.83
(4)
Cancelled
2.02
(15)
2.20
(23)
2.25
(12)
At 31 December
1.61
95
1.64
96
2.01
84
Options are exercisable within six months of vesti
ng; 6.0 million options were exercisable at 3
1 December 2021 (2020 – 6.3
million;
2019 – 3.2 million). The weighted average share p
rice at the date of exercise of options was
£2.19 (2020 - £1.57; 2019
- £2.49). At
31 December 2021, exercise price
s ranged from £1.12 to £2.27 (2020
- £1.12 to £2.27; 2019 - £1.68 to £2.91
) and the remaining
average contractual life was 2.1
years (2020 - 2.3 years; 2019 – 2.7 y
ears). The fair value of options granted in 2021
was £17
million (2020 - £8 million; 2019 - £11 million).
Deferred performance awards
2021
2020
20
19
Value at
Shares
Value at
Shares
Value at
Shares
grant
awarded
grant
awarded
grant
awarded
£m
(million)
£m
(million)
£m
(million)
At 1
January
169
77
196
76
233
92
Granted
61
32
109
67
110
42
Forfeited
(10)
(5)
(5)
(2)
(10)
(4)
Vested
(88)
(
39)
(131)
(
64)
(137)
(54)
At 31 December
132
65
169
77
196
76
The awards granted in 2021 ve
st in equal tranches on their anniversaries, predominan
tly over three years.
Long
-
term incentives
2021
2020
2019
Value at
Shares
Options
Value at
Shares
Options
Value at
Shares
Options
grant
awarded
over shares
grant
awarded
over shares
grant
awarded
over
shares
£m
(million)
(million)
£m
(million)
(million)
£m
(million)
(million)
At 1 January
50
24
63
25
85
32
2
Granted
6
3
14
10
15
6
Vested/exercised
(12)
(6)
(17)
(7)
(12)
(4)
Lapsed
(10)
(4)
(25)
(9)
(2)
At 31 December
44
21
50
24
63
25
The market value of awards vested/exercised in 202
1 was £13 million (2020 - £13 million; 2019
- £10 million). There are no vested
options of shares exercisable up to 2022
(2020 - nil; 2019 - nil).
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
317
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
3 Operating expenses continued
Bonus awards
The following tables analyse NatWest Group's bonus
awards for 2021.
2021
2020
Cha
nge
£m
£m
%
Non-deferred cash awards
(1)
38
35
9%
Deferred cash awards
214
111
93%
Deferred share awards
49
60
(18%)
Total deferred bonus awards
263
171
54%
Total bonus awards
(2)
301
206
46%
Bonus awards as a % of operating profit before tax
(3)
7%
(83%)
Proportion of bonus awards that are defe
rred
87%
83%
of which
- deferred cash awards
81%
65%
-
deferred share awards
19%
35%
Reconciliation of bonus awards t
o income statement charge
2021
2020
2019
£m
£m
£m
Bonus awarded
301
206
307
Less: deferral of charge for amounts a
warded for current year
(99)
(77)
(110)
Income statement charge for amoun
ts awarded in current year
202
129
197
Add: current year charge for amounts deferred f
rom prior years
80
114
127
Less: forfeiture of amounts deferred from
prior years
(15)
(11)
(25)
Income statement charge for amoun
ts deferred from prior years
65
103
102
Income statement charge for bonus aw
ards
(2)
267
232
299
(1)
Non-deferred cash awards a
re limi
ted to £2
,000 for all employees.
(2)
Excludes other performance related
compensation.
(3)
Operating profit before tax and bonus
expense.
Actual
Expected
Year in which income statement charge is expected to
be taken for deferred bonus awards
20
23
2019
2020
2021
2022
and beyond
£m
£m
£m
£m
£m
Bonus awards deferred from 20
19 and earlier
127
114
28
11
6
Bonus awards deferred from 20
20
52
8
7
Less: forfeiture of amounts deferred from
prior years
(25)
(
11)
(15)
Bonus awards for 2021 defe
rred
86
13
102
103
65
105
26
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
318
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
4 Segmental analysis
NatWest Group analyses its per
formance between the different operating s
egments of the Group. Ulster Bank RoI is presente
d
separately from the Go-forward group (refe
r to the split below) to reflect the strategic
decision on the phased withdrawal from the
Republic of Ireland announced in Februa
ry 2021. This is consistent with internal f
inancial reporting and how senior manageme
nt
assesses the performance of each ope
rating segment.
The directors manage NatWest Group p
rimarily by class of business
and present the segmental analysis on that basis. This in
cludes
the review of net interest income for each class of busines
s. Interest receivable and payable f
or all reportable segments is therefore
presented net. Segments charge
market prices for services rendered between each othe
r; funding charges between segments are
determined by NatWest Group Treasury, h
aving regard to commercial demands. The segme
nt performance measure is operating
profit/(loss).
Reportable operating segments:
The reportable operating segments are as follows:
Retail Banking
serves personal
customers in the UK and includes Uls
ter Bank customers.
Private Banking
serves UK-connected high net worth individu
als and their business interests.
Commercial Banking
serves start-up, SME, commercial, corporate an
d institutional customers in the UK.
RBS International (RBSI)
serves retail, commercial, an
d corporate customers in the Channel I
slands, Isle of Man and Gibraltar, and
financial institution clients in th
ose same locations in addition to the UK and Lu
xembourg.
NatWest Markets (NWM)
helps NatWest Group’s corporate and institutional cust
omers manage their financial
risks safely and
achieve their short-term and long-term sustain
able financial goals.
Central items & other
includes corporate functions, s
uch as NatWest Group Treasury, financ
e, risk management, compliance
,
legal, communications and human resources. Ce
ntral functions manages NatWest Group ca
pital resources and NatWest Group-
wide regulatory projects and provides se
rvices to the reportable se
gments. Balances in relation to litigation issues and the
international private banking business
are included in Central items in the relevant periods.
Ulster Bank RoI
serves individu
als and businesses in the Republic of Irel
and (RoI).
Allocation of central balance sheet items
NatWest Group allocates all ce
ntral costs relating to Services and Functions to the business u
sing
appropriate drivers; these
are
reported as indirect costs in the se
gmental income statements. Assets and risk-weighted asse
ts held centrally, mainly relating to
NatWest Group Treasury, are allocated to the busine
ss using appropriate drivers
.
Go-forward group
Total
Central
ex
cluding
Retail
Private
Commercial
RBS
NatWest
items
Ulster
Ulster
Banking
Banking
Banking
International
Markets
& other
Bank RoI
Bank RoI
Tota
l
2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
Continuing operations
Net interest income
4,074
480
2,582
383
9
(14)
7,514
100
7,614
Net fees and commissions
377
258
1,158
124
158
(16)
2,059
65
2,124
Other non-interest income
(6)
78
135
41
248
215
711
63
774
Total income
4,445
816
3,875
548
415
185
10,284
228
10,512
Depreciation and amortisation
(85)
(146)
(13)
(14)
(665)
(923)
(923)
Other operating expenses
(2,428)
(520)
(2,208)
(229)
(1,147)
179
(6,353)
(482)
(6,835)
Impairment releases
36
54
1,073
52
35
1,250
28
1,278
Operating profit/(loss)
1,968
350
2,594
358
(711)
(301)
4,258
(
226)
4,032
2020
(2)
Continuing operations
Net interest income
3,868
489
2,740
371
(57)
(57)
7,354
122
7,476
Net fees and commissions
379
257
1,110
94
99
(16)
1,923
77
2,000
Other non-interest income
(66)
17
108
32
1,081
(163)
1,009
23
1,032
Total income
4,181
763
3,958
497
1,123
(236)
10,286
222
10,508
Depreciation and amortisation
(8)
(149)
(17)
(16)
(723)
(913)
(
913)
Other operating expenses
(2,540)
(
447)
(2,281)
(274)
(1,294)
332
(6,504)
(441)
(
6,945)
Impairment losses
(792)
(100)
(
1,927)
(107)
(40)
(
26)
(2,992)
(139)
(
3,131)
Operating profit/(loss)
849
208
(399)
99
(227)
(653)
(123)
(358)
(
481)
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
319
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
4 Segmental analysis continu
ed
Go
-
forward group
Total
Central
excluding
Retail
Private
Commercial
RBS
NatWest
items
Ulster
Ulster
Banking
Banking
Banking
Interna
tional
Markets
&
other
(1)
Bank RoI
Bank RoI
Total
2019
(2)
£m
£m
£m
£m
£m
£m
£m
£m
£m
Continuing operations
Net interest income
4,130
521
2,842
478
(188)
(136)
7,647
152
7,799
Net fees and commissions
696
226
1,312
106
85
(23)
2,402
95
2,497
Other non-interest income
40
30
164
26
1,445
1,932
3,637
54
3,691
Total income
4,866
777
4,318
610
1,342
1,773
13,686
301
13,987
Depreciation and amortisation
(4)
(142)
(10)
(12)
(1,050)
(1,218)
(1,218)
Operating expenses
(3,618)
(482)
(2,458)
(254)
(1,406)
666
(7,552)
(510)
(8,062)
Impairment losses
(393)
6
(391)
(2)
51
(1)
(
730)
6
(724)
Operating profit/(loss)
855
297
1,327
344
(25)
1,388
4,186
(203)
3,983
(1)
2019 predominantly related to st
rategic disposals in Functions
.
(2)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8.
Total revenue
(2)
Go
-
forward group
Total
Central
excluding
Ulster
Retail
Private
Commercial
RBS
NatWest
items &
Ulster
Bank
Banking
Banking
Banking
International
Markets
Other
Bank RoI
RoI
Total
Year ended 31 D
ecember 2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
Continuing operations
External
5,419
792
3,751
594
823
1,109
12,488
297
12,785
Inter-segmental
14
127
87
6
30
(265)
(
1)
1
Total
5,433
919
3,838
600
853
844
12,487
298
12,785
Year ended 31 December 2020 (1)
Continuing operations
External
5,386
702
3,734
505
1,984
961
13,272
280
13,552
Inter-segmental
39
163
64
3
13
(284)
(
2)
2
Total
5,425
865
3,798
508
1,997
677
13,270
282
13,552
Year ended 31 December 2019 (1)
Continuing operations
External
6,161
703
4,347
639
2,516
3,447
17,813
350
18,163
Inter-segmental
62
241
139
19
558
(1,025)
(6)
6
Total
6,223
944
4,486
658
3,074
2,422
17,807
356
18,163
(1)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8.
(2)
Total revenue comprises interest receivable, fees and commissions receivab
le, income from trading activities and other operating income.
Total income
Go
-
forward group
Total
Central
excluding
Retail
Private
Commercial
RBS
NatWest
items &
Ulster
Ulster
Banking
Banking
Banking
International
Markets
Other
Bank RoI
Bank RoI
Total
Year ended 31 D
ecember 2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
Continuing operations
External
4,433
801
3,939
548
554
10,275
237
10,512
Inter-segmental
12
15
(64)
(139)
185
9
(9)
Total
4,445
816
3,875
548
415
185
10,284
228
10,512
Year ended 31 December 2020
(1)
Continuing operations
External
4,157
700
4,065
500
1,395
(537)
10,280
228
10,508
Inter-segmental
24
63
(
107)
(3)
(272)
301
6
(6)
Total
4,181
763
3,958
497
1,123
(236)
10,286
222
10,508
Year ended 31 December 2019 (1)
Continuing operations
External
4,834
631
4,814
603
1,664
1,145
13,691
296
13,987
Inter-segmental
32
146
(
496)
7
(322)
628
(5)
5
Total
4,866
777
4,318
610
1,342
1,773
13,686
301
13,987
(1)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
320
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
4 Segmental analysis continu
ed
Go-forward group
Total
Central
excluding
Retail
Private
Commercial
RBS
NatWest
items
Ulster
Ulster
Analysis of net fees and commissions
Banking
Banking
Ban
king
Intern
ational
Markets
& other
Bank RoI
Bank
RoI
Tota
l
2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
Continuing operations
Fees and commissions receivable
-
Payment services
306
35
538
19
20
918
53
971
- Credit and debit card fees
344
10
147
2
503
19
522
- Lending and financing
13
10
515
54
74
666
4
670
- Brokerage
48
6
1
41
96
96
- Investment management, trustee
and fiduciary services
(1)
3
230
45
278
2
280
-
Underwriting fees
127
127
127
- Other
35
105
4
(112)
32
32
Total
714
326
1,305
125
262
(112)
2,620
78
2,698
Fees and commissions payable
(337)
(68)
(147)
(1)
(
104)
96
(561)
(13)
(
574)
Net fees and commissions
377
258
1,158
124
158
(16)
2,059
65
2,124
2020 (2)
Continuing operations
Fees and commissions receivable
- Payment services
264
28
507
18
18
835
57
892
- Credit and debit card fees
299
9
129
2
439
21
460
- Lending and financing
42
7
505
34
86
674
4
678
- Brokerage
54
6
1
93
154
1
155
- Investment management, trustee
and fiduciary services
(1)
3
225
1
38
2
269
2
271
- Underwriting fees
183
183
183
- Other
1
26
82
3
4
(33)
83
83
Total
663
301
1,224
96
386
(33)
2,637
85
2,722
Fees and commissions payable
(284)
(44)
(114)
(2)
(
287)
17
(714)
(8)
(722)
Net fees and commissions
379
257
1,110
94
99
(16)
1,923
77
2,000
2019 (2)
Fees and commissions receivable
- Payment services
292
33
659
27
24
1,035
60
1,095
- Credit and debit card fees
427
12
154
2
595
28
623
- Lending and financing
356
3
510
36
85
990
4
994
- Brokerage
55
5
96
156
8
164
-
Investment management,
trustee
and fiduciary services
44
186
3
41
1
275
3
278
- Underwriting fees
170
170
170
- Other
2
27
90
2
69
(173)
17
4
21
Total
1,176
266
1,416
108
445
(173)
3,238
107
3,345
Fees and commissions payable
(480)
(40)
(104)
(2)
(
360)
150
(836)
(12)
(
848)
Net fees and commissions
696
226
1,312
106
85
(23)
2,402
95
2,497
(1)
Comparisons with prior periods are impact
ed by the transfer of the Private Client Advice business to Private Banking from 1 January 2020.
(2)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8.
2021
2020
2019
Assets
Liabilities
Assets
Liabilities
Assets
Liabilities
£m
£m
£m
£m
£m
£m
Retail Banking
209,973
192,715
197,618
178,617
182,305
153,999
Private Banking
29,854
39,388
26,206
32,457
23,304
28,610
Commercial Banking
184,564
184,890
187,413
174,251
165,399
140,863
RBS International
40,578
38,436
33,984
31,989
31,738
30,330
NatWest Markets
200,576
188,431
270,147
254,098
263,885
246,907
Central items & other
93,614
77,308
57,503
61,262
31,023
57,762
Total excluding Ulster Bank RoI
759,159
721,168
772,871
732,674
697,654
658,471
Ulster Bank RoI
22,833
19,021
26,620
22,993
25,385
21,012
Total
781,992
740,189
799,491
755,667
723,039
679,483
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
321
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
4 Segmental analysis continu
ed
Segmental analysis of goodwill
There was an £85 million impairment of goodwill in
Retail banking during 2021. The total car
rying value of goodwill at 31
December was £5,522 million, comprised of Retail
Banking £2,607 million; Commercial Bankin
g £2,606 million; Private Banking £9
million; and RBS International £3
00 million. (2020 – total carrying value was £5,607
million comprising of Retail Banking £2,692
million; Commercial Banking £2,6
06 million; Private Banking £9 million; and RBS In
ternational £300 million). See note 17 for fu
rther
details.
Geographical segments
The geographical analysis in the tables below has been co
mpiled on the basis of location of of
fice where the transactions are
recorded.
UK
USA
Europe
RoW
Total
2021
£m
£m
£m
£m
£m
Continuing operations
Total revenue
12,100
87
565
33
12,785
Interest receivable
8,949
20
336
8
9,313
Interest payable
(1,483)
(2)
(211)
(3)
(1,699)
Net fees and commissions
1,820
27
235
42
2,124
Income from trading activities
247
53
(1)
24
323
Other operating income
387
2
62
451
Total income
9,920
100
421
71
10,512
Operating profit/(loss) before tax
4,143
48
(199)
40
4,032
Total assets
693,221
21,776
64,415
2,580
781,992
Total liabilities
676,684
23,286
38,835
1,384
740,189
Contingent liabilities and commitments
117,225
1
8,114
27
125,367
2020 (1)
Continuing operations
Total revenue
12,511
211
656
174
13,552
Interest receivable
9,479
297
22
9,798
Interest payable
(2,163)
(158)
(1)
(2,322)
Net fees and commissions
1,637
33
233
97
2,000
Income from trading activities
911
170
33
11
1,125
Other operating income
(117)
(22)
42
4
(93)
Total income
9,747
181
447
133
10,508
Operating profit/(loss) before tax
(193)
(85)
(291)
88
(481)
Total assets
704,725
25,439
66,884
2,443
799,491
Total liabilities
686,500
26,932
41,018
1,217
755,667
Contingent liabilities and commitments
118,654
10,068
10
128,732
2019 (1)
Continuing operations
Total revenue
16,925
228
882
128
18,163
Interest receivable
10,923
169
35
11,127
Interest payable
(3,255)
(70)
(3)
(3,328)
Net fees and commissions
2,191
37
197
72
2,497
Income from trading activities
727
148
49
8
932
Other operating income
2,305
13
432
9
2,759
Total income
12,891
198
777
121
13,987
Operating profit/(loss) before tax
3,543
186
172
82
3,983
Total assets
634,642
27,396
57,534
3,467
723,039
Total liabilities
613,151
31,715
33,539
1,078
679,483
Contingent liabilities and commitments
114,422
10,571
2
124,995
(1)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
322
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
5 Pensions
NatWest Group operates two types
of pension scheme: defined
benefit and defined contribution. The def
ined contribution
schemes invest contributions in
a choice of funds and the
accumulated contributions and inves
tment returns are used by
the employee to provide benefits on re
tirement, there is no
legal or constructive obligation
for NatWest Group to pay any
further contributions or benefits. T
he defined benefit schemes
provide pensions in retirement based on e
mployees’
pensionable salary and service.
NatWest Group’s balance sheet includes any defined benefit
pension scheme surplus or deficit as a retiremen
t benefit asset
or liability reported in other asse
ts and other liabilities. The
surplus or deficit is the difference between the liabilities t
o be
paid from the defined benefit scheme, and the
assets held by
the scheme to meet these liabilities. T
he liabilities are calculated
by external actuaries using a nu
mber of financial and
demographic assumptions.
For some NatWest Group define
d benefit schemes where there
is a net defined benefit surplus which means a
ny surplus in
excess of present value of any e
conomic benefits, the
application of accounting standards means
we don’t recognise
that surplus on the balance she
et as the trustees may have
control over the use of the surplus.
For accounting policy information se
e Accounting policies note
4.
Defined contribution schemes
NatWest Group sponsors several defined contribution s
chemes
in different territories, which new employees are en
titled to join.
NatWest Group pays specific contributions into indi
vidual
investment funds on employees’ behalf. Once those
contributions are paid, there is
no further liability on the
NatWest Group balance sheet relating to
the defined
contribution scheme.
Defined benefit schemes
NatWest Group sponsors a number of pension schemes
in the
UK and overseas, including the Main section of the N
atWest
Group Pension Fund (the “Main se
ction”) which operates under
UK trust law and is managed a
nd administered on behalf of its
members in accordance with the terms of the trust
deed, the
scheme rules and UK legislation.
Pension fund trustees are appointed to operate eac
h fund and
ensure benefits are paid in accordance with the sche
me rules
and national law. The trustees are the
legal owner of a
scheme’s assets, and have a duty to act in the best in
terests of
all scheme members.
The schemes generally provide a pension of one-si
xtieth of final
pensionable salary for each year of service
prior to retirement
up to a maximum of 40 years and a
re contributory for current
members. These have been close
d to new entrants for over ten
years, although current members continue to buil
d up
additional pension benefits, currently subject
to 2% maximum
annual salary inflation, while they remain employed by N
atWest
Group.
The Main section corporate trustee
is NatWest Pension Trustee
Limited (the Trustee), a wholly owned subsidiary of NWB
Plc,
Principal Employer of the Main section. The B
oard of the
Trustee comprises four member trustee direc
tors selected from
eligible active staff, deferred and pensioner membe
rs who
apply and six appointed by Nat
West Group. Under UK
legislation, a defined benefit pensi
on scheme is required to
meet the statutory funding objec
tive of having sufficient and
appropriate assets to cover its liabilities (
the pensions that have
been promised to members).
Similar governance principles apply to NatWest G
roup’s other
defined benefit pension schemes.
Investment strategy
The assets of the Main section, which is typic
al of other group
schemes, represent 90% of all p
lan assets at 31 December 2021
(2020 - 90%) and are invested as shown
below.
The Main section employs both physical and de
rivative
instruments to achieve a desired asset class expos
ure and to
reduce the section’s interest rate, inflati
on, and currency risk.
This means that the net funding position is conside
rably less
sensitive to changes in market conditions than
the value of the
assets or liabilities in isolation. In particular, move
ments in
interest rate and inflation are substantially hed
ged by the
Trustee.
Major classes of plan
assets as
a percentage of
total plan assets
of the Main section
2021
2020
Quoted
Unquoted
Total
Quoted
Unquoted
Total
%
%
%
%
%
%
Equities
3.7
4.7
8.4
3.9
4.6
8.5
Index linked bonds
46.7
46.7
49.4
49.4
Government bonds
9.8
9.8
6.2
6.2
Corporate and other bonds
10.7
4.4
15.1
11.8
5.0
16.8
Real estate
4.4
4.4
4.2
4.2
Derivatives
8.8
8.8
10.0
10.0
Cash and other assets
6.8
6.8
4.9
4.9
70.9
29.1
100.0
71.3
28.7
100.0
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
323
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
5 Pensions continued
The Main section’s holdings of derivative instruments
are summarised in the table below:
2021
2020
Notional
Fair value
Notional
Fair v
alue
amounts
Assets
Liabilities
a
mounts
Assets
Liabilities
£bn
£
m
£m
£bn
£m
£
m
Inflation rate swaps
20
1,408
796
18
1,390
1,716
Interest rate swaps
172
8,385
4,421
68
11,197
6,215
Currency forwards
12
61
98
11
334
38
Equity and bond call options
1
1
169
1
Equity and bond put options
1
3
3
1
19
Other
1
9
10
2
63
17
Swaps have been executed at prevailing
market rates and within standard market bid/offe
r spreads with a number of
counterparties, including NWB Plc.
At 31 December 2021, the gross notional v
alue of the swaps was £192 billion (202
0 - £88 billion) and had a net positive fair value
of £4,573 million (2020 - £4
,706 million) against which the counterparties had pos
ted approximately 95% collateral.
The schemes do not invest dire
ctly in NatWest Group but can have exposure to NatWes
t Group. The trustees of the respective UK
schemes are responsible for ensuring that indirect inves
tments in NatWest Group do not exce
ed the regulatory limit of 5% of plan
assets.
Main section
All schemes
Present
Present
value of
Asset
Net
value of
Asset
Net
Fair value
defined
ceiling/
pension
Fair value
defined
ceiling/
pension
of plan
benefit
minimum
(assets)/
of plan
benefit
minimum
(assets)/
assets
obligation
funding
liability
assets
obligation
funding
liability
Changes in value of net pension (assets)/li
ability
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January 2020
46,555
39,669
6,886
51,925
44,115
7,315
(495)
Currency translation and other adjustments
4
4
92
71
(21)
Income statement
936
954
141
159
1,037
1,103
149
215
Statement of comprehensive income
5,486
5,130
426
70
6,027
5,704
319
(4)
Contributions by employer
233
(
233)
296
(
296)
Contributions by plan participants and other scheme
members
9
9
14
14
Assets/liabilities extinguished upon settle
ment
(2)
(3)
(1)
Benefits paid
(1,896)
(1,896)
(2,140)
(2,140)
At 1 January 2021
51,323
43,870
7,453
57,249
48,864
7,783
(
602)
Currency translation and other adjustments
(129)
(116)
(3)
10
Income statement
Net interest expense
713
603
105
(5)
795
676
109
(10)
Current service cost
158
158
213
213
Past service cost
6
6
12
12
713
767
105
159
795
901
109
215
Statement of comprehensive income
Return on plan assets excluding
recognised interest income
841
(841)
872
(872)
Experience gains and losses
(241)
(241)
(236)
(236)
Effect of changes in actuarial financial assum
ptions
(1,165)
(1,165)
(1,204)
(1,204)
Effect of changes in actuarial demographic assum
ptions
350
350
379
379
Asset ceiling adjustments
2,443
2,443
2,602
2,602
841
(1,056)
2,443
546
872
(1,061)
2,602
669
Contributions by employer
705
(705)
780
(780)
Contributions by plan participants and other scheme
members
8
8
13
13
Assets/liabilities extinguished upon settle
ment
Benefits paid
(1,569)
(1,569)
(1,793)
(1,793)
At 31 December 2021
52,021
42,020
10,001
57,787
46,808
10,491
(488)
(1)
Defined benefit obligations are s
ubject to annual valuation by independent actuaries.
(2)
NatWest Group recognises the net p
ension scheme surplus or deficit as a net asset or liability. In doing so, the funded status is adjusted to reflect any schemes with a surplus that
NatWest Group may not be able to access, as well as any minimum funding req
uirement to pay in additional contributions. This is most relevant to the Main section, where the
surplus is not recognised as the trustees may have
control over the use of the surplus. Other NatWest Group schemes that this applies to include the Ulster Bank Pension Scheme
(NI) and the NatWest Markets section.
(3)
NatWest Group expects to make contributions
to the Main section of £714 million in 2022. Following the £500 million contribution in March 2021, additional contributions of up to
£500 million will be paid to the Main section in 2022, should NatWest
Group make further distributions in 2022. This leaves one remaining payment of up to £500 million to be paid to
the Main Section after 2022, in line with the ring-fencing ag
reement with the Trustee. Such contributions do not constitute a minimum funding requirement as the obligation to pay
only arises on the payment of a distribution to sha
reholders.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
324
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
5 Pensions continued
All schemes
2021
2020
Amounts recognised on the balance sheet
£m
£m
Fund asset at fair value
57,787
57,249
Present value of fund liabilities
46,808
48,864
Funded status
10,979
8,385
Assets ceiling/minimun funding
10,491
7,783
488
602
2021
2020
Net pension assets/(liability) comprise
s
£m
£m
Net assets of schemes in surplu
s (included in Other assets, Note 18
)
602
723
Net liabilities of schemes in deflicit (included in Othe
r liabilities, Note 21)
(114)
(121)
488
602
The income statement charge comprises
(1)
:
2021
2020
£m
£m
Continuing operations
196
195
Discontinued operations
19
20
(1)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8.
Funding and contributions by NatWest Group
In the UK, the trustees of defined benefit pension sc
hemes are
required to perform funding valu
ations every three years. The
trustees and the sponsor, with the suppo
rt of the Scheme
Actuary, agree the assumptions
used to value the liabilities and
to determine future contribution requirements. The fundi
ng
assumptions incorporate a margin for prudence o
ver and
above the expected cost of providing the benefits p
romised to
members, taking into account the s
ponsor’s covenant and the
investment strategy of the scheme. Simil
ar arrangements apply
in the other territories where NatWest Group sponsors
defined
benefit pension schemes.
A full triennial funding valuation of the Main section, effe
ctive
31 December 2020, was comple
ted during the year.
This triennial funding valuation determined t
he funding level to
be 104%, pension liabilities to be
£49 billion and the surplus to
be £2 billion, all assessed on the agreed funding b
asis. The
average cost of the future service
of current members is 49% of
salary before contributions from those
members. In addition,
the sponsor has agreed to mee
t administrative expenses.
Following the ring-fencing agreement with the T
rustee reached
in 2018, additional contributions
of up to £500 million p.a. are
payable to the Main section should the Group m
ake
distributions to shareholders of an equal amount. These
contributions are capped at £1.5 billion in tot
al; £500 million
was made in 2021 (2020 – Nil).
The key assumptions used to determine the fundin
g liabilities
were the discount rate, which is determined base
d on fixed
interest swap and gilt yields plus 0.6
4% per annum, and
mortality assumptions, which res
ult in life expectancies of
27.7/29.4 years for males/female
s who are currently age 60
and 28.9/30.7 years from age 60
for males/females who are
currently aged 40.
The 2020 triennial valuation of the G
roup Pension Fund
included an allowance for the es
timated impact of guaranteed
minimum pension equalisation,
which is reflected in the IAS 19
valuation at 31 December 2021. As s
uch, no explicit allowance
is required in the IAS 19 figures
(2020: £169 million).
Accounting Assumptions
Placing a value on NatWest Gr
oup’s defined benefit pension
schemes’ liabilities requires NatWes
t Group’s management to
make a number of assumptions, with
the support of
independent actuaries. The ultimate cost of the def
ined benefit
obligations depends upon actu
al future events and the
assumptions made are unlikely
to be exactly borne out in
practice, meaning the final cost may be hi
gher or lower than
expected.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
325
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
5 Pensions continued
The most significant assumptions use
d for the Main section are shown below:
Principal IAS 19 a
ctuarial assumptions
2021
2020
%
%
Discount rate
1.8
1.4
Inflation assumption (RPI)
3.3
2.9
Rate of increase in salaries
1.8
1.8
Rate of increase in deferred pensions
3.7
3.0
Rate of increase in pensions in paymen
t
2.5
2.7
Lump sum conversion rate at r
etirement
18
20
Longevity at age 60:
years
years
Current pensioners
Males
27.3
27.1
Females
29.0
29.0
Future pensioners, currently aged 40
Males
28.2
28.3
Females
30.1
30.4
Discount rate
The IAS 19 valuation uses a single discount rate s
et by reference to the yield on a basket of ‘h
igh quality’ sterling corporate bonds.
Significant judgment is required when se
tting the criteria for bonds to be included in the bask
et
of bonds that is used to dete
rmine
the discount rate used in the IAS 19 valua
tions. The criteria include issue
size, quality of pricing and the exclusion of outliers.
Judgment is also required in determining the sha
pe of the yield curve at long durations; a co
nstant credit spread relative to g
ilts is
assumed. Sensitivity to the main assumptions is prese
nted below.
The weighted average duration of the Main se
ction’s defined benefit obligation at 31
December 2021 is 2
0 years (2020 – 22 years).
The chart below shows the projected benefit p
ayment pattern for the Main section in nomin
al terms. These cashflows are bas
ed on
the most recent formal actuarial valuation, eff
ective 31 December 2020.
The larger outflow in the first three years represents
the expected level of transfers out to 31
December 2023.
0
500
1000
1500
2000
2500
2021
2023
2025
2027
2029
2031
2033
2035
2037
2039
2041
2043
2045
2047
2049
2051
2053
2055
2057
2059
2061
2063
2065
2067
2069
2071
2073
2075
2077
2079
2081
2083
2085
2087
2089
2091
2093
2095
Expected C
ashflows (£m)
Year
Non pension
er
Pensioner
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
326
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
5 Pensions continued
The table below shows how th
e net pension asset of the Main section would chan
ge if the key assumptions used were ch
anged
independently. In practice the v
ariables have a degree of correlation an
d do not move completely in isolation.
(Decrease)/
(Decrease)/
Increase in
increase
increase
net pension
in value of
in value of
(obligations)/
assets
liabilities
assets
2021
£m
£m
£m
0.25% increase in interest rates/discount rate
(2,917)
(1,926)
(991)
0.25% increase in inflation
1,883
1,329
554
0.25% increase in credit spreads
(3)
(1,926)
1,923
Longevity increase of one year
1,790
(1,790)
0.25% additional rate of increase
in pensions in payment
1,485
(1,485)
Increase in equity values of 10%
(1)
442
442
2020
0.25% increase in interest rates/discount rate
(2,585)
(2,384)
(201)
0.25% increase in inflation
2,204
1,603
601
0.25% increase in credit spreads
(6)
(2,384)
2,378
Longevity increase of one year
1,930
(1,930)
0.25% additional rate of increase
in pensions in payment
1,608
(1,608)
Increase in equity values of 10%
(1)
454
454
(1)
Includes both quoted and p
rivate equity.
The funded status is most sensitive to move
ments in credit spreads and longevity. The table b
elow shows the combined change in
the funded status of the Main s
ection as a result of larger movements in these ass
umptions, assuming no changes in othe
r
assumptions.
Change in life expecta
ncies
-
2 years
-
1 years
No change
+ 1 year
+ 2 years
2021
£bn
£bn
£bn
£bn
£bn
Change in credit spreads
+50 bps
6.9
5.3
3.8
2.3
0.8
No change
3.6
1.8
(1.8)
(3.6)
-50 bps
(0.3)
(
2.4)
(
4.5)
(6.6)
(8.7)
2020
Change in credit spreads
+50
bps
7.8
6.1
4.5
2.9
1.3
No change
3.9
1.9
(
1.9)
(3.9)
-50 bps
(0.6)
(
2.8)
(
5.1)
(7.4)
(9.7)
The defined benefit obligation of
the Main section is attributable to the different classes of sc
heme members in the following
proportions:
2021
2020
Membership category
%
%
Active members
10.7
14.2
Deferred members
47.6
50.9
Pensioners and dependants
41.7
34.9
100.0
100.0
The experience history of NatWe
st Group schemes is shown below:
Main section
All schemes
2021
2020
2019
2018
2017
2021
2020
2019
2018
2017
History of defined benefit schemes
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Fair value of plan assets
52,021
51,323
46,555
43,806
44,652
57,787
57,249
51,925
48,752
49,746
Present value of plan obligations
42,020
43,870
39,669
35,466
37,937
46,808
48,864
44,115
39,607
42,378
Net surplus/(deficit)
10,001
7,453
6,886
8,340
6,715
10,979
8,385
7,810
9,145
7,368
Experience gains/(losses) on plan liabilities
241
427
275
(122)
(107)
237
455
279
(81)
(93)
Experience gains/(losses) on plan assets
841
5,486
3,021
(
1,891)
1,580
872
6,027
3,556
(
2,090)
1,728
Actual return on plan assets
1,554
6,422
4,266
(768)
2,735
1,667
7,064
4,930
(848)
3,013
Actual return on plan assets %
3.0%
13.8%
9.7%
(
1.7%)
6.2%
2.9%
13.6%
10.1%
(
1.7%)
6.1%
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
327
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
6 Auditor’s remuneration
Amounts payable to NatWest Group's auditors fo
r statutory audit and other services are set
out below.
All audit-related and other service
s are approved by the Group Audit Committee a
nd are subject to strict controls to ensure
the
external auditor’s independence
is unaffected by the provision of other se
rvices. The Group Audit Committee recognise
s that for
certain assignments, the auditors are best placed to
perform the work economically; for o
ther work, NatWest Group selects
the
supplier best placed to meet its require
ments. NatWest Group’s auditors are permitted
to tender for such work in competition with
other firms where the work is pe
rmissible under audit independence rules.
2021
2020
2019
£m
£m
£m
Fees payable for:
- the audit of NatWest Group’s annual accoun
ts
(1)
4.4
4.7
3.8
-
the audit of NatWest Group p
lc’s subsidiaries
(1)
29.6
30.6
25.7
- audit-related assurance service
s
(1,2)
5.3
4.7
3.2
Total audit and audit-related as
surance services fees
39.3
40.0
32.7
Other assurance services
0.4
0.6
1.2
Corporate finance services
(3)
0.5
0.4
0.6
Total other services
0.9
1.0
1.8
(1)
The 2021 audit fee was approved by the
Group Audit Committee. At 31 December 2021, £19.7 million has been billed and paid in respect
of the 2021 NatWest Group audit fees.
(2)
Comprises fees of £1.1 million (2020 - £1.1 million) in relat
ion to reviews of interim financial information, £3.5 million (2020 - £3.2 million) in respect of reports t
o NatWest Group’s
regulators in the UK and overseas, and £0.7 million (2020 - £0.4 million) in relation t
o non-statutory audit opinions.
(3)
Comprises fees of £0.5 million (2020 - £0.4 million) in resp
ect of work performed by the auditors as reporting accountants on debt and equity issuances undertaken by NatW
est
Group.
7 Tax
NatWest Group’s corporate income t
ax charge for the period is set out below, toge
ther with a reconciliation to the expected
tax
charge calculated using the UK standard corpo
ration tax rate and details of the NatWest
Group’s deferred tax balances.
For accounting policy information se
e Accounting policies note 9.
Analysis of the tax charge for the year
The tax charge comprises curre
nt and deferred tax in respect of profits and losse
s recognised or originating in the income
statement. Tax on items originating outside the inco
me statement is charged to othe
r comprehensive income or direct to e
quity (as
appropriate) and is therefore not reflected in the table belo
w.
Current tax is tax payable or re
coverable in respect of the taxable profit or loss fo
r the year and any adjustments to tax p
ayable in
prior years. Deferred tax is explained on page
328.
2021
2020 (1)
2019 (1)
Continuing operations
£m
£m
£m
Current tax
Charge for the year
(1,036)
(191)
(673)
Over provision in respect of prior years
31
86
122
(1,005)
(105)
(551)
Deferred tax
(Charge)/credit for the year
(185)
176
38
UK tax rate change impact
(2)
165
75
Net increase/(decrease) in the car
rying value of deferred tax assets in respect of
UK,
Ireland and Netherlands losses
12
(130)
55
Over/(under) provision in respect of prior yea
rs
(3)
17
(90)
19
Tax charge for the year
(996)
(74)
(439)
(1)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8.
(2)
It was announced in the UK
Government’s bu
dget on 3 March 2021 th
at the main UK corporation tax rate will increase from 19% to 25% from 1 April 2023. This legislative change
was enacted on 10 June 2021.
(3)
Prior year tax adjustments
incorporate refinem
ents t
o tax computations made on submission and agreement with the tax authorities and adjustments to provisions in respect of
uncertain tax positions.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
328
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
7 Tax continued
Factors affecting the tax charge for the year
Taxable profits differ from profi
ts reported in the income statement as certain amou
nts of income and expense may not be taxable
or deductible. In addition, taxa
ble profits may reflect items that have been inclu
ded outside the income statement (for insta
nce, in
other comprehensive income) or adjustments that
are made for tax purposes only.
The expected tax charge for the
year is calculated by applying the standard UK corpo
ration tax rate of 19% (2020 and 2019
– 19%)
to the Operating profit or loss be
fore tax in the income statement.
The actual tax charge differs from the expected
tax charge as follows:
2021
2020 (1)
2019 (1)
Continuing operations
£m
£m
£m
Expected tax (charge)/credit
(766)
92
(757)
Losses and temporary differen
ces in year where no deferred tax asset recognised
(51)
(43)
(
24)
Foreign profits taxed at other rates
(11)
(29)
7
Non deductible goodwill impairment
(16)
Items not allowed for tax:
- losses on disposals and write-downs
(55)
(22)
(
71)
-
UK bank levy
(18)
(32)
(
26)
- regulatory and legal actions
(74)
14
(165)
- other disallowable items
(28)
(70)
(
62)
Non-taxable items:
-
Alawwal bank merger gain dis
posal
215
- FX recycling on the liquidation of RFS Holdin
gs
279
- other non-taxable items
73
28
80
Taxable foreign exchange movements
8
(3)
(1)
Unrecognised losses brought forward and utilised
10
16
16
(Decrease)/increase in the carrying value of defer
red tax assets in respect of:
- UK losses
(9)
7
129
- Ireland losses
(27)
(137)
(74)
- Netherlands losses
48
Banking surcharge
(341)
(27)
(199)
Tax on paid-in equity
48
61
73
UK tax rate change impact
165
75
Adjustments in respect of prior ye
ars
48
(4)
141
Actual tax charge
(996)
(74)
(439)
(1)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8.
Judgment: tax contingencies
NatWest Group’s corporate income t
ax charge and its provisions for corporate income taxes
necessarily involve a degree of
estimation and judgment. The tax treatment of some
transactions is uncertain and tax com
putations are yet to be agreed wi
th the
tax authorities in a number of jurisdictions. N
atWest Group recognises anticipated tax li
abilities based on all available evidence
and,
where appropriate, in the light of external advice. Any dif
ference between the final outcome a
nd the amounts provided will aff
ect
current and deferred income tax charges in the perio
d when the matter is resolved.
Deferred tax
Deferred tax is the tax expected to be
payable or recoverable in respect of temporary diffe
rences where the carrying amount of
an asset or liability differs for accounting and t
ax purposes. Deferred tax liabilities reflect
the expected amount of tax payab
le in
the future on these temporary
differences. Deferred tax assets refle
ct the expected amount of tax recoverable in the futu
re on
these differences.
The net deferred tax asset recognised by the NatWe
st Group is shown below, together with de
tails of the accounting judgments
and tax rates that have been used to calculate the de
ferred tax. Details are also provided of any defe
rred tax assets or liabilities
that have not been recognised on the bala
nce sheet.
Analysis of deferred tax
£m
£m
Deferred tax asset
(1,195)
(901)
Deferred tax liability
359
291
Net deferred tax asset
(836)
(610)
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
329
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
7 Tax continued
Accelerated
Tax losses
capital
Expense
Financial
carried
Pension
allowances
provisions
instruments
forward
Other
Total
£m
£m
£m
£m
£m
£m
£m
At 1 January 2020
(139)
172
(118)
315
(951)
(24)
(745)
Charge/(credit) to income state
ment:
(1)
- continuing operations
15
(234)
33
114
46
(
5)
(31)
- discontinued operations
9
9
Charge/(credit) to other compre
hensive income
119
51
(
7)
163
Currency translation and other adjustments
1
(2)
(9)
4
(6)
At 1 January 2021
(4)
(64)
(85)
480
(905)
(32)
(610)
Charge/(credit) to income state
ment:
- continuing operations
19
21
(
5)
(10)
(1)
(33)
(9)
- discontinued operations
3
3
Charge/(credit) to other compre
hensive income
10
(7)
(222)
(5)
(224)
Currency translation and other adjustments
(1)
1
4
4
At 31 December 2021
24
(42)
(97)
248
(899)
(70)
(836)
(1)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8.
Deferred tax assets in respect of carried for
ward tax losses are recognised if the losses can
be used to offset probable future
taxable profits after taking into account the expec
ted reversal of other temporary differences.
R
ecognised deferred tax assets in
respect of tax losses are analysed further below.
2021
2020
£m
£m
UK tax losses carried forward
- NWM Plc
56
62
- NWB Plc
608
592
-
RBS plc
176
200
- Ulster Bank Limited
8
Total
840
862
Overseas tax losses carried for
ward
- UBIDAC
11
43
- NWM N.V.
48
899
905
Critical accounting policy: Deferred tax
NatWest Group has recognised a defe
rred tax asset of £1,195
million (31 December 2020 - £901
million) and a deferred tax
liability of £359 million (31 December 2020 - £2
91 million). These
include amounts recognised in
respect of UK and overseas tax
losses of £899
million (31 December 2020 - £905 million).
Deferred tax assets are recognis
ed to the extent that it is
probable that there will be future taxable profits to
recover
them.
Judgment
-
NatWest Group has
considered the carrying value of
deferred tax assets and concluded that, based o
n
management’s estimates, suffic
ient taxable profits will be
generated in future years to recover recognised defe
rred tax
assets.
Estimate
- These estimates are partly base
d on forecast
performance beyond the horizon for management’s det
ailed
plans. They have regard to inhe
rent uncertainties, such as
climate change and the impact of C
OVID. The deferred tax
assets in NWM Plc and UBIDAC are supported by w
ay of future
reversing taxable temporary differences
on which deferred tax
liabilities are recognised at 31 December 2021
.
UK tax losses
Under UK tax rules, tax losses can be carrie
d forward
indefinitely. As the recognised tax losses in Na
tWest Group
arose prior to 1 April 2015, credit in future periods is given
against 25% of profits at the main rate of UK corporati
on tax,
excluding the Banking Surcharge 8
% rate introduced by The
Finance (No. 2) Act 2015.
It was announced in the UK Government’s budget o
n 3 March
2021 that the main UK corpora
tion tax rate will increase from
19% to 25% from 1 April 2023. T
his legislative change was
enacted on 10 June 2021
. NatWest Group’s closing deferred tax
assets and liabilities have therefore been recalcul
ated taking
into account this change of rat
e and the applicable period the
deferred tax assets and liabilities
are expected to crystallise. As
a result, the net deferred tax asse
t position in NatWest Group
has increased by £163 million, with a £16
5 million tax credit
included in the income stateme
nt (refer to reconciling item
above), and a £2 million tax charge included in other
comprehensive income.
It was subsequently announced in the UK Govern
ment’s budget
on 27 October 2021 that the U
K banking surcharge will
decrease from 8% to 3% from 1 April 2023
. This legislative
change was substantively enacted on 2 Feb
ruary 2022. Had this
rate reduction been substantively
enacted as at the balance
sheet date, the estimated rate change i
mpact would not have
been material.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
330
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
7 Tax continued
NWM Plc
– NWM Plc expects th
at the balance of recognised
deferred tax asset at 31 December 202
1 of £56 million (2020 -
£62 million) in respect of tax losse
s amounting to £254 million
will be recovered by the end of 2
027. The movement in the
current financial year reflects a £1
3 million decrease in the
carrying value of the deferred tax asset, offse
t by a £7 million
increase due to the UK tax rate change imp
act.
NWB Plc
– A deferred tax asset of
£608 million (2020 - £592
million) has been recognised in respect of total loss
es of £2,610
million. The losses arose principally as a result of sig
nificant
impairment and conduct charges
between 2009 and 2012
during challenging economic conditions in the UK b
anking
sector. NWB Plc expects the deferred tax asset to be u
tilised
against future taxable profits by the end of 20
25.
RBS plc
– A deferred tax asset of
£176 million (2020 - £200
million) has been recognised in respect of losses of
£722 million
of total losses of £3,979
million carried forward at 31 December
2021. The losses were transferred from NatWe
st Markets Plc as
a consequence of the ring fencing regulations. RB
S plc expects
the deferred tax asset to be util
ised against future taxable
profits by the end of 2027.
Overseas tax losses
UBIDAC
A deferred tax asset
of £11 million (2020 - £43 million)
has been recognised in respect of los
ses of £88 million, and is
now entirely supported by way of f
uture reversing taxable
temporary differences on which def
erred tax liabilities are
recognised at 31 December 20
21. The movement in the current
financial year reflects a £32 million reduction in the ca
rrying
value of the deferred tax asset f
ollowing the announcement of
the Group’s withdrawal from the Republic of Irel
and.
NatWest Market N.V. (NWM N.V.)
A deferred tax asset of £4
8
million has been recognised in respect of p
reviously
unrecognised tax losses and cre
dits of £187 million of total tax
losses and credits of £2,785 million carried fo
rward at 31
December 2021. NWM N.V. Group expects the defe
rred tax
asset to be utilised against future taxa
ble profits by the end of
2026. NWM N.V. Group’s Dutc
h fiscal unit has reported taxable
profits in the period since the adoption of the ne
w business
model and repurposing of NWM N.V.’s ba
nking license in 2019.
In addition, NatWest Group strategic review of NWM G
roup has
been largely completed in 2021, which h
as removed material
uncertainties around the future busines
s of NWM N.V.. As a
result, NWM N.V. Group now considers it to be
probable, based
on its 5 year budget forecast, that future tax
able profit will be
available against which the tax
losses and tax credits can be
partially utilised.
Unrecognised deferred tax
Deferred tax assets of £5,437 million (2020
- £4,965 million;
2019 - £4,653 million) have not been recognised in respect of
tax losses and other deductible temporary differences
carried
forward of £24,699 million (202
0 - £25,091 million; 2019 -
£23,555 million) in jurisdictions where dou
bt exists over the
availability of future taxable prof
its. Of these losses and other
deductible temporary difference
s, £77 million expire within five
years and £4,288 million thereaf
ter. The balance of tax losses
and other deductible temporary diffe
rences carried forward has
no expiry date.
Deferred tax liabilities of £302
million (2020 - £242 million; 2019
- £262 million) on aggregate underlying
temporary differences
of £1,032 million (2020 - £1
,021 million; 2019 £1,074 million)
have not been recognised in res
pect of retained earnings of
overseas subsidiaries and held-
over gains on the incorporation
of certain overseas branches. Retained earnings of
overseas
subsidiaries are expected to be reinvested indefinitely or
remitted to the UK free from fu
rther taxation. No taxation is
expected to arise in the foresee
able future in respect of held-
over gains on which deferred t
ax is not recognised. Changes to
UK tax legislation largely exem
pts from UK tax overseas
dividends received on or after 1 July
2009.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
331
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
8 Discontinued operations and assets and liabili
ties of disposal groups
Discontinued operations are reported sepa
rately on the income statement to allow users to di
stinguish the profits and cash flows
from continuing operations from those
activities that are subject to disposal.
Assets and liabilities which we intend
to dispose of in a single transaction a
re also presented separately on the balance sheet.
For accounting policy information se
e Accounting policies note 3.
This note sets out the profit/(loss) from the discontinued o
perations (represented for comparati
ve periods), the assets and liabilities
of the disposal group and the operating c
ash flows attributable to the discontinued oper
ations.
Two legally binding agreements f
or the sale of UBIDAC business were announced in 2021
as part of the phased withdrawal from
the Republic of Ireland:
On 28 June 2021
we announced it had agreed a binding sale agreement with Allied
Irish Banks, p.l.c. for the transfer of c.€4
.2
billion (plus up to €2.8 billion of undrawn exposures),
of performing commercial loans as well
a
s c.280 colleagues that are w
holly or
mainly assigned to supporting t
hat part of the business, with the final number of roles to
be confirmed as the deal completes. T
he
sale, subject to Competition and Consume
r Protection Commission (CCPC) approval, is expe
cted to be completed in a series
of
transactions during 2022 and Q1 2
023.
On the 17 December 2021 we s
igned a legally binding agreement with Permanent TSB
p.l.c.
The proposed
sale will include
performing non-tracker mortgages, the perfo
rming loans in the micro-SME business; the UB
IDAC Asset Finance business, in
cluding
its Lombard digital platform, and a subset of Uls
ter Bank branch locations in the Republic of
Ireland.
The majority of loans are
expected to transfer by Q4 2022
. As part of the transaction it is anticipated that c.450
colleagues will have the right to transfe
r
under the TUPE regulations with the final num
ber of roles to be confirmed as the deal comple
tes.
The business activities relating to these sales t
hat meet the requirements of IFRS 5 are p
resented as a discontinued operation and
as a disposal group at 31 December 2021. T
he Ulster Bank RoI operating segment con
tinues to be reported separately and r
eflects
the results and balance sheet position of its co
ntinuing operations.
(a) Profit from discontinued operations, net of tax
2021
2020
2019
£m
£m
£m
Interest receivable
260
273
248
Net interest income
260
273
248
Non-interest income
9
15
18
Total income
269
288
266
Operating expenses
(47)
(47)
(45)
Profit before impairment losses
222
241
221
Impairment releases/(losses)
57
(111)
28
Operating profit before tax
279
130
249
Tax (charge)/credit
(3)
(9)
7
Profit from discontinued operations, net of t
ax
276
121
256
(b) Assets and liabilities of disposal groups
2021
£m
Assets of disposal groups
Loans to customers - amortised cost
9,002
Derivatives
5
Other assets
8
9,015
Liabilities of disposal groups
Other liabilities
5
5
Net assets of disposal groups
9,010
(c) Operating cash flows attributable to discontin
ued operations
2021
2020
2019
£m
£m
£m
Net cash flows from operating activi
ties
1,290
(895)
(3,909)
Net increase/(decrease) in cash and c
ash equivalents
1,290
(895)
(3,909)
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
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Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
9 Earnings per share
Earnings per share is a metric to measure how
much profit NatWest Group makes for each sh
are that is in issue during the
year.
Basic earnings per ordinary share is calcul
ated by dividing the profit attributable to o
rdinary shareholders by the weighted
average number of ordinary sh
ares outstanding. Diluted earnings per ordina
ry share is calculated by dividing the basic ea
rnings by
the weighted average number of ordinary shares ou
tstanding plus the weighted aver
age number of ordinary shares that wo
uld be
issued on conversion of dilutive share options and conve
rtible securities.
2021
2020
2019
£m
£m
£m
Earnings
Profit/(loss) from continuing operations attributable
to ordinary shareholders
2,674
(874)
2,877
Profit from discontinued operations attribut
able to ordinary shareholders
276
121
256
Profit/(loss) attributable to ordinary shareholders
2,950
(753)
3,133
Weighted average number of shares (millions)
Weighted average number of ordinary sh
ares outstanding during the year
11,622
12,095
12,067
Effect of dilutive share options and convertible securities
(1)
45
35
Diluted weighted average number of ordin
ary shares outstanding during the year
11,667
12,095
12,102
(1)
As there was a loss from continuing op
erations attributable to the parent company for the period to 31 December 2020, the effect of share options and convertible securities was
not dilutive.
10 Financial instruments – classification
Financial instruments are contracts that give
rise to a financial asset of one entity and a co
rresponding financial liability or equity
instrument of a counterparty entity, such as: cash; de
rivatives; loans; deposits; and settlemen
t balances.
This note presents
financial instruments classified in accordance with IFR
S 9 – Financial Instruments.
Judgment: classification of finan
cial assets
Classification of financial assets be
tween amortised cost and fair value through other comp
rehensive income requires a degre
e of
judgment in respect of business models a
nd contractual cashflows.
The business model criteria is as
sessed at a portfolio level to determine whether assets are cl
assified as held to collect or hel
d
to collect and sell. Information t
hat is considered in determining the applic
able business model includes the portfolio’s policies
and objectives, how the performance and risks of the p
ortfolio are managed, evaluated
and reported to management; and the
frequency, volume and timing of s
ales in prior periods, sales expectation for future periods,
and the reasons for sales.
The contractual cash flow characteris
tics of financial assets are assess
ed with reference to whether the cash flows represe
nt
solely payments of principal and interes
t. A level of judgment is made in assessing terms t
hat could change the contractual
cash flows so that it would not meet the co
ndition for solely payments of principal and in
terest, including contingent and
leverage features,
non-recours
e arrangements and features that could modify
the time value of money.
For accounting policy information se
e Accounting policies 10, 12, 13
and 15.
Notes to the c
onsolidated fi
nancial statement
s
NatWest Group
A
nnual Repor
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nts 2021
333
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
10 Financial instruments - classification
continu
ed
Judgment: classification of finan
cial assets
The following tables analyse financial assets and liabili
ties in accordance with the categories
of financial instruments on an IFRS 9
basis.
Amortised
Other
MFVTPL
FVOCI
cost
assets
T
otal
Assets
£m
£m
£m
£m
£m
Cash and balances at central banks
177,757
177,757
Trading assets
59,158
59,158
Derivatives
(1)
106,139
106,139
Settlement balances
2,141
2,141
Loans to bank - amortised cost
(2)
7,682
7,682
Loans to customers - amortised cost
(3)
358,990
358,990
Other financial assets
317
37,266
8,562
46,145
Intangible assets
6,723
6,723
Other assets
8,242
8,242
Assets of disposal groups
9,015
9,015
31 December 2021
165,614
37,266
555,132
23,980
781,992
Cash and balances at central banks
124,489
124,489
Trading assets
68,990
68,990
Derivatives
(1)
166,523
166,523
Settlement balances
2,297
2,297
Loans to bank - amortised cost
(2)
6,955
6,955
Loans to customers - amortised cost
(3)
360,544
360,544
Other financial assets
440
44,902
9,806
55,148
Intangible assets
6,655
6,655
Other assets
7,890
7,890
31 December 2020
235,953
44,902
504,091
14,545
799,491
Held-for-
Amortised
Other
trading
DFV
cost
liabilities
Total
Liabilities
£m
£m
£m
£m
£m
Bank deposits
(4)
26,279
26,279
Customer deposits
479,810
479,810
Settlement balances
2,068
2,068
Trading liabilities
64,598
64,598
Derivatives
(1)
100,835
100,835
Other financial liabilities
(5)
1,671
47,655
49,326
Subordinated liabilities
703
7,726
8,429
Notes in circulation
3,047
3,047
Other liabilities
(6)
1,356
4,441
5,797
31 December 2021
165,433
2,374
567,941
4,441
740,189
Bank deposits
(4)
20,606
20,606
Customer deposits
431,739
431,739
Settlement balances
5,545
5,545
Trading liabilities
72,256
72,256
Derivatives
(1)
160,705
160,705
Other financial liabilities
(5)
2,403
43,408
45,811
Subordinated liabilities
793
9,169
9,962
Notes in circulation
2,655
2,655
Other liabilities
(6)
1,882
4,506
6,388
31 December 2020
232,961
3,196
515,004
4,506
755,667
(1)
Includes net hedging derivatives ass
ets of £44 milli
on (2020 -
£93 million) and net hedging derivatives liabilities of £120 million (2020 - £130 million).
(2)
Includes items in the course of
collection from other banks of £67 million (2020 - £148 million).
(3)
Includes finance lease receivables of £8,531 million (2020 - £9,061
million).
(4)
Includes items in the course of transmission to oth
er banks of £56 milli
on (2020
- £12 million).
(5)
The carrying amount of other customer accounts d
esignated at fair value through profit or loss is the same as the principal amount for both periods. No amounts have been
recognised in the profit or loss for changes in credit
risk associated with these liabilities as the changes are immaterial both during the period and cumulatively.
(6)
Includes lease liabilities of £1,263 million (2020
- £1,698 million) held at amortised cost.
Notes to the c
onsolidated fi
nancial statement
s
NatWest Group
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nnual Repor
t and Accou
nts 2021
334
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
10 Financial instruments - classification
continu
ed
Judgment: classification of finan
cial assets
2021
2020
£m
£m
Reverse repos
Trading assets
20,742
19,404
Loans to banks - amortised cost
189
153
Loans to customers - amortised cost
25,962
25,011
Repos
Bank deposits
7,912
6,470
Customer deposits
14,541
5,167
Trading liabilities
19,389
19,036
The tables below present information on financi
al assets and financial liabilities that are offse
t on the balance sheet under IFRS or
subject to enforceable master netting agree
ments together with financial coll
ateral received or given.
Instruments which
can be offset
Potential for of
fset not recognised by IFRS
Effect of
Net amount
master
after the effect
Instruments
netting
of netting
outside
IFRS
Balance
and similar
Cash
Securities
agreements and
netting
Balance
Gross
offset
sheet
agreements
collateral
collateral
related collateral
agreements
sheet
total
2021
£m
£
m
£m
£m
£m
£m
£m
£m
£m
Derivative assets
113,220
(7,961)
105,259
(85,006)
(15,035)
(2,428)
2,790
880
106,139
Derivative liabilities
108,594
(8,568)
100,026
(85,006)
(9,909)
(2,913)
2,198
809
100,835
Net position
(1)
4,626
607
5,233
(5,126)
485
592
71
5,304
Trading reverse repos
44,529
(24,422)
20,107
(
900)
(19,136)
71
635
20,742
Trading repos
42,664
(24,422)
18,242
(
900)
(17,341)
1
1,147
19,389
Net position
1,865
1,865
(1,795)
70
(512)
1,353
Non trading reverse repos
33,729
(7,594)
26,135
(26,135)
16
26,151
Non trading repos
30,047
(7,594)
22,453
(22,453)
22,453
Net position
3,682
3,682
(3,682)
16
3,698
2020
Derivative assets
176,425
(10,807)
165,618
(137,086)
(19,608)
(5,053)
3,871
905
166,523
Derivative liabilities
171,614
(11,540)
160,074
(137,086)
(15,034)
(4,921)
3,033
631
160,705
Net position
(1)
4,811
733
5,544
(4,574)
(132)
838
274
5,818
Trading reverse repos
43,908
(24,867)
19,041
(929)
(18,040)
72
363
19,404
Trading repos
42,203
(24,867)
17,336
(929)
(16,407)
1,700
19,036
Net position
1,705
1,705
(1,633)
72
(1,337)
368
Non trading reverse repos
36,117
(10,953)
25,164
(25,164)
25,164
Non trading repos
22,590
(10,953)
11,637
(11,637)
11,637
Net position
13,527
13,527
(13,527)
13,527
(1)
The net IFRS offset balan
ce of £607 million (2020 - £733 million) relates to variation margin netting reflected on other balance sheet lines.
Notes to the c
onsolidated fi
nancial statement
s
NatWest Group
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nnual Repor
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nts 2021
335
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
10 Financial instruments - classification
continu
ed
Interest rate benchmark reform
The
NatWest
G
roup
IBOR
pro
gram
successfully
delivered
the
conversion
of
the
vast
majority
of
the
IBOR
exposures
to
risk
free
rates
(RFR)
in
advance
of
the
cessation
date.
This
encompasses
loa
ns,
deposits,
c
apital
instruments
and
d
erivatives,
which,
have
been
converted
using
fallback
provisions,
switch
pr
ovisions
or
as
part
of
market-wide
conv
ersion
events
in
t
he
case
of
der
ivatives
subject to clearing. These instruments will conver
t at the first repricing date post cessation.
The total amount of exposure for NatWest Gr
oup at 31 December 2021 subject to the above conversion
provisions are £22,056
million of assets, £426 million of
liabilities, £15,785 million of loan commitments and £557
.7 billion of derivative notionals.
Despite the significant conversion le
vels achieved, certain instruments remain in discussi
on with customers and counter
parties to
achieve consensual conversion.
If consensual conversion is not achieved these
instruments will default to synthetic LIBOR in li
ne
with relevant legislation.
The level of exposures without explicit o
r agreed conversion provisions as of 31 Dece
mber 2021 is as follows:
Rates subject t
o IBOR reform
GBP LIBOR
USD IBOR
(1)
Other IBOR (2)
Total
2021
£m
£m
£m
£m
Trading assets
62
90
152
Loans to banks - amortised cost
11
11
Loans to customers - amortised cost
4,788
4,565
267
9,620
Other financial assets
864
768
1,632
Bank deposits
37
37
Customer deposits
Trading liabilities
31
166
197
Other financial liabilities
2,390
7,023
131
9,544
Subordinated liabilities
90
90
Loan commitments
(3)
1,016
6,366
55
7,437
Derivatives notional (£bn)
3.6
1,152.0
1,155.6
At December 2021 NatWest Group held certain cur
rency swaps with both legs subject to IBO
R reform, for which only the G
BP
LIBOR leg has an explicit or agreed conve
rsion provisions as of 31 December 2021
, but not the entire contract. These include
currency swaps of GBP LIBOR of £8
.7 billion with USD IBOR £8.2 billion and Other IBOR £0
.5 billion; currency swaps of USD IBO
R
of £117 billion with GBP LIBOR
£91.7 billion and Other IBOR £25
.3 billion; currency swaps of EURIBOR of £0
.1 billion with GBP
LIBOR £0.1 billion; currency swaps of Othe
r IBOR of £0.4 billion with USD IBOR £0.4 billion.
Notes to the c
onsolidated fi
nancial statement
s
NatWest Group
A
nnual Repor
t and Accou
nts 2021
336
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
10 Financial instruments - classification
continu
ed
Interest rate benchmark reform
Rates subject to IBOR reform
GBP LIBOR
USD IBOR
(1)
EURIBOR (2)
Other
IBOR
Total
2020
£m
£m
£m
£m
£m
Trading assets
75
60
348
1
484
Loans to banks - amortised cost
23
82
101
206
Loans to customers - amortised cost
40,299
6,366
4,950
234
51,849
Other financial assets
2,918
303
370
3,591
Bank deposits
367
107
474
Customer deposits
4
4
Trading liabilities
54
414
269
2
739
Other financial liabilities
2,492
9,806
5,902
196
18,396
Subordinated liabilities
8
850
438
1,296
Loan commitments
(3)
25,616
9,228
7,176
682
42,702
Derivatives notional (£bn)
1,407.5
1,368.8
2,358.7
289.6
5,424.6
(1)
In 2021 the FCA declared that USD IBOR will be
non-representative post 30 June 2023; at the time of preparing the 31 December 2020 Annual Reports & Accounts this date was
expected to be 31 December 2021.
(2)
In 2021 management concluded that E
URIBOR is not expected to be significantly reformed further and therefore any uncertainty due to interest benchmark rate reform for
EURIBOR has ended. 31 December 2020 data includes
EURIBOR exposure as subject to reform.
(3)
Certain loan commitments are multi-currency fa
cilities. Where these are fully undrawn, they are allocated to the principal currency of the facility. Where the facilities are partly
drawn, the remaining loan commitment is a
lloc
ated to the currency wit
h the largest drawn amount.
Included within the 31 Decemb
er 2020 table above for derivatives were currency s
waps with corresponding legs also subject
to
IBOR reform of GBP LIBOR of £5
.2 billion with USD IBOR £2.0 billion, EURIBOR £2.9
billion and Other IBOR £0.3 billion. Cur
rency
swaps of USD IBOR of £231.7 billion with GBP LIBOR £9
8.5 billion, EURIBOR £8
5.8 billion and Other IBOR £47.4 billion. Cur
rency
swaps of EURIBOR of £5.1 billio
n with GBP LIBOR £2.3 billion, USD IBOR £1.8 billion
and Other IBOR £1.0 billion. Currency s
waps
of Other IBOR of £2.2 billion with EUR
IBOR £0.7 billion, USD IBOR £1
.2 billion and Other IBOR £0.3 billion.
Additionally, included above are
basis swaps for GBP LIBOR of £97 billion, USD IBOR of
£81 billion, EURIBOR of £49 billion and
Other IBOR of £10 billion.
AT1 issuances
NatWest Group has issued certain capital inst
ruments, AT1, under which reset clauses are li
nked to IBOR rates subject to reform.
Where under the contractual terms of the instrumen
t the coupon resets to a rate which has IB
OR as a specified component of its
pricing structure, these are subject to IBOR reform an
d listed below:
31 December
31 December
2021
2020
£m
£m
US$1.15 billion 8% notes
734
734
US$2.65 billion 8.625% notes
2,046
NatWest Group‘s non-cumulative preference shares of
USD$0.01 Series U (£494
million) are also subject to IBOR reform.
Notes to the c
onsolidated fi
nancial statement
s
NatWest Group
A
nnual Repor
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nts 2021
337
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
11 Financial instruments - valuation
Financial instruments recognised at f
air value are revalued using techniques th
at can include observable inputs (pricing infor
mation
that is readily available in the market, for exa
mple UK Government securities), and unobse
rvable inputs (pricing information that is
not readily available, for example
unlisted securities). Gains and losses are recognised in
the income statement and state
ment of
comprehensive income as appr
opriate.
This note presents information on
the valuation of financial instruments.
The table below provides an overview of the
various sections contained within the note.
Critical accounting policy: Fair val
ue – financial instruments
Financial instruments classified as mand
atory fair value through profit or loss; held-fo
r-trading; designated fair value through profit
or loss and fair value through o
ther comprehensive income are recognised in
the financial statements at fair value. All deriv
atives
are measured at fair value.
Fair value is the price that would be received to sel
l an asset or paid to transfer a liability in
an orderly transaction between market
participants at the measurement date. A fai
r value measurement considers the characteris
tics of the asset or liability and th
e
assumptions that a market participan
t would consider when pricing the asset or liabili
ty.
NatWest Group manages some portfolios of financi
al assets and financial liabilities based on it
s net exposure to either market or
credit risk. In these cases, the fair value is
derived from the net risk exposure of that po
rtfolio with portfolio level adjustments
applied to incorporate bid-offer s
preads, counterparty credit risk, and funding cos
ts (see ‘Valuation Adjustments’).
Where the market for a financial instrumen
t is not active, fair value is established us
ing a valuation technique. These valuation
techniques involve a degree of
estimation, the extent of which depends on
the instrument’s complexity and the availabili
