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NatWest Group plc
2022 Annual Report and Accounts
Championing
A relationship bank for
a digital world
potential
Chairman:
Howard Davies
Executive directors:
Alison Rose DBE (Group CEO)
Katie Murray (Group CFO)
Non-executive directors:
Frank Dangeard
Roisin Donnelly
Patrick Flynn
Morten Friis
Yasmin Jetha
Mike Rogers
Mark Seligman
Lena Wilson
Our 2022 reporting suite brings together key reports, including NatWest Group’s Annual Report and
Accounts, Climate-related Disclosures Report which includes the initial iteration of our Climate transition
plan and Environmental, Social and Governance Disclosures Report. The reports are intended to provide
useful information to our stakeholders and are available at natwest.com.
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
Progress against our
climate ambitions including
the initial iteration of our
Climate transition plan. The
report covers climate-related
governance, strategy, risk
management (including
scenario analysis) and
metrics and targets.
ESG Disclosures
Report and ESG
Frameworks Appendix
An overview of key progress
across environmental, social
and governance matters
(ESG), and frameworks
appendix prepared with
reference to industry-wide
sustainability standards.
Approval of Strategic report
The Strategic report for the year ended 31 December 2022
set out on pages 1 to 71 was approved by the Board of
directors on 16 February 2023.
By order of the Board
Jan Cargill
Chief Governance Officer and Company Secretary
16 February 2023
At www.natwestgroup.com
potential
Championing
A relationship bank for
a digital world
NatWest Group plc
2022 Climate-related Disclosures Report
NatWest Group plc
Annual results for the year
ended
31 December 2022
and
Q4 2022 Financial supplement
1
Strategic report
1
Championing potential
2
Financial performance
3
Operational highlights
4
Chairman’s statement
6
Group Chief Executive’s review
10
Investment case
11
Outlook
12
Our purpose framework
14
Enterprise case study
16
Market environment
18
Our business model
22
Our strategy
24
Key performance indicators
26
Our purpose-led areas of focus
28
Learning case study
29
Business performance
30
Retail Banking
32
Private Banking
34
Commercial & Institutional
72
Financial review
84
Governance and
remuneration
176
Risk and capital
management
284
Financial statements
428
Additional information
36
Our stakeholders
40
Section 172(1) statement
42
Stakeholder focus areas
42
Customers
45
Investors
46
Colleagues
50
Communities
52
Suppliers
52
Regulators
52
Respecting human rights
53
Climate case study
54
Our climate strategy
56
Climate transition plan overview
58
Task Force on Climate-Related
Disclosures (TCFD) summary
62
Own operational footprint
64
Risk management
68
Viability statement
70
Non-financial information
statement
Inside this report
We are driven by our purpose and enabled by our strategy.
We remove barriers to create strong enterprises. We turn ambition
into action to help tackle climate change. And we build financial capability
through learning.
By supporting our customers at every stage of their lives, we can build
long-term value, invest for growth, make a positive contribution to society
and drive sustainable returns for shareholders.
Championing
potential
A relationship bank
for a digital world
1
NatWest Group
| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
In an uncertain environment, we delivered a strong financial performance
while also supporting our customers, responsibly growing our lending and making
significant investments to transform the bank.
Our purpose underpinned by
our financial strength
Financial performance
Robust balance sheet
Net lending to
customers
£366.3bn
(2021: £359.0bn)
£450.3bn
(2021: £479.8bn)
Customer deposits
Net lending to customers increased by £7.3 billion, 2.0%, with
growth balanced across the bank. Mortgage growth continued
and wholesale lending was strong. We provided £24.5 billion
(*)
of
climate and sustainable funding and financing in 2022, bringing
the cumulative contribution to £32.6 billion against our target to
provide £100 billion between 1 July 2021 and the end of 2025.
Customer deposits decreased by £29.5 billion, or 6.1%
principally reflecting a reduction in Commercial & Institutional,
particularly non-operational accounts in Financial Institutions
and professional services with relatively low margin and funding
value, and a £12.2 billion reduction due to our withdrawal from
the Republic of Ireland.
Strong financial performance
Income
£13,156m
(2021: £10,429m)
£7,687m
(2021: £7,758m)
£5,132m
(2021: £3,844m)
£3,340m
(2021: £2,950m)
Operating expenses
Profit before tax
Profit attributable to
shareholders
We delivered a strong financial performance and achieved our
targets. Total income increased by £2,727 million, or 26.1%,
and return on tangible equity was 12.3%.
Other operating expenses, for the Go-forward group
(1)
, were
£201 million, or 2.9% lower than 2021, in line with our cost
reduction target of around 3%
(2)
. We have made good progress
on our phased withdrawal from the Republic of Ireland.
Our net impairment charge of £337 million for 2022 principally
reflects revisions of scenario weightings, with levels of default
remaining low.
(1) Go-forward group excludes Ulster Bank RoI and discontinued operations.
(2) Go-forward group expenses excluding litigation and conduct costs were
£6,648 million (2021 – £6,849 million).
Strong capital generation supports substantial distributions
CET1 ratio
14.2%
(1)
(2021: 18.2%)
£5.1bn
(2)
(2021: £3.8bn)
£176.1bn
(1)
(2021: £157.0bn)
30.3p
(2021: 10.5p)
Total capital returned
to shareholders
RWAs
Dividend per share
(paid and proposed)
The common equity tier 1 (CET1) ratio remains robust at 14.2%,
or 14.0% excluding IFRS 9 transitional relief. Risk-weighted
assets (RWAs) of £176.1 billion decreased by £0.2 billion
compared with 1 January 2022
(1)
as lending growth and model
changes were offset by disposal activity in Ulster Bank RoI.
A final dividend of 10.0 pence per share is proposed, and we
intend to commence an ordinary share buyback programme
of up to £800 million in the first half of 2023, taking total
distributions deducted from capital in the year to £5.1 billion,
or 53 pence per share.
(1) On 1 January 2022 the proforma CET1 ratio was 15.9% and RWAs were
£176.3 billion following regulatory changes.
(2) Paid and proposed.
(*)
Within the scope of EY assurance. Refer to page 70.
NatWest Group
| 2022 Annual Report and Accounts
2
Delivering on income growth, efficiency and capital returns
Operational highlights
2022
2021
2020
Growth
Loans to customers – amortised cost
£366.3bn
£359.0bn
£360.5bn
AUM net new money
£2.0bn
£3.0bn
£1.5bn
Gross new mortgage lending in Retail Banking
£41.4bn
£36.0bn
£31.5bn
Percentage of customers exclusively using digital channels to interact with us
Retail Banking
63%
(*)
60%
58%
Simplification
Operating expenses
£7,687m
£7,758m
£7,858m
Artificial intelligence – Retail Banking conversations with Cora our virtual assistant
10.4m
(*)
10.7m
8.4m
Video banking interactions (2022 for the year and 2021/2020 per week)
0.33m
(*)
10,200
3,300
Capital
Dividend per share (paid and proposed)
30.3p
10.5p
3p
Total dividend (paid and proposed)
£3.1bn
£1.2bn
£0.4bn
Directed buyback
£1.2bn
£1.1bn
On-market buyback
(1)
£0.8bn
£1.5bn
Total capital returned to shareholders
£5.1bn
£3.8bn
£0.4bn
Risk-weighted assets (RWAs)
£176.1bn
157.0bn
170.3bn
CET1 ratio
14.2%
18.2%
18.5%
Return on tangible equity
12.3%
9.4%
(2.4%)
(1) Included in the year proposed.
(*)
Within the scope of EY assurance. Refer to page 70.
3
NatWest Group
| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
2022 proved to be another extraordinary year.
The UK inflation rate reached a 40-year high, and Russia’s
invasion of Ukraine not only inflicted devastation on the country
and its people, but also led to volatility in energy and financial
markets, as well as heightened costs and uncertainty for
businesses and consumers around the world.
In response to the surge in inflation, the Bank of England’s
Monetary Policy Committee voted to increase the Bank Rate
from 0.5% in February 2022 to 3.5% in December 2022.
Against a difficult and uncertain economic backdrop, NatWest
Group delivered a strong financial performance in 2022. We
saw continued growth in our lending and progress against our
strategy. The bank’s share price rose by 17.5% over the year,
outperforming our major UK competitors, while during 2022
the UK Government’s shareholding fell from 53% to 46%.
Clearly, the outlook for 2023 remains challenging, with declines
in economic activity expected and a further tightening of
consumer spending and real incomes. Indications of weakening
housing market activity are also emerging. The UK labour
market, however, remains strong, with the unemployment
rate at 3.7%
(1)
.
As a bank with 19 million customers in the UK – and an
employer of around 60,000 people worldwide – we know that
many are worried about this economic outlook and its impact
on their own financial situation. In the Stakeholder focus area
of this report (pages 42–43) we explain the work we have been
doing to help our customers, especially those in vulnerable
situations, to navigate through this difficult period.
NatWest Group has a high-quality, well-diversified loan book
where we are not yet seeing any material signs of deterioration,
and credit losses remain low. However, we continue to monitor
customer activity and behaviours closely for signs of stress,
taking action where appropriate.
‘The bank’s financial strength,
and that of our business
segments, allowed us to grow
our lending throughout 2022,
while investing to create a
simpler and better banking
experience for our customers.’
Howard Davies
Chairman
£5.1 billion
shareholder distributions paid and
proposed for 2022
Dividend per share (paid and proposed)
30.3p per share
Resilient for
Chairman’s statement
the long term
(1) UK labour market overview in January 2023.
NatWest Group
| 2022 Annual Report and Accounts
4
Our strong financial performance, continued capital generation
and robust balance sheet mean that we are able to stand
alongside customers, colleagues and communities; providing
practical, proactive support as they face into this challenging
economic environment.
The bank’s financial strength, and that of our business
segments, allowed us to grow our lending throughout 2022,
while investing to create a simpler and better banking
experience for our customers.
Looking back at the three years since we set out our purpose-
led strategy, there is a strong track record of success. The
Board is fully supportive of our strategy: building on the progress
we have made; diversifying our business in order to generate
sustainable growth and returns through the economic cycle.
In total, we paid and proposed £5.1 billion of capital returns to
shareholders in 2022. As well as paying a £364 million interim
dividend and a £1.0 billion final dividend, we paid a special
dividend of £1.75 billion along with a share consolidation.
We were also pleased to complete our second directed
buyback of £1.2 billion of UK Government shares in March
2022 and we maintain capacity to do more in future. In addition,
we completed our second £750 million on-market buyback
announced in February 2022 and we will consider further
buybacks of that kind.
The drop in the UK Government’s shareholding to below
50% for the first time since the financial crisis was a significant
moment. While it had no material effect on the way the bank
operates, it was an important milestone, underlining the
progress we have made.
NatWest Group’s strong financial performance has been
reflected in the bonus pool for 2022, which has increased
from the previous year as our profits rose, while we continue
to demonstrate restraint given the market conditions. We kept
pay under review through 2022 as the increasing cost of living
impacted our people. We focused support on those colleagues
working in lower-paid roles, with a permanent pay rise in
September 2022 and a one-off cost of living payment
announced in December 2022.
We also agreed a 2023 pay package which was supported by
our employee representatives and their members, and which
recognises the impact inflation is having on spending power,
with many colleagues receiving a pay rise of at least £2,000.
There was also strong support at our annual general meeting
(AGM) in April 2022 for the Board’s recommended changes to
normalise executive pay policy and to bring it in line with other
UK banks.
The changes will result over time in a more competitive policy
for our most senior leaders, recognising the strong progress
that has been made against our strategy in recent years.
Around two-thirds of pay will continue to be delivered in shares,
aligning it to the long-term interests of the bank and its investors.
Board succession planning was a key area of focus in 2022, as
two of our long-standing directors approached the end of their
tenure on the Board.
In December 2022 we said farewell to Robert Gillespie,
who resigned as a non-executive director after nine years.
To allow for an orderly handover of responsibilities, Robert
stepped down as Chair of the Group Performance and
Remuneration Committee in September 2022 and was
succeeded by Lena Wilson.
Robert expertly chaired the Group Performance and
Remuneration Committee from 2018 until 2022, successfully
navigating a period of continued change for the bank. I would
like to thank him for his tremendous contribution over the years.
We have benefited greatly from his wisdom and experience.
In October 2022, we were pleased to welcome Roisin
Donnelly to the Board as an independent non-executive
director. Roisin has an impressive executive track record in
customer experience, data and digital transformation, together
with significant board experience, and brings valuable
perspectives to Board discussions.
And in December 2022, we announced that Stuart Lewis will
join the Board as a non-executive director in April 2023. Subject
to regulatory approval, Stuart will be appointed as Chair of the
Group Board Risk Committee on 1 August 2023. He will replace
Morten Friis, who has confirmed his intention to step down as a
non-executive director in July 2023.
Mike Rogers has also confirmed he will be stepping down as
a non-executive director in April 2023, in order to take up the
role of Chairman of Admiral Group plc. I would like to record my
thanks to both Morten and Mike for their commitment, diligence
and immense contributions as non-executive directors.
During a period of significant change in the external
environment, the Board was kept regularly informed by
management on the impacts of geopolitical and economic
developments on the bank and its customers.
Strategy and climate were also high on the Board’s agenda.
Following strong shareholder support at our AGM for our ‘Say
on Climate’ resolution, the Board continued its close oversight of
progress towards our climate ambitions ahead of the publication
of the initial iteration of our Climate transition plan.
As they did during the COVID-19 pandemic, Alison and her
leadership team have used the bank’s purpose to support our
commercial and retail customers while growing the business
and delivering against the strategic priorities.
The Board is pleased with the progress that has been made
over the last three years and supports the priorities that Alison
and her capable team have set out.
I would also like to take this opportunity to congratulate Alison
on being appointed a Dame in the New Year Honours List in
December 2022, which recognised her contribution to the
financial services sector.
While we are operating in an uncertain landscape, I am
confident that NatWest Group’s strategy will continue to
ensure that we can support all of our stakeholders through
the challenges and opportunities in the years to come.
Howard Davies
Chairman
5
NatWest Group
| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Group Chief Executive’s review
‘We champion the potential of
the people, families and businesses
we serve – when things are going
well, and when things are tough.
By standing strong and standing
together, we can provide the
support and security our
customers, colleagues,
economy and society need.’
Alison Rose DBE
Group Chief Executive Officer
In 2022, as the country recovered from the COVID-19
pandemic, we witnessed economic conditions not seen
in generations. The highest inflation rate in decades, rising
interest rates, a steep increase in energy costs and supply chain
disruption had a huge impact on people’s lives. This meant that
being guided by our purpose to support our stakeholders and
drive long-term sustainable value was as important as ever.
In light of these challenging economic circumstances, we
focused on putting in place proactive support to help people,
families and businesses to manage, and to help alleviate the
financial pressures being felt by those who were most vulnerable.
The strength of our balance sheet has allowed us to stand
alongside our customers and help them to navigate this
heightened uncertainty, as well as delivering a strong financial
performance for NatWest Group and value for shareholders.
Support for the cost of living
We responded quickly and meaningfully, proactively contacting
our customers to offer support and information on the cost of
living. In addition, we carried out c.0.7 million financial health
checks in 2022 and launched our credit score feature in our
mobile app to help customers understand their credit score. Our
online cost of living hub was also established to share resources
and tools, informing customers of the support that is available to
them, as well as support through third parties. These measures
were in addition to £4 million in donations to provide grants and
support, delivered in collaboration with organisations including
Citizens Advice, The Trussell Trust, Step Change and PayPlan.
As one of the leading banking partners of UK business, we
have taken a range of actions on charges, waiving fees on
some products where appropriate, including freezing standard
published tariffs on Business Current Accounts for 12 months
to help SMEs, and offering free card machine hire for new
customers on our payment service Tyl.
for a digital world
A relationship bank
NatWest Group
| 2022 Annual Report and Accounts
6
For our commercial customers, we were able to deliver tailored
support to the most impacted sectors, including a £1.25 billion
lending package for our c.40,000 agriculture customers, as
well as providing c.51,700 financial health checks for our
business customers.
Supporting our colleagues during this period has continued to
be a key focus. In addition to the pay review in April 2022,
and following consultation with our recognised employee
representatives in September 2022, we put in place targeted
action to provide long-term support for colleagues through a
permanent increase in base pay for our lowest-paid colleagues,
globally. This brought total investments in pay of around
£115 million per annum in 2022, an increase of 85% on 2021.
We agreed further measures for 2023 which include a one-off
£1,000 cost of living cash payment for c.42,000 colleagues in
the UK, Republic of Ireland and Channel Islands, and c.60,000
people globally. The 2023 pay proposal also includes a minimum
increase of £2,000 for almost all of the colleagues covered by it.
Taken together, this will mean that c.80% of lower-paid
colleagues covered by our negotiated pay approach will receive
an increase, plus a cash payment, equivalent to 10% or more of
their fixed pay. In the UK, our rates of pay continue to exceed
the ‘Living Wage Foundation’ benchmarks and, for our major
hubs outside the UK, we continue to pay above the minimum
and living wage rates in the Republic of Ireland as well as
exceeding the minimum wage benchmarks in India and Poland.
Delivering on our strategy
Of course, these actions – driven by our purpose – are not just
the right thing to do, but they are key to building a long-term,
profitable organisation and are underpinned by the strong
foundations of our strategy. Our operating profit for 2022
of £5.1 billion increased from £3.8 billion the year before.
Pleasingly, this was driven by strong performance across all
business segments and enabled from a position of responsible
and sustainable lending. We also continued to make progress
against our financial targets. Other operating expenses, for
the Go-forward group
(1)
, were £201 million, or 2.9% lower than
2021, in line with our cost reduction target of around 3%
(2)
,
and we retain a CET1 ratio of 14.2%, in line with our target.
Against an uncertain economic outlook, the strength of our
balance sheet and the quality of our loan and deposit base
allow us to continue lending responsibly while also helping our
customers to navigate the challenges they are facing. Net
lending balances increased by £7.3 billion, 2.0%, with growth
balanced across the bank. Mortgage growth continued and
wholesale lending was strong across the whole book. Customer
deposits did decrease by £29.5 billion, or 6.1%. However, this
principally reflected a reduction in our Commercial & Institutional
segment, and a £12.2 billion reduction due to our withdrawal
from the Republic of Ireland.
This strong capital position and continued capital generation
means 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 £5.1 billion
shareholder distributions paid and proposed for 2022 through
dividends and buybacks. Against this backdrop, we also
returned to majority private ownership during 2022 with
the UK Government’s stake falling below 50%, which was
a symbolic milestone for our bank.
It is from this basis of progress and profitability that we are
amplifying our strategy, accelerating what we’re doing but also
being mindful of new opportunities and challenges we and our
customers face. We aim to create ever closer and deeper
relationships with our customers at every stage of their lives –
support that starts earlier, reflects their values and meets their
changing needs. It is a simple principle: if our customers thrive,
so will we.
And our purpose, to champion potential, helping people, families
and businesses to thrive, which has guided us through the last
few years, is here to stay. Through our three areas of focus
– climate, enterprise, and learning – we believe we can make
a meaningful contribution to our customers and society and
create long-term value for all our stakeholders. This allows us
to build on our track record of delivery, to move forward with
confidence and pace and to compete effectively in a rapidly
changing external market. The result will be a more sustainable
business with more diverse income streams, able to support our
customers and generate sustainable growth.
New and emerging social, commercial and economic
trends are shaping our customers’ financial lives and there are
important opportunities to transform our relevance and value to
customers, building on their trust. We will do this by delivering
personalised solutions throughout customers’ lifecycles;
embedding our services in our customers’ digital lives;
and supporting customers’ sustainability transitions.
Our values in action
Our values are at the heart of how we deliver our purpose-led
strategy. In 2021, 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 of being inclusive, curious, robust, sustainable
and ambitious were launched in 2022 and now form an integral
part of our identity (read more in our Stakeholder focus area
on page 47).
Indeed, these values are evident in the contributions we have
been making to communities and wider society during 2022.
With the tragic events from Russia’s invasion of Ukraine
dominating our thoughts for most of the year, it has been
incredibly humbling to witness the collective response for
those affected. Donations from NatWest Group colleagues and
customers to the DEC Ukraine Humanitarian Appeal exceeded
£10 million. In addition, NatWest Group pledged £100,000 to
support 500 Ukrainian students to continue their studies at
Polish universities and polytechnics. We also made Gogarburn
House, in the grounds of our head office in Edinburgh, available
to the Scottish Government and Edinburgh City Council as
a welcome centre for people displaced from Ukraine and
offered assistance to refugees wishing to open bank accounts.
Meanwhile, our colleagues provided relief aid at the Polish–
Ukrainian border and opened their homes to Ukrainian families.
We continue to invest in the future of not just our colleagues,
but future generations. We have been delighted to collaborate
with footballer and campaigner Marcus Rashford MBE and
the National Youth Agency (NYA) to provide NatWest Thrive, a
unique programme for young people to develop their self-belief
as well as their money confidence. Early feedback from the pilot
scheme was incredibly encouraging, delivering a 63% uplift in
participants’ confidence about their futures.
(1) Go-forward group excludes Ulster Bank RoI and discontinued operations.
(2) Go-forward group expenses excluding litigation and conduct costs were £6,648 million (2021 – £6,849 million).
7
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ADDITIONAL INFORMATION
NatWest Thrive has since been rolled out to 15 clubs, reaching
over 800 young people across the UK with plans to scale
much further. NatWest Group will also transfer £3 million of
its apprenticeship levy to the NYA to support the training of
200 youth workers.
Learning is a key focus area for the business. And whether
this is through the ongoing successes of our MoneySense and
CareerSense schemes helping young people with financial
advice and employability, our Talent Academy, or our social
mobility apprenticeship programmes, we have ensured that we
continue to help break down the barriers for people to succeed
and thrive.
To help build financial capability early on, we also launched
NatWest Rooster Money. The pocket money product helps
children develop money confidence and positive habits around
saving and spending, nurturing financial resilience in the next
generation. We have built a smooth connection to Rooster
Money via the main mobile app and there have been
c.89,000 Rooster Money card openings in 2022.
Elsewhere, in collaboration with Meta, we launched a
package of support for female entrepreneurs through the
#SheMeansBusiness programme, which selected 50 of the most
promising female entrepreneurs from c.3,600 applicants to form
a dedicated support community, with sessions delivered by our
Enterprise Delivery Team over a six-month period. And to shine
a light on women running thriving businesses in the face of
current economic challenges, we were delighted to launch with
The Telegraph
, the ‘100 Female Entrepreneurs to Watch’ list.
Alongside Aston University, we also published the report ‘Time
to change: A blueprint for advancing the UK’s ethnic minority
businesses’, which sets out recommendations for policymakers,
companies and entrepreneurs to advance the growth potential
of ethnic minority businesses.
I was also immensely proud of the announcement of our new
partner leave policy
(1)
, which supports all eligible colleagues with
significantly more time away from work to help their partner
look after their new child, whether the child has arrived
through birth, adoption or surrogacy.
The net-zero opportunity
Through funding, refinancing and supporting people, families
and businesses to transition to net zero, we want to help create
a sustainable future for our customers, communities and our
planet. It is why addressing the climate challenge – one of the
biggest issues of our time – is a key strategic priority for the
bank. It sits at the heart of our purpose, because we know that
tackling climate change is the right thing to do both societally
and commercially.
We have made significant progress in turning our climate
ambition into action since setting out our climate strategy in
2020. As a founding member of the Net Zero Banking Alliance
(NZBA) and the Glasgow Financial Alliance for Net Zero
(GFANZ), and as a principal partner of COP26, in 2021 NatWest
Group established itself as one of the leading voices for finance
on tackling climate change.
During 2022, I was delighted to see that our momentum
continued. Our global approach was again in evidence at
COP27, where we worked alongside the UK Government to
support the UK Pavilion, co-hosting several high-profile events
with customers and key stakeholders such as the Sustainable
Markets Initiative. Closer to home, through our first climate
resolution, the Board gave shareholders their ‘Say on Climate’,
asking them to support our strategic direction on climate
change at the AGM. 92.58% of votes cast were in favour of
the resolution, indicating strong support for our climate strategy.
NatWest Group has also become the first UK bank, and one
of the largest banks globally, to have science-based targets
validated by the Science Based Targets initiative (SBTi). These
targets underpin the initial iteration of our Climate transition
plan (published in our 2022 Climate-related Disclosures Report),
which outlines the steps we aim to take to at least halve the
climate impact of our financing activity by 2030, thereby
contributing to the UK’s net-zero strategy, and to reach net
zero by 2050 across our financed emissions, assets under
management and operational value chain.
But we know that we can, and must, do more. We also want to
provide the practical solutions to help our customers transition
to net zero. By delivering initiatives such as our Greener Homes
Retrofit pilot, launching our EPC rating tool in our digital
mortgage hub and launching our new Carbon Planner for UK
business, we are enabling our customers to identify potential
cost and carbon savings.
Importantly, I believe these actions are not only good for
the planet, but good for business too. With the right support,
the UK’s SMEs could create up to 260,000 new jobs, produce
around 40,000 new businesses and deliver an estimated
£175 billion revenue opportunity for the UK economy by 2030
(2)
.
Of course, this is not something any individual organisation
can do on its own. Support from policymakers as well as
collaboration across the private sector will be vital for mobilising
the finance necessary to fund the infrastructure of future green
economies. Initiatives such as Carbonplace, where NatWest
Group has joined forces with other financial institutions to create
a global carbon credit transaction network, or the Sustainable
Homes and Buildings Coalition, which NatWest Group launched
with British Gas and Worcester Bosch to improve UK buildings’
energy efficiency, are great examples of how this cross-industry
collaboration can have meaningful real-world impact.
Group Chief Executive’s review
continued
(1)
Our partner leave policies will replace existing paternity leave policies from 1 January 2023 across our operations in the UK, Offshore, Republic of Ireland, US, Poland and India.
(2)
This Springboard to Sustainability Report (i) has been prepared by NatWest Group for information and reference purposes only; (ii) is intended to provide non-exhaustive, indicative
and general information only; (iii) does not purport to be comprehensive; and (iv) does not provide any form of legal, tax, investment, accounting, financial or other advice. The key
findings, estimates and projections in this report are based on various industry and other information and are based on assumptions and estimates and the result of market research,
and are not statements of historical fact. Whilst the information of this report is believed to be reliable, it has not been independently verified by NatWest Group and NatWest Group
makes no representation or warranty (express or implied) of any kind, as regards the accuracy or completeness of this information, nor does it accept any responsibility or liability
for any loss or damage arising in any way from any use made of or reliance placed on, this information. Unless otherwise stated, any views, forecasts, or estimates included in this
report are solely those of the NatWest Group Economics Department, as of this date and are subject to change without notice.
(3)
Green Mortgages are available to all intermediaries for all residential and Buy to Let properties with an energy performance rating of A or B and specific new build developer
properties. Available for Purchase, Porting & Re-mortgage applications.
NatWest Group
| 2022 Annual Report and Accounts
8
We have now provided £32.6 billion of climate and sustainable
funding and financing against our target to provide £100 billion
between 1 July 2021 and the end of 2025, which includes
£27.2 billion across Commercial & Institutional (C&I), as well as
mortgage lending for EPC A and B homes totalling £5.1 billion in
Retail Banking and £0.2 billion in Private Banking. And, delivered
in collaboration with fintech firm Cogo, our carbon-tracking tool
for retail customers had 334,500 unique users in 2022, a clear
indication of the demand that our customers have for
understanding the carbon footprint of their daily spending.
Conclusion
2022 has shown us the importance of being a purpose-led
bank. But it has also shown us what it takes to be purpose-led.
Against a volatile economic backdrop, we continue to
demonstrate the strength and resilience of our business,
delivering a strong financial performance while supporting our
customers and putting in place proactive support to help those
who are most vulnerable.
To continue to do this, we are evolving our capabilities.
Underpinned by the strong foundations of our strategy, we are
investing in our technology and colleagues so we can serve our
customers in new ways that make their lives easier. Our focus
now is on the opportunities those relationships offer for growth:
for our customers, for our economy and, as a result, for
the bank.
Sustainable growth will come from building closer relationships
that better serve our customers at every stage of their lives.
These relationships will be based on insight, understanding,
and shared goals, powered by data-driven innovation. This
will enable us to make a real difference to our customers’ lives
by providing the right advice, products and support to unlock
potential. We will also strengthen our relationships by working
with partners to ensure we deliver the services and products
customers expect, when they want them, tailored to fit
their lives.
By getting closer to our customers, by offering them an
ever-better service, day in, day out, we create sustainable
growth for the bank because those customers, over a lifetime,
will recommend us to others and use us in more parts of
their lives.
We’ve always known relationships matter, and now we are
doing more than ever before to harness them. By providing the
support and security our customers, colleagues, economy and
society need, together we can help build a more sustainable
future for people, families, businesses and the planet.
Alison Rose DBE
Group Chief Executive Officer
The initial iteration of our Climate transition plan
focuses on the delivery of our 2030 decarbonisation
ambitions. This will form the basis for further work on
our journey to net zero by 2050 across our financed
emissions, Assets under Management and our
operational value chain. We have used available
guidance, including GFANZ, Transition Planning
Taskforce and the Task Force on Climate-related
Financial Disclosures (TCFD) recommendations, to
inform the development of our transition plan.
A strategic tool, the initial iteration of our Climate
transition plan will be developed and enhanced
further as we move towards 2030 and beyond. Read
more in our 2022 Climate-related Disclosures Report.
Our ambition to be a leading bank in the UK helping
to address the climate challenge is a core part of our
purpose-led strategy. For more information of our
purpose in action, watch Alison Rose’s interview online:
The initial iteration
of our Climate
transition plan
Watch the
interview online
The QR code above directs to a video on our 2022 Annual Report
webpage. None of the information on that webpage (including the video)
is, or should be read as being, incorporated by reference into this report.
9
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FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Supporting customers
at every stage of
their lives
Powered by innovation
and partnerships
Simple to deal with
Sharpened capital
allocation
Investment case
Our purpose-led strategy
is delivering
Our strategic priorities
Our investment case over the medium term
Pay out ratio of 40% +
capacity to participate
in buybacks
Strong market positions across our three business segments
Well-positioned for targeted growth
All-weather balance sheet, operating with a CET1 ratio in the range of 13–14%
Sustainable medium-term RoTE of 14–16%
We have identified three key growth areas where we can amplify our strategy:
Delivering personalised solutions
throughout customers’ lifecycles –
every customer is an individual.
Supporting our customers’
sustainability transitions.
Embedding our services in our
customers’ digital lives – being
where our customers are.
Customer needs and expectations are continuing to change ever more rapidly; new and emerging social, commercial
and economic trends are shaping the future of their financial lives.
Disciplined expense and risk management, targeting a cost:income ratio
(excl. litigation and conduct) of <50% by 2025
(1)
NatWest Group
| 2022 Annual Report and Accounts
10
Outlook
Outlook
(1)
(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 of the 2022 NatWest Group plc Annual Report and Accounts. These statements constitute forward-looking statements.
Refer to Forward-looking statements in this document.
Outlook 2023
We continue to expect to achieve a return on tangible equity
for the Group of 14-16%.
Income excluding notable items for the Group is expected
to be around £14.8 billion and full year NIM around 3.20%,
based on a Bank of England base rate of 4.00% through
the remainder of 2023.
We expect to deliver a Group cost:income ratio (excl.
litigation and conduct) below 52% or around £7.6 billion
of Group operating costs, excluding litigation and
conduct costs.
Impairment losses in 2023 are expected to be in line with
our through the cycle guidance of 20-30 basis points.
Capital and funding
We expect to generate and return significant capital to
shareholders through 2023.
We expect to pay ordinary dividends of 40% of attributable
profit, and maintain capacity to participate in directed
buybacks from the UK Government, recognising that any
exercise of this authority would be dependent upon HMT’s
intentions and limited to 4.99% of issued share capital in any
12-month period.
We will also consider further on-market buybacks as part of
our overall capital distribution approach as well as inorganic
opportunities where the strategic case and returns are
suitably compelling.
As part of the Group’s capital and funding plans we intend
to issue between £3 billion to £5 billion of MREL-compliant
senior instruments in 2023, with a continued focus on
issuance under our Green, Social and Sustainability Bond
Framework, and up to £1 billion of Tier 2 capital instruments.
NatWest Markets plc’s funding plan targets £3 billion to
£5 billion of public benchmark issuance.
Medium term
We continue to target a sustainable return on tangible
equity for the group of 14-16% over the medium term.
We expect to deliver a Group cost:income ratio
(excl. litigation and conduct) of less than 50%, by 2025.
We expect that RWAs could increase by a further 5-10%
by the end of 2025, including the impact of Basel 3.1.
We expect to continue to generate and return significant
capital via ordinary dividends and buybacks to shareholders
over the medium term and continue to expect that the CET1
ratio will be in the range of 13-14%.
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 our current expectations for interest rates and economic activity.
11
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ADDITIONAL INFORMATION
NatWest Group champions potential, helping people,
families and businesses to thrive.
Because when they thrive, so do we.
Read more on pages 6–9
We are guided by
our purpose
Read more on pages 36–39
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
Read more on pages 22–23
Read more on pages 26–27
We have four
strategic priorities…
Supporting customers at
every stage of their lives
Suppliers
Simple to deal with
Sharpened capital allocation
Powered by innovation
and partnerships
A relationship bank
for a digital world
Customers
Regulators
Communities
Colleagues
Investors
Enterprise
…creating a
positive impact
through our areas
of focus
Our ambition is to remove barriers to enterprise and
to provide businesses in the UK the support they need to grow.
Read the story on page 14
Climate
We have made addressing the climate challenge and supporting our
customers in their transition to net zero a key strategic priority.
Read the story on page 53
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.
Read the story on page 28
Our purpose framework
NatWest Group
| 2022 Annual Report and Accounts
12
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
Our purpose
We aim to balance the different interests of our stakeholders –
customers, investors, regulators, colleagues, communities, 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 stakeholders
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 strategy
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, Enterprise and Learning.
Our positive impact
Our values are at the heart of how we deliver our purpose-led
strategy. In 2022, having engaged with colleagues, customers,
community stakeholders and suppliers, we launched our
refreshed values of being inclusive, curious, robust, sustainable
and ambitious. These refreshed values now form an integral
part of our cultural identity.
We continue to partner with the Blueprint for Better Business,
whose framework informs our purpose-led decision-making
and helps us to create and protect value for customers,
suppliers, colleagues, communities, future generations and our
shareholders. Read how we have created value for stakeholders
and society in 2022 on pages 20 and 21, and refer to our key
performance indicators on pages 24 and 25.
Our values
Better Business
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 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.
13
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ADDITIONAL INFORMATION
Building strong
relationships
to help businesses
thrive
Supporting dynamic businesses
Championing the potential of UK
businesses is about more than just providing
financial backing.
For us, it’s about understanding ambition and helping to remove
the barriers to enterprise. We know we can play a key role in
inspiring future generations to develop their skills, experience
and business ideas, and ultimately to achieve their goals.
A great example of this is our support for Birmingham-based
social enterprise Miss Macaroon. Founded by Rosie Ginday
MBE in 2011, the company combines a passion for producing
premium-quality food and a desire to help young people gain
the skills and confidence to change their lives.
Starting life with a small kitchen space and just £500 in capital,
Miss Macaroon has now produced over three million macaroons
for global brands, royalty and a host of celebrities, as well as
becoming one of the region’s leading employability programmes.
We were first able to support Rosie through the NatWest Group
Accelerator programme by providing one-to-one coaching,
access to mentors and industry experts, and networking with a
community of like-minded entrepreneurs, as well as hot-desking
space at our commercial offices in Birmingham. Through the
Accelerator, Rosie received support to expand her company
and open multiple retail outlets across the Midlands.
The company has gone from strength to strength, expanding
its operations from individual customer orders to catering for
wholesale businesses. With the development of a unique
colour-matching service, Miss Macaroon has also attracted
major corporate clients such as John Lewis.
Importantly, Miss Macaroon’s commercial success has enabled
its social purpose, helping to deliver the MacsMAD programme
which provides young people who often have multiple and
complex needs the opportunity to gain work experience,
better their career prospects and positively change their lives.
To date, 134 young people have been supported through the
programme. It’s a fantastic achievement that not only speaks
to Rosie’s vision, but also to the opportunities created when
businesses get the support to thrive.
Enterprise case study
NatWest Group
| 2022 Annual Report and Accounts
14
Watch the
story online
Through the Accelerator,
Rosie received support to
expand her company and
open multiple retail outlets
across the Midlands.
The QR code above directs to a case study video on our 2022 Annual Report webpage.
None of the information on that webpage (including the case study video) is, or should be
read as being, incorporated by reference into this report.
15
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ADDITIONAL INFORMATION
Adapting to
evolving
market trends
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.
We have remained
focused on removing
barriers to doing business
and providing more
opportunities for
companies to grow.
Economy
Overview
In 2022, the UK economy continued its recovery from the
impact of COVID-19 and lockdown restrictions, with GDP
approaching pre-pandemic levels. Russia’s invasion of Ukraine
and other global factors led to very large increases in energy
costs and other commodities during the year. The resulting
high inflation prompted central banks to tighten monetary policy
and markets to anticipate significant increases in interest rates,
leading to asset market volatility. In the UK the government
announced a significant easing of fiscal policy, with measures
to protect households from some of the increase in energy
prices, as well as support for businesses and a reversal of some
planned tax rises. Other countries introduced similar measures
through a variety of policies. Sterling fell against the US dollar
and the euro. In the longer term, demographic change, climate
change, high levels of debt and inequality could all have financial
impacts for our customers.
Our response
We know the tough economic conditions many of our customers
have faced throughout 2022. 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 through initiatives such as our Accelerator
programme, our national and regional SME Taskforce boards
and our Business Builder toolkit, as well as supporting young
enterprise through our involvement with The Prince’s Trust.
Customers
Overview
Expectations of banks have shifted markedly in recent years.
Customers are wanting banks to deliver a better service:
one that is simpler, more relevant and more purposeful.
How customers access our products and services has already
changed with increasing numbers of customers reaching us
online and through our mobile app. The ways people live, work
and run businesses are also altering at pace, with the pandemic
accelerating the trend towards more digital services, while also
seeing a proliferation of ‘side-hustle’ businesses. As well as
monitoring these longer-term trends we have also been
extremely mindful of the impact of rising prices during 2022
and the potential financial distress that this could cause the
customers, businesses and communities we serve.
Our response
In response to the continued increases in the cost of living
across the UK, we have put in place a range of targeted
measures to support those who are likely to need it most,
including proactive contacts to our customers to offer support
and information. In addition, we carried out c.0.7 million financial
health checks in 2022 and launched our credit score feature in
our mobile app to help customers understand their credit score.
Our online cost of living hub was also established to share
resources and tools, informing customers of the support that
is available to them, as well as support through third parties.
These measures were in addition to £4 million in donations
to provide grants and support, delivered in collaboration with
organisations including Citizens Advice, The Trussell Trust,
Step Change and PayPlan. Meanwhile, as we look ahead to the
next phase of our strategy, our future growth will be based on
building new forms of relevance and trust with our customers,
as well as supporting them through the challenges of today. We
have identified three areas for sustainable future growth where
we are well placed to do this: delivering personalised solutions
throughout our customers’ lifecycles; embedding our services
in our customers’ digital lives; and supporting our customers’
sustainability transitions.
Technology
Overview
New business models and customer behaviours continue
to evolve rapidly through advancing technology alongside
large-scale societal changes. In the post-pandemic era, we
recognise the growing role of technology in everything from
digital work environments to the access and delivery of goods
and services, including those within the financial sector.
Market environment
NatWest Group
| 2022 Annual Report and Accounts
16
(1) Since 1 July 2021, UK £17.8 billion, Western Europe £13.0 billion and Other
£1.8 billion. Geography for band issuance is linked to the region of the issuer;
for loans it is linked to the region of operation of the borrowing customer.
(*)
Within the scope of EY assurance. Refer to page 70.
Our response
We are leveraging technology to deliver value through the
lifecycles of our customers. By helping them more and in
technologically-embedded ways, our relationships should
become closer and deeper, as well as more valuable. We
continue to develop new services, based on an understanding of
customers’ lives, that more closely fit with what our customers
want. Whether this is through new commercial offers that help
run invoice management and cash flow analysis, integrated
payments solutions or AI-based customer service, each of
these innovations is designed to benefit customers, society
and the economy, as well as being a driver of long-term
sustainable value.
Cyber threats
Overview
Cyberattacks pose a constant risk to our operations, both in
relation to our own digital estate and indirectly with regard
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, to deploy rigorous due
diligence with regard to third parties and to 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, our customers,
suppliers and counterparties, 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, legislative,
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
As part of the implementation of its climate ambitions, at
NatWest Group’s AGM in April 2022, ordinary shareholders
passed an advisory ‘Say on Climate’ resolution. Through the
bank’s first climate resolution, the Board asked shareholders to
support our strategic direction on climate change, our intention
to develop a Climate transition plan and for annual progress
reports to be published. 92.58% of votes cast were in favour of
the resolution, indicating strong support for our climate strategy.
We also became the first UK bank, and one of the largest banks
globally to date, to have science-based targets validated by
the Science Based Targets initiative (SBTi). These targets,
which cover 79% of our lending activities by exposure as at
31 December 2019, underpin the initial iteration of our Climate
transition plan, which is incorporated within our 2022 Climate-
related Disclosures Report. We provided £24.5 billion
(*)
climate
and sustainable funding and financing in 2022, bringing
the cumulative contribution towards our target to provide
£100 billion between 1 July 2021 and the end of 2025, to
£32.6 billion. As at the end of 2022, we had reduced our direct
own operations emissions by 46%, against a 2019 baseline, with
a plan to achieve a 50% reduction by 2025. Achievement of our
climate ambitions is dependent on timely UK Government policy
and technology developments, as well as on our customers
and society to respond. At the same time, as a purpose-led
organisation, we aim to engage and support our customers’
transition to a net-zero economy. Read more in the 2022
Climate-related Disclosures Report.
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 Financial
Conduct Authority’s (FCA) new requirements for a Consumer
Duty, which expands its rules and principles to force firms to
provide better consumer protection; operational resilience,
in light of the UK authorities’ 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.
United Kingdom: £12.3bn
Western Europe: £11.0bn
Other: £1.2bn
£11.0bn
£1.2bn
Total
£24.5bn
£12.3bn
Geographical split of
climate and sustainable
funding and financing
in 2022
(1)
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FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
How we create value
Customer relationships
We support our customers with financial
services that meet their needs, and which
include keeping their funds safe and secure,
improving financial capability and
supporting enterprise.
Partners and networks
We are powered by innovation and
partnerships, working with a diverse range of
partners to help shape our business strategy
and deliver positive outcomes for our
customers and society.
Robust
governance
framework
We have an integrated
approach to governance,
ensuring purpose is embedded
within our corporate
governance framework.
Revenues
and returns
We earn income from
interest charged
on lending to our
customers, fees from
transactions and
other services.
Products
and services
We provide a
comprehensive range
of banking financial
services to personal,
business and
commercial
customers via
our businesses.
Human
Strong and deep customer
relationships
Credible and diverse talent pipeline
Healthy and inclusive culture
Creative and innovative partnerships
Positive contribution to communities
Financial
Strong balance sheet and
financial position
Focused capital allocation
Intelligent approach to risk
Sustainability as a driver for
value creation
Infrastructure
Property and technology
infrastructure
Partnerships and collaborations
to enable a diverse and sustainable
supply chain
Guided by our purpose and informed by the needs of our stakeholders,
we aim to create value that has a positive impact on our environment and wider society.
Our business model
Our approach to running a safe and
secure bank
Our key relationships and resources
NatWest Group
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Focus on the customer journey
Continually focused on improving the customer journey, using
technology and data to advance our service offerings and
protect our customers.
Creating a leading customer digital experience
Offering our customers more relevant products, more quickly
and at the right time through our targeted investment in data,
technology, and digitisation.
Delivering fair and sustainable returns
for shareholders
Focused on sustainability as a driver for value creation.
Supporting our customers’ transition to net zero
Qualified relationship managers and carbon tracking tools to
support customers’ transition to net zero.
Creating opportunity for businesses and enterprise
Removing the barriers to enterprise particularly supporting
those that have traditionally faced the highest barriers.
A leading bank in the UK helping to address the
climate challenge
We have an ambition to at least halve the climate impact of our
financing activity by 2030, against a 2019 baseline, align with
the 2015 Paris agreement and be net zero by 2050.
Promoting financial capability
Our purpose-led focus areas help us to build financial skills and
capabilities across colleagues, customers, and the community.
Reducing our carbon footprint
Continuing to reduce emissions from our own operations and
that of our wider operational value chain.
Highly experienced colleagues with valuable
industry insight
Experience of a challenging economic environment, shaping
responses to current economic conditions, including how the
cost of living crisis impacts customers.
Supporting energy-efficient homes
Supporting our UK mortgage customers through differentiated
product pricing to incentivise residential energy efficiency and
the purchase of the most energy efficient homes.
Powerful partnerships
Collaborating across industry and creating products and
services to enable customers to track their carbon impact.
Helping colleagues realise their potential
With inclusion at the heart of our values, we continue to bring
our diversity, equity and inclusion strategy to life. We provide
all colleagues with the chance to succeed and the support
to thrive.
Making a difference in our local communities
Supporting and giving back to the communities we operate in.
Delivering long-term sustainable value
and
attractive returns,
now and for the
next generation
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ADDITIONAL INFORMATION
79%
of our lending exposure, as at
31 December 2019, covered
by 2030 sector targets
validated as science-based by
Science Based Targets initiative
£2.9 billion
(*)
Retail Banking Green Mortgage
completions since launch
(5)
(2021: £0.7 billion)
Value created for stakeholders
and society during the year
Our View
colleague survey
colleague sentiment on inclusivity remained strong
in 2022, maintaining a
score of 93% –
9% above
the Global Financial Services Norm
and
8%
above the Global High Performance Norm
10.1 million
(*)
active digital customers
8.9 million
(*)
actively use our mobile app
3.8 million
(*)
use our online banking platform
We hired
1,135
interns, graduates and
apprentices in 2022, including
171
apprentices
recruited through
our social mobility programmes
£32.6 billion
(*)
cumulative contribution towards
£100 billion climate and sustainable
funding and financing target
(4)
(2021: £8.1bn (1 July-31 Dec))
5.1 million
(*)
financial capability interactions
delivered by 31 December 2022
against the 2023 target
(6)
Cumulative 2020 –
2022: 14.07m
Our business model
continued
Over
£10 million
raised for the DEC Ukraine Appeal
by NatWest Group, and through
customer and colleague donations
to support relief efforts
(*)
Within the scope of EY assurance. Refer to page 70.
(1) 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.
(2) Historic values are updated from values reported in 2021. This is due to updated
bills, data provision and extrapolations.
(3) Comprises £1,172 million corporate tax, £543 million irrecoverable VAT, £98 million
bank levies, £276 million employer payroll taxes and £82 million other taxes.
Over
£80 million
of Coutts’ clients’ capital mobilised in
equity growth funding for SMEs
in the UK Enterprise Fund
NatWest Group
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46%
reduction in emissions in
our direct own operations
(1)
(2021: 44%)
(2)
We supported
over
16,000
young people this year
through our CareerSense
Programme (over 24,000
since launch in June 2021)
MoneySense has helped
11.5 million
young people learn about
money since it was launched
in 1994
Over
72,000
trees planted by our
UK colleagues in
partnership with
The Conservation
Volunteers
£77.8 billion
lending across Business Banking
and Commercial Mid-market in our
Commercial & Institutional segment,
supporting economic
growth
Payment of
£2.17 billion
in tax was made to the UK
Government in 2022 which
supported central government
and local authority spending
(3)
Over 76,000
hours volunteered by our
colleagues to help local communities
£3.8 million
raised for good causes by
colleague giving and fundraising
167
colleagues reskilled
as part of a formal
programme
Supporting customers at
every stage of their lives
Powered by innovation
and partnerships
Simple to
deal with
Sharpened
capital allocation
63%
(*)
of our active current accounts
are customers exclusively
banking with us using
digital channels through
mobile or online
Strategic priorities
We developed the initial iteration of our
Climate
transition plan
which outlines the steps we aim to take
to at least halve the climate impact of our
financing activity by 2030 and achieve our
net zero climate ambition by 2050
(4) Between 1 July 2021 and the end of 2025.
(5) Since launch in Q4 2020 Retail Banking Green Mortgage products only. Green
mortgages are available to all intermediaries for all residential and Buy to Let
properties with an energy performance rating of A or B and specific new build
developer properties. Available for purchase, porting and re-mortgage applications.
NatWest Group’s
systems enabled
19,500
new customers to apply for a
mortgage online, an increase of
47%
from 2021
(6) Includes additional initiatives approved during 2021 and 2022 which met the criteria
for inclusion in the financial capability target.
21
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ADDITIONAL INFORMATION
Supporting customers at
every stage of their lives
Powered by innovation
and partnerships
Why it’s important
We believe that sustainable growth will come from building
closer relationships with our customers and our ability to
better serve them at every stage of their lives.
We need to continually evolve our capabilities, investing in
technology and partnerships so we can be a simple, safe
and smart bank that is driven by data and digital innovation.
What we have achieved
We made it easier for our customers to understand their
financial health, by providing c.0.7 million financial health
checks in 2022. We also initiated proactive contacts to our
customers to provide support and information on the cost
of living.