ty of
market-based data. The complexity and uncertainty in t
he financial instrument’s fair value is c
ategorised using the fair value
hierarchy.
For accounting policy information se
e Accounting policies notes 10 and 15.
Valuation
Fair value hierarchy
Financial instruments carried at f
air value have been classified
under the fair value hierarchy.
The classification ranges from
level 1 to level 3, with more expert judgment and price
uncertainly for those classified at level 3.
The determination of an instrument’s level ca
nnot be made at
a global product level as a single
product type can be in more
than one level. For example, a si
ngle name corporate credit
default swap could be in level 2 or level 3 dependi
ng on the
level of market activity for the re
ferenced entity
.
Level 1 – instruments valued usi
ng unadjusted quoted prices in
active and liquid markets, for id
entical financial instruments.
Examples include government bonds, listed e
quity shares and
certain exchange-traded derivatives.
Level 2 - instruments valued usi
ng valuation techniques that
have observable inputs. Observable inputs a
re those that are
readily available with limited adjus
tments required. Examples
include most government agency
securities, investment-grade
corporate bonds, certain mortgage products - includin
g CLOs,
most bank loans, repos and rev
erse repos, state and municipal
obligations, most notes issued, ce
rtain money market
securities, loan commitments and most OTC deriv
atives.
Level 3 - instruments valued usi
ng a valuation technique where
at least one input which could have a significan
t effect on the
instruments valuation, is not base
d on observable market data.
Examples include non-derivativ
e instruments which trade
infrequently, certain syndicated and comme
rcial mortgage
loans, private equity, and derivatives with unobserv
able model
inputs.
Page
Financial instrument
s
Critical accounting policy: Fair value
337
Valuation
Fair value hierarchy
(D)
337
Valuation techniques
(D)
338
Inputs to valuation models
(D)
338
Valuation control
(D)
338
Key areas of judgment
(D)
339
Table of assets and liabilities split by fair value
hierarchy level
(T)
340
Valuation adjustments
Table of fair value adjustments made
(T)
341
Funding valuation adjustments (FVA)
(D)
341
Credit valuation adjustments
(CVA)
(D)
341
Bid-offer
(D)
341
Product and deal specific
(D)
341
Own credit
(D)
3
41
Level 3 additional information
Level 3 ranges of unobservable i
nputs
(D)
342
Table of level 3 instruments, valuation
techniques and inputs
(T)
342
Level 3 sensitivities
(D)
343
Alternative assumptions
(D)
343
Other considerations
(D)
343
Table of high and low range of fair value of
level 3 assets and liabilities
(T)
343
Movement in level 3 assets and liabilities
over the reporting period
(D)
344
Table of the movement in level 3
assets and liabilities
344
Fair value of financial instruments me
asured
at amortised cost
Table showing the fair value
of financial instruments
measured at amortised cost on the balance s
heet
(T)
345
(D) = Descripti
ve; (T) = Table
Notes to the c
onsolidated fi
nancial statement
s
NatWest Group
A
nnual Repor
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nts 2021
338
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
11 Financial instruments – valuation
continued
Valuation techniques
NatWest Group derives the fair value of its instru
ments
differently depending on whether the instrument is
a non-
modelled or a modelled product.
Non-modelled products
are valued directly from
a price input,
typically on a position-by-position basis. Examples inclu
de
equities and most debt securities
.
Non-modelled products can fall into any fair value levelling
hierarchy depending on the obs
ervable market activity,
liquidity, and assessment of val
uation uncertainty of the
instruments. The assessment of
fair value and the classification
of the instrument to a fair value
level is subject to the valuation
controls discussed in the Valuation control sectio
n.
Modelled products
valued using a pricing
model range in
complexity from comparatively
vanilla products such as interest
rate swaps and options (e.g., interest rate caps and floo
rs)
through to more complex derivatives (e.g., balance gu
arantee
swaps).
For modelled products the fair value is derived using the
model
and the appropriate model inputs or
parameters, as opposed to
a cash price equivalent. Model inputs are t
aken either directly
or indirectly from available data, where some inpu
ts are also
modelled.
Fair value classification of modelled instruments is eithe
r level 2
or level 3, depending on the product/
model combination, the
observability and quality of input paramete
rs and other factors.
All these must be assessed to c
lassify a position. The modelled
product is assigned to the lowest fair value hierarc
hy level of
any significant input used in that valuation.
Most derivative instruments, for
example vanilla interest rate
swaps, foreign exchange swaps and liquid single n
ame credit
derivatives, are classified as level 2
. This is because they are
vanilla products valued using standard m
arket models and with
observable inputs. Level 2 prod
ucts range from vanilla to more
complex products, where more complex pro
ducts remain
classified as Level 2 due to the materiality of any un
observable
inputs.
Inputs to valuation models
When using valuation techniques, the fair value can be
significantly affected by the choice of valuation
model and
underlying assumptions. Factors considered include
the
cashflow amounts and timing of
those cash flows, and
application of appropriate discount rates, incorpor
ating both
funding and credit risk. Values between and beyond
available
data points are obtained by int
erpolation and extrapolation.
The principal inputs to these valuation techniques
are as
follows:
Bond prices - quoted prices are gene
rally available for
government bonds, certain corporate securities,
and some
mortgage-related products.
Credit spreads - these express the return require
d over a
benchmark rate or index to compensate for
the referenced
credit risk. Where available, thes
e are derived from the price of
credit default swaps or other cr
edit-based instruments, such as
debt securities. When direct price
s are not available; credit
spreads are determined with reference to available prices of
entities with similar characteris
tics.
Interest rates - these are principally based on in
terest rate
swap prices referencing benchmark interest rates. Be
nchmark
rates include Interbank Offered Rates (IBOR)
and the Overnight
Index Swap (OIS) rate, including SONIA (Sterlin
g Overnight
Interbank Average Rate). Other quoted interest
rates may also
be used from both the bond, and futures marke
ts.
Foreign currency exchange rates - there are obser
vable prices
both for spot and forward contracts and futures in
the world's
major currencies.
Equity and equity index prices - quoted prices a
re generally
readily available for equity share
s listed on the world's major
stock exchanges and for major indices on such sha
res.
Price volatilities and correlations
- volatility is a measure of the
tendency of a price to change
with time. Correlation measures
the degree which two or more prices or va
riables are observed
to move together. Variables that move in the s
ame direction
show positive correlation; those that m
ove in opposite
directions are negatively correl
ated.
Prepayment rates - rates used to reflect how fast
a pool of
assets prepay. The fair value of
a financial instrument that can
be prepaid by the issuer or borrower diff
ers from that of an
instrument that cannot be prepaid. When valui
ng prepayable
instruments, the value of this pre
payment option is considered.
Recovery rates/loss given defa
ult - these are used as an input
to valuation models and reserv
es for asset-backed securities
and other credit products as an indicator of se
verity of losses
on default. Recovery rates are prima
rily sourced from market
data providers, the value of the underlying collate
ral, or
inferred from observable credit spreads.
Valuation control
NatWest Group's control environment for the deter
mination of
the fair value of financial instruments includes fo
rmalised
procedures for the review and validation of fair values. T
his
review is performed by an independent
price verification (IPV)
team.
IPV is a key element of the control envi
ronment. Valuations are
first performed by the business which entered in
to the
transaction. These valuations are then reviewed by
the IPV
team, independent of those trading the financi
al instruments, in
light of available pricing evidence
.
Independent pricing data is collated from a range of sou
rces.
Each source is reviewed for quality and the independen
t data
applied in the IPV processes using a formalise
d input quality
hierarchy. Consensus services are one sou
rce of independent
data and encompass interest rate, currency, credi
t, and bond
markets, providing comprehensive
coverage of vanilla products
and a wide selection of exotic products.
Where measurement differences
are identified through the IPV
process these are grouped by the
quality hierarchy of the
independent data. If the size of the difference exce
eds defined
thresholds, an adjustment is made to bring the valu
ation to
within the independently calcul
ated fair value range.
IPV takes place at least monthly, for all fair value f
inancial
instruments. The IPV control inclu
des formalised reporting and
escalation of any valuation differences
in breach of established
thresholds.
Notes to the c
onsolidated fi
nancial statement
s
NatWest Group
A
nnual Repor
t and Accou
nts 2021
339
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
11 Financial instruments – valuation
continued
The quality and completeness of
the information gathered in
the IPV process gives an indication as to the liquidi
ty and
valuation uncertainty of an inst
rument and forms part of the
information considered when de
termining fair value hierarchy
classifications.
Initial fair value level classification of a fin
ancial instrument is
carried out by the IPV team. These
initial classifications are
subject to senior management review. P
articular attention is
paid to instruments transferring fro
m one level to another, new
instrument classes or products,
instruments where the
transaction price is significantly diff
erent from the fair value
and instruments where valuation uncertain
ty is high.
Valuation Committees are made u
p of valuation specialists and
senior business representatives f
rom various functions and
oversees pricing, reserving and valuations issues
. These
committees meet monthly to review an
d ratify any
methodology changes. The Executive Valuation Com
mittee
meets quarterly to address key material an
d subjective
valuation issues, to review items
escalated by Valuation
Committees and to discuss other relevant indust
ry matters.
The Group model risk policy se
ts the policy for model
documentation, testing and review. Governa
nce of the model
risk policy is carried out by the
Group model risk oversight
committee, which comprises model risk owners and
independent model experts. All
models are required to be
independently validated in accordance with the Model Ris
k
Policy.
Key areas of judgment
Over the years the business ha
s simplified, with most products
classified as level 1 or 2 of the fair value hier
archy. However,
the diverse range of products h
istorically traded by NatWest
Group means some products remain classifi
ed as level 3. Level
3 indicates a significant level of
pricing uncertainty, where
expert judgment is used. As su
ch, extra disclosures are
required in respect of level 3 instruments
.
Over the years the business ha
s simplified, with most products
classified as level 1 or 2 of the fair value hier
archy. However,
the diverse range of products h
istorically traded by NatWest
Group means some products remain classifi
ed as level 3. Level
3 indicates a significant level of
pricing uncertainty, where
expert judgment is used. As su
ch, extra disclosures are
required in respect of level 3 instruments
.
In general, the degree of expert judgment used
and hence
valuation uncertainty depends on the degree of
liquidity of an
instrument or input.
Where markets are liquid, little judgmen
t is required. However,
when the information regarding the liquidity in
a particular
market is not clear, a judgment may need
to be made. For
example, for an equity traded on an exchange, daily v
olumes of
trading can be seen, but for an over the counte
r (OTC)
derivative, assessing the liquidity of
the market with no central
exchange is more challenging.
A key related matter is where a market moves fr
om liquid to
illiquid or vice versa. Where this movement is conside
red
temporary, the fair value level is
not changed. For example, if
there is little market trading in a product on a repo
rting date
but at the previous reporting date and during the in
tervening
period the market has been liquid. In
this case, the instrument
will continue to be classified at the same level in
the hierarchy.
This is to provide consistency so that transfe
rs between levels
are driven by genuine changes
in market liquidity and do not
reflect short term or seasonal e
ffects. Material movements
between levels are reviewed quarterly by the B
usiness and IPV.
The breadth and depth of the IPV data allows fo
r a rules-based
quality assessment to be made of
market activity, liquidity, and
pricing uncertainty, which assists with the process of alloc
ation
to an appropriate level. Where s
uitable independent pricing
information is not readily available, the quality assess
ment will
result in the instrument being ass
essed as level 3.
Notes to the c
onsolidated fi
nancial statement
s
NatWest Group
A
nnual Repor
t and Accou
nts 2021
340
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
11 Financial instruments - valuation
continued
The table below shows the asse
ts and liabilities held by NatWest Group split by fair value hie
r
archy level. Level 1 are considered
the most liquid instruments, and level 3 the mos
t illiquid, valued using expert judgment and he
nce carry the most significant price
uncertainty.
2021
2020
Level 1
Level 2
Level 3
Total
Level 1
Level 2
Le
vel 3
Total
£m
£m
£m
£m
£m
£m
£m
£m
Assets
Trading assets
Loans
33,482
721
34,203
39,550
225
39,775
Securities
19,563
5,371
21
24,955
21,535
7,599
81
29,215
Derivatives
105,222
917
106,139
165,441
1,082
166,523
Other financial assets
Loans
359
207
566
185
168
353
Securities
28,880
7,951
186
37,017
35,972
8,850
167
44,989
Total financial assets held at fair
value
48,443
152,385
2,052
202,880
57,507
221,625
1,723
280,855
As % of total fair value assets
24%
75%
1%
20%
79%
1%
Liabilities
Trading liabilities
Deposits
38,658
2
38,660
44,062
7
44,069
Debt securities in issue
974
974
1,408
1,408
Short positions
20,507
4,456
1
24,964
19,045
7,734
26,779
Derivatives
100,229
606
100,835
159,818
887
160,705
Other financial liabilities
Debt securities in issue
1,103
1,103
1,607
1,607
Other deposits
568
568
796
796
Subordinated liabilities
703
703
793
793
Total financial liabilities held at fair
value
20,507
146,691
609
167,807
19,045
216,218
894
236,157
As % of total fair value liabilities
12%
88%
0%
8%
92%
0%
(1)
Transfers between levels a
re deemed to have occurred at the beginning of the quarter in which the instrument was transferred.
(2)
For an analysis of debt securities held at mandatory fair value th
rough profit or loss by issuer as well as ratings and derivatives, by type and contract, refer to Risk and capital
management – Credit risk.
Notes to the c
onsolidated fi
nancial statement
s
NatWest Group
A
nnual Repor
t and Accou
nts 2021
341
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
11 Financial instruments – valuation
continued
Valuation adjustments
When valuing financial instruments in the tradin
g book,
adjustments are made to mid-market valua
tions to cover bid-
offer spread, funding and credit risk. These adjust
ments are
presented in the table below:
Adjustment
2021
£m
2020
£m
Funding – FVA
90
140
Credit – CVA
390
390
Bid – Offer
113
148
Product and deal
specific
119
172
712
850
There was a reallocation of FVA to CVA during
the period
following an update to the risk manageme
nt of certain
exposures. The net decrease across CVA an
d FVA was driven
by reduced exposures, due to increases in interest
rates and
trade exit activity. The reduction in bid-off
er and product and
deal specific reserves followed reduced risk due
to trade exit
activity and LIBOR cessation.
Funding valuation adjustments (FVA)
FVA represents an estimate of the adjustmen
t that a market
participant would make to incorporate funding cos
ts and
benefits that arise in relation to derivative exposures. FVA is
calculated as a portfolio level adjustment and can result i
n
either a funding charge (positive) or funding benefit (
negative).
Funding levels are applied to estimated poten
tial future
exposures. For uncollateralised derivatives, the e
xposure
reflects the future valuation of the deriv
ative. For collateralised
derivatives, the exposure reflects the difference bet
ween the
future valuation of the derivativ
e and the level of collateral
posted.
Credit valuation adjustments (CVA)
CVA represents an estimate of the adjustment to fair
value that
is made to incorporate the counterparty credit
risk inherent in
derivative exposures. CVA is actively manage
d by a credit and
market risk hedging process, and the
refore movements in CVA
are partially offset by trading revenue
on the hedges.
The CVA is calculated on a portfolio basis refle
cting an
estimate of the amount a third party would cha
rge to assume
the credit risk.
Collateral held under a credit support agreemen
t is factored
into the CVA calculation. In such cases
where NatWest Group
holds collateral against counterparty exposu
res, CVA is held to
the extent that residual risk remains.
Bid-offer
Fair value positions are required to be marked to e
xit,
represented by bid (long positions) or offer (short pos
itions)
levels. Non-derivative positions
are typically marked directly to
bid or offer prices. However de
rivative exposures are adjusted
to exit levels by taking bid-offer
reserves calculated on a
portfolio basis. The bid-offer approach is b
ased on current
market spreads and standard market bucketing of
risk.
Bid-offer spreads vary by maturity and risk type to ref
lect
different spreads in the market.
For positions where there is no
observable quote, the bid-offer spreads are wi
dened in
comparison to proxies to reflect reduced li
quidity or
observability.
Netting is applied on a portfolio basis to refle
ct the value at
which NatWest Group believes it could exi
t the net risk of the
portfolio, rather than the sum of
exit costs for each of the
portfolio’s individual trades. This i
s applied where the asset and
liability positions are managed as a portfolio for risk an
d
reporting purposes.
Product and deal specific
On initial recognition of financial assets and lia
bilities valued
using valuation techniques which have
a significant
dependence on information othe
r than observable market data,
any difference between the transaction price and
that derived
from the valuation technique is
deferred. Such amounts are
recognised in the income statement ove
r the life of the
transaction; when market data becomes observable; o
r when
the transaction matures or is close
d out as appropriate. On 31
December 2021, net gains of £7
1 million (2020 - £63 million)
were carried forward. During the y
ear, net gains of £103 million
(2020 - £75 million) were deferr
ed and £94 million (2020 - £100
million) were recognised in the i
ncome statement.
Where system generated valuations do not accur
ately recover
market prices, manual valuation adjustmen
ts are applied either
at a position or portfolio level. Manual adjustmen
ts are subject
to the scrutiny of independent c
ontrol teams and are subject to
monthly review by senior management.
Own Credit
NatWest Group considers the eff
ect of its own credit standing
when valuing financial liabilities recorded a
t fair value. Own
credit spread adjustments are made when valuing issued deb
t
held at fair value, including issue
d structured notes. An own
credit adjustment is applied to positions where it is
believed
that counterparties would consi
der NatWest Group’s
creditworthiness when pricing trades.
Notes to the c
onsolidated fi
nancial statement
s
NatWest Group
A
nnual Repor
t and Accou
nts 2021
342
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
11 Financial instruments - valuation continued
Level 3 additional information
For illiquid assets and liabilities, classifie
d as level 3, additional information is provided on
the valuation techniques used and
price
sensitivity of the products to those inputs. This is to en
able the reader to gauge the level of un
certainty that arises from positions
with significant unobservable in
puts or modelling parameters.
Level 3 ranges of unobservable inputs
The table below provides additional information on level 3 ins
truments and inputs. This shows the valuation techni
que used for the
fair value calculation, the unob
servable input or inputs and input range.
2021
202
0
Financial instrument
Valuation technique
Unobservable inputs
Units
Low
High
Low
High
Trading assets
and Other financia
l assets
Loans
Price-bas
ed
P
rice
%
106
105
D
iscount cas
h flow
Credit spreads
bps
40
102
69
119
D
iscount cas
h flow
D
iscount margi
n
bps
46
55
51
226
Debt securities
Price-based
Price
%
240
232
Equity Shares
Price-b
ased
Price
GBP
30,378
27,737
Price-based
P
rice
%
7
80
D
iscount cas
h flow
D
iscount margi
n
%
6
8
7
9
Net asset valuation
Net asset value
%
80
120
80
120
Derivative asset
s and liabilities
Credit derivatives
Credit derivative pricing
Credit spreads
bps
6
635
2
500
Correlati
on
%
(15)
95
(
50)
95
Volat
ility
%
30
108
27
80
Up
front points
%
100
100
Rec
overy rate
%
60
10
40
Interest rate & F
X
Option pricing
Correlation
%
(50)
100
(
50)
100
derivatives
Volatility
%
17
77
17
60
Constant Prepay
ment
Rate
%
2
16
2
18
Mean Re
version
%
92
92
Bas
is volatility
bp
s
8
18
15
21
Inflatio
n volatility
%
1
2
1
2
Inflatio
n rate
%
2
3
1
2
Equity derivatives
Option pricing
Correlation
%
(53)
87
(53)
87
(1)
Valuation for private equity investments may be estimated by
looking at past prices of simil
ar stocks
and from valuation statements where valuations are usually derived from
earnings measures such as EBITDA or net asset value (NA
V). Similarly,
for equity or
bond fund investments, prices may be estimated from valuation or credit statements using
NAV
or similar measures.
(2)
NatWest Group does not have any mat
erial liabilities measured at fair value that are issued with an inseparable third-party credit enhancement.
Notes to the c
onsolidated fi
nancial statement
s
NatWest Group
A
nnual Repor
t and Accou
nts 2021
343
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
11 Financial instruments – valuation continued
Level 3 sensitivities
The level 3 sensitivities presente
d below are calculated at a
trade or low-level portfolio basi
s rather than an overall portfolio
basis. As individual sensitivities
are aggregated with no
reflection of the correlated natu
re between instruments, the
overall portfolio sensitivity may not be
accurately reflected. For
example, some portfolios may be negatively cor
related to
others, where a downwards movement in one asse
t would
produce an upwards movement in another. However,
due to
the additive presentation of the above figures this co
rrelation
impact cannot be displayed. As such, the actual poten
tial
downside sensitivity of the total portfolio may be le
ss than the
non-correlated sum of the additive figures as shown in
the
below table.
Alternative assumptions
Reasonably plausible alternative
assumptions of unobservable
inputs are determined based on a specif
ied target level of
certainty of 90%.
Alternative assumptions are determined wi
th reference to all
available evidence including consideration of the followin
g:
quality of independent pricing information conside
ring
consistency between different s
ources, variation over time,
perceived tradability or otherwise of
available quotes;
consensus service dispersion ranges; volume of
trading activity
and market bias (e.g. one-way inventory); day 1
profit or loss
arising on new trades; number
and nature of market
participants; market conditions; modelling
consistency in the
market; size and nature of risk; length of holdin
g of position;
and market intelligence.
Other considerations
Whilst certain inputs used to ca
lculate CVA, FVA and own
credit adjustments are not base
d on observable market data,
the uncertainty of these inputs i
s not considered to have a
significant effect on the net valuation of the
related derivative
portfolios and issued debt.
As such, the fair value levelling of the derivative po
rtfolios and
issued debt is not determined by
CVA, FVA or own credit
inputs. In addition, any fair value s
ensitivity driven by these
inputs is not included in the level 3 s
ensitivities presented.
The table below shows the high and low
range of fair value of the level 3 assets and liabili
ties. This range incorporates the range of
fair value inputs as described in the p
revious table.
2021
2020
Level 3
Favourable
Unfa
vourable
Level 3
F
avourable
Unfavourable
£m
£m
£m
£m
£m
£m
Assets
Trading assets
Loans
721
10
(10)
225
10
Securities
21
81
Derivatives
917
60
(70)
1,082
80
(80)
Other financial assets
Loans
207
10
(10)
168
20
(10)
Securities
186
20
(20)
167
30
(20)
2,052
100
(110)
1,723
140
(110)
Liabilities
Trading liabilities
Deposits
2
7
Debt securities in issue
Short positions
1
-
-
Derivatives
606
30
(30)
887
50
(40)
Other financial liabilities
609
30
(30)
894
50
(40)
Notes to the c
onsolidated fi
nancial statement
s
NatWest Group
A
nnual Repor
t and Accou
nts 2021
344
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
11 Financial instruments – valuation continued
Movement in level 3 assets and liabilities
The following table shows the movement in level 3 asse
ts and liabilities in the year.
2021
2020
Trading
Other
Trading
Other
assets
financial
Total
Total
assets
financial
T
otal
Total
(2)
assets (3)
a
ssets
liabilities
(2)
assets (3)
assets
liabilities
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January
1,388
335
1,723
894
2,233
321
2,554
1,317
Amounts recorded in the income
statement
(1)
(93)
(29)
(
122)
(90)
127
(21)
106
(67)
Amounts recorded in the statement of
comprehensive income
23
23
63
63
Level 3 transfers in
125
3
128
20
165
98
263
188
Level 3 transfers out
(104)
(6)
(109)
(168)
(139)
(139)
(368)
Purchases/originations
(4)
965
452
1,416
305
441
327
768
127
Settlements/other decreases
(47)
(
364)
(411)
(28)
(293)
(153)
(446)
(
59)
Sales
(573)
(17)
(
590)
(321)
(1,148)
(301)
(1,449)
(245)
Foreign exchange and other
(3)
(3)
(6)
(3)
2
1
3
1
At 31 December
1,658
394
2,052
609
1,388
335
1,723
894
Amounts recorded in the income
statement in respect
of balances held at year end - unrealised
(93)
(32)
(
126)
(90)
129
(22)
107
(68)
(1)
There were £3 million net losses on trading ass
ets and liabilities (2020 – £194 million net gain) recorded in income from trading activities. Net losses on other instruments of £29
million (2020 – £21 million net losses) were recorded in
other operating income and interest income as appropriate.
(2)
Trading assets comprise assets held at fair
value in trading portfolios.
(3)
Other financial assets comprise fair
value through other comprehensive income, designated as at fair value through profit or loss and other fair value through profit
or loss.
(4)
Movement in the period includes new
loan originations classified as HTC&S under IFRS 9 and fair valued through other comprehensive income. 2021 purchases include a new
leveraged finance loan of £450 million. As a result of
its composition and illiquid nature, pricing is based on unobservable inputs and the judgment of valuation experts.
Notes to the c
onsolidated fi
nancial statement
s
NatWest Group
A
nnual Repor
t and Accou
nts 2021
345
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
11 Financial instruments - valuation continued
Fair value of financial instruments measured at amortised cost on the balance sheet
The following table shows the carrying value an
d fair value of financial instruments measu
red at amortised cost on the balance
sheet.
Fair value hierarchy level
Items where
fair value
approximates
Carry
ing
Fair
carrying value
value
value
Level 1
Level 2
Level 3
2021
£bn
£bn
£bn
£bn
£b
n
£bn
Financial assets
Cash and balances at central banks
177.8
Settlement balances
2.1
Loans to banks
0.1
7.5
7.5
5.0
2.5
Loans to customers
359.0
354.1
28.0
326.1
Other financial assets - securities
8.6
8.6
4.4
0.7
3.5
2020
Financial assets
Cash and balances at central banks
124.5
Settlement balances
2.3
Loans to banks
0.1
6.9
6.9
3.8
3.1
Loans to customers
360.5
359.2
25.2
334.0
Other financial assets - securities
9.8
10.1
5.9
1.2
3.0
2021
Financial liabilities
Bank deposits
4.9
21.4
21.0
18.7
2.3
Customer deposits
442.4
37.4
37.6
18.1
19.5
Settlement balances
2.1
Other financial liabilities - debt sec
urities in issue
47.7
48.6
41.4
7.2
Subordinated liabilities
7.7
8.3
8.2
0.1
Notes in circulation
3.0
2020
Financial liabilities
Bank deposits
4.4
16.2
16.2
11.3
4.9
Customer deposits
371.7
60.0
60.1
10.1
50.0
Settlement balances
5.5
Other financial liabilities - debt sec
urities in issue
43.4
44.6
34.7
9.9
Subordinated liabilities
9.2
9.8
9.7
0.1
Notes in circulation
2.7
The assumptions and methodol
ogies underlying the calculation
of fair values of financial instru
ments at the balance sheet date
are as follows:
Short-term financial instruments
For certain short-term financial instruments: c
ash and balances
at central banks, items in the course of colle
ction from other
banks, settlement balances, items in the c
ourse of transmission
to other banks, customer dema
nd deposits and notes in
circulation, carrying value is de
emed a reasonable
approximation of fair value.
Loans to banks and customers
In estimating the fair value of net loans to custo
mers and banks
measured at amortised cost, NatWest Group’s lo
ans are
segregated into appropriate portfolios
reflecting the
characteristics of the constituent loans. Two p
rincipal methods
are used to estimate fair value:
(a)
Contractual cash flows are discounted using
a market
discount rate that incorporates the cur
rent spread for the
borrower or where this is not obse
rvable, the spread for
borrowers of a similar credit standing. This met
hod is used
for portfolios where counterpar
ties have external ratings:
institutional and corporate lend
ing.
(b)
Ex
pected cash flows (una
djusted for credit losses) are
discounted at the current offer rate for the same or simil
ar
products. The current methodology caps all l
oan values at
par rather than modelling clients’ option t
o repay loans
early. This approach is adopted f
or lending portfolios in
Retail Banking, Ulster Bank RoI, Comme
rcial Banking (SME
loans) and Private Banking in order to
reflect the
homogeneous nature of these portfolios.
Debt securities and subordinated liabili
ties
Most debt securities are valued
using quoted prices in active
markets
or from quoted prices of similar financi
al instruments
in active markets. Fair values of the remaining po
pulation are
determined using market standard valu
ation techniques, such
as discounted cash flows, adjusting for own credi
t spreads
where appropriate.
Bank and customer deposits
Fair values of deposits are estimated using discounted cash
flow valuation techniques. Where require
d, methodologies
can be revised as additional information and valuation
inputs become available.
Notes to the c
onsolidated fi
nancial statement
s
NatWest Group
A
nnual Repor
t and Accou
nts 2021
346
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
12 Financial instruments - maturity analy
sis
Remaining maturity
This note shows the maturity profile of NatWes
t Group’s financial assets and liabilities by
contractual da
te of maturity and
contractual cash flows.
The following table shows the r
esidual maturity of financial instruments, based on c
ontractual date of maturity.
2021
2020
Less than
More than
Less than
More t
han
12 months
12 months
Total
12 months
12
months
T
otal
£m
£m
£m
£m
£m
£m
Assets
Cash and balances at central banks
177,757
177,757
124,489
124,489
Trading assets
40,263
18,895
59,158
42,037
26,953
68,990
Derivatives
34,538
71,601
106,139
46,244
120,279
166,523
Settlement balances
2,141
2,141
2,297
2,297
Loans to banks
-
amortised cost
7,425
257
7,682
6,835
120
6,955
Loans to customers - amortised cost
103,689
255,301
358,990
87,531
273,013
360,544
Other financial assets
11,151
34,994
46,145
8,901
46,247
55,148
Liabilities
Bank deposits
13,715
12,564
26,279
12,315
8,291
20,606
Customer deposits
478,801
1,009
479,810
430,283
1,456
431,739
Settlement balances
2,068
2,068
5,545
5,545
Trading liabilities
41,664
22,934
64,598
45,037
27,219
72,256
Derivatives
34,593
66,242
100,835
47,361
113,344
160,705
Other financilal liabilities
16,060
33,266
49,326
12,403
33,408
45,811
Subordinated liabilities
1,375
7,054
8,429
365
9,597
9,962
Notes in circulation
3,047
3,047
2,655
2,655
Lease liabilities
238
1,025
1,263
185
1,513
1,698
Assets and liabilities by contractual cash flows up to 20
years
The tables on the following page
, show the contractual
undiscounted cash flows receivable and payable, up
to a period
of 20 years, including future receipts and pay
ments of interest
of financial assets and liabilities by contractual
maturity. The
balances in the following tables do not agree direc
tly with the
consolidated balance sheet, as the t
ables include all cash flows
relating to principal and future coupon paymen
ts, presented on
an undiscounted basis. The table
s have been prepared on the
following basis:
Financial assets have been reflected in the time b
and of the
latest date on which they could be repaid, unless e
arlier
repayment can be demanded by NatWest Group. Fi
nancial
liabilities are included at the earliest date on which
the
counterparty can require repay
ment, regardless of whether or
not such early repayment results in a pe
nalty. If the repayment
of a financial instrument is triggered by, or is subject
to, specific
criteria such as market price hurdles being reached,
the asset
is included in the time band that contains
the latest date on
which it can be repaid, regardles
s of early repayment.
The liability is included in the ti
me band that contains the
earliest possible date on which the condi
tions could be fulfilled,
without considering the probability of the con
ditions being met.
For example, if a structured no
te is automatically prepaid when
an equity index exceeds a certain level, the c
ash outflow will be
included in the less than three months period, wha
tever the
level of the index at the year end. The se
ttlement date of debt
securities in issue, issued by ce
rtain securitisation vehicles
consolidated by NatWest Group, depends on
when cash flows
are received from the securitised assets. Where these
assets
are prepayable, the timing of t
he cash outflow relating to
securities assumes that each asse
t will be prepaid at the
earliest possible date. As the repayments of asse
ts and
liabilities are linked, the repayment of assets in securi
tisations is
shown on the earliest date that the asset ca
n be prepaid, as
this is the basis used for liabilities.
The principal amounts of financial assets and liabilities th
at are
repayable after 20 years or where the coun
terparty has no
right to repayment of the principal are excluded f
rom the table,
as are interest payments after 20
years.
The maturity of guarantees and com
mitments is based on the
earliest possible date they would be drawn in o
rder to evaluate
NatWest Group’s liquidity position.
MFVTPL assets of £165.6 billion (2
020 - £235.9 billion) and HFT
liabilities of £165.3 billion (2020 - £2
32.8 billion) have been
excluded from the following tables.
Notes to the c
onsolidated fi
nancial statement
s
NatWest Group
A
nnual Repor
t and Accou
nts 2021
347
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
12 Financial instruments – maturity analy
sis
continued
0-3 months
3-1
2 months
1-3 years
3-
5 years
5-
10 years
10-
20 years
2021
£m
£m
£m
£m
£m
£m
Assets by contractual maturity up to 20 ye
ars
Cash and balances at central banks
177,757
Derivatives held for hedging
(23)
(32)
72
15
10
17
Settlement balances
2,141
Loans to banks - amortised cost
5,735
1,689
21
Loans to customers - amortised cost
65,760
43,144
63,979
45,057
73,044
90,115
Other financial assets
(1)
3,924
7,576
10,467
8,048
7,444
5,523
Finance lease
290
340
746
504
704
377
255,584
52,717
75,285
53,624
81,202
96,032
Liabilities by contractual maturity up to 20 ye
ars
Bank deposits
13,292
421
566
12,003
Customer deposits
473,123
5,440
1,155
73
4
19
Settlement balances
2,068
Derivatives held for hedging
(57)
(31)
561
155
(152)
(198)
Other financial liabilities
6,967
9,293
16,953
10,062
7,905
292
Subordinated liabilities
66
1,604
3,481
2,170
1,496
563
Other liabilities- Notes in circulation
3,047
Lease liabilities
74
161
220
167
281
251
498,580
16,888
22,936
24,630
9,534
927
Guarantees and commitments - notional amou
nt
Guarantees
(2)
2,055
Commitments
(3)
118,536
120,591
2020
Assets by contractual maturity up to 20 ye
ars
Cash and balances at central banks
124,489
Derivatives held for hedging
14
18
96
12
6
Settlement balances
2,297
Loans to banks - amortised cost
5,600
1,245
1
110
Loans to customers
-
amortised cost
47,507
46,718
65,138
58,680
81,544
88,155
Other financial assets
(1)
4,019
5,919
12,592
10,791
11,855
5,774
Finance lease
48
366
840
671
895
545
183,974
54,266
78,666
70,142
94,307
94,590
Liabilities by contractual maturity up to 20 ye
ars
Bank deposits
11,217
1,078
3,241
5,038
Customer deposits
421,763
8,528
1,407
23
26
20
Settlement balances
5,545
Derivatives held for hedging
36
(17)
94
3
64
(2)
Other financial liabilities
4,716
8,144
15,558
11,470
7,358
254
Subordinated liabilities
73
685
4,387
3,444
923
562
Other liabilities- Notes in circulation
2,655
Lease liabilities
51
135
294
245
429
497
446,056
18,553
24,981
20,223
8,800
1,331
Guarantees and commitments - notional amou
nt
Guarantees
(2)
2,244
Commitments
(3)
121,922
124,166
(1)
Other financial assets excludes
equity shares.
(2)
NatWest Group is on
ly called upon to satisfy a guarantee when the guaranteed party fails to meet its obligations. NatWest Group expects most guarantees it provides to expire
unused.
(3)
NatWest Group has given commitments to
provide funds to customers under undrawn formal facilities, credit lines and other commitments to lend subject to certain conditions being
met by the counterparty. NatWest Group does not expect a
ll facilities to be drawn, and some may lapse before drawdown
.
Notes to the c
onsolidated fi
nancial statement
s
NatWest Group
A
nnual Repor
t and Accou
nts 2021
348
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
13 Trading assets and liabili
ties
Trading assets and liabilities comprise asse
ts and liabilities held at fair value and classified as held-for-tradi
ng. Financial
instruments are classified as held for trading if they a
re held for the purpose of se
lling or repurchasing them in the short term
, to
make a spread between purchase and sale price or held to take advantage
of movements in prices and yields.
For accounting policy information se
e Accounting policies note 10.
2021
2020
Assets
£m
£m
Loans
Reverse repos
20,742
19,404
Collateral given
12,047
18,760
Other loans
1,414
1,611
Total loans
34,203
39,775
Securities
Central and local government
- UK
6,919
4,184
-
US
3,329
5,149
- other
10,929
16,436
Financial institutions and corporate
3,778
3,446
Total securities
24,955
29,215
Total
59,158
68,990
Liabilities
Deposits
Repos
19,389
19,036
Collateral received
17,718
23,229
Other deposits
1,553
1,804
Total deposits
38,660
44,069
Debt securities in issue
974
1,408
Short positions
24,964
26,779
Total
64,598
72,256
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
349
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
14 Derivatives
Derivative is a term covering a wide range of fina
ncial instruments that derive their
fair v
alue from an underlying rate or price, for
example interest rates or exchange rates (
the underlying). NatWest Group uses deriv
atives as a part of its trading activities, to
manage its own risks such as interest
rate, foreign exchange, or credit risk and in cer
tain customer transactions. This note
shows
contracted volumes of derivatives, how they are use
d for hedging purposes and more specifically the ef
fects of the application of
hedge accounting.
For accounting policy information se
e Accounting policies note 10 and 15.
2021
2020
Notional
Assets
L
iabilities
Notional
Ass
ets
Liabilities
£bn
£m
£m
£bn
£m
£m
Exchange rate contracts
3,167
38,517
39,286
3,328
52,239
55,107
Interest rate contracts
8,919
67,458
61,206
10,703
114,115
105,214
Credit derivatives
14
154
343
15
161
376
Equity and commodity contracts
10
1
8
8
106,139
100,835
166,523
160,705
NatWest Group applies hedge acc
ounting to reduce the
accounting mismatch caused in the inco
me statement by using
derivatives to hedge the following risks: in
terest rate, foreign
exchange and net investment in f
oreign operations.
NatWest Group’s interest rate he
dging relates to the
management of NatWest Group’s non-
trading structural
interest rate risk, caused by the mismatch be
tween fixed
interest rates and floating interes
t rates on its financial
instruments. NatWest Group manages
this risk within approved
limits. Residual risk positions are hedged with deri
vatives,
principally interest rate swaps.
Suitable larger fixed rate financial instruments a
re subject to
fair value hedging; the remaining exposu
re, where possible, is
hedged by derivatives designated as cash flow hedges.
Cash flow hedges of interest rate risk relate to exposu
res to the
variability in future interest payments and
receipts due to the
movement of benchmark interest rates on fo
recast transactions
and on financial assets and financial lia
bilities. This variability in
cash flows is hedged by interest rate swaps, whic
h convert
variable cash flows into fixed. For these cash flow hed
ge
relationships, the hedged items are actual and fo
recast variable
interest rate cash flows arising f
rom financial assets and
financial liabilities with interest rates linked to the relev
ant
benchmark rates, most notably LIBO
R, EURIBOR, SONIA and
the Bank of England Official Bank Rate. The v
ariability in cash
flows due to movements in the
relevant benchmark rate is
hedged; this risk component is identified usi
ng the risk
management systems of NatWest Group and enco
mpasses the
majority of cash flow variability risk.
Fair value hedges of interest rate risk invol
ve interest rate
swaps transforming the fixed interest rate risk in fin
ancial
assets and financial liabilities to floating. The he
dged risk is the
risk of changes in the hedged item’s fair value att
ributable to
changes in the benchmark inte
rest rate risk component of the
hedged item. The significant benchmarks iden
tified as risk
components are LIBOR, EURIBO
R and SONIA. These risk
components are identified usin
g the risk management systems
of NatWest Group and encompass the majo
rity of the hedged
item’s fair value risk.
NatWest Group hedges the exchange rate risk of its
net
investment in foreign currency denominated
operations with
currency borrowings and forw
ard foreign exchange contracts.
NatWest Group reviews the value
of the investments’ net
assets, executing hedges wher
e appropriate to reduce the
sensitivity of capital ratios to foreign exch
ange rate movement.
Hedge accounting relationships
will be designated where
required.
Exchange rate risk also arises in NatWes
t Group where
payments are denominated in currencies other
than the
functional currency. Residual risk positions are hed
ged with
forward foreign exchange contracts, fixing the exch
ange rate
the payments will be settled in.
The derivatives are documented
as cash flow hedges.
For all cash flow hedging and fair value hedge
relationships,
and net investment hedging, NatWest G
roup determines that
there is an adequate level of offs
etting between the hedged
item and hedging instrument at
inception and on an ongoing
basis. This is achieved by comparing movemen
ts in the fair
value of the expected highly probable forecast interest c
ash
flows/fair value of the hedged item attributable to the hed
ged
risk with movements in the fair value of the ex
pected changes
in cash flows from the hedging interest rate swa
p. Hedge
effectiveness is asse
ssed on a cumulative basis over a time
period management determines
to be appropriate. NatWest
Group uses either the actual ratio betwee
n the hedged item
and hedging instrument(s) or one that minimises hedge
ineffectiveness to establish the hedge r
atio for hedge
accounting. Hedge ineffectivene
ss is measured and recognised
in the income statement as it arises.
IBOR reform - NatWest Group in the year conti
nued to apply,
for relationships directly affected by interest rate benc
hmark
reform, Interest Rate Benchmark Reform Amen
dments to IAS
39 and IFRS 7 issued September 201
9 (“Phase 1 relief”) and
Interest Rate Benchmark Refor
m – Phase 2 Amendments to IAS
39 and IFRS 7 issued August 202
0 (“Phase 2 relief”).
Significant transitions in the year we
re the GBP, JPY and CHF
derivatives subject to cash flow and fair v
alue hedging
transitioned as part of the LCH ‘big b
ang’ conversion in
December 2021. The swaps were restructu
red to reprice off
the appropriate risk free rate from the next rep
ricing date post
31 December 2021 plus a spread adjustment. All i
mpacted
hedge accounting relationships had their designations up
dated
to reflect this transition.
USD cash flow and fair value he
dges of interest rate risk that
mature post 30 June 2023 c
ontinue to be directly affected by
interest rate benchmark reform.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
350
Financial statements
Strategic report
Governance
Risk and capital
management
Additional information
Financial review
14 Derivatives continued
Included in the table below are
derivatives held for hedging purposes as follows:
2021
2020
Changes in
Changes in fair
fair value used
value used for
for hedge
hedge
Notional
Assets
Liabilities
ineffectivenes
s (1)
Notional
Assets
Liabilities
ineffectiveness (1)
£bn
£m
£m
£m
£bn
£m
£m
£
m
Fair value hedging
Interest rate contracts
65.6
1,176
2,057
897
65.5
1,878
3,844
(875)
Cash flow hedging
Interest rate contracts
133.1
952
1,149
(931)
128.8
2,035
1,210
217
Exchange rate contracts
7.3
30
109
27
10.8
37
116
(
55)
Net investment hedging
Exchange rate contracts
0.5
11
1
7
0.2
9
11
206.5
2,169
3,316
205.3
3,950
5,179
(702)
IFRS netting/Clearing
house settlements
(2,125)
(3,196)
(3,857)
(5,049)
44
120
93
130
(1)
The change in fair va
lue used for hedge ineffectiveness includes instruments that were decrecognised in the year.
The notional of hedging instruments affected
by interest rate benchmark reform is as follows
:
2021
2020
£bn
£bn
Fair value hedging
EURIBOR
(1)
13.6
GBP LIBOR
11.2
USD LIBOR
(2)
20.2
26.6
Other currency LIBOR
1.1
Cash flow hedging
EURIBOR
(1)
5.2
GBP LIBOR
51.7
SOFR
(3)
0.2
USD LIBOR
(2)
3.1
2.7
(1)
In 2021 management concluded that E
URIBOR is not expected to be significantly reformed further and therefore any uncertainty due to interest benchmark rate reform for
EURIBOR has ended.
(2)
In 2021 the FCA declared that USD LIBOR will be non-
representative post 30 June 2023; at the time of preparing the 2020 disclosures this date was expected to be 31 December
2021.
(3)
Hedge relationships subject to reform a
re those where either the hedged item or the hedging instrument is subject to the IBOR reform.
(4)
Notional of £1 billion cross currency d
erivative contracts in cash flow hedge relationships will convert to repricing off the relevant risk-free rate at the first repricing date post
cessation.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
351
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial revie
w
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
14 Derivatives continued
The following table shows the period in which
the notional of hedging contract ends:
0-3
3-12
1-3
3-5
5
-10
10-20
20+
months
months
years
years
years
years
years
Total
2021
£bn
£bn
£bn
£bn
£bn
£bn
£b
n
£b
n
Fair value hedging
Hedging assets - interest rate risk
0.9
2.5
5.5
5.7
6.2
4.9
4.5
30.2
Hedging liabilities - interest rate risk
1.1
4.2
11.8
9.3
8.4
0.6
0.0
35.4
Cash flow hedging
Hedging assets
Interest rate risk
5.4
8.1
14.3
24.5
11.4
63.7
Average fixed interest rate (%)
1.40
1.19
1.35
0.65
0.82
0.97
Hedging liabilities
Interest rate risk
8.8
21.1
33.0
3.3
2.5
0.7
69.4
Average fixed interest rate (%)
0.50
0.24
0.41
0.47
1.01
4.55
0.44
Hedging assets
Exchange rate risk
Hedging liabilities
Exchange rate risk
0.1
2.4
3.5
1.3
7.3
Net investment hedging
Exchange rate risk
0.5
0.5
2020
Fair value hedging
Hedging assets - interest rate risk
1.2
2.3
6.3
7.4
8.9
5.1
4.2
35.4
Hedging liabilities - interest rate risk
0.6
10.1
11.6
7.1
0.5
0.2
30.1
Cash flow hedging
Hedging assets
Interest rate risk
0.7
10.5
19.3
13.9
10.5
0.1
55.0
Average fixed interest rate (%)
1.28
1.22
1.51
1.06
0.92
3.12
1.23
Hedging liabilities
Interest rate risk
1.6
28.9
36.8
3.4
2.4
0.7
73.8
Average fixed interest rate (%)
1.14
0.78
0.37
1.25
0.65
4.55
0.64
Hedging assets
Exchange rate risk
0.1
0.1
Hedging liabilities
Exchange rate risk
3.3
5.3
1.0
1.1
10.7
Net investment hedging
Exchange rate risk
0.1
0.1
0.2
For cash flow hedging of exchange rate risk, the a
verage foreign exchange rates applicable a
cross the relationships were as below
for the main currencies hedged.
2021
2020
INR/GBP
106.58
95.29
USD/GBP
1.38
1.36
CHF/GBP
1.25
n/a
JPY/GBP
132.93
132.93
JPY/EUR
n/a
120.21
CNH/GBP
8.74
n/a
For net investment hedging of e
xchange rate risk, the average foreign exchange
rates applicable were as below for the main
currencies hedged.
2021
2020
SEK/GBP
11.74
11.15
DKK/GBP
8.85
8.28
NOK/GBP
12.12
12.73
AED/USD
3.67
n/a
USD/GBP
1.32
n/a
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
352
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial revie
w
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
14 Derivatives continued
The table below a
nalyses asset
s and liabilities subject
to hedging derivatives.
Impact on
Changes in fa
ir
hedged items
Carrying value
Impact on
value used as
ceased to be
of hedged
hedged items
a
basis to
adjusted f
or
assets and
included in
determine
hedging
liabilities
carry
ing value
ineffectivenes
s (1)
gains or loss
es
2021
£m
£m
£m
£m
Fair value hedging
-
interest rate
Loans to banks and customers - amor
tised cost
6,603
701
(478)
69
Other financial assets - securities
30,882
518
(1,576)
Total
37,485
1,219
(2,054)
69
Other financial liabilities - debt sec
urities in issue
34,371
454
953
Subordinated liabilities
6,235
(9)
255
Total
40,606
445
1,208
Cash flow hedging - interest rate
Loans to banks and customers
-
amortised cost
63,025
1,984
Other financial assets - securities
714
26
Total
63,739
2,010
Cash flow hedging - interest rate
Bank and customer deposits
68,383
(1,084)
Other financial liabilities - debt sec
urities in issue
1,006
(21)
Total
69,389
(1,105)
Cash flow hedging - exchange rate
Loans to banks and customer - amortised cos
t
21
Other financial assets
-
securities
2
Total
23
Other financial liabilities - debt sec
urities in issue
6,337
(5)
Subordinated liabilities
742
(12)
Other
200
(10)
Total
7,279
(27)
2020
Fair value hedging - interest rate
Loans to banks and customers - amor
tised cost
6,858
1,228
323
77
Other financial assets - securities
35,754
2,268
1,568
Total
42,612
3,496
1,891
77
Other financial liabilities - debt sec
urities in issue
29,317
1,336
(746)
Subordinated liabilities
6,441
293
(268)
10
Total
35,758
1,629
(1,014)
10
Cash flow hedging - interest rate
Loans to banks and customers - amor
tised cost
53,335
(601)
Other financial assets - securities
1,550
(16)
Total
54,885
(617)
Cash flow hedging - interest rate
Bank and customer deposits
72,880
409
Other financial liabilities
-
debt securities in issue
1,014
13
Total
73,894
422
Cash flow hedging - exchange rate
Loans to banks and customer
-
amortised cost
112
1
Other financial assets - securities
30
Total
142
1
Cash flow hedging - exchange rate
Other financial liabilities - debt sec
urities in issue
6,272
20
Subordinated liabilities
4,194
36
Other
152
(2)
Total
10,618
54
(1)
The change in fair va
lue used for hedge ineffectiveness includes instruments that were derecognised in the year
.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
353
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial revie
w
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
14 Derivatives continued
The following risk exposures will be affec
ted by interest rate benchmark reform (notional, he
dged adjustment):
2021
2020
Hedged
Hedged
Notional
adjustment
Notional
a
djustment
£bn
£m
£bn
£m
Fair value hedging
EURIBOR
(1)
15.1
27
GBP LIBOR
11.4
1,178
USD LIBOR
(2)
21.8
7
28.1
(427)
Other currency LIBOR
1.1
1
Cash flow hedging
EURIBOR
(1)
4.1
(76)
GBP LIBOR
10.5
(473)
USD LIBOR
(2)
3.3
2
1
2.7
(61)
BOE Base rate
(3)
40.7
(156)
ECB REFI rate
(3)
1.2
SONIA
(3)
0.6
4
(1)
In 2021 management concluded that E
URIBOR is not expected to be significantly reformed further and therefore any uncertainty due to interest benchmark rate reform for
EURIBOR has ended.
(2)
In 2021 the FCA declared that USD LIBOR will be non-
representative post 30 June 2023; at the time of preparing the 2020 disclosures this date was expected to be 31 December
2021.
(3)
Hedge relationships subject to reform a
re those where either the hedged item or the hedging instrument is subject to the IBOR reform.
(4)
Notional of £6.5 billion GBP LIBOR hedged
item
s in cash f
low hedge relationships will convert to repricing off SONIA at the first repricing date post cessation.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
354
Financial statements
Strategic report
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Risk and capital management
Additional information
Financial review
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
14 Derivatives continued
The following table shows an analysis
of the pre-tax cash flow hedge reserve
and foreign exchange hedge reserve.
2021
2020
Foreign
Foreign
Cash flow
exchange
Cash flow
exchange
hedge reserve
hedge reserve
hedge reserve
hedge reserve
£m
£m
£m
£m
Continuing
Interest rate risk
(295)
695
Foreign exchange risk
23
53
22
(13)
De-designated
Interest rate risk
(297)
(424)
Foreign exchange risk
10
(759)
(1)
(775)
Total
(559)
(706)
292
(788)
2021
2020
Foreign
Foreign
Cash flow
exchange
Cash flow
exchange
hedge reserve
hedge reserve
hedge reserve
hedge reserve
£m
£m
£m
£m
Amount recognised in equity
Interest rate risk
(700)
318
Foreign exchange risk
13
88
3
(57)
Total
(687)
88
321
(57)
Amount transferred from equity
to earnings
Interest rate risk to net interest income
(181)
(19)
Interest rate risk to non-interest inco
me
(1)
20
Foreign exchange risk to net interest inco
me
(4)
2
(35)
Foreign exchange risk to non-interest income
1
(2)
2
Foreign exchange risk to operating expenses
3
4
Total
(161)
(50)
2
(1)
There was £20 million reclassified from the
cash flow reserve to earnings due to forecasted cash flows that are no longer expected to occur.
Hedge ineffectiveness recognised in othe
r operating income comprises:
2021
2020
2019
£m
£m
£m
Fair value hedging
(Losses)/gains on hedged items attributa
ble to the hedged risk
(846)
877
610
Gains/(losses) on the hedging instruments
897
(875)
(585)
Fair value hedging ineffectiveness
51
2
25
Cash flow hedging
Interest rate risk
(26)
22
23
Cash flow hedging ineffectiveness
(26)
22
23
Total
25
24
48
The main sources of ineffectiveness
for interest rate risk hedge accounting relationships a
re:
The effect of the counterparty
credit risk on the fair value of the interest rate swap which is
not reflected in the fair value of the
hedged item attributable to the change in inte
rest rate (fair value hedge).
Differences in the repricing basis between the hedging i
nstrument and hedged cash flows (cas
h flow hedge); and
Upfront present values on the hedging derivative
s where hedge accounting relationships ha
ve been designated after the trade
date (cash flow hedge and fair value hedge).
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
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nnual Repor
t and Accou
nts 2021
355
Financial statements
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Risk and capital management
Additional information
Financial review
15 Loan impairment provisions
Loan exposure and impairment metrics
There
is
a r
isk
that
customers and
counterparties
fail
to
meet
their
contractual obligation
to
settle
outstanding
amounts,
kn
own
as
expected
credit
losses
(ECL).
The
calculation
of
ECL
considers
historic,
current
and
forward-looking
information
to
determine
the
amount we do not expect to recover. ECL is recognised o
n current and potential exposures,
and contingent liabilities.
For
a
ccounting
policy
informa
tion
see
Accounting
policies
n
ote
11.
Further
d
isclosures
on
credit
risk
and
information
o
n
ECL
methodology are shown from page 197.
The table below summarises loans and credit impai
rment measures within the scope of IFRS
9 Expected credit losses framework.
2021
2020
£m
£m
Loans - amortised cost
Stage 1
330,824
287,124
Stage 2
33,981
78,917
Stage 3
5,022
6,358
Of which: individual
1,215
2,292
Of which: collective
3,807
4,066
369,827
372,399
ECL provisions
(1)
- Stage 1
302
519
- Stage 2
1,478
3,081
-
Stage 3
2,026
2,586
Of which: individual
363
831
Of which: collective
1,663
1,755
3,806
6,186
ECL provision coverage
(2,3)
- Stage 1 (%)
0.09
0.18
- Stage 2 (%)
4.35
3.90
-
Stage 3 (%)
40.34
40.67
1.03
1.66
Continuing operations
Impairment (releases)/losses
ECL (release)/charge
(3,4)
(1,278)
3,131
Stage 1
(1,377)
(89)
Stage 2
(187)
2,601
Stage 3
286
619
Of which: individual
20
194
Of which: collective
266
425
Amounts written off
876
937
Of which: individual
455
191
Of which: collective
421
746
(1)
Includes £5 million (2020 - £6 million) related to ass
ets classified as FVOCI.
(2)
ECL provisions coverage is calculated as total ECL provisions
divided by third party loans – amortised cost and FVOCI.
(3)
Includes a £3 million charge (2020 - £12 million cha
rge) related to other financial assets, of which £2 million release (2020 - £2 million charge) related to assets classified as
FVOCI; and £34 million release (2020 - £28 million charge)
related to contingent liabilities.
(4)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8.
(5)
The table shows gross loans only and
excludes amounts that are outside the scope of the ECL framework. Refer to Financial instruments within the scope of the IFRS 9 ECL
framework for further details. Other financial assets
within the scope of the IFRS 9 ECL framework were cash and balances at central banks totalling £176.3 billion (2020 –
£122.8 billion) and debt securities of £44.9 billion (2020 – £53.8 billion).
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
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nnual Repor
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356
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Additional information
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15 Loan impairment provisions continu
ed
Credit risk enhancement and mitigation
For information on Credit risk enhance
ment and mitigation held
as security, refer to Risk and capital managemen
t – Credit risk
enhancement and mitigation section.
Critical accounting policy: Loan impairment provisions
Accounting policies note 11 sets
out how the expected loss
approach is applied. At 31 December 2021
, customer loan
impairment provisions amounted to £3,806 million (2020
-
£6,186 million). A loan is impaired when there is objec
tive
evidence that the cash flows wi
ll not occur in the manner
expected when the loan was advanced. Such evidence
includes, changes in the credit rating of a borrower,
the failure
to make payments in accordan
ce with the loan agreement,
significant reduction in the valu
e of any security, breach of
limits or covenants, and observ
able data about relevant
macroeconomic measures.
The impairment loss is the difference between
the carrying
value of the loan and the present value of e
stimated future
cash flows at the loan's original eff
ective interest rate.
The measurement of credit impairment unde
r the IFRS
expected loss model depends on management’s asse
ssment of
any potential deterioration in the
creditworthiness of the
borrower, its modelling of expected perfo
rmance and the
application of economic forecasts. All th
ree elements require
judgments that are potentially significan
t to the estimate of
impairment losses. For further information and sensitivi
ty
analysis, refer to Risk and capital managemen
t – Measurement
uncertainty and ECL sensitivity analysis section.
IFRS 9 ECL model design principles
Refer to Credit risk – IFRS 9 ECL model design pri
nciples
section for further details.
Approach for multiple economic scenarios (MES)
The base scenario plays a greater part in the calculation
of
ECL than the approach to MES. Ref
er to Credit risk – Economic
loss drivers - Probability weightings of scenarios s
ection for
further details.
16 Other financial assets
Other financial assets consist of debt securities, equi
ty shares and loans that are not held for
trading. Balances consist of loc
al and
central government securities, a component part of Nat
West Group’s liquidity portfolio.
For accounting policy information se
e Accounting policy 10.
Debt securities
Central and local g
overnment
Other
Equity
Other
UK
U
S
Other
debt
Total
sh
ares
loans
Total
2021
£m
£m
£m
£m
£
m
£m
£m
£m
Mandatory fair value through profit or loss
6
6
13
298
317
Fair value through other comprehensive
income
(1)
11,938
10,086
5,604
9,058
36,686
312
268
37,266
Amortised cost
3,821
156
81
4,504
8,562
8,562
Total
15,759
10,242
5,685
13,568
45,254
325
566
46,145
2020
Mandatory fair value through profit or loss
88
88
14
338
440
Fair value through other comprehensive
income
(1)
17,458
11,742
6,802
8,591
44,593
294
15
44,902
Amortised cost
4,997
235
116
4,458
9,806
9,806
Total
22,455
11,977
6,918
13,137
54,487
308
353
55,148
(1)
Upon initial recognition, the Group occas
ionally irrevocably
designates some of its equity investments as equity instruments at FVOCI when they meet the definition of equity under
IAS 32 Financial instruments: presentation, are not held for trading or they a
re held for strategic purposes. Such classification is determined on an instrument by
instrument basis.
Gains and losses on these equity instruments are not recycled to the
income statement and dividends are recognised in profit or loss except when they represent a recovery of part
of the cost of the instrument, in which case such g
ains are recorded in OCI. Equity instruments at FVOCI are not subject to an impairment assessment.
Equity shares disposed during 20
20 included SABB (£383 million), VISA Inc. (£186 million), an
d Vocalink (£16 million).
Dividends on FVOCI equity shares include
£4 million (2020: £5 million) in relation to
the equity holding in OTC Derivative Limited
and £1 million (2020: £2 million) for VISA Inc.
Dividends received in relation to equity s
hares disposed during the year were nil
(2020: £15 million for NWG’s equity holding in SABB
).
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
357
Financial statements
Strategic report
Governance
Risk and capital
management
Additional information
Financial review
17 Intangible assets
Intangible assets, such as internally generated sof
tware and goodwill generated on business combinations a
re not physical in
nature. This note presents the
cost of the assets, which is the amount N
atWest Group initially paid or incurred, additions an
d
disposals during the year, and any a
mortisation or impairment. Amortisation is a cha
rge that reflects the usage of the asset
and
impairment is a reduction in value arising f
rom specific events identified during the ye
ar.
For accounting policy information se
e Accounting policies notes 5 and 6.
2021
2020
Goodwill
Other (1)
Total
Goodwill
Other
(1)
Total
Cost
£m
£m
£m
£m
£m
£m
At 1 January
9,939
2,592
12,531
9,980
2,293
12,273
Currency translation and other adjustments
29
29
(1)
(1)
Additions
479
479
348
348
Disposals and write
-
off of fully amortised assets
(50)
(50)
(41)
(
48)
(89)
At 31 December
9,939
3,050
12,989
9,939
2,592
12,531
Accumulated amortisation and impairment
At 1 January
4,332
1,544
5,876
4,373
1,278
5,651
Currency translation and other adjustments
31
31
1
1
Disposals and write-off of fully amortised ass
ets
(28)
(28)
(41)
(
26)
(67)
Impairment of intangible assets
85
2
87
9
9
Amortisation charge for the year
300
300
282
282
At 31 December
4,417
1,849
6,266
4,332
1,544
5,876
Net book value at 31 December
5,522
1,201
6,723
5,607
1,048
6,655
(1)
Principally internally generat
ed software.
Intangible assets and goodwill are reviewed for i
ndicators of
impairment. In 2021 £85 million of goodwill was i
mpaired due to
a reduction in the recoverable value.
NatWest Group’s goodwill acquired in business co
mbinations
analysed by reportable segment is in Note 4 Seg
mental analysis.
It is reviewed annually at 31 Dece
mber for impairment. In 2021
goodwill in the Retail segment was impaired by £85
million. No
other impairment was indicated at 31 December 2021
or 2020.
Impairment testing involves the comparison of
the carrying
value of each cash-generating unit (CGU) wi
th its recoverable
amount. The carrying values of the segmen
ts reflect the equity
allocations made by manageme
nt, which are consistent with
NatWest Group’s capital targets.
Recoverable amount is the high
er of fair value less costs of
disposal and value in use. Fair value is the price th
at would be
received to sell an asset in an orderly transaction be
tween
market participants. Value in use
is the present value of
expected future cash flows from the C
GU.
The recoverable amounts for all CGUs at 31
December 2021
were based on value in use, using managemen
t's latest five-
year revenue and cost forecasts
. These are discounted cash
flow projections over five years. T
he forecast is then
extrapolated in perpetuity using a long-term gr
owth rate to
compute a terminal value, which comprises the
majority of the
value in use. The long-term growth
rates have been based on
expected growth of the CGUs. T
he pre-tax risk discount rates
are based on those observed to
be applied to businesses
regarded as peers of the CGUs.
Critical accounting policy: Goodwill
Critical estimates
Impairment testing involves a number of judg
ments. The key
judgments are the five-year cash flow forecas
t, the long-term
growth rate used to derive the
terminal value, and the discount
rate. Future value in use is primarily affe
cted by changes in
profitability and changes in discount
rate. Adverse changes
could lead to value in use falling below ca
rrying value. The most
likely cause for this would be a failure to meet bu
dgets,
including cost targets, or exter
nal downgrades in the UK
economy.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
358
Financial statements
Strategic report
Governance
Risk and capital
management
Additional information
Financial review
17 Intangible assets continu
ed
The impact of reasonably possible changes to the mo
re significant variables in the value in us
e calcula
tions is presented belo
w.
This reflects the sensitivity of the
VIU to each key assumption on its own. It is possible that mo
re than one change may occur at the
same time.
Consequential impact
of
1% adverse
Consequential impact
of
5% adverse
Recoverable
Assumptions
amount
movement
movement
Terminal
Pre
-
tax
Cost:
exceeded
Terminal
growth
discount
income
carrying
Discount
growth
Forecas
t
Forecast
Goodwill
rate
rate
ratio (1)
value
rate
rate
Income
cost
31 December 2021
£bn
%
%
%
£bn
£bn
£bn
£b
n
£bn
Retail Banking
2.6
1.6
13.9
51.6
6.8
(1.8)
(0.8)
(2.1)
(1.0)
Commercial Banking
2.6
1.6
13.9
52.3
6.3
(1.9)
(0.8)
(2.0)
(1.0)
RBS International
0.3
1.6
12.1
37.0
2.6
(0.6)
(0.3)
(0.4)
(0.1)
31 December 2020
Retail Banking
2.7
1.6
13.7
48.3
5.9
(1.8)
(0.8)
(2.0)
(0.9)
Commercial Banking
2.6
1.6
13.7
53.7
1.5
(1.5)
(0.5)
(1.8)
(0.9)
RBS International
0.3
1.6
12.1
42.7
1.1
(0.4)
(0.2)
(0.3)
(0.1)
(1)
Average Cost:income ratio % over the 5-year forecast period
The following table gives the percentage chan
ge in key assumptions that would reduce the headroom of
CGUs to nil.
2021
2020
Terminal
Pre-
tax
Pre-
tax
growth
discount
Forecast
Forecast
Terminal
discount
Forecast
Forecast
Change in key assumptions to re
duce
rate
rat
e
income
cost
growth rate
rate
income
cost
headroom to nil (%)
%
%
%
%
%
%
%
%
Retail Banking
(139.2)
8.1
(16.1)
32.7
(25.4)
6.2
(14.6)
33.9
Commercial Banking
(47.0)
6.6
(15.7)
32.8
(4.0)
1.3
(4.1)
8.2
RBS International
(85.2)
10.3
(
30.3)
87.2
(10.8)
4.4
(18.6)
52.8
18 Other assets
Other assets are not financial as
sets and reflect a grouping of assets that are not la
rge enough to present separately on
the
balance sheet.
2021
2020
£m
£m
Interests in associates
(1)
716
449
Property, plant and equipment
(2)
4,230
4,418
Pension schemes in net surplus (Note 5)
602
723
Prepayments
360
328
Accrued income
248
2
16
Tax recoverable
190
192
Deferred tax (Note 7)
1,195
9
01
Acceptances
225
272
Other
476
3
91
Other assets
8,242
7,890
(1)
Includes interest in Business Growth Fund £
700 million (2020 - £442 million).
(2)
The estimated useful lives of NatW
est Group’s property, plant and equipment are: freehold buildings and long leasehold 50 years, short leaseholds for unexpired period of lease,
property adaptation costs 10 to 15 years, computer equipment
up to 5 years and other equipment 4 to 15 years.
19 Other financial liabilities
Other financial liabilities consist
of customer deposits designated at fair value an
d debt securities in issue cl
assified as designated at
fair value and amortised cost.
For accounting policy information se
e Accounting policies notes 10 and 14.
2021
2020
£m
£m
Customer deposits - designated as at fair value t
hrough profit or loss
568
796
Debt securities in issue
-
designated as at fair value through profit o
r loss
1,103
1,607
- amortised cost
47,655
43,408
Total
49,326
45,811
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
359
Financial statements
Strategic report
Governance
Risk and capital
management
Additional information
Financial review
20 Subordinated liabilities
Subordinated liabilities are debt s
ecurities that, in the event of winding up o
r bankruptcy, rank below other liabilities for inte
rest
payments and repayment. The subordinated liabilities prese
nted in the note are classified as designated at f
air value and amortised
cost.
For accounting policy information se
e Accounting policies notes 10 and 14.
2021
2020
£m
£m
Dated loan capital
8,051
8,530
Undated loan capital
259
1,287
Preference shares
119
145
8,429
9,962
Certain preference shares issu
ed by the company are classified as liabilities; these s
ecurities remain subject to the capi
tal
maintenance rules of the Companies Act 20
06.
Capital
2021
2020
New issue
treatment
£m
£m
NatWest Group plc
£1,000 million 3.622% dated notes
2030 (callable between May 20
25 to August 2025)
Tier 2
996
US$850 million 3.032% dated notes 2
035 (callable November 2030
)
Tie
r 2
634
£1000 million 2.105% dated notes
2031 (callable between August 2026 to Novembe
r 2026)
Tier 2
996
€750 million 1.043% dated notes 2
032 (callable between June 2027
to
September 2027)
Tier 2
638
1,634
1,630
Redemptions
NatWest Group plc
US$2,250 million 6.13% dated notes 2
022 (partial redemption)
Tier 2
226
499
US$1,000 million 6.10% dated notes 2
023 (partial redemption)
Tier 2
57
358
US$2,000
million 7.5% dated notes 2020
Tier 2
1,528
US$762 million 7.648% undated notes (p
artial redemption)
Ineligible
45
497
US$106 million floating rate un
dated notes (callable on any interest payment date)
In
eligible
77
US$2,650 million 8.625% dated notes 2021
(callable August 2021)
(1)
Tier 2
1,914
US$2,250 million 5.125% dated notes 2024
(partial redemption)
Tier 2
729
US$2,000 million 6% dated notes
2023 (partial redemption)
Tier 2
436
3,484
2,882
NatWest Markets Plc
US$125.6 million floating rate notes 202
0
Tie
r 2
97
€145.6 million floating rate dated notes 202
3 (partial redemption)
Tier 2
20
£31 million 7.38% notes (partial
redemption)
Tier 2
29
£19 million 5.63% notes (partial
redemption)
Tier 2
20
69
97
National Westminister Bank Plc
£300 million 6.5% subordinated notes 20
21 (not callable)
Tier 2
300
€10 million floating rate notes (callable quarterly)
Upper Tier 2
9
€178 million floating rate notes
(callable quarterly)
Upper Tier 2
152
US$193 million floating rate notes (callable semi-
annually)
Upper Tier 2
138
US$229 million floating rate notes (callable semi-
annually)
Upper Tier 2
167
US$285 million floating rate notes (callable semi-
annually)
Upper Tier 2
201
£35 million 11.5% notes (callable December 2022) (p
artial redemption)
Upper Tier 2
3
£140 million 9% cumulative pref
erence shares of £1 (not callable)
Tier 1
24
994
NWM N.V. and subsidiaries
US$650 million 6.425% dated notes 2
043 (partial redemption)
Ineligible
73
187
€15 million 6.00% notes 2020
Tier 2
11
73
198
(1)
In July 2021, paid in equity reclassified t
o liabilities as the result of a call in August 2021 of US$2.65 billion AT1 capital note
s which were subsequently redeemed in August 2021.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
360
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
21 Other liabilities
Other liabilities are amounts due
to third parties that are not financial liabilities including le
ase liabilities, amounts due for goods
and services that have been received but not in
voiced,
tax due to HMRC, and retiremen
t benefit liabilities. Liabilities which have a
level of uncertainty regarding their timing or
the future cost to settle them are included in othe
r liabilities as provisions for liabilities
and charges.
2021
2020
Other liabilities
£m
£m
Lease liabilities (Note 23)
1,263
1,698
Provisions for liabilities and charges
1,268
1,852
Retirement benefit liabilities (No
te 5)
114
121
Accruals
1,508
990
Deferred income
319
361
Current tax
12
63
Deferred tax (Note 7)
359
291
Acceptances
225
272
Other liabilities
(1)
729
740
5,797
6,388
(1)
Other liabilities include liabilities
of disposal grou
ps of £5 million (2020: n
il). See Note 8 for further information.
Financial
Litigation
commitments
Customer
and other
and
redress (1)
regulatory (4)
Propert
y (3)
guarant
ees
Other (2)
Total
Provisions for liabilities and charges
£m
£m
£m
£m
£m
£m
At 1 January 2021
749
365
271
178
289
1,852
Expected credit loss impairment release
(83)
(83)
Currency translation and other movements
(5)
2
(
2)
(7)
(12)
Charge to income statements
173
307
113
196
789
Release to income statement
(25)
(86)
(118)
(82)
(311)
Provisions utilised
(418)
(309)
(37)
(203)
(967)
At 31 December 2021
474
277
231
93
193
1,268
(1)
Includes payment protection insurance provision
which reflects the estimated cost of PPI redress attributable to claims prior to the Financial Conduct Authority (FCA) complaint
deadline of 29 August 2019. All pre-deadline complaints ha
ve been processed which removes complaint volume estimation uncertainty from the provision estimate. NatWest Group
continues to conclude remaining bank-identified closure work and
conclude cases with the Financial Ombudsmen Service.
(2)
Other materially comprises provisions relating t
o restructuring costs.
(3)
Property provision materially includes dilapidation
provisions. Release in property provision includes the effect of purchase of freeholds for properties where the group was the
primary leaseholder.
(4)
Majority of charge in the year and utilisat
ion of litigation provisions relates to FCA investigation into money laundering.
Provisions are liabilities of uncertain timing or amount
and are
recognised when there is a pres
ent obligation as a result of a
past event, the outflow of econ
omic benefit is probable and the
outflow can be estimated reliably
. Any difference between the
final outcome and the amounts provided will aff
ect the reported
results in the period when the matter is
resolved.
For accounting policy information se
e Accounting policies note
8.
Critical accounting policy: Provisions for liabilities
The key judgment is involved in determining whet
her a present
obligation exists. There is often a high degree of unce
r
tainty
and judgment is based on the specific f
acts and circumstances
relating to individual events in determining whethe
r there is a
present obligation. Judgment is also involved in esti
mation of
the probability, timing and amount of any outflows. W
here
NatWest Group can look to another pa
rty such as an insurer to
pay some or all of the expenditure required to se
ttle a
provision, any reimbursement is recognised w
hen, and only
when, it is virtually certain that it will be
received.
Estimates -
Provisions are liabili
ties of uncertain timing or
amount and are recognised whe
n there is a present obligation
as a result of a past event, the outflow of economic benefit is
probable and the outflow can be
estimated reliably.
Any difference between the final outcome and t
he amounts
provided will affect the reported results in
the period when the
matter is resolved.
Customer redress: Provisions refle
ct the estimated cost of
redress attributable to claims where it is dete
rmined that a
present obligation exists.
Litigation and other regulatory: NatWest G
roup is engaged
in various legal proceedings, both in the UK and in overseas
jurisdictions, including the US. For fu
rther information in
relation to legal proceedings and discussion of the
associated uncertainties, refer to Note 27.
Property: This includes provision for contractual costs such
as rates associated with vacant properties.
Other provisions: These materially c
omprise provisions for
onerous contracts and restructuring costs. O
nerous
contract provisions comprise an es
timate of the costs
involved in fulfilling the terms and conditions of co
ntracts
net of any expected benefits to be rece
ived. This includes
provision for contractual costs
such as rates associated
with vacant properties. Redundancy and rest
ructuring
provisions comprise the estimated cost of rest
ructuring,
including redundancy costs whe
re an obligation exists.
Background information for all ma
terial provisions is given in
Note 27
.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
361
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
22 Share capital and other equity
Share capital consists of ordinary shares and preference sha
res and is measured as the numb
er of shares allotted and fully paid
multiplied by the nominal value of a share. Other e
quity includes paid-in equity, merger reserves
, capital redemption reserve and
own shares held.
For accounting policy information se
e Accounting policies note 14.
Number of shares
2021
2020
2021
2020
Allotted, called up and fully pai
d
£m
£m
000s
000s
Ordinary shares of £1
11,468
12,129
11,467,982
12,129,165
Cumulative preference shares of £
1
1
1
483
900
Non
-
cumulative preference shares of US$
0.01
(1)
10
10
(1)
No shares were redeemed in 2021
or 2020. The company announced on 1 February 2022 that it had given notice to holders of the redemption on 31 March 2022 of the Series U
Non-cumulative dollar preference shares.
Movement in allotted, called up
and fully paid ordinary shares
£m
Number of shares 0
00s
At 1 January 2020
12,094
12,093,909
Shares issued
35
35,256
At 1 January 2021
12,129
12,129,165
Shares issued
38
37,584
Shares redeemed
(699)
(698,767)
At 31 December 2021
11,468
11,467,982
Ordinary shares
There is no authorised share capital under the c
ompany’s
constitution. At 31 December 2021
, the directors had authority
granted at the 2021 Annual General Meeting to is
sue up to
£608,328,288 nominal of ordina
ry shares other than by pre-
emption to existing shareholder
s. This figure was reduced to
£578,791,771 to reflect the reduction in issued sh
are capital
resulting from the off-market buyback announced on
19 March
2021.
On 6 February 2019 the company held a Gene
ral Meeting and
shareholders approved a special resoluti
on to give the
company authority to make off-market purch
ases of its
ordinary shares from HM Treasury (or its nominee) a
t such
times as the directors may dete
rmine is appropriate. Full details
of the proposal are set out in the Circular and Notice of
General Meeting. This authority was renewed a
t the Annual
General Meeting in 2021 and s
hareholders will be asked to
renew the authority at the Ann
ual General Meeting in 2022.
The company utilised the autho
rity it obtained at the 2020 AGM
to make an off-market purchas
e of 590,730,325 ordinary
shares (nominal value £590,7
30,325) in the company from HMT
on 19 March 2021, at a price of 1
90.50p per ordinary share
for
the total consideration of £1,125
,341,269, representing 4.86% of
the company's issued ordinary share capital. The com
pany
cancelled 390,730,3
25 of the purcha
sed ordinary sha
res and
held the remaining 200,000,00
0 ordinary shares in treasury.
The company has used a total of 1
9,062,290 treasury shares to
satisfy the exercise of options a
nd the vesting of share awards
under the employee share plans
.
At the Annual General Meeting in 202
1 shareholders authorised
the company to make market purchases of up
to 1,216,656,575
ordinary shares in the company
. The directors utilised the
authority obtained at the 2021 A
GM to conduct a share
buyback programme (the Prog
ramme) of up to £750 million, as
announced to the market on 30 Ju
ly 2021.
The Programme’s
purpose is to reduce the ordinary share capital of N
atWest
Group. Taking into account the reduction in issue
d ordinary
share capital which occurred as a result of the off-m
arket
buyback announced on 19 Marc
h 2021, the maximum number
of ordinary shares that could be
purchased by the company
under the Programme was 1,157,5
83,542. The Programme
commenced on 2 August 2021 and, as at 31 Dece
mber 2021,
310,802,416 ordinary shares (n
ominal value £310,802,416
) had
been purchased by the company at an avera
ge purchase price
of 217.5796p per ordinary share
for the total consideration of
£676,242,656.
A further 29,735,044 ordinary shares (
nominal value
£29,735,044) were purchased by
the company from 1 January
to 18 January 2022 at an average purchase price of 24
5.5264p
per ordinary share
for the total
consideration of £73,007,3
75.
All of the purchased ordinary shares were cancelle
d,
representing 2.93% of the company's issued o
rdinary share
capital. Shareholders will be aske
d to renew the authorisation
at the Annual General Meeting in 2
022.
In 2021, the company issued 38 million ordina
ry shares of £1
each in connection with employe
e share plans.
In 2021 NatWest Group paid an interi
m dividend of £347 million,
or 3.0p per ordinary share (2020 - nil).
The company has announced that the di
rectors have
recommended a final dividend
of £844.3 million, or 7.5p per
ordinary share (2020 – £364 mi
llion, or 3p) subject to
shareholder approval at the An
nual General Meeting on 28
April 2022.
If approved, payment will be made on 4 May 20
22 to
shareholders on the register at the close of busines
s on 18
March 2022. The ex-dividend date will be 17 March 2022
.
Cumulative preference shar
es
At the 2021 Annual General Meeting, shareholders au
thorised
the company to make an off-market purchase of
preference
shares in the company. The company announced on 15
December 2021 that it had utilised this autho
rity to purchase
157,546 5.5% cumulative preference s
hares (nominal value
£157,546), representing 39.39%
of the share class, at a
purchase price of 102%
for the total consideration of £16
0,697
and 259,314 11.00
% cumulativ
e preference sha
res (nominal
value £259,314), representing 51.8
6% of the share class, at a
purchase price of 155% for the total conside
ration of £401,937.
The company cancelled all of the purch
ased preference shares.
Non-cumulative preference shares
Non-cumulative preference shares entitle their holders
to
periodic non-cumulative cash d
ividends at specified fixed rates
for each series payable out of distribut
able profits of the
company.
The company may redeem some or all of the
non-cumulative
preference shares from time to time at the r
ates detailed in the
table on the next page plus dividends ot
herwise payable for the
then current dividend period to the date of rede
mption.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
362
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
22 Share capital and other equity
continued
Number of shares
Redemption
Redemption
Non-cumulative preference shares classified as equity
in issue
Interest rate
date on
or after
price per share
Shares of US$0.01 -
Series U
10,130
Floating
29 September 2017
US$100,000
(1)
Preference shares where d
istributions are discretionary are classified as equity.
On a winding-up or liquidation
of the company, the holders of
the non-cumulative preference
shares are entitled to receive,
out of any surplus assets available f
or distribution to the
company's shareholders (after payment of a
rrears of dividends
on the cumulative preference shares up to
the date of
repayment) pari passu with the cumulative p
reference shares
and all other shares of the company ranking p
ari passu with
the non-cumulative preference
shares as regards participation
in the surplus assets of the company, a liquid
ation distribution
per share equal to the applicable redemption price det
ailed in
the table above, together with an amoun
t equal to dividends for
the then current dividend period accrued to the d
ate of
payment, before any distribution or paymen
t may be made to
holders of the ordinary shares
as regards participation in the
surplus assets of the company.
Except as described above, the
holders of the non-cumulative
preference shares have no right to pa
rticipate in the surplus
assets of the company.
Holders of the non-cumulative preference sha
res are not
entitled to receive notice of or attend general mee
tings of the
company except if any resolution is proposed fo
r adoption by
the shareholders of the compa
ny to vary or abrogate any of
the rights attaching to the non-cumulative preference sh
ares or
proposing the winding-up or liquidation of t
he company. In any
such case, they are entitled to receive notice of a
nd to attend
the general meeting of shareholders at which such resolutio
n is
to be proposed and are entitled
to speak and vote on such
resolution (but not on any other resolution).
In addition, in the
event that, prior to any general
meeting of shareholders, the
company has failed to pay in full the mos
t recent dividend
payment due on the series U non-cumulative
dollar preference
shares, the holders shall be entitled to
receive notice of, attend,
speak and vote at such meeting on all matte
rs together with
the holders of the ordinary shares. In thes
e circumstances only,
the rights of the holders of the non-cumulative preference
shares so to vote shall continue until the
company shall have
resumed the payment in full of the dividends in
arrears.
Paid-in equity
-
comprises equity instruments issue
d by the
company other than those lega
lly constituted as shares.
Additional Tier 1 instruments iss
ued by NatWest Group plc
having the legal form of debt are classified as equity un
der
IFRS. The coupons on these ins
truments are non-cumulative
and payable at the company’s discretion. In the event N
atWest
Group’s CET1 ratio falls below 7% any ou
tstanding instruments
will be converted into ordinary shares at a fixed p
rice
Capital recognised for regulatory purposes canno
t be
redeemed without Prudential Regulation Autho
rity consent. This
includes ordinary shares, preference shares and addition
al Tier
1
instruments.
2021
2
020
2019
£m
£m
£
m
Additional Tier 1 notes
US$2.0 billion 7.5% notes callable August 20
20
(1)
1,277
US$1.15 billion 8% notes callable August 20
25
(1)
735
735
735
US$2.65 billion 8.625% notes callable August 202
1
(2)
2,046
2,046
US$1.5 billion 6.000% notes callable
December 2025 - June 2026
(3)
1,220
1,220
GBP£1.0 billion 5.125% notes callable
May
-
November 2027
(4)
998
998
GBP£0.4 billion – March 2021 is
suance
(5)
399
US$0.75 billion – June 2021 is
suance
(6)
538
3,890
4,999
4,058
(1)
Issued in August 2015. In the e
vent of conversion, converted into ordinary shares at a price of $3.606 nominal per £1 share.
(2)
Issued in August 2016. In the e
vent of conversion, converted into ordinary shares at a price of $2.284 nominal per £1 share. In July 2021, paid-in equity reclassified to liabilities as
the result of a call in August 2021 of US$2.65 billion AT1 Capital notes.
(3)
Issued in June 2020. In the event of conversion, converted into
ordinary shares at a price of £1.754 (translated at applicable exchange rate) per £1 share.
(4)
Issued in November 2020. In the
event of conversion, converted into ordinary shares at a price of £1.754 nominal per £1 share.
(5)
Issued in March 2021. In the event
of conversion, converted into ordinary shares at a price of £1.754 nominal per £1 share.
(6)
Issued in June 2021. In the event of conversion, converted into
ordinary shares at a price of £1.754 (translated at applicable exchange rate) per £1 share.
Merger reserve
-
the merger rese
rve comprises the premium on
shares issued to acquire NatWe
st Bank Plc less goodwill
amortisation charged under previous GAAP.
Capital redemption reserve
-
under UK companies legisla
tion,
when shares are redeemed or purchased wholly o
r partly out
of the company's profits, the amoun
t by which the company's
issued share capital is diminishe
d must be transferred to the
capital redemption reserve. The
capital maintenance provisions
of UK companies legislation apply to the capi
tal redemption
reserve as if it were part of the company’s paid up sh
are
capital. On 15 June 2017, the Court of Ses
sion approved a
reduction of NatWest plc capital so that the am
ounts which
stood to the credit of the capital redemp
tion reserve were
transferred to retained earning
s. The nominal value of the
shares bought back from HM Treasury in
March 2021 and via
the Programme during 2021 have been transfer
red to the
Capital redemption reserve.
Own shares held
-
at 31 December 2021, 15 million ordina
ry
shares of £1 each of the comp
any (2020 - 16 million) were held
by employee share trusts in respect of sha
re awards and
options granted to employees. During the ye
ar, the employee
share trusts purchased no ordinary shares and delive
red 1
million ordinary shares in satisfaction of the exercise
of options
and the vesting of share awards u
nder the employee share
plans. The company retains the fle
xibility to use newly issued
shares, shares purchased by the NatWest Group E
mployee
Share Ownership Trust and any available t
reasury shares to
satisfy obligations under its employee
share plans.
The
company does not use performance conditions o
r targets
based on earnings per share (EPS), total shareholde
r return
(TSR), and net asset value (NA
V) in connection with its
employee share plans.
As part of the shares bought back from HM T
reasury in March
2021, the company transferred 2
00 million ordinary shares to
treasury. The company has used a total of 1
9,062,290 treasury
shares to satisfy the exercise of options and the vesti
ng of
share awards under the employee
share plans. The balance of
ordinary shares held in treasury as at 31 December 202
1 was
180,937,710.
NatWest Group plc optimises capital efficie
ncy by maintaining
reserves in subsidiaries, including regulated entities. Cer
tain
preference shares and subordinated debt
are also included
within regulatory capital. The re
mittance of reserves to the
company or the redemption of shares or subo
rdinated capital
by regulated entities may be subject to maint
aining the capital
resources required by the relevant regulato
r.
UK law prescribes that only the rese
rves of the company are
taken into account for the purpos
e of making distributions and
in determining permissible applications of
the share premium
account.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
363
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
23 Leases
A lease is a contract or part of a contract whereby t
he lessor (the legal owner of an asse
t) conveys to the lessee (the user of the
asset) the right to use an asset
for an agreed period of time in exchange for a payme
nt or series of payments.
This note presents the income, e
xpenses, assets, liabilities and cash flows of NatWest Group in
the capacity of both lessee and
lessor.
Lessee
NatWest Group is party to lease contracts as les
see to
support its operations. The following ta
ble provides information in respect of
those lease contracts as lessee.
2021
2020
£m
£m
Amount recognised in consolid
ated income statement
Interest payable
(38)
(42)
Depreciation
(1)
(167)
(209)
Rental expenses on short term
leases
(1)
Income from subleasing right to use assets
4
4
2021
2020
£m
£m
Amount recognised on balance shee
t
Right of use assets include pro
perty, plant and equipment
(2),(3)
733
955
Additions to right of use assets
70
80
Lease liabilities
(3),(4)
(1,263)
(1,698)
The total cash outflow for leases is £
195 million (2020: £220 million), including payment of p
rincipal amount of £164 million (202
0:
£179 million) which are included in the operating ac
tivities in the cash flow statement.
(1)
Includes impairment of
right of use assets of £52 million (2020: £89 million).
(2)
Includes right of use asset for p
lant and equipment of £9 millio
n (2020
: £8 million) and depreciation of £4 million (2020: £2 million).
(3)
Includes the effect of the purchas
e of freeholds for properties where the Group was the primary leaseholder.
(4)
Contractual cashflows of lease liabilities are shown
in Note 12.
Lessor
Acting as a lessor, NatWest Group provides asse
t finance to its customers. It purchase
s plant, equipment and intellectual pro
perty,
renting them to customers under lease arrangemen
ts that, depending on their terms, qualify
as either operating or finance le
ases.
2021
2020
£m
£m
Amount included in consolidated income state
ment
Finance leases
Finance income on the net investment in lease
s
298
289
Operating leases
Lease income
169
168
The following table shows the r
econciliation of undiscounted finance lease receiva
bles to net investment in fin
ance leases:
2021
2020
£m
£m
Amount receivable under finance le
ases
Within 1 year
3,272
3,156
1 to 2 years
2,044
2,231
2 to 3 years
1,443
1,609
3 to 4 years
757
952
4 to 5 years
429
492
After 5 years
1,423
1,688
Lease payments total
9,368
10,128
Unguaranteed residual values
225
232
Future drawdowns
(21)
(22)
Unearned income
(891)
(1,081)
Present value of lease payments
8,681
9,257
Impairments
(150)
(196)
Net investment in finance leases
8,531
9,061
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
364
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
23 Leases continued
The following tables show undiscounted lease rece
ivables from operating leases:
2021
2020
£m
£m
Amount receivable under operating leases
Within 1 year
131
143
1 to 2 years
92
112
2 to 3 years
50
79
3 to 4 years
23
34
4 to 5 years
11
14
After 5 years
9
11
Total
316
393
2021
2020
£m
£m
Nature of operating lease assets on the balance shee
t
Transportation
282
327
Car and light commercial vehicl
es
21
28
Other
223
245
526
600
Fair value of investment properties
under operating lease are £838
million (2020: £840 million) and had lease income of £59
million
(2020: £60 million). The following table shows undisc
ounted lease receivables from invest
ment properties:
2021
2020
£m
£m
Amount receivable under inves
tment properties
Within 1 year
63
67
1 to 2 years
62
127
2 to 3 years
58
54
3 to 4 years
56
76
4 to 5 years
51
88
After 5 years
304
142
Total
594
554
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
365
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
24 Structured entities
A structured entity (SE) is an e
ntity that has been designed such that voting or simila
r rights are not the dominant fac
tor in
deciding who controls the entity
, for example when any voting rights relate to ad
ministrative tasks only and the
relevant activities
are directed by means of contractual arr
angements. SEs are usually established for a specific,
limited purpose. They do not carry
out a business or trade and typically have no employee
s. They take a variety of legal forms -
trusts, partnerships and compa
nies -
and fulfil many different functions where thes
e can be a medium for a single transaction o
r portfolio of similar transactions. SEs
are established as investment or funding vehicles, wit
hin the NatWest Group and fo
r client transactions.
Consolidated structured entities
Securitisations
In a securitisation, assets, or interests in a pool of asse
ts, are
transferred generally to an SE which then is
sues liabilities to
third party investors. The majority of se
curitisations are
supported through liquidity facilities or other c
redit
enhancements. NatWest Group arranges
securitisations to
facilitate client transactions an
d undertakes own-asset
securitisations to sell or to fund portfolios of f
inancial assets.
NatWest Group also acts as an
underwriter and depositor in
securitisation transactions in bo
th client and proprietary
transactions.
NatWest Group involvement in client securitisations
takes a
number of forms. It may: sponsor or adminis
ter a securitisation
programme; provide liquidity facilities or program
me-wide
credit enhancement; and purchase se
curities issued by the
vehicle.
Other credit risk transfer securitisati
ons
NatWest Group also transfers credit risk on originate
d loans
and mortgages without the transf
er of assets to a SE. As part
of this, NatWest Group enters i
nto credit derivative and
financial guarantee contracts with co
nsolidated SEs. At 31
December 2021, debt securities i
n issue by such SEs (and held
by third parties) were £867 million (202
0 - £772 million). The
associated loans and mortgages at 31 Decembe
r 2021 were
£7,137 million (2020 - £1
0,027 million). At 31 December, ECL in
relation to non-defaulted assets
was reduced by £28 million
(2020 - £183 million) as a result
of financial guarantee
contracts with consolidated SEs.
Covered debt programme
Group companies have assigned loans to customers
and debt
investments to bankruptcy remote limited liability par
tnerships
to provide security for issues of debt securities. N
atWest Group
retains all of the risks and rewards of thes
e assets and
continues to recognise them. The partne
rships are consolidated
by NatWest Group and the related covered
bonds included
within other financial liabilities. A
t 31 December 2021, £8,965
million (2020 - £10,758 million) of
loans to customers and nil
(2020 - £318 million) of debt inv
estments provided security for
debt securities in issue and other bo
rrowing of £3,512 million
(2020 - £4,105
million).
Lending of own issued securities
NatWest Group has issued, retained, and le
nt debt securities
under securities lending arrange
ments. Under standard terms
in the UK and US markets, the recipient has a
n unrestricted
right to sell or repledge collateral, subject to re
turning
equivalent securities on maturity
of the transaction.
NatWest
Group retains all of the risks and rewards of own issue
d
liabilities lent under such arrangements
and does not recognise
them. At 31 December 2021, £1,494
million (2020 - £1,893
million) of secured own issued liabilities have been re
tained and
lent under securities lending arrangemen
ts. At 31 December
2021, £1,564 million (2020 - £2
,029 million) of loans and other
debt instruments provided security for secured own is
sued
liabilities that have been retained and lent unde
r securities
lending arrangements
.
Unconsolidated structured entities
NatWest Group’s interest in unconsolida
ted structured entities is analysed below.
2021
2020
Asset
Asset
backed
Investment
backed
Investment
securitisation
funds and
securitisation
funds and
vehicles
others
Total
vehicles
others
Total
£m
£m
£m
£m
£m
£m
Trading assets and derivatives
Trading assets
490
117
607
319
46
365
Derivative assets
251
18
269
441
16
457
Derivative liabilities
(170)
(1)
(171)
(319)
(21)
(340)
Total
571
134
705
441
41
482
Non trading assets
Loans to customers
1,692
361
2,053
1,400
497
1,897
Other financial assets
3,645
379
4,024
3,892
170
4,062
Total
5,337
740
6,077
5,292
667
5,959
Liquidity facilities/loan commitments
1,403
135
1,538
1,482
204
1,686
Maximum exposure
7,311
1,009
8,320
7,215
912
8,127
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
366
Financial statements
Strategic report
Governance
Risk and capital management
Additional
information
Financial review
25 Asset transfers
This note provides an overview of asse
t transfers which do not qualify for derecognition and t
herefore continue to be recogni
sed in
NatWest Group’s balance sheet.
For accounting policy information se
e Accounting policies note 4.
Transfers that do not qualify for derecognition
NatWest Group enters into securities repurchase
, lending and
total return transactions in accordance with no
rmal market
practice which includes the provision of additional coll
ateral if
necessary. Under standard terms in the UK a
nd US markets,
the recipient has an unrestricted right
to sell or repledge
collateral, subject to returning equivalent securities on
settlement of the transaction.
Securities sold under repurchase
transactions and transactions
with the substance of securities repurc
hase agreements are not
derecognised if NatWest Group retains substa
ntially all the risks
and rewards of ownership. The fair value (and ca
rrying value)
of securities transferred under s
uch transactions included on
the balance sheet, are set out below. All of
these securities
could be sold or repledged by the
holder.
2021
2020
The following assets have failed derecognition
(1)
£m
£m
Trading assets
13,084
20,526
Loans to bank - amortised cost
38
5
Loans to customers - amortised cost
1,837
39
Other financial assets
11,746
11,542
Total
26,705
32,112
(1)
Associated liabilities were £24,747 million (2020 – £31,932 million).
Assets pledged as collateral
NatWest Group pledges collateral with its counte
rparties in respect of derivative liabilities an
d bank and stock borrowings.
2021
2020
Assets pledged against liabilitie
s
£m
£m
Trading assets
23,601
28,728
Loans to banks - amortised cost
62
49
Loans to customers
-
amortised cost
20,108
15,939
Other financial assets
(1)
3,624
4,966
Total
47,395
49,682
(1)
Includes assets pledged for pens
ion derivatives and stock borrowings.
As part of the covered debt programme £8
,965 million of loans to customers and other debt in
struments (2020 – £11,076
million)
have been transferred to bankruptcy remote limi
ted liability partnerships within the Na
tWest Group to provide collateral for issue
s
of debt securities and other borrowing by t
he NatWest Group of £3
,512 million (2020 – £4,105 million). See St
ructured Entities Note.
Own asset securitisations
In own-asset securitisations, the
pool of assets held by the SE is either origin
ated by NatWest Group or, in the case of whole l
oan
programmes, purchased from third
parties.
The table below analyses the ass
et categories for those own-asset securitisations whe
re the transferred assets continue to be
recorded on NatWest Group’s balance she
et.
2021
2020
Debt Securities in
issue
Debt Securities in issue
Held by
Held by
Held by
Held by
third
NatWest
third
NatWrst
Assets
parties
Group (1)
Total
Assets
parties
Group (1)
Tota
l
Asset Type
£m
£m
£m
£m
£m
£m
£m
£m
Mortgages
-
Rol
1,244
1,314
1,314
1,921
243
1,848
2,091
Cash deposits
42
146
1,286
2,067
(1)
Debt securities retained by NatW
est Group may be pledged with central banks.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
367
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
26 Capital resources
NatWest Group’s regulatory capital is
assessed against minimum requirements that are set o
ut under the Capital Requirements
Regulation to determine the strength of its capital
base.
This note shows a reconciliation of shareholders’ equi
ty to regulatory capital.
PRA transitional
basis
2021
2020
£m
£m
Shareholders’ equity (excluding non-controlling i
nterests)
Shareholders’ equity
41,796
43,860
Preference shares - equity
(494)
(494)
Other equity instruments
(3,890)
(4,999)
37,412
38,367
Regulatory adjustments and deductions
Own credit
21
(1)
Defined benefit pension fund adjustment
(465)
(579)
Cash flow hedging reserve
395
(229)
Deferred tax assets
(761)
(760)
Prudential valuation adjustments
(274)
(286)
Goodwill and other intangible assets
(6,312)
(6,182)
Foreseeable ordinary dividends
(846)
(364)
Foreseeable charges
(825)
Foreseeable pension contributions
(365)
(266)
Adjustment under IFRS 9 transitional arrangements
621
1,747
Other regulatory adjustments
(5)
(8,816)
(6,920)
CET1 capital
28,596
31,447
Additional Tier 1 (AT1) capital
Qualifying instruments and related sh
are premium
3,875
4,983
Qualifying instruments and related sh
are premium subject to phase out
571
690
Qualifying instruments issued by su
bsidiaries and held by third parties subject to phase out
140
AT1 capital
4,446
5,813
Tier 1 capital
33,042
37,260
Qualifying Tier 2 capital
Qualifying instruments and related sh
are premium
4,935
4,882
Qualifying instruments issued by su
bsidiaries and held by third parties
314
1,191
Other regulatory adjustments
457
400
Tier 2 capital
5,706
6,473
Total regulatory capital
38,748
43,733
It is NatWest Group policy to maintain a strong capi
tal base, to
expand it as appropriate and to utilise
it efficiently throughout
its activities to optimise the return to sha
reholders while
maintaining a prudent relationship betwee
n the capital base
and the underlying risks of the busine
ss. In carrying out this
policy, NatWest Group has regard to
the supervisory
requirements of the PRA. The PRA us
es capital ratios as a
measure of capital adequacy in the UK banking se
ctor,
comparing a bank's capital res
ources with its risk-weighted
assets (the assets and off-balance
sheet exposures are
weighted to reflect the inherent credit and othe
r risks); by
international agreement, the Pillar 1 capital ratios sh
ould be not
less than 8% with a Common Equity Tier 1 component
of not
less than 4.5%. NatWest Group has complied wi
th the PRA’s
capital requirements throughout the yea
r.
A number of subsidiaries and sub-groups within Nat
West
Group, principally banking entities
, are subject to various
individual regulatory capital requirements in t
he UK and
overseas. Furthermore, the payment of dividends
by
subsidiaries and the ability of members of NatWest
Group to
lend money to other members of NatWest Group
may be
subject to restrictions such as l
ocal regulatory or legal
requirements, the availability of rese
rves and financial and
operating performance.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
368
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
27 Memorandum items
Contingent liabilities and commitments
NatWest Group provides its cus
tomers with a variety of services to support their
businesses, such as guarantees. Thes
e are
reported as commitments.
Con
tingent liabilities are possible obligations dependent o
n a future event or present obligations which
are either not probable or cann
ot be measured reliably.
For accounting policy information se
e Accounting policies note 8.
The amounts shown in the table
below are intended only to provide an indication of the volu
me of business outstanding at 31
December 2021. Although NatWest G
roup is exposed to credit risk in the event of a custo
mer’s failure to meet its obligation
s, the
amounts shown do not, and are
not intended to, provide any indication of NatWest
Group's expectation of future losses.
More than
More than
2021
2020
1 year but
3 years but
Less than
less than
less than
Over
1 year
3 years
5 years
5 years
£m
£m
£m
£m
£m
£m
Guarantees
993
321
195
546
2,055
2,244
Other contingent liabilities
1,005
435
43
521
2,004
2,321
Standby facilities, credit lines and other co
mmitments
60,029
26,775
27,136
7,368
121,308
124,167
Contingent liabilities and commitments
62,027
27,531
27,374
8,435
125,367
128,732
(1)
The maturity of contingent liabilities and commitment is
based on the expiry of the agreement between NatWest Group and the customer.
Banking commitments and contingent obligations, whic
h have
been entered into on behalf of customers and fo
r which there
are corresponding obligations from customers, are no
t included
in assets and liabilities. NatWes
t Group's maximum exposure to
credit loss, in the event of its obligation c
rystallising and all
counterclaims, collateral or security proving valuele
ss, is
represented by the contractual nominal amoun
t of these
instruments included in the table
above. These commitments
and contingent obligations are subject to N
atWest Group's
normal credit approval process
es.
Guarantees – NatWest Group gives
guarantees on behalf of
customers. A financial guarantee
represents an irrevocable
undertaking that NatWest Group will meet a cus
tomer's
specified obligations to third party if the custome
r fails to do so.
The maximum amount that NatWest Group coul
d be required
to pay under a guarantee is its principal amount as
disclosed in
the table above. NatWest Group expects most guaran
tees it
provides to expire unused.
Other contingent liabilities - the
se include standby letters of
credit, supporting customer debt issues and contin
gent
liabilities relating to customer trading activities su
ch as those
arising from performance and customs bonds, w
arranties and
indemnities.
Standby facilities and credit line
s - under a loan commitment,
NatWest Group agrees to make funds available
to a customer
in the future. Loan commitments, which are usually f
or a
specified term, may be unconditionally cancellable o
r may
persist, provided all conditions in the lo
an facility are satisfied
or waived. Commitments to len
d include commercial standby
facilities and credit lines, liquidit
y facilities to commercial paper
conduits and unutilised overdraft facilities.
Other commitments - these include documen
tary credits, which
are commercial letters of credit providing for p
ayment by
NatWest Group to a named benef
iciary against presentation of
specified documents, forward ass
et purchases, forward
deposits placed and undrawn note issuance and rev
olving
underwriting facilities, and other short-ter
m trade related
transactions.
Contractual obligations for future expenditure not provided for in the accounts
The following table shows contractual obligations fo
r future expenditure not provided for in the
accounts at the year end.
2021
2020
£m
£m
Capital expenditure on property, plant and equip
ment
16
15
Contracts to purchase goods or services
(1)
682
729
698
744
(1)
Of which due within 1
year: £301 million (2020 – £267 million).
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
369
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
27 Memorandum items continued
Trustee and other fiduciary activi
ties
In its capacity as trustee or oth
er fiduciary role, NatWest Group
may hold or place assets on behalf of individuals,
trusts,
companies, pension schemes and others. T
he assets and their
income are not included in Nat
West Group's financial
statements. NatWest Group earned fe
e income of £280 million
(2020 - £245 million; 201
9 - £250 million) from these activities.
The Financial Services Compensation Scheme
The Financial Services Compensation Scheme (
FSCS), the UK's
statutory fund of last resort for
customers of authorised
financial services firms, pays compensa
tion if a firm is unable to
meet its obligations. The FSCS f
unds compensation for
customers by raising management expenses levies
and
compensation levies on the indu
stry. In relation to protected
deposits, each deposit-taking institution contributes to
wards
these levies in proportion to the
ir share of total protected
deposits on 31 December of the y
ear preceding the scheme
year (which runs from 1 April to 3
1 March), subject to annual
maxima set by the Prudential Re
gulation Authority. In addition,
the FSCS has the power to rais
e levies on a firm that has
ceased to participate in the sche
me and is in the process of
ceasing to be authorised for the
costs that it would have been
liable to pay had the FSCS made
a levy in the financial year it
ceased to be a participant in the s
cheme.
Litigation and regulatory matters
NatWest Group plc and certain members of Nat
West Group are
party to legal proceedings and
involved in regulatory matters,
including as the subject of inves
tigations and other regulatory
and governmental action (Matt
ers) in the United Kingdom (UK),
the United States (US), the Eur
opean Union (EU) and other
jurisdictions.
NatWest Group recognises a provision for a liability in
relation
to these Matters when it is probable tha
t an outflow of
economic benefits will be required to settle an oblig
ation
resulting from past events, and a reliable es
timate can be made
of the amount of the obligation.
In many of these Matters, it is n
ot possible to determine
whether any loss is probable, or to estimate reli
ably the amount
of any loss, either as a direct consequence of the relev
ant
proceedings and regulatory matters or as
a result of adverse
impacts or restrictions on NatWest Group’s reputation,
businesses and operations. Numerous leg
al and factual issues
may need to be resolved, including through p
otentially lengthy
discovery and document production exercises a
nd
determination of important factual matters, and by
addressing
novel or unsettled legal questions relevant to the proceedin
gs in
question, before a liability can reasonably be esti
mated for any
claim. NatWest Group cannot predict if, how, o
r when such
claims will be resolved or what
the eventual settlement,
damages, fine, penalty or other relief
, if any, may be,
particularly for claims that are at an ea
rly stage in their
development or where claimants see
k substantial or
indeterminate damages.
There are situations where NatWest Group may pu
rsue an
approach that in some instances le
ads to a settlement
agreement. This may occur in order to
avoid the expense,
management distraction or reputational implic
ations of
continuing to contest liability, or in order to
take account of the
risks inherent in defending claims or regulato
ry matters, even
for those Matters for which NatWest Group believes it
has
credible defences and should prevail on the meri
ts. The
uncertainties inherent in all such Matters
affect the amount and
timing of any potential outflows for both M
atters with respect
to which provisions have been es
tablished and other contingent
liabilities.
It is not practicable to provide an aggregate es
timate of
potential liability for our legal proceedings and regula
tory
matters as a class of contingent liabilities
.
The future outflow of resources in respect of
any Matter may
ultimately prove to be substantially greater th
an or less than
the aggregate provision that NatWest G
roup has recognised.
Where (and as far as) liability cannot be re
asonably estimated,
no provision has been recognised. NatWes
t Group expects that
in future periods, additional provisions, se
ttlement amounts and
customer redress payments will be nece
ssary, in amounts that
are expected to be substantial in some inst
ances. Please refer
to Note 21 for information on ma
terial provisions.
Material Matters in which NatWest Group is cu
rrently involved
are set out below. We have provided information on
the
procedural history of certain Matters, where we belie
ve
appropriate, to aid the understanding of the Mat
ter.
For a discussion of certain risks associated
with NatWest
Group’s litigation and regulatory matters, see the Risk fac
tor
relating to legal, regulatory and
governmental actions and
investigations set out on page
425.
Litigation
Residential mortgage-backed securities (RMBS) litigation in
the US
NatWest Group companies continue to def
end RMBS-related
claims in the US in which the plaintiff, the Feder
al Deposit
Insurance Corporation (FDIC), alleges that cer
tain disclosures
made in connection with the rele
vant offerings of RMBS
contained materially false or misle
ading statements and/or
omissions regarding the underwriting standa
rds pursuant to
which the mortgage loans und
erlying the RMBS were issued. In
Q4 2021, NWMSI settled RMBS cl
aims by the State of New
Mexico for an amount that was covered by an existi
ng
provision. In addition, NWMSI previously agreed to settle a
purported RMBS class action entitled New Jersey
Carpenters
Health Fund v. Novastar Mortgage Inc. et al. fo
r US$55.3
million. This was paid into escrow pendi
ng court approval of
the settlement, which was granted in March 2019, but
which
remains the subject of an appeal by a class mem
ber who does
not want to participate in the se
ttlement.
London Interbank Offered Rate (LIBOR) and other rates
litigation
NWM Plc and certain other members of NatWes
t Group,
including NatWest Group plc, are defendants in a
number of
class actions and individual claims pendin
g in the United States
District Court for the Southern District of New Yo
rk (SDNY)
with respect to the setting of LI
BOR and certain other
benchmark interest rates. The complaints allege th
at certain
members of NatWest Group and other panel banks viola
ted
various federal laws, including t
he US commodities and
antitrust laws, and state statuto
ry and common law, as well as
contracts, by manipulating LIBO
R and prices of LIBOR-based
derivatives in various markets through various
means.
Several class actions relating to USD LIBO
R, as well as more
than two dozen non-class actions concernin
g USD LIBOR, are
part of a co-ordinated proceeding in the SDNY.
In December
2021, the United States Court of Appeals for the Second Ci
rcuit
(US Court of Appeals), reversing a Dece
mber 2016 decision of
the SDNY, held that plaintiffs in
these cases have adequately
asserted the court’s personal jurisdiction ove
r NWM Plc and
other non-US banks, including with respec
t to antitrust class
action claims on behalf of over-the-counter plain
tiffs and
exchange-based purchaser plaintiffs.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
370
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
27 Memorandum items continued
Litigation and regulatory matters
In the same decision, the appellate court affi
rmed the SDNY’s
prior decision that plaintiffs who purchased LIBOR-b
ased
instruments from third parties (as opposed
to the defendants)
lack antitrust standing to pursu
e such claims. The appellate
court remanded these matters to the SDNY f
or further
proceedings in light of its rulings. A se
parate appeal concerning
the SDNY’s dismissal of a fraud c
lass action on behalf of lender
plaintiffs remains pending in the
US Court of Appeals. In March
2020, NatWest Group companies
finalised a settlement
resolving the class action on behalf of bondholde
r plaintiffs
(those who held bonds issued by non-defendants o
n which
interest was paid from 2007 to 20
10 at a rate expressly tied to
USD LIBOR). The amount of the
settlement (which was covered
by an existing provision) has bee
n paid into escrow pending
court approval of the settlement.
The non-class claims filed in th
e SDNY include claims that the
FDIC is asserting on behalf of certain failed US
banks. In July
2017, the FDIC, on behalf of 39 of those failed US
banks,
commenced substantially similar claims against Nat
West Group
companies and others in the High Court of Justice of E
ngland
and Wales. The action alleges collus
ion with regard to the
setting of USD LIBOR and that the defendants b
reached UK
and European competition law, as well as asserting com
mon
law claims of fraud under US law. T
he defendant banks
consented to a request by the
FDIC for discontinuance of the
claim in respect of 20 failed US banks, leaving 19 failed US
banks as claimants. The UK pr
oceedings are at the disclosure
stage.
In addition, there are two class actions rela
ting to JPY LIBOR
and Euroyen TIBOR. The first class action, which rela
tes to
Euroyen TIBOR futures contracts, was dismisse
d by the SDNY
in September 2020 on jurisdictional and other
grounds, and the
plaintiffs have commenced an appeal to
the US Court of
Appeals. The second class action, which rela
tes to other
derivatives allegedly tied to JPY
LIBOR and Euroyen TIBOR,
was dismissed by the SDNY in relation to NWM Plc
and other
NatWest Group companies in Septembe
r 2021. That dismissal
may be the subject of a future appeal
.
In addition to the above, five other class ac
tion complaints were
filed against NatWest Group companies in the S
DNY, each
relating to a different reference rate. In Febru
ary 2017, the
SDNY dismissed the case relating to Eu
ribor for lack of
personal jurisdiction and in Augus
t 2019, the SDNY dismissed
the case relating to Pound Sterl
ing for various reasons.
Plaintiffs’ appeals in both cases remain pendi
ng. In July 2019,
the SDNY dismissed the case re
lating to the Singapore
Interbank Offered Rate and Singapore Swap Off
er Rate (‘SIBOR
/ SOR’) but in March 2021, the US Court of Appeals
reversed
the SDNY’s decision, such that the case has retu
rned to the
SDNY, where it is the subject of
a further motion to dismiss. In
the class action relating to the Australian Bank Bill S
wap
Reference Rate, the SDNY in Fe
bruary 2020 declined to dismiss
the amended complaint as against NWM Plc an
d certain other
defendants, but dismissed it as to other
members of NatWest
Group (including NatWest Group plc). The clai
ms against non-
dismissed defendants (including NWM Plc) are now p
roceeding
in discovery. In June 2021, NWM Plc and the plaintiff
s in the
Swiss Franc LIBOR class action
finalised a settlement resolving
that case. The amount of the se
ttlement (which was covered
by an existing provision) has bee
n paid into escrow pending
court approval of the settlement.
NWM Plc is also named as a def
endant in a motion to certify a
class action relating to LIBOR in the Tel Aviv Dis
trict Court in
Israel. NWM Plc filed a motion for cancellatio
n of service
outside the jurisdiction, which was g
ranted in July 2020.
The claimants appealed that decision and in Nove
mber 2020
the appeal was refused and the claim dismissed by t
he
Appellate Court. The claim could in future be recom
menced
depending on the outcome of an appeal to Isr
ael’s Supreme
Court in respect of dismissal of the substantive
case against
banks that had a presence in Israel.
In January 2019, a class action
antitrust complaint was filed in
the SDNY alleging that the defendants (USD ICE LIBOR p
anel
banks and affiliates) have conspired to supp
ress USD ICE
LIBOR from 2014 to the present by submitti
ng incorrect
information to ICE about their borrowing costs. The Na
tWest
Group defendants are NatWest Group plc, NWM Plc, N
WMSI
and NWB Plc. The defendants
made a motion to dismiss this
case, which was granted by the
court in March 2020. One
plaintiff sought to appeal the dismissal, but on 14 Feb
ruary
2022, the US Court of Appeals dismissed the
appeal because
that plaintiff lacks standing to maintain the
appeal.
In August 2020, a complaint was f
iled in the United States
District Court for the Northern
District of California by several
United States consumer borrowers against the USD IC
E LIBOR
panel banks and their affiliates, alleging
that the normal
process of setting USD ICE LIBO
R amounts to illegal price-
fixing, and also that banks in the United States have ille
gally
agreed to use LIBOR as a component of price in
variable
consumer loans. The NatWest Group defendants a
re NatWest
Group plc, NWM Plc, NWMSI and NWB Plc. The pl
aintiffs seek
damages and to prevent the enf
orcement of LIBOR-based
instruments through injunction. Defe
ndants have filed a motion
to dismiss, which remains pending.
FX litigation
NWM Plc, NWMSI and/or NatWe
st Group plc are defendants in
several cases relating to NWM Plc’s foreign exc
hange (FX)
business. In 2015, NWM Plc pai
d US$255 million to settle the
consolidated antitrust class acti
on filed in the SDNY on behalf
of persons who entered into over-the-counte
r FX transactions
with defendants or who traded FX inst
ruments on exchanges.
In 2018, some members of the settlement class who
opted out
of that class action settlement filed their own non-class
complaint in the SDNY asserting antitrust claims a
gainst NWM
Plc, NWMSI and other banks. Those
opt-out claims are
proceeding in discovery.
In April 2019, some of the sam
e claimants in the opt-out case
described above, as well as othe
rs, served proceedings (which
are ongoing) in the High Court of Ju
stice of England and Wales,
asserting competition claims ag
ainst NWM Plc and several
other banks. The claim was transferred from
the High Court of
Justice of England and Wales in December 2021 an
d registered
in the Competition Appeal Trib
unal in January 2022.
An FX-related class action, on behalf of ‘consu
mers and end-
user businesses’, is proceeding in the SDNY against N
WM Plc
and others. Plaintiffs have filed a motion fo
r class certification,
which defendants are opposing
.
In May 2019, a cartel class action was filed in the Fede
ral Court
of Australia against NWM Plc and four other ba
nks on behalf of
persons who bought or sold currency through FX spots o
r
forwards between 1 January 200
8 and 15 October 2013 with a
total transaction value exceeding AUD $0.5 millio
n. The
claimant has alleged that the banks, including NWM
Plc,
contravened Australian competition law by sh
aring information,
coordinating conduct, widening s
preads and manipulating FX
rates for certain currency pairs during this period. Nat
West
Group plc and NWMSI have been named in the action as ‘o
ther
cartel participants’, but are not respondents. The claim
was
served in June 2019 and, after a number of interlocu
tory
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
371
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
27 Memorandum items continued
Litigation and regulatory matters
pleading disputes, NWM Plc is preparing its defence
.
In July and December 2019, two se
parate applications seeking
opt-out collective proceedings orders we
re filed in the UK
Competition Appeal Tribunal against NatWes
t Group plc, NWM
Plc and other banks. Both appli
cations have been brought on
behalf of persons who, between 18
December 2007 and 31
January 2013, entered into a re
levant FX spot or outright
forward transaction in the EEA with a relevant fin
ancial
institution or on an electronic communica
tions network. A
hearing to determine class certif
ication and which of the
applications should be permitted to represent the class
took
place in July 2021 and judgment is awaited.
In November 2020, proceedings were iss
ued in the High Court
of Justice of England and Wales against NWM Plc by a cl
aimant
who sought an account of profits and/or da
mages in respect of
alleged historical FX trading misc
onduct. The claim was served
on NWM Plc in March 2021 and discontinued in
December
2021.
Two motions to certify FX-relat
ed class actions were filed in the
Tel Aviv District Court in Israel i
n September and October 2018,
and were subsequently consolidated into one motion. The
consolidated motion to certify, which n
ames The Royal Bank of
Scotland plc (now NWM Plc) and several other banks
as
defendants, was served on NW
M Plc in May 2020. NWM Plc has
filed a motion challenging the pe
rmission to serve the
consolidated motion outside the Israeli juris
diction, which
remains pending.
In December 2021, a claim was
issued in the Netherlands
against NatWest Group plc, NWM Plc and NWM N.
V. by
Stichting FX Claims, seeking a declar
ation from the court that
anti-competitive FX market conduct descri
bed in decisions of
the European Commission of 16 May 2
019 is unlawful, along
with unspecified damages. The c
laimant has indicated that it
may seek to amend its claim to also refer to the Dece
mber
2021 decision by the EC (described below under “F
oreign
exchange related investigations”
). A hearing is scheduled for
June 2022.
Certain other foreign exchange transaction
related claims have
been or may be threatened. Na
tWest Group cannot predict
whether all or any of these claims will be pu
rsued.
Government securities antitrust litigation
NWMSI and certain other US broke
r-dealers are defendants in
a consolidated antitrust class ac
tion pending in the SDNY on
behalf of persons who transacte
d in US Treasury securities or
derivatives based on such instruments, including futu
res and
options. The plaintiffs allege that defendants rig
ged the US
Treasury securities auction bidding process to
deflate prices at
which they bought such securities and colluded to inc
rease the
prices at which they sold such se
curities to plaintiffs. The
complaint was dismissed in Ma
rch 2021. Plaintiffs have filed an
amended complaint, which defe
ndants are again seeking to
have dismissed
.
Class action antitrust claims commenced in Ma
rch 2019 are
pending in the SDNY against NWM Plc, NW
MSI and other banks
in respect of Euro-denominated bonds issued by
European
central banks (EGBs). The complaint alleges a co
nspiracy
among dealers of EGBs to widen the bid-ask spreads
they
quoted to customers, thereby increasing the prices
customers
paid for the EGBs or decreasing the p
rices at which customers
sold the bonds. The class consists of those wh
o purchased or
sold EGBs in the US between 20
07 and 2012. The defendants
filed a motion to dismiss this m
atter, which was granted by the
court in respect of NWM Plc and NWMSI in July 2
020. Plaintiffs
have filed an amended complai
nt which defendants are seeking
to have dismissed.
Swaps antitrust litigation
NWM Plc and other members of NatWest Group, inclu
ding
NatWest Group plc, as well as a number of other interes
t rate
swap dealers, are defendants in several cases pen
ding in the
SDNY alleging violations of the US antitrust l
aws in the market
for interest rate swaps. There is a consolid
ated class action
complaint on behalf of persons who entered in
to interest rate
swaps with the defendants, as well as non-class acti
on claims
by three swap execution facilities (Te
raExchange, Javelin, and
trueEx). The plaintiffs allege that the swa
p execution facilities
would have successfully e
stablished exchange-like trading of
interest rate swaps if the defen
dants had not unlawfully
conspired to prevent that from happening through
boycotts
and other means. Discovery in these
cases is complete, and the
plaintiffs’ motion for class certification remains pen
ding.
In June 2021, a class action antitrust complaint w
as filed
against a number of credit default swap dealers in Ne
w Mexico
federal court on behalf of persons who, fr
om 2005 onwards,
settled credit default swaps in the United States by
reference to
the ISDA credit default swap auction protocol. The com
plaint
alleges that the defendants conspired to manipul
ate that
benchmark through various means in violation of t
he antitrust
laws and the Commodity Exch
ange Act. The defendants
include several NatWest Group companies, includin
g NatWest
Group plc. Defendants are seeking dismiss
al.
Odd lot corporate bond trading antitrust litigation
In October 2021, the SDNY gra
nted defendants’ motion to
dismiss the class action antitrust com
plaint alleging that from
August 2006 onwards various sec
urities dealers, including
NWMSI, conspired artificially to widen sp
reads for odd lots of
corporate bonds bought or sold in the United Sta
tes secondary
market and to boycott electronic trading platfor
ms that would
have allegedly promoted pricing competitio
n in the market for
such bonds. Plaintiffs have com
menced an appeal of the
dismissal.
Spoofing litigation
In December 2021, three substantially s
imilar class actions
complaints were filed in federal court in the United S
tates
against NWM Plc and NWMSI alle
ging Commodity Exchange
Act and common law unjust enrichment clai
ms arising from
manipulative trading known as
spoofing. The complaints refer
to NWM Plc’s December 2021 spoofing-rela
ted guilty plea
(described below under “US inv
estigations relating to fixed-
income securities”) and purport to asser
t claims on behalf of
those who transacted in US Treasury se
curities and futures and
options on US Treasury securities between 20
08 and 2018.
The three complaints are pending in the United St
ates District
Court for the Northern District
of Illinois.
Madoff
NWM N.V. is a defendant in two actions f
iled by the trustee for
the bankruptcy estates of Bernard L. Mad
off and Bernard L.
Madoff Investment Securities L
LC, in bankruptcy court in New
York, which together seek to clawback more than U
S$298
million that NWM N.V. allegedly received fro
m certain Madoff
feeder funds and certain swap counterpa
rties. The claims were
previously dismissed, but as a re
sult of an August 2021 decision
by the US Court of Appeals, the
y will now proceed in the
bankruptcy court subject to NWM N.V.’s legal and factu
al
defences.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
372
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
27 Memorandum items continued
Litigation and regulatory matters
EUA trading litigation
NWM Plc was a named defendant in civil p
roceedings before
the High Court of Justice of England an
d Wales brought in 2015
by ten
companies (all in liquidation) (the ‘L
iquidated
Companies’) and their respective l
iquidators (together, ‘the
Claimants’). The Liquidated Companies previously
traded in
European Union Allowances (E
UAs) in 2009 and were alleged
to be VAT defaulting traders within (or otherwise connected
to)
EUA supply chains of which N
WM Plc was a party. In March
2020, the court held that NWM Plc and Me
rcuria Energy
Europe Trading Limited (‘Mercuria’) were liable f
or dishonestly
assisting and knowingly being a party to fraudulen
t trading
during a seven business day pe
riod in 2009.
In October 2020, the High Court quantified tot
al damages
against NWM Plc and Mercuria
at £45 million plus interest and
costs, and permitted the defendants to appeal to
the Court of
Appeal. In May 2021 the Court of A
ppeal set aside the High
Court’s judgment and ordered that a retrial t
ake place before a
different High Court judge. The claimants have soug
ht
permission from the Supreme Court to appeal. The Cou
rt of
Appeal also dismissed an appeal by Mercu
ria against the
finding by the High Court that N
WM Plc and Mercuria were
both vicariously liable. Mercuria has sought pe
rmission from the
Supreme Court to appeal that decision.
Offshoring VAT assessments
HMRC issued protective tax asse
ssments in 2018 against
NatWest Group plc totalling £143 million relating to un
paid VAT
in respect of the UK branches
of two NatWest Group
companies registered in India. NatWest G
roup formally
requested reconsideration by HMRC of their asse
ssments, and
this process was completed in
November 2020. HMRC upheld
their original decision and, as a result, NatWest Group plc
lodged an appeal with the Tax Tribunal and an applic
ation for
judicial review with the High Court of Justice of
England and
Wales, both in December 2020
. In order to lodge the appeal
with the Tax Tribunal, NatWest Group plc was requi
red to pay
the £143 million to HMRC, and payment was made in
December 2020. The appeal and the application for judici
al
review have both been stayed pending
resolution of a separate
case involving another bank.
US Anti-Terrorism Act litigation
NWB Plc is a defendant in lawsuits filed in the Uni
ted States
District Court for the Eastern District of Ne
w York by a number
of US nationals (or their estates, survivors, o
r heirs) who were
victims of terrorist attacks in Isr
ael. The plaintiffs allege that
NWB Plc is liable for damages arising from those
attacks
pursuant to the US Anti-Terrorism Act because NWB Plc
previously maintained bank accounts and tra
nsferred funds for
the Palestine Relief & Development Fund, an or
ganisation which
plaintiffs allege solicited funds for Hamas, t
he alleged
perpetrator of the attacks.
In March 2019, the trial court granted summary judg
ment in
favour of NWB Plc. In April 2021
, the US Court of Appeals
affirmed the trial court’s judgme
nt in favour of NWB Plc. In
September 2021, the plaintiffs filed a petition seeking
discretionary review by the United States Su
preme Court, and
that petition remains pending.
NWM N.V. and certain other financial institu
tions are
defendants in several actions filed by a number of
US nationals
(or their estates, survivors, or he
irs), most of whom are or were
US military personnel, who were
killed or injured in attacks in
Iraq between 2003 and 2011. NWM Plc is also
a defendant in
some of these cases.
According to the plaintiffs’ allegations, the def
endants are liable
for damages arising from the attacks because they allegedly
conspired with Iran and certain Iranian banks
to assist Iran in
transferring money to Hezbollah and the Iraqi te
rror cells that
committed the attacks, in violation of the US Anti-Ter
rorism
Act, by agreeing to engage in ‘stripping’ of transac
tions
initiated by the Iranian banks so that the I
ranian nexus to the
transactions would not be detected.
The first of these actions was filed in the United S
tates District
Court for the Eastern District of New York in Nove
mber 2014.
In September 2019, the district court dismissed t
he case,
finding that the claims were def
icient for several reasons,
including lack of sufficient allegations as to
the alleged
conspiracy and causation. The plaintiff