In Retail Banking, we have completed £2.9 billion
(*)
of Green
Mortgages
(1)
since their launch in Q4 2020, rewarding
customers for choosing an energy-efficient home.
We delivered £77.8 billion of lending across Business
Banking and Commercial Mid-market in our Commercial
& Institutional segment, supporting economic growth.
Our support for young people continued with the launch of
our new pocket money product, NatWest Rooster Money,
which helps children build money confidence and develop
positive money habits around saving and spending.
We entered into a strategic partnership with the Vodeno
Group to help us meet the evolving needs of our business
customers as they look to embed financial products in their
own propositions and journeys.
Alongside footballer and campaigner Marcus Rashford
MBE, we have created a programme designed to support
young people in communities across the UK to learn about
and develop a positive relationship with money.
We launched a collaboration with Workplace owner Meta
to offer female business owners training and support, as
well as opportunities to expand business connections
and networks.
We launched the NatWest Carbon Planner, a free-to-use
digital platform designed to help UK businesses identify
potential cost and carbon savings.
The outcomes it creates
We will leverage the expertise we have across our bank to
deliver products and services that are relevant throughout the
lifecycles of our customers.
By scaling new and existing relationships through technological
and digital expertise, we will meet our customers’ evolving
needs and fulfil our growth ambitions.
Our strategy
A strategy to deliver our purpose,
driving 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.
Delivering personalised solutions throughout our customers’ lifecycles – every customer is an individual.
Embedding our services in our customers’ digital lives – being where our customers are.
Supporting our customers’ sustainability transitions.
We have identified three key growth areas where we can amplify our strategy:
(1)
Green Mortgages are available to all intermediaries for all residential and Buy to Let properties with an energy performance rating of A or B and specific new build developer
properties. Available for Purchase, Porting & Re-mortgage applications.
NatWest Group
| 2022 Annual Report and Accounts
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Simple to
deal with
Sharpened capital
allocation
By being simple to deal with we will improve both customer
journeys and colleague engagement, providing an easier and
more intuitive banking experience.
Effective deployment of capital and efficient portfolio discipline
enables targeted investment, helps manage risk and ultimately
drives sustainable returns.
We now have 10.1 million
(*)
active digital users. We have
8.9 million
(*)
customers who have accessed the mobile
app and 3.8
(*)
million customers who have accessed
online banking.
63%
(*)
of our customers who exclusively use digital channels
to engage with us, regularly use our mobile app.
In 2022, Cora, our AI virtual assistant, handled 10.4 million
(*)
Retail Banking conversations, almost half of which required
no human input.
c.90,000 customers now invest through our digital
investment platform managed through the Coutts
Investment Centre of Expertise.
Following our investments to improve customer journeys,
over 77% of digitalised new Current and Savings Account
openings in Retail Banking were completed without human
intervention in 2022.
We continue to deliver on our commitment to invest
c.£3 billion over 2021-2023 with an increasing focus
on growth.
In 2022, NatWest Group announced the creation of the
Commercial & Institutional business segment, which brings
together the best of our expertise to better support our
non-personal financial customers’ needs.
The majority of the commercial loan sale to Allied Irish
Banks, p.l.c. (AIB) and the majority of the non-tracker
mortgage sale to Permanent TSB Group Holdings p.l.c.
(PTSB) were complete by the end of 2022 and we expect
the tracker mortgage sale to AIB to complete in 2023.
£5.1 billion shareholder distributions were paid and
proposed for 2022.
We provided £24.5 billion
(*)
in climate and sustainable funding
and financing in 2022 towards our £100 billion target.
(1)
Through understanding our customers better and being simple
to deal with we can offer more relevant products, more
quickly and at the right time.
We will continue to deploy our financial and non-financial
capital to create value for our stakeholders and society over
the long term as well as generating sustainable returns.
(1)
In October 2021, having surpassed our previous 2020–2021 £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.
(*)
Within the scope of EY assurance. Refer to page 70.
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ADDITIONAL INFORMATION
Key performance indicators
Financial measures
Measuring our performance
Achieve income in the
Go-forward group, excluding
notable items of around
£12.8 billion
(1)
.
Income excluding notable items is
expected to be around £14.8 billion
in 2023.
Total income increased by 26.1%
to £13,156 million compared with
2021. Income in the Go-forward
group
(1)
, excluding notable items
(2)
increased by £2,989 million, in the
year to £13,063 million, exceeding
our income guidance for the year.
Achieve a c.3% reduction
in Go-forward group operating
expenses excluding litigation
and conduct costs
(1)
.
Cost:income ratio (excl. litigation
and conduct) below c.52% or
c.£7.6 billion of operating costs
in 2023.
Operating expenses were
£71 million lower than in 2021.
Other operating expenses
(3)
in the Go-forward group were
£201 million, or 2.9% lower,
in line with our target of a
c.3% reduction
(4)
.
Aim to end 2022 with a CET1
ratio of around 14%.
Continue to expect that the CET1
ratio will be in the range of 13-14%
over the medium term.
The CET1 ratio remains robust
at 14.2%.
The 170 basis point reduction
compared with 1 January 2022
(5)
primarily reflects distributions and
linked pension accruals of c.310
basis points partially offset by
the attributable profit, c.190
basis points.
Achieve return on tangible
equity for NatWest Group of
14-16% in 2023
(6)
.
Continue to target a sustainable
return on tangible equity for the
group of 14-16% over the
medium term.
We achieved a return on tangible
equity of 12.3.%. This is net of a
£1.0 billion attributable loss from
our continued withdrawal from
the Republic of Ireland.
Income (£m)
Why it is important
Delivering long-term sustainable performance.
Run a safe and secure bank.
Our performance
Alignment with our strategy and areas of focus
How we measure our progress and our future priorities
Operating expenses (£m)
CET1 ratio (%)
Return on tangible equity (%)
Read more: Our investment case on page 10 and in our Outlook statement on page 11. For details on how the KPIs are aligned to
executive directors’ remuneration refer to our Annual remuneration report on pages 152 to 167.
2022
2021
10,429
10,403
13,156
2020
2022
2021
7,758
7,858
7,687
2020
2022
2021
18.5
18.2
14.2
2020
2022
2021
9.4
(2.4)
12.3
2020
Supporting customers at
every stage of their lives
Enterprise
Powered by innovation
and partnerships
Climate
Simple to deal with
Learning
Sharpened capital
allocation
Key
Achieved
On track
Not achieved
(1) Performance on a Go-forward
group basis (NatWest Group
excluding Ulster Bank RoI) will not
be reported going forward. Included
to align with targets provided
during 2022.
(2) £146 million (2021 – £210 million).
(3) Operating expenses excluding
litigation and conduct costs of
£385 million (2021 – £466 million).
(4) £6,648 million (2021 – £6,849 million).
(5) On 1 January 2022 the proforma
CET1 ratio was 15.9% following
regulatory changes.
(6) As per target which was updated
during 2022.
NatWest Group
| 2022 Annual Report and Accounts
24
Non-financial measures
Provide an additional £100 billion
of climate and sustainable financing
and funding between 1 July 2021
and the end of 2025.
A guardian for future generations.
To be a leading bank in the
UK helping to address the
climate challenge.
In 2022 we provided £24.5
(*)
billion
of climate and sustainable
funding and financing, towards
our £100 billion target.
This took our cumulative total since
July 2021 to £32.6
(*)
billion towards
our target to provide £100 billion
climate and sustainable funding
and financing by the end of 2025.
Support the removal of barriers
to UK enterprise growth through the
provision of learning, networking,
and funding interventions.
A good citizen.
Remove barriers to UK
enterprise growth.
In 2022 we have supported 48,000
(*)
young people and 53,000
(*)
individuals
and businesses through our
enterprise programmes, with
269,000
(*)
customer interventions
delivered. Of those supported:
34%
(*)
were people from ethnic
minority backgrounds.
32%
(*)
businesses were purpose-led.
59%
(*)
support provided to women
90%
(*)
were in regions outside
London and southeast England.
Achieve our Culture target of 83
points as measured through the
Our View colleague survey
(1)
.
A responsible and responsive
employer.
Build up and strengthen a
healthy culture.
In 2022 we narrowly missed
our target on Culture of 83 by
one point.
In 2022 we changed our Culture
measurement calculation
methodology from the Financial
Services Culture Board (FSCB)
methodology to the Willis Towers
Watson (WTW) methodology, as
we no longer participate in the
FSCB survey.
Increase the likelihood that
customers will recommend our
brands and achieve NPS targets for
our core customer-facing businesses.
Honest and fair with customers
and suppliers.
Build up and strengthen a
healthy culture.
Funding and financing provided to
support climate and sustainable
activities in line with our climate
and sustainable funding and
financing inclusion (CSFFI) criteria.
Read more: Our climate-
related disclosures on pages
54 to 63 and in our Climate-
related Disclosures Report.
Support provided to individuals,
businesses and young people
through enterprise programmes
and customer interactions, to start,
run or grow a business.
Read more: Our purpose-
led areas of focus on pages
26 and 27 and in our ESG
Disclosures Report.
Annual Our View colleague
sentiment survey.
Read more: Our colleagues
section on pages 46 to 49
and in our ESG
Disclosures Report.
NatWest Retail Banking NPS 23
or be 3
rd
; NatWest Business
Banking NPS -6 or be 3
rd
; NatWest
Commercial Banking NPS 17 or 1
st
.
Read more: Our customers
section on pages 42 to 44.
Climate and sustainable
funding and financing (£bn)
Why it is important
Our performance
Alignment with our strategy and areas of focus
How we measure our progress and our future sustainable long-term targets
Supporting enterprise
through unique
programmes
Build up and strengthen
a healthy culture
Net Promoter Score (NPS)
NatWest Retail Main Bank NPS
exceeded its target by 1 point.
There was an additional
improvement of 7 points driven
by a methodological change
(2)
.
Despite missing its NPS target in
2022, NatWest Business Banking
continues to rank 3
rd
compared
with its high-street competitors.
NatWest Commercial &
Mid-Market met its 2022 target
by retaining 1
st
position versus
its high street competitors.
2022
2021
8.1
9.4
12.0
24.5
2020
2022
2021
c.55,000
c.60,700
c.53,000
2020
2022
2021
83
83
82
2020
(1) All scores shown are for NatWest Group and include Ulster Bank
RoI. To enable like-for-like year-on-year comparisons, all scores
shown are based on the WTW calculation methodology.
2022
2021
2020
13
13
-3
-6
+15
+22
+16
7
19
-3
Retail
Retail: 2022 new baseline
Business
Commercial
(2) During 2022, a methodological change was made to retail NPS measurement which resulted in
an uplift in NPS scores for all brands including NatWest. 2022 performance has been measured
removing the impact of this positive change. 2023 goals have been set from a new +22 baseline
which takes into account the positive impact of the methodological change.
(*)
Within the scope of EY assurance. Refer to page 70.
Climate and sustainable finance
and funding provided towards
our £100 billion target.
25
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Our purpose-led areas of focus
Building long-term value
Our ambition is to champion 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:
climate, enterprise and learning.
Our ambition
Our areas of focus
contribute to UN Sustainable
Development Goals (SDGs):
As signatories of the UN Principles
for Responsible Banking, our
ambition is to align our strategy
with the 2015 Paris Agreement
and the UN SDGs
(1)
. As well as
highlighting activity that relates
to each of the SDGs above, case
studies throughout this report
reference positive impacts
mapped against other SDGs.
(1) The Sustainable Development
Goals (SDGs) are a collection of 17
non-legally binding interlinked global
goals set forth by the UN for countries
and governments. These are included only
as indicative guidance for the proposed aim
of each area of focus and NatWest Group
makes no representation, warranty or
assurance of any kind, express or implied,
or takes no responsibility or liability as to
whether the areas of focus further the
objective or achieves the purpose of
the indicated SDG.
(2) Refer to section 1.2, 1.3 and 3.3 in the
NatWest Group Climate-related Disclosures
Report for further detail on our climate
ambitions and SBTi targets.
(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) Represents approximate number of
interventions delivered and individuals
supported through enterprise programmes
during 2022, which is based upon data
provided by third parties delivering these
interventions without further independent
verification by NatWest Group.
(5) Demographics cover uniquely supported
individuals and youth interventions supported.
(6) Youth interventions supported through
enterprise and entrepreneurship activity is a
new metric for 2022.
(7) Includes additional initiatives approved
during 2021 & 2022 which met the criteria
for inclusion in the financial capability target.
(8) Includes instances where customers had
existing savings with other banks and
transferred them into a NatWest
Group account.
Our ambitions and targets
(2)
2050
achieve net zero by 2050 across our financed emissions, Assets under
Management and our operational value chain.
£100bn
provide 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, against a
2019 baseline, and align with the 2015 Paris Agreement.
50%
reduce carbon intensity of our in-scope Assets under Management by 50%,
against a 2019 baseline.
-50%
reduce our direct own operations
(3)
carbon footprint by 2025.
Climate
A leading bank in the UK helping to address the climate challenge
Our targets
15m
financial capability interactions delivered between January 2020
and December 2023.
(7)
2m
additional customers helped to start saving between January 2020
and December 2023.
(8)
Learning
Building financial capability and resilience
Our targets
250,000
interventions delivered to start, run or grow a business in 2022.
(4)
35,000
individuals and businesses supported through enterprise
programmes in 2022.
(4)
30,000
youth interventions supported through enterprise
and entrepreneurship 2022.
(4,6)
60%
of support provided to women.
(5)
75%
of support based in regions outside London and southeast England.
(5)
20%
of support provided to individuals from ethnic minority backgrounds.
(5)
20%
of support provided to those with a purpose-led business or business idea.
(5)
Enterprise
Removing the barriers to enterprise
NatWest Group
| 2022 Annual Report and Accounts
26
Our 2022 performance
(1) 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.
(2) As at 31 December 2022
£138.8 billion, 68%, of the total
residential mortgages portfolio had
EPC data available. In addition
to the Retail Banking portfolio,
during Q2 2022, EPC data
became available for the Private
Banking portfolio for all periods.
(3) Since launch in Q4 2020. Green
Mortgages are available to all
intermediaries for all residential
and buy-to-let properties with an
energy performance rating of A or
B and specific new build developer
properties, Available for Purchase,
Porting & Re-mortgage applications.
(4) 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.
(5) Historic values are updated from
values reported in 2021. This is
due to updated bills, data provision
and extrapolations.
(6) Represents approximate number
of interventions delivered and
individuals supported through
enterprise programmes during
2022, which is based upon data
provided by third parties delivering
these interventions without further
independent verification by
NatWest Group.
(7) Demographics cover uniquely
supported individuals and youth
interventions supported.
(8) Youth interventions supported
through enterprise and
entrepreneurship activity is
a new metric for 2022.
(9) Includes additional initiatives
approved during 2021 & 2022
which met the criteria for inclusion
in the financial capability target.
(10) Includes instances where customers
had savings with other banks and
transferred them to their NatWest
Group account.
(11) Includes additional 144k customers
for 2021 and 2020. The customers
helped start to save criteria was
revised in April 2022 to reflect
products aligned to the ambition.
(*)
Within the scope of EY assurance.
Refer to page 70.
Climate
£32.6bn
(*)
cumulative contribution towards
£100 billion climate and sustainable
funding and financing target
(1)
2021: £8.1bn (1 Jul – 31 Dec)
£2.9bn
(*)
Retail Banking Green Mortgage
completions since launch
(3)
2021: £0.7bn since launch
41.5%
(*)
of EPC C or better rated homes
in our UK Mortgage portfolio for
which EPCs are available
(2)
2021: 38.3%
79%
of our lending activities by exposure
as at 31 December 2019, covered
by 2030 sector emissions reduction
targets, validated as science based
by the SBTi
-46%
reduction in emissions in our direct
own operations
(4)
2021: -44%
(5)
92.58%
of votes cast were in favour of our
first Say on Climate resolution
Enterprise
269,000
(*)
interventions delivered
to start, run or grow a business
in 2022
(6)
2021: c.200,000
34%
(*)
of support provided to
individuals from ethnic
minority backgrounds
(7)
2021: c.26%
90%
(*)
of support based in
regions outside London
and southeast England
(7)
2021: c.75%
32%
(*)
of support provided to those
with a purpose-led business
or business idea
(7)
2021: c.52%
53,000
(*)
individuals and businesses
supported through enterprise
programmes in 2022
(6)
2021: c.55,000
48,000
(*)
young adults engaged in
enterprise and entrepreneurship
activity in 2022
(6,7,8)
59%
(*)
of support provided to women
(7)
2021: c.60%
Learning
5.1m
(*)
financial capability interactions
delivered by 31 December 2022
against the 2023 target
(9)
Cumulative 2020 to 2022: 14.07m
0.5m
(*)
additional customers helped to
start saving by 31 December 2022
against the 2023 target
(10)
Cumulative 2020 to 2022: 1.7m
(11)
Read more in the
NatWest Group plc 2022,
the Climate-related
Disclosures Report and
ESG Disclosures Report.
27
NatWest Group
| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
(1) London Institute of Banking and Finance.
(2) Money Advice Service.
(3) NatWest Thrive Impact report – our summer impact 2022.
people to thrive
Helping young
NatWest Group collaborates
with footballer and campaigner
Marcus Rashford
All young people deserve to feel financially
secure and fulfil their potential.
Yet 81% of young people today say they are uncertain about
their financial future
(1)
. And 56% of 12- to 17-year-olds don’t
feel confident about managing their money
(2)
.
We want this to change.
But we know that for this to happen, we must think beyond
money management and practical financial education. We know
we must also help young people overcome the emotional and
psychological obstacles blocking their success.
That’s why we have created a programme for 8- to 18-year-
olds that aims to help them develop their self-belief as well as
their money confidence.
NatWest Thrive is a unique collaboration between NatWest
Group, the National Youth Agency (the national body for youth
work) and footballer and campaigner Marcus Rashford MBE.
It’s built around three pillars: the redemptive power of (forging
a new) identity; delivery via trusted adults and role models;
and connection to the young people’s interests and passions.
As such, NatWest Thrive is about people, relationships,
mentoring and contact with role models to create community
and connection. It’s why the programme is primarily delivered
face-to-face, in relevant, safe places for young people and with
trusted adults.
Watch the
story online
In spring 2022, we launched the programme’s
pilot scheme to 135 young people in three youth
clubs in London, Manchester and Sunderland.
Following that, over the summer in 2022, we
rolled out a 12-week NatWest Thrive programme to
12 more youth clubs, reaching more than 800 young
people across the UK during 2022. Results from
the summer programme are hugely encouraging:
98% say their money confidence has improved
after four sessions and 83% say it has improved
their mental wellbeing
(3)
.
Our vision is now to scale the programme to
improve the financial confidence of many more
young people.
The QR code above directs to a
case study video on our 2022
Annual Report webpage. None of
the information on that webpage
(including the case study video)
is, or should be read as being,
incorporated by reference into
this report.
Learning case study
NatWest Group
| 2022 Annual Report and Accounts
28
Business performance
Retail Banking
Private Banking
Commercial
& Institutional
Contribution to NatWest Group
Strong brands to meet
customers’ needs
Through the NatWest, Royal Bank of Scotland and Ulster Bank 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.
Private Banking is the Investment Centre of Expertise for NatWest Group, servicing all client
segments across Retail, Premier and Private Banking. We provide private banking and wealth
management services to UK-connected high-net-worth individuals and their business interests
through the Coutts 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.
Commercial & Institutional provides the expertise and tailored solutions needed by businesses,
from entrepreneurs through to large corporate organisations, multi-nationals and financial
institutions. As the biggest bank for UK businesses, we’re also known for supporting businesses
that want to start, scale and grow. Our people, combined with our digital channels, help our
broad set of customers manage their day-to-day business activity, support them through
good and challenging times, and work with them to plan for the future.
Income
43%
8%
49%
0%
Operating profit
before tax
55%
8%
50%
-13%
Net lending to
customers
54%
5%
36%
5%
Key
Retail Banking
Private Banking
Commercial & Institutional
Central items & other
For further information on
the financial performance
of our operating segments
refer to the Financial review
section on pages 72 to 83
29
NatWest Group
| 2022 Annual Report and Accounts
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FINANCIAL REVIEW
GOVERNANCE
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FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Business performance
continued
In Retail Banking, we’re focused on helping our customers reach their financial goals.
From budgeting and saving, to supporting our customers to make more sustainable
choices, our mobile app combined with exceptional colleagues are helping us to deliver
our goal to become a relationship bank in a digital world. We want to deepen relationships
with our customers by supporting them at key moments in their lives, improving their
financial health and resilience and supporting younger generations to plan for the future.
By providing personalised insights, we are helping our customers to understand how
decisions they make today could affect their future finances.
Retail Banking
Our priority is to support our customers as the cost of living
rises and, by engaging customers early, we can help those
facing financial hardship. We have conducted c.0.7 million
financial health checks in 2022, 76,000 more than in 2021,
and have proactively spoken to 1.45 million customers to
provide additional support through regular customer care
campaigns. Our ‘Know My Credit Score’ tool and budgeting
help in our mobile app assists our customers to act promptly
and understand their credit options. We have created an online
cost of living hub which shares resources and support provided
by us and third parties, and which has attracted 346,000 visits.
Our £4 million of donations provides support through
collaboration with organisations including Citizens Advice,
The Trussell Trust, Step Change and PayPlan.
Our ambition is to provide the best digital experience with
access to the best people. We remain focused on improving
the digital experience of our customers, with 88% of their needs
currently met digitally. We’ve reached our highest ever levels
for customer satisfaction, which reflects the increasing number
of customers who use us as their main bank. Our AI virtual
assistant, Cora, fully supported 48.4% of customer queries
without handing over to a human and we’ve made it easier
to book an appointment in our branches or through our video
channel with over 330,000 video appointments held in 2022.
Our digital platforms help to make banking safe and more
convenient. Our digital account opening journey has significantly
reduced the associated cost of fraud and improved the
experience for our customers with record satisfaction levels.
We’ve made payments simpler and safer with a new payment
hub in our app, while biometrics now enable 46% of payments.
Our ‘Card reveal’ feature makes it easy to access card details
and complete online purchases and ‘PIN reveal’ allows our
customers to view their PIN on their app, with over one
million pin reveals displayed in the mobile app, supporting our
customers with their sustainability transitions by significantly
reducing the number of PIN reminder slips sent.
We know how important it can be to save for unexpected bills,
so we have supported c.0.5 million customers to start saving in
2022. We have increased the interest rate for our digital regular
savers and Round Ups make it easy to save little and often with
over 1.25 million customers signed up since it was launched
last year, saving a total of £138 million. We’re helping future
generations to create good habits through Rooster Money and
saw c.89,000 new card openings to build financial resilience
Other operating
expenses
£2,484m
2021: £2,437m
Operating
profit
£2,824m
2021: £1,968m
Return
on equity
28.6%
2021: 26.1%
Customer deposits
£188.4bn
2021: £188.9bn
Total income
£5,646m
2021: £4,445m
Net loans to
customers
£197.6bn
2021: £182.2bn
Rooster Money new
card openings
c.89,000
Customer needs
met digitally
88%
2021: 85%
UK mortgage
flow share
13%
2021: 12%
Climate and
sustainable finance
and funding in 2022
£4.0bn
NatWest Group
| 2022 Annual Report and Accounts
30
across the family. Saving towards the future can be difficult so
it is important to help our customers make their money work
harder and grow over the longer term. Our digital investing
platforms, NatWest Invest and Royal Bank Invest, allow
customers to invest from £50 into a choice of five funds
depending on their approach to risk and time horizon. 31,000
new investment accounts were opened on the platform in 2022.
We want to help our customers to use credit responsibly and
have regularly reviewed our affordability checks to prevent
customers from over-stretching. Our overdraft cost calculator
has been used over 3.5 million times since its June launch and
our soft search for credit cards gives customers the eligibility
information they need without impacting their credit score. We
launched a 30-month 0% balance transfer card which can help
customers pay off outstanding debt, and our buy-now-pay-later
offering gives our customers choice and control around how
they manage their money with safeguards in place to help
customers to use the facility responsibly.
Despite volatility, we remained in the mortgage market
throughout the period with our full product selection and
continued to provide a consistent service to help our customers
to purchase their homes, growing our UK market flow share to
13% with total mortgage balances of £187.2 billion. We
supported 232,000 customers to move to a new deal and
allowed customers to remortgage six months before the expiry
of their existing mortgage, to help our customers to secure a
rate earlier in a rising rate environment. Our over payment
process has been simplified and our higher LTV products
continue to provide customers with the flexibility they need
in a challenging environment. Our investment in digitising the
mortgage journey has resulted in 19,600 applications digitally
and allowed us to launch a market first purchase decision in
principle and remortgage journey with price comparison websites.
How we use our money today could change the world
tomorrow and help to make a greener planet. We’ve had
over 531,000 visits to our climate change hub and 333,000
customers have used our carbon tracker to understand and
reduce their carbon footprint. To provide sustainable growth
in the future, our aim is to encourage our customers to make
more sustainable choices through lifestyle changes and
home energy efficiencies. We supported our customers
with £2.2 billion in Green Mortgages, offering a lower rate
for purchasing or re-mortgaging an energy efficient home.
Our cards are now made from 86% recycled plastic, which is
expected to save 23 tonnes of plastic and 50 tonnes of carbon
dioxide a year.
Building money
confidence
Teaching positive financial habits
with Rooster Money
We believe it’s vital for young people to feel confident and
capable with money.
Enabling financial capability early in life is an essential tool for
developing good money management in adulthood. And as
young people adopt technology at an earlier age, the need
to build these skills in a digital environment becomes even
more important.
That’s why, in 2021, we decided to acquire Rooster Money and
integrate it into our wider youth proposition. The pocket-money
app and pre-paid debit card enable parents to help their
children to feel financially capable by teaching budgeting
skills and encouraging saving to develop positive habits.
The contactless card gives children aged six and over more
independence, while staying safe with spending notifications,
limits and freezes managed within the app. Rooster Money’s
chore and star capabilities can also help children with their
understanding of money from the age of three. As well as
reaffirming our purpose-led ambition to attract and support
the financial needs of more young people and their families,
we also believe the Rooster Money proposition makes sound
commercial sense.
The number of 18-year-olds in the UK is set to grow 20%
by 2030
(1)
and there is increasing competition to provide this
cohort with a digital pocket money proposition in their younger
years. We believe we will be able to take a bigger share of the
bankable (but currently unbanked) youth market by leveraging
our strong customer base, offering a solution to parents for
banking young people all the way through childhood.
In the short term, this will help us to engage customers in other
youth products (for instance, growing Junior ISA volumes),
increase the wider engagement of current parent customers
and attract new families to us.
In the longer term, these young customers will graduate
into primary adult customers, driving value for the bank for
decades to come.
(1) Office for National Statistics.
31
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FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Business performance
continued
Within Private Banking, we serve the banking, lending and wealth management
needs of UK-connected high-net-worth individuals and their business interests through
the Coutts & Co brand, and the investment needs of customers from across NatWest
Group via our Investment Centre of Expertise. As the first UK-headquartered private
bank to become a certified B Corp, clients can rely on Coutts & Co to provide
exceptional service, while managing their wealth responsibly.
Private Banking
In 2022, we continued to put our climate ambition into action.
From 1 February 2022, the Personal Portfolio Funds available
through Coutts Invest, NatWest Invest and Royal Bank Invest
include a commitment that a minimum of 50% of assets by
value in each fund will be on a net-zero trajectory. From 18 July
2022, the Coutts Managed Funds and discretionary portfolios
include a commitment that a minimum of 20% of assets by
value in each fund or portfolio will be on a net-zero trajectory.
As of the end of the year, £6.5 billion of AUM are invested in
funds that are on a net-zero trajectory
(1)
and are decarbonising
at an average rate of 7% per annum.
Building on existing Coutts mortgage products that
offer discounted arrangement fees for purchasing a more
energy-efficient home (EPC rating of A or B) or for making
improvements to improve energy efficiency (EPC rating C and
above) Coutts launched a pilot for its Greener Homes Service.
Providing bespoke advice to help participating customers
overcome the barriers to retrofitting, the service includes a
free energy performance assessment, details of retrofit costs
and benefits, and the option to implement recommended
measures through a pre-vetted supply chain. 30 customers are
participating in the initial pilot of the Greener Homes Service,
with further enhancement planned. In 2022, Coutts completed
£241 million in mortgages for properties rated EPC A or B.
Business exit is an incredibly important moment for any
entrepreneur. Drawing on the knowledge and insights of
entrepreneurs who have been through the process, we’ve
created a free programme to share 20-plus years of our
research. In March, we launched a series of video masterclasses
from industry experts available to all entrepreneurs, regardless
of whether they are a client. In 2022, we have taken 45 owners
and Financial Directors, representing ownership of more than
£572 million of shareholder value, through our Business
Exit Programme.
Continuing the collaboration with Business Growth Fund, we
have now raised over £80 million through the UK Enterprise
Fund (UKEF). The fund is closing the year in a strong position
with over 47 companies now backed. These companies are
well spread across the UK with 73% outside of London and
the South East, diversified across new economy sectors, with
over 20% of companies actively addressing climate change.
Total income
£1,056m
2021: £816m
Net loans to
customers
£19.2bn
2021: £18.4bn
Other operating
expenses
£610m
2021: £523m
AUMA
£33.4bn
2021: £35.6bn
Operating profit
£436m
2021: £350m
Climate and
sustainable financing
and funding in 2022
£0.2bn
AUM net new money
£2.0bn
5.6% of opening
AUMA balances
Return
on equity
24.5%
2021: 17.0%
NatWest Invest/
Royal Bank Invest/
Coutts Invest users
c.90,000
2021: c.79,000
Customer deposits
£41.2bn
2021: £39.3bn
(1) Net-zero trajectory is a commitment, credible plan or action taken to achieve net-zero greenhouse gas emissions by 2050.
NatWest Group
| 2022 Annual Report and Accounts
32
The UKEF is proud to support female founders and their
businesses with over 22% of the portfolio invested in female-led
companies, alongside supporting initiatives such as investment-
ready workshops run by BGF, NatWest Bank and Coutts & Co,
as well as executive coaching for female and ethnic
minority founders.
In December 2022, in line with our aim to build financial
capability and lower barriers to investing, we completed a
nationwide launch of our Digital Assist for Investment service
across the NatWest Bank and Royal Bank branch network.
Branch customers now have the option to speak to a Digital
Wealth Manager who can give them guidance on how to use
our Automated Advice service. This involved training over 1,730
branch staff across 650+ branches in the UK. The colleagues
trained reported a 157% increase in their confidence to talk
about investments and our branch-based Senior Personal
Bankers helped over 100 customers in December with
their long-term savings goals.
In October 2022, Coutts & Co Collective was launched,
making it easier for clients to donate to charity. Supported by
the Charities Trust, the scheme allows clients to give to causes
that support social and environmental issues. By donating
collectively, clients can make a bigger difference to the
causes they care about with high-impact, pre-vetted charities.
The chosen charities are The Prince’s Trust, Future Frontiers
and Ocean Generation. 100% of all donations are received by
the charities.
In June 2022, we launched our new Coutts & Co digital service
through our app to our personal clients. We have introduced
several easy-to-use digital features such as integrated
biometrics for enhanced security, digital cheque deposits,
spend controls, first-time beneficiary payment authorisation
as well as authenticated web and app messaging (live chat).
Client adoption has been high, with over 80% client activation
(1)
.
(1) Of clients invited to use the service.
Coutts championing high-growth businesses
We’re committed to helping clients reach their potential:
connecting with, and contributing to our wider society. By
championing new businesses, we can encourage growth
and create value for our clients and the economy.
To help us achieve this, Coutts was delighted to launch a new
Accelerator programme during 2022 for ambitious individuals
within e-sports, gaming, social media or streaming.
The interactive entertainment industry has experienced
healthy growth in recent years which is expected to continue
to increase in the post-pandemic world. Valued at US$197 billion
in 2022, the global gaming market is now on track to surpass
US$225 billion by 2025.
(2)
The Coutts Interactive Entertainment Accelerator programme
was designed to help UK entrepreneurs scale their businesses
in this growing sector and take them to the next level.
Delivered in partnership with NatWest Accelerator, this
bank-wide initiative allowed entrepreneurs to access and learn
from business and industry experts. Whether they had been
thinking about setting up a business or been running a business
for a while, this fully-funded programme helped them access
new markets, fund expansion or attract new talent to build
more effective teams.
During the six-month programme, applicants benefited from a
range of useful services, including one-to-one coaching with our
experienced business acceleration managers, access to thought
leadership and events, a network of like-minded peers, focused
support from experts and co-working spaces in one of our
nationwide hubs.
We believe this help can give interactive entertainment
entrepreneurs essential early assistance, empowering them to
grow their business further and faster and overcome challenges
to reach their full potential.
Accelerating
the interactive
entertainment sector
(2) Newzoo, Global Games Market Report 2022.
33
NatWest Group
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FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Business performance
continued
In 2022, NatWest Group announced the creation of Commercial & Institutional, which
brought together the Commercial, NatWest Markets and RBS International customer
businesses. The new segment is a step forward in becoming a simpler bank to deal with,
bringing the best of our expertise to better support our customers’ needs. In a particularly
challenging environment, Commercial & Institutional effectively supported customers
manage the increasing costs of doing business from both interest rate and inflationary
pressure, continued developing innovative digital capabilities and remained committed
to providing award-winning sustainable financing solutions to support customers to
transition to greener business practices.
Commercial & Institutional
We remain fully committed to supporting businesses to manage
the increasing costs of doing business with a comprehensive
package of support measures. In 2022, we contacted over
0.8 million customers to offer information, support and advice
through proactive communications, our specialist relationship
managers and local business hubs positioned across the UK.
Alongside our extensive outreach programme, our Business
Current Accounts remained available without a minimum
charge, while we froze the standard published tariffs and
committed to no increases to published fees for 12 months.
Moreover, through our deep sector expertise and service
offering, we tailored support for the most impacted sectors,
including a £1.25 billion lending package for the farming
industry, as part of a range of supportive measures for our
c.40,000 agricultural customer base, which is facing extreme
impacts on supply costs and profit margins – this is in addition
to other support measures, such as capital repayment holidays
and increased overdraft limits.
Establishing the new segment enables us to build even longer
and deeper relationships with our customers, by providing
support at each stage of their journey. As the biggest bank for
businesses in the UK and a committed champion of startups,
we are removing barriers to enterprise, tackling inequality
and supporting growth by helping entrepreneurs achieve their
ambitions. In 2022, we supported over 53,000
(*)
individuals
or businesses through enterprise programmes, with over
269,000
(*)
interventions delivered. Of those supported, 32%
(*)
were purpose-led, 34%
(*)
were from ethnic minority backgrounds
and 59%
(*)
provided support to women. We also offer the UK’s
largest free business accelerator network which continued to
grow this year with the launch of our new Enterprise Hub
to support our Accelerator programme at the University of
Warwick, and the opening of a new hub in Southampton, taking
our total number of Enterprise Hubs to 14. Our commitment to
new businesses resulted in the opening of over 130,000 new
Business Accounts (including Mettle Accounts) in 2022.
By extending the reach of our proposition, we provide a more
comprehensive product offering to our customers, where and
when they need it. In 2022 our corporate FX services were used
by over 650 new corporate and institutional customers for the
first time. In addition, our award-winning FX and long-standing
expertise in fixed income, capital markets, and bespoke
financing solutions, supported customers in navigating the
challenging macro environment and managing their risk.
We are accessible for customers through our expansive
UK footprint and presence across Europe, Asia and the US.
Total income
£6,413m
2021: £4,838m
Net loans to
customers
£129.9bn
2021: £124.2bn
Other operating
expenses
£3,563m
2021: £3,646m
Business accounts
opened (incl.Mettle)
130,000
Operating
profit
£2,547m
2021: £2,241m
Tyl payments
processed
69.5m
2021: 39.3m
Return
on equity
12.2%
2021: 10.9%
Climate and
sustainable finance
and funding in 2022
£20.3bn
Customer
deposits
£203.3bn
2021: £217.5bn
(*)
Within the scope of EY assurance. Refer to page 70.
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Guided by our purpose and our aim to deepen customer
relationships, we continue to support our customers with
their ESG and climate-related finance needs. In 2022, the
Commercial & Institutional segment provided £20.3 billion in
climate and sustainable funding and financing. Our role as a
cornerstone lender in the first greenfield solar transaction in the
UK since 2018 demonstrates our commitment to leadership in
renewables sector project financing. The syndicated loan will
enable our customer to fund the construction of up to 1GW of
solar capacity across the UK and the Netherlands, enough to
power over 300,000 households, while creating local employment
opportunities. To ensure as many SMEs as possible can realise
the bottom-line benefits from their carbon-reduction efforts and
innovation, we reduced the lower threshold for our Green Loans
offering for SMEs from £50,000 to £25,001, so more businesses
can access funding to transition to more sustainable practices.
We also launched our digital Carbon Planner, a free-to-use
digital platform designed to help UK businesses identify
potential cost and carbon savings.
We continue to be a leading underwriter of Green, Social
and Sustainability finance after winning several awards at
the Environmental Finance Bond Awards 2022 (including ‘Lead
manager of the year, social bonds – local authority/municipality
award’), as well as being presented the ‘Leadership in Sustainable
Banking award’ at the Jersey Finance Sustainable Finance
Awards 2022.
Finally, as a relationship bank in a digital world, we continue to
evolve our digital, data and technology capabilities to provide an
easier and more insightful banking experience for customers. In
2022, digitally-initiated commercial service requests more than
doubled compared to the previous year. In addition, 83% of our
customers are actively using digital channels to interact with us.
Improvements in our digital lending journey now enable business
customers to utilise our self-serve digital channels to apply for
up to £50,000 of borrowing and receive an automated decision
within minutes. Alongside this, our innovative merchant acquiring
platform Tyl saw over £3.1 billion of transactions in 2022 – a
104% increase from 2021. Furthermore, we announced a
strategic partnership with Vodeno Group to create a banking-
as-a-service business for the UK market. This will enable us
to create new and exciting opportunities for our customers to
seamlessly integrate financial solutions into their ecosystems,
including payments, deposits, point-of-sale credit and merchant
cash advances.
Financing
sustainability goals
Providing expertise and collaboration
As a relationship bank, we strive to anticipate our customers’
future needs. In 2022, NatWest Group was able to help
Compass Group, a world-leading food service business,
understand how sustainable financing could help it achieve
its long-term sustainability goals.
Serving billions of meals each year in more than 40 countries
and employing and engaging with over 500,000 people, its aim
is to do so in a way which better benefits people and the planet.
The company’s sustainability strategy seeks to maximise the
positive social and environmental impact it has across its value
chain and includes a commitment to reach net-zero emissions
across its global operations and value chain by 2050. The
Sustainable Development Goals illustrated are ones towards
which Compass Group strive to make a positive impact.
Given the scale of Compass Group’s operating expenditures,
and the way these contribute to its sustainability targets,
assistance in formulating the design of its sustainable financing
framework was needed. This required a fresh approach which
wasn’t pre-determined by market precedent.
NatWest Group’s breadth of structuring experience in the
sustainable finance market meant Compass Group was fully
supported in carrying out a review of expenditures which
aligned with its sustainability ambitions across outcomes relating
to environmental as well as social factors. Each was carefully
assessed for the contribution towards its strategic targets,
to ensure only the most material projects were included.
Importantly, facilitating the investment in sustainability for
Compass Group should prove to be a key driver for growth
for the business, helping to meet its clients’ environmental
and social commitments.
This, we believe, is the value that Commercial & Institutional can
provide to customers and stakeholders. By bringing together a
depth of expertise and collaboration across the bank we are
there for our customers’ current and future needs.
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Our stakeholders
We have a reciprocal relationship with all our stakeholders – knowing that
when they succeed, so do we. The insights we gain by listening and engaging with
them enable us to improve outcomes for customers, society and the environment.
Below we provide some examples of how we collaborate with our key
stakeholders to create value.
Stakeholder engagement
How we engaged
What we discussed
Customers – the people and businesses we serve
Supporting businesses through our Accelerator
Programme and Specialist Accelerators, as well
as Business Builder and Business Insights Hub.
The UK Government’s levelling-up agenda for strengthening communities, supporting
diverse entrepreneurs, removing barriers to enterprise, providing access to our wide
range of partners, business accelerator hubs, and our thought-leadership material.
Regular, monthly sessions with people with lived
experience of vulnerability.
Insights from charitable organisations and those with lived experiences on how our
proposed products and propositions work for their circumstances, taking into account
their perspectives.
A big data study, using customer data to explore
the relationship between ethnicity and banking.
Innovative data-led research exploration into the access and some attitudinal analysis
of financial products and services in the UK.
Carbon Planner tool.
A free-to-use tool to help UK businesses identify potential cost and carbon savings.
Meetings with customers during a Board regional
visit to Bristol.
A broad range of topics including the impact of rising inflation, firms’ sustainability
strategies, support for new customers who have fled the invasion of Ukraine and
future growth plans.
At a customer ‘live lounge’ conducted by our Group
Sustainable Banking Committee, non-executive
directors were joined by our frontline Financial
Health and Support telephony team.
The cost of living crisis, the mental health of frontline colleagues and how to
respond to the growing issue of supporting customers in vulnerable situations.
Investors – providers of our capital and funding
Meetings with our senior management,
presentations at industry conferences and
investor roundtables.
Progress on the delivery of our strategy and future priorities, updates on the
financial performance of our business, our funding requirements and deep-dives
on business segments.
The Chairman, Group CEO and Group CFO
took part in quarterly results presentations
and 169 meetings with our largest investors.
Progress against strategic priorities, financial performance, interest rate sensitivity,
capital returns policy, environmental, social and governance topics, regulation and
the macroeconomic environment.
The Chairman, Group CEO and other
non-executive directors engaged with private
investors at two virtual shareholder events.
As above, plus the business of the 2022 AGM and NatWest Group customer support
initiatives under our Retail Banking strategy.
How we engage across the company
How we engage at Board level
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Outcome of engagements
Challenges we faced
In 2022 we supported 1,300 entrepreneurs via the Accelerator Programme, of which 50%
are female-led businesses. New content modules delivered on the cost of trading, financial
resilience, and action tools on energy and cost saving.
Engaging effectively with customers on our
climate agenda, while many face significant
cost pressures, has been challenging. We believe
there is an opportunity for our customers and
NatWest Group, because tackling climate
change is not only good for the planet and
the communities we serve, but good for our
business too. However, demonstrating this
link is a challenge which requires clear and
sustained messaging and engagement.
We’ll continue to develop our customer
climate hub, to bring customers engaging and
educational resources on energy efficiency and
climate change, as well as our carbon footprint
tracking tool in collaboration with Cogo, which
allows customers to see a rolling monthly view
of their carbon footprint.
21 products have now been reviewed by the panel and product owners are working
through proposed adaptations and changes.
The findings were discussed informally with the Bank of England, Prudential Regulation
Authority (PRA) and Financial Conduct Authority (FCA).
Businesses, including those who do not bank with us, have been able to use NatWest
Group’s free tool to help them identify potential cost and carbon savings.
The Board heard about the challenges and opportunities facing these customers and how
the bank could best support them. Learnings were taken into the Board’s wider approach
to assisting customers.
Non-executive directors heard customer conversations to better understand the
challenges faced by colleagues in supporting customers in vulnerable situations.
Institutional equity and fixed income investors and research analysts gained a deeper
understanding of our business and were able to provide feedback on our strategic priorities.
At our 2022 AGM, the resolution to re-elect
Frank Dangeard as a director was passed
with lower support than expected following a
recommendation to vote against by a proxy
adviser under their methodology on over-
boarding. We acknowledged the situation
in our post-AGM announcement and
re-confirmed the Board’s view that Mr
Dangeard has sufficient time to devote to
NatWest Group. The Chairman also engaged
with institutional shareholders to discuss
their concerns.
An open dialogue was maintained with institutional equity and fixed income investors,
updating investors on progress and keeping the Board informed about their views and
priorities throughout 2022.
Private investors had the opportunity to engage with Board members, to ask questions
prior to voting on the business of the AGM, and to hear from Board members and senior
management on current topics.
Read more about our assessment and approach to
materiality in relation to our ESG disclosures in our
2022 ESG Disclosures Report.
For further information on how stakeholder considerations
influenced the Board’s discussions and decision-making,
refer to our section 172(1) statement on pages 40 and 41,
and our Corporate governance report on page 94.
Key ESG topics for our stakeholders
We re-evaluate our key ESG topics annually and refresh
where appropriate to ensure that our list continues to be
comprehensive, relevant and reflective of our stakeholder
groups’ perspectives. For this year’s assessment we’ve taken
into consideration the evolving landscape and engaged with a
number of internal and external stakeholders. The findings guide
our reporting and decision-making, ensuring we remain focused
on the right issues. This year’s review once again confirmed
that, as a responsible business, our approach to a broader
range of ESG topics is of great significance to our stakeholders.
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Our stakeholders
continued
How we engaged
What we discussed
Regulators – whose rules and expectations we seek to comply with
With regulators, including the PRA, on managing
the financial risks from climate change. Including
submissions regarding compliance approach taken
to regulatory standards and the Bank of England
Climate Biennial Exploratory Scenario (CBES).
The outcomes of climate stress testing of NatWest Group and the management
response determined, and how climate-related risks have been integrated within
the enterprise-wide risk management framework.
Engagement with the FCA on our implementation
of the new Consumer Duty.
High level of importance on achieving good customer outcomes, how we intend to
implement the Duty,
PRA attendance at July 2022 Board meeting and
FCA attendance at February 2023 Board meeting.
PRA: 2022 Periodic Summary Meeting outputs; FCA: 2022 Firm Evaluation
Letter outputs.
Non-executive directors engaged with regulators
through continuous assessment and proactive
engagement meetings.
Strategy, financial performance, capital distributions, Board and Committee priorities,
Board effectiveness, governance, the risk and control environment, financial crime,
ring-fenced bank independence, Consumer Duty and the cost of living.
Colleagues – the people who deliver our purpose
Our View opinion survey.
The results of Our View, which asked for colleague opinion on topics such as purpose,
wellbeing, inclusion, leadership and reward.
Wellbeing Champions, Inclusion Champions,
Our Colleague Experience Squad and
employee-led networks.
Topics that influence our culture, including wellbeing, new ways of working, diversity,
equity and inclusion, colleague capability and remuneration.
One of our weekly huddles with UK
frontline colleagues.
A spotlight on climate change, focusing on reducing household energy bills and
carbon emissions, as well as developing colleagues’ capability to have conversations
on climate.
Colleague Advisory Panel (CAP).
Remuneration, our values, customers in vulnerable situations and future skills.
Meet the Board event, and a range of
informal events.
Future challenges and opportunities for the Board, how effectively we are living our
purpose, our role in addressing climate change, and supporting future generations.
Communities – the places where we have an impact
Charity relationships, customer giving channels,
colleague fundraising and volunteering.
How to best help the most vulnerable in society through our colleague and customer
giving channels. We facilitated colleague and customer donations, and supported our
colleagues to volunteer their skills and expertise, creating positive outcomes for a range
of good causes.
Support for young people through MoneySense,
Island Saver, and our new programme with
Marcus Rashford, NatWest Thrive.
MoneySense provides curriculum-linked activities for delivery in the classroom, while
Island Saver helps young people with money skills and climate change awareness.
Meetings with the UK Government, devolved
administrations, NGOs, think tanks and academia.
Our climate-related ambitions, support for customers and businesses through the
cost of living crisis, assistance for startups, the Rose Review and our work with
female entrepreneurship more widely and help for businesses to recover from
COVID-19 and grow.
Meetings with community groups during a Board
visit in the southwest of England.
How we live our purpose through community engagement and how future support
could best be provided.
Board climate training, led by the University
of Edinburgh.
Managing climate-related institutional change, climate measurement and influencing.
Suppliers – where we source our goods and services
Regular review meetings with key suppliers.
Supplier review meetings have a standing agenda point to discuss the Supplier Charter,
which includes elements such as modern slavery and human rights issues.
Risk management – onboarding new suppliers.
We launched a new inherent risk questionnaire to simplify how we interact with our
suppliers and stakeholders.
Meetings with key suppliers during a Board
regional visit to Bristol.
Suppliers’ experiences of working with NatWest Group and future opportunities and
challenges, including the suppliers’ ESG agendas.
Board training on embedding purpose in our
supply chain.
Embedding our purpose in our supply chain and increasing diversity and inclusion with
existing and new suppliers.
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Outcome of engagements
Challenges we faced
Transparency on the NatWest Group’s exposure to climate-related risks and the response
in order to manage the risk effectively.
We recognise that the success of the Consumer
Duty requirements is dependent upon a
collaborative approach being taken between
firm and regulator. The change in expectations
set out by the FCA is in tune with our Purpose
and Values. To this end we have committed to
close and continuous ongoing engagement with
the regulator throughout the implementation
period. This will help us to identify where we
need to make change to evidence compliance
with the guidelines and help make sure this is
reflected in our policies and procedures and
culturally across the organisation.
Transparency on our implementation, consistent with the FCA’s stated ambition to iterate
on approach with firms.
The Board heard from the PRA and FCA on the key messages in their respective letters.
Directors gained a better understanding of the regulators’ key areas of interest and
provided feedback on those topics.
Our View September 2022 response rate was one of the highest in the last 10 years.
In the face of an unprecedented external environment, our results overall show resilience.