s are appealing the
decision to the US Court of Appeals. Another action, filed i
n the
SDNY in 2017, was dismissed in March 2019
on similar
grounds, but remains subject to appeal to the US Cou
rt of
Appeals. Other follow-on actions that are subst
antially similar
to the two that have now been dismisse
d are pending in the
same courts.
Securities underwriting litigation
NWMSI is an underwriter defen
dant in securities class actions
in the US in which plaintiffs gene
rally allege that an issuer of
public securities, as well as the underwriters of the sec
urities
(including NWMSI), are liable to purchasers for
misrepresentations and omissions made i
n connection with the
offering of such securities.
1MDB litigation
A claim for a material sum has
been issued, but not served,
recently in Malaysia by 1MDB against Cout
ts & Co Ltd for
alleged losses in connection wit
h the 1MDB fund. Coutts & Co
Ltd is a company registered in
Switzerland and is in wind-down
following the announced sale of its business asse
ts in 2015.
Regulatory matters (including investigations and
customer redress programmes)
NatWest Group’s businesses and financial condition c
an be
affected by the actions of various
governmental and regulatory
authorities in the UK, the US, the EU and else
where. NatWest
Group has engaged, and will continue to eng
age, in discussions
with relevant governmental an
d regulatory authorities,
including in the UK, the US, the EU and else
where, on an
ongoing and regular basis, and in response to infor
mal and
formal inquiries or investigation
s, regarding operational,
systems and control evaluations and issues
including those
related to compliance with applicable laws
and regulations,
including consumer protection, inves
tment advice, business
conduct, competition/anti-trust, VAT recovery, anti-
bribery,
anti-money laundering and sanctions regimes
.
NWM Group in particular has been providing infor
mation
regarding a variety of matters, including, fo
r example, offering
of securities, the setting of benchmark rates and
related
derivatives trading, conduct in the foreign e
xchange market,
product mis-selling and various issue
s relating to the issuance,
underwriting, and sales and trading of fixed-i
ncome securities,
including structured products and government securi
ties, some
of which have resulted, and oth
ers of which may result, in
investigations or proceedings.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
373
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
27 Memorandum items continued
Litigation and regulatory matters
Any matters discussed or identif
ied during such discussions and
inquiries may result in, among
other things, further inquiry or
investigation, other action bein
g taken by governmental and
regulatory authorities, increased costs being i
ncurred by
NatWest Group, remediation of
systems and controls, public or
private censure, restriction of NatWest Group’s business
activities and/or fines. Any of the events or circums
tances
mentioned in this paragraph or below could have
a material
adverse effect on NatWest Group, its business, au
thorisations
and licences, reputation, results of operations o
r the price of
securities issued by it, or lead t
o material additional provisions
being taken.
NatWest Group is co-operating f
ully with the matters described
below.
Investigations
US investigations relating to fixed-income securities
In December 2021, NWM Plc pl
ed guilty in the United States
District Court for the District of Connecticut to one cou
nt of
wire fraud and one count of secu
rities fraud in connection with
historical spoofing conduct by former empl
oyees in US
Treasuries markets between January 2008 and May 20
14 and,
separately, during approximately
three months in 2018.
The 2018 trading occurred duri
ng the term of a non-
prosecution agreement (NPA) be
tween NWMSI and the United
States Attorney's Office for the District of Conne
cticut (USAO
CT), under which non-prosecution was co
nditioned on NWMSI
and affiliated companies not en
gaging in criminal conduct
during the term of the NPA. The relevant t
rading in 2018 was
conducted by two NWM traders in Singapore an
d breached
that NPA.
The plea agreement reached with the US Dep
artment of
Justice and the USAO CT resolves
both the spoofing conduct
and the breach of the NPA.
As required by the resolution a
nd sentence imposed by the
court, NWM Plc is subject to a three-year period of
probation
and has paid a US$25.2 million criminal fine, a
pproximately
US$2.8 million in criminal forfeiture and app
roximately US$6.8
million in restitution out of exist
ing provisions. The plea
agreement also imposes an ind
ependent corporate monitor. In
addition, NWM Plc has committed to co
mpliance programme
reviews and improvements and
agreed to reporting and co-
operation obligations.
Other material adverse collateral consequence
s may occur as
a result of this matter, as furthe
r described in the Risk factor
relating to legal, regulatory and
governmental actions and
investigations set out on page
425.
Foreign exchange related investigations
In recent years, NWM Plc paid significant penal
ties to resolve
investigations into its FX business by
the FCA, the Commodity
Futures Trading Commission, the US Dep
artment of Justice, the
Board of Governors of the Fede
ral Reserve System, the
European Commission (EC) and others. In Decembe
r 2021, the
EC announced that a settlement had been re
ached with
NatWest Group plc, NWM Plc and other banks in
relation to its
investigation into past breaches
of competition law regarding
spot foreign exchange trading.
NatWest Group plc and NWM
Plc were fined EUR 32.5 million in total relating t
o conduct that
took place between 2011 and 201
2. The fine was covered by
existing provisions. This concludes
the EC’s investigations into
NatWest Group’s past spot foreign exchange trading
activity.
FCA investigation into NatWest Group’s compliance with the
Money Laundering Regulations 2007
Following an FCA investigation, commenced in 201
7, into
potential breaches of the UK Money Laundering Regul
ations
2007 (‘MLR 2007
’), NWB Plc pled guilty in October 2021 to
three offences under regulation 45
(1) of the MLR 2007 for
failure to comply with regulation 8(1) between 7 Nove
mber
2013 and 23 June 201
6, and regulat
ions 8(3) and 14
(1) between
8 November 2012 and 23 June 20
16. These regulations
required the firm to determine, conduct and demons
trate risk
sensitive due diligence and ongoing monit
oring of its
relationships with its customers f
or the purposes of preventing
money laundering. The offences
relate to operational
weaknesses between 2012 and 2
016, during which period NWB
Plc did not adequately monitor the accoun
ts of a UK
incorporated customer. In December 2021, NWB Plc w
as fined
£264.8 million, incurred a confiscation order and w
as ordered
to pay costs. This was met by NWB Plc fro
m existing provisions,
with a small additional provisio
n taken in Q4 2021.
Other material adverse collateral consequence
s may occur as
a result of this matter, as furthe
r described in the Risk factor
relating to legal, regulatory and
governmental actions and
investigations set out on page
425.
Systematic Anti-Money Laundering Programme assessment
In December 2018, the FCA commenced a Systematic A
nti-
Money Laundering Programme
assessment of NatWest Group.
In August 2019, the FCA instru
cted NatWest Group to appoint a
Skilled Person under section 166 of the Financial
Services and
Markets Act 2000 to provide assurance on financi
al crime
governance arrangements in relation to two financial c
rime
change programmes. The Skilled Person’s final re
port was
received in January 2022.
Customer redress programmes
FCA review of NatWest Group’s treatment of SMEs
In 2014, the FCA appointed an independen
t Skilled Person
under section 166 of the Financial Services a
nd Markets Act
2000 to review NatWest Group’s
treatment of SME customers
whose relationship was managed by NatWest Group’s
Global
Restructuring Group (GRG) in the
period 1 January 2008 to 31
December 2013. In response to the Skilled Person’s final
report
and update in 2016, NatWest Group annou
nced redress steps
for SME customers in the UK and the Repu
blic of Ireland that
were in GRG between 2008 an
d 2013. These steps were (i) an
automatic refund of certain complex fees; and
(ii) a new
complaints process, overseen b
y an independent third party.
Both processes have now been
completed. Accordingly,
NatWest Group retains only a small residual pro
vision at
December 2021.
Investment advice review
In October 2019, the FCA notifi
ed NatWest Group of its
intention to appoint a Skilled Pe
rson under section 166 of the
Financial Services and Markets Ac
t 2000 to conduct a review of
whether NatWest Group’s past busi
ness review of investment
advice provided during 2010 to 20
15 was subject to
appropriate governance and accountability and led
to
appropriate customer outcomes. T
he Skilled Person’s review
has concluded and, after discuss
ion with the FCA, NatWest
Group is now conducting additional
review / remediation work.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
374
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
27 Memorandum items continued
Litigation and regulatory matters
Review and investigation of treatment of tracker mortgage
customers in Ulster Bank Ireland DAC
In December 2015, correspondence was received fro
m the CBI
setting out an industry examination framework i
n respect of the
sale of tracker mortgages from approxi
mately 2001 until the
end of 2015. The redress and compensation ph
ase has
concluded, although an appeals process is c
urrently anticipated
to run until the end of 2022. NatWest Grou
p has made
provisions totalling €358 million (£3
00 million), of which €335
million (£281 million) had been utilised by 31
December 2021.
UBIDAC customers have lodged tracker mortgage co
mplaints
with the Financial Services and Pensions Ombu
dsman (FSPO).
UBIDAC is challenging three FSPO adjudic
ations in the Irish
High Court. The outcome and impact of that challen
ge on those
and related complaints is uncertain but may be
material.
UBIDAC has identified further legacy business is
sues and these
remediation programmes are ongoing. Nat
West Group has
made provisions of €188 million (£1
58 million), of which €156
million (£131 million) had been utilised by 31
December 2021
for these programmes.
28 Analysis of the net investment in business interests and intangible assets
This note shows cash flows relating to obtainin
g or losing control of associates or subsidi
aries and net assets and liabilities
purchased and sold. These cash f
lows are presented as investing activities on the cash flow st
atement.
2021
2020
2019
£m
£
m
£m
Fair value given for businesses acquired
(1)
(55)
Additional investment in associates
(51)
(40)
Net assets/liabilities purchased
(3,128)
Net outflow of cash in respect of acquisitions
(3,179)
(40)
(55)
Sale of interests in associates
27
Net assets/liabilities disposed
114
288
351
Profit on disposal
55
3
Net inflow of cash in respect of disposals
169
318
351
Cash expenditure on intangible
assets
(479)
(348)
(380)
Net outflow of cash
(3,489)
(70)
(84)
(1)
2019 includes the purchase
of Free agent.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
375
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
29 Analysis of changes in finan
cing during the year
This note shows cash flows an
d non-cash movements relating to the f
inancing activities of the Group. These ac
tivities reflect
movements in share capital, share premiu
m, paid-in equity, subordinated liabilities and MR
ELs.
Share capita
l, share premium,
and paid
-
in equity
Subordinated liabilities
MRELs
2021
2020
2019
2021
2020
2019
2021
2020
2019
£m
£m
£
m
£m
£m
£m
£m
£m
£m
At 1 January
18,239
17,246
17,134
9,962
9,979
10,535
20,873
19,249
16,821
Ordinary shares issued
17
Issue of paid-in equity
937
2,218
Issue of subordinated liabilities
1,634
1,631
577
Redemption of subordinated liabilities
(4,765)
(3,502)
(1,108)
Interest on subordinated liabilities
(321)
(510)
(533)
Issue of MRELs
3,383
1,309
3,640
Maturity/redemption of MRELs
(2)
(1,285)
Interest on MRELs
(647)
(671)
(428)
Net cash inflow/(outflow) from financin
g
937
2,218
17
(3,452)
(2,381)
(1,064)
2,736
636
1,927
Ordinary shares issued
87
52
95
Share cancellation
(698)
Effects of foreign exchange
(18)
(234)
(315)
(190)
(514)
(683)
Changes in fair value of subordinated
liabilities and MRELs
(434)
133
317
(649)
829
539
Paid in equity reclassified to subordina
ted
liabilities
(2,046)
(1,277)
1,915
1,632
Loss on sale of subordinated liabilities
and MRELs
145
324
Interest on subordinated liabilities
and MRELs
311
509
506
653
673
645
At 31 December
16,519
18,239
17,246
8,429
9,962
9,979
23,423
20,873
19,249
30 Analysis of cash and cash equivalents
In the cash flow statement, cash and cash equiv
alents comprises c
ash, loans to banks and treasury bills with an o
riginal maturity
of less than three months that are readily conve
rtible to known amounts of cash and subject
to insignificant risk of change in value.
2021
2020
2019
£m
£
m
£m
At 1 January
- cash
124,489
80,993
91,368
-
cash equivalents
14,710
19,595
17,568
139,199
100,588
108,936
Net increase/(decrease) in cash and c
ash equivalents
51,507
38,611
(8,348)
At 31 December
190,706
139,199
100,588
Comprising:
Cash and balances at central banks
177,757
124,489
80,993
Trading assets
7,137
9,220
12,578
Other financial
assets
16
173
459
Loans to banks - amortised cost
(1)
5,796
5,317
6,558
Cash and cash equivalents
190,706
139,199
100,588
(1)
Includes cash collateral posted with bank counterpart
ies in respect of derivative liabilities of £4,293 million (2020 - £7,592 million; 2019 - £7,570 million).
Certain members of NatWest Group are
required by law or regulation to m
aintain balances with the central banks in the
jurisdictions in which they operate. Natwest M
arkets N.V.
had mandatory reserve deposi
ts with
De Nederlandsche Bank N.V.
of
€60 million (2020 - €81 million, 201
9 €47 million).
The Royal Bank of Scotland Inte
rnational (Holdings) Limited had balances
with
Central Bank of Luxembourg of €
123 million (2020 - €59 million, 2019
€58 million)
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
376
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
31 Directors' and key management remuneration
Directors and key management are
remunerated for services rendered in the peri
od. The executive directors may pa
rticipate in
the company's long-term incentive plans, execu
tive share option and sharesave schemes and
details of their interests in the
company's shares arising from their participation a
re given in the directors' remuneration rep
ort. Details of the remuneration
received by each director are also given in the di
rectors' remuneration report
.
Key management comprises me
mbers of the NatWest Group plc and NWH L
td Boards, members of the NatWest Group plc
a
nd
NWH Ltd Executive Committee
s, and the Chief Executives of NatWest Markets Plc and RBS
International (Holdings) Limited. T
his is
on the basis that these individuals have
been identified as Persons Discharging Man
agerial Responsibilities of NatWest Group
plc
under the new governance struc
ture.
2021
2020
Directors' remuneration
£000
£000
Non-executive directors emoluments
1,641
1,708
Chairman and executive directors emoluments
4,688
4,349
6,329
6,057
Amounts receivable under long-term incentive
plans and share option plans
549
609
Total
6,878
6,666
No directors accrued benefits under defined bene
fit schemes or defined contribution schemes
d
uring 2021 and 2020.
Compensation of key management
The aggregate remuneration of directors and o
ther members of key management during
the year was as follows:
2021
2020
£000
£000
Short-term benefits
18,124
18,718
Post-employment benefits
380
474
Share
-
based payments
2,491
3,249
20,995
22,441
32 Transactions with directors and key management
This note presents information relating to any
transactions with directors and key manageme
nt. Key management comprises
directors of the company and Persons Discharging Man
agerial Responsibilities (PDMRs) of Na
tWest Group plc.
For the purposes of IAS 24 Related pa
rty disclosures, key management comp
rise directors of the company and PDMRs of NatWest
Group plc. Key management have banking rela
tionships with NatWest Group entities which are entered i
nto in the normal course
of business and on substantially
the same terms, including interest rates and security, as f
or comparable transactions with other
persons of a similar standing or, where a
pplicable, with other employees. T
hese transactions did not involve more than the no
rmal
risk of repayment or present other unfavour
able features.
Amounts in the table below are attributed t
o each person at their highest level of N
atWest Group key management.
2021
2020
£000
£000
Loans to customers - amortised cost
9,128
5,165
Customer deposits
51,018
45,747
At 31 December 2021, amount
s outstanding in relation to transactions, arrangemen
ts and agreements entered into by
authorised
institutions in NatWest Group, as
defined in UK legislation, were £7,0
23,190 in respect of loans to seven persons who were
directors of the company at any
time during the financial period.
Notes to the c
onsolidated fi
nancial statement
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
377
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
33 Related parties
A related party is a person or entity that is rela
ted to the entity that is preparing its financial st
atements. Transactions between an
entity and any related party ar
e disclosed in the financial statements to ensure readers
are aware of how financial statements may
be affected by these transactions
.
UK Government
The UK Government through H
M Treasury is the ultimate
controlling party of The NatWes
t Group plc. The UK
Government’s shareholding is managed by
UK Government
Investments Limited, a compan
y wholly owned by the UK
Government. As a result the UK Government and U
K
Government controlled bodies are related pa
rties of the Group.
At 31 December 2021, HM Treasury’s holding in
the company’s
ordinary shares was 52.96%.
NatWest Group enters into tran
sactions with many of these
bodies. Transactions include the
payment of: taxes – principally
UK corporation tax (Note 7) and value a
dded tax; national
insurance contributions; local autho
rity rates; and regulatory
fees and levies (including the bank levy (No
te 3) and FSCS levy
(Note 27) - together with banking transactio
ns such as loans
and deposits undertaken in the nor
mal course of banker-
customer relationships.
Bank of England facilities
NatWest Group may participate in a nu
mber of schemes
operated by the Bank of England in the no
rmal course of
business.
Members of NatWest Group that are UK aut
horised institutions
are required to maintain non-interest be
aring (cash ratio)
deposits with the Bank of Engla
nd amounting to 0.406% of their
average eligible liabilities in excess
of £600 million. They also
have access to Bank of England reserve acc
ounts: sterling
current accounts that earn interest at the Bank of En
gland Base
rate.
NatWest Group provides guarantees for certain subsi
diaries
liabilities to the Bank of England.
Other related parties
In their roles as providers of fin
ance, NatWest Group
companies provide development and other type
s of capital
support to businesses. These
investments are made in the
normal course of business. In some instances
, the
investment may extend to ownership or con
trol over 20% or
more of the voting rights of the investee company.
NatWest Group recharges NatWes
t Group Pension Fund with
the cost of administration servi
ces incurred by it. The
amounts involved are not material to NatWest
Group.
In accordance with IAS 24, transactions
or balances
between NatWest Group entitie
s that have been eliminated
on consolidation are not report
ed.
The captions in the primary fin
ancial statements of the
parent company include amounts attributable
to
subsidiaries. These amounts have bee
n disclosed in
aggregate in the relevant notes
to the financial statements.
Other net income/(expenses) represents the s
hare of post-
tax results of associates and joint ventures, p
rofit (or loss) on
disposal of subsidiaries, associates and joint
ventures, and
gains on acquisitions.
34 Post balance sheet events
A
post balance sheet event is an event that takes
place between 31 December 2021 (reportin
g date) and 17 February 2022 (date
of approval of these financial statements). Significan
t events are included in the financial state
ments either to provide new
information about conditions that existe
d at 31 December 2021, including esti
mates used to prepare the financial statements
(known as an adjusting event) or to provide new i
nformation about conditions that did not exist at 31
December 2021 (non-
adjusting events). This note provides infor
mation relating to material non-adjusting events.
On 27 January 2022, NatWest Group announced
that we will create a new franchise, Comme
rcial and Institutional, bringing
together our Commercial, NatWes
t Markets and RBS International businesses to fo
rm a single franchise, with common objectives,
to best support our customers across the f
ull non-personal customer lifecycle. O
ur reporting will follow this new structure from Q1
2022.
Regulatory calls were announce
d as a result of the PRA determination that certai
n instruments can no longer be included as
part
of Tier 1 capital on a solo and/or consolida
ted basis after 31 December 2021:
On 11 February 2022, NatWest Group plc gave no
tice to noteholders of the redemption of its
€1.5 billion Fixed to Floating Rate
notes due 8 March 2023. The notes will be redee
med on the optional redemption date of 8 M
arch 2022. Payment of principal and
accrued interest will be settled upon redemption
at par. The call is because the note will cease
to be MREL eligible from 8 March
2022.
Other than as disclosed in the accounts, there h
ave been no other significant events be
tween 31 December 2021 and the d
ate of
approval of these accounts whic
h would require a change or additional disclosure.
On 1 February 2022, NatWest Group plc gave notice of
redemption to holders of the USD Series U N
on-Cumulative Dollar
Preference Shares (ISIN US3905
7AA62). The notional outstanding of $1,01
3
m
illion
plus dividends for the current period to,
but excluding the redemption date
of 31 March 2022 will be paid to noteholders at par.
On 1 February 2022, NatWest Group plc gave notice of
redemption to holders of the $1,200
m
illion 7.648% dollar Perpetual
Regulatory Tier One Security (ISIN US7800
97AH44). The notional outstanding of $
67.5 million plus interest for the current
period will be paid to noteholders at a
make whole price calculated at least one business d
ay prior to the redemption date of 3
March 2022.
Parent com
pany financi
al statement
s and notes
NatWest Group
A
nnual Repor
t and Accou
nts 2021
378
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Balance sheet as at 31 December 2021
Note
2021
2020
£m
£m
Assets
Derivatives with subsidiaries
974
1,580
Amounts due from subsidiaries
4
29,962
26,910
Other financial assets
668
579
Investments in Group undertakings
9
48,835
46,229
Other assets
38
117
Total assets
80,477
75,415
Liabilities
Amounts due to subsidiaries
4
378
723
Derivatives
704
1,102
Other financial liabilities
23,600
21,056
Subordinated liabilities
8
7,740
7,944
Other liabilities
150
151
Total liabilities
32,572
30,976
Owners’ equity
47,905
44,439
Total liabilities and equity
80,477
75,415
Owners’ equity includes a total comprehensive p
rofit for the year, dealt with in the accoun
ts of the parent company, of £7,14
1
million (2020 - £9,598 million loss
). This is primarily due to a VIU write back on subsidia
ries and intercompany dividends that
eliminate on consolidation.
As permitted by section 408(3) of the Companies Act 200
6, the primary financial statements o
f the company do not include an
income statement or a statement of co
mprehensive income.
The accompanying notes on pages 38
1 to 394 form an integral part of these financial stateme
nts.
The accounts were approved by the Board of di
rectors on 17 February 2022 and signed on it
s behalf by:
Howard Davies
Alison Rose-Slade
Katie Murray
NatWest Group plc
Chairman
G
roup Chief Executive Off
icer
Group Chief Financial Officer
Registered No. SC45551
Parent company
financial s
tatements and n
otes continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
379
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Statement of changes in equity for the year ended 31 December 2021
2021
2020
2019
£m
£m
£
m
Called-up share capital - at 1 January
12,129
12,094
12,049
Ordinary shares issued
37
35
45
Share cancellation
(1,3)
(698)
At 31 December
11,468
12,129
12,094
Paid
-
in equity
-
at 1 January
4,979
4,047
4,047
Redeemed
(1,277)
Reclassified
(2)
(2,037)
Securities issued during the period
933
2,209
At 31 December
3,875
4,979
4,047
Share
premium
-
at 1 January
1,111
1,094
1,027
Ordinary shares issued
50
17
67
At 31 December
1,161
1,111
1,094
Cash flow hedging reserve - at 1 January
42
67
83
Amount recognised in equity
8
4
18
Amount transferred from equity
to earnings
(12)
(33)
(39)
Tax
(2)
4
5
At 31 December
36
42
67
Capital Redemption reserve - at 1 January
Share cancellation
698
At 31 December
698
Own Shares held - at 1 January
Shares issued under employee share schemes
37
Own shares acquired
(385)
At 31 December
(348)
Retained earnings - at 1 January
26,178
36,485
37,181
Profit/(Loss) attributable to ordinary shareh
olders and other equity owners
7,147
(9,573)
2,728
Equity preference dividends paid
(19)
(26)
(39)
Ordinary dividend paid
(693)
(3,018)
Paid-in equity dividends paid
(299)
(355)
(
367)
Unclaimed dividend
2
Shares issued under employee share schemes
(1)
Shares repurchased during the ye
ar
(1,423)
Redemption/reclassification of paid-in equity
125
(355)
At 31 December
31,015
26,178
36,485
Owners’ equity at 31 December
47,905
44,439
53,787
(1)
In March 2021, there was an agreement with HM Treasury to buy 591
million ordinary shares in the Company from UK Government Investments Ltd (UKGI), at 190.5p per share for
the total consideration of £1.13 billion. NatWest Group cancelled 391 million of the purchased ordinary shares, amounting to £744
million excluding fees, and held the remaining 200
million in own shares held, amounting to £381 million excluding fees. T
he nominal value of the share cancellation has been transferred to the capital redemption reserve.
(2)
In July 2021, paid-in equity
reclassified to liabili
ties as th
e result of a call in August 2021 of US$2.65 billion AT1 Capital notes.
(3)
In line with the announcement in July 2021
, NatWest Group plc repurchased and cancelled 310.8 million shares for total consideration of £676.2 million excluding fees. Of the 310.8
million shares bought back, 2.8 million sha
res were settled and cancelled in January 2022. The nominal value of the share cancellations has been transferred to the capital
redemption reserve with the share premium element to retained earnings.
(4)
The total distributable rese
rves for the Bank i
s £31
,015 million (2020 – 26,178 million).
The accompanying notes on pages 38
1 to 394 form an integral part of these financial stateme
nts
.
Parent company
financial s
tatements and n
otes continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
380
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Cash flow statement for the year ended 31 December 2021
2021
2020
2019
£m
£m
£
m
Operating profit/(loss) before tax from continuing
operations
7,133
(9,698)
2,799
Adjustments for:
Impairment releases on intercompany loans to bank
(6)
Net impairment (reversals)/charges of invest
ments in Group undertakings
(2,600)
9,606
1,489
Change in fair value taken to profit or loss on o
ther financial liabilities and
subordinated liabilities
(440)
672
221
Elimination of foreign exchange diff
erences
(14)
(540)
(
526)
Other non
-
cash items
(12)
(31)
(23)
Dividends receivable from subsi
diaries
(4,872)
(485)
(5,596)
Loss on sale of investments in Group undertakings
22
1,739
Interest payable on MRELs and subordina
ted liabilities
447
537
513
Loss on sale of MRELs and subordinated liabilities
113
324
Charges and releases on provisions
(3)
(8)
(25)
Net cash flows from trading act
ivities
(232)
377
591
Decrease/(increase) in derivative assets with subsi
diaries
614
(598)
(
436)
(Increase)/decrease in amounts due from subsi
diaries
(1,825)
(792)
863
Increase in other financial assets
(89)
(302)
(36)
Decrease/(increase) in other asse
ts
2
(2)
113
(Decrease)/increase in amounts due to subsidi
aries
(347)
289
(
193)
(Decrease)/increase in derivative liabilities with subsidi
aries
(398)
391
266
Increase/(decrease) in other financial li
abilities
2
(1)
Decrease in other liabilities
(2)
(33)
Change in operating assets and liabilities
(2,045)
(1,045)
576
Income taxes received
97
40
15
Net cash flows from operating activi
ties
(1)
(2,180)
(628)
1,182
Net movement in business interests
(29)
(27)
(
442)
Dividends received from subsidiaries
4,872
485
3,751
Net cash flows from investing activities
4,843
458
3,309
Movement in MRELs
1,531
(147)
(
142)
Movement in subordinated liabilities
(2,256)
(1,972)
(709)
Ordinary shares issued
87
109
17
Share cancellations
(1,808)
Dividends paid
(1,011)
(381)
(3,424)
Issue of paid
-
in equity
933
2,209
Net cash flows from financing
activities
(2,524)
(182)
(4,258)
Effects of exchange rate changes
on cash and cash equivalents
4
1
(1)
Net increase/(decrease) in cash and c
ash equivalents
143
(351)
232
Cash and cash equivalents at 1 January
188
539
307
Cash and cash equivalents at 31 December
(2)
331
188
539
(1)
Includes interest received of £183 million (2020
- £344 million, 2019 - £371 million) and interest paid of £551 million (2020 - £816 million, 2019 - £988 million).
(2)
Cash and cash equivalents comprise intragroup loans and advan
ces with a maturity of less than 3 months for 2021, 2020 and 2019.
Parent company
financial s
tatements and n
otes continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
381
Financial
statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
1. Presentation of financial statements
The financial statements are pre
pared on a going concern basis based on the directo
rs’ assessment that the parent company will
continue in operational existence for a period of
twelve months from the date the financial s
tatements are approved (refer to the
Report of the directors page 184). The accounting policies
applied to the parent company financial st
atements are the same as
those applied in the consolidated financial statemen
ts on pages 300 to 377
.
The parent company is incorpora
ted in the UK and registered in Scotland. The fin
ancial statements are prepared on the hist
orical
cost basis except for derivatives and certain financi
al instruments which are stated at fair value. Re
cognised financial assets and
financial liabilities of fair value
hedges are adjusted for changes in fair value in respect
of the risk that is hedged.
The accounting policies that ar
e applicable to the parent company are included in NatWest
Group plc’s accounting policies which
are set out on pages 307 to 312 of the consolidated fin
ancial statements, except that it has no policy reg
arding consolidation.
2. Critical accounting policies and sources of estimation u
ncertainty
The reported results of the parent company
are sensitive to the accounting policies, assu
mptions and estimates that underlie the
preparation of its financial statements. The judg
ments and assumptions involved in
the parent company’s accounting polici
es that
are considered by the Board to
be the most important to the portrayal of its financial co
ndition are those involved in
assessing the
impairment, if any, in its investments in grou
p undertakings, refe
r to Note 9.
Future accounting developments
International Financial Reporting Standards
A number of IFRSs and amendments to IFRS we
re in issue at 31 December 2021. The parent
company is assessing the effect of
adopting these standards
and amendments on its financial statemen
ts but does not expect the eff
ect to be material.
3 Derivatives with subsidiaries – designated h
edges
Fair value hedging is used to hedge loans and other fi
nancial liabilities, and cash flow hed
ging is used to hedge other financial
liabilities and subordinated liabilities.
For accounting policy information se
e accounting policies notes 10
and 15.
Derivatives held for hedging purposes a
re as follows:
2021
2020
Notional
Assets
Liabilities
Notional
Assets
L
iabilities
£bn
£m
£m
£bn
£m
£m
Fair value hedging - interest rate contracts
22.2
825
167
25.0
1,537
359
Cash flow
hedging
-
exchange
rate contracts
4.9
8
5.8
7
3
Total
833
167
1,544
362
Parent company
financial s
tatements and n
otes continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
382
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
4 Financial instruments – classification
The following tables analyse NWG plc’s financial asse
ts and liabilities in accordance with the
categories of financial instruments on
an IFRS 9 basis.
For accounting policy information se
e accounting policies 10, 12
, 13 and 14.
Amortised
Other
MFVTPL
FVOCI
cost
assets
Total
Assets
£m
£m
£m
£m
£m
Derivatives with subsidiaries
974
974
Amounts due from subsidiaries
16,189
13,773
29,962
Other financial assets
665
3
668
Investment in Group undertakings
48,835
48,835
Other assets
38
38
31 December 2021
17,828
3
13,773
48,873
80,477
Derivatives with subsidiaries
1,580
1,580
Amounts due from subsidiaries
15,506
11,404
26,910
Other financial assets
576
3
579
Investment in Group undertakings
46,229
46,229
Other assets
117
117
31 December 2020
17,662
3
11,404
46,346
75,415
Held
-
for
-
Amortised
Other
trading
DFV
cost
liabilities
Total
Liabilities
£m
£m
£m
£m
£m
Amounts due to subsidiaries
252
113
13
378
Derivatives with subsidiaries
704
704
Other financial liabilities
6,624
16,976
23,600
Subordinated liabilities
7,740
7,740
Other liabilities
150
150
31 December 2021
956
6,624
24,829
163
32,572
Amounts due to subsidiaries
542
111
70
723
Derivatives with subsidiaries
1,102
1,102
Other financial liabilities
3,987
17,069
21,056
Subordinated liabilities
7,944
7,944
Other liabilities
151
151
31 December 2020
1,644
3,987
25,124
221
30,976
Amounts due from/to subsidiaries
2021
2020
£m
£m
Assets
Loans to banks and customers
-
amortised cost
13,773
11,404
Other financial assets
16,189
15,506
Amounts due from subsidiaries
29,962
26,910
Derivatives
(1)
974
1,580
Liabilities
Bank and customer deposits
252
542
Other liabilities
13
70
Subordinated liabilities
113
111
Amounts due to subsidiaries
378
723
Derivatives
(1)
704
1,102
(1)
Intercompany derivatives are included
within derivative classification on the balance sheet.
Parent company
financial s
tatements and n
otes continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
383
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
5 Financial instruments
Interest rate benchmark reform
The total amount of exposure for NatWest Gr
oup plc at 31 December 2021 subject to conver
sion provisions is £1.6 billion derivative
notionals.
Rates subject t
o IBOR reform
GBP LIBOR
USD
IBOR (1)
Other IBOR (2)
Total
2021
£m
£m
£m
£m
Amounts due from subsidiaries
9,338
9,338
Other financial assets
665
665
Amounts due to subsidiaries
Other financial liabilities
1,320
7,055
97
8,472
Subordinated liabilities
604
604
Derivatives notional - with subsidiaries (£bn)
20.4
20.4
Rates subject to IBOR reform
GBP LIBOR
USD IBOR (1)
EURIBOR (2)
Other IBOR
Total
2020
£m
£m
£m
£m
£m
Amounts due from subsidiaries
1,422
15,444
4,557
38
21,461
Other financial assets
577
577
Other financial liabilities
1,376
9,540
4,187
108
15,211
Subordinated liabilities
767
767
Derivatives notional - with subsidiaries (£bn)
4.1
23.7
9.8
0.1
37.7
(1)
In 2021 the FCA declared that USD IBOR will be
non-representative post 30 June 2023; at the time of preparing the 2020 Annual Report and Accounts this date was expected to be
31 December 2021.
(2)
In 2021 management concluded that E
URIBOR is not expected to be significantly reformed further and therefore any uncertainty due to interest benchmark rate reform for
EURIBOR has ended. December 2020 data includes EURIBOR
exposure as subject to reform
AT1 issuances
As part of its capital management activities NatWest
Group has acquired certain equity ins
truments issued by its subsidiaries which
contain reset clauses linked to IBOR rates subject
to reform reported in investment in group u
ndertakings.
These are outlined below:
31 December 2021
31 December 2020
£m
£m
USD$2 billion 8.0169%
1,581
1,581
£300 million 6.597%
300
300
USD$2.65 billion 7.9916%
1,161
2,095
USD$950 million 7.9604%
749
749
USD$200 million 5.540%
155
155
6 Financial instruments - fair value of financial in
struments not carried at fair value
The following table shows the carrying value an
d fair value of financial instruments ca
rried at amortised cost on the balance shee
t.
2021
2020
Carrying
Carrying
value
Fair value
value
Fair value
£bn
£bn
£bn
£bn
Financial assets
Amounts due from subsidiaries
(1)
13.8
13.9
11.4
11.7
Financial liabilities
Amounts due to subsidiaries
(2)
0.1
0.2
0.1
0.1
Other financial liabilities - debt sec
urities in issue
(3)
17.0
17.5
17.1
17.7
Subordinated liabilities
(3)
7.7
8.2
7.9
8.6
(1)
Fair value hierarchy level 2 - £5.9 billion (2020 - £6.4 b
illion) and level 3 - £8.1 billion (2020 - £5.3 billion).
(2)
Fair value hierarchy level 2
(2020 – level 3).
(3)
Fair value hierarchy level 2.
Parent company
financial s
tatements and n
otes continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
384
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
7 Financial instruments - maturity analysis
Remaining maturity
The following table shows the r
esidual maturity of financial instruments based on cont
ractual date of maturity.
2021
2020
Less than
More than
Less than
More th
an
12 months
12 months
Total
12 months
12 months
Tota
l
£m
£m
£m
£m
£m
£m
Assets
Derivatives with subsidiaries
49
925
974
3
1,577
1,580
Amounts due from subsidiaries
8,276
21,686
29,962
5,591
21,319
26,910
Other financial assets
668
668
579
579
Liabilities
Amounts due to subsidiaries
(1)
254
111
365
543
110
653
Derivatives with subsidiaries
1
703
704
38
1,064
1,102
Other financial liabilities
3,709
19,891
23,600
203
20,853
21,056
Subordinated liabilities
1,018
6,722
7,740
36
7,908
7,944
(1)
Amounts due to subsidiaries relating t
o non-financial instruments of £13 million (2020 - £70 million) have been excluded from the table.
Financial liabilities: contractual maturity
The following table shows undiscounted cash flo
ws payable up to 20 years from the b
alance sheet date, including future inte
rest
payments.
Held-for-trading liabilities amounting to £0.8 billion
(2020 - £1.3 billion) have been excluded fro
m the tables.
2021
0-3 months
3-12 months
1-3 years
3-5 years
5-10 years
10-20 years
£m
£m
£m
£m
£m
£m
Liabilities by contractual maturity
Amounts due to subsidiaries
(1)
9
18
18
44
89
Derivatives held for hedging
28
22
73
17
31
Other financial liabilities
1,484
2,662
8,866
5,406
7,060
Subordinated liabilities
20
1,274
3,277
2,199
1,567
544
1,532
3,967
12,234
7,640
8,702
633
2020
Liabilities by contractual maturity
Amounts due to subsidiaries
(1)
7
18
18
44
88
Derivatives held for hedging
47
73
187
46
30
Other financial liabilities
222
420
9,884
5,623
6,522
Subordinated liabilities
22
361
3,728
3,444
907
674
291
861
13,817
9,131
7,503
762
(1)
Amounts due to subsidiaries relating t
o non-financial instruments have been excluded from the tables.
Parent company
financial s
tatements and n
otes
continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
385
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
8 Subordinated liabilities
2021
2020
£m
£m
Dated loan capital
7,689
7,768
Undated loan capital
51
175
Preference shares
1
7,740
7,944
(1)
Excludes amounts due to NatWest Group subsidiaries of £113 million (2020 - £11
1 million).
Redemptions in the period are disc
losed in Note 20 to the consolidated accounts.
For accounting policy information se
e Accounting policies notes 10 and 14.
Certain preference shares issu
ed by the company are classified as liabilities; these s
ecurities remain subject to the capital
maintenance rules of the Companies Act 20
06.
Capital
2021
2020
Dated loan capital
treatment
£m
£m
US$2,250 million 6.13% dated notes 2
022
Tier 2
986
1,234
US$650 million 6.425% dated notes 2
043 (callable January 2034)
(1)
Ineligible
554
593
US$2,000 million 6.00% dated notes 2
023
T
ier 2
1,073
1,574
US$1,000 million 6.10% dated notes 2
023
T
ier 2
354
419
US$2,250 million 5.13% dated notes 2
024
T
ier 2
956
1,778
US$750 million 3.754% dated notes 2
029
Tier 2
558
551
US$850 million 3.032% dated notes 2
035 (callable November 2030
)
Tier 2
584
606
£1,000 million 3.622% dated notes
2030 (callable between May 20
25 to August 2025)
Tier 2
995
1,013
£1000 million 2.105% dated notes
2031 (callable between August 2026 to Novembe
r 2026)
T
ier 2
999
€750 million 1.043% dated notes 2
032 (callable between June 2027
to September 2027)
Tier 2
630
7,689
7,768
(1)
The call is on the underlying security in th
e partnership, rather than the internal issued debt
.
Undated loan capital
Capital
2021
2020
treatment
£m
£m
US$106 million floating rate notes (callable semi-
annually)
Ineligible
78
US$762 million 7.648% notes (callable Septem
ber 2031)
(1)
Ineligible
51
97
51
175
(1)
The company can satisfy interest pa
yment obligations by issuing sufficient ordinary shares to appointed trustees to enable them, on selling these shares, to settle the
interest
payment
.
Capital
2
021
2020
Preference shares
(1)
treatment
£m
£m
£0.5 million 11% and £0.4 million 5.5
% cumulative preference shares of £1 (not callable)
Ineligible
1
(1)
Further details of the cont
ractual terms of the preference shares are given in Note 22 to the consolidated accounts.
The following table analyses intercompany subo
rdinated liabilities:
Capital
202
1
2020
Undated loan capital
treatment
£m
£m
US$150 million 8.00% undated notes 201
2
Tier 2
113
112
Parent company
financial s
tatements and n
otes
continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
386
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
9 Investments in Group undertakings
Critical accounting policy: Investments in Group undertakings
At each reporting date, the company assesse
s whether there is any indication that its investment in its G
roup undertakings is
impaired. If any such indication e
xists, the company undertakes an impairment test by com
paring the carrying value of the
investment in its Group undertakings with its es
timated recoverable amount. The key judg
ment is in determining the recoverable
amount. The recoverable amount of a
n investment in its Group undertakings is
the higher of its fair value less cost to sell and
its
value in use, being an assessment of the discounted futu
re cash flows of the entity. Impairment testing in
herently involves a
number of judgments: the five-y
ear cash flow forecast, the choice of appropriate discoun
t and growth rates, and the estimation of
fair value.
For accounting policy information se
e Accouting policies note 16.
Investments in Group undertakings a
re carried at cost less impairment losses. Move
ments during the year were as follows:
2021
2020
£m
£m
At 1 January
46,229
55,808
Additional investments in Group undertakings
940
27
Disposals of investments in Group undertakings
(934)
Impairment of investments
(1)
2,600
(9,606)
At 31 December
48,835
46,229
(1)
Net of impairment reversals.
The recoverable amount of inves
tments in Group undertakings is the higher of net asset value
as a proxy for fair value less cost to
sell or value in use. Where recoverable value is based
on net asset value, the fair value measu
rement is categorised as Level 3 of
the fair value hierarchy. The carrying value of
Investments in Group undertakings at 31 Dece
mber 2021 is supported by the
respective recoverable values of the entities.
In August 2021 the company issued £9
41 million of contingent convertible AT1 notes to NWH L
td and redeemed £934 million of
contingent convertible AT1 notes
issued to NWH Ltd. In 2020 the company invested additio
nal capital of £27 million in its
subsidiaries, NWM Plc and RBS AA Holdings.
In 2021, Impairment of investme
nts includes a £5,250 million reversal of an e
arlier impairment of the company's investment i
n
NatWest Holdings Limited as improved five
-year cash flow forecasts increased the value in us
e and a £2,650 million impairment of
the company's investment in NatWest Markets Plc due
to a decline in its net asset value
mainly driven by dividends paid during the
year and losses incurred by the business. T
he impairment in 2020 was mainly related to Nat
West Holdings Limited.
The impact of reasonably possible changes to the mo
re significant variables in the value in us
e calcula
tions for Natwest Holdings
Limited are presented below. This reflects the sensitivi
ty of the value in use to each variable o
n its own. It is possible that more
than one change may occur at the same time. The v
alue in use calculations use 10% as a discount rate and 1.6
% as a long term
growth rate.
The value in use model shows the f
ollowing sensitivities:
Potential VIU movement
2021
2020
£bn
£bn
1% adverse movement in discount rate
(4.4)
(4.0)
1% adverse movement in terminal growth
rate
(2.0)
(1.5)
£250 million adverse movement in ope
rating profit before tax
(2.1)
(2.2)
The principal subsidiary undertakings of the com
pany are shown below. Their capital consist
s of ordinary shares, preference
shares and additional Tier 1 notes which a
re unlisted with the exception of certain p
reference shares listed by NWB Plc. All of these
subsidiaries are included in NatWes
t Group’s consolidated financial statements and have an a
ccounting reference date of 31
December.
Nature of business
Country of incorporation and
principal area of operation
Group interest
National Westminster
Bank Plc
(1,3)
Banking
Great Britai
n
100%
The Royal Bank of S
cotland plc
(3)
Banking
Great Britai
n
100%
Coutts & Company
(2, 3)
Banking
Great Britai
n
100%
Ulster Bank Irela
nd Designated Act
ivity Company
(3)
Banking
Republic of Ireland
100%
NatWest Markets Pl
c
Banking
Great Britai
n
100%
NatWest Markets N.V
.
(4)
Banking
Netherlands
100%
The Royal Bank of S
cotland Internati
onal Limited
(5)
Financial
Institution
Jersey
100%
(1)
The company does not hold any of the p
reference shares in issue.
(2)
Coutts & Company is incorporat
ed with unlimited liability.
(3)
Owned via NatWest Holdings Limited.
(4)
Owned via NatWest Markets Plc.
(5)
Owned via The Royal Bank of Scotland Int
ernational (Holdings) Limited.
For full information on all related undertakings, refe
r to Note 12.
Parent company
financial s
tatements and n
otes
continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
387
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
10 Analysis of changes in finan
cing during the year
Share capita
l, share premium,
and paid-in
equity
S
ubordinated liabilities
MRELs
2021
2020
2019
2021
2020
2019
2021
2020
2019
£m
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January
18,219
17,235
17,123
8,055
7,763
8,059
6,655
6,440
6,785
Ordinary shares issued
87
52
17
Issue of paid-in equity
933
2,209
Issue of subordinated liabilities
1,634
1,631
577
Redemption of subordinated liabilities
(3,598)
(3,207)
(855)
Interest on subordinated liabilities
(292)
(396)
(431)
Issue of MRELs
598
(3)
1,178
Maturity/redemption of MRELs
1,082
(2)
(1,285)
Interest on MRELs
(149)
(142)
(
35)
Net cash inflow/(outflow) from financin
g
1,020
2,261
17
(2,256)
(1,972)
(709)
1,531
(147)
(142)
Issue of ordinary shares
95
Effects of foreign exchange
44
(264)
(264)
(54)
(275)
(261)
Changes in fair value of subordinated
liabilities and MRELs
(309)
173
268
(131)
499
(
46)
Paid in equity reclassified to subordina
ted liabilities
(2,037)
(1,277)
1,915
1,632
Loss on sale of subordinated liabilities and MRELs
114
324
Interest on subordinated liabilities
and MRELs
290
399
409
157
138
104
Other
(698)
At 31 December
16,504
18,219
17,235
7,853
8,055
7,763
8,158
6,655
6,440
11 Directors’ and key managemen
t remuneration
Directors’ remuneration is disclosed in Note 31 to
the consolidated accounts. The directors had no othe
r reportable related party
transactions or balances with the company.
Parent company
financial s
tatements and n
otes
continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
388
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
12 Related undertakings
Legal entities and activities at 31 December 2021
In accordance with the Companies
Act 2006, the company’s related undertakings and the ac
counting treatment for each are
listed
below. All undertakings are wholly-owned by the com
pany or subsidiaries of the company an
d are consolidated by reason of
contractual control (Section 1162(2) CA
2006), unless otherwise indicated. NatWest Group interest refers to or
dinary shares of
equal values and voting rights unless
further analysis is provided in the notes. Activities are classif
ied in accordance with Annex I to
the Capital Requirements Directive (CR
D IV) and the definitions in Article 4 of the Capital Req
uirements Regulation.
The following table details active related undertakings incorporated in the UK which are
100% owned by NatWest Group
and fully consolidated for accounting purposes
Regulatory
Entity name
Activity
trea
tment
Notes
280 Bishopsgate
Finance Ltd
INV
FC
(1)
Caledonian Slee
pers Rail Lea
sing Ltd
BF
FC
(
1)
Care Homes 1 Lt
d
BF
FC
(
1)
Care Homes 2 Lt
d
BF
FC
(
1)
Care Homes 3 Lt
d
BF
FC
(
1)
Care Homes Hol
dings Ltd
BF
FC
(
1)
Churchill Manag
ement Ltd
BF
FC
(
1)
Coutts & Comp
any
CI
FC
(
17)
Coutts Finance Co
mpany
BF
FC
(17)
Desertlands En
tertainment Ltd
BF
FC
(
1)
Distant Planet P
roductions Lt
d
BF
FC
(
1)
Esme Loans L
td
BF
FC
(
1)
FreeAgent Cen
tral Ltd
SC
FC
(33)
FreeAgent Hold
ings Ltd
SC
FC
(33)
G L Trains Ltd
BF
FC
(21)
Gatehouse
Way Developments
Ltd
INV
DE
(1)
ITB2 Ltd
BF
FC
(
3)
KUC Properties
Ltd
BF
DE
(3)
Land Options (
West) Ltd
INV
DE
(3)
Lombard & Ul
ster Ltd
BF
FC
(16)
Lombard Busin
ess Finance Ltd
BF
FC
(
1)
Lombard Busin
ess Leasing Lt
d
BF
FC
(
1)
Lombard Corpor
ate Finance (6)
Ltd
BF
FC
(
1)
Lombard Corpor
ate Finance (7)
Ltd
BF
FC
(
1)
Lombard Corpor
ate Finance (11)
Ltd
BF
FC
(
1)
Lombard Corpor
ate Finance (15)
Ltd
BF
FC
(
1)
Lombard Corpor
ate Finance (D
ecember 1) L
td
BF
FC
(
1)
Lombard Corpor
ate Finance (D
ecember 3) L
td
BF
FC
(
1)
Lombard Corpor
ate Finance (Ju
ne 2) Ltd
BF
FC
(
1)
Lombard Discoun
t Ltd
BF
FC
(
1)
Lombard Fina
nce Ltd
BF
FC
(
1)
Lombard Indus
trial Leasing Lt
d
BF
FC
(
1)
Lombard Lease
Finance Ltd
BF
FC
(
1)
Lombard Leasi
ng Company Lt
d
BF
FC
(
1)
Lombard Leasi
ng Contracts L
td
BF
FC
(
1)
Lombard Lessor
s Ltd
BF
FC
(
1)
Lombard Mariti
me Ltd
BF
FC
(
1)
Lombard North
Central Leasin
g Ltd
BF
FC
(
1)
Lombard North
Central PLC
BF
FC
(
1)
Lombard Prop
erty Facilities Lt
d
BF
FC
(
1)
Lombard Tec
hnology Servic
es Ltd
BF
FC
(
1)
Mettle Venture
s Ltd
OTH
FC
(1)
Nanny McPhee
Productions Ltd
BF
FC
(
1)
National West
minster Bank Plc
CI
FC
(1)
National West
minster Home Loa
ns Ltd
BF
FC
(
1)
NatWest Corpo
rate Investmen
ts
BF
FC
(
1)
NatWest Holdi
ngs Ltd
INV
FC
(1)
NatWest Invoi
ce Finance Ltd
OTH
FC
(1)
NatWest Mark
ets Plc
CI
FC
(
28)
NatWest Mark
ets Secretarial Se
rvices Ltd
SC
FC
(
1)
NatWest Mark
ets Secured Fun
ding LLP
BF
FC
(20)
NatWest Prope
rty Investment
s Ltd
INV
DE
(1)
Entity name
Activity
Regulatory
Notes
treatment
NatWest Truste
e and Depositary
Services Ltd
INV
FC
(
1)
NatWest Ventur
es Investment
s Ltd
BF
FC
(
1)
P of A Produc
tions Ltd
BF
FC
(
1)
Patalex Product
ions Ltd
BF
FC
(
1)
Patalex V Produ
ctions Ltd
BF
FC
(
1)
Pittville Leasing L
td
BF
FC
(
1)
Premier Audit Co
mpany Ltd
BF
FC
(
1)
Price Productio
ns Ltd
BF
FC
(
1)
Priority Sites Inv
estments Ltd
BF
DE
(1)
Priority Sites L
td
INV
DE
(1)
Property Ventur
e Partners Ltd
INV
FC
(
3)
R.B. Capital L
easing Ltd
BF
FC
(
1)
R.B. Equipment L
easing Ltd
BF
FC
(
1)
R.B. Leasing (Ap
ril) Ltd
BF
FC
(
1)
R.B. Leasing (Se
ptember) Ltd
BF
FC
(
1)
R.B. Leasing Co
mpany Ltd
BF
FC
(
3)
R.B. Quadran
gle Leasing Ltd
BF
FC
(
1)
R.B.S. Special
Investments Ltd
BF
FC
(
1)
RB Investment
s 3 Ltd
OTH
FC
(1)
RBOS (UK) Ltd
BF
FC
(
1)
RBS AA Holdings
(UK) Ltd
BF
FC
(
1)
RBS Asset Mana
gement Hol
dings
BF
FC
(17)
RBS Collective
Investment Fund
s Ltd
BF
FC
(11)
RBS HG (UK)
Ltd
BF
FC
(
1)
RBS Invoice
Finance Ltd
BF
FC
(
1)
RBS Manage
ment Services (UK)
Ltd
SC
FC
(1)
RBS Mezzanin
e Ltd
BF
FC
(
3)
RBS Property De
velopments L
td
INV
FC
(
3)
RBS Property V
entures Investm
ents Ltd
BF
FC
(
3)
RBS SME Inves
tments Ltd
BF
FC
(
1)
RBSG Collective
Investment
s Holdings Ltd
BF
FC
(11)
RBSG Internatio
nal Holdings Lt
d
BF
FC
(
3)
RBSM Capital Lt
d
BF
FC
(
3)
RBSSAF (2) Lt
d
BF
FC
(
1)
RBSSAF (8) Lt
d
BF
FC
(
1)
RBSSAF (12) L
td
BF
FC
(
1)
RBSSAF (25) L
td
BF
FC
(
1)
RoboScot Equity
Ltd
BF
FC
(
3)
Royal Bank Inv
estments Ltd
BF
FC
(
3)
Royal Bank Lea
sing Ltd
BF
FC
(
3)
Royal Bank of S
cotland (Indus
trial Leasing) Lt
d
BF
FC
(
3)
Royal Bank Ve
ntures Investme
nts Ltd
BF
FC
(
3)
Royal Scot Lea
sing Ltd
BF
FC
(
3)
RoyScot Trust P
lc
BF
FC
(
1)
SIG 1 Holdings L
td
BF
FC
(
3)
SIG Number 2
Ltd
BF
FC
(
3)
The One Accoun
t Ltd
BF
FC
(
1)
The Royal Ban
k of Scotland Grou
p
Independent Fi
nancial Servic
es Ltd
BF
FC
(
3)
The Royal Ban
k of Scotland pl
c
CI
FC
(28)
Ulster Bank Ltd
CI
FC
(16)
Parent company
financial s
tatements and n
otes
continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
389
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
12 Related undertakings continued
Regulatory
Entity name
Activity
trea
tment
Notes
Ulster Bank Pen
sion Trustees Lt
d
TR
DE
(16)
Voyager Leasin
g Ltd
BF
FC
(
1)
Walton Lake D
evelopments Lt
d
INV
DE
(1)
West Register (Ho
tels Number 3)
Ltd
INV
DE
(3)
Regulatory
Entity name
Activity
treatment
Notes
West Register (Pro
perty Invest
ments) Ltd
BF
DE
(3)
West Register (Re
alisations) L
td
INV
DE
(3)
Winchcombe Fi
nance Ltd
BF
FC
(1)
World Learning Li
mited
BF
FC
(29)
The following table details active related undertakings incorporated outside the
UK which are 100% owned by NatWest
Group and fully consolidated for accounting purposes
Regulatory
Entity name
Activity
treatment
Notes
AA Merchant S
ervices B.V.
BF
FC
(13)
Airside Propertie
s AB
BF
FC
(
2)
Airside Propertie
s ASP Denma
rk AS
BF
FC
(12)
Airside Propertie
s Denmark AS
BF
FC
(12)
Alcover A.G.
BF
DE
(72)
Alternative Inv
estment Fund B.
V.
BF
FC
(13)
Arkivborgen KB
BF
FC
(
2)
Artul Koy
BF
FC
(
4)
Backsmedjan KB
BF
FC
(
2)
BD Lagerhus
AS
BF
FC
(
5)
Bilfastighet i A
kalla AB
BF
FC
(
2)
Bioenergie Wie
senburg GmbH &
Co. KG
INV
DE
(62)
Brödmagasinet KB
BF
FC
(
2)
C.J. Fiduciarie
s Ltd
BF
FC
(15)
Candlelight Acqu
isition LLC
BF
FC
(
6)
Coutts & Co (
Cayman) Ltd
BF
FC
(19)
Coutts & Co Lt
d
CI
FC
(
70)
Coutts General Pa
rtner (Cayma
n) V Ltd
BF
FC
(64)
Eiendomssels
kapet Apteno La
AS
BF
FC
(
5)
Espeland Naer
ing AS
BF
FC
(
5)
Eurohill 4 KB
BF
FC
(
2)
Fab Ekenäs Fo
rmanshagen 4
BF
FC
(
4)
Fastighets AB Flöj
ten I Norrkö
ping
BF
FC
(10)
Fastighets AB Sto
ckmakaren
BF
FC
(18)
Fastighets Aktie
bolaget Sambi
blioteket
BF
FC
(
2)
Fastighetsbola
get Holma I Höör
AB
BF
FC
(10)
Financial Asset S
ecurities Corp.
BF
FC
(
6)
First Active Ltd
BF
FC
(
7)
Forskningshöjde
n KB
BF
FC
(
2)
Förvaltningsbo
laget Dalkyrkan K
B
BF
FC
(10)
Förvaltningsbo
laget Klöverba
cken Skola KB
BF
FC
(10)
Fyrsate Fastigh
ets AB
BF
FC
(10)
Gredelinen KB
BF
FC
(
2)
Grinnhagen K
B
BF
FC
(
2)
Hatros 1 AS
BF
FC
(
5)
Horrsta 4:38 KB
BF
FC
(
2)
IR Fastighets A
B
BF
FC
(
2)
IR IndustriRentin
g AB
BF
FC
(
2)
Kallebäck Institu
tfastigheter AB
BF
FC
(10)
Kastrup Commut
er K/S
BF
FC
(12)
Kastrup Hanga
r 5 K/S
BF
FC
(12)
Kastrup V & L Buil
ding K/S
BF
FC
(12)
KB Eurohill
BF
FC
(
2)
KB Lagermann
en
BF
FC
(
2)
KB Likriktare
n
BF
FC
(
2)
KEB Investor
s, L.P.
BF
FC
(54)
Koy Espoon Ent
resse II
BF
FC
(
4)
Koy Helsingin M
echelininkatu 1
BF
FC
(
4)
Koy Helsingin
Osmontie 34
BF
FC
(
4)
Koy Helsingin P
anuntie 6
BF
FC
(
4)
Koy Helsingin P
anuntie 11
BF
FC
(
4)
Koy Iisalmen Kihl
avirta
BF
FC
(
4)
Regulatory
Entity name
Activity
treatment
Notes
Koy Jämsän Ke
skushovi
BF
FC
(4)
Koy Jasperintie 6
BF
FC
(24)
Koy Ko
kkolan Kaarlenportti F
ab
BF
FC
(4)
Koy Ko
uvolan Oikeus ja Poliisit
alo
BF
FC
(4)
Koy Lohjan Oja
monharjuntie 6
1
BF
FC
(4)
Koy Millennium
BF
FC
(4)
Koy Nummelan Po
rtti
BF
FC
(4)
Koy Nuo
lialan päiväkoti
BF
FC
(4)
Koy Pennalan Joh
totie 2
BF
FC
(4)
Koy Peltolantie
27
BF
FC
(24)
Koy Porkkanak
atu 2
BF
FC
(24)
Koy Puo
tikuja 2 Vaasa
BF
FC
(4)
Koy Raision Kih
lakulma
BF
FC
(4)
Koy Ravattulan K
auppakeskus
BF
FC
(4)
Koy Tapiolan Louh
i
BF
FC
(4)
Koy Vantaan Ras
ti IV
BF
FC
(4)
Koy Vapaalan Se
rvice-Cente
r
BF
FC
(4)
Kvam Eiendom
AS
BF
FC
(5)
Läkten 1 KB
BF
FC
(2)
Leiv Sand Eiendo
m AS
BF
FC
(5)
LerumsKrysset K
B
BF
FC
(2)
Limstagården KB
BF
FC
(2)
Lombard Fina
nce (CI) Ltd
BF
FC
(15)
Lothbury Insur
ance Company L
td
BF
DE
(67)
Lundbyfilen 5 A
B
BF
FC
(18)
Maja Finance S
.R.L.
BF
FC
(50)
Narmovegen 455
AS
BF
FC
(5)
National West
minster Interna
tional Holdings B.V
.
BF
FC
(77)
NatWest Ger
many GmbH
OTH
FC
(34)
NatWest Innovatio
n Services I
nc.
OTH
FC
(6)
NatWest Mark
ets Group Holdin
gs Corporat
ion
BF
FC
(6)
NatWest Mark
ets N.V.
CI
FC
(23)
NatWest Mark
ets Securities In
c.
INV
FC
(6)
NatWest Mark
ets Securities
Japan Ltd
INV
FC
(14)
NatWest Service
s (Switzerlan
d) Ltd
SC
FC
(61)
Nordisk Renting
AB
BF
FC
(2)
Nordisk Renting
AS
BF
FC
(58)
Nordisk Renting
OY
BF
FC
(4)
Nordisk Renting
Facilities Mana
gement AB
BF
FC
(18)
Nordisk Special
invest AB
BF
FC
(2)
Nordiska Strate
gifastigheter Hol
ding AB
BF
FC
(2)
NWM Services I
ndia Private Ltd
SC
FC
(39)
Nybergflata 5 AS
BF
FC
(5)
Optimus KB
BF
FC
(2)
R.B. Leasing B
DA One Ltd
BF
FC
(74)
Random Proper
ties Acquisition Co
rp. III
INV
FC
(6)
RBS (Gibraltar) L
td
BF
FC
(63)
RBS AA Holdings
(Netherland
s) B.V.
BF
FC
(13)
RBS Acceptance
Inc.
BF
FC
(6)
RBS Americas P
roperty Corp.
SC
FC
(6)
RBS Asia Finan
cial Services Lt
d
BF
FC
(14)
RBS Asia Futures
Ltd
BF
FC
(14)
Parent company
financial s
tatements and n
otes
continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
390
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
12 Related undertakings continued
Regulatory
Entity name
Activity
treatment
Notes
RBS Assessoria
Ltd
SC
FC
(43)
RBS Asset Mana
gement (Dubli
n) Ltd
BF
FC
(66)
RBS Commerci
al Funding Inc.
BF
FC
(
6)
RBS Deutschla
nd Holdings Gmb
H
BF
FC
(34)
RBS Employme
nt (Guernsey)
Ltd
SC
FC
(69)
RBS Financial P
roducts Inc.
BF
FC
(
6)
RBS Group (Aus
tralia) Pty Ltd
BF
FC
(30)
RBS Holdings I
II (Australia) Pty
Ltd
BF
FC
(30)
RBS Holdings N.
V.
BF
FC
(23)
RBS Holdings USA
Inc.
BF
FC
(
6)
RBS Hollandsch
e N.V.
BF
FC
(23)
RBS Internatio
nal Depositary S
ervices S.A.
CI
FC
(
46)
RBS Investment
s (Ireland) Ltd
BF
FC
(
7)
RBS Netherlan
ds Holdings B.
V.
BF
FC
(13)
RBS Nominees (
Hong Kong) L
td
BF
FC
(14)
RBS Nominees (
Ireland) Ltd
BF
FC
(
7)
RBS Nominees (N
etherlands)
B.V.
BF
FC
(13)
RBS Polish Finan
cial Advisory
Services
Sp. Z o.o.
BF
FC
(59)
RBS Prime Servi
ces (India) Priva
te Ltd
OTH
FC
(
37)
RBS Services I
ndia Private Ltd
SC
FC
(48)
Rigedalen 44 Ei
endom AS
BF
FC
(
5)
Ringdalveien 20 A
S
BF
FC
(
5)
Sandmoen Naer
ingsbygg AS
BF
FC
(
5)
Regulatory
Entity name
Activity
treatment
Notes
SFK Kommunfa
stigheter AB
BF
FC
(
2)
Sjöklockan KB
BF
FC
(
2)
Skinnarängen K
B
BF
FC
(
2)
Sletta Eiendom
II AS
BF
FC
(
5)
Snipetjernveie
n 1 AS
BF
FC
(
5)
Solbänken KB
BF
FC
(
2)
Solnorvika AS
BF
FC
(
5)
Strand European
Holdings AB
BF
FC
(18)
Svenskt Fastig
hetskapital AB
BF
FC
(
2)
Svenskt Energik
apital AB
BF
FC
(
2)
Svenskt Fastig
hetskapital Holdi
ng AB
BF
FC
(
2)
The RBS Group
Ireland Retire
ment Savings
Trustee Ltd
TR
FC
(7)
The Royal Ban
k of Scotland I
nternational
(Holdings) Ltd
BF
FC
(15)
The Royal Ban
k of Scotland I
nternational Ltd
CI
FC
(15)
Tygverkstaden
1 KB
BF
FC
(
2)
Ulster Bank (Irel
and) Holdings
Unlimited Com
pany
INV
FC
(
7)
Ulster Bank Dubli
n Trust Compa
ny
Unlimited Co
mpany
TR
FC
(7)
Ulster Bank Holdi
ngs (ROI) Lt
d
BF
FC
(
7)
Ulster Bank Ir
eland Designate
d Activity C
ompany
CI
FC
(7)
Ulster Bank Pen
sion Trustees (R
I) Ltd
TR
FC
(7)
The following table details related undertakings which are 1
00% owned by NatWest Group ownership but are not
consolidated for accounting purposes
Regulatory
Entity name
Activity
treatment
Notes
RBS Capital LP
II
BF
DE
(76)
RBS Capital Trus
t II
BF
DE
(
44)
RBS Internatio
nal Employee
s' Pension
BF
DE
(15)
Trustees Ltd
Regulatory
Entity name
Activity
treatment
Notes
RBSG Capital Cor
p.
BF
DE
(6)
West Granite
Homes Inc.
INV
DE
(41)
The following table details active related undertakings incorporated in the UK where
NatWest Group ownership is less than
100%
Activity
Accounting
Regulatory
Group
Notes
Entity name
treatment
treatment
%
BGF Group Plc
BF
AHC
P
C
25
(21)
Falcon Wharf Lt
d
OTH
EAJV
PC
50
(32)
GWNW City Dev
elopments Ltd
BF
EAJV
DE
50
(32)
Higher Broug
hton (GP) Ltd
BF
AHC
PC
41
(60)
Higher Broug
hton Partnershi
p LP
BF
AHC
DE
41
(55)
Jaguar Cars Fi
nance Ltd
BF
FC
FC
50
(1)
JCB Finance (L
easing) Ltd
BF
FC
FC
75
(26)
JCB Finance Ltd
BF
FC
FC
75
(26)
Landpower Le
asing Ltd
BF
FC
FC
75
(26)
London Rail Lea
sing Ltd
BF
EAJV
PC
50
(49)
Accounting
Regulatory
Group
Entity name
Act
ivity
treatment
trea
tment
%
Notes
Natwest Covere
d Bonds (LM) Lt
d
BF
IA
PC
20
(20)
Natwest Covere
d Bonds LLP
BF
FC
FC
73
(21)
Natwest Mark
ets Secured
Funding (LM) Lt
d
BF
FC
PC
20
(20)
Oaxaca Ltd
OTH
IA
IA
24
(80)
Pollinate Interna
tional Ltd
OTH
AHC
DE
30
(79)
RBS Sempra Co
mmodities LLP
BF
FC
FC
51
(3)
Silvermere Hol
dings Ltd
BF
FC
FC
95
(11)
Vizolution Ltd
OTH
AHC
PC
5
(65)
Parent company
financial s
tatements and n
otes
continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
391
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
12 Related undertakings continued
T
he following table details related undertakings incorporated outside the UK where NatWest Group ownership is less than
100%.
Accounting
Regulatory
Group
Entity name
Activity
treatment
treatment
%
Notes
Ardmore Securi
ties No.1
DAC
BF
FC
DE
0
(22)
Ardmore Securi
ties No.2 DAC
BF
FC
DE
0
(22)
CITIC Capital C
hina
BF
IA
PC
33
(51)
Mezzanine Ltd
Dunmore Se
curities No.1 DAC
BF
FC
DE
0
(22)
Eris Finance S.
R.L.
BF
IA
PC
45
(50)
German Public S
ector Finance
B.V.
BF
EAJV
PC
50
(56)
Herge Holding
B.V.
BF
IA
PC
63
(73)
Lunar Funding V
III Ltd
BF
FC
FC
0
(8)
Lunar Luxembour
g SA
BF
FC
DE
0
(78)
Lunar Luxembour
g Series
BF
FC
DE
0
(78)
2019- 04
Lunar Luxembour
g Series
BF
FC
DE
0
(78)
2019- 05
Lunar Luxembour
g Series
BF
FC
DE
0
(78)
2019- 06
Lunar Luxembour
g Series
BF
FC
DE
0
(78)
2020- 01
Accounting
Regulatory
Group
Entity name
Activity
treatment
treatment
%
Notes
Lunar Luxembour
g Series
BF
FC
DE
0
(78)
2020- 02
Natwest Secur
ed Funding DAC
BF
FC
FC
0
(47)
Nightingale CRE 2
018-1 Ltd
BF
FC
DE
0
(9)
Nightingale L
F 2021-1 Ltd
BF
FC
DE
0
(9)
Nightingale Proj
ect Finance
BF
FC
DE
0
(9)
2019 1 Ltd
Nightingale S
ecurities 2017-1 Lt
d
BF
FC
DE
0
(9)
Nightingale UK Co
rp
BF
FC
DE
0
(9)
2020 2 Ltd
Pharos Estates
Ltd
OTH
AHC
DE
49.49
(42)
Sempra Energy
Trading LLC
BF
FC
FC
51
(6)
Spring Allies Je
rsey Ltd
BF
IA
DE
49
(9)
Thames Asse
t Global
BF
FC
FC
0
(36)
Securitization No
.1 Inc.
The Drive4Gro
wth Company Lt
d
OTH
IA
DE
20
(52)
Wiöniowy Ma
nagement sp. Z.o.
o.
SC
AHC
DE
25
(59)
The following table details related undertakings that are not active (active
ly being dissolved).
Accounting
Regulatory
Group
Entity name
treatment
treatment
%
Notes
Belfast Bankers' C
learing
Company Ltd
AHC
DE
25
(53)
Celtic Reside
ntial Irish Mortga
ge
Securitisation No 1
0 Plc
F
C
DE
0
(25)
Celtic Reside
ntial Irish Mortga
ge
Securitisation No 1
1 Plc
F
C
DE
0
(25)
Celtic Reside
ntial Irish Mortga
ge
Securitisation No 1
4 DAC
FC
DE
0
(31)
Celtic Reside
ntial Irish Mortga
ge
Securitisation No 1
5 DAC
FC
DE
0
(31)
Lombard Corpor
ate Finance (13)
Ltd
FC
FC
100
(
1)
Lombard Ireland
Group
Holdings Unlimit
ed
FC
FC
100
(81)
Lombard Ireland
Ltd
FC
FC
100
(81)
Lombard Manx L
easing Ltd
FC
FC
100
(27)
Accounting
Regulatory
Group
Entity name
treatment
treatment
%
Notes
Lombard Manx L
td
FC
FC
100
(27)
Morar ICC Insu
rance Ltd
FC
DE
100
(68)
NatWest Nomin
ees Ltd
FC
FC
100
(1)
NatWest Capital
Finance Ltd
F
C
FC
100
(1)
Northern Isles F
erries Ltd
FC
FC
100
(1)
RBSSAF (6) Lt
d
F
C
FC
100
(1)
RBS Asset Finan
ce Europe Lt
d
FC
FC
100
(1)
Redlion Investme
nts Ltd
FC
FC
100
(19)
Redshield Holdin
gs Ltd
FC
FC
100
(19)
Royhaven Secr
etaries Ltd
FC
FC
100
(19)
RoyScot Fina
ncial Services Ltd
FC
FC
100
(1)
Style Financial S
ervices Ltd
FC
FC
100
(3)
UB SIG (ROI) L
td
FC
FC
100
(25)
West Register
Hotels (Holding
s) Ltd
FC
FC
100
(3)
Parent company
financial s
tatements and n
otes
continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
392
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
12 Related undertakings continued
The following table details related undertakings that are dormant
Accounting
Regulatory
Group
Entity name
treatment
treatment
%
Notes
Adam & Comp
any (Nominees) L
td
FC
FC
100
(11)
Atlas Nominees
Ltd
FC
FC
100
(14)
British Overseas
Bank Nominee
s Ltd
FC
FC
100
(1)
Buchanan Hol
dings Ltd
FC
FC
100
(1)
Custom House Do
cks Basem
ent
Management No.
2 Ltd
IA
DE
25
(57)
Dixon Vehicle S
ales Ltd
FC
FC
100
(1)
Dunfly Trustee L
td
FC
FC
100
(1)
FIT Nominee 2
Ltd
FC
FC
100
(1)
FIT Nominee L
td
FC
FC
100
(1)
Freehold Mana
gers (Nominee
s) Ltd
FC
FC
100
(1)
HPUT A Ltd
NC
DE
100
(1)
HPUT B Ltd
NC
DE
100
(1)
ITB1 Ltd
FC
FC
100
(3)
JCB Finance Pe
nsion Ltd
FC
DE
88
(16)
Marigold Nomin
ees Ltd
FC
FC
100
(1)
Mulcaster Stre
et Nominees L
td
FC
FC
100
(15)
N.C. Head Offic
e Nominees Lt
d
FC
FC
100
(3)
National West
minster Bank No
minees
(Jersey) Ltd
FC
FC
100
(38)
NatWest FIS No
minees Ltd
FC
FC
100
(1)
NatWest Group S
ecretarial
FC
FC
100
(3)
Services Ltd
Accounting
Regulatory
Group
Entity name
treatment
treatment
%
Notes
NatWest Pensio
n Trustee Ltd
NC
DE
100
(1)
NatWest PEP No
minees Ltd
FC
FC
100
(
1)
Nextlinks Ltd
FC
FC
100
(
1)
Nordisk Renting
A/S
FC
FC
100
(75)
Nordisk Renting
HB
FC
FC
100
(
2)
Project & Expo
rt Finance (No
minees) Ltd
FC
FC
100
(
1)
R.B. Leasing (M
arch) Ltd
FC
FC
100
(
1)
RBOS Nominee
s Ltd
FC
FC
100
(
1)
RBS Investment Ex
ecutive Ltd
NC
DE
100
(3)
RBS Retiremen
t Savings Trust
ee Ltd
FC
FC
100
(
1)
RBSG Collective
Investment
s
Nominees Ltd
FC
FC
100
(11)
RoosterMoney UK
Limited
FC
FC
100
29
Sixty Seven No
minees Ltd
FC
FC
100
(
1)
Strand Nomi
nees Ltd
FC
FC
100
(17)
Syndicate Nomi
nees Ltd
FC
FC
100
(
1)
TDS Nomine
e Company Ltd
FC
FC
100
(
3)
Tilba Ltd
BF
FC
100
(40)
The Royal Ban
k of Scotland (
1727) Ltd
FC
FC
100
(
3)
The Royal Ban
k of Scotland Grou
p Ltd
FC
FC
100
(
1)
W G T C Nomin
ees Ltd
FC
FC
100
(
1)
The following table details overseas branches of NatWest Group
Subsidiary
Geographic location
Coutts & Co Lt
d
Switzerland
National West
minster Bank Plc
Germany
Germany, Hong
Kong, Japan,
Singapore
NatWest Mark
ets Plc
T
urkey, United A
rab Emirates
Subsidiary
Geographic location
France, Germ
any, Italy
Republic of
Ireland, Spain,
Sweden
NatWest Mark
ets N.V.
United Kingdom
The Royal Ban
k of
Gibraltar,
Guernsey, Isle o
f
Man
Scotland Intern
ational Ltd
Luxembourg,
United Kingdom
Parent company
financial s
tatements and n
otes
continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
393
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
12 Related undertakings continued
Key:
BF
Banking an
d financial ins
titution
CI
Credit institution
INV
Investment (shar
es or prope
rty) holding compa
ny
SC
Service
company
TR
Trustee
OTH
Other
DE
Deconsolidated
FC
Full consoli
dation
PC
Pro-
rata consolidatio
n
AHC
Associa
te held at cost
EAJV
E
quity accounting –
Joint venture
IA
Investment a
ccounting
NC
Not consolid
ated
Notes
Registered addresses
Country of incorporation
(1)
250 Bishopsgate, Lo
ndon, EC2M
4AA
UK
(2)
Care of Nordisk
Renting AB, J
akobsbergsga
tan 13, 8th Floo
r, Box 14044, S
tockholm, SE
-111 44
Sweden
(3)
RBS Gogarburn, 1
75 Glasgow Roa
d, Edinburgh, E
H12 1HQ
UK
(4)
c/o Epicenter, M
ikonkatu 9, 6th
Floor, Helsinki, 0
0100
Finland
(5)
c/o Advokatfirma
et Wiershol
m AS, Postboks
1400, 0115 Oslo
Norway
(6)
251, Little Falls
Drive, Wilmington,
DE, 19808
USA
(7)
Ulster Bank He
ad Office, Bloc
k B Central P
ark, Leopardsto
wn, Dublin 18, D
18 N153
RoI
(8)
Grand Pavilion Co
mmercial C
entre, 802 West B
ay Road, P.O. Box
31119
Cayman Island
s
(9)
44 Esplanade, St
Helier, JE4 9W
G
Jersey
(10)
c/o Nordisk R
enting AB, Jako
bsbergsgatan 13, 8
storey, Box
14044, SE-111
44, Stockhol
m
Sweden
(11)
6-8 George St
reet, Edinbu
rgh, EH2 2P
F
UK
(12)
C/O Visma S
ervices Danma
rk A/S, Ly
skaer 3C-3D, 2730
Herlev
Denmark
(13)
Claude Debu
ssylaan 94, A
msterdam, 1082 M
D
Netherlands
(14)
Level 54, Hope
well Centre, 1
83 Queen
's Road East
Hong Kong
(15)
Royal Bank