The rising cost of living impacted our colleagues
creating new challenges for them through
rising inflation and energy prices. We provided
financial support to the colleagues most likely to
be impacted in addition to our normal pay cycle,
reflected the economic climate by making a
significant investment in our annual pay review
effective April 2023 and continue to support
colleagues with our suite of financial wellbeing
materials. Focusing on our lowest paid
colleagues we immediately implemented
the changes to the real living wage and also
increased our lowest starting salary to £22,000
effective April 2023, an increase of 16% since
April 2022.
Our Wellbeing Strategy was supported by over 1,400 Wellbeing Champions.
We continuously support our employee-led networks, which have around
24,000 members globally.
Improved colleague awareness of climate issues, the impact of the cost of living and
how to talk about these issues with customers.
The CAP continued to provide an important communication channel between the Board
and colleagues.
Improved dialogue between the Board and colleagues on current issues.
£7.6 million donations through our mobile app, Reward Account and online donations.
The bank, our customers and colleagues together raised over £12 million for three DEC
appeals, supporting humanitarian relief efforts in Afghanistan, Ukraine and Pakistan.
Our colleagues raised over £3.8 million for good causes and volunteered 76,230 hours.
Following COVID-19, charities faced challenges
in generating income and meeting increased
demand. Schools gradually reopened to
external volunteers, but new ways of working
for colleagues led to a slower-than-anticipated
uptake of volunteering opportunities.
The rise in the cost of living further impacted
people and communities creating new
challenges with customer and colleague giving.
Stakeholder engagement helped us to better
understand the immediate and potential
longer-term impacts of the cost of living
and to act quickly to support charities
and organisations in the community.
76,086 teachers registered to use MoneySense resources, with 12,028 registering
in 2022.
We sponsored the UK Pavilion at COP27. We worked with the SME Transformation
Taskforce to support SME businesses.
A package of support launched for customers, colleagues and communities to help with
the rising cost of living.
Insights into our work with these groups, a demonstration of the Board’s support and
the reiteration of the bank’s commitment to such projects.
Building on directors’ foundational climate knowledge with insights into more
technical areas.
Non-compliance with the bank policy schedule is dealt with on a case by case basis
and includes engaging with the supplier to identify potential remediation measures.
Where suppliers that underwent the EcoVadis
assessment performed below the global
average, we are implementing corrective
improvement plans to support them in
improving their performance on key
sustainability topics.
We have built objectives into our core strategy
to enable our suppliers to improve and help us
cultivate a more responsible and diverse supply
value chain.
Supply Chain Services implemented a new tool for assessing and understanding the
risk profile associated to any service. The new Inherent Risk Questionnaire replaced the
Service Impact Assessment.
The Board gained an external perspective of NatWest Group and strengthened
supplier relations.
Directors gained insights into how NatWest Group engages with its suppliers, including
cost and service, sustainability and stakeholder impacts.
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Board decisions and stakeholder engagement
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.
Section 172(1) statement
Board engagement with stakeholders
The Board reviews and confirms its key stakeholder groups
for the purposes of section 172 annually. For 2022, they
remained customers, investors, regulators, colleagues,
communities 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 36 to 39
(stakeholder engagement) and pages 90 to 137
(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 expectations of all
stakeholders who may be impacted. For decisions which
are particularly challenging or complex, an optional page
in our paper template provides directors with further
information to support purposeful decision-making.
This additional page uses the Blueprint for Better
Business framework 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 2022.
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.
Overseeing our future strategy
What was the decision-making process?
The Board considered NatWest Group’s future strategy over
three sessions in March, June and October 2022, reviewing
and confirming its support for a plan to amplify our strategy.
In March 2022, the Board considered insights arising from a
comprehensive programme of stakeholder listening. Directors
joined breakout groups to discuss key themes, collaborating
with the executive management team and Junior Management
Team members. In June 2022, the Board agreed key areas
of focus and a vision for our purpose-led strategy, including
exploring the opportunities for sustainable growth. Then, in
October 2022, the Board reviewed and confirmed its support
for a strategic plan consistent with the ambition discussed in
June 2022, including the identification of three growth areas
where we can amplify our strategy. Throughout the process
there was strong engagement and constructive debate
among directors and management.
How did the directors fulfil their section 172 duties and how were
stakeholders considered?
Stakeholder impacts were considered throughout. The
process began with stakeholder listening, engaging on the
trends affecting our customers’ financial lives, as individual
households and institutions, and as networks and communities.
Participating stakeholder groups included customer segments,
shareholders, colleagues, suppliers and external third parties
such as politicians and non-government organisations. Views
were also gathered on what banking services and products
might be appropriate in future. Framing the discussion in the
context of how these stakeholders viewed NatWest Group
provided a strong foundation from which to amplify
our strategy.
How was our purpose considered as part of the decision?
Building on the outputs of our stakeholder listening, our
purpose-led strategic approach considered where and how we
could drive new growth by becoming more relevant, and more
trusted, in supporting our customers’ financial lives. Our purpose
was the core governing objective in defining our three growth
areas and supported the assessment of specific initiatives.
Actions and outcomes
In October 2022 the Board confirmed its support for a plan
to amplify our strategy and will oversee progress in 2023.
Further information on our strategy, including the three growth
areas, can be found on pages 22 to 23.
Factors considered:
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Appointing a new non-executive director
What was the decision-making process?
On 30 September 2022, the Board approved the appointment
of Roisin Donnelly as an independent non-executive director
with effect from 1 October 2022. The appointment followed
a rigorous search process led by the Group Nominations and
Governance Committee (Group N&G) on behalf of the Board.
To support the Board’s decision, a detailed paper described
how Ms Donnelly had been identified as the preferred
candidate. Directors considered how the role specification
criteria had been met and how the appointment would
enhance the Board’s composition, including its diversity.
Following discussion, the Board approved the appointment,
noting that Ms Donnelly would bring extensive customer, digital,
ESG, marketing and branding experience to the Boardroom.
How did the directors fulfil their section 172 duties and how were
stakeholders considered?
In identifying the skills, knowledge and experience required at
Board level to support delivery of NatWest Group’s purpose and
strategic priorities, a long-term view was taken.
From a customer perspective, the Board discussed how
Ms Donnelly’s strengths in consumer markets, data and digital
transformation would enhance the Board. It would also help
with supporting business transformation and growth.
In the context of maintaining a reputation for high standards
of business conduct, directors considered detailed character
references from Ms Donnelly’s current and previous Boards
prior to approval, and in order to support their assessment of
Ms Donnelly’s fitness, propriety and suitability. Directors also
noted that Ms Donnelly had sufficient time to devote to the
role and that the UK Corporate Governance Code criteria
on director independence would be met.
How was our purpose considered as part of the decision?
Ensuring a diverse Board with an appropriate balance of skills,
knowledge and experience is critical in delivering effective Board
oversight of the business, which in turn supports our purpose.
Actions and outcomes
Since joining the Board, Ms Donnelly has embarked on a tailored
induction programme, spending time with key stakeholders to
deepen her knowledge of the business and the context in which
it operates.
Further details on the search process leading to Ms Donnelly’s
appointment can be found in the Group N&G report on pages
106 and 107.
Factors considered:
Approving the initial iteration
of our Climate transition plan
What was the decision-making process?
At the Annual General Meeting on 28 April 2022, shareholders
supported our ‘Say on Climate’ resolution with 92.58% of votes
cast in favour. This included the intention to publish a climate
transition plan for the company to demonstrate progress against
our ambition to at least halve the climate impact of our financing
activity by 2030, and to reach net zero by 2050 across our
financed emissions, assets under management and operational
value chain.
Following this, management continued work on the initial iteration
of our Climate transition plan and provided regular updates to the
Board, Group Sustainable Banking Committee and Group Audit
Committee. Board and Committee feedback was incorporated
into the development process, including the way in which
progress against the plan would be measured and reported.
Key dependencies discussed included government policies,
customer behaviour changes and new technology development.
An external perspective was provided to the Board by NatWest
Group’s independent climate change adviser, Lord Stern. Board
decision-making was further informed by a training session with
Dr Sarah Ivory of the University of Edinburgh, NatWest Group’s
learning partner on climate change transformation.
How did the directors fulfil their section 172 duties and how were
stakeholders considered?
Directors were mindful of their duties under section 172 during
their review of the initial iteration of our Climate transition plan
and wider related considerations. Support for third parties to
deliver their climate ambitions, including customers and suppliers,
was discussed. The Board also considered how we were
supporting customers and colleagues to ensure their actions
complemented our long-term strategic direction on climate
change. The Board supported management’s decision to
recommend that all suppliers complete an external assessment
to help the transition of our operational value chain to net zero
and nearer-term own operational footprint targets. During their
visit to Bristol in September 2022, the directors discussed with
suppliers their experience of undertaking the assessment and
its impact.
How was our purpose considered as part of the decision?
Creating and implementing the initial iteration of our
Climate transition plan is critical to fulfilling our purpose and
being sustainable.
Actions and outcomes
In February 2023, the Board approved the initial iteration of our
Climate transition plan included in the Climate-related Disclosures
Report. Progress will be tracked at executive and Board level.
Factors considered:
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Stakeholder focus areas
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 ways we have continued to support our stakeholders’ requirements during 2022.
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 2022, Net Promoter Scores (NPS) for
Retail Banking improved by 9 points for NatWest and 12 points
for Royal Bank of Scotland. NatWest Business Banking NPS
declined by 3 points and improved by 7 points for Royal Bank of
Scotland. In Commercial Banking NPS improved by 3 points for
NatWest and remained unchanged for Royal Bank of Scotland.
Refer to page 44 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 2022, we
incorporated customer feedback into a range of
innovative solutions.
Against the backdrop of the cost of living crisis during 2022, we
have helped our customers better manage their finances with
a range of new features. Our new credit score feature in our
mobile app helps customers understand their credit score,
supporting them to improve their financial health. Meanwhile,
the new Round Ups feature in our mobile banking app helps
our customers save their small change every time they use
their debit card or contactless device. To help build customers’
financial capability and make sure they’re getting the most from
our digital tools, we introduced new insights into the Spending
newsfeed on the NatWest and Royal Bank apps including Know
Your Credit Score, Travel Checklist and Energy Anniversary.
We are also the first UK high street bank to launch a bill-splitting
function – Split Bill – in our banking app using Open Banking,
making it simple to split bills with friends and family.
To support more startups with digital solutions we collaborated
with Business Data Group (BDG), a business formation service,
to make it simpler for new businesses to find our startup
support and services, including accessing and opening our
Start-Up Account, more quickly and easily. Collaborating
with Cogo, we also launched the pilot of an app to selected
manufacturing and transport business banking customers
to track their carbon footprint using their transaction data.
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.
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.
Improving financial capability sits at the heart of the
bank’s purpose.
We want to provide the people, families and businesses
we serve with the skills and the confidence to manage
their money better and take control of their finances.
And with financial wellbeing concerns rising due to
the increases in the cost of living, this has never been
more important. In addition to our flagship financial
capability programme for young people, MoneySense,
our Financial Foundations pilot programme aims to help
develop good money practices and financial resilience
for adults.
Initially, the Financial Foundations programme centred
around a series of free, interactive workshops facilitated by
trained bank colleagues for small groups of young adults,
job seekers and survivors of domestic abuse.
However, the financial challenges of 2022 meant there
was a much wider interest in the programme from new
audiences. As well as local authorities, social housing
groups and higher education teaching staff, we received
enquiries from large corporate and commercial clients.
A.S. Watson Group is one such example. It operates over
1,300 retail stores across the UK and Republic of Ireland
including the Savers and Superdrug brands, which employ
around 20,000 people across these locations.
We delivered the Financial Foundations workshops as a
webinar to a range of their colleagues, covering topics such
as budgeting, planning for the unexpected and managing
debt. The response to the sessions was excellent, with the
group’s head of Payroll, Shared Services & Reward noting
that they prompted ‘reflection on money management,
personal spending habits and other important topics for
our colleagues in this climate’.
Following the success of these workshops, and to meet the
growing number of requests, the Sustainable Banking team
is now developing a variety of delivery methods to allow us
to reach these new audiences at scale.
Building strong
financial
foundations
Scaling our financial capability education
Stakeholder focus areas
NatWest Group
| 2022 Annual Report and Accounts
42
Evolving sustainable design
for our branches
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 dark and light
modes 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.
Supporting our customers
At any time, a customer may find themselves either in a
vulnerable situation or caring for a loved one experiencing a
vulnerability. During 2022, we were aware that cost of living
pressures had the potential to make this a reality for many
of our customers. As such, we initiated proactive contacts to
customers in 2022 to offer support and information on the cost
of living. We also launched an online cost of living hub to share
resources and tools, and to inform customers of the support
that is available to them through third parties. And throughout
the volatility in the mortgage market in 2022, we remained
open for business, ready to serve our customers.
We continued to support our customers in other ways as well.
In collaboration with SafeLives, we have reached more than
2,000 domestic and economic abuse survivors through a
£1 million Circle Fund donation. The Fund has supported
frontline services to provide crisis intervention, increase safety
and help support recovery, after a dramatic rise in cases of
abuse over lockdown. Our support for young people continued
with the launch of our new pocket money product, NatWest
Rooster Money, which helps children build money confidence
and develop positive money habits around saving and spending.
We have built a smooth connection to Rooster Money via the
main mobile app and there have been c.89,000 Rooster Money
card openings in 2022.
Cost of living support
As part of our response to the cost of living crisis the bank took
action on a range of fees and charges for personal customers in
financial difficulty and those receiving support from its Financial
Health & Support team, this included waiving fees on products
where appropriate to support customers experiencing financial
difficulty. We also delivered 5.1 million
(*)
financial capability
interactions in 2022, including carrying out c.0.7 million
financial
health checks. Meanwhile, to provide certainty to SMEs,
Business Current Accounts remained available without
a minimum charge and we froze the standard published
tariffs on these accounts for 12 months. We also announced
a £1.25 billion lending package to our c.40,000 farming
customers within the agriculture sector.
A sustainable
mindset
We know that achieving our overall climate
ambition means significantly reducing our
direct own operations emissions. Making
our branches more sustainable is a vital
part of this.
Since 2020, we have been on a journey to
improve and embed sustainable practices
across all our branch locations.
This has included improving the EPC ratings of
our buildings for better energy efficiency, the
reuse of furniture to minimise waste, and the
use of natural, biodegradable or recycled and recyclable
materials. In addition, LED lighting is being deployed
throughout all our branches as standard to further
reduce energy consumption.
In 2021, we delivered our first sustainable hub in
Bristol: a dynamic space providing a safe and relaxing
environment, focused on accessibility and supporting
vulnerable customers, and which achieved the SKA
(1)
Silver accreditation
Importantly, this also provided valuable insights into the
practices we can deploy elsewhere in other branches.
Since then, we have completed a further four sustainable
hubs, all of which have also achieved the SKA Silver
accreditation and, importantly, evolved our learning
each time.
We have recently completed refurbishments at our Milton
Keynes branch and in our drive towards ‘circularity’ we
continue to maximise the use of pre-loved furniture and
recycled materials, as well as implementing technology
such as heat pumps and building management systems
to assist with reducing energy requirements. This includes
daylight energy saving lighting systems and timing clocks
for external signage and marketing digital displays.
But our ambition is to do more. We will continue to
improve our design practices and use only the most
sustainable suppliers and materials with an aim of
achieving Gold SKA accreditation in early 2023.
(1) The SKA assessment scheme, which has been developed by the Royal
Institution of Chartered Surveyors (RICS), assesses the environmental impact
of refurbishments and fitouts.
(*)
Within the scope of EY assurance. Refer to page 70.
43
NatWest Group
| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Stakeholder focus areas
continued
NPS
Account opening
Q4 2022
32
Q4 2022
24
Q4 2022
49
Q4 2022
33
Q4 2021
28
Q4 2021
14
Q4 2021
45
Q4 2021
25
Source: Strategic NPS benchmarking study run through InMoment
Source: Strategic NPS benchmarking study run through InMoment,
based on 12-month rolling.
Source: Strategic NPS benchmarking study run through InMoment
Source: Strategic NPS benchmarking study run through InMoment
Mortgage
Mobile Banking
Online Banking
Retail Banking
(1)
Q4 2022
75%
Q4 2022
67%
Q4 2021
74%
Q4 2021
70%
Source: Yonder reputation tracker, GB, Trust among Retail Banking customers
Source: Yonder reputation tracker, GB, Trust among Retail Banking customers
NatWest
Royal Bank of Scotland
Customer Trust
Overall NPS
Royal Bank of Scotland Retail
Q4 2022
-6
Q4 2022
-6
Q4 2021
-3
Source: MarketVue Business Banking from Savanta, England & Wales, Businesses with a
turnover up to £750k
Q4 2021
-13
Source: MarketVue Business Banking from Savanta, Scotland, Businesses with a turnover
up to £750k
Q4 2022
16
Q4 2022
12
Q4 2021
13
Source: MarketVue Commercial Banking from Savanta, England & Wales, Businesses
with a turnover above £750k
Q4 2021
12
Source: MarketVue Commercial Banking from Savanta, Scotland, Businesses with a
turnover above £750k
Banking:
NatWest Retail
(1)
NatWest Business
NatWest Commercial
Q4 2022
22
Q4 2021
13
Source: Strategic NPS benchmarking study run through InMoment, England & Wales
Q4 2022
10
Q4 2021
-2
Source: Strategic NPS benchmarking study run through InMoment, Scotland
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.
Royal Bank of Scotland Business
Royal Bank of Scotland Commercial
(1)
Smartphone interviewing was integrated into the NPS survey from December 2021 to provide a better respondent experience, maintain robust sample sizes and keep us in line with
industry best practice. Due to this methodology change we have seen an uplift in NPS scores for all brands.
NatWest Group
| 2022 Annual Report and Accounts
44
Investors
A key milestone was reached in March 2022 when we agreed an off-market purchase of 550 million shares from UK
Government Investments, for a total of £1.2 billion. This took its stake in NatWest Group below 50% for the first time
since 2008. Further selling by the government as part of its ongoing trading programme has reduced its stake further
throughout the year.
Private investors
We engaged with our private investors through our Annual
General Meeting, virtual shareholder events, and our annual
and strategic report communications.
The AGM was held in April 2022 and, for the first time in two
years, we were able to invite shareholders to attend in person.
We also held a live virtual shareholder event a week prior to the
AGM where shareholders were invited to submit questions in
advance of and during the virtual event. A General Meeting and
Class Meeting of ordinary shareholders were also held in August
2022 to approve a special dividend and an associated share
consolidation of ordinary shares.
In addition, we held a further virtual shareholder event in
November 2022. At this event, we spoke about the initiatives
NatWest Group is involved in to support its customers. We
also published a shareholder update on the topic, which set
out initiatives such as the package of support for customers,
colleagues and communities to help with the rising cost of living.
The virtual shareholder events remain a key component of our
stakeholder engagement programme and provide an opportunity
for shareholders 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 2023. Our
shareholder updates and recordings of our virtual shareholder
events can be found on our website at natwestgroup.com.
Institutional investors
Our well-established programme of global institutional investor
engagement saw management host 322 meetings with equity
investors and 242 meetings with fixed income investors in 2022.
The financial year began with a presentation on our annual
results in February 2022, hosted by our Chairman, CEO
and CFO. This live event took place virtually and included
an interactive Q&A session to give research analysts and
investors an opportunity to ask questions and engage with
our management team. Further quarterly results presentations
took place virtually alongside the release of our financial results
in April, July and October 2022.
Our CEO and CFO engaged regularly with UK Government
Investments and our largest active institutional investors
throughout the year to update them on our progress. As
in-person contact resumed in 2022, we hosted a hybrid
programme of in-person and virtual one-to-one and group
meetings with institutional investors from around the world.
Meetings with investors covered key topics such as progress
against our financial targets, interest rate sensitivity, capital
return policy, environmental, social and governance topics,
regulation and the macroeconomic environment. Throughout
the year as market movements and investor sentiment were
influenced by the war in Ukraine, energy prices, inflation and
the wider macroeconomic outlook, meetings became more
focused on these areas and the health of the UK consumer
and corporate environment.
Environmental, Social and Governance (ESG) issues were
regularly discussed at our one-to-one meetings and we also
engaged with specialist socially responsible investors via
meetings with ESG analysts from institutional investors, and
increased interactions with sustainability rating agencies. We
further enhanced our ESG reporting suite with an inaugural
Non-financial Information Datasheet to allow investors and
analysts to more easily find data on our key ESG metrics.
Our climate reporting received external recognition, winning
the Best Climate-related Reporting Award at the 2022 ESG
Reporting Award and the Accounting for Sustainability
Finance for the Future Award.
Our ongoing Investor Relations programme also allows investors
the opportunity to hear from the wider management team. In
June 2022 we hosted a data round table, inviting investors and
analysts to join a presentation and Q&A on our data strategy.
Throughout the year, our business CEOs and CFOs attended
industry conferences and hosted broker-organised meetings
with groups of investors on their specific business areas,
allowing investors the opportunity to hear about their
strategic priorities and recent business performance.
Say on Climate
At the Annual General Meeting on 28 April 2022, shareholders
supported our ‘Say on Climate’ resolution with 92.58% of votes
cast in favour. This included the intention to publish a climate
transition plan for the company to demonstrate progress
against our ambition to at least halve the climate impact of
our financing activity by 2030, and to reach net zero by 2050
across our financed emissions, assets under management
and operational value chain.
45
NatWest Group
| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Stakeholder focus areas
continued
Colleagues
Our colleagues are the heart of our business. By supporting them in what they do and by ensuring that NatWest
Group is a great place to work, we can champion their potential and collectively deliver our purpose.
Listening to our colleagues
We listen to our colleagues and use this insight to attract,
engage and retain the best talent for the future. Our colleague
listening strategy contributes to our deeper understanding of
colleague sentiment and includes: our colleague opinion surveys
including pulse 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. We also track metrics
and key performance indicators which we can benchmark
with sector and high-performing comparisons.
Over 48,000 colleagues (82%) across all countries and levels
participated in our September 2022 Our View survey
1
. At 82%
this response rate is one of the highest seen in the last 10 years.
In the face of an unprecedented external environment, our
results remain strong and show overall resilience. However,
lead measures in culture, wellbeing and purpose fell marginally,
while our inclusion measure remained stable and, despite the
challenging backdrop, our measure on building capability
improved. Across all comparable categories, NatWest Group sits
an average of six percentage points above the Global Financial
Services Norm (GFSN) and two percentage points above the
Global High Performance Norm (GHPN).
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.
Our CAP was set up in 2018 to help promote colleague
voices in the boardroom. In 2022, topics included remuneration
(including executives and the wider workforce), our values,
future skills and the work being done to support customers in
vulnerable situations. We also remain committed to respecting
our employees’ rights of freedom of association across all
our business.
For full details on CAP refer to the Corporate governance
report and ESG Disclosures Report.
Performance and reward
Performance management at NatWest Group is a continuous
approach aligned to our ambition to be a learning organisation
and to enable all colleagues to thrive and reach their full
potential. At the core of our performance management
approach are regular performance and development
conversations between line managers and their colleagues.
Refer to our ESG Disclosures Report for full details.
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 make sure we do so.
In the UK, our rates of pay continue to exceed the Living
Wage Foundation benchmarks and we make sure employees
performing the same roles are paid fairly. We help colleagues
to 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. We
announced a range of support measures in response to the cost
of living crisis. In September 2022, we provided a permanent
uplift in salary to our lower-paid employees. This targeted action
was complemented by a one-off cash payment in January 2023
to most of the workforce and further significant investment in
fixed pay from April 2023.
Refer to our Directors’ remuneration report for
full details on our remuneration policies,
cost of living support and employee share plans.
Helping colleagues realise their potential
We’re investing in our workforce to deliver long-term,
sustainable performance by providing our colleagues with the
capabilities and future skills they need to fulfil their potential,
underpinned by our ambition to be a learning organisation.
We have a significant focus on supporting all colleagues to be
ready for the future and have given colleagues two days per
year dedicated to developing priority future skills aligned to
our Critical People Capabilities. Our ambition is that half of our
elective learning is focused on future skills by the end of 2023.
Our technology is supporting this by providing personalised
recommendations for learning, gigs, mentors and jobs, based
on colleagues’ skills and skills interests.
(1) NatWest Group Our View results exclude Ulster Bank RoI.
NatWest Group colleague
listening
Workplace, our
social media
platform
Pulse surveys
Our View, our
colleague
opinion survey
Colleague
representative
engagement
Colleague
Advisory Panel
Colleague
Experience
Squad
Employee-led
networks
NatWest Group
| 2022 Annual Report and Accounts
46
We’re supporting our businesses to close the future skills gap,
through reskilling programmes, predominantly in data and digital.
In 2022, 167 colleagues were reskilled for a new future-focused
role or have actively participated in a programme. Our Talent
Academy continues to develop our highest potential colleagues,
with over 3,300 colleagues participating in 2022. Our pipeline of
future talent continues with over 1,135 joining the bank through
our early career programmes as interns, graduates and
apprentices, which focus on building future skills including
through our new financial crime graduate programme and
our award-winning internship programme.
Our leadership and coaching faculty supports leaders and
their teams. Our new leadership experience, Thrive, launched
in 2022 to give our leaders opportunities to learn and grow to
lead themselves and their people. Our succession planning is
purpose-led with our framework spotting, developing and
mobilising a diverse pool of our most promising talent,
supported by our ExCo.
Refer to our ESG Disclosures Report for full details
on how we support colleagues to realise their potential.
Supporting our colleagues’ wellbeing
We recognise that taking proactive action to support positive
mental health and wellbeing plays a crucial part in achieving
our purpose. We were delighted to collaborate with Just Ask
A Question (JAAQ), a new mental health and wellbeing social
media platform that provides information from trusted experts,
academics and people with lived experience.
In addition to our mental health focus, we worked with Peppy
Health, launching a brand new digital product on menopause
providing colleagues and their partners with online support
and access to specialist clinicians.
To support our colleagues’ financial wellbeing we launched the
new NatWest Group Benefits Hub in 2022. The online platform
allows employees to manage their benefits, pension and to
access NatWest Group offers and discounts.
We also have a new market-leading partner leave policy from
January 2023. The policy supports all eligible employees with
significantly more time away from work to look after their new
child, whether the child has arrived through birth, adoption or
surrogacy.
For full details of our partner leave policy,
wellbeing focus, including financial wellbeing,
refer to our ESG Disclosures Report.
Colleague highlights
As the needs of our stakeholders have evolved, our values
have needed to evolve too: to align more closely with
our purpose and strategy; to become a simple way of
explaining what’s important to us; and to help us be
the kind of bank all our stakeholders want us to be.
To do this, we refreshed our values through a truly
collaborative process. We talked and listened to around
11,000 colleagues, customers, community stakeholders
and suppliers to understand what they value personally
and what they value from us. And together we created,
tested and refined our values with them.
Our refreshed values of being Inclusive, Curious, Robust,
Sustainable and Ambitious, were launched to colleagues,
customers and communities in February 2022 and now
inspire and guide us in everything we do.
These values are helping us to live our purpose on our
journey to work as One Bank: to transform we need to be
ambitious but sustainable. To work together we must be
inclusive and curious and consider broad perspectives, not
just work in silos. And, in everything we do, we must bring
a robust commitment, act with integrity and make
good decisions.
Transformation isn’t just about implementing our strategy
or updating our technology, it’s about thinking and acting
differently, and our values are guiding us to do that.
What’s more, we’re proud to say that these are values
that have been created by our people, for our people.
Refreshing our values
167
colleagues reskilled as part
of a formal programme
2021: 20
39%
increase in elective
learning vs 2020 baseline
1,135
graduates, apprentices
and interns hired
2021: 1,057
35%
elective learning
focused on future skills
(**) References to ‘colleagues’ in this Strategic report mean all members of our
workforce (which include contractors and agency workers).
47
NatWest Group
| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Stakeholder focus areas
continued
Diversity, equity and inclusion
Creating a diverse, equitable and inclusive workplace is integral to fulfilling our purpose. It enables us to work
together to achieve great things with our colleagues, communities and customers. We will stand up for people who
are excluded, remove barriers that stop people progressing in their careers and create a safe, happy and healthy
environment for all. We want to give everyone who works here, and every customer who comes into contact
with us, the chance to succeed and the support to thrive.
Our contribution towards an inclusive workplace
The One Bank Diversity, Equity & Inclusion Action Committee
chaired by Jen Tippin, Chief People and Transformation Officer,
and Marg Jobling, Chief Marketing Officer, continues to take a
focused and impactful approach to diversity, equity and inclusion
(DE&I). Three workstreams have been developed to drive action
and change.
For full details refer to the ESG Disclosures Report.
Over 36,000 colleagues have enrolled in our learning module
Choose to Challenge which educates participants on the
importance of challenging non-inclusive behaviours. We have
also encouraged colleagues to take other learning modules such
as LGBT+ Awareness and Disability Smart, to continue to build
a more inclusive workplace in NatWest Group.
We launched a revised and improved Recruitment YES Check to
ensure DE&I is front of mind at every stage of the recruitment
process. We also introduced Inclusive Interview Ambassadors
who are trained in technical aspects of interviewing, along with
inclusion and identifying bias, to help bring an objective lens to
the recruitment decision-making process. In 2022, we increased
our team of ambassadors to over 800 and introduced them
in India.
Sponsorship plays a key role in breaking down barriers to help
under-represented groups progress into senior leadership roles.
We have created a best practice sponsorship guide, with a clear
framework to encourage leaders to advance and retain diverse
talent, by taking responsibility for supporting and advancing
individuals across the organisation.
We highlighted DE&I globally during our Inclusion Week in
September 2022. #ThePowerofNow was the theme and events
were centred around this topic globally, which included a talk
from Dr Grace Lordan, founder of The Inclusion Initiative, as
part of our Leadership Thrive Lounge on Leading Inclusively.
We continuously support our eight employee-led networks,
which have around 24,000 members globally. We have also
refreshed our Inclusion Champion programme for our c.1,000
registered champions.
For full details refer to the ESG Disclosures Report and
natwestgroup.com.
We celebrated Race Equality Week in February 2022, with the
theme of #ActionsNotJustWords and Black History Month in
October 2022, focused on Black Visibility is Power. During Black
History Month, a number of events showcased how visibility of
Black professionals is driving change, and we published our
annual Banking on Racial Equality Taskforce update.
Following its relaunch in 2021, our Ethnicity Advisory Council,
comprising nominated external specialists from different
industries, continued to meet regularly to provide critical
challenge, guidance and direction on our strategy.
For the fifth time, NatWest Poland organised the LGBT+
DIAMONDS AWARDS to recognise individuals and organisations
making a real change for LGBT+ colleagues in Poland. The
hybrid event had strong engagement with 160 nominations
and over 50 partnering companies. NatWest Group was also
the headline sponsor of Trans Festival in August 2022, an event
in London focused on what businesses can do to support the
Trans community. We ranked 49
th
(up from 83
rd
in 2018) in
Stonewall’s UK Workplace Equality Index and were awarded
Gold status for inclusion.
We are a signatory of HM Treasury’s Women in Finance
Charter and our Executive Sponsor for Gender, David Lindberg
(CEO, Retail Banking), is part of the external Accountable
Executive Taskforce for the Charter. In 2022, we introduced
the returnship initiative, which targets the women’s returners
market, to build our pipeline using a specialist recruitment
partner. Our women’s engineering reskilling programme,
delivered with Code First Girls, won the Champions of
Change category at the Management Today DE&I
Leadership Awards 2022.
Our Global Accessibility Working Group helps us to be
an accessible bank by design, enabling all colleagues and
customers to thrive. The group has three focus areas: to ensure
colleagues understand what accessibility means and the benefits
of inclusive design; to inform colleagues with the knowledge and
skills to design and build our policies and processes inclusively;
and to ensure accessibility is in our existing methods and
frameworks. NatWest Group renewed our leadership status
in the UK Government Disability Confident Scheme and we are
working with Lexxic, our external neurodiversity specialists,
to develop a roadmap to enhance our performance on
neurodiversity for colleagues.
Our ambition is to create an inclusive environment where
everyone has the same opportunity to progress their career,
irrespective of their socio-economic background. In 2022, we
created the One Bank Socio-Economic Working Group, to
further our work in this area.
For full details refer to the ESG Disclosures Report.
‘Respect, listening and
opening up opportunity are
key to an inclusive culture.’
Alison Rose
Group Chief Executive Officer
NatWest Group
| 2022 Annual Report and Accounts
48
Our progress and targets
Colleague sentiment on inclusivity remained strong in
2022, maintaining a score of 93 percentage points. Although
sentiment has remained consistent in all our colleague groups,
our focus remains on where scores may vary for our minority
colleagues. We ran a smaller pulse survey in June 2022, focused
on championing belonging, in which 95 percentage points of
colleagues agreed NatWest Group does a good job of
highlighting the importance of DE&I.
In line with our commitment to transparency under the UK
Government’s Race at Work Charter, we have voluntarily
disclosed our aggregated ethnicity pay gap for NatWest Group
UK. The mean ethnicity pay gap for NatWest Group is 7.2%
(median: 10.3%). The mean ethnicity bonus gap for NatWest
Group, excluding recognition vouchers, is 21.8% (median:
16.9%). This year we have broken down our ethnicity pay
gaps to compare Asian, Black, mixed/multiple and other
ethnic minority colleague’s average hourly pay to that of White
colleagues for NatWest Group in Great Britain. This highlighted
a wider pay gap between Black and White colleagues than the
average ethnicity pay gap. The target set in 2021 to increase
the number of Black colleagues in CEO-5 and above UK
roles is intended, alongside other initiatives, to address
underrepresentation in this area.
For our full pay gap report refer to natwestgroup.com.
In 2020 we launched the Racial Equality Taskforce to listen,
learn and better understand barriers faced by colleagues
from ethnic minority backgrounds. The Taskforce set out 10
commitments in the Banking on Racial Equality Report, including
a UK target to have Black colleagues occupying 3% of UK roles
(CEO-5 and above) by 2025. At 31 December 2022, we have
1.5% of colleagues who identify as Black in CEO-5 and above
roles in the UK, which remains consistent from 2021. Overall, of
those who share their ethnicity, 3% of our colleagues in the UK
identify as Black.
For our Banking on Racial Equality Report refer to
natwestgroup.com.
2022 Our View inclusion score
93%
2021: 93%
+8 vs GHPN (Global High Performance Norm)
+9 vs GFSN (Global Financial Services Norm)
Our Board composition exceeds the FTSE Women Leaders
Review (formerly the Hampton Alexander Review) target of
a minimum of 40%
(*)
women’s representation on the board by
2025, with a figure of 45% women’s representation. We have
women representation of 29% on our executive management
team with a woman Chief Executive Officer, Chief Financial
Officer, Chief Marketing Officer, Chief People and
Transformation Officer, and Chief Governance Officer
and Company Secretary.
We have a target to have full gender balance in our CEO-3 and
above global roles by 2030. At 31 December 2022, we had, on
aggregate, 40% women in our top three layers
(*)
, an increase of
2% since 31 December 2021. This represents an increase of
11% since targets were introduced in 2015.
(**)
The mean gender pay gap for NatWest Bank, our largest
reporting entity, is 28.7% (median: 31.6%) and the mean gender
bonus gap is 30.4% (median: 17.5%). If we include recognition
vouchers in our calculation, the bonus gap increases to 52.5%
(median 90.2%). This means every colleague who received a
small recognition award – for example £10 – is included in
the calculations, whether or not they received a bonus. Most
colleagues in our more junior jobs only receive fixed pay – a
change made to provide more certainty over earnings. We
currently have a higher proportion of women in these roles.
We believe the figures excluding recognition vouchers are
more accurate reflections of our gender bonus gap.
For our full pay gap report refer to natwestgroup.com.
Introduced in 2018, our ethnicity target is to have 14% of
colleagues from ethnic minority backgrounds in CEO-4 and
above positions in the UK by 2025. At 31 December 2022, of
82% of colleagues who disclosed their ethnicity, we have an
aggregate 11% of colleagues from ethnic minority backgrounds
in our CEO-4 and above positions
(*)
. This represents a 3%
increase since targets were introduced and remains consistent
from 2021. Overall, of those who disclose their ethnicity, 19%
of colleagues in the UK identify as being from an ethnic
minority background.
Companies Act 2006, section 414C (8)(c) disclosure
Male #
Female #
Directors of the company
6
5
Executive employees
69
26
Directors of subsidiaries
182
64
Permanent employees
(active and inactive)
31,500
30,600
17 Directors of subsidiaries have not declared their sex.
There were 358 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.
UK Corporate Governance Code Provision 23: As at 31 December 2022, the gender
balance of senior management and their direct reports was 33% female and 67% male.
For the purposes of this note, senior management means our executive management
team (which includes the Company Secretary).
Our partners and recognition
For full details, refer to our Diversity,
Equity & Inclusion pages at natwestgroup.com.
For a full breakdown of our colleague data,
including our gender and ethnicity profiles by
level,
Refer to our Non-financial information
datasheet at natwestgroup.com.
(*)
Within the scope of EY assurance. Refer to page 70.
(**) NWG’s management structures were revised during 2022. For the purpose
of remuneration reporting, the representation targets were set based on the
management structures in place at the start of the FY 2022 with performance
assessed against these at 31 December 2022. Based on the management structures
at the start of 2022, we had 41% women in our CEO-3 and above global roles as at
31 December 2022, an increase of 3% since 31 December 2021. This reflects a 12%
increase since the targets were introduced in 2015.
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Stakeholder focus areas
continued
Communities
Continuing to give back
Our ambition is to support and give back to the communities we
operate in. Our direct community investment in 2022 amounted
to £13.6 million
(*)
compared with £7.3 million in 2021, as
measured using the Business for Societal Impact benchmarking
standard. This includes the funding we make available to
support colleague giving and the direct costs of delivering
our community programmes.
In 2022, we continued to promote our Do Good Feel Good
campaign to give our colleagues opportunities to support the
good causes they care about through volunteering their time
and fundraising. Across all our fundraising and volunteering
programmes, our colleagues gave back £3.8 million and
c.76,000 worktime volunteering hours, providing their skills
and expertise to support a range of causes.
Our popular challenge events in September 2022 offered
colleagues across the UK free access to fundraising events
which included walking, running, bungee jumping and abseiling.
In addition, we matched all colleague fundraising throughout the
month of September. Through this campaign, our colleagues
raised £583,276 for charitable causes. Our 2021 Do Good Feel
Good challenge events won Best Scheme to Encourage Staff
Fundraising at The Better Society Awards in May 2022.
To celebrate Giving Tuesday, a global day of giving held on
29 November 2022, our colleagues donated £200,000 to
charities through payroll giving. We also matched customer
reward donations, raising £150,000. In recognition of the cost of
living crisis, we also held three auctions of rare and collectable
banknotes, donating the proceeds to The Trussell Trust, a
charity which supports a network of foodbanks across the
UK and which has seen demands on its services increase
exponentially during 2022.
During 2022, our colleagues and customers donated to three
appeals launched by the Disasters Emergency Committee
(DEC) to support the humanitarian relief efforts in Afghanistan,
Ukraine and Pakistan. This led to a donation of £12 million to
the DEC, including a £2.7 million donation from NatWest Group.
As a result, the DEC and NatWest Group won Gold for the most
effective one-off campaign and Silver for the most innovative
collaboration at the 2022 Corporate Engagement Awards.
Through our customer giving channels, including our mobile
app, Reward Account and website, we facilitated customer
donations amounting to £7.6 million. Our mobile app has proved
to be a successful channel for generating additional income for
the charity sector and raised over £4.6 million in 2022. In 2022,
we introduced three new charities to the list of nominated
charities our customers can donate to through their Reward
Accounts. The three new charities are linked to our purpose
and are helping to support people affected by the cost of
living crisis.
Elsewhere Tyl, our card payment provider for businesses,
donated £274,785 to charity. For every card payment,
Tyl donates to charities and community projects around
the country.
Delivering impact in our communities
NatWest Group has three independent, well-established
charities, which continue to support specific activities in line
with our purpose, including The NatWest India Foundation
(1)
, the
Coutts Foundation
(2)
and NatWest Social & Community Capital
(3)
.
NatWest Social & Community Capital was established in 1999
and is supported by the bank. Its mission is to enable social
enterprises, charities and community businesses to make a
positive impact on communities across the UK through
flexible loan finance.
The charity has a specific focus on organisations delivering
employability, education and training for those furthest from
the labour market, services for the most disadvantaged and
community regeneration, and works with social ventures unable
to access mainstream funding. In addition to lending, NatWest
Social & Community Capital provides business support and
expertise to its clients and has access to a pool of volunteers
they can turn to for practical advice.
NatWest Social & Community Capital was recognised as
Nationwide Social Lender of the Year 2022 at the UK Enterprise
Awards. It was also shortlisted for Social Investment Deal of
the Year at the 2022 Social Enterprise UK Awards for a funding
deal for social-led business, Northumbria Youth Action, which
enabled the company to continue trading and develop young
people’s skills to help them enter employment.
As a leading financial firm in the UK, we believe we can make a real and positive difference to people’s lives.
(1) The Foundation’s company registration number (CIN) is: U45200MH2007NPL167933
(2) Charity Registration No: 802643
(3) Charity Registration No: 1079626
(*)
Within the scope of EY assurance. Refer to page 70
Community highlights
c.76,000
hours volunteered
by our colleagues
c.72,000
trees planted
£13.6m
in direct community
investment
(*)
£12m
donated to DEC appeals
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Following the invasion of Ukraine, colleagues from
right across the bank did what they could to help.
Donations from NatWest Group colleagues and
customers to the DEC Ukraine Humanitarian Appeal
exceeded £10 million. This included £2.5 million
matching from the bank, over £2.3 million in Reward
donations (including Gift Aid) and £284,000 (including
Gift Aid) donated by colleagues through our
SponsorMe page.
Gogarburn House, in the grounds of our head office in Edinburgh,
was made available to the Scottish Government and Edinburgh
City Council to use as a welcome centre for people displaced
from Ukraine, and greeted over 10,000 people during the year
since opening in April 2022. Importantly, we set out information
on our customer websites (in Ukrainian and Russian) to help
refugees arriving in the UK from Ukraine who were in need
of bank accounts.
We also pledged £100,000 to support 500 Ukrainian students
to continue their studies at Polish universities and polytechnics.
Many of our colleagues felt the need to help directly. For
Anna Majdak, based in our Warsaw office in Poland, this meant
travelling to the border with Ukraine to directly offer her support.
Together with her husband and friends she set up a stall offering
clothes and food to those crossing into Poland. They also
transported people to the registration centre four kilometres
from the crossing.
‘The first trip was a natural, spontaneous reaction’, Anna recalls.
‘What we saw there showed how much our help was needed
and was in fact essential.’
‘We made a collection available so people could donate money
for fuel and the purchase of necessary items. After a week at
the border, our stall was fully equipped including a grill to
provide hot food.’
Many of the refugees Anna helped were children. ‘There were
many that crossed the border alone,’ she says. ‘They were able
to wait with us being warmed up with blankets in our cars, until
family members were able to pick them up.’
Elsewhere, our colleagues opened their homes to families fleeing
the conflict, helped Ukrainians secure access to medical facilities
and provided language classes.
Support for Ukraine
How NatWest Group was
able to help
Celebrating 15 years’ working with
The Conservation Volunteers
In November 2022, we were delighted to celebrate 15 years
of working in partnership with The Conservation Volunteers,
enabling our colleagues to give their time, energy and
skills to support vital conservation projects across the UK.
Together we have created new woodland areas, built new
green parks and restored derelict land to community use.
The impact of this work will be felt for years to come.
In 2022, we continued to provide colleagues opportunities
to participate in our tree planting programme, helping them
to make a positive contribution to tackling climate change,
while improving natural environments, enjoying the benefits
of being outdoors and working together as a team. In 2022,
our colleagues planted c.72,000 trees, with 2,890 planted
during a special event at our headquarters at Gogarburn,
Edinburgh. This event was attended by our Coutts Scotland
colleagues to celebrate Coutts’ collaboration with The
Queen’s Green Canopy, an initiative inviting people and
communities to plant a tree to mark the Platinum Jubilee of
Her Majesty Queen Elizabeth II and to benefit the environment.
Banking on Racial Equality
Our Banking on Racial Equality report, published in October
2020, set out 10 commitments to our customers, colleagues
and communities from ethnic minority backgrounds and
the actions – new and existing – that would help us meet
those commitments.
On the second anniversary of the report in 2022, we
published an update on our progress and identified areas
where we still need to improve. To help build a more
inclusive culture, we have introduced mandatory training
for all colleagues and an ethnicity ally programme.
For the first time, and with oversight from the Board and
Group Executive Committee, we have taken a bank-wide
approach to assessing the health and diversity of succession
planning at CEO-1 and CEO-2 levels for c.200 value-creating
and specialist jobs, matching talent with the potential,
aspirations and skills required to thrive in these roles.
During 2022, we published ‘Time to Change: A Blueprint
for Advancing the UK’s Ethnic Minority Businesses’ with the
Centre for Research in Ethnic Minority Entrepreneurship at
Aston University.
However, there is much more we still need to do. By
regularly tracking and disclosing our progress against our
commitments, we can identify areas where more action
is needed to deliver long-term change.
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Stakeholder focus areas
continued
Suppliers
Our Supplier Charter
Our Supplier Charter (which replaced our Supplier Code of
Conduct in 2020) sets out our aims and expectations for ethical
business conduct, human rights, environmental sustainability,
diversity and inclusion, the Living Wage and prompt payment.
It details what we expect from our suppliers and outlines our
commitments and the outcomes we aim to achieve by
working together.
Working alongside the Group Chief People and Transformation
Officer – the new Accountable Executive of our Supplier
Charter – we have completed our annual review of the charter.
The Supplier Charter continues to help us become a more
sustainable business, delivering better outcomes for our
customers, colleagues, shareholders and the communities
in which we operate.
Central to its aims, we worked with EcoVadis, a leading provider
of evidence-based assessments of sustainability performance.
EcoVadis is helping us to understand and measure the
performance of NatWest Group and our suppliers against core
ESG pillars, enabling us to identify social, environmental, and
ethical improvements.
In 2022, we made tangible progress, with over 531 suppliers
scoring an average of 55.4% against the Global EcoVadis average
of 44.8%. EcoVadis also conducted a sustainability assessment of
NatWest Group, where we scored 62%, which is higher than the
global EcoVadis average of 49% for the financial services sector.
Supporting our suppliers to net zero
We have an ambition to halve emissions from our operational
value chain by 2030, against a 2019 baseline, with a minimum
of a 90% reduction by 2050. We are focused on how we start
to work with our suppliers and customers on understanding and
reporting their own emissions and build the capability to measure
and report these together. Our suppliers’ data should help us to
measure and monitor our own indirect climate impact which will
enable us all to take the right steps towards net zero.
We are in the process of scoping out a multi-year programme
to work with our supply chain to reduce carbon emissions.
During Q4 2022, we undertook data analysis to understand
the capability of our suppliers, where they are on the journey
to net zero, and what help they might need to progress.
Prompt payment
We continue to pay our suppliers promptly for the services
they provide to us. Our standard payment terms are 30 days,
however, we have continued to maintain immediate payment
on goods and services received, which supports our suppliers
and the cost of living crisis. This goes significantly beyond our
commitment undertaken as a signatory to the government’s
Prompt Payment Code, which requires payment to be made
in 60 days.
Good Business Pays is a campaign to end late or slow payments
to suppliers. For the second year running, NatWest Group was
recognised for fast payment throughout the company, winning
the Fast Payer Award for a consecutive year, placing us in the
top seven companies in 2022.
Respecting human rights
At NatWest Group, we understand that businesses
have an important role to play in promoting
respect for human rights.
We seek to promote and respect human rights through
the continued application of policies and practices covering
our colleagues, customers and suppliers. Our approach to
respecting human rights takes into account a range of
international standards and principles including the UN
Guiding Principles on Business and Human Rights (UNGPs).
We reviewed and updated our Human Rights Position
Statement in 2022.
Tackling modern slavery is integral to our approach to
human rights. We publish an annual modern slavery
statement outlining the actions and steps we take to
identify and address the risks of modern slavery and
human trafficking within our own operations and wider
value chain.
In 2022, we engaged with various stakeholders, including
charities, non-governmental organisations (NGOs) and
campaign groups on human rights to help grow our
knowledge and understanding of the issues. We continued
our membership of the Thun Group and the UN Global
Compact’s UK Modern Slavery Working Group and we
report annually against the Principles for Responsible
Banking, the Equator Principles and UN Global Compact.
Further information on our approach to
human rights, including our annual Modern Slavery
and Human Trafficking Statement, can be found
at natwestgroup.com.
Regulators
We operate in a highly regulated market which
continues to evolve. As such, we understand the need
to have an ongoing, constructive and open dialogue
with all relevant regulatory bodies.
Ongoing dialogue
During 2022, this included bilateral responses to material
consultations or other requests for comment and input from
various government, regulatory and standard-setting bodies.
Key consultation responses included the FCA’s Consumer Duty
proposals and the Payment Systems Regulator’s proposals on
Authorised Push Payment (APP) scams.
We formally engage with our regulators, at senior executive
and Board level, as well as via individual non-executive directors,
through continuous assessment and proactive engagement
meetings. Most notably, during 2022, we kept our regulators fully
informed of contingencies and impacts on our operations as a
result of Russia’s invasion of Ukraine and the cost of living crisis.
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Funding the drive
to clean transport
Championing
sustainability ambitions
NatWest Group has set out a clear ambition
to be a leading bank in the UK helping to
address the climate challenge. A key part
of this is providing financing structures for businesses that
are developing sustainable energy.