House, 71 Bat
h Street, St Helier,
JE4 8PJ
Je
rsey
(16)
11-16 Don
egall Square Ea
st, Belfast, Co
Antrim, BT1 5U
B
UK
(17)
440, Strand, Lo
ndon, WC2R OQ
S
UK
(18)
C/O Nordisk R
enting AB, Box 1
4044, SE-104 4
0 Stockholm
Sweden
(19)
Estera Trust (Cay
man) Limi
ted,Clifton Hou
se, 75 Fort Stre
et, PO Box 13
50, Grand C
ayman, KY1-
1108
Cayman Island
s
(20)
1 Bartholome
w Lane London EC
2N 2AX
UK
(21)
1 Princes Str
eet, London, E
C2R 8BP
UK
(22)
3rd Floor, Flem
ing Court,
Fleming's Pl
ace, Dublin 4, D04 N4X
9
RoI
(23)
94, Claude D
ebussylaan, Am
sterdam, 1082 M
D
Netherlands
(24)
c/o Nordisk R
enting Oy, Miko
nkatu 9, 0010
0, Helsinki
Finland
(25)
One Spencer Do
ck, Dublin,
D01 X9R7
RoI
(26)
The Mill, High S
treet, Roces
ter, Staffords
hire, ST14 5JW
UK
(27)
2 Athol Stre
et, Douglas, IM1 1
JA
Isle Of Man
(28)
36 St Andrew
Square, Edin
burgh, EH2
2YB
UK
(29)
64 New Cave
ndish Street, Lo
ndon, W1G 8TB
UK
(30)
Ashurst Australia, So
uth Tow
er,
80 Co
llins Street,
M
elbourne
Australia
(31)
Block A Georg
es Quay Plaza,
Georges Qu
ay, Dublin 2
RoI
(32)
Gate House, T
urnpike Roa
d, High Wyco
mbe, Buckingham
shire, HP12 3NR
UK
(33)
One Edinbu
rgh Quay, 133 Fou
ntainbridge, E
dinburgh, EH
3 9QG
UK
(34)
Roßmarkt 10,
Frankfurt am
Main, 60311
Germany
(35)
Ulster Bank G
roup Centre, G
eorge's Quay
, Dublin 2
RoI
(36)
114 West 47t
h Street, New Yo
rk, 10036
USA
(37)
12/14 Veer Nari
man Road,
Brady House 4th
floor, Fort,
Mumbai, 400001
India
(38)
16 Library Pla
ce, St. Helier
Jersey
(39)
1st floor, T
ower A, Building No.
1, Candor Te
chspace, IT/ITE
S SEZ, Sector
21, Gurugra
m, Haryana, 122
016
India
(40)
2 Athol Stre
et, Douglas,
IM99 1AN
Isle Of Man
(41)
200, Bellevue P
arkway, Su
ite 210, Wilmington,
DE 19809
USA
(42)
24 Demosthe
ni Severi, 1st Floo
r, Nicosia,
1080
Cyprus
(43)
254, 13 Floor,
Rua Boa Vis
ta, Sao Paul
o, 01014-907
Brazil
(44)
301, Bellevue P
arkway, 3rd
Floor, Wilmin
gton, DE, 19809
USA
(45)
4 Atlantic Quay
, 70 York Str
eet, Glasgo
w, G2 8JX
UK
(46)
40, Avenue J.F K
ennedy,
Kirchberg, L1855
Luxembourg
(47)
5 Harbourma
ster Place, Dub
lin 1, D01
E7E8
RoI
(48)
6th Floor, Bui
lding 2, To
wer A, GIL IT/IT
ES SEZ, Candor Te
chSpace, S
ector 21, Gurug
ram, Haryana,
122016
India
(49)
99 Queen Victor
ia Street, Lo
ndon, EC4V
4EH
UK
(50)
Via Vittorio Alfi
eri 1, Conegli
ano TV, IT
-TN 31015
Italy
(51)
Boundary Hall,
Cricket Squa
re, 171 Elgin Ave
nue, Grand C
ayman, KY1-
1104
Cayman I
slands
(52)
c/o Denis Cro
wley & Co Cha
rtered Accou
ntants, Unit 6 Ri
verside Grove, Riv
erstick, P43 W
221
RoI
(53)
C/o Pinsent Ma
sons Llp, Th
e Soloist, 1 Lanyo
n Place, B
elfast, Co. Antrim,
BT1 3LP
UK
(54)
Clarendon
House, Two Chur
ch Street, Suite
104, Reid Str
eet, Hamilton, HM
11
Bermuda
(55)
Cornwall Buil
dings, 45-51 N
ewhall Str
eet, Birmingham,
West Midlands, B
3 3QR
UK
(56)
De entree 99 -
197, 1101HE
Amsterdam Zui
doost
Net
herlands
Parent company
financial s
tatements and n
otes
continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
394
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
12 Related undertakings continued
Notes
Registered addresses
Country of incorporation
(57)
First Floor, 1 Ex
change Pla
ce, Dublin 1,
D01 R8W8
RoI
(58)
H. Heyerdahls
gate 1, Postbok
s 2020 Vika, O
slo, 0125
Norway
(59)
ul. Ilzecka 26, bu
ilding E, 02-13
5, Warsa
w
Poland
(60)
Inpartnership Lt
d, 35 St Paul'
s Square, Birming
ham, West Midl
ands, B3 1QX
UK
(61)
Lerchenstras
se 18, Zurich, C
H 8022
Switzerland
(62)
Liszt Straße 1
0, Regensburg, D-
93053
Germany
(63)
Madison Buildi
ng, Midtown, Qu
eensway
Gibraltar
(64)
Maples Corpora
te Services
Limited, P.O. Box
309, 121 Sout
h Church Str
eet, George Tow
n,
Grand Cayma
n, KY1-1104
Cayman Island
s
(65)
Office Block A,
Bay Studios
Business P
ark, Fabian Way
, Swansea, SA1 8Q
B
UK
(66)
One Dockland
Central, Guil
d Street, IF
SC, Dublin 1
RoI
(67)
PO Box 230, H
eritage Hall, L
e Marchant S
treet, St Peter Po
rt, GY1 4JH
Guernsey
(68)
PO Box 384, T
he Albany, Sou
th Esplanade,
St Peter Port,
Guernsey, GY1 4
NF
Guernsey
(69)
Regency Cour
t, Glategny Es
planade, St Pe
ter Port, GY1
3AP
Guernsey
(70)
Schuetzenga
ssse 4, CH-8001
Zurich
Switzerla
nd
(71)
The Chestnu
ts Brewers En
d, Takeley,
Bishop's Stortford, C
M22 6QJ
UK
(72)
Tirolerweg 8, Zu
g, CH- 6300
Sw
itzerla
nd
(73)
Verlengde Po
olseweg 16, Br
eda, 4818
CL
Netherlands
(74)
Victoria Place, 5
th Floor, 31 Vi
ctoria Street, H
amilton, HM 1
0
Bermuda
(75)
c/o Adv Jan-Eri
k Svensson,
HC Andersens Bo
ulevard 12, Ko
penhaum V, 1
553
Denmark
(76)
1209, Orang
e Street, Wilmin
gton, New Cast
le County, DE,
19801
USA
(77)
Kokermole
n 16, Houten, 399
4 DH
Net
herlands
(78)
46A, Avenue J.
F Kennedy,L 18
55
Luxembourg
(79)
2nd Floor 120
Old Broad Str
eet, London,
EC2N 1AR
UK
(80)
5 Little Portl
and Street, Lon
don W1W 7JD
UK
(81)
13 - 18 City Qu
ay, Dublin Doc
kland, Dublin 2,
D02 ED70
RoI
Non-IFRS fi
nancial me
asures
NatWest Group
A
nnual Repor
t and Accou
nts 2021
395
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
NatWest Group prepares its financial statements in
accordance with generally accepted acc
ounting principles (GAAP). This
document contains a number of adjusted or alternati
ve performance measures, also know
n as non-GAAP or non-IFRS
performance measures. These
measures are adjusted for notable and other defined items whi
ch management believe are not
representative of the underlying perfo
rmance of the business and which distort period-on-pe
riod comparison. The non-IFRS
measures provide users of the financial s
tatements with a consistent basis for comparing busi
ness performance between financial
periods and information on elements of pe
rformance that are one-off in nature. The no
n-IFRS measures also include the
calculation of metrics that are u
sed throughout the banking industry. These non-IFRS measu
res are not measures within the sc
ope
of IFRS and are not a substitute for IFRS
measures.
Non-IFRS financial measures
1. Adjustment for notable items
Go-forward group income excl
uding notable items is calculated as total income exclu
ding Ulster Bank RoI total income and
excluding notable items. UK an
d RBSI retail and commercial busines
ses total income excluding notable items comprises income in
the Retail Banking, Commercial
Banking, Private Banking and RBS International ope
rating segments excluding notable items
.
The exclusion of notable items aims to remove the
impact of one-offs which may distort period-on-period com
parisons.
Refer to page 83 for further details.
2021
2020
2019
Continuing operations
Total income
(1)
10,512
10,508
13,987
Less Ulster Bank RoI total income
(228)
(222)
(301)
Go-forward group income
10,284
10,286
13,686
Less notable items
(210)
384
(2,115)
Go-forward group total income excluding not
able items
10,074
10,670
11,571
Total income
Retail Banking
4,445
4,181
4,866
Private Banking
816
763
777
Commercial Banking
3,875
3,958
4,318
RBS International
548
497
610
UK and RBSI retail and commercial businesse
s income
9,684
9,399
10,571
Less notable items
(2)
(64)
87
(33)
UK and RBSI retail and commercial businesse
s income excluding notable items
9,620
9,486
10,538
(1)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the
consolidated
financial statements.
(2)
For details of UK and RBSI reta
il and commerci
al businesses notab
le items refer to page 84.
2. Adjustment for asset disposals/strategic risk reductions and own credit adjustments
NWM total income excluding asset disposals/strategic risk
reductions and own credit adjust
ments (OCA) is calculated as total
income of the NWM business le
ss asset disposals/strategic risk reductions and OCA.
This aims to show underlying inc
ome generation in NWM excluding the impact
of disposal losses and OCA.
Refer to pages 83 and 92 for further details.
2021
2020
2019
NWM total income
415
1,123
1,342
Less asset disposals/strategic risk reduction
64
83
Less OCA
(6)
24
80
NWM total income excluding asset disposals/ strategic
risk reductions and OCA
473
1,230
1,422
Non-IFRS financial m
easure
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
396
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
3. Operating expenses - management vie
w
The management analysis of o
perating expenses shows strategic costs and litigation
and conduct costs in separate lines.
Depreciation and amortisation, and other administr
ative expenses attributable to these costs
are included in strategic costs and
litigation and conduct costs lines f
or management analysis. These amounts are included in st
aff, premises and equipment and
other administrative expenses in the statu
tory analysis.
Other expenses excludes strate
gic costs and litigation and conduct costs,
which are more volatile and may distor
t comparisons
with prior periods.
Refer to page 300 for further details.
Non-statutory analysis
Year ended
31 December 2021
Litigation
Statutory
Strategic
and conduct
Other
operating
Operating expenses
costs
costs
expenses
expenses
Continuing operations
Staff expenses
411
3,265
3,676
Premises and equipment
103
1,030
1,133
Other administrative expenses
133
466
1,427
2,026
Depreciation and amortisation
140
783
923
Total
787
466
6,505
7,758
31 December 2020 (1)
Litigation
Statutory
Strategic
and conduct
Other
operating
Operating expenses
costs
costs
expenses
expenses
Continuing operations
Staff expenses
462
3,416
3,878
Premises and equipment
233
989
1,222
Other administrative expenses
197
113
1,535
1,845
Depreciation and amortisation
121
792
913
Total
1,013
113
6,732
7,858
31 December 2019 (1)
Litigation
Statutory
Strategic
and conduct
Other
operating
Operating expenses
costs
costs
expenses
expenses
Continuing operations
Staff expenses
451
3,525
3,976
Premises and equipment
239
1,019
1,258
Other administrative expenses
295
895
1,638
2,828
Depreciation and amortisation
396
822
1,218
Total
1,381
895
7,004
9,280
(1)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8.
4. Other expenses excluding operating lease
depreciation (OLD) and Ulster Bank RoI direct costs
Our cost target for 2021 is based on this measure
and we track progress against this.
Refer to page 83 for further details.
2021
2020 (1)
2019 (1)
Continuing operations
Total operating expenses
7,758
7,858
9,280
Less strategic costs
(787)
(1,013)
(1,381)
Less litigation and conduct costs
(466)
(113)
(895)
Other expenses
6,505
6,732
7,004
Less OLD
(140)
(145)
(138)
Other expenses excluding OLD
6,365
6,587
6,866
Less Ulster Bank RoI direct costs
(273)
(239)
(247)
Other expenses excluding OLD and Ulster Bank R
oI direct costs
6,092
6,348
6,619
(1)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the
consolidated
financial statements.
Non-IFRS financial m
easure
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
397
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
5. Cost:income ratio
The cost:income ratio is calculated as total ope
rating expenses less OLD divided by total income le
ss OLD.
This is a common metric used to compare
profitability across the banking industry.
Refer to pages 87 to 92 for furthe
r details.
Go
-
forward group
Total
Central
excluding
Retail
Pr
ivate
Commercial
RBS
Nat
West
items
Ulster
Ulster
NatWest
Banking
Banking
Banking
International
Markets
& other
Bank RoI
Bank RoI
Group
Year ended 31 December 2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
Continuing operations
Operating expenses
(2,513)
(520)
(2,354)
(242)
(1,161)
(486)
(7,276)
(482)
(7,758)
Operating lease depreciation
140
140
140
Adjusted operating expenses
(2,513)
(520)
(2,214)
(242)
(1,161)
(486)
(7,136)
(482)
(7,618)
Total income
4,445
816
3,875
548
415
185
10,284
228
10,512
Operating lease depreciation
(140)
(140)
(140)
Adjusted total income
4,445
816
3,735
548
415
185
10,144
228
10,372
Cost:income ratio
56.5%
63.7%
59.3%
44.2%
279.8%
nm
70.3%
nm
73.4%
Year ended 31 December 2020
(1)
Continuing operations
Operating expenses
(2,540)
(455)
(2,430)
(291)
(1,310)
(391)
(7,417)
(441)
(
7,858)
Operating lease depreciation
145
145
145
Adjusted operating expenses
(2,540)
(455)
(2,285)
(291)
(1,310)
(391)
(7,272)
(441)
(
7,713)
Total income
4,181
763
3,958
497
1,123
(236)
10,286
222
10,508
Operating lease depreciation
(145)
(145)
(145)
Adjusted total income
4,181
763
3,813
497
1,123
(236)
10,141
222
10,363
Cost:income ratio
60.8%
59.6%
59.9%
58.6%
116.7%
nm
71.7%
nm
74.4%
Year ended 31 December 2019
(1)
Continuing operations
Operating expenses
(3,618)
(486)
(2,600)
(264)
(1,418)
(384)
(8,770)
(510)
(
9,280)
Operating lease depreciation
138
138
138
Adjusted operating expenses
(3,618)
(486)
(2,462)
(264)
(1,418)
(384)
(8,632)
(510)
(
9,142)
Total income
4,866
777
4,318
610
1,342
1,773
13,686
301
13,987
Operating lease depreciation
(138)
(138)
(138)
Adjusted total income
4,866
777
4,180
610
1,342
1,773
13,548
301
13,849
Cost:income ratio
74.4%
62.5%
58.9%
43.3%
105.7%
nm
63.7%
nm
66.0%
(1)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the
consolidated
financial statements.
Non-IFRS financial m
easure
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
398
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
6. NatWest Group return on tangible equity
Return on tangible equity comprises
annualised profit or loss for the period attribut
able to ordinary shareholders divided
by
average tangible equity. Average tangible equity is a
verage total equity excluding non-cont
rolling interests (NCI) less average
intangible assets and average other owners’ e
quity.
Go-forward group return on tangible equity is calcul
ated as annualised profit or loss fo
r the period less Ulster Bank RoI loss f
rom
continuing operations and less
profit from discontinued operations divided by go-fo
rward group total tangible equity.
This measure shows the return
NatWest Group generates on tangible equity deployed. It is us
ed t
o determine relative perfor
mance
of banks and used widely across the sector.
Refer to pages 83 and 87 for further details.
Year ended or as at
31 December
31 December
NatWest Group return on tangible e
quity
2021
2020
Profit/(loss) attributable to ordinary shareholders (£
m)
2,950
(753)
Average total equity (£m)
42,727
43,774
Adjustment
for other owners equity and int
angibles (£m)
(11,395)
(11,872)
Adjusted total tangible equity (
£m)
31,332
31,902
Return on tangible equity (%)
9.4%
(2.4%)
Go-forward group return on tangible equity
Profit/(loss) attributable to ordinary shareholders (£
m)
2,950
(753)
Less Ulster Bank RoI loss from continuing opera
tions (£m)
255
495
Less profit from discontinued o
perations (£m)
(276)
(121)
Go
-
forward group profit/(loss
) attributable to
ordinary shareh
olders (£m)
2,929
(379)
Average total equity (£m)
42,727
43,774
Adjustment
for other owners equity and int
angibles (£m)
(11,395)
(11,872)
Adjusted total tangible equity (
£m)
31,332
31,902
Go-forward group RWAe applying factor (%)
93%
93%
Go-forward group total tangible equity (£m)
29,139
29,669
Return on tangible equity (%)
10.0%
(1.3%)
Non-IFRS financial m
easure
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
399
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
7. Segmental return on equity
Segmental return on equity comp
rises segmental operating profit or loss, adjusted fo
r preference share dividends and tax, divided
by average notional tangible eq
uity, allocated at an operating segment specific rate of the
period average segmental risk-
weighted assets, incorporating the effe
ct of capital deductions (RWAes).
This measure shows the return
generated by operating segments on equi
ty deployed.
Refer to pages 87 to 92 for furthe
r details.
Retail
Private
Commercial
RBS
NatWest
Year ended 31 December 2021
Banking
Banking
Banking
Internationa
l
Markets
Operating profit/(loss) (£m)
1,968
350
2,594
358
(711)
Preference share cost allocation (£m)
(79)
(21)
(
154)
(20)
(63)
Adjustment for tax
(£m)
(529)
(92)
(
683)
(59)
217
Adjusted attributable profit/(loss
) (£m)
1,360
237
1,757
279
(557)
Average RWAe (£bn)
36.0
11.2
69.5
7.8
28.4
Equity factor
14.5%
12.5%
11.5%
16.0%
15.0%
RWAe applying equity factor (£bn)
5.2
1.4
8.0
1.2
4.3
Return on equity
26.1%
17.0%
22.0%
22.5%
(13.1%)
Year ended 31 December 2020
Operating profit/(loss) (£m)
849
208
(399)
99
(227)
Preference share cost allocation (£m)
(88)
(22)
(
153)
(20)
(68)
Adjustment for tax (£m)
(213)
(52)
155
(11)
83
Adjusted attributable profit/(loss
) (£m)
548
134
(397)
68
(212)
Average RWAe (£bn)
37.2
10.4
76.4
7
.0
37.3
Equity factor
14.5%
12.5%
11.5%
16.0%
15.0%
RWAe applying equity factor (£bn)
5.4
1.3
8.8
1
.1
5.6
Return on equity
10.2%
10.3%
(4.5%)
6.1%
(3.8%)
Year ended 31 December 2019
Operating profit/(loss) (£m)
855
297
1,327
344
(25)
Adjustment for tax (£m)
(236)
(83)
(
372)
(48)
7
Preference share cost allocation (£m)
(74)
(18)
(
163)
(11)
(64)
Adjustment for Alawaal bank m
erger gain (£m)
(150)
Adjusted attributable profit/(loss
) (£m)
545
196
792
285
(232)
Average RWAe (£bn)
37.7
9.8
78.2
6.9
48.0
Equity factor
15.0%
13.0%
12.0%
16.0%
15.0%
RWAe applying equity factor (£bn)
5.7
1.3
9.4
1
.1
7.2
Return on equity
9.6%
15.4%
8.4%
25.7%
(3.2%)
8. Tangible equity
Tangible equity is ordinary shareholders’ interest less int
angible assets. TNAV per ordinary sh
are is calculated as tangible equity
divided by the number of ordinary shares in iss
ue.
This is a measure used by external an
alysts in valuing the bank and the star
ting point for calculating regulatory capital.
Refer to page 83 for further details.
Year ended
31 December
31 December
2021
2020
Ordinary shareholders’ interests (£m)
37,412
38,367
Less intangible assets (£m)
(6,723)
(6,655)
Tangible equity (£m)
30,689
31,712
Ordinary shares in issue (millions)
11,272
12,129
TNAV per ordinary share (pence)
272p
261p
Non-IFRS financial m
easure
s continued
NatWest Group
A
nnual Repor
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nts 2021
400
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
9. Net interest margin
Bank net interest margin is defined as net interest
income of the banking business of the
Go-forward group less NatWest Markets
(NWM) element and
excluding liquid asset buffer,
as a percentage of bank average interest-e
arning assets. Bank average inte
rest
earning assets are the average interest earning assets of
the banking business of the Go-for
ward group less NWM element and
excluding liquid asset buffer.
The exclusion of the NWM element aims to eli
minate the impact of distorting volatility in NWM.
The exclusion of the Ulster Bank RoI
from the aims to align the basis
of calculation with prior periods.
Liquid asset buffer consists of asse
ts held by NatWest Group, such as cash and balances at central b
anks and debt securities in
issue, that can be used to ensure rep
ayment of financial obligations as they fall due.
The exclusion of liquid asset bu
ffer has been introduced as a way to present net interest
margin on a basis more comparable with
UK peers and exclude the impact of regul
atory driven factors.
Refer to pages 83 and 88 to 91 for further de
tails.
Year ended
31 December
31 December
31 December
2021
2020
2019
£m
£m
£m
Continuing operations
NatWest Group net interest income
(1)
7,614
7,476
7,799
Less NWM net interest income
(9)
57
188
Less Ulster Bank RoI net interes
t income
(100)
(122)
(152)
Bank net interest income
7,505
7,411
7,835
Average interest earning assets (IEA)
524,886
483,719
439,994
Less NWM average IEA
(32,730)
(37,929)
(35,444)
Less Ulster Bank RoI average I
EA
(15,854)
(16,600)
(16,538)
Less liquid asset buffer average IEA
(1)
(162,195)
(127,945)
(
106,925)
Bank average IEA
314,107
301,245
281,087
Bank net interest margin
2.39%
2.46%
2.79%
(1)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the
consolidated
financial statements.
Non-IFRS financial m
easure
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
401
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
10. Net lending
NatWest Group net lending is calculated as total loans
to customers less loan impairment pro
visions.
Go-forward group net lending is calculated as net lo
ans to customers less Uls
ter Bank RoI net loans to customers.
UK and RBSI retail and commercial businesse
s net lending excluding UK Government sup
port schemes comprises customer l
oans
in the Retail Banking, Commercial Banking, P
rivate Banking and RBS International operating s
egments, excluding UK Government
support schemes.
This is the basis of our lending
target for our key retail and comme
rcial businesses.
Refer to pages 83 for further details.
As at
31 December
31 December
2021
2020
£bn
£bn
Total loans to customers (amortise
d cost)
362.8
366.5
Less loan impairment provisions
(3.8)
(6.0)
Net loans to customers (amortis
ed cost)
359.0
360.5
Less Ulster Bank RoI net loans to custome
rs (amortised cost)
(6.7)
(18.0)
Go
-
forward group net lending
352.3
342.5
Net loans to customers (amortis
ed cost)
Retail Banking
182.2
172.3
Private Banking
18.4
17.0
Commercial Banking
101.2
108.2
RBS International
15.5
13.3
UK and RBSI retail and commercial businesse
s net loans to customers (a
mortised cost)
317.3
310.8
Less UK Government support schemes
(11.6)
(12.9)
Total UK and RBSI retail and co
mmercial businessesnet lending excluding UK Go
vernment support
schemes
305.7
297.9
11. Customer deposits
Go-forward group customer deposits is calculated
as total customer deposits less Ulster Bank
RoI customer deposits.
UK and RBSI retail and commercial businesse
s customer deposits comprises
customer deposits in the Retail Banking, Comme
rcial
Banking, Private Banking and RBS International ope
rating segments.
This metric is used to show unde
rlying deposit movements across our key ret
ail and commercial businesses.
Refer to pages 83 for further details.
As at
31 December
31 December
2021
2020
£bn
£bn
Total customer deposi
ts
479.8
431.7
Less Ulster Bank R
oI customer de
posits
(18.4)
(19.6)
Go-forward group customer deposits
461.4
412.1
Retail Banking
188.9
171.8
Private Banking
39.3
32.4
Commercial Banking
177.7
167.7
RBS International
37.5
31.3
Total UK and RBSI retail and co
mmercial businesses customer deposits
443.4
403.2
12. Total operating profit before tax including discontinued operations
Given the current progress of the phased with
drawal from the Republic of Ireland, Ulster Ban
k RoI results are currently prese
nted
in both continuing and disconti
nued operations. Including operating profit befo
re tax from discontinued operations provides
a
complete view of the NatWest Group operating profit in 2
021.
Refer to page 82 for further details.
2021
2020
2019
Operating profit/(loss) before tax
4,032
(481)
3,983
Operating profit before tax from discon
tinued operations
279
130
249
Total operating profit including discontinued
operations
4,311
(351)
4,232
Non-IFRS financial m
easure
s continued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
402
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Performance metrics not defined under IFRS
Metrics based on GAAP measu
res, included as not defined under IFRS and
reported for compliance with ESMA adjusted
performance measure rules.
1. Loan:deposit ratio
Loan:deposit ratio is calculated as net custo
mer loans held at amortised cost divide
d by total customer deposits.
This is a common metric used among peers to assess
liquidity.
Refer to page 89 to 90 for further details.
As at
31 December
31 December
31
December
2021
2020
2019
£m
£m
£m
Loans to customers - amortised cost
358,990
360,544
326,947
Customer deposits
479,810
431,739
369,247
Loan:deposit ratio (%)
75%
84%
89%
2. Loan impairment rate
Loan impairment rate is the annualised loan impai
rment charge divided by gross customer loans.
Refer to pages 83 and 88 to 91 for further de
tails.
3. Funded assets
Funded assets is calculated as t
otal assets less derivative assets.
This measure allows review of balance shee
t trends exclusive of the volatility associated with
derivative fair values.
Refer to pages 92 and 93 for further details.
4. AUMAs
AUMA comprises both assets under
management (AUMs) and assets under ad
ministration (AUAs) serviced through the Priv
ate
Banking franchise. AUMs comprise assets where
the investment management is unde
rtaken by Private Banking on behalf of
Private Banking, Retail Banking and RBSI custo
mers. AUAs comprise third party assets held o
n an execution-only basis in custody
by Private Banking, Retail Banking and RBSI for their custo
mers accordingly, for which the exe
cution services are supported by
Private Banking. Private Bankin
g receives a fee for providing investment managemen
t and execution services to Retail Ban
king
and RBSI franchises.
Private
Banking
is the Centre of Expertise for ass
et management across NatWest Group, servi
cing all client segments across Retail,
Premier and Private Banking.
Refer to page 89 for further details.
5. Depositary assets
Assets held by RBSI as an independent trustee
and in a depositary service capacity.
Depositary assets are a closely monitored KP
I for the RBS International business and its inclusi
on in commentary highlights the
services that RBS International provides
.
Refer to page 91 for further details.
6. Wholesale funding
Wholesale funding comprises deposits by banks, deb
t securities in issue and subordinated li
abilities.
This is a closely monitored metric used ac
ross the banking industry to ensure capital requi
rements are being met.
Refer to page 83 for further details.
The Capital Req
uirement
s (Country-b
y-Country
Reporting) R
egulations
(Audited)
NatWest Group
A
nnual Repor
t and Accou
nts 2021
403
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
This report has been prepared f
or NatWest Group to comply with the Capital Require
ments (Country-by-Country Reporting)
Regulations 2013 which impleme
nt Article 89 of the Capital Requirements Directive
IV.
This report shows the income, profit/(loss
) before tax, tax paid/(received), average and spo
t employee numbers on a full-time
equivalent basis for the entities
located in the countries in which we operate.
Country
Each subsidiary or branch is all
ocated to the country in which it is resident for
tax purposes. The data is consolidated for all the
subsidiaries and branches allocated to each count
ry.
Income and profit/(loss) before tax
Income and profit/(loss) totals are reported in Note 4 wi
thin the Geographical segments table.
Tax paid/(received)
Tax paid/(received) disclosed under CR
D IV relates to corporation tax.
Corporation tax paid represents net cash taxes p
aid to/(received) from the tax authorities in e
ach jurisdiction.
Corporation tax paid is reported on a cash basis as op
posed to an accounting basis and there
fore does not necessarily have a
direct correlation to the reporte
d profits or losses arising in the year. For example, in certain j
urisdictions taxable profits may
be
reduced as a result of the offset of tax losses br
ought forward from prior years; or tax pay
ments may be calculated with reference
to prior year profits.
Full time equivalent employees (FTEs)
FTEs are allocated to the country in which they a
re primarily based for the performance of th
eir employment duties. The figures
disclosed represent the average number of FTEs, inclu
ding temporary staff, in each country durin
g the period. The FTEs, including
temporary staff, at 31 Decembe
r 2021, have been added for completeness.
Public subsidies received
No public subsidies were receiv
ed during the period
.
The Capital Re
quirements (
Country-by-Co
untry Report
ing) Regulations (
Audited) continu
ed
NatWest Group
A
nnual Repor
t and Accou
nts 2021
404
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
NatWest Group Country-by-Country tax
breakdown 2021
Headcount
Income (1,7)
Profit/(loss) bef
ore
tax (1,7)
Tax paid/
(received)
Average FTE including
temporary staff
FTE including tempora
ry staff as at
the year end 31
December 2021
Country
£m
£m
£m
UK
9,600
3
,948
787
40,426
39,692
Guernsey
99
83
8
85
83
Isle of Man
55
22
348
337
Jersey
166
90
1
702
676
UK region
9,920
4
,143
796
41,561
40,788
Finland
2
3
3
France
23
(9)
1
40
49
Germany
14
(2)
2
61
70
Gibraltar
29
17
1
58
55
Greece
(1)
1
1
Republic of Ireland
453
(1)
2
2,000
1,935
Italy
7
(2)
1
14
12
Luxembourg
28
14
2
59
59
Netherlands
86
30
106
112
Norway
1
Poland
(2)
5
2
1,280
1,369
Spain
6
(2)
1
13
5
Sweden
37
28
9
35
34
Switzerland
(2)
1
5
6
273
274
Turkey
2
1
1
2
2
Europe region
691
80
28
3,945
3,980
USA
100
48
2
291
270
US region
100
48
2
291
270
Hong Kong
9
(2)
14
9
India
(2)
13
37
12
13,164
13,541
Japan
18
2
37
37
Singapore
31
3
110
110
Asia Pacific region
71
40
12
13,325
13,697
Saudia Arabia
(3)
18
Middle East region
18
UK region
9,920
4
,143
796
41,561
40,788
US region
100
48
2
291
270
Europe region
691
80
28
3,945
3,980
Rest of World region
71
40
30
13,325
13,697
Global total
10,782
4,311
856
59,122
58,735
For the notes to this table refer to the following pa
ge.
The Capital Re
quirements (
Country-by-Co
untry Report
ing) Regulations (
Audited) continu
ed
NatWest Group
A
nnual Repor
t and Accou
nts 2021
405
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
NatWest Group Country-by-Country tax
breakdown 2020
Headcount
(Loss)/profit
Tax paid/
Average FTE
FTE including temporary
Income (1,4)
before tax (1,4)
(received) (4)
including
staff as at t
he year end
£m
£m
£m
temporary staff
31 December 2020
Country
UK
9,431
(223)
113
42,748
41,185
Guernsey
92
42
12
100
92
Isle of Man
59
4
3
405
382
Jersey
165
(16)
15
624
616
UK region
9,747
(193)
143
43,877
42,275
Finland
6
6
2
3
2
France
20
2
31
32
Germany
13
1
(1)
39
43
Gibraltar
28
9
4
67
60
Greece
1
1
1
Republic of Ireland
512
(235)
1
2,223
2,153
Italy
9
2
1
16
16
Luxembourg
16
1
1
57
62
Netherlands
77
7
99
96
Norway
3
2
2
Poland
(2)
1
5
1,216
1,184
Spain
9
1
18
18
Sweden
36
21
(2)
36
36
Switzerland
(2)
3
18
11
273
270
Turkey
2
3
2
2
Europe region
735
(161)
24
4,081
3,975
USA
181
(85)
(1)
378
326
US region
181
(85)
(1)
378
326
Hong Kong
13
27
24
India
(2)
28
52
24
13,321
13,164
Japan
23
5
1
41
39
Singapore
68
30
135
112
Taiwan
1
2
(1)
Asia Pacific region
133
89
24
13,524
13,339
Saudi Arabia
(3)
24
United Arab Emirates
(
1)
Middle East region
(
1)
24
UK region
9,747
(193)
143
43,877
42,275
Europe region
735
(161)
24
4,081
3,975
US region
181
(85)
(1)
378
326
Rest of World region
133
88
48
13,524
13,339
Global total
10,796
(351)
214
61,860
59,915
(1)
A full list of NatWest Group subsidiaries' names, nat
ure of activities and geographical locations is available at Note 12 of the parent company accounts.
(2)
Income excludes internal serv
ice fee income which has been calculated on a cost plus mark-up basis.
(3)
Tax paid of £18 million in Saudi Arab
ia is due to capital gains tax arising on the merger of Alawwal bank with SABB during 2019.
(4)
Comparative results have been
re-presented from those previously published to reclassify certain operations as discontinued operations as described in Note 8 to the
consolidated
financial statements.
(5)
A list of the principal subsidiaries in each jurisdiction and the nature of th
eir activities is available at Note 9 of the parent company accounts.
(6)
The amounts shown above are presented to the nea
rest million and as a result any amounts less than £0.5 million have been rounded to zero.
(7)
The information above is presented on a gross
reporting basis and includes results from discontinued operations. The results from discontinued operations are included in the Ireland
totals, contributing to Income: £269 million; Profit bef
ore tax: £279 million;
Tax p
aid: nil; Subsidies received: nil; Headcount: 715.
Risk factors
NatWest Group
A
nnual Repor
t and Accou
nts 2021
406
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Principal Risks and
Uncertainties
Set out below are certain risk factors
that could adversely affect NatWest
Group’s future results, its financial
condition and prospects and caus
e them
to be materially different from what is
forecast or expected, and direc
tly or
indirectly impact the value of it
s
securities in issue. These
risk factors are
broadly categorised and should be read
in conjunction with other sectio
ns of this
annual report, including the forward-
looking statements section, the strategic
report and the risk and capital
management section. They should not be
regarded as a complete and
comprehensive statement of all potential
risks and uncertainties facing NatWest
Group. The COVID-19 pandemic may
exacerbate any of the risks described
below.
Economic and political risk
The impact of the COVID-19 pa
ndemic
and related uncertainties continue to
affect the UK, global economies and
financial markets and NatWest
Group’s
customers, as well as its competitive
environment, which may continue to
have an adverse effect on NatWes
t
Group.
In many countries, including the U
K
(NatWest Group’s most signific
ant
market), the COVID-19 pandemic has,
at
times, resulted in the imposition of strict
social distancing measures, res
trictions
on non-essential activities and travel
quarantines, in an attempt to slow the
spread and reduce the impact of the
COVID-19 pandemic. The COVID-19
pandemic has also, at times, cause
d
significant reductions in levels of
consumer and commercial activity,
reductions in consumer spending,
increased levels of corporate d
ebt and,
for some customers, personal debt,
increased unemployment and significan
t
market volatility in asset prices, interest
rates and foreign exchange rates
. It has
also, at times, caused physical disruption
to global supply chains and working
practices, all of which have affe
cted
NatWest Group’s customers. NatWest
Group has significant exposure
s to many
of the commercial sectors economically
impacted by the COVID-19 pandemic,
including property, retail, leisure
and
travel.
Despite widespread COVID-19
vaccination within the geographical
regions in which NatWest Group
operates, the proliferation of CO
VID-19
variants continues to affect the UK an
d
global economies. Further waves of
infection or the spread of new s
trains
may result in renewed restrictions in
affected countries and regions.
As a
result, significant uncertainties remain as
to how long the impact of the COVID-19
pandemic will last, and how it will
continue to affect the global economy.
In response to the COVID-19 pandemic,
central banks, governments, regulators
and legislatures in the UK and e
lsewhere
have offered unprecedented levels of
support and various schemes to assist
impacted businesses and individuals. This
has included forms of financial
assistance and legal and regulatory
initiatives. Many of these support
schemes have now been curtailed.
However, uncertainty remains as to the
impact of the ending or tapering of these
schemes and the repayment of the loa
ns
involved
on customers, the economic
environment and NatWest Group.
Moreover, it is unclear as to how any
further measures, such as risin
g interest
rates and inflation, may affect NatWest
Group’s business and performance.
The COVID-19 pandemic has prompted
many changes that may prove to be
permanent shifts in customer be
haviour
and economic activity, such as changes
in spending patterns and significantly
more people working from home. The
se
changes may have long lasting impacts
on asset prices, the economic
environment and its customers financial
needs.
Uncertainties relating to the COVID-19
pandemic has made reliance o
n
analytical models and planning and
forecasting for NatWest Group more
complex, and may result in uncertainty
impacting the risk profile of NatWest
Group and/or that of the wider banking
industry. The medium and long-term
implications of the COVID-19 pandemic
for NatWest Group customers, the UK
housing market, and the UK and global
economies and financial markets remain
uncertain.
Any of the above may have a negative
impact on NatWest Group.
NatWest Group faces continued
economic and political risks an
d
uncertainty in the UK and global
markets.
The outlook for the global economy over
the medium-term remains uncertain due
to a number of factors including: the
COVID-19 pandemic, societal inequalities
and changes, trade barriers and the
increased possibility of and/or
continuation of trade wars, widespread
political instability (including as a result
of populism and nationalism, which may
lead to protectionist policies, state and
privately sponsored cyber and terroris
t
acts or threats, efforts to destabilis
e
regimes or armed conflict), changes in
inflation and interest rates (including
negative interest rates), supply chain
disruption, climate, environmental, social
and other sustainability-related risks and
global regional variations in the impact
and responses to these
factors.
These conditions could be worsened by a
number of factors including macro-
economic deterioration, increased
instability in the global financial sy
stem
and concerns relating to further financial
shocks or contagion (for example, due to
economic concerns in emerging
markets), market volatility or fluctuations
in the value of the pound sterling, new o
r
extended economic sanctions, volatility
in commodity prices or concerns
regarding sovereign debt. This
may be
compounded by the changing
demographics of the populations in the
markets that NatWest Group serves,
increasing social and other inequalities,
or rapid change to the economic
environment due to the adoption of
technology and artificial intellige
nce. Any
of the above developments could
adversely impact NatWest Group directly
(for example, as a result of credit losses)
or indirectly (for example, by impacting
global economic growth and financial
markets and NatWest Group’s cus
tomers
and their banking ne
eds).
In addition, NatWest Group is exposed t
o
risks arising out of geopolitical events or
political developments, such as
exchange
controls and other measures take
n by
sovereign governments that may hinder
economic or financial activity levels.
Furthermore, unfavourable political,
military or diplomatic events, inclu
ding
secession movements or the exit of othe
r
member states from the EU, armed
conflict, pandemics and widespread
public health crises (including the c
urrent
COVID-19 pandemic and any future
epidemics or pandemics), state and
privately sponsored cyber and terroris
t
acts or threats, and the responses
to
them by governments and markets,
could negatively affect the busi
ness and
performance of NatWest Group,
including as a result of the indirect eff
ect
on regional or global trade and/or
NatWest Group’s customers.
NatWest Group faces political
uncertainty in Scotland, as a res
ult of a
possible second Scottish independence
referendum. Independence may
adversely impact NatWest Group since
NatWest Group plc and other NatWest
Group entities (including NWM Plc) are
incorporated in Scotland. Any changes
to Scotland’s relationship with t
he UK or
the EU would impact the enviro
nment in
which NatWest Group and its
subsidiaries operate, and may require
further changes to NatWest Group’s
structure, independently or in
conjunction with other mandatory or
strategic structural and organisational
changes which, any of which could
adversely impact NatWest Group.
Risk factors c
ontinued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
407
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
The value of NatWest Group’s financial
instruments may be materially affected
by market risk, including as a res
ult of
market fluctuations. Market volatility,
illiquid market conditions and di
sruptions
in the credit markets may mak
e it
extremely difficult to value certain of
NatWest Group’s financial instruments,
particularly during periods of market
displacement. This could cause a decline
in the value of NatWest Group’
s financial
instruments, which may have an adverse
effect on NatWest Group’s results of
operations in future periods, or
inaccurate carrying values for ce
rtain
financial instruments.
In addition, financial markets are
susceptible to severe events evi
denced
by rapid depreciation in asset values,
which may be accompanied by a
reduction in asset liquidity. Unde
r these
conditions, hedging and other risk
management strategies may not be as
effective at mitigating trading losse
s as
they would be under more normal
market conditions. Moreover, under
these conditions, market participants are
particularly exposed to trading
strategies
employed by many market partic
ipants
simultaneously and on a large scale,
increasing NatWest Group’s cou
nterparty
risk. NatWest Group’s risk management
and monitoring processes see
k to
quantify and mitigate NatWest Group’s
exposure to more extreme mark
et
moves. However, severe marke
t events
have historically been difficult to predict
and NatWest Group could reali
se
significant losses if extreme market
events were to occur.
Any of the above may have a negative
effect on NatWest Group.
Continuing uncertainty regarding the
effects and extent of the UK’s post Brexit
divergence from EU laws and regulation,
and NatWest Group’s post Brexit EU
operating model may continue
to
adversely affect NatWest Group and its
operating environment.
The UK ceased to be a member of the
EU and the European Economic Area
(‘EEA’) on 31 January 2020 (‘B
rexit’) and
the 2020 EU-UK Trade and Cooperation
Agreement (‘TCA’) ended the transition
period on 31 December 2020. T
he TCA
provides for free trade between the UK
and EU with zero tariffs and quotas on
all goods that comply with the
appropriate rules of origin, with minimal
coverage. However, for financial
services, UK-incorporated financi
al
services providers no longer have EU
passporting rights and there is no mutual
recognition regime. Financial se
rvices
may largely be subject to individual
equivalence decisions by relevant
regulators. A number of temporary
equivalence decisions have been made
that cover certain services offered by
NatWest Group. The EU’s equivalence
regime does not cover most lending and
deposit taking, and determinations in
respect of third countries have not, to
date, covered the provision of most
investment services. In addition,
equivalence determinations do not
guarantee permanent access rights and
can be withdrawn with short notice. T
he
TCA is accompanied by a Joint
Declaration on financial services
which
sets out an intention for the EU and UK
to cooperate on matters of financial
regulation and to agree a Memorandum
of Understanding, which has yet to be
signed. In late 2021 the European
Commission proposed legislation that
would require non-EU firms to es
tablish
a branch or subsidiary in the EU bef
ore
providing “banking services” in the EU. If
these proposals become law all “
banking
services” will be licensable acti
vities in
each EU member state and member
states will not be permitted to o
ffer
bilateral permissions to financial
institutions outside the EU allowing them
to provide “banking services” i
n the EU.
Uncertainty remains as to whet
her
“banking services” will also include
investment products.
NatWest Group continues to ev
aluate its
post Brexit EU operating model, making
adaptations as necessary. NatWest
Group also continues to assess where
NatWest Group companies can obtain
bilateral regulatory permissions
to
facilitate intragroup transactions
and/or
to permit business to continue from its
UK entities, transferring what cannot be
continued to be rendered from the UK to
an EEA subsidiary or branch where
permitted. Where these regulatory
permissions are temporary or are
withdrawn, a different approach may
need to be taken or may result in a
change in operating model or some
business being ceased. Not all NatWest
Group entities have applied for bilateral
regulatory permissions and instead
intend to move EEA business to an EEA
licensed subsidiary or branch. T
here is a
risk that these EEA licenses may
not be
granted, or may be withdrawn, and
where these permissions are not
obtained, further changes to NatWest
Group’s operating model may be
required or some business may need to
be ceased. In addition, failure to obtain
required
regulatory permissions or
licences in one part of NatWest Group
may impact other parts of NatWes
t
Group adversely. Certain permissions
are required in order to maintain the
ability to clear euro payments. O
ther
permissions, including the ability to have
two intermediate EU parent
undertakings, would allow NatWest
Group to continue to serve EEA
customers from both the ring-fenced and
non-ring-fenced banking entitie
s.
Furthermore, transferring busine
ss to an
EEA based subsidiary is a complex
exercise and involves legal, regulatory
and execution risks, and could result in a
loss of business and/or custome
rs or
greater than expected costs. The
changes to NatWest
Group’s operating
model have been costly and fur
ther
changes to its business operations,
product offering and customer
engagement could result in further costs.
The long-term effects of Brexit and the
uncertainty regarding NatWest Group’s
EU operating model may have a
negative impact on NatWest Group’s
business. These may be exacerbated by
wider global macro-economic trends and
events, particularly COVID-19 pandemic
related uncertainties, which may
significantly impact NatWest Gr
oup and
its customers and counterpartie
s who
are themselves dependent on trading
with the EU or personnel from the EU.
They may exacerbate the economic
impacts of the COVID-19 pandemic on
the UK, the Republic of Ireland (‘ROI’)
and the rest of the EU/EEA.
Significant uncertainties remain as to the
extent to which EU/EEA laws will diverge
from UK law (including bank regulation),
whether and what equivalence
determinations will be made by the
various regulators, whether the propose
d
EEA licensed subsidiary is granted a
banking licence, whether banking
services will be harmonised across
the
EEA and, therefore, what the respective
legal and regulatory arrangements will
be, under which NatWest Group and its
subsidiaries will operate. This divergence
could lead to further market
fragmentation. These risks and
uncertainties may require costly changes
to NatWest Group’s EU operating model.
The legal and political uncertainty, and
any actions taken as a result of this
uncertainty, as well as the approach
taken by regulators and new or
amended rules, could have a si
gnificant
adverse impact on NatWest Group’s
businesses, non-UK operations and/or
legal entity structure, including attendant
operating, compliance and restructu
ring
costs, level of impairments, capital
requirements, changes to intra
group
arrangements, increased compl
exity,
regulatory environment and tax
implications and as a result may
adversely impact NatWest Group’s
profitability, competitive position,
business model and product off
ering.
Changes in interest rates have
significantly affected and will continue to
affect NatWest Group’s business and
results.
Interest rate risk is significant for
NatWest Group. Monetary policy has
been accommodative in recent
years
including initiatives implemented by the
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Bank of England and HM Treasury, suc
h
as the Term Funding Scheme with
additional incentives for SMEs (‘TFSME’),
which have helped to support demand at
a time of pronounced fiscal tightening
and balance sheet
repair. However,
market expectations are curre
ntly that
benchmark interest rates such as UK
base rate, could begin to rise furthe
r and
faster than had been anticipated
previously and that this could be
accompanied by other measures
to
reverse accommodative policy, such as
quantitative tightening.
While increases in interest rates
may
support NatWest Group’s interes
t
income, sharp rises could have
macroeconomic effects that lead to
adverse outcomes for the busin
ess. For
example, they could lead to ge
nerally
weaker than expected growth,
or even
contracting GDP, reduced busi
ness
confidence, higher default rates
on
customer loans, higher levels of
unemployment or underemployment, and
falling property prices in the markets in
which NatWest Group operates, all of
which could adversely affect the
business and performance of NatWest
Group. Conversely, decreases in interest
rates and/or continued sustained low or
negative interest rates would be
expected to continue to put further
pressure on NatWest Group’s interest
income and profitability.
Unexpected moves in interest rates will
also affect valuations of assets and
liabilities that are recognised at
fair value
on the balance sheet. Changes in these
valuations may be adverse. Unexpected
movements in spreads between ke
y
benchmark rates could have adverse
impacts and also adversely affect
NatWest Group’s financial position.
Changes in foreign currency exchange
rates may affect NatWest Group’s results
and financial position.
Decisions of major central banks
(including the Bank of England, the
European Central Bank and the US
Federal Reserve) and political o
r market
events, which are outside NatWes
t
Group’s control, may lead to sh
arp and
sudden variations in foreign ex
change
rates.
Although NatWest Group is principally a
UK focused banking group, it is su
bject
to foreign exchange risk from capital
deployed in NatWest Group’s foreign
subsidiaries, branches and joint
arrangements and customer transactions
denominated in a currency other than
the functional currency of NatWes
t
Group. NatWest Group also reli
es on
issuing securities in foreign currencies
that assist in meeting NatWest Group’s
minimum requirements for own funds
and eligible liabilities (‘MREL’) and NWM
Plc deals foreign exchange inst
ruments.
NatWest Group maintains policies
and
procedures designed to manage
the
impact of exposures to fluctuations in
currency rates. Nevertheless, changes in
currency rates, particularly in t
he
sterling-US dollar and euro-sterling
rates, can adversely affect the
value of
assets, liabilities (including the total
amount MREL-eligible instruments),
foreign exchange dealing activi
ty,
income and expenses, RWAs and hence
the reported earnings and financial
condition of NatWest Group.
HM Treasury (or UKGI on its behalf)
could exercise a significant degree of
influence over NatWest Group and
further offers or sales of NatWest
Group’s shares held by HM Tre
asury
may affect the price of NatWest Group
securities.
In its March 2021 Budget, the UK
Government announced its intention to
continue the process of privatisation of
NatWest Group plc and to carry
out a
programme of sales of NatWest Group
plc ordinary shares with the obj
ective of
selling all of its remaining shares in
NatWest Group plc by 2025-2026. A
s a
result of a directed buyback of NatWest
Group plc shares by NatWest Group plc
from UK Government Investments
Limited (‘UKGI’) in March 2021, sales of
NatWest Group plc shares by UKGI by
accelerated bookbuild in May 2021
and
purchases made under NatWest Group
plc’s on-market buyback program
me
announced in July 2021, as at 11
February 2022, the UK Government held
50.94% of the issued share capital with
voting rights of NatWest Group plc. In
addition to the £750 million on-market
buyback announced on 18 February
2022, NatWest Group may participate in
further directed or on-market buybacks
in the future.
The timing, extent and
continuation of UKGI’s sell-dow
ns is
uncertain, which could result in a
prolonged period of increased price
volatility on NatWest Group plc’
s
ordinary shares.
Any offers or sales of a substantial
number of ordinary shares by UKGI,
market expectations about these
sales
and any associated directed, o
n or off
market buyback activity by NatWest
Group, could affect the prevailing market
price for the outstanding ordinary shares
of NatWest Group plc.
HM Treasury has indicated that it intends
to respect the commercial decisions of
NatWest Group and that NatWest Group
will continue to have its own
independent board of directors and
management team determining its own
strategy. However, for as long as HM
Treasury remains the NatWest Group
plc’s largest single shareholder, HM
Treasury and UKGI (as manager of HM
Treasury’s shareholding) could e
xercise
a significant degree of influence over the
election of directors and appointment of
senior management, NatWest Group’s
capital strategy, dividend policy,
remuneration policy or the conduct of
NatWest Group’s operations, amongst
others. HM Treasury or UKGI’s app
roach
depends on government policy, which
could change. The manner in which HM
Treasury or UKGI exercises HM
Treasury’s rights as the largest
single
shareholder could give rise to conflicts
between the interests of HM Treasury
and the interests of other shareholders,
including as a result of a chang
e in
government policy.
Strategic risk
NatWest Group continues to implement
its purpose-led strategy, which carries
significant execution and operational
risks and may not achieve its stated aims
and targeted outcomes.
In February 2020, NatWest Gro
up
announced a new strategy, focuse
d on
becoming a purpose-led busine
ss,
designed to champion potential and to
help individuals, families and busi
nesses
to thrive. This strategy is intende
d to
reflect the rapidly shifting environment
and backdrop of unprecedente
d
disruption in society driven by
technology and changing customer
expectations, as accelerated by the
COVID-19 pandemic. The purpose-led
strategy has required an internal cultural
shift across NatWest Group as to how
performance is perceived and how
NatWest Group conducts its bus
iness.
These changes are substantial and will
take many years to fully embed. Thes
e
changes may not result in the expected
outcome within the timeline and in the
manner currently contemplated.
As part of its purpose-led strategy,
NatWest Group has set a numb
er of
financial, capital and operational targets
and expectations, both for the s
hort term
and throughout the implementation
period. Meeting these targets and
expectations requires further significant
reductions to NatWest Group’s cost base.
Realising these cost reductions may
result in material strategic costs
, which
may be more than currently expected.
The continued focus on meeting cost
reduction targets may also mean limited
investment in other areas, which could
affect NatWest Group’s long-te
rm
prospects, product offering or
competitive position, its ability to meet its
other targets and commitments
(including those related to customer
satisfaction) and its capacity to respond
to climate-related risks.
Risk factors c
ontinued
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Additional information
Financial review
NatWest Group’s ability to meet its
planned reductions in its annual
underlying costs may vary considerably
from year to year. Any of the factors
above could jeopardise NatWest Group’s
ability to achieve its associated financial
targets and generate sustainable returns.
The financial services industry is
currently experiencing a trend towards
consolidation and technological
advancement and disruption. In
pursuing
its purpose-led strategy, NatWe
st Group
may decide to undertake divestments,
restructurings or reorganisations of
certain of its customer segments.
Conversely, it may decide to grow its
business through acquisitions, j
oint
ventures, investments and/or strategic
partnerships as well as other
transactions and initiatives, in certain
customer segments and including to: (i)
enhance capabilities that may lead to
better productivity or cost efficiencies
; (ii)
acquire talent; (iii) pursue new products
or expand existing products; or (iv) enter
new markets or enhance its pres
ence in
existing markets. There are risks that
NatWest Group may not fully realise
the
expected benefits and value from these
transactions and initiatives. In particula
r,
NatWest Group may: (i) fail to realise
the
business rationale for the transaction or
initiative, or assumptions underlying the
business plans supporting the valuation
of a target business may prove
inaccurate, for example, synergies and
expected commercial demand; (ii) fail to
successfully integrate any acquired
businesses (including in respect of
technologies, existing strategies,
products and human capital); (iii) fail to
retain key employees, customers and
suppliers of any acquired busines
s; (iv)
be required or wish to terminate pre-
existing contractual relationships, which
could prove costly and/or be execu
ted at
unfavourable terms and conditions; (v)
fail to discover certain contingent o
r
undisclosed liabilities in business
es that it
acquires, or its due diligence to discover
any such liabilities may be inad
equate;
and (vi) not obtain necessary re
gulatory
and other approvals or onerous
conditions may be attached to
such
approvals. Accordingly, NatWest Group
may not be successful in growi
ng its
business through these types of
transactions and initiatives and any
particular transaction may not s
ucceed,
may be limited in scope or scale
(including due to NatWest Group’s
current ownership structure) and may
not conclude on the terms conte
mplated,
or at all. Any of the above may
materially and adversely affect NatWest
Group’s results of operations, financial
condition or prospects.
NatWest Group’s phased withdrawal
from ROI continues to present significant
commercial, operational, legal and
execution risks. In particular, th
e phased
withdrawal from ROI involves transfers
of business, assets and liabilities to third
parties, and entails many risks, the most
significant of which include: (i)
anticipated reductions in net income,
total lending and RWAs; (ii) pote
ntial
trapped or stranded capital; (iii)
the
diversion of management resources
and
attention away from day-to-day
management; (iv) the recognition of
disposal losses as part of the orderly run-
down of certain loan portfolios which
may be higher than anticipated; (v)
execution risks arising from the
significant uncertainties of a phased
withdrawal, including the additional IT
and operational expense and re
source
required to mitigate manual and limite
d
customer switching and handling
processes of Ulster Bank Ireland DAC,
potential counterparties and ot
her banks;
(vi) customer action or inaction, or the
inability to obtain necessary approvals
and/or support from governmental
authorities, regulators, trade unions
and/or other stakeholders resulting in
additional cost, resource and delays; (vii)
potential loss of customers, resulting in
retail and commercial deposit ou
tflows
(or a failure to attract deposit inflows)
and reduced revenues and liqui
dity; (viii)
increased people risk through the
potential loss of key colleagues and
institutional knowledge and increased
challenges of attracting and retaining
colleagues; (ix) regulatory risk, including
in relation to prudential, conduct and
other regulatory requirements; (x) no or
limited access to Euro system funding
arrangements; and (xi) brand and
reputational risks due to press
speculation and stakeholder scrutiny
about the phased withdrawal from ROI.
Any of these risks and uncertainties may
cost more, be more complex or harder
to mitigate than currently estimated and
may adversely affect NatWest Group’s
ability to execute a phased withdrawal
from ROI, or may affect the financial
performance of NatWest Group.
On 27 January 2022, NatWest Group
announced that, in order to further
support its customers’ growth ambitions
and deliver on the next phase
of its
strategy, it is evolving its Commercial,
NatWest Markets and RBS Inter
national
businesses to form a single franchise to
best support its customers across
the full
non-personal customer lifecycle. T
he
transition is expected to begin over the
coming months and be effe
ctive from
July 2022.
In pursuing its strategy, NatWest Group
may not be able to successfully: (i)
implement all aspects of its strategy; (ii)
reach any or all of the related targets or
expectations of its strategy; or (iii) realise
the intended strategic objectives of any
other future strategic or growth initi
ative.
The scale and scope of its strategy and
the intended changes continue
to
present material business, operational
(including compliance with the
UK ring-
fencing regime), legal, execution, IT
system, internal culture, conduct and
people risks to NatWest Group.
Implementing many changes and
strategic actions concurrently, including
in respect of any growth initiatives, will
require application of robust go
vernance
and controls frameworks and r
obust IT
systems; there is a risk that Nat
West
Group may not be successfu
l in these
respects. The implementation of
the
purpose-led strategy and any other
strategic initiatives could result in
materially higher costs than initially
contemplated (including due to material
uncertainties and factors outside of
NatWest Group’s control) and may not
be completed as planned, or at all, or
could be phased or could progres
s in a
manner other than currently expected.
This could lead to additional
management actions by NatWest Group.
Changes in the economic, politic
al and
regulatory environment in whic
h
NatWest Group operates, or regulatory
uncertainty and changes, stron
g market
competition and industry disruption o
r
economic volatility may require NatWest
Group to adjust aspects of its strategy or
the timeframe for its implementation
including in relation to its financial,
capital and operational targets and
expectations. As certain initiatives
depend on achieving growth in new
ventures and opportunities for NatWest
Group, its strategy is vulnerable to an
economic downturn. NatWest Group’s
strategy also requires ongoing
confidence from customers and the
wider market, without which c
ustomer
activity and related income leve
ls may
fall or NatWest Group’s reputation may
be adversely affected.
Each of these risks, and others identified
in these Risk Factors, individually or
collectively could jeopardise the
implementation and delivery of the
purpose-led strategy and other
strategic
initiatives, result in higher than expected
costs, impact NatWest Group’s products
and services offering, its reputation with
customers or business model and
adversely impact NatWest Group’s ability
to deliver its strategy and meet its
targets and guidance, each of which
could have a negative impact on
NatWest Group.
Additional
information
Risk factors c
ontinued
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NatWest Group continues to refocu
s its
NWM franchise, which entails material
execution, commercial and operational
risks and the intended benefits for
NatWest Group may not be realis
ed
within the timeline and in the manner
currently contemplated.
Over the past few years, as part of i
ts
purpose-led strategy, NatWest Group
has sought to implement a more
strategically congruent and economically
sustainable model for its NWM franchise.
As part of this, NatWest Group
has been
refocusing the NWM franchise to
principally serve NatWest Group’s
corporate and institutional customer
base. This requires NWM Group to
simplify its operating model and
technology platform, as well as
reduce
its cost base and capital requirements.
NWM Group has also directed resources
to emphasising and growing pr
oduct
capability in the areas of impor
tance to
NatWest Group’s corporate and
institutional customers, includin
g the
Fixed Income and Capital Markets
businesses, and has refocused i
ts Rates
business to best serve its core
customers.
In addition, to improve efficie
ncies and
best serve customers following B
rexit,
NatWest Group expects that certain
assets, liabilities, transactions and
activities of its Western European
corporate portfolio (principally including
term funding and revolving credit
facilities), will be transferred from the
ring-fenced subgroup of NatWest Group
to NWM Group on a rolling basis, su
bject
to certain regulatory and customer
requirements. The timing and quantum
of these transfers remain uncertain as is
the impact of these transaction
s on its
go-forward results of operations. A
s a
result, NatWest Group’s business
, results
of operations, financial position and
prospects could be adversely affe
cted.
NatWest Group’s ability to serve its
customers may be diminished by
the
changed business strategy, as
a result of
the NWM Refocusing. In addition,
customer reactions to the changed
nature of NWM Group’s business
model
may be more adverse than expected and
previously anticipated revenue and
profitability levels may not be a
chieved in
the timescale envisaged or at all. A
n
adverse macroeconomic environment
(including due to the COVID-19
pandemic, heightened inflation
and rising
interest rates), continued political and
regulatory uncertainty, market volatility
and/or strong market competition may
also pose significant challenges to the
achievement of the anticipated ta
rgets
and goals of the NWM Refocusing.
The implementation of the NWM
Refocusing has been a complex process
and although substantial progress has
been made, the risk remains that this
strategy may not result in the
contemplated business outcome
and
there continue to be material execu
tion,
commercial and operational risks in
connection with the NWM Refocusing.
There may continue to be material
execution, commercial and operational
risks for NWM Group and NWM Group
may continue to be subject to s
ignificant
structural and other change. The
re can
be no certainty that the NWM Refocus
ing
will be successful or that NWM
Group
will be a viable, competitive or profitable
business. The intended benefits for
NatWest Group may not be realis
ed
within the timeline and in the manner
currently contemplated.
Trends relating to the COVID-1
9
pandemic may adversely affect
NatWest
Group’s strategy and impair its ability
to
meet its targets and strategic objectives.
The trajectory of the COVID-19
pandemic’s impact on the UK a
nd global
economy and NatWest Group r
emains
uncertain. If trends relating to t
he
COVID-19 pandemic negatively
impact
the UK and global economy, NatWest
Group’s may be unable to meet i
ts
financial, capital and operational targets
and expectations. In addition, t
he
COVID-19 pandemic has, at times,
caused significant market volatility,
which could cause RWA inflation for
NatWest Group. This could impair
NatWest Group’s ability to timel
y deliver
on certain aspects of its purpose-led
strategy, which may have an adverse
effect on NatWest Group’s business
,
results of operations and outlook. Se
e
also, ‘
NatWest Group continues
to
implement its purpose-led strategy, which
carries significant execution and
operational risks and may not achieve it
s
stated aims and targeted outcomes
’.
It is uncertain as to how the broader
macroeconomic business envir
onment
and societal norms may be impacted by
the COVID-19 pandemic, causing
significant wider societal changes. For
example, one of the most notable e
ffects
of the COVID-19 pandemic has
been its
disproportionate impact on the most
vulnerable groups of society an
d
concerns about systemic racial biases
and social inequalities.
In addition, the COVID-19 pand
emic has
accelerated existing economic
trends
that may radically change the way
businesses are run and people live
their
lives. These trends include digitalisation,
decarbonisation, automation, e-
commerce and agile working, e
ach of
which has resulted in significant market
volatility in asset prices. There is also
increased investor, regulatory and
customer scrutiny regarding how
businesses address these changes
and
related climate, environmental, s
ocial,
governance and other sustainability
issues, including tackling inequality,
working conditions, workplace health,
safety and wellbeing, diversity and
inclusion, data protection and
management, workforce management,
human rights and supply chain
management. Any failure or delay by
NatWest Group to successfully
adapt its
business strategy and to establish and
maintain effective governance,
procedures, systems and controls in
response to these changes, and to
manage emerging climate,
environmental, social, governa
nce and
other sustainability-related risks and
opportunities, may have a material
adverse impact on NatWest Group’s
reputation, business, results of
operations, outlook and the value
of
NatWest Group’s securities. See also,
Any failure by NatWest Group to
implement effective and compliant
climate change resilient systems, controls
and procedures could adversely affect
NatWest Group’s ability to mana
ge
climate-related risks
’ and ‘
A failure to
adapt NatWest Group’s business
strategy, governance, procedur
es,
systems and controls to manage
emerging sustainability-related risks and
opportunities may have a material
adverse effect on NatWest Group, its
reputation, business, results of operations
and outlook
’.
The COVID-19 pandemic may also result
in unexpected developments or c
hanges
in financial markets, the fiscal, tax and
regulatory frameworks and cons
umer
customer and corporate client be
haviour,
which could intensify competition in the
financial services industry. This could
negatively impact NatWest Group if
it is
not able to adapt or compete eff
ectively.
Financial resilience risk
NatWest Group may not meet the targets
it communicates or be in a position to
continue to make discretionary c
apital
distributions (including dividends to
shareholders).
As part of NatWest Group’s strategy,
NatWest Group has set a numb
er of
financial, capital and operational targets
for NatWest Group including in respect
of: CET1 ratio targets, MREL targets,
return on tangible equity (‘ROTE’),
funding plans and requirements,
employee engagement, diversit
y and
inclusion as well as ESG (includ
ing
climate and sustainable funding and
financing targets) and custome
r
satisfaction targets and discretiona
ry
capital distributions (including dividends
to shareholders).
See also, ‘
NatWest Group continues to
implement its purpose-led strategy, which
carries significant execution and
Risk factors c
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operational risks and may not achieve it
s
stated aims and targeted outcomes
’.
NatWest Group’s ability to meet its
targets and to successfully mee
t its
strategy is subject to various internal and
external factors and risks. These i
nclude
but are not limited to: the impa
ct of the
COVID-19 pandemic, market, regulatory,
macroeconomic and political
uncertainties, operational risks and risks
relating to NatWest Group’s busine
ss
model and strategy (including ris
ks
associated with climate, environmental,
social, governance and other
sustainability-related issues) and
litigation, governmental actions
,
investigations and regulatory matters.
A number of factors, including the
economic and other effects of the
COVID-19 pandemic, may impact
NatWest Group’s ability to maintain its
CET1 ratio target and make
discretionary capital distributions. See
also, ‘
NatWest Group may not meet the
prudential regulatory requirements for
capital and MREL, or manage it
s capital
effectively, which could trigger the
execution of certain management actions
or recovery options
’.
There is a risk that NatWest Group may
not meet its targets and expectations or
be in a position to continue to distribute
capital, or that NatWest Group
will be a
viable, competitive or profitable
banking
business.
NatWest Group operates in markets that
are highly competitive, with increasing
competitive pressures and technology
disruption.
The markets within which NatWe
st
Group operates are highly competitive.
NatWest Group expects such competition
to continue and intensify in response to
various changes. These include: e
volving
customer behaviour, technological
changes (including digital currencie
s,
stablecoins and the growth of digital
banking, such as from fintech e
ntrants),
competitor behaviour, new entrants to
the market (including non-traditional
financial services providers such as large
retail or technology conglomerates, who
may have competitive advantages in
scale, technology and customer
engagement), competitive forei
gn-
exchange offerings, industry trends
resulting in increased disaggregation or
unbundling of financial services or
conversely the re-intermediation of
traditional banking services, and the
impact of regulatory actions and other
factors. In particular, developments in
the financial sector resulting from new
banking, lending and payment
solutions
offered by rapidly evolving incumbents,
challengers and new entrants, notably
with respect to payment service
s and
products, and the introduction of
disruptive technology may impe
de
NatWest Group’s ability to grow or ret
ain
its share and impact its revenues and
profitability, particularly in its ke
y UK
retail and commercial banking segments.
Moreover, innovations such as
biometrics, artificial intelligence, the
cloud, blockchain, cryptocurren
cies and
quantum computing may rapidly
facilitate industry transformatio
n.
These trends have accelerated during
the COVID-19 pandemic and may be
catalysed by various regulatory and
competition policy interventions,
including the UK initiative on Open
Banking (PSD2), Open Finance and other
remedies imposed by the Competition
and Markets Authority (CMA) which are
designed to further promote competition
within retail banking. The competition
enhancing measures under NatWest
Group’s independently administe
red
Alternative Remedies Package
(‘ARP’)
benefits grant recipients and eligible
competitors. The ARP may be
more
costly than anticipated and ma
y
adversely impact customer service for
NatWest Group’s own customers, its
competitive position and reputation.
Failure to comply with the terms of
the
scheme could result in the imposition of
additional measures or limitations on
NatWest Group’s operations, additional
supervision by NatWest Group’s
regulators, and loss of investor
confidence.
Increasingly many of the products and
services offered by NatWest Group a
re,
and will become, more technology
intensive. For example, NatWest Group
recently invested in a number of
fintech
ventures, including Mettle, Free
Agent,
Tyl, Rapid Cash and Rooster Money. Se
e
also, ‘
NatWest Group continues
to
implement its purpose-led strategy, which
carries significant execution and
operational risks and may not achieve it
s
stated aims and targeted outcomes
’.
NatWest Group’s ability to develop such
digital solutions (which also need to
comply with applicable and evolving
regulations) has become increasingly
important to retaining and growing
NatWest Group’s customer busi
ness in
the UK. There can be no certainty that
NatWest Group’s innovation strategy
(which includes investment in its
IT
capability intended to address the
material increase in customer us
e of
online and mobile technology for banking
as well as selective acquisitions, which
carry associated risks) will be s
uccessful
or that it will allow NatWest Group to
continue to grow such services in the
future. Certain of NatWest Group’s
current or future competitors may be
more successful in implementing
innovative technologies for delivering
products or services to their customers.
NatWest Group may also fail to identify
future opportunities or derive bene
fits
from disruptive technologies in the
context of rapid technological innovation,
changing customer behaviour and
growing regulatory demands, r
esulting in
increased competition from traditional
banking businesses as well as new
providers of financial services, including
technology companies with strong b
rand
recognition, that may be able to develop
financial services at a lower cost base.
NatWest Group’s competitors may also
be better able to attract and retain
customers and key employees, may have
better IT systems, and may have
access
to lower cost funding and/or be able to
attract deposits on more favourable
terms than NatWest
Group. Although
NatWest Group invests in new
technologies and participates in industry
and research led initiatives aimed at
developing new technologies, su
ch
investments may be insufficient
or
ineffective, especially given NatWest
Group’s focus on its cost savin
gs targets.
This may limit additional investment in
areas such as financial innovation and
could therefore affect NatWest Group’s
offering of innovative products
or
technologies fo
r delivering products or
services to customers and its competitive
position. Furthermore, the development
of innovative products depends on
NatWest Group’s ability to produce
underlying high-quality data, fa
iling
which its ability to offer innovative
products may be compromised.
If NatWest Group is unable to off
er
competitive, attractive and innovative
products that are also profitable and
timely, it will lose share, incur losse
s on
some or all of its activities and l
ose
opportunities for growth. In this
context,
NatWest Group is investing in the
automation of certain solutions
and
interactions within its customer-facing
businesses, including through artificial
intelligence. Such initiatives may
result in
operational, reputational and conduct
risks if the technology used is de
fective,
inadequate or is not fully integr
ated into
NatWest Group’s current solutions. There
can be no certainty that such initiatives
will deliver the expected cost savings
and investment in automated processes
will likely also result in increased short-
term costs for NatWest
Group.
In addition, the implementation of
its
purpose-led strategy (including
in
relation to acquisitions, reorganisations
and/or partnerships), delivery on its
climate ambition, cost-reduction
measures, as well as employee
remuneration constraints, may also have
an impact on its ability to compete
effectively and intensified compe
tition
from incumbents, challengers and new
entrants could affect NatWest Group’s
Risk factors c
ontinued
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Additional information
Financial review
ability to maintain satisfactory re
turns.
Moreover, activist investors have
increasingly become engaged and
interventionist in recent years, which
may pose a threat to NatWest Group’s
strategic initiatives. Furthermore,
continued consolidation or technological
or other developments in certain sectors
of the financial services industry could
result in NatWest Group’s remaining
competitors gaining greater ca
pital and
other resources, including the ability to
offer a broader range of products and
services and geographic diversity, or the
emergence of new competitors
.
The impact of the COVID-19 pa
ndemic
on the credit quality of NatWest
Group’s
counterparties may negatively impact
NatWest Group.
The effects of the COVID-19 pandemic
have adversely affected the credit quality
of some of NatWest Group’s borrowers
and other counterparties, and
government support schemes may delay
the effects of defaults by such
counterparties. As government support
schemes reduce, defaults are expected
to rise with more customers moving from
IFRS 9 Stage 2 to Stage 3. As a
result,
NatWest Group continues to experience
elevated exposure to credit risk and
demands on its funding, and the long-
term effects remain uncertain. If
borrowers or other counterpartie
s face
increasing levels of debt and d
efault or
suffer deterioration in credit, this would
increase impairment charges, write-
downs, regulatory expected loss and
impact credit reserves. See also,
NatWest Group has significant exp
osure
to counterparty and borrower risk
an
d
‘NatWest Group’s financial statements
are sensitive to the underlying accounting
policies, judgments, estimates and
assumptions’.
In line with certain mandated COVID-19
pandemic support schemes, NatWest
Group has sought to assist affected
customers with a number of initiatives
including NatWest Group’s par
ticipation
in BBLS, CBILS and CLBILS pro
ducts.
NatWest Group has sought to
manage
the risks of fraud and money laundering
against the need for the fast and eff
icient
release of funds to customers and
businesses. NatWest Group may
be
exposed to fraud, conduct and litigation
risks arising from inappropriate approval
(or denial) of BBLS or CBILS or
the
enforcing or pursuing repayme
nt of
BBLS and CBILS (or a failure to e
xercise
forbearance), which may have an
adverse effect on NatWest Group’s
reputation and results of opera
tions. The
implementation of the initiatives and
efforts mentioned above may re
sult in
litigation, regulatory and government
actions and proceedings. These actions
may result in judgments, settlements,
penalties or fines.
Any of the above may have a negative
impact on NatWest Group.
NatWest Group has significant exposure
to counterparty and borrower risk
.
NatWest Group has exposure to many
different industries, customers and
counterparties, and risks arising from
actual or perceived changes in credit
quality and the recoverability of monies
due from borrowers and other
counterparties are inherent in a wide
range of NatWest Group’s busine
sses.
NatWest Group’s lending strategy
and
associated processes may fail to identify
or anticipate weaknesses or risks in a
particular
sector, market or borrower, or
fail to adequately value physica
l or
financial collateral. This may result in
increased default rates or a higher loss
given default for loans, which may, in
turn, impact NatWest Group’s
profitability. See also, ‘
Risk and capital
management — Credit Risk
’.
The credit quality of NatWest Group’s
borrowers and other counterparties may
be affected by a deterioration in
prevailing economic and marke
t
conditions (including those cause
d by the
COVID-19 pandemic) and by the
legal
and regulatory landscape in the
UK and
countries where NatWest Grou
p is
exposed to credit risk and any
deterioration in such conditions or
changes to legal or regulatory
landscapes (including the extent of the
UK’s post-Brexit divergence from EU
laws and regulation). These cou
ld
worsen borrower and counterparty
credit quality or impact the enforcement
of contractual rights over security,
increasing credit risk.
An increase in drawings upon committed
credit facilities may also increase
NatWest Group’s RWAs. In addition, the
level of household indebtedness
in the
UK remains high. The ability of
households to service their debts could
be worsened by a period of high
unemployment (including as a re
sult of
the COVID-19 pandemic), increasing
interest rates and higher inflation,
particularly if prolonged. NatWe
st Group
may be affected by volatility in property
prices (including as a result of the
general UK political or economic cl
imate
or the COVID-19 pandemic) give
n that
NatWest Group’s mortgage loan and
wholesale property loan portfolios as at
31 December 2021, amounted to £
226.5
billion, representing 61%
of NatWest
Group’s total customer loan exposure. If
property prices were to weaken this
could lead to higher impairmen
t charges,
particularly if default rates also increase.
In addition,
NatWest Group’s c
redit risk
may be exacerbated if the collateral that
it holds cannot be realised as a
result of
market conditions or regulatory
intervention or if it is liquidated at prices
not sufficient to recover the net amou
nt
after accounting for any IFRS 9
provisions already made. This is most
likely to occur during periods of illiquidity
or depressed asset valuations.
Concerns about, or a default by
, a
financial institution could lead to
significant liquidity problems and loss
es
or defaults by other financial institutions,
since the commercial and financial
soundness of many financial institutions
is closely related and interdependent as
a result of credit, trading, clearing and
other relationships. Any perceived lack
of creditworthiness of a counterparty
may lead to market-wide liquidity
problems and losses for NatWest Group.
This systemic risk may also adve
rsely
affect financial intermediaries, suc
h as
clearing agencies, clearing hous
es,
banks, securities firms and exchanges
with which NatWest Group inte
racts on a
daily basis. See also, ‘
NatWest Group
may not be able to adequately access
sources of liquidity and funding
’.
As a result, adverse changes in borrower
and counterparty credit risk may cause
accelerated impairment charges under
IFRS 9, increased repurchase demands,
higher costs, additional write-downs and
losses for NatWest Group and an inability
to engage in routine funding
transactions.
NatWest Group has applied an internal
analysis of multiple economic s
cenarios
(MES) together with the determi
nation of
specific overlay adjustments to
inform its
IFRS 9 ECL (Expected Credit L
oss). The
recognition and measurement of ECL is
complex and involves the use of
significant judgment and estimation. This
includes the formulation and
incorporation of multiple forward-looking
economic scenarios into ECL to meet the
measurement objective of IFRS 9. T
he
ECL provision is sensitive to the
model
inputs and economic assumptions
underlying the estimate. Going
forward,
NatWest Group anticipates obs
ervable
credit deterioration of a proportion of
assets resulting in a systematic
uplift in
defaults, which is mitigated by t
hose
economic assumption scenarios being
reflected in the Stage 2 ECL across
portfolios, along with a combination of
post model overlays in both wholes
ale
and retail portfolios reflecting the
uncertainty of credit outcomes. See also,
Risk and capital management
’. A credit
deterioration would also lead to RWA
increases. Furthermore, the ass
umptions
and judgments used in the MES
and ECL
assessment at 31 December 2021
may
not prove to be adequate resulting in
incremental ECL provisions for NatWest
Group. As government support s
chemes
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Additional information
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reduce, defaults are expected to rise
with more ECLs cases moving from
Stage 2 to Stage
3.
NatWest Group is exposed to the
financial industry, including sovereign
debt securities, banks, financial
intermediation providers (including
providing facilities to financial sponsors
and funds, backed by assets or investor
commitments) and securitised products
(typically senior lending to special
purpose vehicles backed by pools of
financial assets). Due to NatWest Group’s
exposure to the financial industry, it also
has exposure to shadow banking enti
ties
(i.e., entities which carry out ba
nking
activities outside a regulated
framework). NatWest Group is
required
to identify and monitor its expo
sure to
shadow banking entities, imple
ment and
maintain an internal framewor
k for the
identification, management, control and
mitigation of the risks associate
d with
exposure to shadow banking e
ntities,
and ensure effective reporting and
governance in respect of such exposure.
If NatWest Group is unable to properly
identify and monitor its shadow
banking
exposure, maintain an adequate
framework, or ensure effec
tive reporting
and governance in respect of shadow
banking exposure, this may adversely
affect the business, results of operations
and outlook of NatWest Group.
If NatWest Group experiences loss
es and
a reduction in future profitabilit
y, this is
likely to affect the recoverable value of
fixed assets, including goodwill and
deferred taxes, which may lead to
further write-downs.
NatWest Group may not meet the
prudential regulatory requirements for
capital and MREL, or manage its capital
effectively, which could trigger the
execution of certain manageme
nt
actions or recovery options
.
NatWest Group is required by regulators
in the UK, the EU and other juri
sdictions
in which it undertakes regulate
d
activities to maintain adequate financial
resources. Adequate capital provides
NatWest Group with financial flexibility in
the face of turbulence and uncertainty in
the global economy and specifically in its
core UK operations. It also permits
NatWest Group plc to make discretionary
capital distributions (including dividends
to shareholders).
As at 31 December 2021, NatWest Group
plc’s CET1 ratio was 18.2% and N
atWest
Group plc currently targets a CET1
ratio
of 13-14% by the end of 2023. NatWest
Group plc’s target capital
ratio is based
on a combination of its expecte
d
regulatory requirements and in
ternal
modelling, including stress scenarios and
management’s and/or the Prude
ntial
Regulatory Authority’s (‘PRA’) vie
ws on
appropriate buffers above mini
mum
operating levels.
NatWest Group plc’s current capital
strategy is based on the expected
accumulation of additional capital
through the accrual of
profits over time,
planned capital actions (including
issuances, redemptions, and
discretionary capital distributions), RWA
growth in the form of regulator
y uplifts
and lending growth and other capital
management initiatives which focus on
improving capital
efficiency and e
nsuring
NatWest Group meets its mediu
m to long
term targets.
A number of factors may impact
NatWest Group plc’s ability to maintain
its current CET1 ratio target an
d achieve
its capital strategy. These include,
amongst other things:
a depletion of its capital resourc
es
through increased costs or liabilities
or reduced profits;
an increase in the quantum of RWAs
in excess of that expected, inclu
ding
due to regulatory changes, o
r a
failure in internal controls or
procedures to accurately measure
and report RWAs;
changes in prudential regulatory
requirements including NatWest
Group plc’s Total Capital
Requirement set by the PRA,
including Pillar 2 requirements and
regulatory buffers as well as any
applicable scalars;
reduced dividends from NatWest
Group’s subsidiaries because of
changes in their financial
performance and/or the extent to
which local capital requirements
exceed NatWest Group plc’s target
ratio; and limitations on the use of
double leverage, i.e. NatWest Group
plc’s use of debt to invest in the
equity of its subsidiaries, as a resu
lt
of the Bank of England’s and/or
NatWest Group’s evolving view
s on
distribution of capital within gr
oups.
A shortage of capital could in turn affect
NatWest Group plc’s capital rati
o, and/or
its ability to make capital distributions.
A minimum level of capital adequacy is
required to be met by NatWest
Group plc
for it to be entitled to make certain
discretionary payments, and institutions
which fail to meet the combined buffe
r
requirement are subject to restricted
discretionary payments. The res
ulting
restrictions are scaled according to the
extent of the breach of the combined
buffer requirement and calculated as a
percentage of the profits of the
institution since the last distribution of
profits or discretionary payment which
gives rise to a maximum distributable
amount (MDA) (if any) that the
financial
institution can distribute through
discretionary payments. Any bre
ach of
the combined buffer requireme
nt, may
necessitate for NatWest Group plc
reducing or ceasing discretiona
ry
payments (including payments of
dividends to shareholders) to th
e extent
of the
breach.
NatWest Group is required to maintain a
set quantum of MREL set as the higher
of its RWAs or leverage requirement. The
Bank of England has identified single
point-of-entry as the preferred resolution
strategy for NatWest Group. As a result,
NatWest Group plc is the only entity tha
t
can externally issue securities that count
towards its MREL requirements, the
proceeds of which can then be
downstreamed to meet the internal
MREL issuance requirements of its
operating
entities and intermediate
holding c
ompanies.
If NatWest Group plc is unable to raise
the requisite amount of regulatory
capital or MREL, downstream the
proceeds of MREL to subsidiarie
s as
required, or to otherwise meet its
regulatory capital, MREL and leverage
requirements, it may be exposed to
increased regulatory supervision or
sanctions, loss of investor confidence,
constrained or more expensive
funding
and be unable to make dividen
d
payments on its ordinary share
s or
maintain discretionary payments on
capital instruments.
If, under a stress scenario, the le
vel of
capital or MREL falls outside of risk
appetite, there are a range of rec
overy
management actions (focused on risk
reduction and mitigation) that
NatWest
Group could take to manage its capital
levels, but any such actions ma
y not be
sufficient to restore adequate capital
levels. Under the EU Bank Recovery and
Resolution Directives I and II (‘BRRD’), as
implemented in the UK, NatWest Group
must maintain a recovery plan
acceptable to its regulator, such that
a
breach of NatWest Group’s app
licable
capital or leverage requirement
s may
trigger the application of NatW
est
Group’s recovery plan to remediate a
deficient capital position. NatWe
st
Group’s regulator may request
that
NatWest Group carry out certain capital
management actions or, if NatWest
Group plc’s CET1 ratio falls below 7%,
certain regulatory capital instru
ments
issued by NatWest Group will be
written-
down or converted into equity and there
may be an issue of additional e
quity by
NatWest Group plc, which could result in
the dilution of the holdings of N
atWest
Group plc’s existing shareholders. The
success of such iss
uances will also be
dependent on favourable market
conditions and NatWest Group may not
be able to raise the amount of c
apital
required on acceptable terms or at all.
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Separately, NatWest Group may address
a shortage of capital by taking action to
reduce leverage exposure and/or RWAs
via asset or business disposals. T
hese
actions may, in turn, affect, among other
things, NatWest Group’s product
offering, credit ratings, ability t
o operate
its businesses, pursue its current
strategies and pursue strategic
opportunities, any of which may aff
ect
the underlying profitability of NatWest
Group and future growth poten
tial. See
also, ‘
NatWest Group may become
subject to the application of UK statutory
stabilisation or resolution powers which
may result in, among other actions, the
cancellation, transfer or dilution of
ordinary shares, or the write-down or
conversion of certain other of NatWest
Group’s securities
’.
NatWest Group is subject to Bank of
England and PRA oversight in r
espect of
resolution, and NatWest Group
could be
adversely affected should the Bank of
England deem NatWest Group’s
preparations to be inadequate.
NatWest Group is subject to regulatory
oversight by the Bank of Engla
nd and
the PRA, and is required (under the PRA
rulebook) to carry out an asses
sment of
its preparations for resolution, s
ubmit a
report of the assessment to the PRA, and
disclose a summary of this rep
ort. The
initial report was submitted to the PRA
on 30 September 2021 and the B
ank of
England’s assessment of NatWest
Group’s preparations is schedule
d to be
released on 10 June 2022 although the
Bank of England may provide fe
edback
before then.
NatWest Group has dedicated significan
t
resources towards the preparation of
NatWest Group for a potential re
solution
scenario. However, if the Bank of
England assessment identifies a
significant gap in NatWest Grou
p’s ability
to achieve the resolvability outcomes, or
reveals that NatWest Group is not
adequately prepared to be resolved, or
did not have adequate plans in place to
meet resolvability requirements which
came into effect on 1 January 20
22,
NatWest Group may be required to take
action to enhance its preparations to be
resolvable, resulting
in additional costs
and the dedication of additional
resources. Such a scenario may
have an
impact on NatWest Group as, depending
on the Bank of England’s assessment,
potential action may include, but is not
limited to, restrictions on NatWe
st
Group’s maximum individual and
aggregate exposures, a requirement to
dispose of specified assets, a
requirement to change legal or
operational structure, a requirement to
cease carrying out certain activities
and/or maintaining a specified amount of
MREL, consequently impacting NatWest
Group’s strategic plans and having an
adverse effect on the financial position
and/or reputation of NatWest Group or a
loss of investor
confidence.
NatWest Group may not be able
to
adequately access sources of liquidity
and funding.
NatWest Group is required to a
ccess
sources of liquidity and funding through
retail and wholesale deposits, as well as
through the debt capital markets. As
at
31 December 2021, NatWest Group plc
held £506.1 billion in deposits. The le
vel
of deposits may fluctuate due to factors
outside NatWest Group’s control, such as
a loss of investor confidence (in
cluding in
individual NatWest Group entitie
s),
sustained low or negative intere
st rates,
government support, increasin
g
competitive pressures for retail and
corporate customer deposits or
the
reduction or cessation of deposits by
wholesale depositors, which could result
in a significant outflow of depos
its within
a short period of time. An inability to
grow or any material decrease in
NatWest Group’s deposits could,
particularly if accompanied by one of the
other factors described above, materially
affect NatWest Group’s ability to satisfy
its liquidity or funding needs. In turn, this
could require NatWest Group to adapt its
funding plans.
The effects of the COVID-19 pandemic,
current economic uncertainties and any
significant market volatility could affect
NatWest Group’s ability to access
sources of liquidity and funding, which
may result in higher funding costs and
failure to comply with regulator
y capital,
funding and leverage requireme
nts.
As a
result, NatWest Group and its
subsidiaries could be required to adapt
their funding plans.
This could
exacerbate funding and liquidity risk,
which could have a negative ef
fect on
NatWest Group.
As at 31 December 2021, NatWest Group
plc’s liquidity coverage ratio was 1
72%. If
its liquidity position were to come under
stress, and if NatWest Group plc we
re
unable to raise funds through deposits or
in the debt capital markets on
acceptable terms or at all, its li
quidity
position could be adversely affe
cted and
it might be unable to meet deposit
withdrawals on demand or at their
contractual maturity, to repay
borrowings as they mature, to meet its
obligations under committed fin
ancing
facilities, to comply with regulatory
funding requirements, to undertake
certain capital and/or debt management
activities, or to fund new loans,
investments and businesses. NatWest
Group may need to liquidate
unencumbered assets to meet its
liabilities, including disposals of assets
not previously identified for disposal to
reduce its funding commitment
s or
trigger the execution of certain
management actions or recovery
options. In a time of reduced liq
uidity,
NatWest Group may be unable to sell
some of its assets, or may need to sell
assets at depressed prices, which in
either case could negatively aff
ect
NatWest Group’s
results.
Any reduction in the credit rating and/or
outlooks assigned to NatWest Group plc,
any of its subsidiaries or any of their
respective debt securities could
adversely affect the availability of
funding for NatWest Group, reduce
NatWest Group’s liquidity position and
increase the cost of funding.
Rating agencies regularly review
NatWest Group plc and other NatWest
Group entity credit ratings and outlooks,
which could be negatively affected by a
number of factors
that can change over
time, including: the credit rating agency’s
assessment of
NatWest Group’s strategy
and management’s capability; its
financial condition including in respect of
profitability, asset quality, capital,
funding and liquidity; the level of political
support for the industries in which
NatWest Group operates; the
implementation of structural reform; the
legal and regulatory frameworks
applicable to NatWest Group’s legal
structure; business activities and the
rights of its creditors; changes i
n rating
methodologies; changes in the relative
size of the loss-absorbing buffers
protecting bondholders and deposito
rs;
the competitive environment, political
and economic conditions in NatWes
t
Group’s key markets (including the
impact of the COVID-19 pandemic and
any further Scottish independence
referendum); any reduction of the UK’s
sovereign credit rating and ma
rket
uncertainty.
In addition, credit ratings agencie
s are
increasingly taking into accoun
t
sustainability-related factors, including
climate, environmental, social and
governance related risk, as part of the
credit ratings analysis, as are investors in
their investment decisions.
Any reductions in the credit ratings of
NatWest Group plc or of certain other
NatWest Group entities, including, in
particular, downgrades below investment
grade, or a deterioration in the capital
markets’ perception of NatWest Group’s
financial resilience could significantly
affect NatWest Group’s access to money
markets, reduce the size of its deposit
base and trigger additional collateral or
other requirements in derivative
s
contracts and other secured funding
arrangements or the need to amend
such arrangements, which coul
d
adversely affect NatWest Group’s (and,
in particular, NatWest Group plc
’s) cost
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of funding and its access to capital
markets and could limit the range of
counterparties willing to enter into
transactions with NatWest Group (and, in
particular, with NatWest Group plc). This
could in turn adversely impact
Nat
West
Group’s competitive position an
d
threaten
its prospects in the short to
medium-term.
NatWest Group may be adversely
affected if it fails to meet the
requirements of regulatory stres
s tests.
NatWest Group is subject to annual
stress tests by its regulator in t
he UK and
is also subject to stress tests by
European regulators with respect to
NWM N.V. and Ulster Bank Ireland DAC.
Stress tests are designed to ass
ess the
resilience of banks to potential
adverse
economic or financial developments and
ensure that they have robust, forward-
looking capital planning processes that
account for the risks associated with
their business profile. If the stress tes
ts
reveal that a bank’s existing regulatory
capital buffers are not sufficient to
absorb the impact of the stress, then it is
possible that the bank will need to take
action to strengthen its capital position.
Failure by NatWest Group to me
et the
quantitative and qualitative requirements
of the stress tests as set forth b
y its UK
regulator or those elsewhere may result
in:
NatW
est Group’s
regulators requiring
NatWest Group to generate additional
capital, reputational damage, increased
supervision and/or regulatory sanctions,
restrictions on capital distributions and
loss of investor confidence.
NatWest Group’s results could be
adversely affected if an event trigge
rs
the recognition of a goodwill impairment.
NatWest Group capitalises goodwill,
which is calculated as the excess
of the
cost of an acquisition over the net fair
value of the identifiable assets,
liabilities
and contingent liabilities acquired.
Acquired goodwill is recognised at cost
less any accumulated impairment losses.
As required by IFRS, NatWest Group
tests goodwill for impairment at least
annually, or more frequently when
events or circumstances indicate that it
might be impaired.
An impairment test compares the
recoverable amount (the higher of the
value in use and fair value less cost to
sell) of an individual cash gener
ating unit
with its carrying value. At 31 De
cember
2021, NatWest Group plc carried
goodwill of £5.5 billion on its balance
sheet. The value in use and fair value of
NatWest Group’s cash-generating units
are affected by market conditio
ns, the
economies in which NatWest Group
operates and may also be affected by
the COVID-19 pandemic.
The goodwill held by NatWest Group plc
relies on management’s assumptions on
future profitability. Goodwill is
particularly sensitive to changes
in
assumed future profitability. If actual
performance were to fall below
management’s forecasts, then there is a
risk that an impairment of goodwill
would become necessary.
Where NatWest Group is required to
recognise a goodwill impairment, it is
recorded in NatWest Group’s income
statement, but it has no effect on
NatWest Group’s regulatory capital
position. Changes in such assumptions
may result in the
ca
rrying bala
nce being
impaired, which could have a negative
impact on NatWest Group.
NatWest Group could incur losses or be
required to maintain higher levels
of
capital as a result of limitations
or failure
of various models.
Given the complexity of NatWest Group’s
business, strategy and capital
requirements, NatWest Group re
lies on
analytical and other models for
a wide
range of purposes, including to manage
its business, assess the value of its assets
and its risk exposure, as well as
to
anticipate capital and funding
requirements (including to facilitate
NatWest Group’s mandated stre
ss
testing). In addition, NatWest Group
utilises models for valuations, credit
approvals, calculation of loan impairment
charges on an IFRS 9 basis, financial
reporting and for financial crime
(criminal activities in the form of
money
laundering, terrorist financing, bribery
and corruption, tax evasion and
sanctions
as well as fraud risk
management
(collectively, ‘financial
crime’)). NatWest Group’s mode
ls, and
the parameters and assumptions on
which they are based, are periodically
reviewed and updated to maximise their
accuracy.
As models analyse scenarios based on
assumed inputs and a conceptual
approach, model outputs theref
ore
remain uncertain. Failure of mo
dels
(including due to errors in model desi
gn)
or new data inputs (including non-
representative data sets), for example, to
accurately reflect changes in the
micro
and macroeconomic environme
nt in
which NatWest Group operates (for
example to account for the impact of the
COVID-19 pandemic), to capture risks
and exposures at the subsidiary
level
and to update for changes to
NatW
est
Group’s current business model or
operations, or for findings of de
ficiencies
by NatWest Group’s regulators (including
as part of NatWest Group’s mandated
stress testing), may render some
business lines uneconomic, result in
increased capital requirements, may
require management action or may
subject NatWest Group to regulatory
sanction. NatWest Group may also face
adverse consequences as a result of
actions based on models that a
re poorly
developed, implemented or used, models
that are based on inaccurate or
compromised data or as a result of the
modelled outcome being misun
derstood,
or by such information being u
sed for
purposes for which it was not de
signed.
NatWest Group’s financial statements
are sensitive to the underlying
accounting policies, judgments, e
stimates
and assumptions.
The preparation of financial statements
requires management to make
judgments, estimates and assumptions
that affect the reported amounts of
assets, liabilities, income, expens
es,
exposures and RWAs. While esti
mates,
judgments and assumptions tak
e into
account historical experience and other
factors, (including market pract
ice and
expectations of future events that are
believed to be reasonable under the
circumstances), actual results may differ
due to the inherent uncertainty in
making estimates, judgments and
assumptions (particularly those involving
the use of complex models).
The accounting policies deemed critical
to NatWest Group’s results and financial
position, based upon materiality
and
significant judgments and estimates,
which include loan impairment
provisions, are set out in
‘Critical
accounting policies and key sources of
estimation uncertainty
’. New ac
counting
standards and interpretations that have
been issued by the International
Accounting Standards Board but which
have not yet been adopted by NatWest
Group are discussed in ‘
Future
accounting developments
’.
Changes in accounting standards may
materially impact NatWest Group’s
financial results.
Changes in accounting standards or
guidance by accounting bodies or in
the
timing of their implementation, whether
immediate or foreseeable, could result in
NatWest Group having to recognise
additional liabilities on its balance
sheet,
or in further write-downs or impairments
to its assets and could also signif
icantly
impact the financial results, condition
and prospects of NatWest Group.
The valuation of financial instruments,
including derivatives, measured at fair
value can be subjective, in particular
where models are used which include
unobservable inputs. Generally, to
establish the fair value of these
instruments, NatWest Group rel
ies on
quoted market prices or, where the
market for a financial instrument is no
t
sufficiently credible, internal valuation
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models that utilise observable market
data. In certain circumstances, the data
for individual financial instruments or
classes of financial instruments utilised
by such valuation models may not be
available or may become unavailable
due to prevailing market conditions. In
these circumstances, NatWest Group’s
internal valuation models require
NatWest Group to make assumptions,
judgments and estimates to establish fai
r
value, which are complex and of
ten
relate to matters that are inher
ently
uncertain.
The value or effectiveness of any c
redit
protection that NatWest Group has
purchased depends on the value of
the
underlying assets and the financial
condition of the insurers and
counterparties.
NatWest Group has some rema
ining
credit exposure arising from over-the-
counter derivative contracts, mainly
credit default swaps (CDSs), and othe
r
credit derivatives, each of which are
carried at fair value. The fair value of
these CDSs, as well as NatWest Group’s
exposure to the risk of default by the
underlying counterparties, dep
ends on
the valuation and the perceived credit
risk of the instrument against which
protection has been bought. Many
market counterparties have be
en
adversely affected by their exposure to
residential mortgage-linked an
d
corporate credit products, whether
synthetic or otherwise, and thei
r actual
and perceived creditworthiness
may
deteriorate rapidly. If the financial
condition of these counterparties
or their
actual or perceived creditworthines
s
deteriorates, NatWest Group may record
further credit valuation adjustm
ents on
the credit protection bought from these
counterparties under the CDSs. NatWest
Group also recognises any fluctuations in
the fair value of other credit de
rivatives.
Any such adjustments or fair value
changes may have a negative i
mpact on
NatWest Group’s results.
NatWest Group may become subject to
the application of UK statutory
stabilisation or resolution powers which
may result in, among other actions, the
cancellation, transfer or dilutio
n of
ordinary shares, or the write-down or
conversion of certain other of NatWest
Group’s securities.
HM Treasury, the Bank of Engl
and and
the PRA and FCA (together, the
‘Authorities’) are granted subst
antial
powers to resolve and stabilise UK-
incorporated financial institutions. Five
stabilisation options exist: (i) transfer of
all of the business of a relevant entity o
r
the shares of the relevant entit
y to a
private
sector pur
chaser; (ii) tr
ansfer of
all or part of the business of the relevant
entity to a ‘bridge bank’ wholly-owned
by the Bank of
England; (iii) transfer of
part of the assets, rights or liabilities of
the relevant entity to one or more asset
management vehicles for management
of the transferor’s assets, rights or
liabilities; (iv) the write-down, conversion,
transfer, modification, or suspension of
the relevant entity’s equity, capital
instruments and liabilities; and (
v)
temporary public ownership of the
relevant entity. These tools ma
y be
applied to NatWest Group plc as the
parent company or an affiliate where
certain conditions are met (such as,
whether the firm is failing or likely to fail,
or whether it is reasonably likely that
action will be taken (outside of
resolution) that will result in the firm no
longer failing or being likely to f
ail).
Moreover, there are modified insolvency
and administration procedures
for
relevant
entities, and the Authorities
have the power to modify or override
certain contractual arrangements in
certain circumstances and amend the
law for the purpose of enabling their
powers to be used effectively a
nd may
promulgate provisions with retrospective
applicability.
Under the UK Banking Act, the
Authorities are generally requir
ed to
have regard to specified objectives in
exercising the powers provided for by
the Banking Act. One of the obje
ctives
(which is required to be balance
d as
appropriate with the other spe
cified
objectives) refers to the protection and
enhancement of the stability of the
financial system of the UK. Mor
eover, the
‘no creditor worse off’ safeguard
contained in the Banking Act m
ay not
apply in relation to an applicati
on of the
separate write-down and conversion
power relating to capital instruments
under
the Banking Act, in circumstances
where
a stabilisation power is n
ot also
used. Holders of debt instrume
nts which
are subject to the power may, however,
have ordinary shares transferred to or
issued to them by way of compensation.
Uncertainty exists as to how the
Authorities may exercise their
powers
including the determination of actions
undertaken in relation to the ordinary
shares and other securities of NatWest
Group, which may depend on f
actors
outside of NatWest Group’s control.
Moreover, the Banking Act provisions
remain untested in practice.
If NatWest Group is at or is approaching
the point of non-viability such that
regulatory intervention is require
d, any
exercise of the resolution regime powers
by the Authorities may adversely aff
ect
holders of NatWest Group plc’s ordinary
shares or other NatWest Group
securities. This may result in va
rious
actions being undertaken in rel
ation to
NatWest Group and any securities of
NatWest Group, including cancell
ation,
transfer, dilution, write-down or
conversion (as applicable). There may
also be a corresponding adverse e
ffect
on the market price of such securities.
Climate and sustainability-relat
ed risks
NatWest Group and its custome
rs face
significant climate-related risks,
including
in transitioning to a net zero economy,
which may adversely impact NatWest
Group.
Climate-related risks and uncertainties
are continuing to receive increasing
regulatory, judicial, political and societal
scrutiny.
Financial and non-financial risk
s from
climate change arise through p
hysical
and transition risks. Furthermor
e,
NatWest Group may also face a variety
of climate-related legal risks, both
physical and transition, from potential
litigation and conduct liability. Se
e also,
NatWest Group may be subject to
potential climate, environmental and
other sustainability-related litigation,
enforcement proceedings, invest
igations
and conduct risk’
.
There are significant uncertaint
ies as to
the extent and timing of the
manifestation of the physical risks of
climate change, such as more se
vere
and frequent extreme weather events
(flooding, subsidence, heat wave
s and
long-lasting wildfires), rising sea levels,
biodiversity loss and resource scarcity.
Damage to NatWest Group custome
rs’
properties and operations could disrupt
business, impair asset values and
negatively impact the creditworthiness of
customers leading to increased default
rates, delinquencies, write-offs
and
impairment charges in NatWest Group’s
portfolios. In addition, NatWest Group
premises and operations, or thos
e of its
critical outsourced functions may
experience damage or disruption leading
to increased costs and negative
ly
affecting NatWest Group’s business
continuity and reputation.
In October 2021, the UK Government
published its Net Zero Strategy which
sets out how the UK will deliver
on its
commitment to reach net zero emissions
by 2050. The timing, content a
nd
implementation of the specific policies
and proposals remain uncertain.
Widespread transition to a net zero
economy across all sectors of the
economy and markets in which N
atWest
Group operates will be require
d to meet
the goals of the 2015 Paris Agree
ment,
the UK’s Net Zero Strategy and the
Glasgow Climate Pact of 2021. The
impact of the extensive commercial,
technological, policy and regulatory
changes required to achieve transitio
n
remains uncertain, but it is expected to
be significant and may be disruptive
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across the global economy and ma
rkets,
especially if these changes do not occur
in an orderly or timely manner or are
not
effective in reducing emissions
sufficiently. Some sectors such as
property, energy (including oil and gas),
mining, infrastructure, transport
(including automotive and aviation) and
agriculture are expected to be
particularly impacted. The timing and
pace of the transition to a net zero
economy is also uncertain and may be
near term, gradual and orderly or
delayed, rapid and disorderly, or the
combination of these.
Climate-related risks may be drivers of
several different risk categories
simultaneously and may exacerbate
existing risks, including credit risk,
operational risk (business continuity),
market risk (both traded and non-
traded), liquidity and funding risk (f
or
example, net cash outflows or depletion
of liquidity buffers).
If NatWest Group fails to adapt its
business and operating model in a timely
manner to the climate-related ris
ks and
opportunities and changing regulatory
and market expectations, or to
appropriately identify, measure, manage
and mitigate climate change related
physical, transition and legal ris
ks and
opportunities that NatWest Group, its
customers and value chain face,
NatWest Group’s reputation, busines
s,
operations or value chain and resu
lts of
operations and outlook may be impacted
adversely.
NatWest Group’s purpose-led strategy
includes climate change as one of its
three areas of focus. This is likely to
require material changes to the
business
and operating model of NatWe
st Gro
up
which entails significant execution
risk.
In February 2020, NatWest Gro
up
announced its ambition to become a
leading bank on climate in the UK,
helping to address the climate challenge
by setting itself the challenge to at least
halve the climate impact of its f
inancing
activity by 2030 and intending to do
what is necessary to achieve alignment
with the 2015 Paris Agreement. In
addition, in April 2021, NatWest Group
by joining the Net Zero Banking Alliance
'Business Ambition to 1.5C', stated its
ambition to reach net zero by
2050.
Furthermore, a
s part of its e
fforts
to support the transition to a net zero
economy, NatWest Group has
also
announced its ambitions to phase
out of
coal for UK and non UK customers who
have UK coal production, coal fired
generation and coal related
infrastructure
by 1 October 2024, with a
full global phase out by 1 January 2030;
to plan to stop financing new customer
relationships with corporate cus
tomers
who explore for, extract or produce
coal
or operate unabated coal powered
plants; and that it would not provide
services to existing customers who are
increasing coal mining activity by
exploring for new coal, developing new
coal mines or increasing thermal coal
production.
To achieve its 2030 and 2050 a
mbitions,
NatWest Group has also announced
other climate ambitions, targets and
commitments, and going-forward it m
ay
also announce other climate ambitions,
targets and commitments, including
science-based targets to be validated by
the Science Based Target Initia
tive.
Making the changes necessary to
achieving these ambitions may
materially
affect NatWest Group’s business and
operations and will require significant
reductions to its financed emissions and
to its exposure to customers that do no
t
align with a transition to a net zero
economy or do not have a credible
transition plan. Increases in lending and
financing activities may wholly or
partially offset some or all of these
reductions, which may increase the
extent of changes and reductio
ns
necessary. It is anticipated that achieving
these reductions, together with
the
active management of climate-related
risks and other regulatory, policy and
market changes, are likely to nece
ssitate
material and accelerated changes to
NatWest Group’s business, operating
model and existing exposures (potentially
on accelerated timescales and outside of
risk appetite) which may have a material
adverse effect on NatWest Group’s
ability to achieve its financial targets
and
generate sustainable returns.
NatWest Group’s ability to achieve
theses ambitions, targets and
commitments will depend to a large
extent on many factors and uncertainties
beyond NatWest Group’s control. Thes
e
include the macroeconomic en
vironment,
the extent and pace of climate c
hange,
including the timing and manifestation of
physical and transition risks, th
e
effectiveness of actions of governments,
legislators, regulators, businesse
s,
investors, customers and other
stakeholders to adapt and/or mitigate
the impact of climate-related risk
s,
changes in customer behaviour
and
demand, the challenges related with the
implementation and integration of
adoption policy tools, changes in the
available technology for mitigation and
adaptation, the availability of accurate,
verifiable, reliable, consistent and
comparable data.
See also, ‘Na
tWest
Group continues to implement its
purpose-led strategy, which ca
rries
significant execution and operational
risks and may not achieve its stated aims
and targeted outcomes
and ‘
The
re are
significant challenges in relation
to
climate-related data due to quality and
other limitations, lack of standar
disation,
consistency and incompleteness which
amongst other factors contribute to the
significant uncertainties inheren
t in
accurately modelling the impact of
climate-related risks
’.
These internal and external factors and
uncertainties will make it challenging for
NatWest Group to meet its climate
ambitions, targets and commitments and
there is a significant risk that all or some
of them will not be achieved.
Any delay or failure in setting, making
progress against or meeting NatWest
Group’s climate-related ambitio
ns,
targets and commitments may have a
material adverse impact on NatWes
t
Group, its reputation, business, resul
ts of
operations, outlook, market and
competitive position and may increase
the climate-related risks NatWes
t Group
faces.
Any failure by NatWest Group to
implement effective and compliant
climate change resilient systems,
controls and procedures could
adversely
affect
NatWest Group’s ability to manage
climate-related risks.
The prudential regulation of climate-
related risks is an important driver in
how NatWest Group develops its risk
appetite for financing activities or
engaging with counterparties that do not
align with a transition to a net zero
economy or do not have a credible
transition plan.
Legislative and regulatory authorities are
publishing expectations as to how banks
should prudently manage and
transparently disclose climate-related
and environmental risks under prudential
rules.
In April 2019, the PRA published a
supervisory statement (the ‘SS 3
/19’)
with particular focus on the management
of financial risks from climate change
with respect to governance, risk
management, scenario analysis and
disclosures.
Following the submission of initial plans
by UK banks in October 2019, in July
2020 the PRA issued a ‘Dear CEO’ letter
requiring firms to embed fully their
approaches to managing climate-related
financial risks by the end of 2021
. In
response, on 8 October 2020, NatWest
Group provided the PRA with an update
to its original plan noting that the
COVID-19 pandemic had disrupted some
elements of NatWest Group’s origin
al
plan and, as a result, the updated plan
would require additional operating cycles
reaching into 2022 and beyond to prove
embedding. Subsequently the PRA issue
d
its ‘Climate Change Adaptation Re
port’
in October 2021 advising firms of the
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need to continue to refine and innov
ate
ways to further integrate the financial
risks from climate change within risk
management practices and it re
stated
that by the end of 2021, firms s
hould be
able to demonstrate that the
expectations set out in SS3/19 have been
implemented and embedded throughout
the firms’ organisation as fully as
possible. In January 2022, NatWes
t
Group provided the PRA with an update
on how it has addressed the
commitments made in its October 202
0
plan, noting the delivery of a 1st
generation, largely qualitative in nature,
approach to supervisory require
ments.
In June 2021, the Bank of Engla
nd
launched its 2021 Bie
nnial Exploratory
Scenario (‘CBES’) to stress test the
resilience of the current business models
of the largest banks, insurers and the
financial system to the physical and
transition risks from climate ch
ange
under three climate scenarios. NatWest
Group delivered its CBES submiss
ion to
the PRA in October 2021. The Bank of
England has since announced that the
CBES is likely to include a second round
over February and March 2022
, which is
likely to be largely qualitative in nature.
The Bank of England guidance
for the
CBES confirmed that it is exploratory in
nature and not intended to be us
ed to
set capital requirements. In the
aforementioned ‘Climate Change
Adaptation Report 2021’, the Bank of
England confirmed that over the coming
year it will undertake further analysis to
explore enhancements to the r
egulatory
capital frameworks as they relate to
climate related financial risk. To suppo
rt
this work, the Bank of England will put
out a ‘Call for Papers’ and host a
Research Conference on the interaction
between climate change and capital in
Q4 2022. Informed by these ste
ps and
internal analysis, the Bank of England is
expected to publish a follow-up repo
rt on
the use of capital including on the role of
any future scenario exercises by the end
of 2022. It is therefore likely that in the
coming years financial institutions,
including NatWest Group, may be
required to hold additional capital to
enhance their resilience against systemic
and/or institution specific vulnerabilities
to climate-related financial risks, which
could, in turn, negatively impact NatWest
Group.
Any failure of NatWest Group to fully
and
timely embed climate-related risk
s into
its risk management practices and
framework to appropriately identify,
measure, manage and mitigate the
various climate-related physical and
transition risks and apply the appropriate
product governance in line with
applicable legal and regulatory
requirements and expectations, may
have a material and adverse impact on
NatWest Group’s regulatory compliance,
prudential capital requirements, liquidity
position, reputation, business, re
sults of
operations and outlook.
There are significant challenges in
relation to climate-related data due to
quality and other limitations, lack of
standardisation, consistency and
incompleteness which amongst other
factors contribute to the significant
uncertainties inherent in accur
ately
modelling the impact of climate-related
risks.
Meaningful reporting of climate-related
risks and opportunities and their
potential impacts and related metrics
depend on access to accurate, reliable,
consistent and comparable climate-
related data from counterparti
es or
customers. These may not be ge
nerally
available or, if available, may n
ot be
accurate, verifiable, reliable, consistent,
or comparable. Any failure of NatWest
Group to incorporate climate-related
factors into its counterparty and
customer data sourcing and
accompanying analytics, or to
develop
accurate, reliable, consistent and
comparable counterparty and cu
stomer
data, may have a material adve
rse
impact on NatWest Group’s ability to
prepare meaningful reporting of cli
mate-
related risks and opportunities, its
regulatory compliance, reputation,
business and its competitive pos
ition.
In the absence of other sources,
reporting of financed emissions by
financial institutions, including NatWest
Group, is necessarily based therefore on
aggregated information developed by
third parties that may be prepared in an
inconsistent way using different
methodologies, interpretations, or
assumptions. Accordingly, our climate-
related disclosures use a great
er number
and level of assumptions and es
timates
than many of our financial disclosu
res.
These assumptions and estimate
s are
highly likely to change over time
, and,
when coupled with the longer ti
me
frames used in these climate related
disclosures, make any assessment of
materiality inherently uncertain
. In
particular, in the absence of actual
emissions monitoring and measurement,
emissions estimates are based on
industry and other assumptions
that may
not be accurate for a given counterpa
rty
or customer. There may also be data
gaps, particularly for private co
mpanies,
that are filled using proxy data, such as
sectoral averages, again developed in
different ways. As a result, our climate
related disclosures may be ame
nded,
updated or restated in the future
as the
quality and completeness of our data
and methodologies continue to imp
rove.
These data quality challenges, gaps and
limitations could have a material impact
on NatWest Group’s ability to make
effective business decisions about
climate risks and opportunities, including
risk management decisions, comply wi
th
disclosure requirements and our ability
to monitor and report our progress in
meeting our ambitions, targets and
commitments.
Significant risks, uncertainties a
nd
variables are inherent in the asses
sment,
measurement and mitigation of climate-
related risks. These include dat
a quality
gaps and limitations mentioned above,
the pace at which climate science
,
greenhouse gas accounting standards
and various emissions reduction solutions
develop. In addition, there is a significant
uncertainty about how climate c
hange
and the transition to a net zero economy
will unfold over the coming decades an
d
affect how and when climate-re
lated
risks will manifest. These timeframes are
considerably longer than NatW
est
Group’s historical strategic, financial,
resilience and investment planning
horizons.
As a result, it is very difficult to predict
and model the impact of climate
-related
risks into precise financial and e
conomic
outcomes and impacts. Climate-related
risks present significant methodological
challenges due to their forward-looking
nature, the lack and/or quality
of
historical testing capabilities, lack of
standardisation and incomplete
ness of
emissions and other climate and sub-
sector related data and the immature
nature of risk measurement and
modelling methodologies. The evaluation
of climate-related risk exposure and the
development of associated potential risk
mitigation techniques largely de
pend on
the choice of climate scenario modelling
methodology and the assumptions made
which involves a number of risks and
uncertainties, for example
climate scenarios are not predictions
of what is likely to happen or what
NatWest Group would like to happen,
they rather explore the possibl
e
implications of different judgments
and assumptions by considering a
series of scenarios;
climate scenarios do not provid
e a
comprehensive description of all
possible future outcomes;
it requires a special skill set that
banks traditionally do not have and
therefore NatWest Group needs to
rely on third party advice, modelling,
and data which is also subject to
many limitations and uncertaintie
s;
modelling approaches and data on
climate-related risks on financial
assets is immature in nature and it is
expected that techniques and
understanding will evolve rapidly in
the coming
years;
Add
it
io
nal
i
nf
or
mati
on
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it is challenging to benchmark or
back test the climate scenarios given
their forward-looking nature and the
multiple possible outcomes;
there is a significant uncertainty
as to
how the climate will evolve ove
r time,
how and when governments,
regulators, businesses, investors and
customers respond and how those
responses impact the economy,
asset
valuations, land systems, energy
systems, technology, policy and
wider society;
the assumptions will be continually
evolving with more data/inform
ation
which may affect the baselines f
or
comparability across reporting
periods and impact internal and
external verification processes; and
the pace of the development of the
methodologies across different
sectors may be different and
therefore it may be challenging to
report on the whole balance shee
t
with regard to emissions.
Accordingly, these risks and
uncertainties coupled with signific
antly
longer timeframes make the ou
tputs of
climate-related risk modelling, including
emissions reductions targets an
d
pathways, inherently more unc
ertain
than outputs modelled for traditional
financial planning cycles based on
historical financial information.
Capabilities within NatWest Group to
appropriately assess, model and mana
ge
climate-related risks and the su
itability of
the assumptions required to model and
manage climate-related risks
appropriately are developing. Even when
those capabilities are develope
d, the high
level of uncertainty regarding any
assumptions modelled, the highly
subjective nature of risk measurement
and mitigation techniques, incorrect or
inadequate assumptions and judgments
and data quality gaps and limitations
may lead to inadequate risk
management information and
frameworks, or ineffective business
adaptation or mitigation strategies
,
which may have a material adv
erse
impact on NatWest Group’s regulatory
compliance, reputation, business, results
of operations and
outlook.
A failure to adapt NatWest Group’s
business strategy, governance,
procedures, systems and controls to
manage emerging sustainability
-related
risks and opportunities may have a
material adverse effect on NatWest
Group, its reputation, business, resul
ts of
operations and outlook.
Investors, customers, international
organisations, regulators and other
stakeholders are increasingly focusing on
identification, measurement,
management and mitigation of
‘sustainability-related’ risks and
opportunities such as environme
ntal
(including biodiversity and loss of natural
capital); social (including diversity and
inclusion, the living wage, fair taxation
and value chains); and governance
(including board diversity, ethics,
executive compensation and
management structure) related risks and
opportunities and on long term
sustainable value creation.
Financial institutions, including NatWest
Group, are directly and indirectly
exposed to multiple types of
environmental and biodiversity-related
risk through their activities, including risk
of default by clients. Additionally, there is
a growing need to move from
safeguards and interventions th
at focus
on reducing negative impacts on
environment and biodiversity towards
those that focus on increasing positive
impact on environment and bio
diversity
and nature-based solutions. In 202
1,
NatWest Group accordingly classifi
ed
‘Biodiversity and Nature Loss’ as
an
emerging risk for NatWest Group within
its Risk Management Framework. This is
an evolving and complex area which
requires collaborative approaches with
partners, stakeholders and peers to help
measure and mitigate negative i
mpacts
of financing activities on the
environment, biodiversity and n
ature as
well as supporting the growing
sector of
nature-based solutions, habitat
restoration and biodiversity markets.
NatWest Group is in the early stages of
developing its approach and NatWest
Group recognises the need for more
progress.
There is also increased investor,
regulatory and customer scruti
ny
regarding how businesses addre
ss social
issues, including tackling inequality,
working conditions, workplace health,
safety and wellbeing, diversity and
inclusion, data protection and
management, workforce management,
human rights and supply chain
management which may impact NatWest
Group’s employees, customers, and their
business activities or the communities in
which they operate. There is also
growing attention on the need for a 'just
transition' and “energy justice” – in
recognition that the transition to a net
zero economy should not
disproportionally affect the most
disadvantaged members of socie
ty.
The
increased focus on these issues
may
create reputational and other risks
for
financial institutions, including NatWest
Group.
In addition to climate-related risks
,
sustainability-related risks (i) may also
adversely affect economic activity, asset
pricing and valuations of issuers
securities and, in turn, the wider financial
system; (ii) may impact economic
activities directly (for example through
lower corporate profitability or the
devaluation of assets) or indire
ctly (for
example through macro-financial
changes); (iii) may also affect the viabili
ty
or resilience of business models over the
medium to longer term, particu
larly
those business models most vul
nerable
to sustainability-related risks; (iv) can
trigger further losses stemming directly
or indirectly from legal claims (liability
risks) and reputational damage as a
result of the public, customers,
counterparties and/or
investors
associating NatWest Group or its
customers with adverse sustainability-
related issues; and (v) intersect with and
further complexity and challenge to
achieving our purpose-led strategy
including climate ambitions, targets and
commitments.
Together with climate-related ri
sks,
these risks may combine to generate
even greater adverse effe
cts on our
business.
Furthermore, sustainability-related risks
may be drivers of several different risk
categories simultaneously and may
exacerbate the risks described he
rein,
including credit risk, operationa
l risk
(business continuity), market risk (both
traded and non-traded), liquidit
y and
funding risk (for example, net cash
outflows or depletion of liquidity
buffers).
Accordingly, any failure or delay
by
NatWest Group to successfully
adapt its
business strategy and to establish and
maintain effective governance,
procedures, systems and controls in
response to these issues, and to manage
these emerging sustainability-r
elated
risks and opportunities may have a
material adverse impact NatWest
Group’s reputation, liquidity pos
ition,
business, results of operations, outlook
and the value of NatWest Group’s
securities.
Any reduction in the ESG ratin
gs of
NatWest Group could have a negative
impact on NatWest Group’s reputation
and on investors’ risk appetite and
customers’ willingness to deal with
NatWest Group.