One such business is electric vehicle fleet and battery storage
specialist
. Established in 2017,
currently works
with the majority of major bus operators in the UK, as well as
local authority-owned bus companies, to electrify their fleets
and minimise the lifetime costs of their electric vehicles (EV)
and charging infrastructure. The company also provides
battery storage solutions to grid operators, accelerating
the uptake of renewables.
By 2025,
aims to have a fleet of at least 3,000 EV
buses, and 1GW of battery storage.
To support this ambition, the company has established a
funding platform with an initial volume of £241 million, which
will enable it to service and finance up to 430 new e-buses in
the UK and Republic of Ireland.
Having worked with NatWest Group on an innovative financing
facility in 2021,
turned to our team again to advise on a
multi-source debt structure to help accelerate the expansion of
the EV fleet sector.
Our One Bank team, comprising colleagues from Private
Placements, Specialist Asset Financing, Risk Solutions, ESG
Advisory and Climate & ESG Capital Markets, collectively
delivered a bespoke funding package. This incorporated green
loans and private placements that adhered to the Loan Market
Association’s Green Loan Principles attracting institutional
investors and bank lenders.
We believe this financing will have a real-world impact for
accelerating the UK’s drive to electrify its public road
transport system.
Combined with
’s technical expertise, the funding enables
the company to offer end-to-end services to the bus operators
including the design, installation, financing and operation of
electrical charging infrastructure and buses in the depot.
This is a clear example of our purpose in action: building
relationships with businesses such as
, championing
its potential and empowering it to deliver on its
sustainability ambitions.
Climate case study
Watch the
story online
The QR code above directs
to a case study video on
our 2022 Annual Report
webpage. None of the
information on that webpage
(including the case study
video) is, or should be read
as being, incorporated by
reference into this report.
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Our climate strategy
Our Climate strategy
Our climate ambition
To be a leading bank in the UK helping address the climate challenge
We have an ambition to be net zero by 2050 across our financed emissions,
assets under management (AuM) and our operational value chain
We plan to reduce the carbon
intensity of our in-scope
AuM by 50%, against a 2019
baseline, and to move 70%
of in-scope AuM to a
net-zero trajectory.
(1)
We have an ambition to at
least halve the climate impact
of our financing activity by
2030, against a 2019 baseline,
and align with the 2015
Paris Agreement.
We plan to reduce emissions
for our operational
value chain by 50%,
against a 2019 baseline.
Our Purpose
To
champion potential,
helping people, families and businesses to thrive
Our 2030 climate ambitions
How we are helping to address the climate challenge
Supporting customer
transition to net zero
We have a target to provide
£100 billion climate and sustainable
funding and financing between
1 July 2021 and the end of 2025.
As part of this we aim to provide
at least £10 billion in lending for EPC
A and B rated residential properties
between 1 January 2023 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.
Helping to end the
most harmful activities
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.
Powerful partnerships
and collaborations
We plan to collaborate cross industry
and create products and services to
enable customers to track their
carbon impact.
Getting our own
house in order
Each year, we plan to include targets
for executive remuneration that
reflect our latest climate ambitions.
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).
Achievement of our Climate transition plan is dependent on
timely, appropriate government policy, technology developments,
as well as on our customers and society to respond. At the
same time, as a purpose-led organisation, we aim to engage
and support our customers’ transition to a net-zero economy.
Refer to section 3 of the 2022 NatWest Group plc Climate-
related Disclosures Report for further details.
For further detail on our climate ambitions and SBTi targets
refer to sections 1.3 and 3.3 of the 2022 NatWest Group plc
Climate-related Disclosures Report.
Climate transition plan and dependencies
For details on our approach to Nature and Biodiversity refer to the 2022 NatWest Group plc Environmental, Social and Governance (ESG) Disclosures Report.
We have a target to reduce our
direct own operations emissions
by 50% by 2025, against a
2019 baseline.
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.
Notes:
(1) Refer to pages 38 to 39 of the Net Zero Asset Managers Initiative’s Initial Target Disclosure Report (May 2022).
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The table below outlines progress during 2022 – which supports our ambition to be a leading bank in the UK helping to address the
climate challenge. Aligned with our ambition to set sector specific targets, during 2022 we published 2030 targets validated by the
SBTi as science based. These targets included our own operational footprint as well as 79% of our 2019 lending book. For further
details on the initial iteration of our Climate transition plan, our 2030 ambitions and our ambition to be net zero by 2050 across our
financed emissions, assets under management and operational value chain refer to the 2022 NatWest Group plc Climate-related
Disclosures report.
Climate ambition
Progress update
Supporting customer transition to net zero
We have a target to provide £100 billion climate and
sustainable funding and financing between 1 July 2021 and
the end of 2025. As part of this we aim to provide at least
£10 billion in lending for EPC A and B rated residential
properties between 1 January 2023 and the end of 2025.
In the year ended 31 December 2022, we provided £24.5 billion
(*)
of climate and
sustainable funding and financing.
We have now provided £32.6 billion
(*)
of climate and sustainable funding and financing
towards our £100 billion target between 1 July 2021 and the end of 2025. This
includes £5.4 billion for EPC A and B rated residential properties.
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 UK mortgage portfolio has an
EPC rating of C or above by 2030.
As at 31 December 2022, 41.5%
(*)
(31 December 2021 38.3%) of our UK residential
mortgages portfolio that had EPC data available
(1)
was rated as EPC C or higher.
Helping to end the most harmful activities
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.
Exposure to coal customers
(2)
, as defined in the Credible Transition Plan (CTP)
assessment completed in 2021, was £0.3 billion
(*)
as at 31 December 2022
(£0.6 billion as at 31 December 2021). For further details refer to page 41 and
section 5.1 of the 2022 NatWest Group plc Climate-related Disclosures Report.
Powerful partnerships and collaborations
We plan to collaborate across industry and create products
and services to enable customers to track their carbon impact.
Engaged with policymakers and officials on a range of climate-related topics,
recognising the importance of collaboration and significant role that policy has to play
in providing the long-term frameworks, incentives and certainty required for progress
on net zero. As part of the Sustainable Homes and Buildings Coalition, we engaged on
the need to improve the energy efficiency of the UK’s housing stock, focusing on how
this can be accelerated.
Engaged with peers, policy makers and stakeholders through GFANZ, Transition Plan
Taskforce, NZBA, Financial Markets Stability Board and NZAM initiative to facilitate a
net-zero transition.
Getting our own house in order
Each year, we plan to include targets for executive
remuneration that reflect our latest climate ambitions.
Climate considerations continue to be included in senior executive remuneration as
part of the bonus pool assessment for our wider workforce, recognising its central role
in our strategy.
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).
Increasing use of quantification in risk assessments with enhanced analytics
capabilities under development for integration in the EWRMF.
Enhancement of core strategic climate risk modelling capabilities and initial integration
into risk management and customer journeys.
We have a target to reduce our direct own operations
emissions by 50% by 2025, against a 2019 baseline.
We reduced our direct
(3)
own operations emissions by 46% against a 2019 baseline.
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 increased our consumption of renewable electricity to 98% across our global
operations. For operations in the UK and Republic of Ireland, electricity consumption
used 100% renewable electricity.
Energy productivity has increased by 41% since 2015, and electricity consumption
decreased by 8% since 2021.
We plan to install electric vehicle charging infrastructure in
15% of large office space across our UK portfolio by 2025 and
upgrade our fleet of 100 vehicles to electric by 2025 (EV100).
As at 31 December 2022, we have installed electric vehicle charging points in 13%
of our large office car park spaces across our UK portfolio. In addition, as part of our
ambition to electrify our fleet, we reviewed and reduced our fleet size from 300 to
approximately 100 vehicles, of which 3% are EVs.
(1) As at 31 December 2022, £138.8 billion, 68%, of the total residential mortgages portfolio had EPC data available.
(2)
As defined in the Credible Transition Plan (CTP) assessment. Refer to pages 30 – 31 of the NatWest Group plc 2021 Climate-related Disclosures Report for further details on
the assessment of CTPs for oil and gas majors and in-scope coal customers.
(3)
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
(*)
Within scope of EY assurance. Refer to page 70.
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Bank of England publishes SS3/19,
outlining how banks should manage
climate-related financial risks
Founding members of Glasgow Financial Alliance for Net Zero
(GFANZ), Net Zero Banking Alliance (NZBA) and member
of Powering Past Coal Alliance. Joined Net Zero Asset
Managers (NZAM) initiative
Principal partner for COP26
Task Force on
Climate-related Financial
Disclosures (TCFD)
created by the Financial
Stability Board
Announced our purpose-led
climate ambition.
SBTi issues financial services sector
science-based targets guidance
First major UK bank to join Partnership
for Carbon Accounting Financials (PCAF)
Annual General Meeting: Say on Climate resolution
Science-based targets validated by STBi for
79% of our lending book and own
operational emissions.
Initial iteration of Climate transition plan developed
Launched Carbon Planner to support
customer transition
Launched Carbonplace
Climate transition plan overview
Our transition to net zero
NatWest Group has been a signatory to the United Nations Environment Programme Finance Initiative (UNEP FI)
since 1997 and the Equator Principles since 2003. We have come a long way since activists protested against our
financing of oil, gas and coal in 2010. In 2011, we launched our Environmental, Social & Ethical (ESE) Risk Framework,
which required enhanced due diligence for certain lending and loan underwriting customer relationships, transactions,
activities and projects. We recognise that through our financing activity NatWest Group may contribute to climate
change. As the initial iteration of our Climate transition plan illustrates, we are committed to playing our part in
addressing the climate challenge, but we cannot transform the real economy on our own. Ultimately, success will be
determined by society’s willingness to adapt, supported by consistent, long-term government policy and continuing
technical innovation.
Key opportunities
to support the transition
Financed emissions
Provision of £100 billion climate and sustainable funding
and finance between 1 July 2021 and the end of 2025. As
part of this we aim to provide at least £10 billion in lending
for EPC A and B rated residential properties between
1 January 2023 and the end of 2025.
Development of carbon tracking tools.
Enhanced customer and colleague education tools.
Building powerful partnerships to support customer transition.
Refer to the 2022 NatWest Group plc Climate-related
Disclosures Report, section 3.4, 3.5, 5.3, 5.5 for details
There is a dependency on timely, appropriate
Government policy, technology developments, as well as
on our customers and society to respond. At the same
time, as a purpose-led organisation, we aim to engage
and support our customers’ transition to a net-zero
economy. Further detail on how we are exploring
potential opportunities and dependencies for transition
is available in section 3 of the
2022 NatWest Group plc
Climate-related Disclosures Report.
(1)
Our climate transition planning uses different time frames than those used in financial reporting. Accordingly, the references to “short”, “medium” and “long-term” in climate
reporting are not indicative of the meaning of similar terms used in this report or in certain of our other disclosures, including our annual, periodic and interim reports.
2019
2021
2015
2020
2022
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Refer to the 2022 NatWest Group plc Climate-related
Disclosures Report section 3.2, 3.4 for details
Refer to the 2022 NatWest Group plc Climate-related
Disclosures Report, section 3.7 and 5.4 for details
Target to provide £100 billion climate and sustainable funding
and financing between 1 July 2021 and the end of 2025. As part
of this we aim to provide at least £10 billion in lending for EPC A
and B rated residential properties between 1 January 2023 and
the end of 2025.
Target to reduce emissions from direct own operations by 50%
by 2025, against a 2019 baseline
Ambition to at least halve the climate impact of our financing activity, against a
2019 baseline, and align with the 2015 Paris Agreement
Ambition for 50% of our UK mortgage book has an EPC rating of C or above by 2030
Plan to reduce emissions for our operational value chain by 50%, against a 2019 baseline
Plan to reduce the carbon intensity of our in-scope AuM by 50% against a 2019 baseline
and align 70% of in-scope AuM to a net-zero trajectory
Ambition to achieve net
zero across our financed
emissions, AuM and
operational value chain
Assets Management
Move 50% of our assets under management to a net-zero
trajectory by 2025.
Voting and engagement in line with net zero, including
support for climate-related shareholder resolutions.
Continue to build net zero into our investment process
and our engagement with funds.
Own operational footprint
Install electric vehicle charging infrastructure in 15%
of large office space across our UK portfolio by 2025
100% renewable electricity for global operations
by 2025.
Continue to increase energy efficiency in our buildings
through updated technology, design and data analysis.
Review the buildings we occupy and move to more
sustainable buildings where appropriate.
2025
Short-term
(1)
2050
2030
Medium-term
(1)
Long-term > 15 years
(1)
‘Net zero is the growth
opportunity of the 21
st
century’
Mission Zero, Independent Review of Net
Zero Report by Rt Hon Chris Skidmore
MP, published in January 2023
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FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
TCFD Summary
TCFD: Climate-related
disclosures overview
NatWest Group confirms that it has:
made climate-related financial disclosures for the year ended December 31, 2022 that it believes are consistent with the
Task Force on Climate-related Financial Disclosures (“TCFD”) Recommendations and Recommended Disclosures (as defined in
the FCA’s Listing Rules, as amended by the Disclosure of Climate-Related Financial Information (No 2) Instrument 2021) which
include (i) “Recommendations of the Task Force on Climate-related Financial Disclosures” (June 2017) (focusing in particular on
the four recommendations and the eleven recommended disclosures set out in Figure 4 of Section C of the TCFD Final Report);
(ii) “Implementing the Recommendations of the Task Force on Climate-related Financial Disclosures” (October 2021 version);
(iii) “Guidance on Metrics, Targets and Transition Plans” (October 2021 version); (iv) Technical Supplement - “The Use of Scenario
Analysis in Disclosure of Climate-related Risks and Opportunities” (June 2017); and (v) “Guidance on Risk Management Integration
and Disclosure” (October 2020) and summarised in the tables on pages 58-61;
set out these disclosures in this report and in its “2022 NatWest Group Climate-related Disclosures Report”, both published on
17 February 2023 (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 these reports.
Governance
NatWest Group’s governance around climate-related risks and opportunities
The Board’s oversight of climate-related risks and opportunities
2022 progress
92.58% of votes cast were in favour of our Say on Climate resolution, indicating strong shareholder support for our climate strategy.
The NatWest Group Board and Board committees oversaw the development of the initial iteration of our Climate transition plan and approved
the plan prior to publication.
Future priorities
Board and Executive Committee (ExCo) continuing oversight of delivery, and ongoing development, of the initial iteration of NatWest Group’s
Climate transition plan, development of customer level decision-making tools as well as regular monitoring of climate ambitions.
NatWest Group plc 2022 Climate-related Disclosures Report sections 2.1, 2.2
Management’s role in assessing and managing climate-related risks and opportunities
2022 progress
Business areas have enhanced local governance forums to support an integrated management response to delivering our climate ambitions,
development of the initial iteration of our Climate transition plan, the identification of climate-related opportunities and the effective management
of climate-related risks. In addition, cross-bank climate-related forums continue to provide strategic insight and expertise, supporting collaboration
and ensuring a One Bank approach to climate governance.
Future priorities
Continue to build knowledge and further embed operating models and business processes across the organisation to support the oversight and
management of climate-related risks and opportunities within NatWest Group’s overall business strategy and risk appetite.
NatWest Group plc 2022 Climate-related Disclosures Report sections 2.1, 2.3, 2.4
Governance
Strategy
Risk
Management
Metrics and
Targets
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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
2022 progress
NatWest Group’s climate ambition, announced in February 2020, recognises various short, medium and long-term
(1)
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
Continue to integrate climate-related decision-making in business activities.
NatWest Group plc 2022 Climate-related Disclosures Report sections 3.1, 3.2, 4.2, 5.1
The impact of climate-related risks and opportunities on our businesses, strategy and financial planning
2022 progress
We developed the initial iteration of our Climate transition plan. This plan focuses on the delivery of our 2030 decarbonisation ambitions and
will inform further work on our journey to net zero by 2050 across our financed emissions, assets under management and our operational
value chain.
We have enhanced the financial planning process to incorporate actions included within the initial iteration of our Climate transition plan and also
used the financial forecasts to consider impacts on our Climate transition plan.
We continued to harness climate-related opportunities including providing climate and sustainable funding and financing and a range of green
loan products and services.
Future priorities
We will continue to work on aligning the financial planning and transition planning processes.
We will further enhance carbon planning, measurement and tracking capability to support the ongoing development of our Climate transition plan.
NatWest Group plc 2022 Climate-related Disclosures Report sections 1.2, 1.3, 1.4, 2,3, 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.7, 4.2.
4.2a, 4.3, 5.4, 5.5, 5.7
The resilience of our strategy, taking into consideration different climate-related scenarios, including a 2°C or lower scenario
2022 progress
We ran internal scenario analysis and completed round two of the Bank of England’s Climate Biennial Exploratory Scenario (CBES) exercise, as well as
developing internal scenario analysis tools and core strategic climate risk modelling capabilities to embed within our existing risk management processes.
This work allowed us to assess our exposure to climate-related risk across our lending book and provided insights which we continue to incorporate within
our climate strategy and to inform work on the initial iteration of our Climate transition plan.
One of the key lessons from this work is that while climate-related risks could potentially amplify other risk drivers, for example resulting in effects such as
the erosion of competitiveness, profitability, or reputational damage, overall NatWest Group is resilient to these risks, within the context of the scenarios
tested, and we will continue to monitor and manage this through our enterprise-wide risk management framework (EWRMF).
A priority area of focus for NatWest Group in 2022 has been the continued enhancement of how we incorporate climate risk into our capital adequacy
assessment process (ICAAP) and strategic planning process. This ensures that we have sufficient capital for the most material source of climate risk over
the capital planning horizon.
Future priorities
Continue to enhance scenario modelling and analytic capabilities.
Address significant challenges related to the availability of granular, reliable and verifiable customer data.
Respond to developing regulatory requirements on the approach to climate-related risk within the regulatory capital regime.
NatWest Group plc 2022 Climate-related Disclosures Report sections 4.2a, 5.5
Governance
Strategy
Risk
Management
Metrics and
Targets
(1)
Our climate transition planning uses different time frames than those used in financial reporting. Accordingly, the references to “short”, “medium” and “long-term” in climate
reporting are not indicative of the meaning of similar terms used in in certain of our other disclosures, including our annual, periodic and interim reports.
59
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ADDITIONAL INFORMATION
TCFD Summary
continued
Risk Management
How NatWest Group identifies, assesses and manages climate-related risks
Our processes for identifying and assessing climate-related risks
2022 progress
We reviewed and refreshed our assessment of the relative significance of climate risk on other principal risks. This assessment used
the judgement of risk subject matter experts combined with scenario analysis, increased granularity of climate data, as well as improved
understanding of evolving regulatory guidance to understand the current and potential impact of physical and transition climate-related risk
as a causal factor to other principal risks.
We identify and assess climate-related risks through three principles:
Undertaking scenario analysis to understand the potential impacts of climate-related risks.
Identifying segments of our portfolio and operations with heightened climate-related risk exposure. In 2022 we established an increasingly
quantitative methodology for the identification and assessment of heightened climate-related risk sectors and subsectors.
Assessing individual customer and supplier climate-related risk exposure. In 2022, we completed the development and launch of qualitative
climate risk scorecards and conducted sustainability assessments of our suppliers.
NatWest Group regularly considers existing and emerging regulatory requirements related to climate change through external horizon scanning
and monitoring of emerging regulatory requirements.
Future priorities
Scaled implementation of quantitative scorecards within credit assessment processes.
NatWest Group plc 2022 Climate-related Disclosures Report sections 4.2, 4.2a
Our processes for managing climate-related risks
2022 progress
We launched preliminary shadow operational limits supported by EPC for transition risk and physical flood risk data, to monitor the performance
of the current Retail Banking mortgage portfolio and new mortgage business.
Credit assessment processes have been improved to support customer interactions, including mandatory climate conversations with in-scope
(1)
customers. These conversations reflect the specificity of sector and asset class, and the size and sophistication of these customers.
Future priorities
Evolution and application of appropriate credit limits informed by climate-related risk and transition plans.
Continued evolution and monitoring of Environmental, Social and Ethical Risk Acceptance Criteria in accordance with framework.
Review of internal control standards in response to the outcomes of the non-financial risk scenario.
NatWest Group plc 2022 Climate-related Disclosures Report sections 4.3
How our processes for identifying, assessing, and managing climate-related risks are integrated into overall risk management
2022 progress
We continued to mature our integration of climate risk within NatWest Group’s risk management. This involved increasing use of quantification
in risk assessments with enhanced analytics capabilities under development for integration in the enterprise-wide risk management
framework (EWRMF).
Enhanced reporting to relevant senior governance forums covering areas of risk concern across all material sectors and portfolios.
Regular monitoring of an initial suite of quantitative key risk indicators for climate risk.
Future priorities
Work will continue to further integrate climate-related risks across business processes to work towards full integration within our risk
management framework and business-as-usual decision-making.
NatWest Group plc 2022 Climate-related Disclosures Report sections 4.1
Governance
Strategy
Risk
Management
Metrics and
Targets
(1)
Guidance on in-scope customers is tailored to each business area and detailed in the Climate Transaction Acceptance Standards Handbook. For example, for Business Banking
Relationship Managers the criteria is – new or increased lending applications of £50,000 and above.
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Metrics 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
2022 progress
Metrics used to assess climate-related risks:
Exposures to heightened climate-related risk sectors;
Energy efficiency and flood risk assessment for UK residential mortgage portfolio;
NatWest Group’s own operational footprint;
Estimates of financed emissions based on absolute emissions and emissions intensities, including progress against sectoral
decarbonisation pathways;
Estimates of facilitated emissions from corporate bond underwriting.
Metrics used to assess climate-related opportunities:
Climate and sustainable funding and financing;
NatWest Group Own Green Bond issuance.
Refer to the Directors’ Remuneration Report in the NatWest Group plc 2022 Annual Report and Accounts for further details on integration of climate
considerations into remuneration.
Future priorities
Continue to develop metrics and measurement capabilities to monitor and manage climate-related risks and opportunities.
Continue to develop measurement, monitoring and reporting capabilities for Asset management.
Continue to monitor evolving carbon measurement standards and enhance capabilities including continuing engagement with PCAF on finalisation of the
financed emissions standard.
NatWest Group plc 2022 Climate-related Disclosures Report sections 3.2, 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
2022 progress
We continued to develop and enhance capabilities to measure emissions in relation to our own operations as well as financed emissions.
We reduced emissions from our direct own operations by 46%, against a 2019 baseline, and increased our renewable electricity consumption
to 98%.
Future priorities
Continue our work to enhance the availability of data and data quality to support future calculations of financed emissions including absolute
emissions and emissions intensities.
NatWest Group plc 2022 Climate-related Disclosures Report sections 5.4, 5.5, 5.7
The targets used to manage climate-related risks and opportunities and performance against targets
2022 progress
Our stated climate ambition is to be a leading bank in the UK helping to address the climate challenge. We have an ambition 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: supporting customer transition to net zero, helping to end the most harmful
activities, powerful partnerships and collaborations and getting our own house in order.
NatWest Group was the first UK bank, and one of the largest banks globally to date, to have science-based targets validated by the SBTi.
Our portfolio targets cover 79% of lending activities by outstanding exposure as at 31 December 2019.
Future priorities
Continue to monitor our performance against our climate-related targets and ambitions and revise as appropriate.
NatWest Group plc 2022 Climate-related Disclosures Report sections 1.2, 1.3, 1.4, 3.1. 3.3, 3.4, 5.4, 5.5, 5.7
Governance
Strategy
Risk
Management
Metrics and
Targets
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ADDITIONAL INFORMATION
Own operational footprint
In 2021, we disclosed an initial view of our upstream
(3)
emissions,
and for 2022 we are disclosing both our upstream and our
downstream
(4)
emissions to report on our full operational value
chain
(5)
emissions for the first time, covering Scopes 1, 2 and 3
(all relevant categories 1-14, with category 15 financed emissions
covered in section 5.5 of the 2022 NatWest Group plc Climate-
related Disclosures Report).
Our 2022 total market-based operational emissions of 73,927
tCO
2
e covers Scopes 1, 2 and our direct own operations
upstream Scope 3. This includes emission reductions from
the use of green electricity covering 98% 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.
We purchased and retired 120,000 carbon removal credits,
assured under the Verified Carbon Standard (VCS), and Triple
Gold certified to the Climate, Community & Biodiversity Alliance
Standards (CCBA) to invest beyond our value chain, and
provide benefits to climate, especially those that generate
additional co-benefits for people and nature
(6)
. By investing
beyond our value chain, these carbon credits mitigate direct
operational emissions of 73,927 tCO
2
e in 2022, while we
continue to decarbonise in line with SBTi. Further detail of our
decarbonisation plans can be found in the initial iteration of
our Climate transition plan in section 3.7 of the 2022 NatWest
Group plc Climate-related Disclosures Report and on our
website at natwestgroup.com.
Our operational emission reductions are linked to remuneration.
For further information, refer to the Directors’ Remuneration
Report on page 138.
Supply chain
We have used a spend-based approach
(7)
to calculate our
supplier emissions. In late 2022, we established a (multi-year)
Supplier Decarbonisation Programme to support delivery of
the 2030 and 2050 carbon reduction ambitions related to our
operational value chain. This will involve collaborating with our
suppliers to understand their capability, data, where they are
on the journey to net zero, and what help they might need
to progress.
We are also working with a third party to evaluate our
supply chain using evidence-based assessments of sustainability
performance enabling us to understand our wider impact and to
identify where improvements can be made, and risks mitigated.
As part of increasing the sustainability of our cash and coin
operations, we have engaged our suppliers to reduce the
(1) Our own operational footprint reporting year runs from 1 October 2021 to 30 September 2022.
(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) Upstream emissions relate to the Scope 3 Categories 1–8 under the Greenhouse Gas Protocol.
(4) Downstream emissions relates to the Scope 3 Categories 9–15 under the Greenhouse Gas Protocol.
(5)
Our operational value chain is Scope 1, Scope 2, Scope 3 (Categories 1-15, with categories 8, 10, 14 excluded and Category 15 reported in section 5.4 of the 2022 NatWest Group
plc Climate-related Disclosures Report. Refer to the 2021 NatWest Group plc Climate-related Disclosure Report where these categories are described in more detail.
(6)
The SBTi recommends that companies invest to mitigate emissions beyond their value chain while they transition towards a state of net zero emissions. In accordance with the
Greenhouse Gas Protocol, emission reductions cannot be achieved through the use of carbon credits.
(7) Category 1 and 2 emissions have been calculated using spend data and publicly sourced sector-specific emission factors.
amount of single-use plastic coming in and going out of our
cash centres and to improve the accuracy of data for our
waste streams.
For our properties, the suppliers we work with must have
environment and quality management accreditations and
products used in fitouts should meet all Royal Institution of
Chartered Surveyors SKA criteria as standard.
Energy
Following the return to the office after the easing of COVID-19
restrictions, we focused on the practice of using energy more
efficiently and effectively in our operations and reviewed our
processes to reduce consumption.
Building energy optimisation:
our building plant equipment
is continuously reviewed to maximise energy efficiency.
Data analytics are used to proactively identify anomalous
consumption, ensuring our buildings run more efficiently.
Energy audits:
there have been audits carried out in most
of our buildings this year to identify where we can improve
energy efficiency and reduce consumption and this work will
continue in 2023.
Data centres:
we have consolidated our data centres to
allow for more efficient IT architecture using fewer resources.
The work carried out ensures they run more efficiently,
with lighting upgrades and optimisation of the data hall
environmental controls already seeing a significant
reduction in water and power usage.
Renewable electricity:
in 2021, we committed to a
Corporate Power Purchase Agreement (cPPA), bringing
additional renewable generation capacity online to facilitate
the decarbonisation of the UK grid. We are continuing
to work towards this with additional cPPAs, and once
constructed they are expected to generate 59% of
NatWest Group’s electricity demand in the UK by 2024.
Leased buildings:
for our leased buildings in India, we
are working with the landlords to review the scope for
identifying energy-saving opportunities, assessing end
of life for equipment, and creating an energy efficient
replacement plan where possible.
Colleague engagement:
we launched a bank-wide energy
campaign in the second half of 2022 to help educate and
engage our colleagues by sharing tips on how to reduce
consumption at home and in the office through a series of
activities, raising the importance of energy saving actions.
This is an ongoing campaign which we will continue to
work on in 2023.
Own operational footprint
During 2022
(1)
, we reduced our direct own operations
(2)
emissions by 46%, against our 2019
baseline, and increased our renewable electricity consumption to 98% globally.
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62
Streamlined energy and carbon reporting (SECR)
2022
2021
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)
(*)
14,877
1,363
17,560
1,650
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)
(*)
47,546
15,430
56,461
18,159
Total gross Scope 1 & Scope 2 (location-based) emissions CO
2
e (tonnes)
(*)
62,423
16,793
74,021
19,809
Energy consumption used to calculate above emissions (kWh)
298,262,392
35,070,567
329,317,585
40,484,981
Intensity ratio: Location-based CO
2
e emissions per FTE
(Scope 1 & 2) (tonnes/FTE)
1.6
1.0
1.8
1.1
Scope 3
(4)
CO
2
e emissions from direct operations
(5)
(tonnes)
(*)
39,559
15,743
36,197
8,967
Total gross Scope 1, 2 & 3 direct own operations (location-based) emissions
CO
2
e (tonnes)
(*)
101,982
32,536
110,218
28,776
Intensity ratio: Location-based CO
2
e emissions per FTE
(Scope 1, 2 & direct operations Scope 3) (tonnes/FTE)
2.5
2.0
2.7
1.7
Scope 2
(6)
(Indirect) market-based CO
2
e emissions (tonnes)
(*)
13
2,372
8
2,186
Emissions methodology and basis of preparation
Boundary:
this statement has been prepared in accordance with our regulatory obligation to report greenhouse gas (GHG) emissions
pursuant to the Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 which
implement the government’s policy on Streamlined Energy and Carbon Reporting. Our reporting year runs from 1 October 2021
to 30 September 2022. 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 uses a third-party software system, to capture and record our
environmental impact and ensure that control framework and assurance 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 third-party system. For more
information, please see the own operational footprint page at 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)
The historic values reported in the table above are updated from values we reported in 2021. This is due to updated bills, data provision and extrapolations.
(6)
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.
(7)
Market-based Scope 2 emissions. We have procured 100% of UK and RoI and 98% globally from renewable sources using green tariffs and renewable electricity certificates.
The 13 tCO
2
e arises from district cooling and district heating, which is used at only a few sites.
(*)
Within the scope of EY assurance (2022 only). Refer to page 70.
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ADDITIONAL INFORMATION
Our approach to risk management
The enterprise-wide risk management framework
(EWRMF)
sets out our approach to managing risk across
NatWest Group and provides a common risk language and
framework to facilitate effective risk management. The
framework applies to all subsidiary legal entities, business
segments and functions and links each component of the
framework to help deliver NatWest Group’s strategy in a
safe and sustainable way.
Risk culture
NatWest Group’s multi-year programme to enhance risk
management capability at every level of the organisation
continued in 2022, with an ongoing emphasis on risk culture.
We refreshed our approach to risk culture under a new banner
of intelligent risk-taking, intensifying focus on robust risk
management behaviours and practices.
Evolving our risk culture, in line with our purpose-led strategy
and our values across all three lines of defence, enables us to
support better customer outcomes, develop a stronger and
more sustainable business, and deliver an improved cost base.
During 2022, five key outcomes to deliver on the intelligent
risk-taking approach were also identified. These outcomes
focused on behaviours, leadership, risk practices, decision-
making, and roles and responsibilities.
Risk governance
NatWest Group’s governance structure facilitates sound risk
management decision-making, in line with standards of good
corporate governance. The Board reviews and approves the
EWRMF and monitors performance against risk appetite. In
addition, the key risk committees have the following roles
and responsibilities:
The Board Risk Committee (BRC) is responsible for providing
oversight of current and potential future risk exposures, risk
profile, risk appetite and risk culture. The BRC also oversees
the effectiveness of the EWRMF across NatWest Group, and
reviews the performance of NatWest Group relative to risk
appetite and risk policy.
The Group Executive Risk Committee (ERC) reviews,
challenges and debates all material risk and control matters
across NatWest Group. It supports the CEO and other
accountable individuals in discharging their risk management
accountabilities. It considers NatWest Group’s risk profile
relative to current strategy and oversees implementation
of the risk management framework.
Three lines of defence
In line with industry best practice and sound risk governance
principles, NatWest Group adopts a three lines of defence
model of risk governance. Everyone has a responsibility for
the intelligent management of risk in day-to-day activities. This
includes actively demonstrating risk practices and behaviours
that are consistent with NatWest Group’s desired risk culture.
As the second line of defence, the Risk function has a clear
mandate to undertake proactive risk oversight and monitoring
of all risk management activities. The Risk function designs
and maintains the EWRMF. The Chief Risk Officer leads the
Risk function and plays an integral role in advising the Board
on NatWest Group’s risk profile. This includes continuous
monitoring activities to confirm that NatWest Group engages in
sustainable risk-taking activities in pursuit of strategic objectives.
Risk appetite
The risk appetite framework is a component of the EWRMF
and establishes the extent of permissible risk-taking to support
business outcomes and delivery of the strategy. The EWRMF
sets out the requirements on how risk appetite is implemented
through risk policies and standards and translated into operational
procedures. This consistent approach is followed for all principal
risks, frameworks, tools and techniques to support efficient and
effective consolidation and interpretation.
Risk directory and principal risks
To ensure common language and a consistent approach across
NatWest Group, the risk directory defines and documents all
principal risks that NatWest Group may face, categorised
into financial and non-financial risks. The risk directory is an
important component of the EWRMF, underpinning the linkage
between strategy, risk appetite, risk reporting and governance.
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, procedures and controls so that 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 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.
Risk management
Risk overview
Effective risk management ensures that NatWest Group delivers
its long-term strategy and fulfils its purpose.
NatWest Group
| 2022 Annual Report and Accounts
64
Top and emerging threats
Top and emerging threats are a component of the EWRMF
and identify and manage threats that could have a significant
negative impact on our ability to operate or deliver NatWest
Group’s strategy. They are specific scenarios that usually
combine elements of several principal risks and require a
coordinated management response. Top and emerging threats
are subject to regular review by senior governance forums
including the Board, ERC and BRC.
Horizon-scanning is an important activity, enabling NatWest
Group to identify, assess and mitigate top and emerging
threats including via strategic planning. A range of methods
are used including internal working groups, scenario analysis
and consulting with external experts to ensure an external
perspective is incorporated. In 2022, there was increased
focus on assessing and understanding how different individual
risks and threats are correlated with each other, including via
scenario analysis. This approach helps to integrate strategic
risk considerations into business processes and planning
and strategy.
Additional areas of risk focus
Operational risk:
A payment review was initiated in late 2022,
to assess control enhancements in response to manual
payment risk.
Model risk:
Models are increasingly used as a key basis for
informing important business decisions. It is therefore necessary
to understand the potential for adverse consequences from
model errors and the potential for inappropriate use of modelled
outputs. Ensuring models used by NatWest Group are designed
effectively – and that model assumptions and techniques remain
fit for purpose – continued to be a key risk management focus
in 2022. This included a programme of ongoing work to
upgrade a number of models to improve performance
and compliance with new regulatory requirements.
Compliance and conduct:
Further progress was made on
the compliance agenda during 2022. The first line of defence
ring-fencing hub, established to provide an aggregated view
of ring-fencing compliance and risk management, continued
to work across business areas, functions and legal entities to
support completion of the attestation of compliance with the
PRA rules, as at the end of December 2022. From a conduct
risk perspective, the focus on consumer protection continued
during 2022, given cost of living challenges and their impact on
customers in vulnerable situations, as well as the FCA’s increased
expectations under Consumer Duty. The establishment of the
Consumer Duty One Bank programme will ensure continued
focus on delivering the required ‘paradigm shift’ in the levels
of consumer protection.
Common risk language, architecture and approach
Risk directory and principal risks
Financial risks
Non-financial risks
Risk culture
Risk governance
Three lines of defence
Risk appetite
Enterprise-wide risk management framework
Credit risk
Non-traded market risk
Capital adequacy
Liquidity and funding
Earnings stability
Pension risk
Traded market risk
Climate risk
Conduct risk
Financial crime risk
Operational risk
Regulatory compliance risk
Model risk
Reputational risk
Enterprise-wide risk management framework – core components
65
NatWest Group
| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Externally-focused top and emerging threats
Trend
Economic and
political risks
NatWest Group was affected by uncertain and volatile economic conditions in 2022 which
created a challenging operating environment. The outlook for the UK and global economy
remains uncertain including due to falling economic activity, high inflation, rising interest rates,
elevated energy prices, and the Russian invasion of Ukraine.
These conditions could deteriorate, depending on a number of factors including market
volatility, volatility in commodity prices, escalating geopolitical tensions or concerns regarding
sovereign debt or sovereign credit ratings. Economic conditions could also be affected by
changing demographics in the markets that NatWest Group serves including increasing social
inequalities or the threat of new and widespread public health crises (including any future
epidemics or pandemics).
The UK experienced significant political uncertainty in 2022, which may persist into the future.
This could lead to a loss of confidence in the UK by investors, which could in turn negatively
impact NatWest Group. NatWest Group also faces political uncertainty in Scotland, as a
result of a possible second Scottish independence referendum.
A range of complementary approaches is used to mitigate these risks, such as targeted
customer reviews, including for customer segments most vulnerable to inflationary impacts,
scenario analysis, stress tests and review of risk appetite.
Climate change
Climate-related risks represent a source of systemic risk in the global financial system.
Financial and non-financial risks from climate change can arise through physical and transition
risks. In addition, physical and transition risks can trigger further losses, stemming directly
or indirectly from legal claims, litigation and conduct liability (referred to as liability risk).
As a result, NatWest Group and its customers, suppliers and counterparties face significant
climate-related risks. Further progress was made in 2022 in managing climate-related risks,
including progress with embedding climate risk into NatWest Group’s risk framework, financial
planning and the initial iteration of our Climate transition plan.
The successful implementation of NatWest Group’s climate change-related strategy,
ambitions and transition plan will depend to a large extent on many factors and uncertainties
beyond NatWest Group’s control including the macroeconomic environment, and the
effectiveness of actions of governments, regulators, businesses, investors and customers
to mitigate the impact of climate-related risks.
Cyber threats
NatWest Group experiences a constant threat from cyberattacks across the entire NatWest
Group and against NatWest Group’s supply chain. In 2022, NatWest Group witnessed a small
number of attempted Distributed Denial of Service attacks and our supply chain was victim
to a small number of ransomware attacks. The focus is to manage the impact of the attacks
and sustain availability of services for NatWest Group’s customers. As cyberattacks evolve
and become more sophisticated, NatWest Group continues to invest in additional capability
designed to defend against emerging threats.
Competitive
environment
NatWest Group operates in markets that are highly competitive and with increasing
competitive pressures and technology disruption, raising the threat of 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 shifts in customer
behaviour. NatWest Group closely monitors the competitive environment and adapts
strategy as appropriate to deliver innovative and compelling propositions for customers.
Regulatory,
legal and
conduct risks
NatWest Group is subject to extensive laws and regulations and disclosure requirements,
which present ongoing compliance and conduct risks. For example, in 2022 these included
increased regulatory focus on customer protection via the FCA’s Consumer Duty policy
statement and final rules and guidance. NatWest Group implements new regulatory
requirements, where applicable, and incorporates the implications of related changes
in its strategic and financial plans. NatWest Group expects government and regulatory
focus on the financial services industry to remain high for the foreseeable future.
Risk management
continued
NatWest Group
| 2022 Annual Report and Accounts
66
Arrows indicate risk profile trend in 2022 versus 2021
increased risk
decreased risk
stable risk
Internally-focused top and emerging threats
Trend
Change risk
The implementation of NatWest Group’s purpose-led strategy, including the refocusing of
NatWest Markets and creation of the Commercial & Institutional segment, carry significant
execution and operational 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, NatWest Group continues to monitor and strengthen its control
environment via robust governance and controls frameworks.
Financial
crime
Financial crime continues to evolve, whether through fraud, scams, 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, including
investment in new technologies and capabilities to further enhance customer due diligence,
transaction monitoring, sanctions and anti-bribery and corruption systems. NatWest Group
continues to work with law enforcement agencies, industry bodies and regulators to develop
intelligence and collaborative solutions to prevent financial crime.
People risk
NatWest Group’s success depends on its ability to attract, retain and develop highly-skilled,
qualified and diverse personnel, including for technology and data-focused roles, in a highly
competitive market and under internal cost reduction pressures. A combination of developing
a strong people proposition, close monitoring of attrition levels and colleague wellbeing
including versus industry benchmarks are key mitigants.
Third-party
suppliers
Operational risks arise from NatWest Group’s reliance on third-party suppliers and
outsourcing of certain activities across a broad range of activity including the provision of
IT services and the adoption of new technology. While the ineffective management of risks
related to third-party suppliers could adversely affect NatWest Group, significant resources
and planning have been devoted to mitigate the risks. These include robust due diligence,
identification of strategic suppliers, appropriate oversight, and monitoring and building
close working relationships with the third parties on which NatWest Group relies.
Data
management
NatWest Group relies on the effective use of accurate data to support, monitor,
evaluate, manage and enhance its operations and deliver its strategy. The availability
of current, complete, detailed and accurate data, together with appropriate governance
and accountability for data, is fast becoming a critical strategic asset, which is subject to
increased regulatory focus. Failure 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. NatWest Group continues to be focused on delivering a long-term data strategy
alongside enhancing control and policy frameworks governing data usage.
67
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| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Considerations
In assessing NatWest Group’s future viability, the Board
considers a period of three years to be appropriate. The
budget and business planning processes are based on a
five-year horizon. However, a three-year period is considered
more suitable given levels of uncertainty increase as the time
horizon extends.
In assessing NatWest Group’s viability over the three-year
time frame, the Board has considered a wide range of
information including:
Strategic and financial outlook
NatWest Group’s business and strategic plans.
Current capital position and projections over the
relevant period.
Liquidity and funding profile and projections over the
relevant period.
Internal scenarios and stress tests, which consider the
material risks and uncertainties facing NatWest Group.
Risk management and risk profile
NatWest Group’s enterprise-wide risk management
framework (EWRMF) including the processes by which
risks are identified and mitigated.
NatWest Group’s risk profile including any breaches of risk
appetite and top and emerging threats that could have a
significant negative impact on NatWest Group’s ability
to operate.
Regulatory
Mandatory regulatory requirements including activity related
to the completion of the Bank of England annual cyclical
stress (ACS) test, the 2022 Internal Capital Adequacy
Assessment Process (ICAAP) and the 2022 Internal
Liquidity Adequacy Assessment Process (ILAAP).
Operating environment
Consideration of the wider operating environment for
NatWest Group including legal, regulatory and
competitive factors.
Assessment
NatWest Group’s business and strategic plans, which are
reviewed and evaluated on an annual basis at minimum, provide
long-term direction and assess resilience to a range of risks
across the planning horizon. These plans include multi-year
forecasts assessing NatWest Group’s expected financial
position throughout the planning period.
A suite of economic scenarios supports NatWest Group’s
financial planning processes. Stress testing is a key risk and
financial management tool and is also integrated with financial
planning processes. It is used to quantify and evaluate the
potential impact of material risks on the financial strength
of NatWest Group, including its liquidity and capital position.
Given elevated levels of uncertainty in 2022, a broad range of
economic scenarios was designed to capture uncertainties and
risks faced by NatWest Group. The scenarios were continuously
refined and reviewed. In the second half of 2022, this included
benchmarking against external forecasts and regulatory
stress tests. These scenarios explored principal risks and
uncertainties including:
Elevated geopolitical risks including Russia and Ukraine and
the impact of high and volatile energy prices.
Deep simultaneous recessions in the UK and global economy.
High and sustained levels of inflation and higher-than-
anticipated UK interest rates.
A sharp slowdown in the UK housing market including large
falls in UK house prices, reduced mortgage lending and an
increase in mortgage servicing costs.
Climate-related risks including those related to a disorderly
climate transition.
These internal scenarios were used to examine going concern
capital requirements on a forward-looking basis by assessing
the resilience of capital adequacy and leverage ratios. The
assessment included assumptions about regulatory and
accounting factors (such as IFRS 9). They also incorporated
key assumptions on balance sheet and P&L drivers, such as
impairments, to demonstrate that NatWest Group maintains
sufficient capital. Applying the scenarios to NatWest Group’s
capital, liquidity and funding positions did not result in a breach
of any regulatory thresholds.
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.
NatWest Group
| 2022 Annual Report and Accounts
68
Reverse stress testing is also carried out in order to identify
circumstances that may lead to specific, defined outcomes
such as business failure. Reverse stress testing allows potential
vulnerabilities in the business model to be examined more fully.
During 2022, reverse stress testing considered the impact of
sustained income challenges and increased impairments in a
recession. The analysis concluded that a significant drop in UK
GDP (-15% to -20%), coupled with high unemployment (13% to
16%), a collapse in house prices (-44% to -48%) and a dramatic
reduction in asset prices (commercial real estate values falling
by up to 78%) is required for NatWest Group to breach its
defined thresholds, which are currently deemed to be
implausible scenarios.
Consideration was also given to the operational resilience of
NatWest Group across a range of operational risk scenarios
including conduct, financial crime, climate and a cyberattack.
While NatWest Group has not been subject to a material
cyberattack and operates a multi-layered system of defences,
there is a possibility that a cyberattack could have a severe
effect on operations. The evolving threat is continually
monitored with a focus on managing the impact of any
attack and sustaining availability of services for NatWest
Group’s customers. As cyberattacks evolve and become more
sophisticated, NatWest Group continues to invest in additional
capability designed to defend against emerging threats.
Risks facing NatWest Group are identified and assessed through
NatWest Group’s EWRMF which is outlined in the Risk overview
section. The Board reviews and approves the EWRMF and
monitors performance against risk appetite.
Despite elevated economic and political uncertainty, NatWest
Group’s risk profile remained stable in 2022. Risk appetite is
a key consideration in assessing the risk profile and the Board
monitors performance against risk appetite including in relation
to credit risk, liquidity and funding, financial crime, conduct and
operational risk. In 2022, there were no material breaches in
risk appetite that were viewed as a threat to the viability of
NatWest Group.
NatWest Group’s top and emerging threats process also
highlights threat scenarios that could have a significant negative
impact on NatWest Group’s ability to operate or deliver its
strategy. In 2022, the top and emerging threats were subject
to regular review by the Executive Risk Committee and the
Board Risk Committee. This included horizon scanning activity,
to enable early identification and mitigation of emerging
strategic threats. Top and emerging threats are also a
significant consideration in internal scenario planning
as well as the ICAAP and ILAAP.
NatWest Group is impacted in the longer term by a wide range
of macroeconomic, political, regulatory, technological, social and
environmental developments. The evolving operating environment
presents opportunities and risks which NatWest Group continue
to evaluate including via top and emerging threats.
The 2022 Annual Report and Accounts were considered as part
of the assessment. This includes review of the principal risks
and uncertainties set out on pages 64 to 67 and highlights the
possible impact of legal, regulatory and competitive factors on
NatWest Group. The detailed disclosure of financial performance
of NatWest Group was considered as part of the assessment.
This included:
NatWest Group’s robust capital position; CET1 ratio of
14.2%. The current capital position provides significant
headroom above both NatWest Group’s minimum
requirements and its maximum distributable
amount threshold requirements.
The sustainable profitability and capital generation of
the business.
NatWest Group’s strong liquidity and funding position with
a robust liquidity coverage ratio of 145%, £52 billion of
excess over the regulatory minimum of 100% and a
net stable funding ratio of 145%.
NatWest Group participates in stress tests run by regulatory
authorities to test industry-wide vulnerabilities under crystallising
global and domestic systemic risks. The Bank of England
returned to the annual cyclical scenario (ACS) stress-test
framework in 2022 and published the scenario in September
2022. The ACS scenario was considered when calibrating
the internal scenarios and therefore informed the Board’s
assessment of viability.
The 2022 ACS was aimed at testing the resilience of the UK
banking system to deep simultaneous recessions in the UK and
global economies, large falls in asset prices and higher global
interest rates, and a separate stress of misconduct costs. The
Bank of England will publish results of the ACS in summer 2023.
NatWest Group also took part in the Bank of England’s Climate
Biennial Exploratory Scenario (CBES) conducted in late 2021
and early 2022, with the results published by the Bank of
England in May 2022. Insight from the analysis carried out to
support participation in the CBES supported further embedding
of climate risk into NatWest Group’s business model, operations
and risk framework in line with regulatory expectations.
Based on the factors outlined above, the current financial
forecasts including the strength of its capital and liquidity
positions, the management of NatWest Group’s principal
risks, including mitigating actions, the 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.
69
NatWest Group
| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
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 2022, 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, our
ambition is to further align our strategy with the 2015 Paris
Agreement and the UN Sustainable Development Goals (SDGs).
Further information on non-financial and ESG matters can
be found within our reporting suite.
Climate-related Disclosures Report
ESG Disclosures Report
ESG Frameworks Appendix
natwestgroup.com
Assurance Approach
NatWest Group plc appointed Ernst & Young LLP (EY) to
provide independent assurance over certain sustainability
metrics and elements of the UN Principles for Responsible
Banking (UN PRB) Template. These sustainability metrics are
marked with an asterisk (*) within this report and the UN PRB
Template is presented within the ESG Frameworks Appendix.
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.