ESG ratings from agencies and data
providers which rate how NatWest
Group manages environmental, social
and governance risks are increasingly
influencing investment decisions
or being
used as a basis to label financial
products and services as green or
sustainable. ESG ratings are (i)
unsolicited; (ii) subject to the asses
sment
and interpretation by the ESG rating
agencies; (iii) provided without
warranty;
(iv) not a sponsorship, endorsement, or
promotion of NatWest Group by the
relevant rating agency; and (v) may
depend on many factors some of which
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are beyond NatWest Group’s c
ontrol
(e.g. any change in rating meth
odology).
Any reduction in the ESG ratin
gs of
NatWest Group could have a negative
impact on NatWest Group’s reputation
and could influence investors’ risk
appetite for NatWest Group’s and/or its
subsidiaries’ securities, particularly ESG
securities and could affect a cu
stomer’s
willingness to deal with NatWest Group.
Increasing levels of climate,
environmental and sustainability-related
laws, regulation and oversight may
adversely affect NatWest Group’s
business and expose NatWest Group to
increased costs of compliance,
regulatory sanction and reputational
damage.
There are an increasing number of EU,
UK and other regulatory and legislative
initiatives to address issues around
climate, environmental and sustainability
risks and opportunities and to promote
the transition to a net zero economy. As
a result, an increasing number of laws,
regulations, legislative actions are likely
to affect the financial sector and the real
economy, including proposals, guidance,
policy and regulatory initiatives many of
which have been introduced or
amended
recently and are subject to further
changes.
Many of these initiatives are focuse
d on
developing standardized definitions for
green and sustainable criteria of assets
and liabilities, integrating climat
e change
and sustainability into decision-
making
and customers access to green
and
sustainable financial products and
services which may have a significant
impact on the services provided by
NatWest Group and its subsidiaries,
especially mortgage lending, and its
associated credit, market and financial
risk profile. They could also impact
NatWest Group’s recognition of its
climate and sustainable funding and
financing activity and may adversel
y
affect NatWest Group’s ability to achieve
its climate strategy and climate and
sustainable funding and financing
ambitions.
In addition, NatWest Group and its
subsidiaries are and will be sub
ject to
increasing entity wide climate-re
lated
and other non-financial disclosure
requirements pursuant to the
recommendations of the Task Force on
Climate-related Financial Disclosure
(‘TCFD’) and under other regimes
. From
February 2022, NatWest Group will be
required to provide enhanced cli
mate-
related disclosures consistent with the
TCFD recommendations to comply wi
th
the FCA Policy Statement on the ne
w
Listing Rules (PS 20/17) that require
commercial companies with a UK
premium listing – such as NatWe
st Group
- to make climate related disclos
ures,
consistent with TCFD, on a ‘comply or
explain’ basis. The FCA is proposing to
expand this requirement to a wider
scope of listed issuers which w
ould
include NatWest Group’ subsidiaries as i
t
moves towards mandatory TCFD
reporting across the UK economy by
2025. See also, ‘
There are significant
challenges in relation to climate-related
data due to quality and other limitat
ions,
lack of standardisation, consistency and
incompleteness which amongst other
factors contribute to the signific
ant
uncertainties inherent in accurately
modelling the impact of climate-related
risks
’.
In addition, NatWest Group’s E
U
subsidiaries and branches are
and will
continue to be subject to an increasing
array of the EU/EEA climate and
sustainability-related legal and
regulatory requirements. These
requirements may be used as the
basis
for UK laws and regulations (such as the
UK Green Taxonomy) or
regarded by
investors and regulators as best practice
standards whether or not they apply to
UK businesses. Any divergence between
UK, EU/EEA and US climate and
sustainability-related legal and
regulatory requirements may r
esult in
NatWest Group not meeting inve
stors’
expectations, may increase the cost of
doing business and may restrict access
of NatWest Group’s UK business to the
EU/EEA market.
NatWest Group is also participating in
various voluntary carbon reporting and
other standard setting initiatives f
or
disclosing climate and sustaina
bility-
related information, many of which have
differing objectives and methodologies
and are at different stages of
development in terms of how the
y apply
to financial institutions.
Compliance with these developing and
evolving climate and sustainability-
related requirements is likely to require
NatWest Group to implement significant
changes to its business models, pro
duct
and other governance, internal controls
over financial reporting, disclosure
controls and procedures, modelling
capability and risk management sys
tems,
which may increase the cost of doing
business, entail additional chan
ge risk
and compliance costs.
Failure to implement and comply
with
these legal and regulatory requirements
or emerging best practice expec
tations
may have a material adverse effe
ct on
NatWest Group’s regulatory compliance
and may result in regulatory sanction,
reputational damage and investor
disapproval each of which could have an
adverse effect on NatWest Group’s
business, results of operations and
outlook.
NatWest Group may be subject to
potential climate, environmental and
other sustainability-related litigation,
enforcement proceedings, investigations
and conduct risk.
Due to increasing new climate and
sustainability-related jurisprudence, laws
and regulations in the UK and
other
jurisdictions, growing demand from
investors and customers for
environmentally sustainable products
and services, and regulatory scrutiny,
financial institutions, including NatWest
Group, may through their business
activities face increasing litigati
on,
conduct, enforcement and contrac
t
liability risks related to climate c
hange,
environmental degradation and other
social, governance and sustain
ability-
related issues.
These risks may arise, for example, from
claims pertaining to : (i) failures to meet
obligations, targets or commitments
relating to, or to disclose accurately, or
provide updates on material clima
te
and/or sustainability related risk
s, or
otherwise provide appropriate disclosure
to investors, customers, counterparties
and other stakeholders; (ii) conduct, mis-
selling and other customer prote
ction
type claims; (iii) marketing that portrays
products, securities, activities o
r policies
as producing positive climate,
environmental or sustainable outcomes
to an extent that may not the case
; (iv)
damages claims under various tort
theories, including common law public
nuisance claims, or negligent
mismanagement of physical and/or
transition risks; (v) alleged violations of
officers’, directors’ and other fiduciaries’
fiduciary duties, for example by financing
various carbon-intensive,
environmentally harmful or otherwise
highly exposed assets, companies, and
industries; (vi) changes in unde
rstanding
of what constitutes positive climate,
environmental or sustainable outcomes
as a result of developing climate scie
nce,
leading to discrepancy between curren
t
product offerings and investor and/or
market and/or broader stakeholder
expectations; (vi) any weakness
es or
failures in specific systems or p
rocesses
associated particularly with climate,
environmental or sustainability linke
d
products, including any failure in timely
implementation, onboarding and/or
updating of such systems or process
es;
or (vii) counterparties, collaborators and
third parties in NatWest Group’s
value
chain action who act, or fail to act, or
undertake due diligence, or apply
appropriate risk management a
nd
product governance in a manner that
impacts Natwest Group’s reputation or
sustainability credentials.
Furthermore, there is a risk that
shareholders, campaign groups,
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customers and special interest groups
could seek to take legal action against
NatWest Group for financing or
contributing to climate change and
environmental degradation and for not
supporting the principles of “jus
t
transition” (i.e. maximising the
social
benefits of the transition, mitigating the
social risks of the transition, empowering
those affected by the change,
anticipating future shifts to address
issues up front and mobilising
investments from the public and priva
te
sectors).
There is a risk that as climate scie
nce
develops and societal understanding of
climate science increases and deepens,
courts, regulators and enforcement
authorities may apply the then current
understandings of climate related
matters retrospectively when asse
ssing
claims about historic conduct or dealings
of financial institutions, including
NatWest Group.
These potential litigation, conduct,
enforcement and contract liability risks
may have a material adverse effe
ct on
NatWest Group’s ability to achieve its
strategy, including its climate ambition,
and they could have an adverse
effect
on NatWest Group’s reputation, business
,
financial results, position and prospects,
results of operations and outlook.
Operational and IT resilience r
isk
Operational risks (including reliance on
third party suppliers and outsourcing of
certain activities) are inherent in NatWest
Group’s businesses.
Operational risk is the risk of los
s
resulting from inadequate or failed
internal processes, procedures,
people or
systems, or from external events,
including legal risks. NatWest Group
operates in a number of countries,
offering a diverse range of products and
services supported directly or indirectly
by third party suppliers. As a resu
lt,
operational risks or losses can arise from
a number of internal or external factors
(including financial crime and fraud), for
which there may now be a risk of
greater scrutiny by third parties on
NatWest Group’s compliance with
financial crime requirements; see
NatWest Group is exposed to the risks of
various litigation matters, regul
atory and
governmental actions and investigat
ions
as well as remedial undertakings,
including conduct-related reviews, anti-
money laundering and redress projects,
the outcomes of which are inherentl
y
difficult to predict, and which could have
an adverse effect on NatWest Group
’).
These risks are also present wh
en
NatWest Group relies on third-party
suppliers or vendors to provide se
rvices
to it or its customers, as is incre
asingly
the case as NatWest Group outs
ources
certain activities, including with respect
to the implementation of new
technologies, innovation and responding
to regulatory and market
changes.
Operational risks continue to b
e
heightened as a result of the
implementation of NatWest Group’s
purpose-led strategy, including NatWest
Group’s phased withdrawal fro
m ROI,
NatWest Group’s current cost-reduction
measures
and conditions affecting the
financial services industry generally
(including the COVID-19 pandemic and
other geo-political developments) as well
as the legal and regulatory uncertainty
resulting therefrom. It is unclea
r as to
how the future ways of working may
evolve, including in respect of how
working practices may develop
, or how
NatWest Group will evolve to be
st serve
its customers. Any of the above may
place significant pressure on NatWest
Group’s ability to maintain effective
internal controls and governance
frameworks.
The effective management of operational
risks is critical to meeting customer
service expectations and retaining and
attracting customer business. Although
NatWest Group has implemented risk
controls and mitigation actions, with
resources and planning having been
devoted to mitigate operational risk, suc
h
measures may not be effective in
controlling each of the operational risks
faced by NatWest Group. Ineffective
management of such risks could
adversely affect NatWest Group.
NatWest Group is subject to increasingly
sophisticated and frequent cyberattacks.
NatWest Group experiences a constant
threat from cyberattacks across the
entire NatWest Group and against
NatWest Group’s supply chain,
reinforcing the importance of due
diligence of and close working
relationship with the third parties on
which NatWest Group relies. NatWest
Group is reliant on technology, against
which there is a constantly evolving
series of attacks that are increasing in
terms of frequency, sophistication,
impact and severity. As cyberattacks
evolve and become more sophisticated,
NatWest Group is required to continue to
invest in additional capability de
signed to
defend against the emerging threats. In
2021, NatWest Group and its su
pply
chain were subjected to a small numbe
r
of Distributed Denial of Service (‘DDOS’)
and ransomware attacks, which are
a
pervasive and significant threat to the
global financial services industry.
T
he
focus is to manage the impact of
the
attacks and sustain availability of
services for NatWest Group’s c
ustomers.
NatWest Group continues to inves
t
significant resources in the development
and evolution of cyber security controls
that are designed to minimise t
he
potential effect of such
attacks
.
Hostile attempts are made by third
parties to gain access to, introduce
malware (including ransomware) into
and exploit vulnerabilities of, NatWest
Group’s IT systems. NatWest Group has
information and cyber security c
ontrols
in place to minimise the impact of any
attack, which are subject to review on a
continuing basis but given the nature of
the threat, there can be no assurance
that such measures will prevent all
attacks in the future. See also, ‘
NatWest
Group’s operations are highly dependent
on its complex IT systems (inclu
ding those
that enable remote working) and any IT
failure could adversely affect NatWest
Group’
.
Any failure in NatWest Group’s
cybersecurity policies, procedures or
controls, may result in significant
financial losses, major business
disruption, inability to deliver cus
tomer
services, or loss of data or other
sensitive information (including
as a
result of an outage) and may cause
associated reputational damage
. Any of
these factors could increase cos
ts
(including costs relating to notification of,
or compensation for customers, credit
monitoring or card reissuance), result in
regulatory investigations or sanctions
being imposed or may affect NatWest
Group’s ability to retain and att
ract
customers. Regulators in the UK, US,
Europe and Asia continue to recognise
cybersecurity as an important sys
temic
risk to the financial sector and have
highlighted the need for financial
institutions to improve their monitoring
and control of, and resilience
(particularly of critical services) to
cyberattacks, and to provide timely
notification of them, as appropr
iate.
Additionally, third parties may also
fraudulently attempt to induce
employees, customers, third-party
providers or other
users who have
access to NatWest Group’s syst
ems to
disclose sensitive information in order to
gain access to NatWest Group’s
data or
that of NatWest Group’s customers or
employees. Cybersecurity and
information security events can derive
from groups or factors such as: internal
or external threat actors, huma
n error,
fraud or malice on the part of NatWest
Group’s employees or third par
ties,
including third party providers,
or may
result from accidental technological
failure.
NatWest Group expects greater
regulatory engagement, supervision and
enforcement to continue at a high level
in relation to its overall resilienc
e to
withstand IT and related disruption,
either through a cyberattack or
some
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other disruptive event. Such increased
regulatory engagement, supervision and
enforcement is uncertain in relation to
the scope, cost, consequence and the
pace of change, which could negatively
impact NatWest Group. Due to NatWest
Group’s reliance on technology and the
increasing sophistication, frequency and
impact of cyberattacks, such attacks
may have a material adverse impact on
NatWest Group.
In accordance with the Data Protection
Act 2018 and the European Uni
on
Withdrawal Act 2018, the Data
Protection, Privacy and Electro
nic
Communications (Amendments Etc.) (EU
Exit) Regulations 2019, as ame
nded by
the Data Protection, Privacy and
Electronic Communications
(Amendments Etc.) (EU Exit) Regulations
2020 (‘UK Data Protection Framework’)
and European Banking Authority (‘EBA’)
Guidelines on ICT and Security Risk
Management, NatWest Group is required
to ensure it implements timely,
appropriate and effective organisational
and technological safeguards against
unauthorised or unlawful access
to the
data of NatWest Group, its cust
omers
and its employees. In order to meet this
requirement, NatWest Group re
lies on
the effectiveness of its internal policies
,
controls and procedures to protect the
confidentiality, integrity and availability
of information held on its IT sys
tems,
networks and devices as well as with
third parties with whom NatWes
t Group
interacts. A failure to monitor and
manage data in accordance with the UK
Data Protection Framework and EBA
requirements of the applicable legislation
may result in financial losses, regulatory
fines and investigations and associated
reputational d
amage.
NatWest Group operations and strategy
are highly dependent on the accuracy
and effective use of data.
NatWest Group relies on the effective
use of accurate data to support
, monitor,
evaluate, manage and enhance its
operations and deliver its strategy. T
he
availability of current, complete, detailed,
accurate and, wherever possible
,
machine-readable customer segment
and sub-sector data, together with
appropriate governance and
accountability for data, is fast be
coming
a critical strategic asset, which is subjec
t
to increased regulatory focus. Failu
re to
have that data or the ineffective
use or
governance of that data could result in a
failure to manage and report important
risks and opportunities or satisfy
customers’ expectations including the
inability to deliver innovative products
and services. This could also result in a
failure to deliver NatWest Group’s
strategy and could place NatWest Group
at a competitive disadvantage
by
increasing its costs, inhibiting its
efforts
to reduce costs or its ability to improve
its systems, controls and processe
s,
which could result in a failure to deliver
NatWest Group’s strategy. These data
limitations, or the unethical or
inappropriate use of data, and/or non-
compliance with customer data
protection laws could give rise to
conduct and litigation risks and may
increase the risk of operational events,
losses or other adverse consequence
s
due to inappropriate models, systems,
processes, decisions or other actions.
NatWest Group’s operations are highly
dependent on its complex IT systems
(including those that enable remote
working) and any IT failure could
adversely affect NatWest Group.
NatWest Group’s operations are highly
dependent on the ability to proces
s a
very large number of transactions
efficiently and accurately while
complying with applicable laws and
regulations. The proper functioning of
NatWest Group’s payment syst
ems,
financial crime, fraud systems
and
controls, risk management, credit
analysis and reporting, accounting,
customer service and other IT sys
tems,
as well as the communication n
etworks
between its branches and main data
processing centres, is critical to NatWest
Group’s operations.
Individually or collectively, any critical
system failure, material loss of service
availability or material breach of data
security could cause serious damage to
NatWest Group’s ability to provide
services to its customers, which could
result in reputational damage, significant
compensation costs or regulatory
sanctions (including fines resulting from
regulatory investigations) or a breach of
applicable regulations and could affec
t
its regulatory approvals, competitive
position, business and brands, which
could undermine its ability to attract and
retain customers. This risk is heightened
as most of NatWest Group’s employees
continue to work remotely, as it
outsources certain functions and as it
continues to innovate and offer new
digital solutions to its customers as a
result of the trend towards online and
mobile banking.
In 2021, NatWest Group continued to
make considerable investments to
further simplify, upgrade and imp
rove its
IT and technology capabilities (including
migration of certain services to cloud
platforms). NatWest Group also
continues to develop and enhance digital
services for its customers and see
ks to
improve its competitive position through
enhancing controls and procedures and
strengthening the resilience of se
rvices
including cyber security. Any failure of
these investment and rationalisation
initiatives to achieve the expected
results, due to cost challenges
or
otherwise, could negatively affec
t
NatWest Group’s operations, its
reputation and ability to retain or grow
its customer business or adverse
ly
impact its competitive position,
thereby
negatively impacting NatWest Group.
Remote working may adversely affect
NatWest Group’s ability to maintain
effective internal controls.
From March 2020 to September 2021,
many of NatWest Group’s employ
ees
worked exclusively on a remot
e basis.
Following the lifting of government
restrictions, NatWest Group will
implement a new hybrid working policy
whereby many employees may work
remotely the majority of the time in the
ordinary course of their roles.
Remote working arrangements for
NatWest Group employees continues
to
place heavy reliance on the IT sy
stems
that enable remote working and
increased exposure to fraud, conduct,
operational and other risks and
may
place additional pressure on NatWest
Group’s ability to maintain effective
internal controls and governance
frameworks. Remote working
arrangements are also subject to
regulatory scrutiny to ensure adequate
recording, surveillance and supervision
of regulated activities, and compliance
with regulatory requirements and
expectations, including requirements to:
meet threshold conditions for regulated
activities; ensure the ability to oversee
functions (including any outsourced
functions); ensure no detriment is cause
d
to customers; and ensure no increased
risk of financial crime. See also, ‘
A
failure
in NatWest Group’s risk management
framework could adversely affect
NatWest Group, including its abili
ty to
achieve its strategic objectives
.’
Moreover, the IT systems that enable
remote working interface with third-
party systems, and NatWest Gr
oup could
experience service denials or di
sruptions
if such systems exceed capacity
or if a
third-party system fails or experiences
any interruptions, all of which could
result in business and customer
interruption and related reputational
damage, significant compensation costs,
regulatory sanctions and/or a breach of
applicable regulations. See also,
NatWest Group’s operations are highly
dependent on its complex IT systems
(including those that enable remote
working) and any IT failure could
adversely affect NatWest Group
’.
Sustained periods of remote working
may negatively affect workforce
morale.
Whilst NatWest Group has taken
measures seeking to maintain t
he health,
wellbeing and safety of its employe
es,
these measures may be ineffective. Any
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of the above could impair NatWest
Group’s ability to hire, retain and engage
well-qualified employees, espec
ially at a
senior level, which in turn may adversely
impact NatWest Group’s ability to serve
its customers efficiently and impact
productivity across NatWest Group. This
could also adversely affect NatWest
Group’s reputation and compet
itive
position and its ability to grow its
business.
NatWest Group relies on attracting,
retaining and developing diverse se
nior
management and skilled personnel, and
is required to maintain good employee
relations.
NatWest Group’s success depends on its
ability to attract, retain through
creating
an inclusive environment, and de
velop
highly skilled and qualified diverse
personnel, including senior management,
directors and key employees especially
for technology and data focused roles, in
a highly competitive market and under
internal cost reduction pressure
s.
NatWest Group’s ability to do this may
be more difficult due to the cost
reduction pressures,
heightened
regulatory oversight of banks and the
increasing scrutiny of, and (in some
cases) restrictions placed upon,
employee compensation arrangements
(in particular those of banks in receipt of
government support such as NatWest
Group). This increases the cost of hiring,
training and retaining diverse skilled
personnel. In addition, certain economic,
market and regulatory conditio
ns and
political developments may red
uce the
pool of diverse candidates for ke
y
management and non-executive
roles,
including non-executive directors with
the right skills, knowledge and
experience, or increase the number of
departures of existing employe
es.
Moreover, a failure to foster a diverse
and inclusive workforce may have an
adverse impact on NatWest Group’s
employee engagement and the
formulation and execution of its s
trategy,
and could also have a negative e
ffect on
its reputation with customers, investors
and regulators.
The inability to compensate employe
es
competitively and/or any reduc
tion of
compensation, as a result of negative
economic developments or otherwise,
could have an adverse effe
ct on NatWest
Group’s ability to hire, retain and engage
well qualified employees, es
pecially at a
senior level, which may have a
negative
impact on the financial position and
prospects of NatWest Group.
Many of NatWest Group’s employee
s in
the UK, the ROI and continental Europe
are represented by employee
representative bodies, including trade
unions and works councils. Engagement
with its employees and such bodies is
important to NatWest Group in
maintaining good employee relations.
Any failure to do so could impact
NatWest Group’s ability to operate its
business effectively.
A failure in NatWest Group’s risk
management framework could adversely
affect NatWest Group, including its ability
to achieve its strategic objectiv
es.
Risk management is an integral
part of
all of NatWest Group’s activities and
includes the definition and monitoring of
NatWest Group’s risk appetite and
reporting on NatWest Group’s ris
k
exposure and the potential impact
thereof on NatWest Group’s financial
condition. Financial
risk management is
highly dependent on the use and
effectiveness of internal stress te
sts and
models.
In addition, financial crime risk
management is dependent on the use
and effectiveness of financial crime
assessment, systems and contr
ols. Weak
or ineffective financial crime proce
sses
and controls may risk NatWest Group
inadvertently facilitating financial crime
which may result in regulatory
investigation, sanction, litigation and
reputational damage. Financial crime
continues to evolve, whether through
fraud, scams, cyber-attacks or other
criminal activity. NatWest Group has
made and continues to make significant,
multi-year investments to strengthen and
improve its overall financial crime control
framework with prevention systems and
capabilities. As part of its ongoing
programme of investment, there is
current and future investment planned to
further strengthen financial crime
controls over the coming years, including
investment in new technologies and
capabilities to further enhance
customer
due diligence, transaction monitoring,
sanctions and anti-bribery and
corruption systems.
Ineffective risk management may arise
from a wide variety of factors, including
lack of transparency or incomplete risk
reporting, unidentified conflicts or
misaligned incentives, lack of
accountability control and governance,
incomplete risk monitoring and
management or insufficient cha
llenges or
assurance processes. Failure to manage
risks effectively could adversely impact
NatWest Group’s reputation or its
relationship with its regulators,
customers, shareholders or other
stakeholders.
NatWest Group’s operations are
inherently exposed to conduct risks,
which include business decisions, actions
or reward mechanisms that are not
responsive to or aligned with NatWest
Group’s regulatory obligations,
customers’ needs or do not refle
ct
NatWest Group’s customer-foc
used
strategy, ineffective product
management, unethical or inappropriate
use of data, information asymmetry,
implementation and utilisation of new
technologies, outsourcing of customer
service and product delivery, th
e
possibility of mis-selling of financial
products and mishandling of customer
complaints. Some of these risks have
materialised in the past and ineffe
ctive
management and oversight of conduct
risks may lead to further remediation
and regulatory intervention or
enforcement.
NatWest Group’s businesses ar
e also
exposed to risks from employee
misconduct including non-compliance
with policies and regulations, ne
gligence
or fraud (including financial crimes and
fraud), any of which could resul
t in
regulatory fines or sanctions and se
rious
reputational or financial harm t
o
NatWest Group. These risks may
be
exacerbated as most of NatWest Group’s
employees continue to work remotely,
which places additional pressure
on
NatWest Group’s ability to maintain
effective internal controls and
governance frameworks.
NatWest Group has been seeking to
embed a strong risk culture across the
organisation and has implemented
policies and allocated new resou
rces
across all levels of the organisation to
manage and mitigate conduct risk
and
expects to continue to invest in its risk
management framework. However, such
efforts may not insulate NatWest Group
from future instances of misconduct and
no assurance can be given that NatWest
Group’s strategy and control fr
amework
will be effective. Any failure in NatWest
Group’s risk management framework
could negatively affect NatWest Group
and its financial condition through
reputational and financial harm and may
result in the inability to achieve its
strategic objectives for its customers,
employees and wider stakeholders.
NatWest Group’s operations are subje
ct
to inherent reputational risk.
Reputational risk relates to stakeholder
and public perceptions of NatW
est Group
arising from an actual or perceived
failure to meet stakeholder expec
tations,
including with respect to NatWes
t
Group’s purpose-led strategy and related
targets, due to any events, behaviour,
action or inaction by NatWest Group, its
employees or those with whom NatWest
Group is associated. See also ‘
NatWest
Group’s businesses are subject to
substantial regulation and oversig
ht,
which are constantly evolving and may
adversely affect NatWest Group
’. This
includes brand damage, which may be
detrimental to NatWest Group’s business,
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including its ability to build or s
ustain
business relationships with customers,
and may cause low employee morale,
regulatory censure or reduced acces
s to,
or an increase in the cost of, funding.
Reputational risk may arise whenever
there is a material lapse in standards of
integrity, compliance, customer or
operating efficiency and may adversely
affect NatWest Group’s ability to attract
and retain customers. In partic
ular,
NatWest Group’s ability to attract and
retain customers (particularly, corporate
and retail depositors) may be adversely
affected by, amongst others: negative
public opinion resulting from the actual
or perceived manner in which NatWest
Group conducts or modifies its business
activities and operations, media
coverage (whether accurate or
otherwise), employee misconduct,
NatWest Group’s financial performance,
IT systems failures or cyberattack
s, data
breaches, financial crime and fraud, the
level of direct and indirect government
support, or the actual or perceived
practices in the banking and financial
industry in general, or a wide variety of
other f
actors.
Modern technologies, in particul
ar online
social networks and other broadcast
tools that facilitate communication with
large audiences in short timeframes and
with minimal costs, may also significan
tly
increase and accelerate the impact of
damaging information and allegations.
Although NatWest Group has
implemented a Reputational Risk Policy
to improve the identification, assess
ment
and management of customers,
transactions, products and issu
es, which
represent a reputational risk, N
atWest
Group cannot be certain that it will be
successful in avoiding damage to its
business from reputational risk.
Legal, regulatory and conduct
risk
NatWest Group’s businesses ar
e subject
to substantial regulation and ove
rsight,
which are constantly evolving and may
adversely affect NatWest Group.
NatWest Group is subject to exte
nsive
laws, regulations, corporate governance
practice and disclosure requirements,
administrative actions and policies in
each jurisdiction in which it operates.
Many of these have been introduced or
amended recently and are subject to
further material changes, which may
increase compliance and conduct risks,
particularly if EU/EEA and UK laws
diverge as a result of Brexit. N
atWest
Group expects government an
d
regulatory intervention in the financial
services industry to remain high for the
foreseeable future.
In recent years, regulators and
governments have focused on
reforming
the prudential regulation of the financial
services industry and the mann
er in
which the business of financial services is
conducted. Amongst others, me
asures
have included: enhanced capital, liquidity
and funding requirements,
implementation of the UK ring-fencing
regime, implementation and
strengthening of the recovery a
nd
resolution framework applicable to
financial institutions in the UK, the EU
and the US, financial industry reforms
(including in respect of MiFID II),
corporate governance require
ments,
restrictions on the compensation of
senior management and other
employees, enhanced data prot
ection
and IT resilience requirements, financial
market infrastructure reforms (including
enhanced data protection and IT
resilience requirements, enhance
d
regulations in respect of the provision of
‘investment services and activitie
s’), and
increased regulatory focus in certain
areas, including conduct, consumer
protection, competition, disputes
regimes, payment systems, financial
crime and fraud laws and regulations.
Other areas in which, and examples of
where, governmental policies, r
egulatory
and accounting changes, and increased
public and regulatory scrutiny could
have an adverse impact (some of which
could be material) on NatWest Group
include, but are not limited to, t
he
following:
general changes in governmen
t,
central bank, regulatory or
competition policy, or changes in
regulatory regimes that may
influence investor decisions in the
jurisdictions in which NatWest Group
operates;
rules relating to foreign ownership,
expropriation, nationalisation and
confiscation of assets;
increased scrutiny from the CMA
,
FCA and Payment Systems Regulator
(‘PSR’) for the protection and
resilience of, and competition and
innovation in, UK payment syste
ms
and retail banking developments
relating to the UK initiative on O
pen
Banking, Open Finance and the
European directive on payment
services;
the ongoing compliance by NatWes
t
Group with CMA’s Retail Banking
Market Order 2017 (the ‘Order’
) as
well as the ongoing consultation by
the UK Government to introduce
penalties for breaches of the Order
(in addition to the current customer
remediation requirements);
ongoing competition litigation in the
English courts around payment card
interchange fees, combined with
increased regulatory scrutiny (from
the PSR) of the Visa and Maste
rcard
card schemes;
new or increased regulations re
lating
to customer data protection as
well
as IT controls and resilience,
including the UK Data Protection
Framework and the impact of the
Court of Justice of the EU (CJEU)
decision (known as Schrems II),
in
which the CJEU ruled that the
Privacy Shield (an EU/US data
transfer mechanism) is now invalid,
leading to more onerous due
diligence requirements for the Group
prior to sending personal data
of its
EU customers and employees t
o non-
EEA countries, including the UK and
the US;
the introduction of, and change
s to,
taxes, levies or fees applicable to
NatWest Group’s operations, such as
the imposition of a financial
transaction tax, introduction of global
minimum tax rules, changes in tax
rates, changes in the scope and
administration of the Bank Levy
,
increases in the bank corporation tax
surcharge in the UK, restrictions on
the tax deductibility of interest
payments or further restrictions
imposed on the treatment of carry-
forward tax losses that reduce the
value of deferred tax assets and
require increased payments of
t
ax;
increased regulatory focus on
customer protection (such as the
FCA’s consumer duty consultation
paper (CP21/13)) in retail or other
financial markets;
the potential introduction by the
Bank of England of a Central Bank
Digital Currency which could re
sult in
deposit outflows, higher funding
costs, and/or other implications f
or
UK banks including NatWest Group;
and
regulatory enforcement in the form
of PRA imposed financial penal
ties
for failings in banks’ regulatory
reporting governance and cont
rols,
and regulatory scrutiny following the
2019 PRA “Dear CEO letter” letter
regarding PRA’s ongoing focus
on:
the integrity of regulatory reporting,
which the PRA considers has equal
standing with financial reportin
g; the
PRA’s thematic reviews of the
governance, controls and proce
sses
for preparing regulatory returns of
selected UK banks, including N
atWest
Group; the publication of the PRA’s
common findings from those revie
ws
in September 2021; and NatWe
st
Group’s programme of improvements
to meet PRA expectations.
These and other recent regulatory
changes, proposed or future
developments and heightened leve
ls of
public and regulatory scrutiny in the UK,
the EU and the US have resulted in
increased capital, funding and liquidity
requirements, changes in the competitive
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landscape, changes in other regulatory
requirements and increased op
erating
costs, and have impacted, and
will
continue to impact, competitive position,
product offerings and business models.
Future competition investigations, ma
rket
reviews, or the regulation of me
rgers
may lead to the imposition of financial
penalties or market remedies that may
adversely impact NatWest Group’s
competitive or financial position. Any of
these developments (including any failure
to comply with new rules and
regulations) could also have a significant
impact on NatWest Group’s
authorisations and licences, the products
and services that NatWest Grou
p may
offer, its reputation and the val
ue of its
assets, NatWest Group’s operations or
legal entity structure, and the manner in
which NatWest Group conducts its
business. Material consequences c
ould
arise should NatWest Group be
found to
be non-compliant with these regulatory
requirements. Regulatory developmen
ts
may also result in an increased number
of regulatory investigations and
proceedings and have increased the
risks relating to NatWest Group’s ability
to comply with the applicable body of
rules and regulations in the manner and
within the time frames required.
Changes in laws, rules or regulations, or
in their interpretation or enforcement, or
the implementation of new laws, rules or
regulations, including contradictory or
conflicting laws, rules or regulations by
key regulators or policymakers in
different jurisdictions, or failure by
NatWest Group to comply with s
uch
laws, rules and regulations, may
adversely affect NatWest Group’s
business, results of operations and
outlook. In addition, uncertainty and
insufficient international regulatory
coordination as enhanced supervisory
standards are developed and
implemented may adversely aff
ect
NatWest Group’s ability to engage in
effective business, risk and capital
management planning.
NatWest Group is exposed to the risks of
various litigation matters, regulatory an
d
governmental actions and inves
tigations
as well as remedial undertakings,
including conduct-related reviews, anti-
money laundering and redress projects,
the outcomes of which are inhe
rently
difficult to predict, and which c
ould have
an adverse effect on NatWest Group.
NatWest Group’s operations are diverse
and complex and it operates in le
gal and
regulatory environments that expose it
to
potentially significant legal proce
edings,
and civil and criminal regulatory
and
governmental actions. NatWest Group
has resolved a number of legal and
regulatory actions over the pas
t several
years but continues to be, and may in
the future be, involved in such actions in
the US, the UK, Europe and oth
er
jurisdictions.
NatWest Group is currently, has recently
been and will likely be involved in a
number of significant legal and
regulatory actions, including
investigations, proceedings and ongoing
reviews (both formal and informal) by
governmental law enforcement and
other agencies and litigation
proceedings, relating to, among othe
r
matters, the offering of securities
,
conduct in the foreign exchange market,
the setting of benchmark rates such as
LIBOR and related derivatives trading,
the issuance, underwriting, and sales
and trading of fixed-income securities
(including government securities),
product mis-selling, customer
mistreatment, anti-money laundering,
antitrust, VAT recovery and various
other compliance issues. Legal and
regulatory actions are subject to many
uncertainties, and their outcom
es,
including the timing, amount of fines,
damages or settlements or the form of
any settlements, which may be ma
terial
and in excess of any related provisions,
are often difficult to predict, particularly
in the early stages of a case or
investigation. NatWest Group’s
expectation for resolution may change
and substantial additional provisions and
costs may be recognised in respect of
any matter.
The resolution of significant
investigations include: (a) NWM Plc’s
December 2021 spoofing-relate
d guilty
plea in the United States, which involves
a three-year period of probation, an
independent corporate monitor, and
commitments to compliance programme
reviews and improvements and
reporting
obligations, as well as approximately
US$35 million in fines and restitution,
and (b) National Westminster B
ank Plc’s
October 2021 guilty plea for bre
aches of
the UK Money Laundering Regulations
2007, which resulted in a fine o
f
approximately £265 million. For
additional information relating to these
and other legal and regulatory
proceedings and matters to which
NatWest Group is currently expose
d, see
Litigation and regulatory matters
’ at
Note 27 to the consolidated ac
counts.
The recent guilty pleas, other r
ecently
resolved matters or adverse outcomes or
resolution of current or future legal or
regulatory actions could increase
the risk
of greater regulatory and third party
scrutiny and could have material
collateral consequences for NatWest
Group’s business and result in
restrictions or limitations on NatWest
Group’s operations.
These may include the effective
or actual
disqualification from carrying on certain
regulated activities and conseq
uences
resulting from the need to reapply f
or
various important licences or obtain
waivers to conduct certain existing
activities of NatWest Group, particularly
but not solely in the US, which
may take
a significant period of time and the
results of which are uncertain.
Disqualification from carrying on any
activities, whether automatically as a
result of the resolution of a particular
matter or as a result of the fail
ure to
obtain such licences or waivers
could
adversely impact NatWest Group’s
business, in particular in the US. This in
turn and/or any fines, settlement
payments or penalties could ad
versely
impact NatWest Group’s reporte
d
financial results and condition, c
apital
position or reputation.
Failure to comply with undertakings
made by NatWest Group to its
regulators, or the conditions of probation
resulting from the spoofing-related guilty
plea, may result in additional me
asures
or penalties being taken against NatWest
Group. In addition, any failure to
administer conduct redress process
es
adequately, or to handle individual
complaints fairly or appropriately, could
result in further claims as well as the
imposition of additional measure
s or
limitations on NatWest Group’s
operations, additional supervision by
NatWest Group’s regulators, and loss of
investor confidence.
NatWest Group may not effectively
manage the transition of LIBOR and
other IBOR rates to alternative risk-free
rates.
UK and international regulators are
driving the transition from the us
e of
interbank offer rates (‘IBORs’), including
LIBOR, to alternative rates, pri
marily risk
free rates (‘RFRs’). As of 31 December
2021, LIBOR, as currently determined,
has ceased for all tenors of GBP, JPY,
CHF, EUR, and for the 1 week and 2
month tenors for USD. The remaining
USD LIBOR tenors, as currently
determined, are due to cease after 30
June 2023. The FCA has use
d its powers
under the UK Benchmarks Reg
ulation
(‘UK BMR’) to require, for a limited
period of time after 31 Decembe
r 2021,
the ongoing publication of the 1
, 3, and 6
month GBP and JPY LIBOR tenors using
a changed methodology (i.e., ‘Art23A
LIBOR’ on a synthetic basis). The UK has
passed the Critical Benchmarks
(References and Administrators
’ Liability)
Act 2021 (‘Critical Benchmarks
Act’)
which establishes a framework that
allows the ongoing use of Art23A LIBO
R
under certain circumstances w
here
contracts have pro-actively transitioned
onto alternative rates. However, the FCA
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has been clear that the solutions
provided under UK BMR and the Critical
Benchmarks Act are not permanent and
cannot be guaranteed after the e
nd of
2022 (and for JPY the FCA has
confirmed that Art23A LIBOR will no
longer be available after the end of
2022). This framework and its lack of
permanence may expose NatWest
Group, its customers and the financial
services industry more widely to various
risks, including: (i) the FCA further
restricting use of Art23A LIBOR resulting
in proactive transition of contracts; and
(ii) mis-matches between positions in
cleared derivatives and the exposures
they are hedging where those e
xposures
are permitted to make use of Art23A
LIBOR, as the FCA has chosen not to
permit the use of Art23A LIBOR for
cleared derivatives. Although the f
ormal
cessation date for the remaining USD
LIBOR tenors (as currently determined) is
not until the end of June 2023, US and
UK regulators have been clear
that this
is only to support the rundown of back
book USD LIBOR exposures, and that no
new contracts should reference
these
USD LIBOR tenors after 31 December
2021, other than in a very limited range
of circumstances. Natwest Group will
continue to have ongoing expos
ure to
the remaining USD LIBOR tenors until
they cease at the end of June 20
23.
Natwest Group had significant
exposures
to IBORs and has actively sought to
transition away from these during 202
1
in accordance with regulatory
expectations and milestones. Transition
measures have included the pro-active
development of new products on using
alternative rates, primarily but not
exclusively RFRs rather than LIBOR, pro-
actively restructuring existing L
IBOR
exposures so that they cease to
reference LIBOR and instead ref
erence
alternative rates, and embedding
language into contracts that allows for
the automatic conversion to alternative
rates when LIBOR ceases to be available.
The main Central Counterparty Clearing
houses (CCPs) conducted mass
conversion exercises in December 2021
covering GBP, JPY, CHF and EUR LIBO
R
cleared derivatives to fully trans
ition all
outstanding LIBOR exposure to the
relevant RFR. Natwest Group entities,
along with many of their major
counterparties, have already a
dhered to
the ISDA IBOR fall-backs supplement and
protocol which establishes a cle
ar,
industry accepted, contractual process
to manage the transition from IBORs
to
RFRs for non-cleared derivative
products.
These transition efforts have involved
extensive engagement with cus
tomers,
industry working groups and regulators
to seek to deliver transition in a
transparent and economically
appropriate manner. Any economic
impacts will be dependent on, amongst
other things, the establishment of deep
and liquid RFR markets, the
establishment of clear and consistent
market conventions for all replacement
products, as well as counterparties’
willingness to accept, and transition to,
these conventions. Furthermore, ce
rtain
IBOR obligations may not be able
to be
pro-actively changed which co
uld,
depending on any over-arching
legislative transition frameworks
,
potentially result in fundamentally
different economic outcomes than
originally intended. The uncert
ainties
around the manner of transition to R
FRs,
and the ongoing broader acceptance
and use of RFRs across the market,
expose NatWest Group, its clie
nts and
the financial services industry more
widely to
risks.
Examples of these risks may include (i)
legal (including litigation) risks relating to
documentation for new and the
majority
of existing transactions (including, bu
t
not limited to, changes, lack of changes,
unclear contractual provisions,
and
disputes in respect of these); (ii)
financial
risks from any changes in valuation of
financial instruments linked to
impacted
IBORs that may impact NatWest Group’s
performance, including its cost of funds,
and its risk management related
financial models; (iii) pricing, inte
rest rate
or settlement risks such as changes
to
benchmark rates that could impact
pricing, interest rate or settleme
nt
mechanisms in or on certain instruments;
(iv) operational risks due to the
requirement to adapt IT systems, trade
reporting infrastructure and operational
processes, as well as ensuring
compliance with restrictions on new USD
LIBOR usage after December 2
021; (v)
conduct and litigation risks arising fro
m
communication regarding the p
otential
impact on customers, and engage
ment
with customers during and afte
r the
transition period, or non-acceptance by
customers of replacement rate
s; and (vi)
different legislative provisions in different
jurisdictions, for example, unlike
certain
US states and the EU, the UK has not
provided a clear and robust safe
harbour
to protect against litigation and poten
tial
liability arising out of the switch to
‘synthetic LIBOR’.
Notwithstanding all efforts to date, un
til
the transition away from LIBOR onto
alternative rates has been fully
completed and there is greater
experience of how RFRs are adopted
across different products and c
ustomer
groups, it remains difficult to de
termine
to what extent the changes will affect
NatWest Group, or the costs of
implementing any relevant remedial
action. Uncertainty as to the nature and
extent of such potential changes, the
take up of alternative reference rates, or
other reforms may adversely af
fect
financial instruments originally
referencing LIBOR as the benchmark.
The implementation of any alternative
RFRs may be impossible or impracticable
under the existing terms of cert
ain
financial instruments and could have an
adverse effect on the value of, return on,
and trading market for, certain f
inancial
instruments and on NatWest Group’s
profitability.
Changes in tax legislation or failure to
generate future taxable profits may
impact the recoverability of certain
deferred tax assets recognised
by
NatWest Group.
In accordance with the accounting
policies set out in
‘Critical accounting
policies and key sources of estimat
ion
uncertainty
’, NatWest Group has
recognised deferred tax assets
on losses
available to relieve future profits
from
tax only to the extent it is probable that
they will be recovered. The def
erred tax
assets are quantified on the basis of
current tax legislation and accounting
standards and are subject to change in
respect of the future rates of tax or the
rules for computing taxable profits and
offsetting allowable
losses.
Failure to generate sufficient future
taxable profits or further change
s in tax
legislation (including with respect to
rates of tax) or accounting standards
may reduce the recoverable amount of
the recognised tax loss deferred tax
assets, amounting to £899 million as at
31 December 2021. Changes to
the
treatment of certain deferred tax assets
may impact NatWest Group’s capital
position. In addition, NatWest Group’s
interpretation or application of relevant
tax laws may differ from those of the
relevant tax authorities and provisions
are made for potential tax liabilities that
may arise on the basis of the amounts
expected to be paid to tax authorities.
The amounts ultimately paid may diff
er
materially from the amounts pr
ovided
depending on the ultimate resol
ution of
such
matters.
Material con
tracts
NatWest Group
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Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
The company and its subsidiaries are
party to various contracts in the ordinary
course of business. Material contracts
include the following:
B Share Acquisition and Contingent
Capital Agreement
On 26 November 2009, the company
and HM Treasury entered into the
Acquisition and Contingent Ca
pital
Agreement pursuant to which HM
Treasury subscribed for the init
ial B
shares and the Dividend Acces
s Share
(the Acquisitions) and agreed the terms
of HM Treasury's contingent subscription
(the Contingent Subscription) for an
additional £8 billion in aggregate in the
form of further B shares (the Contingent
B shares), to be issued on the same
terms as the initial B shares. The
Acquisitions were subject to the
satisfaction of various conditions,
including the company having obtained
the approval of its shareholders
in
relation to the Acquisitions.
On 16 December 2013, the company
announced that, having received
approval from the PRA, it had terminated
the £8 billion Contingent Subscription.
The company was able to cance
l the
Contingent Subscription as a re
sult of
the actions announced in the sec
ond half
of 2013 to further strengthen its
capital
position.
On 9 October 2015, the company
announced that on 8 October 2015
, it
had received a valid conversion
notice
from HM Treasury in respect of
all
outstanding B shares held by HM
Treasury. The new ordinary shares
issued on conversion of the B shares
were admitted to the official list
of the
UK Listing Authority (UKLA), an
d to
trading on the London Stock Exchange
plc, on 14 October 2015. Following such
conversion, HM Treasury no lo
nger holds
any B shares.
The company gave certain
representations and warranties
to HM
Treasury on the date of the Acquisition
and Contingent Capital Agreement, on
the date the circular was posted to
shareholders, on the first date on which
all of the conditions precedent were
satisfied, or waived, and on the date of
the Acquisitions. The company also
agreed to a number of undertakings.
The company agreed to reimbu
rse HM
Treasury for its expenses incurred in
connection with the Acquisitions.
For as long as it is a substantial
shareholder of the company (within
the
meaning of the UKLA’s Listing Rules),
HM Treasury has undertaken not to vote
on related party transaction resolutions
at general meetings and to direct that i
ts
affiliates do not so vote.
Directed Buyback Contract
On 7 February 2019, the comp
any and
HM Treasury entered into the Directed
Buyback Contract to help facilitate the
return of the company to full private
ownership through the use of any exces
s
capital to buy back the company
’s
ordinary shares held by HM Treasury.
Under the terms of the Directe
d Buyback
Contract, the company may agree with
HM Treasury to make off-market
purchases from time to time of
its
ordinary shares held by HM Treasury,
including by way of one or more
standalone purchases, through a non-
discretionary, broker-managed directed
trading programme, or in conju
nction
with any offer or sale by HM Tre
asury by
way of an institutional placing. Neither
the company nor HM Treasury
would be
under an obligation to agree to make
such off-market purchases and would
only do so subject to regulatory approval
at the time.
The aggregate number of ordinary
shares which the company may
purchase from HM Treasury under the
Directed Buyback Contract will not
exceed 4.99%. of the company’s iss
ued
share capital and the aggregate
consideration to be paid will not exceed
4.99%. of the company’s market
capitalisation. The price to be p
aid for
each ordinary share will be the ma
rket
price at the time of purchase or, if the
directed buyback is in conjunction with
an institutional placing, the placing price.
Framework and State Aid Deed
As a result of the State Aid granted to
the company, it was required to work
with HM Treasury to submit a State Aid
restructuring plan to the Europe
an
Commission (EC), which was the
n
approved by the EC under the State Aid
rules on 14 December 2009. T
he
company agreed a series of me
asures
which supplemented the measures in the
company’s strategic plan.
The company entered into a St
ate Aid
Commitment Deed with HM Treasury at
the time of the initial EC decision and,
following the EC’s approval of
amendments to the restructuring plan in
April 2014, the company entered into a
revised State Aid Commitment Deed with
HM Treasury. In September 20
17, the
revised State Aid Commitment Deed was
amended by a Deed of Variation (as so
amended, the “Revised State Ai
d
Commitment Deed”) following the EC’s
approval of an alternative remedies
package (the “Alternative Remedies
Package”) to replace the comp
any’s final
outstanding commitment under
its State
Aid obligations (to divest the busine
ss
previously known as Williams & Glyn).
On 25 April 2018, the Revised State Aid
Commitment Deed was replaced by the
Framework and State Aid Deed between
the company, HM Treasury and an
independent body established to
facilitate and oversee the delive
ry of the
Alternative Remedies Package
(the
“Independent Body”). Under th
e
Framework and State Aid Deed, the
company agrees to do all acts and things
necessary to ensure that HM Treasury is
able to comply with its obligatio
ns under
any EC decision approving State A
id to
the company, including under the
Alternative Remedies Package.
Pursuant to the Framework and State
Aid Deed, the company has committed:
(i) £425 million into a fund for eligible
bodies in the UK banking and financial
technology sectors to develop and
improve their capability to compete with
the company in the provision of bankin
g
services to small and medium-sized
enterprises (“SMEs”) and devel
op and
improve the financial products and
services available to SMEs (the
“Capability and Innovation Fund”); and
(ii) £275 million to eligible bodies to help
them incentivise SME banking
customers
within the division of the company
previously known as Williams & Glyn to
switch their business current accounts
and loans to the eligible bodies (the
“Incentivised Switching Scheme”
). The
company has also agreed to set aside up
to a further £75 million in funding to
cover certain costs customers may incu
r
as a result of switching under t
he
Incentivised Switching Scheme. In
addition, under the terms of the
Alternative Remedies Package, s
hould
the uptake within the Incentivise
d
Switching Scheme not be sufficie
nt, the
company may be required to make a
further contribution, capped at
£50
million. The Independent Body will
distribute funds from the Capability and
Innovation Fund and implement the
Incentivised Switching Scheme.
Under the Framework and State Aid
Deed, the company also agreed to
indemnify the Independent Body and HM
Treasury, up to an amount of £320
million collectively to cover liabi
lities that
may be incurred in implementi
ng the
Alternative Remedies Package.
The
provisions of the indemnity to the
Independent Body are set out in the
Framework and State Aid Deed and the
provisions of the indemnity to HM
Treasury are set out in a separate
agreement between the company and
HM Treasury, described under “
Deed of
Indemnity
” below.
Material contract
s continue
d
NatWest Group
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Strategic report
Governance
Risk and capital management
Additional information
Financial review
The Framework and State Aid Dee
d also
provides that if the EC adopts a decision
that the UK Government must rec
over
any State Aid (a "Repayment De
cision")
and the recovery order of the
Repayment Decision has not bee
n
annulled or suspended by the General
Court or the European Court of Jus
tice,
then the company must repay HM
Treasury any aid ordered to be
recovered under the Repayme
nt
Decision.
Deed of Indemnity
In the context of the Framework and
State Aid Deed, the company entered
into a Deed of Indemnity with HM
Treasury on 25 April 2018, purs
uant to
which the company agreed to indemnify
HM Treasury to cover liabilities that may
be incurred in implementing the
Alternative Remedies Package, as
described under “Framework and State
Aid Deed” above
.
Trust Deed
In the context of the Framework and
State Aid Deed, the company entered
into a Trust Deed with the Independent
Body on 25 April 2018, to set up a trust
to administer the funds commit
ted by the
company under the Framework and
State Aid Deed for the Alternative
Remedies Package.
State Aid Costs Reimbursement Deed
Under the 2009 State Aid Costs
Reimbursement Deed, the company has
agreed to reimburse HM Treasury for
fees, costs and expenses associated with
the State Aid and State Aid approval.
HMT and UKFI Relationship Deed
On 7 November 2014, in order to comply
with an amendment to the UK Listing
Rules, the company entered into a
Relationship Deed with HM Treasury and
UK Financial Investments Limited in
relation to the company’s obligations
under the UK Listing Rules to pu
t in place
an agreement with any controlling
shareholder (as defined for these
purposes in the Listing Rules). T
he
Relationship Deed covers the three
independence provisions mandated by
the Listing Rules: (i) that contracts
between the company and HM
Treasury
(or any of its subsidiaries) will be
arm's
length and normal commercial
arrangements, (ii) that neither HM
Treasury nor any of its associate
s will
take any action that would have the
effect of preventing the company
from
complying with its obligations under the
Listing Rules; and (iii) neither HM
Treasury nor any of its associate
s will
propose or procure the propos
al of a
shareholder resolution which is intended
or appears to be intended to circumvent
the proper application of the Listing
Rules.
Memorandum of Understanding
Relating to The Royal Bank of Scotland
Group Pension Fund
On 16 April
2018 the company
entered
into a Memorandum of Understanding
(the ”MoU”) with the trustee of T
he
Royal Bank of Scotland Group Pensi
on
Fund (the ”Group Fund”), which aimed to
facilitate both the necessary changes to
the Main Section
of the Group Fund
to
align the employing entity structure with
the requirements of the UK ring-f
encing
legislation and acceleration of the
settlement framework for the 3
1
December
2017 triennial valuation of the
Main Section
of the Group Fund (b
rought
forward from 31 December
2018
).
In addition, the MoU also provided clarity
on the additional related funding
contributions required to be made by the
company to the Main Section
of the
Group Fund as follows: (i)
a pre-tax
payment of £2 billion that was
made in
the second half of 2018 and (ii)
from 1
January
2020, further pre-tax
contributions of up to £1.5 billio
n in
aggregate linked to the making of
future
distributions to RBS shareholders
including ordinary and special dividends
and/or share buy backs (subject to an
annual cap on contributions of £50
0
million before tax).
On 28 September
2018, the
implementation of the MoU was
documented through a Framework
Agreement entered into between the
company and the trustee of the Group
Fund
.
NatWest Group
A
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nts 2021
429
Additional
information
429
Additional information
430
Financial calendar
430
Shareholder enquiries
431
Analysis of ordinary shareholders
431
Important addresses
432
Principal offices
433
Forward-looking statements
434
Presentation of information
Shareholder
information
NatWest Group
A
nnual Repor
t and Accou
nts 2021
430
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financ
ial review
Financial calendar
Dividends
Payment dates
Cumulative
preference
shares
31 May and 30 December 2022
Non-cumulative preference
shares
31 March, 30 June, 30
September and 30 December
2022
Ordinary shares (2021 final)
4 May 2022
Ex
-
dividend date
Cumulative preference
shares
5 May and 1 December 2022
Ordinary shares (2021 final)
17 March 2022
Record date
Cumulative preference
shares
6 May and 2 December 2022
Ordinary shares (2021 final)
18 March 2022
Annual General Meeting
28 April 2022
Interim results
29 July 2022
Shareholder enquiries
You can check your shareholdings in the
company by visiting
the Shareholder Hub section of our website at
natwestgroup.com and clicking the ‘Access y
our shareholding
online’ tab. You will need the shareholder
reference number
printed on your share certificate or dividend confi
rmation
statement to access this information. You c
an also view any
outstanding payments, update bank
account and address
details and download various forms.
NatWest Group is committed to reducing its im
pact on the
environment. You can choose to receive
your shareholder
communications electronically via the ‘Sign u
p for e-comms’
tab and you will receive an email notificatio
n when documents
become available to view on our website.
You can also check your share
holding by contacting our
Registrar:
Braille and audio Strategic report with addition
al
information
Shareholders requiring a Braille or audio ve
rsion of the
Strategic report with additional information should
contact the
Registrar on +44 (0)370 70
2 0135.
ShareGift
The company is aware that shareholde
rs who hold a small
number of shares may be retaining the
se shares because
dealing costs make it uneconomical to dispose of
them.
ShareGift is a free charity share donation ser
vice operated by
The Orr Mackintosh Foundation (regis
tered charity 1052686
) to
enable shareholders to donate s
hares to charity.
If you are a UK taxpayer, donating your shares in
this way will
not give rise to either a gain or a loss f
or UK capital gains tax
purposes. You may be able to claim UK inco
me tax relief on
gifted shares and can do so in various ways. Furthe
r
information can be obtained from HM Revenue
& Customs.
Should you wish to donate your shares to ch
arity please
contact ShareGift for further information:
Share and bond scams
Scammers will request money upfron
t, as a bond or other form
of security, but victims are ofte
n left out of pocket, sometimes
losing their savings or even their family home.
Even seasoned
investors have been caught out by scams.
Clone firms
A ‘clone firm’ uses the name, firm registration numbe
r (FRN)
and address of a firm or individual who is
FCA authorised. The
scammer may claim that the genuine firm's cont
act details on
the FCA Register (Register) are out of date and t
hen use their
own details, or copy the website of an autho
rised firm, making
subtle changes such as the phone numbe
r. They may claim to
be an overseas firm, which won’t always h
ave full contact and
website details listed on the Register.
Share and bond scams are ofte
n run from ‘boiler rooms’ where
fraudsters cold-call investors, offe
ring them worthless,
overpriced or even non-existent shares or bonds. They
use
increasingly sophisticated tactic
s to approach investors,
offering to buy or sell shares, often pressuring inves
tors to
make a quick decision or miss out on the deal. Co
ntact can also
be in the form of email, post or word of mou
th. Scams are
sometimes advertised in newspapers,
magazines or online as
genuine investment opportunities
and may offer free gifts or
discounts on dealing charges.
ShareGift, The Orr Mackintosh
Foundation, 4th Floor Rear,
67/68 Jermyn Street, London SW1Y
6NY, Telephone: +44 (0)20
7930 3737, Website:
shar
egift.org
Computershare Investor Servic
es PLC
The Pavilions
Bridgwater Road
Bristol BS99 6ZZ
Telephone: +44 (0)370
702 0135
Fax: +44 (0)370 703 600
9
Website: www-uk.computershare.com/investor/cont
actus
Shareholder inf
ormation contin
ued
NatWest Group
A
nnual Repor
t and Accou
nts 2021
431
Financial statements
Strategic report
 