UN Principles for Responsible Banking
We became signatories to the UN Principles for Responsible
Banking (PRB) in September 2019 and our ambition is to further
align our strategy with the Paris Climate Agreement and the
UN Sustainable Development Goals (SDGs). In 2022, we were
invited to join the PRB Framework Review Taskforce, which
led to an updated self-assessment report template which was
launched in September 2022. We have adopted this new
template, and in line with requirements for our third self-
assessment, elements of our PRB reporting are subject
to limited assurance.
Further information on the PRB can be found in the ESG
Disclosures Report and our third self-assessment PRB report
can be found in the ESG Frameworks Appendix available
at natwestgroup.com.
NatWest Group
| 2022 Annual Report and Accounts
70
Reporting
requirement
Page references
in this report
Relevant policy or
document available
at natwest.com
Business model
Investment case
Our purpose framework
Our business model
Our strategy
Our purpose-led areas of focus
Business performance
Climate-related disclosures
10
12 to 13
18 to 21
22 to 23
26 to 28
29 to 35
53 to 63
2022 Climate-related
Disclosures Report
Our
stakeholders
Our stakeholders
Section 172(1) statement
Stakeholder focus areas
36 to 39
40 to 41
42 to 52
Environment
Market environment
Climate-related disclosures
Risk management
Risk factors
16 to 17
53 to 63
64 to 67
404 to 425
Environmental, social
and ethical policies
Our colleagues
Colleagues
Diversity and Inclusion
46 to 47
48 to 49
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
92 to 93
40 to 41
93
84 to 133
138 to 151
171 to 174
Boardroom Inclusion Policy
Social matters
Market environment
Our strategy
Stakeholder focus areas
Our business model
16 to 17
22 to 23
42 to 52
18 to 21
Supplier Charter
Respect for
human rights
Respecting human rights
52
Human Rights Position
Statement
Anti-bribery
and corruption
(ABC)
Risk management
Risk and capital management
Training
64 to 67
176 to 283
64, 178
Statement on Anti-Bribery
and Corruption
Risk
management
Risk management
Risk and capital management
Risk factors
64 to 67
176 to 283
404 to 425
Environmental, social
and ethical policies
71
NatWest Group
| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Financial review
We are pleased to report an attributable
profit in 2022 of £3,340 million, with earnings
per share of 33.8 pence and a RoTE of 12.3%.
Total income, excluding notable items, was
28.3% higher in the year. Go-forward income,
excluding notable items, was £13.1 billion,
exceeding our income guidance for the year,
and we achieved our cost reduction target
of around 3%. A net impairment charge of
9 basis points was in line with guidance and,
whilst default levels remain low, we continue
to monitor the evolving economic outlook.
This strong operating performance was net
of a £1.0 billion attributable loss from our
continued withdrawal from the Republic
of Ireland.
Total income increased by 26.1% to £13,156 million compared
with 2021. Excluding notable items, income was £2,877 million,
or 28.3%, higher than 2021 driven by volume growth, increased
transactional related fees, higher trading income and favourable
yield curve movements. Bank NIM of 2.85% was 55 basis points
higher than 2021.
Total operating expenses were £71 million lower than 2021.
Other operating expenses, for the Go-forward group, were
£201 million, or 2.9%, lower than 2021, in line with our cost
reduction target of around 3%. The decrease in the year
principally reflects property exits, continued focus on
customer journeys and strategic efficiency initiatives.
Katie Murray
Chief Financial Officer
Chief Financial
Officer’s review
A net impairment charge of £337 million principally reflects the
latest macro-economics, including updated scenarios and their
associated weighting. Underlying book performance remains
strong, with credit conditions remaining benign and levels of
default remaining low. Compared with 2021, our ECL provisions
have reduced by £0.4 billion to £3.4 billion, and our ECL
coverage ratio has decreased from 1.03% to 0.91%.
The tax charge for the year includes a £267 million credit in the
carrying value of the deferred tax asset in respect of tax losses,
reflecting an improvement in the outlook when compared with
the position at the end of 2021. In addition, the charge also
includes a credit of £135 million in respect of an inflationary
uplift in the value of UK Government Index Linked Gilt assets
that is not subject to corporation tax.
Net lending increased by £7.3 billion, or 2.0%, in 2022 primarily
reflecting £14.4 billion of mortgage lending growth in Retail
Banking and £5.7 billion of growth in Commercial & Institutional,
partially offset by a £14.6 billion reduction in Central items &
other, which included a £6.4 billion decrease as we continued
our exit from the Republic of Ireland. Retail Banking gross new
mortgage lending for the year was £41.4 billion compared with
£36.0 billion in 2021. Within Commercial & Institutional, growth
was largely within Corporate & Institutions whilst UK
Government Scheme lending reduced by £3.4 billion.
Customer deposits reduced by £29.5 billion in the year to
£450.3 billion principally reflecting a £14.2 billion reduction in
Commercial & Institutional, due to an overall market liquidity
contraction in the second half of the year and reduction in
Corporate and Institutions, particularly non-operational accounts
in Financial Institutions and professional services with relatively
low margin and funding value, and a £12.2 billion reduction
due to our withdrawal from the Republic of Ireland.
72
Financial summary
76
Summary consolidated balance sheet
77
Segment summary income statements
79
Segment performance
83
Summary financial statements
NatWest Group
| 2022 Annual Report and Accounts
72
Three legally binding agreements for the sale of the UBIDAC business have been announced as part of the phased withdrawal from the Republic of Ireland: the
transfer of performing commercial loans to Allied Irish Banks, p.l.c. (AIB), the sale of 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 Group Holdings p.l.c (PTSB) and an agreement with AIB for the sale of performing
tracker and linked mortgages. 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 2022. The Financial review presents the results of the NatWest 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.
TNAV per share reduced by 8 pence in the year to 264 pence
principally reflecting movements in cash flow hedging reserves
of 34 pence per share, dividend payments and other reserve
movements partially offset by the attributable profit.
Capital and leverage
The CET1 ratio remains robust at 14.2%, or 14.0% excluding
IFRS 9 transitional relief. The 170 basis point reduction
compared with 1 January 2022 primarily reflected distributions
and linked pension accruals of c.310 basis points. Compared
with the 1 January 2022 position, RWAs reduced by £0.2 billion
as lending growth and model changes were offset by a
£5.7 billion reduction in the Republic of Ireland.
Year ended
2022
2021
(1)
Variance
Continuing operations
Total income
£13,156m
£10,429m
26.1%
Total income excluding notable items
(2)
£13,061m
£10,184m
28.3%
Operating expenses
(£7,687m)
(£7,758m)
(0.9%)
Profit before impairment (losses)/releases
£5,469m
£2,671m
104.8%
Operating profit before tax
£5,132m
£3,844m
33.5%
Go-forward group
(3)
Total income excluding notable items
(4)
£13,063m
£10,074m
29.7%
Other operating expenses
(4)
(£6,648m)
(£6,849m)
(2.9%)
Performance key metrics and ratios
Bank net interest margin
(4,5)
2.85%
2.30%
55bps
Bank average interest earning assets
(4,5)
£345bn
£327bn
5.5%
Cost:income ratio (excl. litigation and conduct)
(4)
55.5%
69.9%
(14.4%)
Loan impairment rate
(4)
9bps
(32bps)
41bps
Profit attributable to ordinary shareholders
£3,340m
£2,950m
13.2%
Total earnings per share attributable to ordinary shareholders – basic
(6)
33.8p
27.3p
6.5p
Return on tangible equity
(4)
12.3%
9.4%
2.9%
Lending and deposits
Loans to customers – amortised cost
£366.3bn
£359.0bn
2.0%
Customer deposits
£450.3bn
£479.8bn
(6.1%)
Capital, funding and liquidity
Common Equity Tier 1 (CET1) ratio
(7)
14.2%
18.2%
(400bps)
Risk-weighted assets (RWAs)
(7)
£176.1bn
£157.0bn
£19.1bn
Liquidity coverage ratio (LCR)
145%
172%
(27%)
Total wholesale funding
£74.4bn
£76.7bn
(£2.3bn)
Tangible net asset value (TNAV) per ordinary share
(8)
264p
272p
(8p)
(1) Comparative results have been re-presented from those previously published to reclassify certain operations as discontinued operations.
(2) Refer to the following page for details of notable items within total income.
(3) Go-forward group excludes Ulster Bank RoI and discontinued operations.
(4)
Refer to the Non-IFRS financial measures section for details of the basis of preparation and reconciliation of non-financial measures and performance metrics.
(5) NatWest Group excluding liquid asset buffer.
(6)
At the General Meeting and Class Meeting on 25 August 2022, the shareholders approved the proposed special dividend and share consolidation. On 30 August 2022 the issued
ordinary share capital was consolidated in the ratio of 14 existing shares for 13 new shares. The average number of shares for earnings per share has been adjusted retrospectively.
(7)
Refer to the Capital, liquidity and funding risk section for details of basis of preparation. On 1 January 2022 the proforma CET1 ratio was 15.9% and RWAs were £176.3 billion
following regulatory changes.
(8)
The number of ordinary shares in issue excludes own shares held. Comparatives for the number of shares in issue and TNAV per ordinary share have not been adjusted for the
effect of the share consolidation referred to in footnote 6 above.
We reached agreement with our pension trustees to restructure
the previous agreement to make dividend linked contributions
and we will no longer pay £471 million in 2023. We have agreed
to create a trust structure to hold those assets and that gives
the pension fund rights to assets in the value of £471 million
in the event a future funding requirement arises based on
pre-agreed triggers. These assets will remain on the Group
balance sheet in the meantime. We continue to hold the
same deduction against capital.
Funding and liquidity
LCR reduced to 145% during the year driven by a decrease
in the liquidity portfolio, primarily reflecting lending growth and
reduced customer deposits along with shareholder distributions,
and a relatively lower reduction in net outflows.
73
NatWest Group
| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Financial review
continued
NatWest Group
Annual Report and Accounts 2022
74
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Financial summary
2022
2021
(1)
Variance
Income -
Continuing operations
£m
£m
£m
%
Interest receivable
(2)
12,637
9,234
3,403
36.9
Interest payable
(2)
(2,795)
(1,699)
(1,096)
64.5
Net interest income
9,842
7,535
2,307
30.6
Net fees and commissions
2,292
2,120
172
8.1
Income from trading activities
1,133
323
810
250.8
Other operating income
(111)
451
(562)
(124.6)
Non-interest income
3,314
2,894
420
14.5
Total income
13,156
10,429
2,727
26.1
Total income excluding notable items
13,061
10,184
2,877
28.3
Notable items within total income
(3)
Private Banking
Consideration on the sale of the Adam & Company Investment
Management Ltd
54
Commercial & Institutional
Fair value and disposal losses and asset disposals/strategic risk reduction
(45)
(86)
Tax variable lease repricing
32
Own credit adjustments (OCA)
42
6
Central items & other
Loss on redemption of own debt
(161)
(138)
Effective interest rate adjustment as a result of redemption of own debt
(41)
Profit from insurance liabilities
92
Ulster Bank RoI gain arising from the restructuring of structural hedges
35
Ulster Bank RoI fair value mortgage adjustments
(51)
Liquidity asset bond sale (losses)/gains
(88)
120
Share of associate (losses)/profits for Business Growth Fund
(22)
219
Property strategy update
(44)
Interest and FX risk management derivatives
not in accounting hedge relationships
(4)
369
47
Total
95
245
(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)
Included in income from trading activities.
2022 compared with 2021
Total income increased by 26.1% to £13,156 million
compared with 2021. Excluding notable items, income was
£2,877 million, or 28.3%, higher than 2021 driven by volume
growth, increased transactional related fees, higher trading
income and favourable yield curve movements.
Bank NIM of 2.85% was 55 basis points higher than 2021
principally reflecting the impact of base rate increases.
Structural hedges, which averaged £223 billion notional in
2022, generated £2.1 billion of net interest income for the
year, compared with £1.4 billion of net interest income on a
balance of £190 billion in 2021.
Financial review
continued
NatWest Group
Annual Report and Accounts 2022
75
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Financial summary continued
2022
2021
(1)
Variance
Operating expenses -
Continuing operations
£m
£m
£m
%
Staff expenses
3,671
3,676
(5)
(0.1)
Premises and equipment
1,112
1,133
(21)
(1.9)
Other administrative expenses
1,686
1,560
126
8.1
Depreciation and amortisation
833
923
(90)
(9.8)
Other operating expenses
7,302
7,292
10
0.1
Litigation and conduct costs
385
466
(81)
(17.4)
Operating expenses
7,687
7,758
(71)
(0.9)
(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.
2022 compared with 2021
Operating expenses were £71 million lower than in 2021.
Operating expenses in the Go-forward group, excluding
litigation and conduct costs of £385 million (2021 - £466
million), were £6,648 million (2021 - £6,849 million). The
decrease of £201 million, or 2.9%, was in line with our cost
reduction target of around 3% and principally reflects
property exits, continued focus on customer journeys and
strategic efficiency initiatives. This has been supported by
ongoing strategic investment in key areas, including Data,
Technology and Financial Crime.
Litigation and conduct costs of £385 million represent the
net impact of a number of remediation and litigation
matters concluding, including customer due diligence costs
paid during the year. Refer to Note 26 to the consolidated
financial statements for additional information on other
litigation and conduct matters.
2022
2021
(1)
Variance
Impairments -
Continuing operations
£m
£m
£m
Loans - amortised cost and FVOCI
377,153
369,827
7,326
2.0%
ECL provisions
3,434
3,806
(372)
(9.8%)
ECL provisions coverage ratio
0.91%
1.03%
(0.12%)
(11.7%)
Impairment losses/(releases)
ECL charge/(release)
(2)
337
(1,173)
1,510
(128.7%)
Amounts written off
482
876
(394)
(45.0%)
(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.
(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.
2022 compared with 2021
A net impairment charge of £337 million principally reflects the latest macro-economics, including updated scenarios and their
associated weighting, with more weight being placed on the downside scenario. Underlying book performance remains strong,
with credit conditions remaining benign, with levels of default remaining low. Compared with 2021, our ECL provisions have
reduced by £0.4 billion to £3.4 billion, and our ECL coverage ratio has decreased from 1.03% to 0.91%. The element of our
economic uncertainty post model adjustments (PMA) that relates to COVID-19 risks has been reduced, which, when combined
with revisions to our scenario weightings, has allowed us to reduce the amount we hold as economic uncertainty PMA to £0.4
billion, or 10.3% of total impairment provisions.
2022
2021
(1)
Tax -
Continuing operations
£m
£m
Tax charge
(1,275)
(996)
UK corporation tax rate
19.0%
19.0%
Effective tax rate
24.8%
25.9%
(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.
2022 compared with 2021
A tax charge of £1,275 million for the year ended 31 December 2022 arises rather than the expected charge of £975 million
based on the corporation tax rate of 19%. The higher tax charge reflects the UK banking surcharge, no tax relief for RoI tax
losses, and other non-deductible items. These factors have been partially offset by tax credits in respect of the carrying value
of loss DTAs and the RPI uplift on indexed linked gilts. Further details can be found in Note 7 to the consolidated financial
statements.
Financial review
continued
NatWest Group
Annual Report and Accounts 2022
76
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Summary consolidated balance sheet as at 31 December 2022
2022
2021
Variance
£m
£m
£m
%
Assets
Cash and balances at central banks
144,832
177,757
(32,925)
(19)
Trading assets
45,577
59,158
(13,581)
(23)
Derivatives
99,545
106,139
(6,594)
(6)
Settlement balances
2,572
2,141
431
20
Loans to banks - amortised cost
7,139
7,682
(543)
(7)
Loans to customers - amortised cost
366,340
358,990
7,350
2
Other financial assets
30,895
46,145
(15,250)
(33)
Other assets (including intangible assets)
16,292
14,965
1,327
9
Assets of disposal groups
6,861
9,015
(2,154)
(24)
Total assets
720,053
781,992
(61,939)
(8)
Liabilities
Bank deposits
20,441
26,279
(5,838)
(22)
Customer deposits
450,318
479,810
(29,492)
(6)
Settlement balances
2,012
2,068
(56)
(3)
Trading liabilities
52,808
64,598
(11,790)
(18)
Derivatives
94,047
100,835
(6,788)
(7)
Other financial liabilities
49,107
49,326
(219)
(0)
Subordinated liabilities
6,260
8,429
(2,169)
(26)
Notes in circulation
3,218
3,047
171
6
Other liabilities
5,346
5,797
(451)
(8)
Total liabilities
683,557
740,189
(56,632)
(8)
Total equity
36,496
41,803
(5,307)
(13)
Total liabilities and equity
720,053
781,992
(61,939)
(8)
Tangible net asset value per ordinary share (pence)
(1)
264p
272p
(8)p
(3)
(1)
Tangible net asset value per ordinary share represents tangible equity divided by the number of ordinary shares.
Total assets of £720.1 billion as at 31 December 2022
decreased by £61.9 billion, 8%, compared with 31
December 2021. This was primarily driven by decreases in
cash and balances at central banks, other financial assets,
trading assets and derivative assets partially offset by an
increase in loans to customers.
Cash and balances at central banks decreased by £32.9
billion mainly due to net business segment funding outflows
driven by an overall market liquidity contraction, £28.0
billion, movements in FX swaps £8.0 billion and higher
levels of debt market activity £4.0 billion partly offset by
liquidity management measures, £8.0 billion.
Other financial assets decreased by £15.3 billion mainly as
a result of net Government and Supranational bond trading
of £13.5 billion and lower mark-to-market valuations of
£1.6 billion on account of higher interest rates.
Trading assets and trading liabilities reduced by £13.6
billion and £11.8 billion respectively, reflecting the lower
trading activity in response to the volatility in key currency
rates.
Derivative assets decreased by £6.6 billion, 6%, to £99.5bn
and liabilities decreased by £6.8 billion, 7%, to £94.0 billion.
These movements were driven by a decrease in interest
rate trading books on account of lower mark-to-market
valuations in main currencies partially offset by an increase
in exchange rate assets trading book.
Total loans to customers increased by £7.4 billion to £366.3
billion, primarily reflecting £14.4 billion growth in Retail
Banking mortgage business and a £5.7 billion increase in
Commercial & Institutional partially offset by a £14.6 billion
reduction in Central items & other, which included a £6.4
billion decrease as we continued our exit from the Republic
of Ireland.
Customer deposits decreased by £29.5 billion principally
reflecting a reduction of £14.2 billion in Commercial &
Institutional, due to an overall market liquidity contraction
in the second half of the year and a £12.2 billion reduction
as a result of the withdrawal from the Republic of Ireland.
Bank deposits decreased by £5.8 billion mainly due to lower
repo activity due to market conditions.
Other financial liabilities, which includes customer deposits
at fair value through profit and loss and debt securities in
issue, decreased by £0.2 billion, to £49.1 billion.
Subordinated liabilities have decreased by £2.2 billion, 26%,
to £6.3 billion due to redemptions partially offset by new
issuances.
Other liabilities decreased by £0.5 billion, 8%, to £5.3 billion
mainly due to a decrease in financial guarantees and
accrued lease liabilities.
Owners’ equity decreased by £5.3 billion, 13%, to £36.5
billion, driven by share repurchase, ordinary and paid-in
equity dividends paid, partially offset by the attributable
profit for the year.
Financial review
continued
NatWest Group
Annual Report and Accounts 2022
77
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Segmental summary income statements
Two changes to reportable segments have been made;
On 27 January 2022, NatWest Group announced that a new business segment, Commercial & Institutional, would be created,
bringing together the Commercial, NatWest Markets and RBSI businesses to form a single business segment, with common
management and objectives, to best support our customers across the full non-personal customer lifecycle.
Following good progress with respect to the phased withdrawal from the Republic of Ireland, announced in February 2021, Ulster
Bank RoI continuing operations are now included in Central items & other.
Comparatives have been re-presented. The re-presentation of operating segments does not change the consolidated financial
results of NatWest Group.
Continuing operations
Central
Total
Retail
Private
Commercial &
items
NatWest
Banking
Banking
Institutional
& other
Group
2022
£m
£m
£m
£m
£m
Net interest income
5,224
777
4,171
(330)
9,842
Non-interest income
422
279
2,242
371
3,314
Total income
5,646
1,056
6,413
41
13,156
Direct expenses
(700)
(219)
(1,497)
(4,886)
(7,302)
Indirect expenses
(1,784)
(391)
(2,066)
4,241
Other operating expense
(2,484)
(610)
(3,563)
(645)
(7,302)
Litigation and conduct costs
(109)
(12)
(181)
(83)
(385)
Operating expenses
(2,593)
(622)
(3,744)
(728)
(7,687)
Operating profit/(loss) before impairment losses/releases
3,053
434
2,669
(687)
5,469
Impairment (losses)/releases
(229)
2
(122)
12
(337)
Operating profit/(loss)
2,824
436
2,547
(675)
5,132
Total income excluding notable items
5,646
1,056
6,416
(57)
13,061
Return on tangible equity
(1)
na
na
na
na
12.3%
Return on equity
(2)
28.6%
24.5%
12.2%
nm
na
Cost:income ratio (excl. litigation and conduct)
(1)
44.0%
57.8%
55.6%
nm
55.5%
Customer deposits (£bn)
188.4
41.2
203.3
17.4
450.3
Average interest earning assets (£bn)
190.8
19.1
126.1
nm
345.2
Net interest margin
(1)
2.74%
4.07%
3.31%
nm
2.85%
Third party asset rate
(3)
2.64%
3.01%
3.53%
nm
nm
Third party customer funding rate
(3)
(0.20%)
(0.27%)
(0.21%)
nm
nm
For the notes to this table, refer to the following page. nm = not meaningful, na = not applicable.
Financial review
continued
NatWest Group
Annual Report and Accounts 2022
78
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Segmental summary income statements continued
Continuing operations
Central
Total
Retail
Private
Commercial &
items
NatWest
Banking
Banking
Institutional
& other
Group
2021 (4)
£m
£m
£m
£m
£m
Net interest income
4,074
480
2,974
7
7,535
Non-interest income
371
336
1,864
323
2,894
Total income
4,445
816
4,838
330
10,429
Direct expenses
(805)
(200)
(1,773)
(4,514)
(7,292)
Indirect expenses
(1,632)
(323)
(1,873)
3,828
Other operating expense
(2,437)
(523)
(3,646)
(686)
(7,292)
Litigation and conduct costs
(76)
3
(111)
(282)
(466)
Operating expenses
(2,513)
(520)
(3,757)
(968)
(7,758)
Operating profit/(loss) before impairment releases/losses
1,932
296
1,081
(638)
2,671
Impairment releases/(losses)
36
54
1,160
(77)
1,173
Operating profit/(loss)
1,968
350
2,241
(715)
3,844
Total income excluding notable items
4,445
762
4,886
91
10,184
Return on tangible equity
(1)
na
na
na
na
9.4%
Return on equity
(2)
26.1%
17.0%
10.9%
nm
na
Cost:income ratio (excl. litigation and conduct)
(1)
54.8%
64.1%
75.4%
nm
69.9%
Customer deposits (£bn)
188.9
39.3
217.5
34.1
479.8
Average interest earning assets (£bn)
179.1
18.3
121.0
nm
327.3
Net interest margin
(1)
2.27%
2.63%
2.46%
nm
2.30%
Third party customer asset rate
(3)
2.66%
2.36%
2.71%
nm
nm
Third party customer funding rate
(3)
(0.06%)
(0.02%)
nm
nm
nm = not meaningful, na = not applicable.
(1)
Refer to the Non-IFRS financial measures section for details of the basis of preparation.
(2)
NatWest Group’s CET1 target is approximately 13-14% but for the purposes of computing segmental return on equity (ROE), to better reflect the differential drivers of capital usage,
segmental operating profit or loss adjusted for preference share dividends and tax, is divided by average notional equity allocated at different rates of 13% (Retail Banking), 11%
(Private Banking),
and 14% (Commercial & Institutional), 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, and excludes
liquid asset buffer.
(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.
Financial review
continued
NatWest Group
Annual Report and Accounts 2022
79
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Segment performance
Retail Banking
2022
2021
Variance
Income statement
£m
£m
£m
%
Net interest income
5,224
4,074
1,150
28.2%
Non-interest income
422
371
51
13.7%
Total income
5,646
4,445
1,201
27.0%
Other operating expenses
(2,484)
(2,437)
(47)
1.9%
Litigation and conduct costs
(109)
(76)
(33)
43.4%
Operating expenses
(2,593)
(2,513)
(80)
3.2%
Impairment (losses)/releases
(229)
36
(265)
(736.1)%
Operating profit
2,824
1,968
856
43.5%
Performance ratios
(1)
Return on equity
28.6%
26.1%
2.5%
Net interest margin
2.74%
2.27%
0.47%
Cost:income ratio (excl. litigation and conduct)
44.0%
54.8%
(10.8%)
Loan impairment rate
11bps
(2bps)
13bps
(1)
Refer to the Non-IFRS financial measures section for details of the basis of preparation and reconciliation of non-IFRS financial measures and performance metrics.
2022
2021
Variance
Capital and balance sheet
£bn
£bn
£bn
%
Loans to customers (amortised cost)
- personal advances
7.6
7.1
0.5
7.0%
- mortgages
187.2
172.8
14.4
8.3%
- cards
4.4
3.8
0.6
15.8%
Total loans to customers (amortised cost)
199.2
183.7
15.5
8.4%
Loan impairment provisions
(1.6)
(1.5)
(0.1)
6.7%
Net loans to customers (amortised cost)
197.6
182.2
15.4
8.5%
Total assets
226.4
210.0
16.4
7.8%
Customer deposits
188.4
188.9
(0.5)
(0.3%)
Risk-weighted assets
54.7
36.7
18.0
49.0%
2022 compared with 2021
In 2022, Retail Banking continued to pursue sustainable
growth with an intelligent approach to risk, delivering a
return on equity of 28.6% and an operating profit of £2,824
million.
Retail Banking provided £4.0 billion of climate and
sustainable funding and financing in 2022.
Total income was £1,201 million, or 27.0%, higher than 2021
reflecting strong loan growth and higher transactional-
related fee income, higher deposit income, supported by
interest rate rises, partially offset by lower mortgage
margins.
Net interest margin was 47 basis points higher than 2021
reflecting higher deposit returns, partly offset by mortgage
margin pressure.
Other operating expenses were £47 million, or 1.9%, higher
than 2021 primarily driven by higher fraud losses, increased
investment in financial crime prevention, increased data
related costs and the impact of pay awards to support
colleague cost of living challenges. This was partly offset by
a 4.4% headcount reduction as a result of the continued
digitalisation, automation and improvement of end-to-end
customer journeys.
Impairment losses of £229 million in 2022 primarily reflect
continued low level of stage 3 defaults as well as updated
economic outlook scenarios partly offset by provision
releases in stage 2. Provision coverage of 0.81% remains
strong.
Net loans to customers increased by £15.4 billion, or 8.5%, in
2022 mainly reflecting continued mortgage growth of £14.4
billion, with gross new mortgage lending of £41.4 billion
representing flow share of around 13%. Cards balances
increased by £0.6 billion and personal advances increased
by £0.5 billion in 2022 reflecting continued strong customer
demand.
Customer deposits decreased by £0.5 billion, or 0.3%, in
2022 driven by higher outflows in H2 2022 as customers
started to spend following relaxation of Covid-related
restrictions and competition for deposit balances increased.
Personal savings balances decreased by £0.9 billion partly
offset by personal current accounts balance growth of £0.4
billion in 2022.
RWAs increased by £2.6 billion, or 5.0% versus 1 January
2022 reflecting lending growth and a further increase of 1st
January 2022 mortgage regulatory changes of £1.0 billion,
partly offset by quality improvements. No material impact of
procyclicality evident.
Financial review
continued
NatWest Group
Annual Report and Accounts 2022
80
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Segment performance continued
Private Banking
2022
2021
Variance
Income statement
£m
£m
£m
%
Net interest income
777
480
297
61.9%
Non-interest income
279
336
(57)
(17.0%)
Total income
1,056
816
240
29.4%
Other operating expenses
(610)
(523)
(87)
16.6%
Litigation and conduct costs
(12)
3
(15)
(500.0%)
Operating expenses
(622)
(520)
(102)
19.6%
Impairment releases
2
54
(52)
(96.3%)
Operating profit
436
350
86
24.6%
Performance ratios
(1)
Return on equity
24.5%
17.0%
7.5%
Net interest margin
4.07%
2.63%
1.4%
Cost:income ratio (excl. litigation and conduct)
57.8%
64.1%
(6.3%)
Loan impairment rate
(1bp)
(29bps)
28bps
Net new money (£bn)
2.0
3.0
(1.0)
(1)
Refer to the Non-IFRS financial measures section for details of the basis of preparation and reconciliation of non-IFRS financial measures and performance metrics.
2022
2021
Variance
Capital and balance sheet
£bn
£bn
£bn
%
Loans to customers (amortised cost)
- personal
2.2
2.3
(0.1)
(4.3%)
- mortgages
12.7
11.8
0.9
7.6%
- other
4.4
4.4
Total loans to customers (amortised cost)
19.3
18.5
0.8
4.3%
Loan impairment provisions
(0.1)
(0.1)
Net loans to customers (amortised cost)
19.2
18.4
0.8
4.3%
Total assets
29.9
29.9
Assets under management (AUMs)
(1)
28.3
30.2
(1.9)
(6.3%)
Assets under administration (AUAs)
(1)
5.1
5.4
(0.3)
(5.6%)
Assets under management and administration (AUMA)
(1)
33.4
35.6
(2.2)
(6.2%)
Customer deposits
41.2
39.3
1.9
4.8%
Loan:deposit ratio (excl. repos and reverse repos)
(1)
47%
47%
Risk-weighted assets
11.2
11.3
(0.1)
(0.9%)
(1)
Refer to the Non-IFRS financial measures section for details of basis of preparation and reconciliation of non-IFRS financial measures and performance metrics.
2022 compared with 2021
During 2022, Private Banking provided a strong operating
performance with continued balance growth, delivering a
return on equity of 24.5%, 7.5 percentage points higher than
2021, and operating profit of £436 million.
Private Banking provided £0.2 billion of climate and
sustainable funding and financing in 2022. At the end of
2022, £6.5 billion of AUM are invested in funds that are on
net zero trajectory and are decarbonising at an average
rate of 7% per annum.
Total income of £1,056 million was £240 million, or 29.4%,
higher than 2021 driven by higher deposit and lending
balances and improved deposit returns supported by interest
rate rises. This represents a particularly strong performance
given that Q4 2021 reflected the £54 million consideration
from the sale of Adam & Company Investment Management
Ltd.
Net interest margin was 144 basis points higher than 2021
reflecting higher deposit returns and lending growth.
Mortgage book margin was 163 basis points in the year.
Other operating expenses were £87 million, or 16.6%, higher
than 2021 due to continued investment in people and
technology to enhance AUMA growth propositions and
increased investment in financial crime prevention.
Impairment releases of £2 million in 2022 primarily reflect
continued low level of stage 3 defaults and release of post
model adjustments, partly offset by a revision of the
economic outlook scenario assumptions.
AUM net new money was £2.0 billion during 2022, which
represented 5.6% of opening AUMA balances on an
annualised basis, demonstrating a strong performance given
volatile investment market conditions. Digital net new money
was £0.3 billion, which represented 20.6% of opening Digital
AUMA balances. AUMAs decreased by £2.2 billion, or 6.2%,
in 2022 primarily reflecting adverse investment market
movements of £4.0 billion.
Customer deposits increased by £1.9 billion, or 4.8%, largely
driven by strong savings growth, particularly during H1
2022.
Net loans to customers increased by £0.8 billion, or 4.3%, in
2022 due to above market mortgage growth of 8%, whilst
RWAs decreased by £0.1 billion, or 0.9% driven by capital
optimisation initiatives.
Financial review
continued
NatWest Group
Annual Report and Accounts 2022
81
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Segment performance continued
Commercial & Institutional
2022
2021
Variance
Income statement
£m
£m
£m
%
Net interest income
4,171
2,974
1,197
40.2%
Non-interest income
2,242
1,864
378
20.3%
Total income
6,413
4,838
1,575
32.6%
Other operating expenses
(3,563)
(3,646)
83
(2.3%)
Litigation and conduct costs
(181)
(111)
(70)
63.1%
Operating expenses
(3,744)
(3,757)
13
(0.3%)
Impairment (losses)/releases
(122)
1,160
(1,282)
(110.5%)
Operating profit
2,547
2,241
306
13.7%
Performance ratios
(1)
Return on equity
12.2%
10.9%
1.3%
Net interest margin
3.31%
2.46%
0.9%
Cost:income ratio (excl. litigation and conduct)
55.6%
75.4%
(19.8%)
Loan impairment rate
9bps
(92bps)
101bps
(1)
Refer to the Non-IFRS financial measures section for details of basis of preparation and reconciliation of non-IFRS financial measures and performance metrics.
2022
2021
Variance
Capital and balance sheet
£bn
£bn
£bn
%
Loans to customers (amortised cost)
- Business Banking
6.1
8.0
(1.9)
(23.8%)
- Commercial Mid-market
71.7
72.5
(0.8)
(1.1%)
- Corporate & Institutions
53.7
45.4
8.3
18.3%
Total loans to customers (amortised cost)
131.5
125.9
5.6
4.4%
Loan impairment provisions
(1.6)
(1.7)
0.1
(5.9%)
Net loans to customers (amortised cost)
129.9
124.2
5.7
4.6%
Total assets
404.8
425.9
(21.1)
(5.0%)
Funded assets
306.3
321.3
(15.0)
(4.7%)
Customer deposits
203.3
217.5
(14.2)
(6.5%)
Loan:deposit ratio (excl. repos and reverse repos)
(1)
64%
57%
7.0%
Risk-weighted assets
103.2
98.1
5.1
5.2%
2022 compared with 2021
During 2022, Commercial & Institutional delivered a strong
performance with a return on equity of 12.2% and an
operating profit of £2,547 million.
Commercial & Institutional provided £20.3 billion of climate
and sustainable funding and financing in 2022.
Total income was £1,575 million, or 32.6%, higher than 2021
reflecting higher deposit returns from an improved interest
rate environment, net loan growth, improved card payment
fees and higher markets income. Markets income
(1)
of £698
million, was £231 million, or 49.5%, higher than 2021
reflecting stronger performance across the product suite.
Net interest margin was 85 basis points higher than 2021
reflecting higher deposits returns.
Other operating expenses were £83 million, or 2.3%, lower
than 2021 reflecting cost efficiencies whilst continuing to
invest in the business. A 4.2% headcount increase was a
result of continuing to build capability including the take
payment proposition.
A net impairment charge of £122 million in 2022 was
predominantly driven by the downward revision of economic
outlook assumptions in the scenarios compared to a £1,160
million credit in 2021.
Net loans to customers increased by £5.7 billion, or 4.6%, in
2022 due to increased term loans and funds activity within
Corporate and Institutions, growth in invoice and asset
finance balances within the Commercial Mid-market
business partly offset by UK Government scheme balance
reductions of £3.4 billion across Commercial Mid-market and
Business Banking.
Customer deposits decreased by £14.2 billion, or 6.5% in
2022 due to overall market liquidity contraction in the
second half of the year following heightened levels built up
during Covid in 2020 and 2021 and reductions in Corporate
and Institutions, particularly non-operational accounts in
Financial Institutions and professional services with relatively
low margin and funding value.
RWAs increased by £5.1 billion, or 5.2%, in 2022 primarily
reflecting 1st January 2022 regulatory changes and lending
growth partly offset by a reduction in counterparty credit
risk, operational risk and management actions.
(1)
Markets income excludes asset disposals/strategic risk reduction, own credit risk adjustments and central items.
Financial review
continued
NatWest Group
Annual Report and Accounts 2022
82
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Segment performance continued
Central items & other
Following good progress with respect to the phased withdrawal from the Republic of Ireland, announced in February 2021, Ulster
Bank RoI continuing operations are now included in Central items & other.
2022
2021
Variance
Continuing operations
£m
£m
£m
%
Total income
41
330
(289)
(87.6%)
Operating expenses
(728)
(968)
240
(24.8%)
of which: other operating expenses
(645)
(686)
41
(6.0%)
of which: Ulster Bank RoI
(1)
(678)
(482)
(196)
40.7%
Impairment releases/(losses)
12
(77)
89
(115.6%)
Operating loss
(675)
(715)
40
(5.6%)
of which: Ulster Bank RoI
(723)
(414)
(309)
74.6%
2022
2021
Variance
£bn
£bn
£bn
%
Net loans to customers (amortised cost)
(2)
19.6
34.2
(14.6)
(42.7%)
Customer deposits
17.4
34.1
(16.7)
(49.0%)
RWAs
7.0
10.9
(3.9)
(35.8%)
(1)
Includes withdrawal-related direct program costs of £195 million for the year ended 31 December 2022 (£17 million – 31 December 2021) and £151 million for the quarter ended 31
December 2022 (£21 million – 30 September 2022 and £17 million - 31 December 2021).
(2)
Excludes £0.5 billion of loans to customers held at fair value through profit or loss (£0.6 billion – 30 September 2022 and nil – 31 December 2021).
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.
2022 compared with 2021
Total income for 2022 included £369 million of gains from
risk management derivatives not in hedge accounting
relationships, partially offset by £202 million of losses on
redemption of own debt and £88 million of bond disposal
losses.
2021 included litigation and conduct charges of £282
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.
2022 operating expenses included £678 million in Ulster
Bank RoI, of which £195 million were withdrawal related
costs. In 2021 operating expenses in Ulster Bank RoI
totalled £482 million, of which £17 million were withdrawal
related costs.
Financial review
continued
NatWest Group
Annual Report and Accounts 2022
83
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.
2022
2021 (1)
2020 (1)
Summary consolidated income statement
£m
£m
£m
Net interest income
9,842
7,535
7,389
Non-interest income
3,314
2,894
3,014
Total income
13,156
10,429
10,403
Operating expenses
(7,687)
(7,758)
(7,858)
Profit before impairment losses/releases
5,469
2,671
2,545
Impairment (losses)/releases
(337)
1,173
(3,098)
Operating profit/(loss) before tax
5,132
3,844
(553)
Tax charge
(1,275)
(996)
(74)
Profit/(loss) from continuing operations
3,857
2,848
(627)
(Loss)/profit from discontinued operations, net of tax
(262)
464
193
Profit/(loss) for the year
3,595
3,312
(434)
Attributable to:
Ordinary shareholders
3,340
2,950
(753)
Preference shareholders
19
26
Paid-in equity holders
249
299
355
Non-controlling interests
6
44
(62)
3,595
3,312
(434)
(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.
2022
2021
2020
Summary consolidated balance sheet
£m
£m
£m
Cash and balances at central banks
144,832
177,757
124,489
Trading assets
45,577
59,158
68,990
Derivatives
99,545
106,139
166,523
Settlement balances
2,572
2,141
2,297
Loans to banks and customers - amortised cost
373,479
366,672
367,499
Other financial assets
30,895
46,145
55,148
Other and intangible assets
16,292
14,965
14,545
Assets of disposal groups
6,861
9,015
Total assets
720,053
781,992
799,491
Deposits
470,759
506,089
452,345
Trading liabilities
52,808
64,598
72,256
Settlement balances, derivatives, other financial liabilities and subordinated liabilities
151,426
160,658
222,023
Other liabilities
5,346
5,797
6,388
Owners' equity
36,488
41,796
43,860
Notes in circulation
3,218
3,047
2,655
Non-controlling interests
8
7
(36)
Total liabilities and equity
720,053
781,992
799,491
Governance
In this section
86
Our Board
90
Chairman’s introduction
92
Governance at a glance
106
Report of the Group Nominations and Governance Committee
108
Report of the Group Audit Committee
117
Report of the Group Board Risk Committee
128
Report of the Group Sustainable Banking Committee
134
Report of the Technology and Innovation Committee
138
Directors’ remuneration report
152
Annual remuneration report
168
Compliance report
171
Report of the directors
175
Statement of directors’ responsibilities
NatWest Group
| 2022 Annual Report and Accounts
84
85
NatWest Group
| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Howard Davies
Chairman
Alison Rose DBE
Group Chief Executive Officer
Katie Murray
Group Chief Financial Officer
Date of appointment:
14 July 2015 (Board), 1 September 2015
(Chairman)
Committee memberships
N
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
Member of the UK Advisory Council
of PrimaryBid Limited
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 30-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
co-leads 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
Vice-Chair of Business in the Community
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
Co-Lead of the UK Government’s Rose
Review Board
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 (2011-2015),
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:
Non-executive director of Phoenix Group
Holdings plc
Board Committees
Group Nominations & Governance Committee
S
Group Sustainable Banking Committee
A
Group Audit Committee
T
Technology & Innovation Committee
Ri
Group Board Risk Committee
Re
Group Performance & Remuneration Committee
Underline denotes Committee Chair
N
Corporate governance
Our Board
NatWest Group
| 2022 Annual Report and Accounts
86
Mark Seligman
Senior Independent Director
Frank Dangeard
Independent non-executive director
Roisin Donnelly
Independent non-executive director
Date of appointment:
1 April 2017 (Board), 1 January 2018
(Senior Independent Director)
Committee memberships
A
Re
N
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
Date of appointment:
16 May 2016
Committee memberships
Re
T
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 Gen Digital Inc.
Non-executive director of IHS
Holding Limited
Non-executive director of SPEAR
Investments I B.V.
Chairman of the Advisory Board of
STJ Advisors
Date of appointment:
1 October 2022
Committee memberships
N/A
Contribution to the Board:
Roisin brings extensive customer,
marketing and branding experience to the
Board, gained during her long executive
career at Procter & Gamble. She has a
strong background in digital transformation
and data and significant knowledge and
experience of developing ESG strategies
at board level. Roisin also brings practical
board and committee experience to the
role, having served on a number of listed
company boards.
Relevant experience:
Roisin spent over 30 years leading
marketing and brand building at Procter &
Gamble in different UK and international
roles. Most recently Roisin served as Chief
Marketing Officer for Procter & Gamble
Northern Europe (2014-2016) and prior
to that served as Chief Marketing Officer
for Procter & Gamble UK and Ireland
(2002-2014).
Roisin’s previous non-executive
directorships include HomeServe plc,
Just Eat plc, Holland and Barrett Limited
and Bourne Leisure Limited.
Roisin is an Honorary Fellow of the
Marketing Society.
Current external appointments:
Non-executive director of Premier
Foods plc
Non-executive director of The Sage
Group plc
Member of the Digital Advisory Board,
Coca Cola Europacific Partners plc
Non-executive Advisor, Internet
Advertising Bureau
87
NatWest Group
| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Morten Friis
Independent non-executive director
Yasmin Jetha
Independent non-executive director
Date of appointment:
10 April 2014
Committee memberships
A
Ri
N
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
Date of appointment:
1 April 2020
Committee memberships
S
T
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
Corporate governance
continued
Patrick Flynn
Independent non-executive director
Date of appointment:
1 June 2018
Committee memberships
A
T
Ri
N
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
NatWest Group
| 2022 Annual Report and Accounts
88
Lena Wilson
Independent non-executive director
Jan Cargill
Chief Governance Officer and
Company Secretary
Mike Rogers
Independent non-executive director
Date of appointment:
1 January 2018
Committee memberships
N
Re
S
Ri
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 former Chair of the NatWest Group
Colleague Advisory Panel, Lena provides
valuable insights on customer, people and
enterprise 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 over 10 years
and previously served on the boards of
Scottish Power Renewables Limited and
Intertek Group plc. Lena was Chief
Executive of Scottish Enterprise (2009-
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 (until
31 May 2023)
Senior Independent Director of Argentex
Group plc (until 28 February 2023)
Chair of Chiene + Tait LLP
Visiting Professor, University of
Strathclyde Business School
Member of the European Advisory Board
of Workday Inc.
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.
Date of appointment:
26 January 2016
Committee memberships
Re
S
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
skill set 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
Former directors
Robert Gillespie stood down from the
Board as an independent non-executive
director on 15 December 2022.
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FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Chairman’s introduction
Dear Shareholder,
I am pleased to present the Corporate governance report
for 2022.
My Board colleagues and I welcomed the return of in-person
meetings during the year. We also resumed regional stakeholder
visits, with a trip to Bristol to meet customers, colleagues,
community organisations and suppliers. We heard stakeholders’
perspectives first hand and discussed how we can best support
them in these challenging times.
During a period of significant change in the external environment,
the Board was kept regularly informed by management on the
impacts of geopolitical and economic developments on the bank
and its customers. Reports from our Group CEO and business
CEOs included spotlights on the cost-of-living crisis and the
continuing situation in Ukraine, and we discussed the actions
the bank was taking in response.
Strategy and climate were also high on the Board’s agenda.
Directors were closely involved in our plans to amplify our
purpose-led strategy as described more fully in the Strategic report
on pages 40 to 41. Following strong shareholder support for our
‘Say on Climate’ AGM resolution, the Board continued its close
oversight of progress towards our climate ambitions ahead of
publication of the initial iteration of our Climate transition plan.
On the governance front we conducted an internal Board and
Committee evaluation, and further information on the actions
we agreed can be found on pages 104 to 105.
The following pages describe additional 2022 governance
highlights, including details of Board and Committee membership
changes. Details of the Board’s operation and principal areas of
focus during 2022 are set out on pages 91 and 94 respectively.
I would like to thank my fellow Board members for their
contribution, commitment and dedication throughout the year.
Howard Davies
Chairman of the Board
16 February 2023
Letter from Howard Davies,
Chairman of the Board
Corporate governance
continued
All directors are committed to observing high
standards of corporate governance, integrity and
professionalism. Throughout 2022, NatWest Group
plc applied the Principles and complied with all
of the Provisions of the 2018 UK Corporate
Governance Code (the 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.
Information on how the company has applied the
Principles and complied with the Provisions of the
Code can be found in this report under the Code’s
five main section headings:
1 Board leadership and company purpose
(page 96)
2 Division of responsibilities
(page 100)
3 Composition, succession and evaluation
(page 102)
4 Audit, risk and internal control
(page 105)
5 Remuneration
(page 105)
Our full 2018 UK Corporate Governance Code
compliance statement is available on page 168.
UK Corporate Governance Code
NatWest Group
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90
How the Board operated in 2022
At each scheduled Board meeting the directors received reports
from the Chairman, Board Committee Chairs, Group CEO,
Group CFO, Group Chief Risk Officer (Group CRO) and other
members of the executive management team, as appropriate.
Business reviews from the CEOs of our Retail Banking, Private
Banking and Commercial & Institutional businesses included
updates on progress against strategy and spotlights on current
topics including the cost of living, Ukraine, climate, unsecured
lending growth in retail, and mortgages.
In addition to our business CEOs, a number of 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 supported succession planning. The Board also welcomed
external presenters and advisers to Board meetings, who
provided useful insights and perspectives.
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 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.
An overview of the Board’s principal areas of focus during 2022,
is set out on page 94.
Board and Committee membership and meeting attendance in 2022
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
8/8
3/3
4/4
Alison Rose
(1)
8/8
2/2
Katie Murray
(1)
8/8
Frank Dangeard
8/8
3/3
6/6
3/3
4/4
Roisin Donnelly
(2)
2/2
Patrick Flynn
8/8
3/3
5/5
1/1
8/8
4/4
4/4
Morten Friis
8/8
3/3
5/5
1/1
8/8
4/4
Robert Gillespie
(3)
8/8
3/3
5/5
1/1
8/8
4/4
4/4
3/3
Yasmin Jetha
8/8
3/3
5/5
1/1
4/4
Mike Rogers
8/8
3/3
6/6
3/3
5/5
1/1
Mark Seligman
(4)
8/8
3/3
5/5
1/1
4/4
6/6
2/3
Lena Wilson
(5)
8/8
2/3
8/8
2/2
6/6
3/3
5/5
1/1
(1) Executive directors are not eligible to attend meetings to discuss their own remuneration.
(2) Ms Donnelly joined the Board on 1 October 2022.
(3)
Mr Gillespie stood down as Chair and as a member of RemCo with effect from 24 September 2022. Mr Gillespie stood down as a director on 15 December 2022.
(4) Mr Seligman was unable to attend one ad hoc RemCo meeting due to prior commitments.
(5)
Ms Wilson assumed the Chair of RemCo and became a member of N&G with effect from 24 September 2022. Ms Wilson was unable to attend one ad hoc Board meeting due to
prior commitments.
Board and Committee meetings
There were eight scheduled Board meetings during 2022.
As well as 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 three additional Board meetings held in 2022
compared to eight additional meetings held in 2021.
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.
There were also three strategy sessions with executive
management in 2022.
In accordance with the Code, the Chairman and the non-
executive directors met at least once without executive
directors present.
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ADDITIONAL INFORMATION
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:
The Group CEO has established the Group Executive Committee (ExCo) to support her in discharging her responsibilities in managing
NatWest Group’s business day to day. Further information on our governance structure is available throughout this Corporate
governance report.