Governance
 
Risk and capital management
 
Additional information
 
Financial review
 
How to protect yourself
Always be wary if you’re contacted out of the blue, p
ressured
to invest quickly, or promised r
eturns that sound too good to be
true. FCA authorised firms are unlike
ly to contact you
unexpectedly with an offer to buy
or sell shares or bonds.
 
It is strongly advised that you se
ek independent professional
advice before making any inves
tment.
Report a scam
If you suspect that you have been approached by fr
audsters, or
have any concerns about a potential scam,
report this to the
FCA by contacting their Consumer Helpline on 080
0 111 6768
or by using their reporting form which can be found
on their
website.
If you have already invested in
a scam, fraudsters are likely to
target you again or sell your details to othe
r criminals. The
follow-up scam may be completely
separate, or may be related
to the previous scam in the for
m of an offer to get your money
back or buy back the investment on payment of a fee
.
Analysis of ordinary shareholders
At 31 December 202
1
Shareholdings
Number
 
%
 
 
of shares
 
- millions
 
Individuals
 
172,365
96,720,657
0.84
 
Banks and nominee companies
3,749
5,347,209,748
46.63
 
Investment trusts
40
335,083
 
Insurance companies
3
487,631
 
Other companies
433
26,797,269
0.24
 
Pension trusts
20
33,956
 
Other corporate bodies
 
68
5,996,398,291
52.29
 
 
 
176,678
11,467,982,635
100.00
 
 
 
 
Range of shareholdings:
 
1 - 1,000
152,553
36,685,708
0.32
 
1,001 - 10,000
22,253
51,255,478
0.45
 
10,001 - 100,000
993
30,052,411
0.26
 
100,001
-
 
1,000,000
 
 
520
185,638,204
1.62
 
1,000,001 - 10,000
,000
272
923,070,585
8.05
 
10,000,001 and over
87
10,241,280,249
89.30
 
 
 
176,678
11,467,982,635
100.00
 
 
Important addresses
 
Shareholder enquiries
Registrar
Computershare Investor Servic
es PLC
The Pavilions
Bridgwater Road
Bristol BS99 6ZZ
Telephone: +44 (0)370
702 0135
Facsimile: +44 (0)370 703 6
009
Website: www-uk.computershare.com/investor/cont
actus
ADR Depositary Bank
BNY Mellon Shareowner Services
PO Box 505000
Louisville, KY 40233
-5000
Direct Mailing for overnight packages:
BNY Mellon Shareowner Services
462 South 4th Street
Suite 1600
Louisville KY 40202
 
 
 
Corporate, Governance
NatWest Group plc
PO Box 1000, Gogarburn
Edinburgh, EH12 1HQ
Telephone: 0131 5
56 8555
Investor Relations
250 Bishopsgate, London
EC2M 4AA, England
Registered office
36 St Andrew Square
Edinburgh, EH2 2YB
Telephone: 0131 5
56 8555
Registered in Scotland No. SC4
5551
Website
natwestgroup.com
Telephone: +44 (0)131
556 8555
Email: investor.relations@
natwest.com
Telephone: 1-888-26
9-2377 (US callers – toll free)
Telephone: +1 201 6
80 6825 (International)
Email: shrrelations@
cpushareownerservices.co
m
Website: mybnymdr.com
Ask for their (FRN) and contact
details and then contact them
using the telephone number on the Register
. Never use a link in
an email or website from the firm offering you
an investment.
Please do not give any personal details to any c
aller unless you
are certain that they are genuine
. Check the Register to ensure
the firm contacting you is authorised and also c
heck the FCA’s
Warning List of firms to avoid at
fc
a.org.uk/scamsmart.
Find out more at fca.org.uk/consumers
Shareholder inf
ormation contin
ued
NatWest Group
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nts 2021
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Financial statements
Strategic report
 
Governance
 
Risk and capital management
 
Additional information
 
Financial review
 
Principal offices
NatWest Group plc
PO Box 1000, Gogarburn
Edinburgh, EH12 1HQ
NatWest Markets Plc
250 Bishopsgate, London
EC2M 4AA, England
The Royal Bank of Scotland plc
PO Box 1000, Gogarburn
Edinburgh, EH12 1HQ
250 Bishopsgate, London
EC2M 4AA, England
National Westminster Bank Plc
250 Bishopsgate, London
EC2M 4AA, England
Ulster Bank Limited
11-16 Donegall Square East, Be
lfast, Co Antrim, BT1 5UB,
Northern Ireland
Ulster Bank Ireland DAC
 
Ulster Bank Head Office, Block B
, Central Park, Leopardstown,
Dublin 18, D18 N153
 
NatWest Markets Group Holdings Corp.
251, Little Falls Drive, Wilmington
Delaware, 19808
Coutts & Company
440 Strand, London
WC2R 0QS, England
The Royal Bank of Scotland International Limited
Royal Bank House, 71 Bath Stree
t
St Helier, JE4 8PJ
Presentatio
n of informati
on
NatWest Group
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nnual Repor
t and Accou
nts 2021
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Financial statements
Strategic report
 
Governance
 
Risk and capital management
 
Additional information
 
Financial review
 
 
In the Annual Report and Accounts, unless
specified otherwise, ‘parent company’ refers to NatWest Grou
p plc
, and ‘NatWest
Group’, ‘Group’ or ‘we’ refers t
o NatWest Group plc and its subsidiaries. T
he term ‘NWH Group’ refers to NatWest Holdings
Limited
(‘NWH’) and its subsidiary and associated undertakin
gs. The term ‘NWM Group’ refers to NatWes
t Markets Plc (‘NWM Plc’) and its
subsidiary and associated undertakings. The te
rm ‘NWM N.V.’ refers to NatWest Markets N.V.
The term ‘NWMSI’ refers to NatWest
Markets Securities, Inc. The term ‘RBS plc’ refe
rs to The Royal Bank of Scotland plc. The ter
m ‘NWB Plc’ refers to National
Westminster Bank Plc. The term ‘UBIDAC’ refers to
Ulster Bank Ireland DAC. The term ‘RBSI Limited’ refe
rs to The Royal Bank of
Scotland International Limited. ‘Go-fo
rward group’ excludes Ulster Bank RoI and discontinued
operations.
NatWest Group publishes its financial s
tatements in pounds sterling (‘£’ or ‘sterlin
g’). The abbreviations ‘£m’ and ‘£bn’ rep
resent
millions and thousands of millions of pounds sterling (‘GBP’
), respectively, and references to ‘p
ence’ represent pence where
amounts are denominated in pounds sterli
ng. Reference to ‘dollars’ or ‘$’ are to United
States of America (‘US’) dollars. The
abbreviations ‘$m’ and ‘$bn’ re
present millions and thousands of millions of doll
ars, respectively. The abbreviation ‘€’ represents
the ‘euro’, and the abbreviations ‘€m’ and ‘€bn’
represent millions and thousands of millions of
euros, respectively.
 
 
 
Forward loo
king statem
ents
NatWest Group
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nts 2021
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Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Cautionary statement regarding forward-looking statements
Certain sections in
this document
contain ‘forward-lo
oking statements’ as
that term is defined i
n the United Sta
tes Private Securities
Litigation Reform Act
of 1995, such as st
atements that in
clude the words ‘expect’
, ‘estimate’, ‘proje
ct’,
‘anticipate’,
‘commit’, ‘believe
’,
‘should’, ‘intend’, ‘
will’, ‘plan’, ‘could
’, ‘probability’, ‘risk’, ‘Value-
at-Ri
sk (VaR)’, ‘target’, ‘goal’
, ‘objective’, ‘may’, ‘e
ndeavour’, ‘outlook
’,
‘optimistic’, ‘prosp
ects’ and similar expressi
ons or variations
on these expres
sions. In particular,
this document includ
es forward-looki
ng
targets and guid
ance relating to financial perf
ormance mea
sures, such as inco
me growth, operat
ing expense, cost reducti
o
ns, RoTE, RO
E,
discretionary capital
distribution t
argets, impairment loss
rates, bala
nce sheet reduction, incl
uding the reducti
on of RWAs, CET1 rati
o (
and
key drivers of the CET1
ratio includ
ing timing, impact and de
tails), Pillar 2 and
other regulatory buff
er requirements and
MREL and n
on-
financial performa
nce measures, s
uch as climate and ESG-
related performa
nce ambitions, targets
and metrics, i
ncluding in relatio
n to
initiatives to transiti
on to a net zero econ
omy, Climate and Susta
inable Funding a
nd Financing (CSFF
) and financed emissi
ons. In addition,
this document includes
forward-looking s
tatements relati
ng, but not limited
to: the COVID-19
pandemic and its imp
act on NatWe
st Group;
planned cost reductio
ns, disposal losses
and strategic costs; imp
lementatio
n of NatWest Group’s pu
rpose-led stra
tegy and other stra
tegic
priorities (including
in relation to:
its phased withdra
wal from ROI, the NW
M Refocusing a
nd investment program
mes relating t
o digital
transformation of it
s operations a
nd services and inorga
nic opportunities
); the timing a
nd outcome of litig
ation and governme
nt and
regulatory investig
ations; direct a
nd on-market buy-
backs; funding plans and c
redit risk profile;
managing its cap
ital position; liquidity
ratio;
portfolios; net interest
margin an
d drivers related the
reto; lending and income gr
owth, product
share and growt
h in target segments;
impairments and write-
downs, including wit
h respect to go
odwill; restructuring and
remediation cos
ts and charges; NatWes
t Group’s
exposure to politica
l risk, economic as
sumptions and risk, climat
e, enviro
nmental and sustainab
ility risk, operatio
nal risk, conduct
risk,
financial crime ris
k, cyber, data and IT
risk and credit rati
ng risk and to vari
ous types of market
risk, including i
nterest rate risk, forei
gn
exchange rate risk a
nd commodi
ty and equity price
risk; customer experie
n
ce, including o
ur Net Promotor Score
(NPS); employee
engagement and g
ender balance
in leadership posit
ions.
Limitations inherent to forward-looking
statements
These statements are
based on c
urrent plans, expecta
tions, estimates
, targets and projectio
ns, and are subject to s
ignificant inhere
nt risks,
uncertainties and
other factors, b
oth external and relat
ing to NatW
est Group’s strateg
y or operations
, which may result in NatWe
st Group
being unable to ac
hieve the current pla
ns, expectations, est
imates, targets
, projections and other
anticipated outcome
s expressed
or
implied by such f
orward-looking s
tatements. In addit
ion, certain of these disc
losures are depende
nt on choices relyi
ng on key model
characteristics and ass
umptions a
nd are subject to various limi
tations, includi
ng assumptions
and estimat
es made by management.
By their
nature, certain of
these disclosures are o
nly estimates and, as a
result, act
ual future results, gai
ns or losses
could differ materiall
y from
those that have been
estimated. Accordingly
, undue reliance
should not be placed
on these statem
ents. The forwa
rd-looking statements
contained in this do
cument speak only as
of the date we make
them and we e
xpressly disclaim a
ny obligation or u
ndertaking to upd
ate or
revise any forward-lo
oking stateme
nts contained herein,
whether to reflect
any change in o
ur expectat
ions with regard theret
o, any
change in events,
conditions or ci
rcumstances on whic
h any such sta
tement is based, or other
wise, except to the
extent legally requi
red.
Important factors that could affect the actual
outcome of the forward-looking statements
We caution you t
hat a large numbe
r of important factors c
ould adversely affect
our results or o
ur ability to imple
ment our strategy
, cause
us to fail to meet ou
r targets, pre
dictions, expectations a
nd other a
nticipated outcomes or
affect the accuracy
of forward-loo
king
statements des
cribed in this docum
ent. These factors i
nclude, but are not limited
to, those set fo
rth in the risk factors a
nd the other
uncertainties des
cribed in NatWes
t Group plc’s Annual Rep
ort on Form 20-F a
nd its other filings
with the US Securities a
n
d Exchang
e
Commission. The pri
ncipal risks a
nd uncertainties that c
ould adverse
ly NatWest Group’s future
results, its
financial condition and pr
ospects
and cause them to b
e materially d
ifferent from what is fo
recast or expected, i
nclude, but are
not limited to: economic a
nd political ris
k
(including in respect
of: the impa
ct of the COVID-19 pa
ndemic on NatW
est Group and its custom
ers; political and ec
onomic risks and
uncertainty in the UK
and global
markets; uncertainty
regarding the effects
of Brexit; cha
nges in interest
rates and foreign curre
ncy
exchange rates; a
nd HM Treasury
’s ownership of NatWe
st Group plc); strate
gic risk (including i
n respect of the imp
lementation of Na
tWest
Group’s purpose-led
Strategy; refocusing
of its NWM franc
hise; and
the effect of the COVID-19 p
andem
ic on NatWest Group’s stra
tegic
objectives and targets
); financial res
ilience risk (including i
n respect of: NatWes
t Group’s abili
ty to meet target
s and to make discretio
nary
capital dis
tributions; the competit
ive environment; imp
act of the COV
ID-19 pandemic on the c
redit quality of NatWes
t Group’s
counterparties; co
unterparty and
borrower risk; prudentia
l regulatory requi
rements for capi
tal and MREL; the ad
equacy of NatWes
t
Group’s resolutio
n plans; liquidity
and funding risks; cha
nges in the credit
ratings; the require
ments of regulatory st
ress tests; good
will
impairment; model ris
k; sensitivit
y to accounting policies,
judgments
, assumptions and estimate
s; changes in app
licable accounti
ng
standards; the value
or effectivene
ss of credit protectio
n; and the appl
ication of UK statutory stabi
lisation or resolutio
n powers); climate
and sustainabilit
y risk (including i
n respect of: risks rel
ating to clima
te change and the tra
nsitioning to a
net zero economy; t
he
implementation of Na
tWest Group
’s climate change strat
egy and climat
e change resilient syste
ms, controls a
nd procedures; climate
-related
data and model risk;
the failure to ada
pt to emerging climat
e, environmental a
nd sustainability ris
ks and opportunities
; changes in ESG
ratings; increasing levels
of climate
, environmental and sustai
nability relat
ed regulation and oversig
h
t; and climat
e, environmental a
nd
sustainabilit
y-related litigation, en
forcement proceedings
and investig
ations); operational and
IT resilience risk (i
ncluding in respect
of:
operational risks (i
ncluding reliance o
n third party supplie
rs); cyberattacks
; the accuracy and effect
ive
use of data
; complex IT syste
ms
(including those t
hat enable remote
working); attracting, reta
ining and developi
ng senior manag
ement and skilled p
ersonnel; NatWe
st
Group’s risk manag
ement framework; a
n
d reputational ris
k); and le
gal, regulatory and co
nduct risk (including i
n respect of: the impa
ct of
substantial reg
ulation and oversig
ht; compliance with reg
ulatory requirem
ents; the outcome
of legal, regulatory and g
overnmental act
ions
and investigat
ions; the transition of LIBOR
other IBOR rates
to alternative risk-
free rates; and c
hanges in tax legis
lation or failure to
generate future taxabl
e profits).
Caution about climate and sustaina
ble funding and financing (CSFF) information.
Climate and ESG disclosu
res in t
his report use a greater
number and level
of judgments, ass
umptions and estima
tes, including with
respect
to the classifica
tion of climate and
sustainable funding a
nd financing activities, t
h
an our reporting
of historical fina
ncial information.
These
judgments, assump
tions and estimates
are highly likely to cha
nge over time, a
nd, when couple
d with the longer time
frames used i
n these
disclosures, make a
ny assessmen
t of materiality inhe
rently uncertain. In ad
dition, our climate risk a
nalysis
and net zero strategy rema
in
under developme
nt, and the data
underlying our analys
is and strategy rema
in subject to evoluti
on over time. As a res
ult, we expect t
hat
certain climate and ES
G disclosure
s made in this report a
re likely to be ame
nded, updated, recalcul
ated or restated in the future. T
his
forward-looking sta
tement shoul
d be read together wit
h the ‘Climate
-related and other forward-l
ooking statements and metrics’
of the
NatWest Group 2021 C
limate-rela
ted Disclosures Report.
The information, stat
ements and opi
nions contained in this d
ocument do n
ot constitute a public
offer under any ap
plicable legi
slation or an
offer to sell or a s
olicitation of an offer t
o buy any securitie
s or financial instrume
n
ts or any advice
or recommendat
ion with respect t
o such
securities or other fi
nancial instruments.
NatWest Group plc
36 St Andrew Square
Edinburgh, EH2 2YB
www.natwestgroup.com
NatWest Group plc
2021 Annual Report and Accounts
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