Governance at a glance
NatWest Group plc Board
Group Audit
Committee (GAC)
see page 108
Group Board Risk
Committee (BRC)
see page 117
Group
Nominations and
Governance
Committee (N&G)
see page 106
Group
Performance and
Remuneration
Committee
(RemCo)
see page 138
Group
Sustainable
Banking
Committee (SBC)
see page 128
Technology and
Innovation
Committee (TIC)
see page 134
Board oversight of our
progress and performance
as a purpose-led organisation
(page 96)
Conducting an internal
Board and
Committee
evaluation
(page 104)
Creating
more
opportunities
for Board stakeholder
engagement
(page 98)
Implementing a
revised strategy cycle and
operating rhythm
at Board and ExCo level
(page 96)
Supporting directors’
professional development
through regular training sessions
(page 102)
Implementing a
remuneration policy for
executive directors
that provides a more direct link between pay and
the delivery of our purpose-led strategy
(page 148)
Completing a
successful
external
audit tender
process
(page 109)
Reviewing
the Board’s approach to
colleague
engagement
(page 99)
Governance highlights
During 2022 our governance framework supported our strategic delivery in a number of ways, including
Robert Gillespie confirmed his
intention to step down as a
non-executive director on
15 December 2022.
Lena Wilson succeeded Robert
Gillespie as RemCo Chair and
joined N&G.
Roisin Donnelly joined the
Board as an independent
non-executive director.
Robert Gillespie stepped down
as a non-executive director.
Mike Rogers will step down as a
non-executive director.
Morten Frilis will step down as
a non-executive director.
Board changes during 2022
Board changes during 2023
24 September
25 April
31 July
1 October
1 April
15 December
Corporate governance
continued
Stuart Lewis will be appointed as an
independent non-executive director.
NatWest Group
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92
Board composition as at 31 December 2022
Skills and experience
0
1
2
3
4
5
6
7
8
9
10
11
Broad Financial Services
Risk Management
Transformation
Customer Experience
Environmental, Social and Governance (incl climate)
Government / Regulatory / Public Sector
CEO / Senior Executive Management
Financial Markets / Investment Banking
Digital and Innovation
Retail / Commercial / Private Banking
Technology (infrastructure, cyber)
CFO / Accountant
Skills and experience
The Board is structured to ensure that the directors provide an appropriate
combination of skills, experience and knowledge as well as independence.
The bar chart above 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 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.
Gender
%
There are 11 directors on the Board, five female and six male. At the end of
2022, 45% of the Board were female, which exceeded the FTSE Women Leaders
Review target of 40% female Board representation by the end of 2025.
2022
45%
55%
Female
Male
Age range
No. of directors
2022
2
5
4
45-55
56-65
66-75
Executive vs non-executive
directors and independence
No. of directors
The Board considers all eight non-executive directors to be independent
and the Chairman was considered to be independent on appointment.
2022
1
2
8
Chairman
Executive directors
Independent non-executive directors
Ethnicity
No. of directors
Throughout 2022 the Board met the Parker Review’s recommendation with
at least one director from an ethnic minority background.
2022
1
10
Ethnic minority
White
Length of tenure
Chairman and non-executive directors
2022
1
4
4
0-3 years
3-6 years
6-9 years
Number of directors
Our boardroom inclusion policy aims to promote diversity
and inclusion in our Board and Board Committee
composition, and in the nominations and
appointments process.
Further information can be found on page 102, and a
copy of the policy is available at natwestgroup.com.
Boardroom inclusion policy
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Principal areas of Board focus
Purpose and strategy
(including climate)
Strategy sessions with executive management
Board business insights pack
Brand portfolio update
The initial iteration of our Climate transition plan
Progress against purpose
One Bank Transformation spotlights (digitisation and
distribution; technology and data; innovation, partnerships
and ventures; portfolio discipline)
‘Say on Climate’ AGM resolution
Customers
Business reviews
Complaints
Consumer Duty implementation plans
Group CEO reports
One Bank Transformation spotlights (customer lifecycle;
customer journeys)
Retail unsecured growth and strategy update
(1)
Mortgages update
(1)
Colleagues
(2)
Colleague Advisory Panel reports
Colleague survey results
Executive director remuneration policy
Executive talent and succession plans
Culture
2021 Modern Slavery and Human Trafficking Statement
Board business insights pack
Colleague Advisory Panel reports
Colleague survey results
Culture measurement reports
One Bank Transformation spotlights (organisation, skills
and culture)
(1) These updates were provided at meetings of the NWH Sub Group Boards where
the directors of NatWest Group plc were also in attendance as NWH Sub Group
directors or observers. In this report, NWH Sub Group means NatWest Holdings
Limited, National Westminster Bank Plc and The Royal Bank of Scotland plc.
(2) References to ‘colleagues’ in this report mean all members of our workforce
(which includes contractors and agency workers).
Financial
2021 Annual Results
Q1, H1 and Q3 2022 Results
2021 Climate-related Disclosures Report
2021 ESG Supplement
Budget
Capital distributions
External audit tender
Group CFO reports
Internal Capital Adequacy Assessment Process results
Internal Liquidity Adequacy Assessment Process results
Off Market Directed Buyback
One Bank Transformation spotlights
Recovery plans
Resolvability self-assessment
Risk and conduct
2022 cyber stress test results
Climate Biennial Exploratory Scenario Round 2 submission
Cyber risk ‘war game’
Enterprise-wide risk management framework
Financial crime updates
Operational resilience self-assessment
Risk appetite
Risk management reports
Legal, governance and regulatory
Annual Cyclical Scenario stress test results
Annual General Meeting arrangements
Board and Committee appointments
Board evaluation actions
Board succession plans
Boardroom inclusion policy
Directors’ external appointments
Governance framework updates
Group CRO appointment
Health and safety annual review
Legal and regulatory reports
Outsourcing arrangements and third party risk
management
Regulatory correspondence
Shareholding policy – Chairman and non-executive directors
Corporate governance
continued
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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 Ltd) is the holding company for
our ring-fenced operations, which include our Retail and Private
Banking businesses and certain aspects of our Commercial &
Institutional business. A common board structure is operated
such that the directors of NWH Ltd are also directors of The
Royal Bank of Scotland plc (RBS plc) and National Westminster
Bank Plc (NWB Plc). Known collectively as the NWH Sub Group,
the boards of these three entities meet concurrently.
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. Abridged biographies for the DINEDs are
presented below with more detailed biographies available at
natwestgroup.com (NatWest Holdings Limited section).
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. They attend NatWest Group plc Board and
relevant Board Committee meetings as observers.
Our 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. When
our Commercial & Institutional business was stood up during
2022, the DINEDs considered and provided input on the
changes proposed specifically from a ring-fenced bank
perspective, ahead of NatWest Group plc and NWH Ltd
Board discussions.
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.
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 106.
Graham Beale
NWH Sub Group – Senior Independent
Director and double independent
non-executive director
Ian Cormack
NWH Sub Group – Double independent
non-executive director
Date of appointment:
1 May 2018
As a chartered accountant, Graham
brings extensive financial knowledge to the
Board alongside his executive management
experience, predominantly in retail banking.
This enables Graham to provide
comprehensive input to Board discussions.
Graham served as Chief Executive Officer
of Nationwide Building Society, the UK’s
largest mutual institution and the world’s
largest building society from 2007 to 2016.
In a non-executive capacity, Graham has
been a member of the boards of VISA
Europe Limited and the British Bankers’
Association. He was also Chair and
member of the Financial Conduct Authority
Practitioners Panel and Chair and a
member of the board of the Building
Societies Association.
Date of appointment:
1 May 2018
Ian’s extensive financial services career
provides him with significant experience in
commercial and investment banking, with
particular focus on customer and risk
management. This knowledge combined
with Ian’s understanding of financial
infrastructures, strategy and
transformation provides invaluable
input into Board discussions.
Ian spent 30 years with Citibank/Citigroup
where he held a number of senior positions,
including UK Country Head (CCO), Head of
European Training and Co-Head of the
Global Financial Institutions Business.
Ian is the Senior Independent Director
of Just Group plc and has previously held
non-executive positions with Phoenix Group
Holdings plc, Hastings Group Holdings plc,
Bloomsbury Publishing plc and Broadstone
Acquisition Corporation Inc.
Francesca Barnes
NWH Sub Group – Double independent
non-executive director
Date of appointment:
1 May 2018
Francesca brings a wealth of banking and
private equity experience to the Board
gained through an extensive executive
career. Francesca’s experience provides
considerable knowledge in important areas
such as customer experience, risk and
stakeholder management.
Francesca started at Chase Manhattan
Bank and went on to hold a number of
senior roles within UBS Investment Bank
including Global Head of Private Equity;
Head of Strategy and Development;
Global Loan Portfolio Manager and Chair
of the UBSIB Development Board.
Francesca is currently the Senior
Independent Director of HarbourVest
Global Private Equity Limited and previously
served on the Board of Coutts & Co
(2012-2021), a NatWest Group subsidiary.
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ADDITIONAL INFORMATION
Corporate governance
continued
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 Provisions 17 and 33, as described on page 90
and explained more fully in our statement of compliance on
page 168.
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 Board 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 here under the Code’s five main section headings.
1. 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.
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 2022.
Board Committees
The Board has established a number of Board Committees with
particular responsibilities. Further details on Board Committee
activities during the year can be found in the Board Committee
reports. Board Committee terms of reference are available
at natwestgroup.com.
Purpose
In February 2020 following an extensive period of stakeholder
engagement, the Board approved NatWest Group’s purpose.
Our focus on purpose has strengthened the Board’s
consideration of the interests of all of our stakeholders and
papers presented to the Board set out how they support our
purpose. Examples of how purpose has guided Board decisions
and discussions can be found in our section 172 statement on
pages 40 to 41.
In April 2022 the Board received an assessment of progress on
embedding purpose and updates on each of the focus areas of
enterprise, climate and financial capability/learning. Directors
considered the outputs of a colleague opinion survey which
had demonstrated good progress on embedding our purpose
and values.
The Board received a further purpose update in December
2022. This included an overview of our evolution to becoming
a purpose-led bank, an assessment of progress on embedding
our purpose, achievements to date, external perceptions of our
progress and future priorities. The directors received a further
update on the three focus areas and considered a broader
stakeholder overview aligned to the Blueprint for Better
Business framework.
Strategy
In response to an action arising from the 2021 Board evaluation,
a new operating rhythm was introduced for Board engagement
and oversight of strategy during 2022. This included more
frequent strategy sessions with executive management
and interactive sessions informed by stakeholder views,
as described below.
Board oversight and engagement on strategy in 2022
March
Listening
and
reflecting
The Board considered insights into evolving
customer needs and future trends from a
comprehensive programme of stakeholder
listening. Directors joined breakout groups to
discuss key themes, collaborating with the
executive management team and Junior
Management Team members.
June
Strategic
vision
Building on the insights gained in March
the Board agreed key areas of focus and
a vision for our purpose-led strategy,
including exploring the opportunities for
sustainable growth.
October
A strategic
plan
The Board reviewed and confirmed its
support for a strategic plan consistent with
the ambition discussed in June, including the
identification of three growth areas where
we can amplify our strategy.
Directors commented positively on the new operating rhythm
during the 2022 Board evaluation. Throughout the process
there was strong engagement and constructive debate
amongst directors and management.
Further information on NatWest Group’s strategy can be
found on pages 22 to 23 of the Strategic report.
Values
In December 2021 the Board approved NatWest Group’s
refreshed values (Inclusive, Curious, Robust, Sustainable and
Ambitious), ahead of their launch in February 2022. The Board
received regular updates on how our values are embedding
within the organisation through One Bank Transformation
spotlights, Our View colleague survey results and culture
measurement reports.
Further information on NatWest Group’s values can be
found in the Strategic report on page 47.
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Culture
The Board assesses and monitors NatWest Group’s culture in several ways, as described 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?
Key areas of focus and outcomes
Colleague Advisory
Panel reports
Feedback on discussions from Colleague Advisory Panel (CAP) meetings held in May and
November. Topics included remuneration (executive pay and the wider workforce), our values,
customers in vulnerable situations and future skills.
One Bank Transformation
spotlights on organisation,
skills and culture
Progress updates (in April and October) on the transition towards a simpler overall organisational
design; creating and embedding a One Bank culture, values and people proposition; and
strategic workforce planning.
Our View colleague
survey results
Insights from the colleague opinion surveys conducted in April and September. Key measures
included culture, purpose, building capability, inclusion, engagement and leadership. In July
the Board received an update on actions agreed by ExCo following the April Our View survey
around ways of working, senior female retention, verbatim comments analysis and NatWest
Group’s wellbeing approach post COVID-19.
Culture measurement
reports
The NatWest Group culture measurement framework enables the Board and senior leaders
to assess the progress NatWest Group is making in reshaping its culture. It uses an integrated
suite of qualitative, quantitative, internal and external data sources to support NatWest Group
in assessing the effectiveness and impact of its culture journey (120 measures in total). These
include customer insights and data (e.g. Net Promoter Scores (NPS) and Competition & Markets
Authority (CMA) survey results), colleague engagement insights (e.g. CAP feedback), Our View
colleague survey insights, risk culture data, audit and behavioural risk data, supplier and
environmental measures, and a range of externally benchmarked ESG data.
Board culture measurement reports were considered in July and December. These used the
Blueprint for Better Business framework to report progress, highlighting both positive trends and
areas for improvement. In July the Board discussed the report in detail with management and
sought further information across several themes including colleague sentiment amid cost-of-
living impacts and financial wellbeing. The December report noted that although there had been
some downward pressure on a number of metrics since the July report – particularly colleague
sentiment and customer measures where the cost-of-living crisis and general economic
conditions were undoubtedly having an impact – the overall picture was relatively stable.
Board business insights packs
Metrics to demonstrate how NatWest Group is delivering for colleagues (including building
capability, diversity and inclusion, and learning).
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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Stakeholder engagement
In February 2022, the Board approved its annual objectives
and confirmed the Board’s key stakeholder groups – customers,
investors, regulators, colleagues, communities 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.
The Chairman also provided regular updates to the Board on
meetings with regulators, key stakeholders and other relevant
bodies including clients, financial institutions, advisers, and
government and media representatives.
The stakeholder engagement section of the Strategic report
on pages 36 to 39 includes some high level examples of how
the Board engaged directly with stakeholders, and our section
172 statement on pages 40 to 41 describes how stakeholder
interests have been considered in Board discussions and
decision-making, including principal decisions.
In addition to the examples highlighted in the Strategic report,
the Board engaged with the views and interests of stakeholders
in a variety of other ways:
Customers
: the Group CEO and business CEOs regularly
updated the Board on customer engagement activity and
sentiment, including CMA and NPS results. An update
on customer complaint volumes and key themes arising
provided a useful indicator of external sentiment, highlighting
key trends in customer complaints and areas of focus for
improvement activity.
Investors
: in addition to engaging directly with institutional
investors through quarterly results presentations and
1:1 meetings, the Board also considered investor feedback
reports and updates from the Group CFO on external
market perspectives, including share price performance and
trading activity, which allowed the Board to monitor investor
activity. Directors engaged with private shareholders and
responded to questions they raised through our virtual
shareholder events and at our Annual General Meeting. The
Board also held roundtable discussions with three institutional
investors, enabling a valuable two-way dialogue on a range
of topics including the investors’ views of NatWest Group and
wider global and economic trends. The Chair of the Group
Performance and Remuneration Committee met with
institutional shareholders, UK Government Investments,
proxy advisers and the UK regulators to discuss
remuneration matters, including wider workforce pay
proposals and executive directors’ remuneration policy and
updated the Board on those discussions. Further details of
remuneration engagement can be found in the Directors’
remuneration report on pages 138 to 167.
Regulators
: in addition to having PRA and FCA
representatives join Board meetings to present the findings
of their Periodic Summary Meeting and Firm Evaluation
Letter respectively, the Board also reviewed regulatory
correspondence and proposed responses. This enabled
directors to understand the key matters raised and how
management were addressing them. Reports from the
Group CEO, Group CFO and business CEOs kept the Board
informed on key topics being discussed by management
with regulators, enhancing the Board’s understanding of
regulatory priorities.
Colleagues
: the Board continued to engage with colleagues
through our multi-channel colleague listening approach,
further details of which are set out on page 99 under
‘Workforce engagement’.
Communities
: During our regional Board visit to Bristol,
the Board met with community groups involved with young
people, climate change and supporting ethnic minority
businesses, and gained useful insights into the bank’s work
with those groups. Directors also continued to develop their
climate knowledge and expertise, through our annual climate
training session and detailed consideration of our Climate
transition plan.
Suppliers
: the Board received regular management
updates on key supplier and partnership relationships and
initiatives being undertaken with them. Directors also met
with suppliers during their visit to Bristol and participated
in a dedicated training session on how we are embedding
diversity in our supply chain.
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Our multi-channel colleague listening approach
Colleague surveys and
behavioural audits
The Board and Group Sustainable
Banking Committee receive the results
of the Our View colleague surveys which
provide insight at all levels and aspects of
colleague experience.
Another valuable Board-level source is
Behavioural Audit reports from Internal
Audit covering sub-culture findings.
Colleague Advisory Panel
Provides a means by which ‘colleague
voice’ can be strengthened and promoted
within the Boardroom.
Board members engage directly with
colleagues on strategic topics. A key
outputs report supports discussion at
the next scheduled Board meeting.
Board and Committee
paper templates
Colleagues is one of a number of
stakeholder groups included within
our governance paper templates.
Our reporting guidance encourages
paper authors and sponsors to consider
colleague views or impact when
presenting reports to our Board
and its Committees.
Board talent sessions and other
direct engagement
Directors meet with potential executive-
level successors and explore strategic
issues with them.
At ‘Meet the Board’ events colleagues
meet the Chairman, Group CEO and
non-executive directors to discuss
topical issues.
Other examples of direct engagement
include Board Committee visits to Risk
and Audit teams, the Chairman meeting
with each new graduate intake and
internal guest presenters at Board
and Committee meetings.
Management reporting and activities
Board-level reporting from the Group CEO and the
executive management team includes insights on
colleague engagement, wellbeing and development.
Board & Colleague
Engagement activities
A number of listening and reporting tools help in promoting colleague voice in the boardroom.
This multi-channel approach aims to provide representation from across the bank and guards
against the risks of relying on a single source to gather views.
Workforce engagement
During 2022, and in response to one of the actions arising from the 2021 Board evaluation exercise, we reviewed our colleague
listening and talent engagement strategy at ExCo and Board levels, including the role of the Colleague Advisory Panel, to ensure
it remained fit for purpose.
The Board agreed to continue its multi-channel approach to colleague engagement at Board level, as described below:
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Corporate governance
continued
2. 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 86 to 89.
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.
Robert Gillespie stepped down from the Board on 15 December
2022, having served a full term of nine years. In order that
Robert’s resignation could coincide with the December Board
meeting, he was on the Board for a total of nine years and
14 days. In that respect alone, Mr Gillespie did not meet the
independence criteria set out in the Code. Notwithstanding
Mr Gillespie’s length of service, the Board has determined
that Mr Gillespie continued to be independent in character and
judgement, offering a strong contribution to Board discussions
and debate until he stepped down on 15 December 2022.
On a similar basis, in February 2023, the Board confirmed
that Morten Friis should continue to serve on the Board and be
considered as an independent non-executive director until he
steps down on 31 July 2023, notwithstanding that he will have
served nine years and four months on the Board by that point.
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 2022, 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.
Our Colleague Advisory Panel
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
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 are self-nominated
or part of an employee representative body. In September
2022 Mike Rogers succeeded Lena Wilson as CAP Chair, and
the panel’s membership was refreshed. New members received
training on the role of the CAP and their responsibilities as
members. Although members were randomly selected, we
cross-checked to ensure the panel was in the main reflective
of the bank’s population covering a variety of business areas,
organisational levels and locations, working patterns and
employee-led networks.
The CAP met with representatives from the Board twice in
2022 to discuss issues including remuneration (executive pay
and the wider workforce), our values, customers in vulnerable
situations and future skills. 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. The Board discusses colleague
feedback received from the CAP and the CAP Chair provides
feedback on this discussion to the Panel to ensure a continuous
feedback loop.
Further details on NatWest Group’s approach to investing in
and rewarding its workforce can be found on pages 46 to 47
of the Strategic report.
The effectiveness of Board stakeholder engagement
mechanisms continues to be considered during the annual
Board evaluation.
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.
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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. In 2022 the Chairman and
non-executive directors’ role profiles were refreshed and
updated to ensure they continue to accurately reflect their
role and responsibilities and are in line with best practice.
The performance of the Chairman and non-executive
directors is evaluated annually and further details of the
process undertaken can be found on page 105.
Chief Governance Officer and Company Secretary
The Chief Governance Officer and Company Secretary 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 executive management team supports the Group CEO
in managing NatWest Group’s businesses. The team reviews,
challenges and debates relevant items and supports the Group
CEO in forming recommendations to the Board. Matters include
strategy, financials, capital, risk and operational issues affecting
NatWest Group as well as monitoring the implementation of
cultural change and executive succession planning. The executive
management team actively promotes NatWest Group’s culture,
values and purpose. Biographies of the executive management
team can be found at natwestgroup.com.
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.
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. After appointment,
external appointments require prior Board approval, with the
reasons for permitting significant appointments explained in the
Annual Report and Accounts. Board papers relating to proposed
additional external appointments of directors include details
of the individual’s full portfolio for review and consideration.
They also include a reminder of applicable Code and Capital
Requirements Directive provisions, and relevant proxy adviser
and investor guidance.
In April 2022 Katie Murray joined the Board of Phoenix
Group Holdings plc (Phoenix) as a non-executive director.
This appointment, and Katie’s subsequent appointment as
Chair of the Phoenix Group Audit Committee, were both
approved by the Board in advance. In reaching its decisions
the Board considered both potential conflicts and time
commitment and was satisfied that Ms Murray would be
able to continue to meet her commitments to NatWest Group.
At the April 2022 AGM, the resolution to re-elect Frank
Dangeard as a director was passed with a lower level
of support than expected, particularly from independent
shareholders. A proxy adviser had recommended a vote against
Mr Dangeard’s re-election due to ‘over-boarding’ under their
methodology, although no regulatory limits had been breached.
Acknowledging the significant vote against Mr Dangeard’s
re-election, we explained the situation in our post AGM
announcement and re-confirmed the Board’s view that Mr
Dangeard has sufficient time to undertake his duties with
NatWest Group. The Chairman also engaged directly with
institutional shareholders, listening and responding to their
concerns. Mr Dangeard has since stepped down as Chair of
Spear Investments I B.V., where he remains a non-executive
director, which will represent a reduction in the number of public
company mandates he holds under any voting guidelines where
Chair roles are counted as additional commitments.
In November 2022, the Board approved Roisin Donnelly’s
appointment as a non-executive director of The Sage Group
plc, effective February 2023. The Board considered potential
conflicts and the time commitment associated with the
additional directorship and, noting that Ms Donnelly expected
shortly to resign from the board of HomeServe plc, it was
satisfied that Ms Donnelly would continue to have sufficient time
to continue to meet her responsibilities to NatWest Group. Ms
Donnelly stepped down from HomeServe plc in January 2023.
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 of how
the directors have complied with their section 172(1) duties can
be found on pages 40 to 41 of the Strategic report.
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In addition, directors broadened their knowledge and
understanding of the risks facing NatWest Group by
participating in a Board dinner discussion with executive
management on principal and emerging risks. A number
of directors also accepted an invitation to the full Board to
join meetings of the Technology and Innovation Committee
which covered areas of broader interest, including a session
on data strategy.
3. 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.
In December 2022 the Group Nominations and Governance
Committee reviewed, and the Board approved, an updated
version of our Board skills matrix, a summary view of which
is set out on page 93.
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.
Board Committees also comprise directors with a variety of
skills and experience so that no undue reliance is placed on
any one individual.
The boardroom inclusion policy aims to promote diversity
and inclusion in the composition of the Boards of directors
of NatWest Group plc, NWH Ltd, NWB Plc and RBS plc and in
the nominations and appointments process. This policy reflects
NatWest Group’s values, its inclusion guidelines and relevant
legal or voluntary code requirements.
The policy includes measurable objectives which exist to ensure
that the Boards, and any Committees they delegate nominations
responsibilities to, follow an inclusive process when making
decisions on nominations and appointments. The policy includes
targets which aspire to meet those set out in the UK Listing
Rules along with the recommendations of the FTSE Women
Leaders Review and the Parker Review. The policy also
acknowledges NatWest Group’s ambition to have gender
balance in our global top three levels (CEO-3 and above)
by 2030.
Throughout 2022 the Board met the recommendation of
the Parker Review with at least one director from an ethnic
minority background and it intends to continue to meet
that recommendation.
As at 31 December 2022:
45% of the Board were female, which exceeded the FTSE
Women Leaders Review target of 40% female representation
by the end of 2025; and
with a female Group CEO and Group CFO, we also met
the FTSE Women Leaders Review recommendation that
companies should have at least one woman in the Chair or
Senior Independent Director roles on the Board and/or one
woman in the Chief Executive Officer or Finance Director
role by the end of 2025.
A copy of the boardroom inclusion policy is available
at natwestgroup.com.
Our directors are mindful that it is not always possible to
achieve an outcome which meets the expectations of all
stakeholders who may be impacted. For decisions which are
particularly challenging or complex, an optional page in our
paper template provides directors with further information to
support purposeful decision-making. This additional page uses
the Blueprint for Better Business framework 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 co-ordinated 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.
Roisin Donnelly joined the Board on 1 October 2022 and the
Chief Governance Officer and Company Secretary worked
closely with Ms Donnelly to devise a comprehensive induction
programme which was tailored to her needs and flexible to
respond to areas of focus which emerged as the programme
progressed. Priorities included early engagement with key
stakeholders, upskilling on the financial services industry
and regulation, and developing an understanding of NatWest
Group’s structure, strategic priorities and business operations.
All new non-executive directors receive a copy of the NatWest
Group non-executive 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
contains links to a wider library of reference materials via our
online resources portal.
Directors’ training and development is co-ordinated by the
Chief Governance Officer and Company Secretary.
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.
During 2022 our Board training covered supply chain diversity,
digital currencies, regulatory updates, the Takeover Code,
capital, financial crime, inside information, climate, ring-fencing
rules and a cyber risk ‘war game’.
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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 June 2022 the Board received an update on executive talent
and succession planning which enabled directors to monitor
the internal talent pipeline and provide feedback. This update
included analysis of the diversity of the talent pool, with a view
towards continuing to improve diversity over the longer term.
In October 2022 the Board held a talent engagement session
with potential ExCo successors. This session helped our
non-executive directors gain insights into the breadth of the
talent pool, getting to know the individuals through a focused
discussion on our values and how they are embedding across
the bank.
Board succession planning has also been an important area of
focus in 2022.
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 June 2022 (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.
On 24 September 2022, the Board approved Lena Wilson’s
appointment as Chair of the Group Performance and
Remuneration Committee, succeeding Robert Gillespie
who had confirmed his intention to resign as a director
on 15 December 2022.
On 1 October 2022, Roisin Donnelly was appointed to the Board
as an independent non-executive director. And on 16 December
2022, we announced that Stuart Lewis will join the Board as an
independent non-executive director on 1 April 2023. Subject to
regulatory approval, Mr Lewis will succeed Morten Friis as Chair
of the Group Board Risk Committee on 1 August 2023.
On 16 December 2022 we announced that Mr Friis had
confirmed his intention to resign as a non-executive director
on 31 July 2023, and on 31 January 2023 we announced that
Mike Rogers would be stepping down from the Board on
25 April 2023.
Further information on the role of the Group Nominations and
Governance Committee and its activities during 2022 can be
found in the Committee Chair’s report on pages 106 to 107.
Election and re-election of directors
In accordance with the provisions of the Code, all directors
will stand for election or re-election by shareholders at the
company’s AGM, with the exception of Mr Rogers, who
has confirmed his intention to resign on 25 April 2023.
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 internal evaluation was conducted in 2022 by the Chief
Governance Officer and Company Secretary, following the
externally facilitated evaluation led by Independent Board
Evaluation in 2021. Further details on how the 2022 evaluation
was conducted and the outcomes and actions arising from
that process are set out in this section.
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Corporate governance
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Progress following the 2021 external Board evaluation
A number of actions were progressed during 2022 in response to the findings of the 2021 external Board evaluation.
Theme
2022 progress
Strategy
A new operating rhythm was introduced for Board engagement and oversight
with more frequent strategy sessions during the year focused on key strategic
topics for the Board as more fully described on page 96.
Board focus and priorities
Board objectives for 2022 were approved by the Board in February 2022.
Processes were streamlined to facilitate effective management of Board
priorities in a number of ways including refreshing the business CEO review
template, integrating climate updates within existing Board papers, issuing
certain Committee invitations to all Board members and ensuring an
appropriate balance between agenda items for discussion and noting.
Engagement with the business and
stakeholders
Further opportunities for non-executive directors to engage with the business
and key stakeholders were identified including Meet the Board sessions,
a colleague networking lunch, a full Board session with executive talent,
the Colleague Advisory Panel, virtual shareholder events, the AGM, an
investor engagement session, engagement with external suppliers,
customer visits and customer dinners.
Colleague engagement
The Board’s overall approach to colleague engagement was reviewed,
including the role of the Colleague Advisory Panel, broader employee listening
and the talent engagement strategy at ExCo. It was concluded that the
approach was fit for purpose.
Details of progress made against the actions arising from the 2021 external Committee evaluations can be found in the relevant
Committee Reports.
How the 2022 evaluation was conducted
Objectives and
scope
The Chairman and Chief Governance Officer and Company Secretary agreed on the scope and
objectives of the Board and Committee evaluation.
The NatWest Group plc and NWH Sub Group Boards and Committees were confirmed to be in scope of
the review. Focus areas included purpose and strategy (oversight and implementation), objectives and
priorities, Board composition and succession planning (including skills, diversity and experience), Board
culture, risk management, stakeholder engagement, and quality of meetings and papers.
Interviews and
reporting
The Chief Governance Officer and Company Secretary held 1:1 interviews with all of the directors and
prepared a draft report summarising the output from the interviews.
The key findings and recommendations for action were discussed with the Chairman in advance of the
report being circulated to the Board.
Review and action
planning
The final report was discussed at the December 2022 Board meeting.
The Board agreed an action plan in response to the recommendations set out in the report.
2022 Board evaluation – outcomes and actions
The conclusion of the 2022 Board evaluation was that the Board operated effectively throughout the year and fulfilled its remit as
set out in its terms of reference. Directors engaged fully with the evaluation exercise and commented positively in relation to many
aspects of the Board’s operations.
The evaluation findings noted that overall sentiment was good and there was a real sense of the Board and executive management
working well together to drive the business forward. Purpose was strong and was evident in decision-making and the revised
approach to strategy had worked well. Setting Board objectives in 2022 was considered helpful in directing focus and there had
been good oversight of priorities and outcomes.
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Implementation of the 2022 Board evaluation action plan will
be overseen by the Group Nominations and Governance
Committee during 2023.
2022 Board Committee evaluations – outcomes and actions
Details of the outcomes of the 2022 Board Committee
evaluations can be found in the relevant Committee Chair
reports. Progress against these actions will be tracked at
Committee level during 2023.
2022 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 by directors
during the evaluation. 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 by directors during the evaluation.
4. 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 report (page 108) which
describes the completion of an external audit tender and sets
out the process undertaken to evaluate the effectiveness of
both the Internal Audit function and the external auditors 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 68) 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 168), which explains the
internal control framework in place and how the Board
monitors and reviews the company’s risk management
and internal control systems; and
the Group Board Risk Committee report (page 117)
which explains how the Board oversees the principal and
emerging risks facing NatWest Group and how management
addresses these.
The Board regularly assesses the company’s emerging
and principal risks in a variety of ways including through
consideration of the risk management report. Details of the
company’s principal risks, procedures in place to identify Top
and Emerging Threats, and how these are being managed or
mitigated, can be found on pages 64 to 67 (Risk overview) and
pages 176 to 283 (Risk and Capital Management).
5. Remuneration
The Directors’ remuneration report on pages 138 to
167 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 including our
approach to providing fair pay.
Overall, the directors felt the Board’s size was about right and succession planning had been handled well. The culture of the Board
had continued to develop positively, although the dynamic could be further improved. The balance of responsibilities between the
Board and Committees was appropriate, but Committee reporting to the Board could be sharper.
Director feedback on the Board calendar, time commitment and stakeholder visits were all positive. Directors reiterated that agendas
should ensure key issues are prioritised and that papers should not be too long. Board training was considered good and directors
appreciated the strong support from the corporate governance team.
In December 2022 the Board agreed a detailed action plan in response to the recommendations set out in the internal Board
evaluation report, which included the following:
Theme
2023 actions
Purpose and
strategy
Include an annual review of purpose embedding at the Board.
Review format of future strategy sessions to include discussion on longer term trends.
Board focus and
priorities
Set Board objectives for 2023.
Chairman and Chief Governance Officer and Company Secretary to review agendas in 2023 and
encourage discipline in Committee Chair reporting and paper lengths.
Engagement with
business and
stakeholders
Review mechanisms for Board engagement with the executive talent pipeline and ensure all CEO-1/2
successors have some form of exposure to the Board during the year.
Explore opportunities for the Board to meet in/visit regional hubs.
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Corporate governance
continued
Report of the Group Nominations
and Governance Committee
Dear Shareholder,
As Chairman of the Board and Chair of the Group Nominations
and Governance Committee, I am pleased to present our report
on the Committee’s activity during 2022.
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 the 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 2022
The Committee supports the Chair in keeping the composition
of the Board and its Committees under regular review. The
Committee reviews and recommends to the Board a skills
matrix which is used to map the skills and experience of
individual directors and ensure that the Board’s collective
skill-set remains appropriately balanced and aligned to current
and future strategic priorities. The matrix is also used to identify
any gaps and opportunities to enhance the collective balance of
skills through additional recruitment to the Board.
Following the Committee’s review of the skills matrix and
noting the tenure of a number of non-executive directors, the
Committee supported implementation of the Board’s succession
plans by overseeing the search for two new non-executive
directors during 2022.
A subset of the Board’s membership selected Audeliss to
support a comprehensive candidate search with diversity and
inclusion considerations at the forefront of the search criteria.
The Committee held a number of discussions on potential
candidates as the search progressed, assessing the credentials
of each candidate against the qualities and capabilities set out
in the role specification agreed by the Committee. Following
a formal, rigorous and transparent process the Committee
recommended two candidates to the Board for appointment.
On 1 October 2022 Roisin Donnelly was appointed to the Board
as a non-executive director. On 16 December 2022 NatWest
Group announced that Morten Friis intends to stand down from
the Board with effect from the close of business on 31 July
2023, shortly after reaching the ninth anniversary of his
appointment. At the same time, it was announced that Stuart
Lewis would join the Board as a non-executive director and
member of the Group Board Risk Committee on 1 April 2023.
Subject to regulatory approval, Stuart will be appointed as Chair
of the Group Board Risk Committee on 1 August 2023. Both
Roisin and Stuart bring extensive skills and experience to their
roles and the Board looks forward to benefitting from their
valuable and important contributions.
During 2022 the Committee also reviewed the contribution
of a number of serving 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 the Chairman and non-executive directors are
set out on page 93.
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 2022, 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 People & Transformation function within NatWest Group.
Letter from Howard Davies,
Chair of the Group Nominations and
Governance Committee
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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 2022 the Committee considered a number of external
policy developments and the impacts on NatWest Group’s
corporate governance framework, including changes to the
Listing Rules and Disclosure and Transparency Rules introduced
following the FCA’s review of diversity and inclusion on
company boards and executive committees.
Membership and meetings
Throughout the majority of 2022 the Committee comprised the
Chairman of the Board and four independent non-executive
directors. Lena Wilson joined the Committee on 24 September
2022, when she succeeded Robert Gillespie as Chair of the
Group Performance and Remuneration Committee. Robert
remained a member of the Committee until he stood down
from the Board on 15 December 2022. 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 2022, there were four meetings. Individual
attendance by directors at these meetings is shown in
the table on page 91.
Performance evaluation
The 2022 review of the effectiveness of the Board and its senior
Committees was conducted internally in 2022 by the Chief
Governance Officer and Company Secretary. The Committee
has considered and discussed the outcomes of the evaluation
and accepts the findings, more information on which can be
found on page 104. 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
Board succession planning that will continue to be a key priority
for the Committee during 2023.
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 pages 93 and 102, the Board operates a
boardroom inclusion policy which reflects NatWest Group’s
values, its inclusion guidelines and relevant legal or voluntary
code requirements. 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.
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.
Page 168 confirms NatWest Group’s approach to Provision 17
of the Code which sees oversight of succession plans for senior
management positions and the development of a diverse
pipeline for succession reserved as a matter for the full Board.
Pages 48 to 49 contain more information on how NatWest
Group is creating a diverse, equitable and inclusive workplace,
including (in relation to Provision 23 of the Code) the gender
balance of senior management and their direct reports.
Monitoring and reporting
Throughout 2022 the Board met the recommendation of the
Parker Review with at least one member of the Board being
of an ethnic minority background and it intends to continue
to meet that recommendation.
At the end of 2022 the Board exceeded the FTSE Women
Leaders Review target of 40% female Board representation
by the end of 2025, with 45% of the Board being female.
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.
Howard Davies
Chair of the Group Nominations and Governance Committee
16 February 2023
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Corporate governance
continued
Report of the Group
Audit Committee
Dear Shareholder,
I am pleased to share with you details of how the Group
Audit Committee (The Committee or GAC) discharged its
responsibilities and its key areas of activity in 2022. It has
been another busy year and I would like to thank my fellow
Committee members for their contributions, in particular Robert
Gillespie who stood down from the Committee at the end of the
year. The Committee also appreciated the views of Graham
Beale and Ian Cormack, who are non-executive directors and
Audit Committee members of NatWest Holdings and attend
GAC meetings in an observational capacity.
The Committee’s primary purpose is to oversee and challenge
management’s approach to the preparation of financial results
and relevant non-financial disclosures. This includes considering
existing and new accounting policies, scrutinising standards of
internal control and their efficacy and reviewing the disclosures
each quarter prior to release. More detail on the remit of the
Committee can be found in its terms of reference which are
reviewed annually and are available at natwestgroup.com.
Interrogating the quarterly releases of financial and relevant
non-financial information continued to be a priority for the GAC
in 2022. This included consideration of relevant reports from
management on the judgements 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 how those
controls might be developed and also applied to other areas
of NatWest Group’s activities. The Committee also received
reports from the internal audit function on the internal control
environment and the external auditors on internal controls over
financial reporting and key accounting and judgemental matters.
As the economic recovery following the COVID-19 pandemic
continued during 2022, it was evident that new macroeconomic
challenges were emerging, including the rising cost of living
and supply chain issues. As such the Committee agreed with
management that post model adjustments to expected credit
losses would be required throughout the year although the
composition evolved during that time.
A major focus of the Committee and management in 2022
was the tender for the external audit. Detailed consideration
was given to the timing of this process, and it was determined
appropriate to accelerate it to ensure a competitive process
and provide management with clarity for potential consultancy
engagements. Following consideration of the responses
received, and presentations from the responding firms to
management and to the Committee, the appointment of PwC
as auditors of NatWest Group from 2026 was recommended
to the Board. Further details can be found on page 109. The
Committee has been satisfied with the performance of the
current auditors, EY, throughout the firm’s tenure.
I have continued to fulfil the role of whistleblowers’ champion
for NatWest Group, receiving regular updates on the efficacy
of the whistleblowing framework, themes in reports made by
colleagues via the systems and monitoring the outcomes of
the most pertinent cases. The Committee continued to hold
responsibility for oversight of the independence, autonomy and
effectiveness of NatWest Group’s whistleblowing policies and
procedures. It is pleasing that colleague awareness of how
to raise concerns remained high in 2022. A refreshed
communications campaign during the year linked to NatWest
Group’s new values and purpose further helped to embed a
culture where colleagues feel able to raise any concerns via
the whistleblowing framework.
Membership
Full biographical details of the members of the Committee
during 2022 are set out on pages 86 to 89. 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.
Letter from Patrick Flynn,
Chair of the Group Audit Committee
‘Our objective was to run a competitive
audit tender through a process that is fair and
transparent for those firms participating with
minimal disruption to NWG during this period.’
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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 Group 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,
during his tenure as a member of the Committee, 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.
Meetings and visits
Five scheduled meetings of the Committee were held in 2022,
four of which took place immediately prior to the release of the
financial results each quarter. One ad hoc meeting was also
held, to consider management’s preliminary assessment of
half-year out-turn on expected credit losses at H1 2022. During
the year all members attended the meetings, the majority of
which were held in person. 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 2022 the annual review of the effectiveness of the Board
and its senior Committees, including the GAC, was conducted
internally by the Chief Governance Officer and Company
Secretary. It was determined that the GAC had continued to
operate effectively during 2022, meeting its statutory duties.
The outcomes of the evaluation were considered by the
Committee and subsequently reported to the Board. The key
area for focus related to improved discipline on the papers
presented to the Committee. The GAC will monitor progress
during 2023. The Committee is satisfied it fulfilled its terms of
reference throughout the year.
The Committee continued to monitor the performance of the
external auditor and the Internal Audit function in 2022. 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.
Patrick Flynn
Chair of the Group Audit Committee
16 February 2023
External audit tender
April 2022
– discussed the benefits and disadvantages of
accelerating the timescales for the external audit tender,
which would be required to be undertaken by 2024 at the
latest. Further information was requested on the potential
participants, the impact on existing and planned consultancy
work, and the proposed selection criteria used in a tender.
June 2022
– it was agreed that the audit tender process
should be accelerated to ensure the best availability of firms
able to respond. The market was informed of the decision to
commence the process, in line with regulatory requirements.
June 2022
– the process commenced with firms invited
to participate in the tender; three statements of intent
were received from firms with one firm unable to provide
a team which would meet NatWest Group’s requirements.
July/August 2022
– management supported the supplier
evaluation, capability and independence assessments,
interviews held with key members of management,
and deep dives into specific areas of capability.
Mid-September 2022
– management panel sessions held.
End of September 2022
– final presentations by firms to
GAC members. The Committee then deliberated on its
recommendation to the Board
October 2022
– Key factors in assessing firms included:
the understanding of NatWest Group; the quality of the
engagement team; the capability of the firm, with a focus
on data and digitisation capabilities; the quality of the audit
approach; the availability to the engagement team of suitable
global resources to meet NatWest Group’s requirements;
independence; and value add. Having considered the scoring
criteria, key factors, input and observations from the
Committee and from the presentations themselves, the
Committee recommended to the Board that PwC be
appointed as NatWest Group’s External Auditor for the
financial period ending 31 December 2026, subject to
shareholder approval.
Our objective was to run a competitive audit tender through a process that is fair and transparent for those
firms participating with minimal disruption to NWG during this period.
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Corporate governance
continued
Financial and non-financial reporting
The GAC considered a number of accounting judgements and reporting issues in the preparation of NatWest Group’s financial results
throughout 2022. 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 Board for approval. This included the
disclosures required by the TCFD and the ESG Disclosures Report. 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. While economic
uncertainty persisted in 2022, the causes pivoted from the post-pandemic
recovery to rising inflation and cost of living. As the macro-economic
environment developed during the year it was clear that it would not
be possible to adopt a net release of IFRS 9 provisions in the year. The
provisions relating to the COVID-19 pandemic were replaced by those
of a similar quantum for economic uncertainty. This was considered to
be the most appropriate course of action given the uncertainty, and an
environment of rising interest rates not experienced in recent times.
Industry benchmarking data continued to be 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. In addition, the circumstances
in which the underlying scenarios used to model expected credit loss
provisions would be revised to reflect significant economic uncertainty
were discussed in October 2022 with a full refresh undertaken in advance
of the 2022 year-end process. The Committee will continue to scrutinise
the application of post-model adjustments in 2023.
Treatment
of goodwill
To consider the treatment of
goodwill throughout the year
and ensure the carrying value
was appropriate and suitable
disclosures were made.
The Committee supported management’s view that it was not necessary
to undertake an out of cycle reassessment of goodwill during 2022.
Following discussion and challenge, the Committee was satisfied that
goodwill remained recoverable throughout the year, and that appropriate
disclosures were included in the financial releases. Goodwill was retired
as a significant accounting judgement at the end of 2022 as a result
of improved projections which result in an impairment being
considered unlikely.
Valuation
methodologies
To consider valuation
methodologies, assumptions
and judgements made
by management.
The GAC considered valuation methodologies and assumptions for financial
instruments carried at fair value and scrutinised judgements made by
management on a quarterly basis throughout 2022.
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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. Three new provisions were taken during the year all
relating to conduct matters, one in relation to the mortgage repayments
by UBIDAC customers, one in relation to issues in respect of orphaned
wills and another for the remediation of historic lifetime mortgage products.
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 macro-economic developments such as
supply chain challenges and rising inflation. 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.
Climate-related
Disclosures
Report and ESG
Disclosures
Report
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 ESG Disclosures Report.
In 2022 the Committee also
reviewed the initial iteration
of our Climate transition
plan disclosure.
The Committee remained focused on the controls which support the
non-financial disclosures to ensure that they remained appropriate and
robust. The GAC noted that the controls were aligned with the controls
in place for financial disclosures.
The GAC discussed and provided feedback on both the Climate related
disclosures report, which incorporated climate transition plan information,
and the ESG Disclosures Report for 2022. A significant area of discussion
related to NatWest Group’s dependency on external factors in order to
achieve its Climate ambition and how this aligned to best practice disclosure.
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Corporate governance
continued
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 2022 enabling it to
monitor progress and support management’s conclusion at the year end.
The Committee continues to receive updates from management on control
deficiencies that arise during the year, including those around expected
credit losses and value in use calculations that remain open at the
year-end. The Committee monitored the plans and transition to
more automated preventative key controls.
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.
As part of management’s ongoing work to strengthen the financial
reporting control environment in 2022, the Committee received updates
at each scheduled meeting as to the progress achieved to implement the
findings of the industry-wide skilled person’s review of regulatory returns.
It encouraged management to ensure delivery remained in line with the
planned timetable and was pleased with the positive progress during
the year.
The Committee received regular updates on the 2021 event affecting
two securitisation structures which was identified during 2022. A particular
focus of the Committee’s discussions was on the review of the end-to-end
framework and the work undertaken to strengthen associated controls.
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.
The Committee received bi-annual reports on the Control Environment
Certification, which were supplemented by the views of the second and
third lines of defence. The Committee was pleased to note that the overall
Control Environment strengthened during 2022 as the Financial Crime
Return to Appetite Plan delivered against key milestones.
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 2022 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.
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Matter
Role of Committee and context
of discussion
How the Committee addressed the matter
Early event
escalation
To monitor control incidents
captured by the internal event
escalation process.
The Committee received bi-annual updates on the volumes and nature of
the most significant control incidents escalated via the internal early event
escalation process and any common themes. The early event escalation
process was introduced at the start of 2022, replacing the previous Group
Notifiable Event Process (GNEP). Simultaneously the impact classification
matrix was revised in line with current risk appetite. The reliance on
manual processes and controls was a significant cause of events in 2022,
which the Committee noted with concern. The work to introduce greater
automation into the bank’s key processes is ongoing and the Committee
encouraged this to be completed promptly. It was noted that the creation
of the payments Centre of Excellence and the appointment of a senior
executive to lead work would improve controls in this area.
All Board directors were alerted to the most significant events throughout
the year.
Whistleblowing
To monitor the effectiveness
of the bank’s whistleblowing
policies and procedures. The
Committee Chair 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 Committee noted the output of Internal Audit’s
annual review of the whistleblowing process, which had focused on
controls over the management of whistleblower detriment in the Speak Up
framework, and the adequacy of detriment training provided to colleagues.
The findings were broadly positive with certain areas identified for
enhancement which will be progressed by management, with the
Committee’s support.
The GAC Chair acts as NatWest Group’s Whistleblowers’ Champion,
in line with PRA and FCA regulations, and meets regularly with the
whistleblowing team. There is appropriate escalation of matters to the
Board and dissemination of information to the principal subsidiaries to
ensure a coordinated approach across the bank.
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.
The Committee received quarterly reports detailing 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 provisioning levels, significant provided
and unprovided tax risks and deferred tax assets.
The GAC reviewed the disclosure on internal control matters in conjunction
with the related guidance from the Financial Reporting Council.
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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.
The Committee received quarterly opinion reports from Internal Audit,
setting out the function’s 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. Internal Audit reported a continued steady strengthening of the
bank’s control environment over the course of the year. The function
continued to assess and report on the implementation of significant
programmes, such as the Financial Crime remediation work, which was
welcomed by the Committee. The increased use of quantitative metrics to
support Internal Audit’s conclusions was also welcomed by the Committee.
The Committee monitored the development of audit report ratings and
timeliness of issue resolution. The Committee considered the IA opinion
of the strength of the control environment.
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 2022 plan and
budget at the end of 2021. The Committee supported the planned focus of
work on the most high-risk areas for the bank, and welcomed the flexible
approach adopted by the Internal Audit management in the event of new
or emerging risks or requests for audit work during the year. The 2022
budget was consistent with the prior year, reflecting the delivery of
efficiencies in the function. In December 2022, the Committee
approved Internal Audit’s 2023 plan and budget.
Internal Audit
Charter and
independence
To approve the Internal Audit
Charter each year and review
the independence of the Chief
Audit Executive (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.
Performance/
evaluation
To monitor and review, at least
annually, the effectiveness of
Internal Audit.
In 2022 the CAE continued to report to the GAC Chair with a secondary
reporting line for administrative purposes to the Group CEO. This is
consistent with prior practice and industry guidance.
The GAC assessed the annual performance (including risk performance) of
the function and CAE. The 2022 evaluation of the Internal Audit function
was carried out internally, and it is expected an external audit quality
assessment will be performed in early 2023. For the purposes of the 2022
evaluation, stakeholders across the bank, including the GAC members,
attendees and the external auditors were invited to provide 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 opportunities to improve bench-strength and
to focus activity on emerging areas of focus for NatWest Group. Progress
will be overseen by the GAC in 2023.
Visit
To undertake an annual deep
dive session with members
of the Internal Audit
leadership team.
Together with the BRC, the GAC participated in a successful deep
dive session with Internal Audit’s management team. A variety of issues
impacting the function were discussed, including: succession planning and
bench-strength; talent and mobility; functional priorities; and the impacts of
increased automation and use of technology in audits.
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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 NatWest Group’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. In October 2022, the
Committee recommended that PwC be appointed as NatWest Group’s auditor from 2026.
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 review-related work
and conclusions of the external auditor. The reports included EY’s view
of the judgements 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.
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 2022 plan. It welcomed the external auditor’s
focus on innovation, as well as the intention to utilise a data-leveraged
approach to the audit.
In line with the authority granted to the Committee by shareholders at
the 2022 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 2022 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. Management also committed
to continuing to support the external auditor in minimising costs associated
with the audit.
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.
The evaluation of the external auditor’s performance in 2022 was
undertaken 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.
Stakeholders were invited to assess 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. Key strengths included fresh perspectives
provided following partner rotation and the technical strength of the
audit. Improvement areas included junior staff capabilities, continued
enhancement of written reporting and providing additional external
benchmarking and market insight.
Audit partner
To oversee the lead audit
partner and resolution of
any points of disagreement
with management.
Micha Missakian has been EY’s lead audit partner for NatWest Group since
February 2021. He attended all meetings of the Committee in 2022 and
met in private session with the Committee members twice during the year.
This provided the external auditor an opportunity to raise any points of
disagreement with management. No such points were raised by the
external auditor in 2022.
Additional
reports
prepared by
the external
auditor
To review reports prepared by
the external auditor in relation
to NatWest Group.
During 2022 the Committee considered 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 and received the outcome of EY’s written auditor report to the PRA
under supervisory statement SS1/16 for the year ended 31 December
2022. EY also presented the findings of their audit of the Climate-related
Disclosures Report and ESG Disclosures Report to the GAC.
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Corporate governance
continued
Matter
Role of Committee and context
of discussion
How the Committee addressed the matter
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 2022. Under the policy, all audit-related services and
permitted non-audit service engagements are approved by the GAC
with updates presented to each scheduled meeting. 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. For
fees under £250,000, work can be approved on an interim basis by the
GAC Chair, subject to subsequent ratification by the next scheduled
GAC meeting. 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 issuance 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 2022, the Committee did not approve any
significant non-audit engagements (where the fees exceeded £100,000) to
be undertaken by the external auditor. The audit to non-audit fee ratio for
2022 was 15%. 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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Report of the Group
Board Risk Committee
Dear Shareholder,
I am pleased to present my third and final report as Chair 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 2022, the Committee ensured its time was prioritised to
focus on oversight of NatWest Group’s principal and emerging
risks. Financial crime has remained a key area of focus and
the Committee has been pleased to see significant progress
towards a return to appetite. Other areas of focus have
included model risk remediation activity; oversight of
implementation of risk management framework improvements,
particularly the Risk and Control Self-Assessment (RCSA)
roll-out; oversight of the effectiveness review of the Risk
function, which included the evolution of the risk management
strategy; and a wide range of operational risk matters. Risk
management across NatWest Group has continued to be an
area of regulatory focus and BRC has played a key role in
overseeing and challenging progress in this regard. Emerging
priorities during the year included Consumer Duty requirements,
data, cloud hosting risk and payments technology and
architecture. Additionally with the volatile geopolitical and
economic environment, BRC devoted significant time to the
impact of the external economic environment on NatWest
Group’s risk profile. It is expected that these will continue to
be areas of focus in 2023 as NatWest Group drives towards
return to appetite in a number of areas, implements changes to
meet regulatory expectations, and continues to respond to the
external economic environment and cost of living pressures.
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 during what has
been an unpredictable and eventful year, and throughout my
tenure as BRC Chair.
Morten Friis
Chair of the Group Board Risk Committee
16 February 2023
Membership
BRC comprises four independent non-executive directors. The
details of the members and their skills and experience are set
out on pages 86 to 89. Robert Gillespie stepped down as a
member of the Committee when he stepped down from the
Board on 15 December 2022. I would like to thank Robert for
his long-standing commitment and contribution to the Committee.
Patrick Flynn is chair of the Group Audit Committee of
which I am also a member. Lena Wilson is chair of the Group
Performance and Remuneration Committee (RemCo). This
common membership helps to ensure effective governance
across the committees.
Regular attendees at BRC meetings include: the Group
Chairman, Group CEO, Group CFO, Group CRO, Group Chief
Legal Officer and General Counsel, Group Chief Audit Executive,
and the External Auditor. External advice is sought by the
Committee where appropriate.
Francesca Barnes joined NWH Ltd’s BRC in September 2022.
Francesca, Graham Beale and Ian Cormack 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.
‘BRC has helped to ensure that NatWest
Group is purpose-led in its decision-making
through its oversight of risk management
frameworks and in overseeing and advising
the Board on both current and potential
future risk exposures.’
Letter from Morten Friis,
Chair of the Group Board Risk Committee
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Meetings and visits
There were eight scheduled meetings of the Committee held in
2022. Six of the eight meetings were held in person, with the
remaining two meetings held virtually during the year. Details
of meeting attendance can be found on page 91.
Outside formal meetings, the Committee met with the Risk
Leadership Team and held additional sessions to consider
improvements to the risk management report and the
development of the risk management strategy. Dinners were
arranged to discuss the Retail strategy from a risk perspective
and to consider the operation of the Committee. Members of
the Group and the NWH Ltd BRCs also undertook a programme
of visits to the Risk, Internal Audit and Finance functions, in
conjunction with members of the Group and the NWH Ltd
Audit Committees.
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 senior Committees, including BRC, was
conducted internally in 2022. The PRA also conducted a
review of the BRC.
The Committee held a dedicated session to discuss its
performance. The session was structured around a number of
themes: focus and priorities; reporting and operating rhythm;
committee effectiveness and culture and dynamics. The
Committee agreed that it was operating effectively and believed
it discussed all principal and emerging risks and challenged
management appropriately. The Committee suggested that
there needed to be continued focus on prioritising agendas to
try to reduce the volume of papers and to allow sufficient time
for discussion. Continued improvement in the quality of papers
and timeliness of data presented to the Committee was also
desired. These will be areas of focus for 2023.
Corporate governance
continued
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Principal areas of Board Risk Committee focus in 2022
The table below describes the Board Risk Committee’s principal areas of focus in 2022, alongside key outcomes
and stakeholders considered.
Theme
Principal areas of Board Risk
Committee focus
Outcomes
Financial crime
Oversight of the management
and return to appetite of
financial crime risk, which
continues to be a principal
risk for NatWest Group.
Quarterly updates were
presented from all three lines
of defence. These included
progress updates on return to
appetite plans, transformation
and emerging risks/issues.
Additionally, the Committee
considered the Money
Laundering Reporting Officer’s
(MLRO’s) report
(*)
and the
enterprise-wide financial
crime risk assessment.
The Group CRO reported on
the financial crime risk profile
and remediation progress at
each meeting.
Throughout the year, the Committee challenged management on return
to appetite timetable, adequacy of resource and external support, and the
pace of transformation and remediation to protect customers by driving
improvements in financial crime. This included interrogating any differing
views among the three lines of defence on confidence in the return to
appetite timeframe.
Additionally, in anticipation of the return to appetite the Committee
ascertained from management the level of funding required to maintain
risk appetite and the evolution of financial crime risk to ensure that threats
were monitored and mitigated effectively. The Committee acknowledged
the significant progress on financial crime made during the year, which
was supported by all three lines of defence.
Model risk
BRC maintained close oversight
of management activity to
return to appetite for model
risk through quarterly detailed
updates, including the
development, validation, and
submission of Internal Ratings
Based models for regulatory
approval. In intervening months,
updates were given via the risk
management report.
The Committee closely monitored the number of models that had
been revised, enhanced or removed due to changes in the external
environment. It held management to account on return to appetite plans
and challenged and agreed proposed recalibration of the model risk
appetite measures to take account of regulatory approvals. It sought to
understand model risk appetite breaches and resultant actions. It asked
for comfort on resource contention, particularly from a technology
perspective to ensure model risk was appropriately prioritised.
(*)
Reviewed by BRC in line with the Committee’s role to review reports and regulatory submissions on behalf of the Board and recommend them for approval.
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Theme
Principal areas of Board Risk
Committee focus
Outcomes
Risk function
oversight
and risk
management
strategy
BRC monitored the effectiveness
of the Risk function, including the
self-assessment undertaken by
Risk supported by independent
review and validation by the
Internal Audit function. The
Committee oversaw the
development of a risk
management strategy across
all three lines of defence.
Whilst the Risk self-assessment concluded that the Risk Function
was materially effective and met regulatory expectation, a number of
improvements were identified by both Risk and Internal Audit assessments.
The Committee requested that a combined action plan with detailed
milestones was developed, and progress updates provided to the
Committee to ensure that continued improvements were delivered
at pace. These updates were discussed by the Committee, and as
necessary management were held to account on progress and timelines.
The Committee provided detailed feedback on the risk management
strategy to ensure it was appropriately aligned with NatWest Group
strategy and relevant to all three lines of defence.
Enterprise-wide
Risk
Management
Framework
(EWRMF)
embedding
(including risk
appetite and
RCSA activity)
The EWRMF is NatWest Group’s
primary risk management and
risk governance document
providing a framework for
NatWest Group’s overall
approach to managing risk. The
EWRMF is approved annually
by the Board following the
Committee’s recommendation.
The Committee considers
EWRMF implementation to be
vital to NatWest Group’s robust
risk management and control
framework. BRC monitored
the effectiveness of the risk
management framework,
including the development
of RCSAs.
Further details can be
found in the Risk and capital
management section of
the report on page 178.
The Committee requested regular updates on embedding of EWRMF,
particularly implementation of the RCSA process which included detailed
oversight of achievement of milestones, ensuring that anticipated benefits
were delivered in the control environment and that lessons learned from
the initial pilots were incorporated into subsequent assessments. Internal
Audit’s year end review concluded that while some improvements were
needed, the RCSA programme had made good progress on delivery
and that RCSA activity overall was driving better risk awareness and
understanding of the end-to-end process.
The annual review of the EWRMF was presented to the Committee in
December 2022. It was recommended to the Board for approval and was
supported by Internal Audit’s review of EWRMF, which stated that, overall,
it was a comprehensive framework.
The Committee oversaw the refresh of both qualitative risk appetite
statements and the quantitative risk appetite measures in line with the
EWRMF. Additionally, it monitored the risk profile of NatWest Group
relative to risk appetite. The Committee provided feedback to ensure
that the measures met regulatory expectations and were robust.
The Committee challenged management to ensure risk appetite limits and
triggers were set appropriately, with changes made to the proposed limits
and triggers as a result. In particular, the Committee was keen to ensure
that risk appetite for NatWest Markets was appropriate.
The Committee received specific spotlights on all principal risks during the
year and approved principal risk policies in respect of those risks under
Board delegated authority.
Internal Audit also reviewed the Risk Appetite Framework, concluding
that this was a comprehensive risk framework, while recommending
improvements to support the consistent use and setting of
operational limits.
Corporate governance
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Theme
Principal areas of Board Risk
Committee focus
Outcomes
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 the
impact of economic pressures
experienced by customers and
colleagues, and scrutinising
management’s actions to
monitor and control exposures.
Oversight included a detailed
analysis of NatWest Group’s
risk profile, including the UK
and global economic outlook,
principal and emerging risks and
threats, and NatWest Group’s
performance against risk
appetite at each of its meetings
via risk management reports.
The Committee continued to seek further improvements to the format and
content of the risk management report throughout 2022, with detailed
feedback provided by the Committee to improve the timeliness of
information reported and the manner in which the information was
presented in order to highlight key messages and to enhance the level
of opinion provided by the Risk function. Updates implemented included
more detail on actions being taken to mitigate principal risks, progress
on implementation of the EWRMF and RCSAs, actions to address findings
from the risk effectiveness self-assessment, credit risk and the Commercial
Real Estate portfolio. It is expected that this work will continue into 2023 to
leverage benefits from ongoing transformation activity regarding risk and
finance data.
BRC continued to focus on principal and emerging risks and the strategic
impact of these. The impact of Russia’s invasion of Ukraine, including
impacts to the economy, and the cost-of-living pressures affecting
our customers and our colleagues was a key element of discussions
throughout the year. Particular focus was given to the credit, conduct,
Consumer Duty, and reputational aspects of both these risks and how
these were managed from a risk perspective. In addition, a reputational
risk spotlight focused on the effectiveness of the reputational risk
framework with a spotlight on the cost-of-living crisis.
Other key areas of focus included financial crime and model remediation;
regulatory compliance and conduct issues; operational and change risk.
Reports on legal and regulatory developments and litigation risks were
considered at each meeting.
Quarterly reports were received from the Chairs 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 Chairs of the Board
Risk Committees of material regulated subsidiaries were invited to join
meetings throughout the year, providing updates on key areas of focus.
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Theme
Principal areas of Board Risk
Committee focus
Outcomes
Transformation/
Major Change
programmes
BRC maintained oversight of
the delivery of NatWest Group’s
transformation and change
programme and its position
relative to risk appetite, including
oversight of red and amber-
rated programmes.
The Committee requested updates on specific programmes reporting
red and challenged how interdependencies between programmes were
managed and monitored and how strategic risks were being managed.
BRC also challenged management on slippage of Objectives and Key
Results (OKRs), and the unequal distribution of milestones across the
year. A proposed Change Risk profile measurement methodology change
was challenged by the Committee but ultimately supported following the
provision of additional rationale. The Committee also received an update
on the management of UBI DAC withdrawal risks as part of the
withdrawal from the Republic of Ireland.
Conduct and
regulatory
compliance
risk (including
Consumer Duty
and ring-
fencing
compliance)
The Committee reviewed
changes to risk appetite
measures and 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 and
in response to the FCA’s
Consumer Duty expectations
through leveraging NatWest
Group’s purpose.
The Committee supported the Board in overseeing management’s
progress in addressing Consumer Duty requirements through detailed
review of the implementation plan prior to approval by the Board. It was
acknowledged that timelines were challenging and there was significant
work to do during 2023. To ensure progress was being monitored, the
Committee requested a detailed milestone plan to implementation which it
was agreed it would track closely. The Committee also sought assurance
from management on appropriate funding and resource.
The Committee was informed of management’s approach to support the
Board ring-fencing compliance attestation due in March 2023 and progress
towards delivering the attestation.
Corporate governance
continued
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Theme
Principal areas of Board Risk
Committee focus
Outcomes
Operational
risk,
operational
resilience, and
cyber security
Operational risk has been
a key area of focus for BRC
throughout the year. It received
regular updates on NatWest
Group’s operational risk profile
and risk appetite, with a
particular focus on operational
resilience, manual controls and
information and cybersecurity.
The annual spotlight on
operational risk considered
improvements made to the
operational risk framework
and oversight of change risk.
The Committee considered
the operational resilience
self-assessment
(*)
in detail prior
to approval by the Board, with
important business services and
associated impact tolerances
operating as the foundation
for the assessment.
In addition, separate updates
on information security were
reviewed and BRC dedicated
time to the consideration of
cyber risk, the external threat
landscape, the action being
taken by management in
response, and the results of the
2022 Cyber Stress test
(*)
in which
NatWest Group participated.
Given the number of operational risk related incidents and regulatory
focus, the Committee requested additional detailed updates on operational
risk performance and trends.
The information and cybersecurity spotlight included consideration of any
increased threat from Russia following the invasion of Ukraine. Additionally,
BRC received updates on the results of a full scan of NatWest Group’s
data centres and remediation activity carried out on Log4J vulnerabilities.
The Committee requested a further update in respect of end of life
systems and received assurance from management on the risk posed
to NatWest Group, the sufficiency of investment, and how it compared
to peers.
Manual controls are a key area of concern for the Committee and the
Committee requested an update on the management of manual controls
and actions to reduce the number of manual controls was provided.
The Committee will continue to receive information on the elimination
of manual controls and drive to automation and requested that updates
be included in every risk management report.
The Committee queried the operational risk profile given recent payments
issues and asked that consideration be given to whether risk appetite
measures were appropriate. The Committee received assurance from
management that an end-to-end review of payments technology and
architecture was being undertaken.
Given the extensive competition for talent and cost of living crisis, the
Committee considered how people risk was being managed and
mitigated across NatWest Group.
(*)
Reviewed by BRC in line with the Committee’s role to review reports and regulatory submissions on behalf of the Board and recommend them for approval.
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Corporate governance
continued
Theme
Principal areas of Board Risk
Committee focus
Outcomes
Data
management
and BCBS239
Data is an emerging area
of focus for the BRC and it
received reports on the data
management risk profile,
including the activity underway
to transform data consumed by
Risk and Finance functions for
risk and regulatory reporting
purposes and to respond to
issues identified as part of
an industry-wide data
thematic review.
The Committee 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.
The Committee continues to have concerns on the timeliness and
accuracy of some data and requested sight of plans to improve the
risk reporting processes, particularly through the Risk and Finance Data
Transformation Programme. The Committee asked to see regular updates
on progress against programme milestones. An update on the programme
was discussed at a joint BRC/GAC visit to Finance in December 2022 and
will continue to be an area of focus.
Outsourcing
and third
party risk
management
BRC maintained oversight of
NatWest Group’s outsourcing
and third party risk management
to facilitate oversight of the
identification and management
of third-party related risks.
In particular, the Committee
focussed on the Cloud Hosting
strategy and management of
related risks.
BRC discussed changes in Board accountabilities for Outsourcing following
the publication on SS2/21. The Committee challenged management
regarding how their approach satisfied regulatory expectations and
requested further updates to the third-party risk management dashboards
and policies which facilitated oversight of the identification and
management of third-party related risks. The Committee requested
clarification of the delineation of responsibilities between the Board and
Executive and challenged management on its assessment of exit planning,
including timings. In addition, the Committee recommended the
outsourcing policies for Board approval.
The Committee also considered the Cloud Hosting strategy which had
been approved by management and received updates on management’s
response to the findings of a benchmarking review of NatWest Group’s
Cloud Hosting strategy compared to peer banks. The Committee
considered the enhancement of risk appetite measures in relation to cloud
hosting and the Committee requested that the proposed future approach
to concentration risk be considered in response to Committee concerns.
The Committee has requested further detail on NatWest Group’s transition
to the cloud.
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Theme
Principal areas of Board Risk
Committee focus
Outcomes
Financial and
Strategic risks
Regular monitoring of principal
financial and strategic risks is a
pivotal part of BRC’s role both
via routine risk reporting and
via regular focused reports.
BRC completed a detailed review
of capital, funding and liquidity
requirements and also reviewed
capital distribution proposals
prior to Board consideration.
BRC received separate updates
in respect of the retail and
wholesale credit risk portfolios
in addition to reporting on credit
and market risk within the
risk management report.
The Committee also received
updates on the Commercial &
Institutional (ring-fenced bank)
credit portfolio and credit
decisions made by the Executive
Credit Group. Further spotlights
were considered in respect of
traded and non-traded
market risk.
Credit and market risk
– These updates provided insight into the sources
of the risk, including asset quality, risk management approach and risk
appetite, controls as well as testing and monitoring activity undertaken.
The Committee challenged whether the level of the BRC’s oversight
of traded market risk was appropriate and whether capabilities were
comparable to peers. This resulted in traded market risk stress limits being
revised and external insight from EY being provided. The Committee also
questioned management on the measures being put in place to support
customers in difficulties due to the cost of living crisis, including problem
debt preparedness and monitoring for signs of stress. The Committee
received regular status updates and assurances from management that
a pro-active approach was being taken across NatWest Group and that
there were sufficient resource levels in the customer services teams.
ICAAPs, ILAAPs and Budget and Risk Appetite Stress Tests
(*)
– The
Committee reviewed and recommended to the Board the scenarios to be
used during 2023 for the budget process, IFRS9 management and for the
monitoring of the risk profile relative to the approved Risk Appetite. BRC
considered the budget and budget stress test as well as the ILAAP and
ICAAP for the NatWest Group and recommended them to Board
for approval. It supported Risk and Internal Audit improvement
recommendations which will be incorporated in 2023 submissions.
Capital distributions
– The Committee provided detailed review of
proposals to increase capital distributions to shareholders prior to approval
by the Board, including an in-market buy-back and payment of a special
dividend with consolidation features, following the improved projected
capital position of NatWest Group. The Committee reviewed and
recommended initial proposals for year-end capital distributions
to the Board ahead of final approval in February 2023.
The Committee challenged management on the appropriateness of
reducing the level of capital held above regulatory supervisory levels, the
manner in which capital would be deployed over the plan, and the level of
anticipated future capital distribution. The Committee recommended the
Capital Management Enhancement Plan to the Board for approval and
had oversight of its delivery which would be required to support 2022
year-end capital distributions.
Climate risk
– The Committee considered the Climate Biennial Stress
Test Results Round 2
(*)
(CBES 2) in detail prior to Board approval. Following
the embedding of climate risk into the existing EWRMF, BRC received a
spotlight on climate risk which considered the status of franchises and
functions against maturity plans and embedding of the Climate Risk
framework together with feedback from the PRA on CBES2. The
continued challenge to achieving NatWest Group’s climate ambition
and maintaining its position versus peers was discussed.
(*)
Reviewed by BRC in line with the Committee’s role to review reports and regulatory submissions on behalf of the Board and recommend them for approval.
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Corporate governance
continued
Theme
Principal areas of Board Risk
Committee focus
Outcomes
Stress testing,
recovery plans
and the
resolvability
self-assessment
BRC reviewed in detail the stress
testing activity undertaken by
management to identify and
monitor risks and threats.
BRC also monitors and
challenges the development
of plans which would allow
NatWest Group to be dealt
with effectively in the event
of financial failure.
Stress testing scenario –
Stress testing scenarios used to monitor and
measure risk profile have been kept under close review by the Committee
given the significant changes to the external environment and the
importance of capturing the range of outcomes NatWest Group needs
to be prepared for. Management responded quickly to the impact of the
Russia/Ukraine conflict providing the Committee with updated scenarios to
reflect the range of potential risk and uncertainties posed. BRC considered
the stress scenarios to be used for monitoring a moderate, severe and
extreme stress, including for the 2023 Bank of England Annual Cyclical
Scenario (ACS) Stress Test and recommended the same to the Board
for approval.
Bank of England stress tests
–– BRC challenged and scrutinised the
outputs of the 2022 Bank of England Annual Cyclical Scenario (ACS)
Stress Test
(*)
and recommended it to the Board. Overall, the results
showed that NatWest Group remained within risk appetite and remained
above regulatory thresholds in all stress scenarios, which the Committee
noted reflected strong capital and risk management by NatWest Group.
The Committee questioned management on the results, focusing
particularly on ensuring that the results and the methodology met
regulatory expectations. The Committee sought clarity on the
Prudential Regulation Authority’s views of the credit submission.
Recovery Plan
– BRC performed a detailed review of changes to the
NatWest Group Recovery Plan
(*)
prior to approval by the Board. The
Committee noted the mature process now in place and improvements
that had been implemented in the past year. It was acknowledged
that NatWest Group had adequate capacity and capabilities in a
recovery scenario.
Resolvability self-assessment
– The Committee reviewed the
Resolvability self-assessment
(*)
and recommended the final submission
to the Board for approval. The Committee discussed market disclosure
requirements and future reporting requirements. It considered
management’s response to regulatory feedback on the Resolvability
self-assessment particularly the Board’s role in resolution, and was keen
to understand how NatWest Group compared to peers. BRC received
updates on resolution planning and retained oversight over material
Resolution Programme deliverables to year end, including Operational
Continuity in Resolution.
(*)
Reviewed by BRC in line with the Committee’s role to review reports and regulatory submissions on behalf of the Board and recommend them for approval.
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Theme
Principal areas of Board Risk
Committee focus
Outcomes
Control
environment
BRC continued to monitor the
effectiveness of internal controls
required to manage risk and
was provided with updates
regarding the control
environment ratings of NatWest
Group, franchises, functions,
services, and legal entities.
Particular areas of focus were in respect of financial crime, model risk,
operational risk and data risk. The Committee received regular updates on
trends in Early Escalation Events 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. BRC received updates on Intelligent Risk Taking as a
fundamental pillar within the One Bank culture. This included an update
on the development of further guidance regarding expected behaviours
including examples. The Committee continuously challenged progress
towards a CE2 rating as it came through in a number of discussions
through the year. The Financial Crime CE rating was a particular
area of focus.
Accountability
and
remuneration
BRC continued to provide
oversight over the risk
dimension of performance and
remuneration arrangements, as
well as accountability review
recommendations, working
closely with RemCo.
Remuneration
– The risk and control goals of the NatWest Group
Executive Committee members and relevant attendees (ExCo) were
considered by the Committee, with particular focus on ensuring alignment
with regulatory expectations. These were recommended to RemCo,
together with the individual performance goals for the Group Chief Risk
Officer. In addition, the Committee considered the risk and conduct
performance of ExCo and made recommendations to RemCo regarding
risk related adjustments to variable pay, including annual bonus awards,
the grant of relevant Restricted Share Plan awards and vesting of the
2020 Long-Term Incentive awards, thereby ensuring fair reflection of risk
and conduct performance in variable pay 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 and conduct management performance.
Remuneration policy
– The Committee conducted its annual review of
the Material Risk Taker identification process. In addition, the Committee
commissioned a review of its role in the NatWest Group’s remuneration
governance framework. The review concluded that, whilst the Committee’s
involvement in performance and remuneration arrangements is in line with
both regulatory expectations and UK peer banks, improvements were
required to the format and content of remuneration-related materials
presented to the Committee. Improvements are underway and will
remain a focus in 2023.
Accountability
– The Committee continued its oversight of regulatory
reportable events, other material investigations and resultant accountability
review recommendations, ensuring the appropriateness of these
recommendations from a risk perspective. Further detail on how risk
is considered in remuneration decisions can be found in the Report of
RemCo from page 138.
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Corporate governance
continued
Report of the Group
Sustainable Banking Committee
Dear Shareholder,
I am pleased to present my fifth and final report as Chair of the
Group Sustainable Banking Committee (the Committee or SBC).
Delivering against the purpose-led strategy
The Committee continued to support the Board in overseeing,
supporting and challenging actions being taken by management
to run the bank as a sustainable business, capable of generating
long term value for stakeholders. This included playing an
important role in overseeing progress and performance against
NatWest Group’s purpose-led strategy on behalf of the Board.
This year our agendas and discussions have reflected the
challenging external environment, both economic and
regulatory, and how it is impacting our stakeholders as
well as our sustainable business model.
In response to feedback arising from the 2021 performance
evaluation and working together with the management team,
we have worked to drive action and effect change in the areas
within our remit.
2022 Highlights
We held several spotlight sessions throughout the year, covering
the pillars of our purpose (climate, learning and enterprise), as
well as customer, people and culture, and conduct and ethics.
The views of internal and external stakeholders were sought
wherever possible and meeting time was prioritised towards
meaningful debate and discussion.
Membership, Meetings and Escalation
There were no changes to the Committee’s membership during
2022. Membership of the Group Sustainable Banking Committee
continued 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 of the Committee can be found in the
Corporate Governance report.
The Committee continues to hold five meetings per annum
and reports to the Board on the Committee’s activities after
each meeting, escalating matters for the Board’s attention
as appropriate. An ad hoc meeting was scheduled in 2022 to
revisit Climate transition plan progress including management
actions raised ahead of consideration by the Board. The
Committee operates under delegated authority from the Board
and its terms of reference are available on natwestgroup.com.
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 internally in 2022. It was
determined that the Committee continued to operate effectively
and have in-depth discussion on areas of critical importance to
the purpose and long-term sustainability of NatWest Group.
It was suggested that the structure of meetings be re-visited
to receive more frequent updates on key matters, including
emerging issues and not be duplicative with other forums.
The Committee is keen for its discussions to be useful for
management whilst driving further action.
In 2023 the Committee will look to ensure the areas considered
by the Committee continue to add value to the Board and
management, with well structured, forward-looking, customer-
focused and strategic discussions. Challenging views and a
diverse range of insights will continue to be sought to support
the 2023 meetings.
The Committee operated within its terms of reference during
the year. In July, the Committee’s terms of reference were
broadened to incorporate environmental (including biodiversity,
forests and water) oversight to help promote the topic within
the Board-level governance framework and this will be an
area of focus in 2023.
Conclusion
The Committee has continued to effectively support the Board
in overseeing progress on the embedding of purpose, which
will drive NatWest Group as a sustainable business generating
long-term value for stakeholders. We have continued to benefit
from a broad range of internal and external stakeholder
perspectives, to better understand how NatWest Group’s
actions are supporting our customers, colleagues and society.
I would like to take this opportunity to thank everyone who
has contributed to the Committee’s activities during 2022 and
throughout my tenure as Committee Chair, including my fellow
directors, attendees, and presenters, for their commitment
and dedication.
Mike Rogers
Chair of the Group Sustainable Banking Committee
16 February 2023
Letter from Mike Rogers,
Chair of the Group Sustainable Banking
Committee
‘This year our agendas and discussions have
reflected the challenging external environment
and how it is impacting our stakeholders as well
as our sustainable business model.’
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Below are the key discussion points and outcomes for 2022.
Theme
Principal areas of Committee focus
Outcomes
Climate
and broader
environmental
progress
The Committee discussed climate
change action and progress across the
broader environmental agenda. This
included updates on the challenge faced,
new initiatives, carbon measurement,
and a detailed discussion on climate
transition sector plans. The Committee
welcomed representatives from an
external asset management firm to
share their views on NatWest Group’s
climate and ESG progress and to help
promote investor voices in the boardroom.
The Committee reviewed NatWest
Group’s Environmental, Social and
Governance rating performance and
key themes arising in relation to this.
The Committee considered steps
being taken and analysis of the current
position on decarbonising the bank’s
supply chain to support efforts to
achieve NatWest Group’s net zero
ambition in relation to its own
operations. The work emphasised
how purpose is embedded in NatWest
Group’s whole eco system. Further
updates will be provided as
implementation continues.
Discussion and challenge focused on:
Decision-making: We discussed management governance
and the role of the Climate Executive Steering Group and
Reputational Risk Committees in considering challenging
decisions. In the context of carbon measurement, it was
acknowledged that the process of systematically
transforming the organisation will take time;
Assurance: We discussed how we as the Board can get
comfortable with the underlying data supporting the external
disclosure and the assurance activity underway with NatWest
Group’s external auditors;
Prioritisation & opportunities: We learned more about the
sectoral interdependencies and interconnected actions/
opportunities from the management teams involved. The
emerging commercial opportunities are also something to
factor into our future Board strategy sessions;
Policy influencing: Following on from an action raised by the
Committee, management presented their policy influencing plan
which focused on home energy given the particular challenges
felt in that sector.
The Committee also sought further detail on sector plan
progress ahead of Board discussion and an ad hoc meeting
was arranged to address this.
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Corporate governance
continued
Theme
Principal areas of Committee focus
Outcomes
Customer
experience
The Committee considered actions
being taken by management to improve
customer service and experience across
key customer segments. Committee
discussion focused on vulnerable
customers and problem debt in
response to the economic environment
and provided an important customer
and colleague listening opportunity, as
well as a chance to get into the detail
on some experimental work.
The Committee had a spotlight session
on customer journey improvements
stemming from complaints data
analysis assessed at the Voice of
the Customer forum.
The Committee also received the annual
Internal Audit Behavioural risk review.
This provided an overview of the
work of the team during the year to
understand customer behaviours and
outcomes quantitatively, highlighting
the good progress made in remediating
issues and opportunities to enhance
understanding and evidencing.
The Committee agreed that it supported the approach to
customer journeys, and explored scaling opportunities and the
associated challenges.
In the context of the cost-of-living crisis, we were joined by the
frontline Financial Health & Support telephony team to listen to real
customer calls. Two key challenges discussed with the Financial
Health & Support teams were supporting colleagues’ mental health
and responding to the growing issue of supporting vulnerable
customers. The Committee requested further detail on NatWest
Group’s vulnerable customer strategy, acknowledging the
increasing number of customers deemed vulnerable. This became
part of wider Board and Executive discussion on Consumer Duty
and ensuring that NatWest Group has a sustainable strategy as
a relationship bank in a digital world for all customers.
Enterprise
The Committee received updates on
how the business supports NatWest
Group’s ambitions in relation to
Enterprise. Progress and future plans
for Enterprise were reported to the
Committee, including a spotlight on
the partnership with Aston University
to develop impact-based reporting
measures. External insight was also
provided from Martin McTague,
Federation of Small Businesses.
The Committee discussed both the growth opportunity and
challenges in relation to NatWest Group’s Enterprise ambitions.
The Committee noted the innovative approach presented in
relation to measuring impact, which would provide robust analysis
and metrics upon which stakeholders could measure NatWest
Group. The Committee discussed the challenges around building
customer confidence during challenging financial times in the
small and medium-sized enterprises market and how partnerships
could be used to provide layered support for customers in these
circumstances. The Committee encouraged management to
focus on how NatWest Group can leverage its products and
communicate with customers in an impactful way as a
relationship bank in a digital world.
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Theme
Principal areas of Committee focus
Outcomes
People, culture
and learning
The Committee oversees action taken
by management to engage today’s
workforce and build the workforce for
tomorrow. It focused on work being
undertaken on talent acquisition; internal
mobility and reskilling; and strategic
workforce planning for the future. We
invited colleagues to join the meeting to
provide their experience of upskilling
and reskilling.
The Committee reviewed progress
of the cultural change to building a
purpose-led bank through consideration
of our colleague survey results and
workforce policies and practices,
including how our values and purpose
are at the centre of our approach
to support long term, sustainable
success and driving a diverse and
inclusive workforce.
The session considered the strategic future for the workforce at a
macro level and highlighted the scale and criticality of the people
transformation for the organisation in the next three to five years.
The changing nature of the mindset and skills of the workforce of
the future was discussed. Challenges of attracting talent, recruiting
at speed, retaining colleagues and reskilling were all considered.
The Committee noted the commitment to supporting colleagues
through internal mobility and reskilling and developing the talent
pipeline and discussed the scale of the ambition. The Committee
requested further detail on the shape and size of programmes in
future and noted the inherent risk of dilution of experience and
knowledge whilst retaining the organisation’s culture as a result of
the changing workforce. Strategic workforce plans for the future
were outlined and will be considered again at a future meeting
once further evolved.
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Theme
Principal areas of Committee focus
Outcomes
Conduct and
ethics
In support of the Committee’s
responsibilities to challenge
management on ensuring decisions are
purpose-led, the Committee’s session
on conduct and ethics focused on the
important area of financial wellbeing
and work across Retail to support the
financial health of customers. Updates
on previous Committee discussions on
improving the Financial Health Check,
branch strategy and branch culture
were provided. We were joined by
Caroline Siarkiewicz (CEO, Money and
Pension Services (MaPS)), who provided
external insight and an overview of the
MaPS UK strategy for financial wellbeing
and current demand and usage levels
as a result of macro events such as
cost of living pressures.
SBC considered NatWest Group’s
updated Human Rights Position
Statement and Modern Slavery and
Human Trafficking Statement and
recommended them to Board for
approval. The Committee was
provided with a comprehensive
update on progress on Human Rights.
Financial wellbeing: The session provided the Committee with a
comprehensive update on key activities and actions underway
to advance NatWest Group’s approach to financial wellbeing.
This included discussion on the future vision of the financial
wellbeing proposition and roadmap to deliver, as well as how
our colleague, channel and product strategies will support
customer wellbeing. The Committee discussed how a more
advanced and personalised offering for customers could be
achieved through data and online and physical presence and
how potential conduct implications could be managed. The
importance of helping customers build lasting financial capability
habits and how NatWest Group’s tools could support this were
examined. External insight highlighted the significance of local
and regional collaboration and the Committee suggested
consideration be given to NatWest Group’s presence in regional
areas to support this. The Committee discussed the number of
bodies supporting financial wellbeing and how impact could be
scaled through a more coordinated approach.
A spotlight on mortgages was provided in the context of the
current environment, including the impact of interest rates and
end of fixed term rates and the Committee considered the
actions being taken to support customers.
Human Rights and Modern Slavery: Modern Slavery discussions
focused on supply chain and third party contract controls to
ensure NatWest Group’s principles are upheld by its suppliers.
The Committee noted the progress made in relation to human
rights and the challenges faced and actions being taken to drive
improvement. Reflecting on ESG benchmarks and ratings, the
Committee challenged whether more could be done to ensure
NatWest Group’s public disclosures reflect the work undertaken,
particularly in relation to social issues.
Corporate governance
continued
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Theme
Principal areas of Committee focus
Outcomes
Supporting
long-term value
creation
The Committee received a purpose
dashboard at each scheduled meeting
allowing it to monitor progress towards
our strategic purpose targets and
metrics. It had oversight of cost-of-living
metrics and actions being taken by
management to support our customers,
communities and colleagues.
The Committee also considered its role
in the performance and remuneration
process, agreeing it was appropriate for
it to continue to provide advice to the
Group Performance and Remuneration
Committee on customer, strategy and
people-related measures, advocating
for sustainable targets within the
incentive framework.
The Committee noted progress made
on the UN Principles for Responsible
Banking and the target setting
requirements, noting that most, but
not all, criteria were currently met.
The Committee sought improvements in the presentation of
the dashboard to improve clarity. It challenged whether targets
were sufficiently ambitious, progress on CMA rankings, and
the effectiveness of financial capability targets for improving
financial health.
The Committee found the costs of living dashboard a useful tool to
oversee NatWest Group’s position and monitor the actions being
taken. They discussed how customers were being supported in
relation to mortgages and future activities in development.
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Report of the Technology
and Innovation Committee
Dear Shareholder,
I am delighted to present my third report as Chair of the
Technology and Innovation Committee (the Committee or TIC).
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 throughout discussions. 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 on natwestgroup.com. These are reviewed annually
and approved by the NWG Board.
During 2022, the Committee has played an important role in
helping to support and challenge management plans to develop
sustainable relationships with our customers through technology
and innovation. Below is a summary of the themes and principal
areas of focus of the Committee during the year.
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
pages 86 to 89 of the Governance Report. As agreed, as part
of the 2021 Committee evaluation, an invitation to each TIC
meeting was extended to all Board members and a number
of Board Directors have attended meetings during the year.
The Committee is supported by management and the Group
CEO, Group CFO, Group Chief Information Officer (previously
the Chief Administration Officer), Group CRO, Director of
Strategy & Corporate Development and Chief Technology
Officer are all standing attendees. External insights were
provided through the updates provided by management
and through attendance by external guests.
The Committee held four scheduled meetings during 2021.
One meeting was convened virtually with three meetings held
in person.
Performance evaluation
The 2022 review of the Committee’s effectiveness was
undertaken internally. Key findings included a reduction in the
number of meetings to three longer meetings each year from
2023; the opportunity for management to make greater use
of the Committee as a sounding board; and consideration of
how the expertise of the Technology Advisory Board could be
leveraged more. It was agreed that these actions would be
addressed during 2023. The Committee continued to act in
accordance with its terms of reference throughout the year.
Conclusion
I am delighted to chair this Committee as it continues to support
the Board in an area core to the Group’s purpose to champion
potential, helping people, families, and businesses to thrive.
The Committee’s primary focus is on management plans
to leverage changes to future technology, the innovation
landscape and its impact on NatWest Group’s purpose to
ensure we remain relevant for the future and improve service
provided to the customers, colleagues and communities which
we serve.
I want to take the opportunity to thank the Committee
members and attendees for their continued commitment
during 2022.
Yasmin Jetha
Chair of the Technology & Innovation Committee
16 February 2023
Letter from Yasmin Jetha,
Chair of the Technology and Innovation Committee
‘The Committee has played an important
role in helping to support and challenge
management plans to develop sustainable
relationships with our customers through
technology and innovation.’
Corporate governance
continued
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Theme
Principal areas of Committee focus
Outcomes
Digitisation of
NatWest Group
to deliver
enhanced
customer value
The Committee has considered how
the modernisation of our technology
is helping us better address customer
needs, and improve the health and
resilience of our estate.
To support this area of focus the
Committee received an update on
modernising technology and progress
made by NatWest Group. In particular
on resolving legacy and complexity
issues in respect of the architecture,
allowing increased agility and
responsiveness to customer and
colleague needs. This included the
use of predictive modelling of
customer lifetime value.
The Committee also discussed
the evolution of open finance from a
response to a regulatory requirement
to focus on new products, services and
revenue streams which leverage the
modern architectural patterns used
within NatWest Group.
A spotlight on the use of the cloud,
including how NatWest Group leveraged
a variety of hosting environments; and
how this would drive competitive
advantage was considered.
Finally, an update on the data strategy
was provided.
Modernisation of the technology estate:
The Committee was keen to understand how NatWest Group was
positioned versus peers. The Committee queried how challenges
resulting from internal processes slowing progress on delivery for
customers and colleagues would be addressed and encouraged
strong linkage to important business services and customer
journeys to ensure customer centricity of design for new
architecture. A spotlight on a new depository services platform
within C&I, which would help protect investors and oversee fund
managers, was provided.
Open finance:
Management explained the approach to driving
increased commercialisation of open finance and the Committee
discussed the potential size of the opportunity together with how
initiatives could be used across the organisation.
Leveraging cloud:
The Committee discussed NatWest Group’s
position versus peer banks, with reference to a Gartner research
paper, and how this aligned with regulatory views on NatWest
Group’s position. Consideration was given to the potential impact
of the entry of large cloud service providers into financial services.
Data Strategy:
The update considered potential disruption to
NatWest Group’s income streams from big technology companies.
It also considered the purpose-led approach to the implementation
of the data strategy with firm guardrails established to ensure that
public trust was not eroded.
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Corporate governance
continued
Theme
Principal areas of Committee focus
Outcomes
Powered by
partnerships,
Ventures and
Innovation
The Committee focused on the culture
and use of new technology, innovation
and partnership, including how we
prioritise, partner and work.
This included an update on the Ventures
portfolio with deep dives on Mettle (our
digital banking proposition for small
businesses to combine their current
account with invoicing, payments and
bookkeeping capabilities) and Take
Payments formerly Tyl (merchant
acquiring) and PayIt (send and receive
payments); and a deep dive on NatWest
Group’s approach to partnerships.
Ventures:
Key areas of discussion included the progress made
on the growth ambitions for Take Payments and the launch of the
cloud based platform for Mettle. Lessons learned including the level
of talent attracted, support from the franchises and funding were
considered. Use of NatWest branding for new innovation activity
was discussed noting that this was in line with the decision to
merge innovation with main business activity.
Partnership update:
considered how partnerships were being
developed, were focused on genuine customer need, and were
carried out on a One Bank basis. The culture of partnership
working was considered and the Committee sought confirmation
that a One Bank approach was taken to prioritisation decisions and
allocation of seed funding. Useful external insights and commentary
on NatWest Group as a partner were provided by Tim Larder and
Dr Matt Wood from Amazon Web Services. The importance of
speed in moving from ideation to proof of concept was emphasised
and NatWest Group’s position versus peers in the UK was noted.
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Theme
Principal areas of Committee focus
Outcomes
Future Ready
The Committee sought to understand
the role NatWest Group can play in the
value chain and future financial services
to stay relevant to customers.
This included discussion of the use
of technology by the Security team
and potential future opportunities to
monetise NatWest Group’s services;
NatWest Group’s approach to digital
assets; and the evolving future
landscape and technology trends.
Security, Trust & Protection:
The Committee considered how
NatWest Group’s position as trusted data custodian could help
support customers from a security perspective, particularly
customer identity attribute sharing and opportunities to help reduce
levels of fraud across the industry. The challenges in progressing
initiatives, including the value of industry-wide solutions and legal
and regulatory hurdles was discussed. This is an area that will
continue to be kept under consideration and investment in future.
Digital Assets
: The outcome of pilot activity undertaken to test
NatWest Group’s appetite to offer digital currencies to a range of
customer groups was discussed and the reduced attractiveness
of digital currencies following external market developments was
noted. The potential broader future use of digital assets and digital
ledger technology would continue to be kept under review given
the potential impact in future periods.
Evolving landscape
: the evolving landscape was discussed
through consideration of five themes: digital, personal, embedded,
safe and secure and polarised. Key areas of discussion included the
evolution of AI capabilities and the importance of staying relevant
to customers. The Committee recognised the need for safety and
security of customer information and the opportunity to assist
with technology skills and education for vulnerable customers
as important considerations in NatWest Group’s response to the
evolving landscape. Following discussion, the Committee requested
future updates in respect of how the blurring of the physical and
digital worlds might impact financial services and what NatWest
Group’s response would be; and sight of NatWest Group’s
response to recent regulatory consultations regarding the impact
of big technology on Finance and a summary of the activity of
other regulators in respect of digital markets.
137
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STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Directors’ remuneration report
Contents
138
Chair’s introduction
142
Remuneration at a glance
144
Wider workforce remuneration and the directors’
remuneration policy
152
The Annual remuneration report
Dear Shareholder,
This is my first report as Chair of the Group Performance and
Remuneration Committee having succeeded Robert Gillespie
in September 2022. I would like to place on record my
sincere thanks to Robert for his considerable contribution to
remuneration practices at NatWest Group. Robert steered the
committee with great skill and determination through a period
of significant transition for the organisation. I have been a
member of the committee since April 2020 which has helped
to facilitate a smooth handover in our responsibilities.
Supporting our colleagues with the cost of living
I want to begin by acknowledging that, very understandably,
the cost-of-living crisis has been a great concern for many
of our customers and colleagues. As a committee, we have
discussed the impact of this situation at length and the ways
in which we can help colleagues through this difficult and
unsettling time. Our colleagues are at the heart of our purpose
and our aim has been to respond in a sensitive and transparent
way, as we have done throughout the COVID-19 pandemic.
As part of the process, we dedicated time to understand the
concerns of individuals across the organisation. I have been
particularly close to this in the role I held as Chair of the Colleague
Advisory Panel. This has given me a deep understanding of our
wider workforce practices and how colleagues feel about working
for NatWest Group. Our approach to remuneration is that
colleagues must be paid fairly for the role they perform
and in ways that support our values and culture.
Support for colleagues
over the last 12 months
April 2022
– scheduled annual salary review
3.6% average increase across our global workforce,
our largest investment in pay for over five years.
Majority of our most junior UK colleagues received
at least 4% with 38% receiving 5% or more.
September 2022
– additional targeted action
c.22,000 of our lowest-paid colleagues globally received
a further permanent pay rise.
UK colleagues earning £32,000 or less received a 4%
salary increase and we increased our salary ranges by
4%. This resulted in an average increase of £1,000 for
impacted colleagues.
Our investment in fixed pay in April and September
2022 combined was £115 million per annum, an
increase of 85% on 2021.
December 2022
– further support announced
A one-off cash payment in January 2023 to
approximately 60,000 colleagues, worth £1,000 for
UK colleagues.
From April 2023, nearly 90% of our junior UK colleagues
(A and B grades) covered by our negotiated pay
approach will receive a salary increase of at least 7%,
and almost two thirds will receive 8% or more, on top
of the £1,000 payment in January.
Broad parts of the UK workforce, including A to C
grade colleagues, will receive salary increases of
at least £2,000 and salary ranges have also been
improved by 6% or more since September 2022.
This support is in addition to the significant investment
in colleagues’ learning, development and wellbeing.
Letter from Lena Wilson, CBE
Chair of the Group Performance
and Remuneration Committee
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| 2022 Annual Report and Accounts
138
Following an extensive data-led review of pay across the
organisation, a permanent uplift to base pay of 4% was agreed
to support our lower paid colleagues from September 2022.
This targeted action was made in consultation with our
employee representative bodies and welcomed by many,
and was intended to help those colleagues most likely to be
affected by the sudden spike in inflation. However, I know
that cost-of-living pressures have intensified since then and
are being felt broadly across the workforce.
We have sought to build on this action as part of our year-end
pay decisions for 2022. In the next stage of our support, we
made a one-off cash payment to around 60,000 colleagues
(more than 95% of the workforce) in January 2023. We also
announced significant salary increases to take place from
April 2023 for a broad range of colleagues.
If we look at the year-on-year position, a junior colleague in the
UK will typically have received salary uplifts of 4% in both April
and September 2022, a one-off payment of £1,000 in January
2023, with a further salary increase of c.7% to come in April
2023. In total this equates to a c.15% salary increase for most
A and B grade colleagues. I believe this is a clear demonstration
of our determination to invest in colleagues’ pay. The lowest
starting salary will also rise to £22,000 on a full-time basis,
an increase of 16% since April 2022.
NatWest Group has been an accredited Living Wage employer
in the UK since 2014 and sets pay levels above the real living
wage (RLW) rates. We take a similar approach across our major
hubs outside the UK. Following the early announcement of the
new RLW rates in 2022, we agreed to immediately increase
pay for our colleagues and relevant suppliers ahead of the
May 2023 deadline.
In these current extraordinary circumstances, we know that
it is impossible to entirely insulate colleagues from inflationary
pressures. However, we believe the actions we have taken
will deliver a significantly improved and competitive level of
pay in all our markets. We engaged again with our employee
representative bodies and I am delighted that the latest
proposal was supported by their members in the ballot.
Our decisions aim to balance the current economic context and
managing our long-term cost base with business performance
and our need to pay fairly and retain critical market skills. It was
important that we recognised the squeeze in living standards
and the dedication of colleagues in delivering strong
performance during a turbulent year.
Other support for the wider workforce
Financial wellbeing is vitally important and colleagues are
supported with access to pension and protection products,
shopping discounts, support with budgeting and help with
managing debt. Over 20,000 colleagues contribute to Sharesave
each month. Sharesave is available to 97% of colleagues, with
participants across the UK, Ireland, India and Poland, and is
particularly popular with our more junior colleagues. It provides
an opportunity for colleagues to benefit from increases in the
NatWest Group share price with limited risk, encouraging
financial capability and aligning their interests with shareholders.
Another way that we champion the potential of colleagues is by
providing extensive development opportunities and dedicated
learning days. During 2022 we extended this to give each
colleague two days to learn new skills for the future. There
is also a comprehensive wellbeing programme, supporting
a range of mental health and financial health initiatives.
I am also very proud of our new Partner Leave policies,
promoting a shared approach to caring and helping growing
families to thrive. The policies introduce the same pay and leave
entitlements as local Maternity and Adoption Leave policies for
eligible fathers and partners to share the caring responsibilities.
Pay gap reporting
We are making good progress in building a diverse, equitable
and inclusive workplace and the committee reviews gender
and ethnicity pay gap metrics as part of the process. This is the
fifth year that we have published ethnicity pay gap information
on a voluntary basis. For the first time, we have disaggregated
our ethnicity pay gaps to compare Black, Asian, mixed and
multiple and minority ethnic average hourly pay to that of
White colleagues.
We are confident that our colleagues are paid fairly and
policies and processes are kept under review to make sure this
continues to be the case. You can find full details of our pay gap
reporting in the Strategic report and at natwestgroup.com.
How we assess performance
Our purpose-led strategic priorities are communicated to all
colleagues. The performance goals and measures agreed
for the executive directors flow through to the executive
management team, adjusted as appropriate to reflect individual
areas of responsibility. The remuneration construct agreed for
executive directors also applies to members of the NatWest
Group and NWH Executive Committees.
This alignment at senior level is continued with performance
goals and measures cascading further through the organisation,
providing consistency in approach across the workforce.
Performance against these goals and targets is directly linked to
performance ratings and variable pay decisions at an individual
level, and the business-level assessments are reflected in
performance adjustments to the bonus pool.
Performance highlights for 2022
In a difficult macroeconomic environment, NatWest Group
has demonstrated resilience and performed strongly in 2022.
Income has grown, reflecting increased lending in key areas and
the impact of base rate increases. In assessing the performance
of the executive directors, we made a downward adjustment for
the material changes in the base rate against our assumptions
for the year. The adjustment was made so that management
did not benefit from the element of performance that we
deemed to be outside their control. Our capital distribution
plan has continued to deliver good value for shareholders
and we are well placed to invest for growth and provide
the support our customers need.
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FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Directors’ remuneration report
continued
Under the new Policy, annual bonus awards, with formulaic,
weighted measures and purpose-led targets, are complemented
by RSP awards that support longer-term performance and
shareholder alignment. The Policy addresses our need for a
more market-facing and competitive pay construct that still
supports prudent risk management. The Board remains very
aware of the importance of recognising good performance
and the need to attract and retain highly talented colleagues.
Greater performance-related pay results in expected
compensation rising, with the increase being phased over two
years given this is a significant change. For 2022, the first year
of the Policy, expected compensation rose 10% for the CEO and
4% for the CFO. A further increase for performance year 2023,
the second year of the transition, will result in NatWest Group
moving closer to, but still below, the average expected
compensation levels paid by other major UK banks.
Strategic KPIs in annual
bonus awards for 2022
Further information
Financial (60%)
The performance
assessment against the
bonus targets for 2022
is summarised on page
142 and set out in full
on page 153.
Details of how
performance was
considered for the 2022
RSP awards can be
found on page 157.
Return on Tangible Equity
Income growth
Cost reduction
Medium-term capital target
Strategic
(1)
(35%)
Climate
Customer
Purpose, culture and people
Enterprise and capability
Personal (5%)
CEO and CFO performance
(1) ESG priorities are incentivised through the Climate, Purpose, culture and people,
and Enterprise and capability elements of the scorecard.
A risk modifier also applies, enabling risk performance to be
assessed and awards reduced, potentially to zero.
Remuneration outcomes for 2022
2022 was a strong year for the business and these results were
directly reflected in remuneration outcomes. In the first year of
the Policy, maximum bonus awards were limited to 85% of
salary and RSP awards were limited to 125% of salary. The
assessment of performance against the scorecard resulted
in proposed awards for the CEO and CFO of 67.76% and
64.26% of maximum opportunity respectively. The committee
considered this to be a fair reflection of an impressive
performance, noting that the majority of targets were met or
exceeded. While people and culture scores had deteriorated
slightly, this was expected in the current macro environment
and scores remain very strong compared to market norms.
Performance highlights
Income growth
26.15%
2021: 0.25%
Attributable profit
£3,340 million
2021: £2,950 million
RoTE
12.3%
2021: 9.4%
Climate and sustainable finance and funding
£24.5 billion
2021: £17.5 billion
Shareholder returns through dividends and
buybacks
£5.1 billion
2021: £3.8 billion
Bonus pool for the wider workforce
The bonus pool is based on a balanced range of strategically
important measures, including financial performance, customer
outcomes, colleague experience and diversity, risk and progress
against our climate and purpose ambitions. The bonus pool
was determined in the context of strong financial and capital
performance, with the distribution of £5.1 billion to shareholders
through buybacks and dividends. The committee agreed a
2022 bonus pool of £367.5 million for those colleagues who
are eligible to receive an award.
This is around 23% higher than the 2021 bonus pool, with the
increase largely the result of strong performance, an increase
in the number of bonus-eligible colleagues and the fact that last
year’s bonus pool was materially reduced to reflect the fine
imposed by the FCA on National Westminster Bank Plc in 2021
for past breaches of the Money Laundering Regulations 2007.
Remuneration policy for executive directors
We obtained approval for a new directors’ remuneration
policy (the Policy) at our 2022 AGM. The Board was delighted
with the strong level of support from shareholders, with around
93% of votes in favour. The final form of the Policy reflected
feedback received from shareholders including a preference
to reduce committee discretion in assessing performance.
Our previous Policy differed in a number of ways to traditional
practice, with no annual bonus and a unique long-term incentive
construct that delivered significantly reduced quantum compared
to peers. As disclosed in last year’s report, we considered
shareholder guidelines that normally expect an appropriate
discount, of at least 50%, to be applied when introducing
restricted share plan (RSP) awards compared to a traditional
LTIP. The committee was satisfied that the move to the RSP is
aligned with the spirit of the guidelines as it delivers more than
a 50% reduction when the RSP is compared to traditional LTIPs
envisaged by the guidance.
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140
Looking ahead
How we reward and support colleagues will remain under
the spotlight for some time, given the macroeconomic
headwinds and competitive market for the best talent.
We will continue to monitor the impact of the cost-of-living
crisis on the workforce and look to balance the needs of
all our stakeholders through our oversight of performance
and remuneration. Our approach is founded on rewarding
colleagues in a fair, sustainable and transparent way.
With this in mind, and to support the refreshed strategy
announced in February 2023 and new financial plan,
the committee has approved a new Sharing in Success
scheme to award colleagues NatWest Group shares.
The scheme is intended to recognise one bank behaviours,
drive a performance culture with purpose-led outcomes
and further align colleagues with our strategic direction.
Since 2017, all A grade and most B grade junior colleagues
have received fixed pay only which provides protection
from pay volatility. As our performance has improved, it
feels like the right time to recognise the contribution of
all colleagues to the bank’s success. The scheme will be
a welcome addition to our employee value proposition,
alongside broader policy enhancements, which will help
in light of market competition for talent.
Subject to performance criteria being met over 2023,
the first awards will be delivered to colleagues in NatWest
Group shares in 2024. Awards will have a maximum value
of £1,500 per colleague (adjusted for local salary levels).
All colleagues will be eligible under the scheme.
From my recent meetings with shareholders, I know
that aligning ESG measures with executive directors’
remuneration remains a priority area. It is vital that we
deliver on our climate and broader societal ambitions. We
will continue to use ESG performance metrics for variable
pay that are demanding, quantifiable and clearly linked to
our strategy.
We also discussed the UK Government’s proposal to
remove the bonus cap for UK banks, which is currently
subject to consultation. The cap limits variable pay to no
more than two times the level of fixed pay. NatWest Group
has operated within a one-to-one ratio of variable to fixed
pay since the regulations came into force in 2014.
The proposal is that, from performance year 2024, it will
be up to UK banks to set an appropriate ratio between
the fixed and variable components of total remuneration.
Over the next year, we will assess any impact for NatWest
Group and confirm details in our next report. Importantly,
the strict rules relating to deferral, delivery in shares, and
malus and clawback will all remain in place.
I hope this letter and the information that follows will
explain our approach to remuneration for 2022. I am very
grateful for the support received from our stakeholders
during this process and would also like to thank my fellow
committee members for their valuable contribution.
Lena Wilson, CBE
Chair of the Group Performance
and Remuneration Committee
16 February 2023
The committee also approved that RSP awards would be
granted at maximum as satisfactory performance had been
achieved over the year prior to award. The vesting of the RSP
awards will be subject to assessment against pre-determined
criteria that take into account whether sustainable performance
has been delivered over the three years after grant.
Long-term incentive (LTI) awards granted in 2020
LTI awards were granted to both executive directors in March
2020. Prior to the awards being granted to the CEO and CFO,
reductions of 22% and 27% respectively were applied to the
maximum award as a result of the pre-grant performance
assessment over 2019. In December 2022, we considered
whether anything had come to light since the grant which
would change our original view of performance.
The outcome of the pre-vest assessment was that there had
been no material deterioration in financial, customer, risk and
culture performance since grant. Therefore, a sustainable level
of performance had been achieved and no further adjustments
were necessary under the pre-vest test.
2020 LTI shares
Maximum
Granted
Due to vest
Alison Rose
1,131,488
881,679
881,679
Katie Murray
881,679
646,565
646,565
The awards were granted at a time when the true impact of
COVID-19 was just beginning to emerge. The committee has
considered whether the vesting of these awards could result
in a potential windfall gain. Using the methodology that we
disclosed in our 2020 Directors’ remuneration report, we looked
at a range of factors including the LTI grant price against pre
COVID-19 levels, the relative share price performance of
NatWest Group and waivers and reductions applied to the
executive directors’ pay in the pre-vest period. The committee
was satisfied that, taking all the relevant circumstances into
account, no further adjustment for windfall gains was required.
Further details on the performance and windfall gains
assessment can be found on page 156.
Implementation of the Policy for 2023
In December 2022, we also approved salary increases for the
executive directors at 3%, which is less than half of the average
salary increase for the global workforce at 6.4%. The increases
will apply from April 2023. As the transition period for the Policy
has now ended, the maximum bonus opportunity for executive
directors in 2023 will be 100% of salary and maximum RSP
awards will be 150% of salary. The committee reviewed the
2023 performance measures for annual bonus awards and the
underpin criteria for RSP awards, as detailed later in this report,
which continue to align with our purpose-led strategy.
141
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FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Remuneration at a glance
Remuneration at a glance
4,262
1,403
477
2,382
2,382
1,403
954
2,382
2,104
954
2,382
1,395
643
2,428
2,178
643
2,428
2,382
4,739
5,440
4,466
5,249
2,914
956
325
1,633
1,633
956
650
1,633
1,434
650
1,633
951
416
1,628
1,597
416
1,628
1,633
3,239
3,717
2,995
3,641
Pay
opportunity
in first year
of Policy
Pay
outcomes
Maximum
Minimum
On-target
Awarded for
2022
Single figure
2022
Maximum
RSP 50%
share price increase
Fixed pay
Annual bonus
RSP award
2020 LTI
Executive director remuneration outcomes (£000’s)
Alison Rose
Katie Murray
(1)
The charts above show pay opportunity for the first year of the Policy together with two pay outcomes for 2022. On-target opportunity is based on annual bonus awards at 50% of
maximum and RSP awards vesting at 100% of maximum. The maximum opportunity is also shown together with the impact of a 50% increase in the share price for RSP awards
over the period from grant to vest, in line with disclosure requirements.
(2)
The fixed pay awarded differs slightly from that under the Policy opportunity for 2022 due to salary increases applying part way through the year and the inclusion of some benefits
where the amounts are not known until year end. Full details of benefits paid for 2022 can be found in the single figure table later in this report. The maximum bonus and RSP
outcomes are based on salary earned during the year, which is slightly lower than the Policy opportunity due to the salary change applying part way through the year.
Pay awarded to the executive directors for 2022, including fixed pay, annual bonus and RSP is broadly in line with that expected
under the first year of the Policy, with strong performance resulting in above target annual bonus outcomes. The single figure of
remuneration, as set out on page 152, includes fixed pay and annual bonus for 2022 along with the estimated vesting value of
the LTI award granted in 2020 under the previous Policy. Therefore it is a combination of the new and the old Policy.
Annual bonus scorecard outcome for 2022
Annual bonus measures
Overall
Weighting
Minimum
On target
Maximum
Weighted
outcome
Financial (60%)
Go-forward group return measure
30%
26.44%
Underlying income growth
10%
9.21%
Cost reduction
10%
4.74%
CET1 ratio post distributions
10%
5.00%
Strategic (35%)
Reduction in carbon emissions vs 2019 baseline
2%
2.00%
Climate and sustainable finance in 2022
4%
4.00%
Publish initial Climate transition plan
4%
2.00%
Customer scores
10%
5.25%
Purpose score
3.33%
1.53%
Culture score
3.33%
1.53%
Percentage of females in top three layers
1.67%
0.84%
Percentage of colleagues from ethnic minority
backgrounds in top four layers
1.67%
0.62%
Supporting diverse enterprise
1.25%
1.10%
Encouraging youth participation in enterprise
1.25%
1.25%
Encouraging customers to save at least £100
1.25%
0.00%
Financial capability interactions delivered
1.25%
1.25%
Personal (5%)
Discretionary assessment at year end for both
executive directors
5%
Strong contribution by the CFO
was fully recognised in the
scorecard outcomes above.
Progress by the CEO on One
Bank transformation, UBIDAC
exit, the Commercial & Institutional
segment, the climate agenda and
strengthening relationships with
external stakeholders led to
4.0% outcome under the
CEO’s personal measures.
4.0% (CEO)
0% (CFO)
(1)
Risk modifier
Downward risk modifier of
3%
applied for
the CEO and
2.5%
for the CFO to reflect risk
performance against core goals, balanced by
strong leadership behaviour
Total scorecard
outcome post risk modifier
67.76% (CEO)
64.26% (CFO)
(1)
The CFO delivered strong performance against the targets set for the year, as reflected in the core scorecard outcome. For the personal measures, the committee considered that
the key areas of strength were appropriately reflected in the financial and strategic outcomes above and opted not to make any additional award to the CFO for 2022.
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142
Fixed
share
allowance
Annual
bonus
Pension
& benefits
(*)
Shareholding requirements for executive directors as at 31 December 2022
Payments for 2022 will be delivered over eight years
RSP pre-grant performance assessment for 2022
Basis of assessment
RSP awards are granted provided
performance has been satisfactory,
based on our internal performance
management ratings scale (1-5).
A rating of three or above will
normally result in the RSP award
being granted at maximum.
Awards are delivered in
shares to align with long-term
performance and shareholders.
Outcome of pre-grant
assessment
The CEO and CFO received
ratings of four and three
respectively for 2022, meaning
performance goals were fully
achieved or exceeded and
behaviours were demonstrated
at the required level. All regulatory
responsibilities were also met. As a
result, RSP awards to be granted
at maximum.
RSP awards to be
granted in 2023
CEO – 125% of salary
CFO – 125% of salary
Awards will vest in 2026 subject
to performance against underpin
criteria over the three-year period.
See page 157 for further details
of the pre-grant and pre-vest
performance assessments.
Maximum
opportunity
for 2022
Awarded for 2022
CEO: £643,059
(67.76% of maximum)
CFO: £415,802
(64.26% of maximum)
85% of
salary
CEO: £1,116,500
CFO: £761,250
100% of
salary
CEO: £193,793
CFO: £105,650
10% of
salary
CEO: £1,116,500
CFO: £761,250
Malus and clawback provisions apply to
annual bonus and RSP awards for up
to 10 years post grant
Nearly two-thirds of expected
remuneration is delivered in shares and
subject to long holding periods
Salary
Structure and timing of payments
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
(*)
Pension aligned with wider workforce rate at 10% of salary. Value shown also includes standard benefit funding as well as benefits detailed in the single figure of remuneration table.
Pension,
standard
benefits
and salary
paid
in cash
Paid in shares
with the shares released in equal amounts
between 2023 and 2027
RSP
CEO: £1,395,625
(maximum)
CFO: £951,563
(maximum)
125% of
salary
Paid in shares
Subject to underpin criteria being met, RSP awards vest
in equal amounts between 2026 and 2030, with a
12-month retention period after each vesting
Paid 50:50 cash and
shares
(12-month
retention period
for shares)
0
100
200
300
400
500
600
700
800
900
1,000
Alison Rose
Katie Murray
300%
£1.1m
398%
220%
603%
Values as percentage
of salary
Shares held outright and performance-assessed unvested share awards that count
towards requirement
Unvested share awards still subject to performance assessment
Shareholding requirement
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GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Wider workforce remuneration and the directors’ remuneration policy
How we align wider workforce and executive directors’ remuneration
We have invested significantly in colleague
(1)
pay throughout 2022, together with material salary increases and a one-off payment in
2023 to help large parts of the workforce with the cost-of-living crisis. Most of this investment is targeted towards our more junior
roles as part of our commitment to deliver fair levels of pay throughout the organisation.
The remuneration policy supports a culture where individuals are rewarded for sustained performance and demonstrating the right
behaviours. The same principles apply to everyone, adjusted to comply with local requirements. The principles 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 peers 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.
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.
UK colleagues receive
pension funding at
10% of base salary, the
same rate as executive
directors. Rates in other
locations reflect local
market practice.
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 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.
We reward individuals
for delivering superior
performance in line
with risk appetite.
The bonus pool is based
on a 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.
Encourages sustainable
long-term performance.
Awards are delivered
entirely in shares to
align with shareholders.
Checks take place before
grant and again after
three years to ensure
sustained performance
has been achieved.
Awards are paid out
over eight years in total
to encourage long-term
thinking when making
decisions.
RSP participants are also
subject to shareholding
requirements.
Fixed pay
Variable pay
Base salary
Pension & benefit
funding
+
Role-based
allowances
Annual bonus
RSP awards
+
Benefit funding
applies to certain jobs
Provided to some
Material Risk Takers
(MRTs) only
Mainly manager grade
and above including
executive directors.
Executive directors
and members of senior
Executive Committees.
As set out on page 141, from 2023 we will launch our new Sharing in Success scheme, to recognise the contribution of all colleagues
to our success and the achievement of our purpose-led strategic goals.
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 shareholding requirements.
Wider workforce remuneration
(1) Colleagues means all employees and, in some instances, other members of the wider workforce (including contractors and agency workers).
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Regular engagement
A colleague opinion survey (Our View) allows people to
have a say on what it feels like to work at NatWest Group.
Over 48,000 (82%) of our colleagues took part in the
latest survey, one of our highest response rates in the last
10 years. We also benchmark our performance against
financial services and global high performance norms.
Regular question and answer sessions take place between
colleagues and senior executives throughout the year.
Feedback from colleagues forms part of the purpose,
culture and people measures that impact pay.
We also consult with our employee representative bodies
on remuneration at relevant points during the year.
Colleague Advisory Panel (CAP)
The CAP helps us to strengthen the colleague voice in the
Boardroom. It allows colleagues to engage directly with senior
management and the Board on topics that are important to
them. The CAP is chaired by one of our non-executive directors
and membership of the panel was refreshed in 2022. It
comprises a random selection of 28 colleagues who are
self-nominated or part of an employee representative body.
After each meeting, the Board receives a summary and a
follow-up call is held so that members can hear how their
views were shared and what happened as a result. The forum
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 May 2022, a meeting was held with members in order to:
increase the CAP’s understanding of our approach to
executive pay and its link to our ESG priorities and our
purpose; and
gather the CAP’s views on our approach to wider workforce
and executive remuneration.
Members asked thoughtful questions on a wide range of
pay-related matters. There was a discussion on the new Policy
for executive directors being more aligned to market practice.
The discussion also touched on the merits of increasing
executive pay in the context of higher household bills. It was
explained that the changes moved remuneration for executive
directors closer to, but still below, the average paid by their
peers. Members were also reminded that, at a previous session,
some had asked whether pay for the CEO was enough.
Colleagues are remunerated according to our Fair Pay Charter
and consistent reward principles. Across the workforce we
take into account the job market, company and individual
performance as well as changes in the external environment.
The cost-of-living crisis was, understandably, one of the main
themes during the discussion. The CAP acknowledged that
the increase in the cost of living was not the bank’s sole
responsibility but noted that front-line colleagues in particular
were feeling the impact. It was confirmed that the issue was
high on the Executive Committee’s agenda, and action was
subsequently taken in September by providing a permanent
salary increase for c.22,000 of our lowest-paid colleagues.
Another suggestion from members was that the benefit
platform could be reviewed in light of the economic conditions
and a number of enhancements were made to the offering in
the second half of the year, including reducing the excess
payable on some policies.
Listening Strategy
We listen to colleagues and use the insight we gain to attract, engage and retain the talent we
need for the future.
Our Colleague
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ADDITIONAL INFORMATION
Employee Value Proposition
New partner leave
and menopause
support
We offer a market-leading approach to partner leave,
increasing the time that partners can spend with their
new child. The policies introduce the same pay and leave
entitlements as local Maternity and Adoption Leave
policies for eligible fathers and partners to share the
caring responsibilities.
This ultimately champions the potential of both parents
and promotes gender equality in the workplace.
The menopause is such an important topic and, working
with Peppy Health, we launched a brand new digital
product providing colleagues and
their partners with online support
and access to specialist clinicians.
Over 1,000 of our colleagues
downloaded the app within
the first few weeks.
Mental Health
We were delighted to partner with
Just Ask A Question (JAAQ), a new
mental health and wellbeing social
media platform that will allow us to
speak with colleagues in a new way.
Dedicated learning
and volunteering
days
We give all colleagues two days each
year so they can develop their skills,
be future ready and have opportunities
to progress. 96% of colleagues have
accessed the NatWest Group
Academy since its launch.
Colleagues also receive three volunteering days each
year, an opportunity for them to help causes they care
about and support local communities.
Fair Pay
Accredited
Living
Wage
employer in the UK since 2014
and we set our pay levels above the real living wage
(RLW) rates. We take a similar approach across our major
hubs outside the UK.
Following the early announcement of the new RLW rates
in 2022, we agreed to immediately increase pay for our
colleagues and relevant suppliers.
Wider workforce interventions
and support in 2022
Cost-of-living crisis
c.£115 million
annualised spend on fixed pay
increases in 2022, which included
a further permanent increase in September for around
22,000 of our lowest-paid colleagues.
On top of the investment above, a one-off cash payment
was made to c.60,000 colleagues in January 2023 and
there will be significant salary increases from April 2023,
with broad parts of the UK workforce to receive at least
£2,000. The majority of colleagues at our two most junior
grades in the UK will receive a salary increase of at least
7% in April 2023 in addition to the £1,000 payment in
January. Salary ranges have been increased by 6% or
more and the lowest starting salary will rise to £22,000
(pro rata), an uplift of 16% since April 2022.
Wider workforce remuneration and the directors’ remuneration policy
continued
Financial
Wellbeing
hub
We have provided colleagues with comprehensive
financial wellbeing support including access to pension
and protection products as well as colleague discounts,
support with budgeting and planning, and help with
managing debt and financial abuse.
We upgraded our benefits platform in 2022 and
negotiated a reduction on the excess payable on
some insurance products.
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Approves the
remuneration policy principles
, which are
applied consistently across NatWest Group, and reviews
the policy’s implementation. The committee is supported by
Subsidiary Performance and Remuneration Committees
which review whether the policies and practices are
appropriate at the respective legal entity level.
Reviews and
approves share plan
offerings
for colleagues. In 2022,
Sharesave was offered in the UK,
Poland and India, encouraging
colleagues to think about their
financial wellbeing with an option
to buy NatWest Group shares.
Considers a report on
how pay has been distributed
across the workforce during the year. The report includes
analysis of performance ratings by grade and diversity
categories and there are checks in place to ensure
that decisions are made fairly.
Reviews the
annual spend on fixed
pay
(approximately half of the
workforce receive fixed pay only).
We have targeted recent increases
towards our most junior colleagues,
areas where specialist skills are
required leading to high attrition
rates and those lowest in their
salary range.
Approves the bonus pool
for
bonus-eligible colleagues across
the wider workforce. The bonus
pool is determined after considering
performance against a balanced
scorecard of strategically-important
measures.
How the committee oversees wider workforce remuneration
Each year, the committee:
Aligning remuneration with our culture
In determining performance outcomes, we consider both the
achievements made and how they have been delivered. Our
Code of Conduct sets out clear expectations of appropriate
behavioural standards, supported by Our Values which guide
colleagues in doing the right thing. In 2022, over 11,000
colleagues, customers and community partners helped to
co-create our refreshed values to reflect our purpose.
Each role has defined behaviours set out in our Critical People
Capabilities which directly link to our purpose and values
and are used in performance management. If a colleague’s
behaviour falls below these expectations, this will be reflected
in their performance rating, fixed pay progression and variable
pay decisions (where their role is eligible to receive variable
pay). The governance of culture is clearly laid out with specific
senior manager roles having defined accountabilities which
are reflected in their performance and pay decisions.
Creating a diverse, equitable and inclusive workplace is integral
to fulfilling our purpose. It enables us to work together to
achieve great things with our colleagues, communities and
customers. Performance measures to support progress in this
area affect the pay of executive directors, senior management
and other bonus-eligible colleagues.
We have a target to have full gender balance in our CEO-3 and
above global roles by 2030. At 31 December 2022, we had, on
aggregate, 41% women in our top three layers
(1)
, an increase of
3% since 31 December 2021. This represents an increase of
12% since targets were introduced in 2015.
Introduced in 2018, our ethnicity target is to have 14% of
colleagues from an ethnic minority background in CEO-4 and
above positions in the UK by 2025. At 31 December 2022,
of 82% of colleagues who disclosed their ethnicity, we have
an aggregate 11% of colleagues from an ethnic minority
background in our CEO-4 and above positions. This
represents a 3% increase since targets were introduced
and remains consistent from 2021.
Pay equality, including neutrality in respect of protected
characteristics such as sex and race is a core feature of
our approach, to support equal pay for equal work.
Further information on our workforce approach
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 ’Diversity, equity and inclusion’
section of the Strategic Report and at natwestgroup.com.
You can also find the CEO-to-employee pay ratios for 2022
later in this report.
The ‘Our Colleagues’ section of the Strategic report and our
ESG Disclosures Report on natwestgroup.com set out further
information on how we are helping colleagues to thrive and
realise their potential, including providing fair pay, supporting
their learning and wellbeing, and creating a diverse, equitable
and inclusive culture.
(1) See footnote (7) on page 154 for further information.
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ADDITIONAL INFORMATION
The Policy was approved by shareholders at the AGM on 28 April 2022 and will apply until the 2025 AGM unless changes are
required. There are no changes requiring shareholder approval at this time. A summary of the Policy is set out below together with
how the Policy supports alignment with Provision 40 of the UK Corporate Governance Code (the Code). The full Policy can be found
under the Governance section of natwestgroup.com.
Purpose and link
to strategy
Operation
Maximum opportunity
Alignment with the Code
Base salary
Providing fair levels
of base salary supports
the recruitment and
retention of high-calibre
executives to develop
and deliver strategic
priorities.
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 and peer practice.
Salaries will be increased by
3% from 1 April 2023. See the
implementation of the Policy for
2023 on page 159 for details.
Any salary increases 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 the Policy.
Risk
Base salary is set at a competitive
level which means there is
less reliance on variable pay.
This helps to discourage
excessive risk-taking.
Alignment with culture
Base salary increases generally
aligned to, or lower than, the
average increase for the
wider UK workforce.
Fixed share
allowance
Additional fixed
pay that reflects the
skills and experience
required as well
as the complexities
and responsibilities
of the role.
A fixed allowance paid entirely in
shares. Individuals receive shares
that vest immediately subject to
any deductions for tax purposes.
Shares are released on a
pro-rata basis over five years
from the date of each award.
The directors are entitled to any
dividends paid on the shares.
An award of shares with an
annual value of up to 100%
of base salary at the time
of award.
Risk
The fixed share allowance
further supports the delivery of
a balanced remuneration policy,
with a suitable mix of fixed and
variable pay, as well as creating
alignment with the experience
of shareholders, given it is paid
entirely in shares.
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.
Travel assistance is provided
in connection with company
business, including the use
of a car and driver. Security
arrangements may be put in
place where that is deemed
appropriate. NatWest Group
will meet the cost of any
tax due on these benefits.
A set level of funding
for standard benefits
(currently £26,250 per
annum). We disclose the total
value of benefits provided
each year in the Annual
remuneration report.
The maximum value of
benefits will depend on the
type of benefit and the cost of
providing it, which will vary
according to market rates.
Proportionality
A competitive benefits offering,
which can be tailored to individual
circumstances, together with
broader support for executive
directors to assist them in
carrying out their duties.
Pension
Encouraging planning
for retirement and
long-term savings.
A monthly pension allowance
paid in cash, 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
The pension allowance rate is
the same as that applicable to
the vast majority of the UK
workforce (currently 10%
of base salary).
Alignment with culture
Reflecting best practice under the
Code, pension rates for executive
directors are aligned with the rate
offered to the wider workforce.
Wider workforce remuneration and the directors’ remuneration policy
continued
Summary of the Policy
for executive directors
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Purpose and link
to strategy
Operation
Maximum opportunity
Alignment with the Code
Annual bonus
Supporting a culture
where individuals are
rewarded for the
delivery of superior
performance, with
measures and targets
reflecting NatWest
Group’s strategic
priorities and purpose.
Performance is
assessed based on a
range of financial and
non-financial measures
that encourage
long-term value
creation.
Awards are subject
to malus and clawback
adjustments to support
long-term decision-
making.
financial measures account for
between 50% and 60% of the
annual bonus opportunity.
non-financial measures account
for at least 30% and personal
measures may be used up to a
maximum of 10% of the scorecard.
awards will be delivered 50% in
shares and 50% in cash.
awards will be deferred in
combination with RSP awards
to meet regulatory requirements.
a post-vesting retention period will
apply to the amount delivered in
shares (currently 12 months).
malus provisions apply prior to
vesting and clawback applies for
seven (and potentially up to ten)
years from the date of award.
Bonus awards will be granted
up to a maximum value of
100% of base salary. The value
of awards can also reflect
a discount for long-term
deferral, in line with
regulatory guidelines.
The level of the award
can vary between 10%
for threshold performance
and 100% for maximum
performance. Target
performance will pay
out at 50% of maximum.
You can find the proposed
performance measures and
weightings for the 2023
financial year on page 159.
Clarity
There is clarity on how
performance will be assessed
and the expected behaviours.
We provide transparency
through detailed disclosure
and engage with
shareholders as well as the
workforce on our approach
to executive pay.
Simplicity
Most of the remuneration
for executive directors is
share-based and subject
to deferral and retention
requirements, which creates
simple and significant
alignment with our
shareholders.
Risk
We take risk into account
at various stages of the
performance assessment
process, with underpins
and malus and clawback
provisions to adjust awards
if necessary.
Predictability
Scenarios of the possible
rewards to executive
directors under the Policy for
2022 are set out on page
142. RSP award levels are
intended to be more
predictable and linked to
long-term performance,
helping to support prudent
risk management.
Proportionality
Variable pay cannot be
awarded above the level of
fixed pay. We believe this is a
restrained and proportionate
approach to executive
remuneration.
Alignment to culture
Variable pay is subject to
the delivery of sustainable
performance and progress
against our purpose-led
strategic goals. Payments
are made over many years
to encourage long-term
thinking. Shareholding
requirements further align
the interests of executive
directors with the returns
to shareholders.
RSP awards
Supporting sustainable
performance over a
multi-year period.
Awards are delivered
entirely in shares over
many years to create
simple and effective
alignment with
shareholders over
the long term.
Malus and clawback
provisions discourage
excessive risk-taking
and other inappropriate
behaviours.
an award will be granted provided
performance has been satisfactory
over the prior year.
after three years, performance
will be assessed against pre-
determined underpin criteria.
awards will vest in combination
with annual bonus awards to
meet regulatory requirements
for deferral (currently between
three to seven years after grant).
a post-vesting retention period
will apply (currently 12 months).
malus provisions apply prior to
vesting and clawback applies for
seven (and potentially up to ten)
years from the date of award.
the number of shares for RSP and
bonus awards may be calculated
using a price that is discounted to
reflect the absence of the right to
receive dividends or dividend
equivalents during the
vesting period.
RSP awards will be granted up
to a maximum value of 150%
of base salary. The value of
awards can also reflect a
discount for long-term
deferral, in line with
regulatory guidelines.
Subject to the underpin
criteria, the vesting level of
RSP awards can vary between
0% and 100% of the original
number of shares granted.
The expected vesting level
is 100% of maximum with
safeguards in place to
ensure no payments for
failure. See page 160 for
further information on RSP
awards to be granted for
the 2023 financial year.
Shareholding
requirements
Executive directors
must build and continue
to hold a significant
shareholding both
during and after
employment.
Shares and unvested awards count
on a net-of-tax basis towards the
requirement once any performance
assessment has taken place.
On leaving, shares must be held for a
period of two years and procedures
are in place to enforce the
requirement.
CEO – 500% of salary.
CFO – 300% of salary.
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ADDITIONAL INFORMATION
Wider workforce remuneration and the directors’ remuneration policy
continued
Other policy elements for Directors
Element
Operation
Recruitment policy
When recruiting new directors, the Policy aims to be competitive and to structure pay in line with
the framework applicable to current directors, recognising that some adjustment to quantum may be
necessary to secure the preferred candidate. A buy-out policy exists to replace awards forfeited or
payments foregone, which is in line with regulatory requirements.
Notice and termination
provisions
Under service contracts, NatWest Group or the executive director is required to give 12 months’ notice to
the other party to terminate the employment. There is discretion for NatWest Group to make a payment
in lieu of notice (based on salary only). The Chairman and the non-executive directors do not have notice
periods and no compensation will be paid in the event of termination, other than standard payments for
the period served up to the termination date.
Non-executive directors have letters of appointment instead of service contracts and are appointed
for three years initially. At the end of this term, a further three-year term may be agreed, and non-
executive directors may be invited to serve beyond six years, up to a maximum tenure of nine years.
The Chairman 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 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
Roisin Donnelly – 1 October 2022
Patrick Flynn – 1 June 2018
Morten Friis – 10 April 2014
(1)
Yasmin Jetha – 21 June 2017
Stuart Lewis – 1 April 2023
Mark Seligman – 1 April 2017
Lena Wilson – 1 January 2018
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. Any deferred annual 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. In good-leaver circumstances, individuals will be eligible to be considered for an
annual bonus award for their final year of employment.
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.
(1)
As explained in the Corporate governance report, the Board confirmed that Morten Friis should continue to serve on the Board and be considered as an independent non-executive
director until he steps down on 31 July 2023, notwithstanding that he will have served nine years and four months on the Board by that point.
Remuneration for the Chairman and non-executive directors
Purpose and link to
strategy
Operation
Maximum opportunity
Fees
Competitive fees
that reflect 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 can be paid in cash, shares or a combination of the
two. From 2023, a portion of fees will be used to purchase
shares under a new shareholding policy for the Chairman
and the non-executive directors. Further details are set out
as part of the Policy implementation on page 161.
The level of fees is reviewed regularly. Additional fees may
be paid for new Board Committees provided these are
not greater than fees payable for the existing Board
Committees. No variable pay is provided so that the
Chairman and non-executive directors can maintain
appropriate independence.
The rates for the year ahead are set out
in the Annual remuneration report.
Any increases to fees will not normally be
greater than the average inflation rate or
salary increases for the wider workforce.
Other than in exceptional circumstances,
fees will not increase by more than 15%
over the course of the Policy.
Benefits
Providing a level of
benefits in line with
market practice.
The Chairman and non-executive directors are entitled
to travel assistance in connection with company business
including the use of a car and driver. NatWest Group will
meet the cost of any tax due on the benefit. Other benefits
may be offered in line with market practice.
The Chairman is entitled to private medical cover and life
insurance cover provided the Board considers the costs to
be reasonable.
The value of the private medical and life
insurance cover for the Chairman, as
well as other benefits, will be in line with
market rates and disclosed in the Annual
remuneration report.
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Shareholder engagement outcomes
Every year we undertake an engagement programme
with major shareholders and other stakeholders before the
committee makes its final decisions on pay awards. In late 2022,
we met with a number of our institutional shareholders, UK
Government Investments, proxy advisors and the UK regulators
to discuss our approach to remuneration for the year.
The meetings were generally positive with the committee Chair
explaining our pay philosophy and no material concerns being
raised. Wider workforce initiatives was the predominant issue
raised, with investors and the proxy advisors interested to hear
how the cost-of-living crisis was expected to impact NatWest
Group’s approach to executive and wider workforce pay. The
committee Chair explained the steps being taken to support
the workforce at this time and confirmed that the Board takes
wider workforce engagement very seriously.
Other recurring topics in meetings included our treatment of
potential windfall gains, the measurement of bonus pool financial
performance, the use of ESG metrics in remuneration and the
retention and recruitment of talent. Investors also continued to
stress the importance of clear disclosures to assist their view of
our approach to pay.
In addition, we held two virtual shareholder events with
retail shareholders in 2022 in order to hear from the wider
shareholder base. During the events, shareholders raised
questions on staff retention, our response to the impact of
the cost-of-living crisis on our colleagues and the increase in
remuneration for the CEO under the new Policy. We are very
grateful that our stakeholders continue to take the time to
engage with us in an open and constructive way.
Adjusting remuneration in light of new information
An accountability review process allows NatWest Group to
respond where new information would change our variable
pay decisions made in previous years and/or the decisions to be
made in the current year. The process seeks to identify material
risk management issues, control weaknesses, policy breaches
and conduct failings, and enables commensurate ex-post risk
adjustments to be applied to variable pay.
Malus provisions allow us to reduce the amount of any unvested
variable pay awards, potentially to zero, prior to payment.
Clawback can be used to recover variable pay awards that
have already vested and we can also apply in-year bonus
reductions to adjust variable pay that would have otherwise
been awarded for the current year.
The circumstances in which we may make adjustments 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.
There is clear alignment between our ESG priorities
and the pay outcomes for executive directors. People
targets have featured in our strategic scorecard for over
ten years, evolving beyond employee engagement to
incorporate purpose, culture and diversity targets. Playing
an active role in the transition to a low-carbon economy is
a core part of our purpose and climate targets have been
part of our executive director scorecard since 2020. There
are also targets to build financial capability and support
equality of opportunity through diverse enterprise.
In a number of areas our ESG ambitions stretch over
several years. However, we are clear on the specific
measures and targets set for each year and publish these
externally. The committee and the Board reviews and
approves these annually to align with our latest strategic
focus areas. You can find further information on how
executive director performance measures align with
the five principles of a purpose-led business in our ESG
Disclosures Report, available on natwestgroup.com.
Turning to the wider workforce, the annual bonus pool
is based on a balanced scorecard of measures which
includes climate, enterprise, financial capability, purpose,
culture and people measures, broadly aligning with the
position for the executive directors. Allocation from the
pool depends on the performance of the business area
and the individual. This helps to provide a consistent
approach to ESG performance and its impact on
variable pay throughout the organisation.
Environmental, Social and
Governance (ESG) priorities
151
NatWest Group
| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Annual remuneration report
Single total figure of remuneration for executive directors for 2022 (audited)
Alison Rose
Katie Murray
2022
£000
2021
£000
2022
£000
2021
£000
Base salary
1,117
1,100
761
750
Fixed share allowance
(1)
1,117
1,100
761
750
Benefits
(2)
82
81
30
30
Pension
(3)
112
110
76
75
Total fixed remuneration
2,428
2,391
1,628
1,605
Annual bonus
(4)
643
n/a
416
n/a
Long-term incentive award
(5)
2,178
1,197
1,597
Total variable remuneration
2,821
1,197
2,013
Total remuneration
(6)
5,249
3,588
3,641
1,605
(1)
The fixed share allowance is based on 100% of salary and, as part of fixed remuneration, is not subject to any performance conditions.
(2)
Includes standard benefit funding at £26,250 per annum. In addition, Ms Rose received travel assistance in connection with company business (£39,542) and assistance with home
security (£16,351) for 2022. Ms Murray also received assistance with home security arrangements (£3,275) for 2022.
(3) The executive directors receive a monthly cash allowance and can choose to participate in the company’s defined contribution pension arrangements.
(4)
Annual bonus awards were introduced as part of the Policy approved by shareholders at the 2022 AGM. In determining bonus awards for 2022, the committee assessed
performance against financial, strategic and personal measures as set out below and on the next page.
(5)
The 2022 value relates to LTI awards granted in 2020. The committee assessed performance prior to vesting and also considered whether the outcome could represent a windfall
gain, as set out on pages 154 to 156. No discretion was exercised as a result of the share price changing over the performance period.
(6)
The increase in total remuneration for the CEO compared to 2021 is primarily driven by the inclusion of annual bonus, in line with the Policy, and a higher estimated vesting value of
the LTI award compared to last year. The CFO has annual bonus and the vesting of an LTI award included for the first time with no equivalent variable pay awards in 2021.
Annual bonus performance assessment for 2022
The committee considered performance against financial and strategic non-financial measures set to reflect our purpose-led strategy
as well as personal performance by the executive directors. Bonus awards are expected to be made at 50% of maximum provided
that target performance has been achieved. The outcome of the assessment against the measures and targets under the bonus
scorecard is set out in full on the next page.
The committee noted that the CEO had performed strongly over the year, which was evident from the bonus scorecard and
supported by other factors including positive share price movement and broker recommendations, indicating market confidence
in management’s actions. NatWest Group had remained open for mortgage business despite market volatility and the CEO had
continued to build a strong team in a difficult hiring environment as well as implementing well-judged cost-of-living initiatives. In terms
of personal measures, the committee recognised good progress on One Bank transformation, the exit of UBIDAC, standing up the
new Commercial & Institutional business segment, supporting the climate agenda and cementing relationships with our key partners.
The CFO was also considered to have delivered good overall performance with strong engagement with investors throughout the
year and her continued contribution to the long-term strategy and our investment cycle through to 2028. The committee noted that
good progress had been made on the Finance transformation programme as well as succession planning and building bench strength.
There had also been significant progress with our climate and purpose reporting framework.
The bonus scorecard takes into account the context in which performance was delivered. In assessing financial performance, a
downward adjustment was made for the material changes in the base rate against our assumptions for the year, as explained in the
footnotes to the scorecard. The committee also considered a downward risk modifier which enables risk performance to be assessed
and awards reduced, potentially to zero. Downward adjustments of 3% were applied for the CEO and 2.5% for the CFO to reflect risk
performance against core goals, balanced by strong leadership behaviours. The committee believed the final outcome reflected the
considerable achievements by the executive directors through a challenging year and therefore no further discretion was applied to
the resulting award levels.
The maximum bonus award under the Policy is set at 100% of base salary, however, in the first year of implementation awards were
limited to 85% of the base salary paid during 2022. The final bonus amounts are set out below and awards will be made in early 2023,
spilt equally in cash and shares. Malus and clawback provisions apply to the awards and the shares will be subject to a 12-month
retention period.
Maximum
award
Reduction for
performance
Final bonus
award
Award level %
of maximum
Alison Rose
£949,025
£305,966
£643,059
67.76%
Katie Murray
£647,063
£231,261
£415,802
64.26%
Annual remuneration report
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152
Annual bonus assessment for 2022
Annual bonus measures
Minimum
(10% payable)
On target
(50% payable)
Maximum
(100% payable)
Weighting
Weighted
outcome
Financial (60%)
Go-forward group return measure
(1)
6.9%
7.9%
10.9%
30%
26.44%
Underlying income growth excluding
notable items of Go-forward group
(2)
£11.2 billion
£11.5 billion
(3)
£12.4 billion
10%
9.21%
Cost reduction based on Go-forward group
operating expenses, excluding litigation and
conduct costs
2%
3%
4%
10%
4.74%
Progress to medium-term capital target
based on CET1 ratio post distributions
(4)
n/a
14%
n/a
10%
5.00%
Strategic (35%)
Progress towards halving emissions by 2025,
reduction in carbon emissions vs 2019 baseline
≥38%
40%
≥44%
2%
2.00%
Funding and financing committed to
Climate and Sustainable Finance
£16.62 billion
£17.5 billion
£19.25 billion
4%
4.00%
Develop and publish initial Climate transition
plan with 2022 results
(5)
4%
2.00%
Customer scores based on an aggregated view
of NPS and Customer Touchpoint Rating
(6)
10%
5.25%
Purpose score (Our View)
80
90
≥92
3.33%
1.53%
Culture score (Our View)
73
83
≥85
3.33%
1.53%
Percentage of females in the top three layers of
the organisation (globally)
(7)
36%
41%
≥43%
1.67%
0.84%
Percentage of colleagues from ethnic minority
backgrounds in the top four layers (UK)
(7)
9%
12%
≥14%
1.67%
0.62%
Supporting diverse enterprise
(8)
Support 35,000 businesses through enterprise
programmes with 250,000 customer interactions
1.25%
1.10%
Number of young adults engaged in enterprise
and entrepreneurship activity
28,500
30,000
33,000
1.25%
1.25%
Number of customers who, having never saved
with us, or having saved less than £100, have
now saved £100
503,500
530,000
583,000
1.25%
0.00%
Number of financial capability
interactions delivered
(9)
3.8 million
4 million
4.4 million
1.25%
1.25%
Personal measures (5%)
Discretionary assessment at year end for both
executive directors
Strong contribution by the CFO was fully recognised
in the scorecard outcomes above. Progress by the
CEO on One Bank transformation, UBIDAC exit, the
stand up of the Commercial & Institutional segment,
personal leadership on the climate agenda and
strengthening relationships with external
stakeholders led to 4.0% outcome under
the CEO’s personal measures.
5%
4.0% (CEO)
0% (CFO)
(*)
Downward risk modifier
Downward risk modifier of 3% applied for the CEO and 2.5% for the CFO to reflect
risk performance against core goals, balanced by strong leadership behaviour
Final outcome
post risk modifier
67.76%
(CEO)
64.26%
(CFO)
(*)
The CFO delivered strong performance against the targets set for the year, as reflected in the core scorecard outcome. For the personal measures, the committee considered that
the key areas of strength were appropriately reflected in the financial and strategic outcomes above and opted not to make any additional award to the CFO for 2022.
The reconciliation to the reported figures and footnotes for the table above are set out on the next page.
Achieved 10.2%
Achieved £12.3 billion
Achieved 2.9%
Achieved 14.2%
Achieved above 44%
Performance achieved in 2022
Achieved £24.5 billion
Achieved 89
Achieved 82
Achieved 41%
Achieved 11%
Achieved 48,000
Achieved 5.1 million
Achieved 477,000
Achievement of goal
Met targets on average
(6)
Published on time
Target slightly exceeded
53,000 businesses supported, 269,000 customer interactions
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FINANCIAL REVIEW
GOVERNANCE
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FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Annual remuneration report
continued
Vesting of 2020 LTI awards (audited)
The LTI award was granted in March 2020 in respect of performance year 2019. Prior to the awards being granted to the CEO
and CFO, reductions of 22% and 27% respectively were applied to the maximum award as a result of the pre-grant performance
assessment. The reductions were made as risk, customer and financial performance were not fully at the desired level. At the end of
2022, a further assessment took place to review whether anything had come to light which might call into question the original award.
The assessment found that there had been no material deterioration in financial, customer, risk and culture performance since grant.
The forensic investigation of Financial Crime and Customer Due Diligence remediation had resulted in adjustments to prior vestings
of the 2018 and 2019 LTI awards through the risk underpin. Given the financial crime return to risk appetite had remained on track
for the objectives set, the committee and the Board determined that no further adjustment was necessary. It was noted that,
while the timeline had slipped since the grant of the 2020 LTI award, this had been a contributory factor in the decision to make
a 5% adjustment to the CEO and former CEO’s 2019 LTI awards last year. Overall, the data indicated that the required level of
sustainable performance had been achieved and no further reductions were made to the 2020 LTI awards under the pre-vest test.
The committee also considered the potential application of risk and stakeholder perception underpins, which included a detailed
discussion on whether the vesting outcome could result in potential windfall gains. The committee used our pre-disclosed framework
and a range of other factors to assess windfall gains and believed there was a strong rationale for not making any adjustment.
Details of the pre-vest performance assessment and the process to assess windfall gains can be found on the pages that follow.
A summary of the position from grant to vest is set out below along with the estimated vesting values for the 2020 LTI award, which
is used in the single total figure of remuneration table. No dividend equivalents were paid prior to vesting. The shares will vest in equal
amounts between 2023 and 2027, followed by a 12-month retention period. Malus and clawback provisions also apply.
Alison Rose
Katie Murray
2020 LTI award
Shares
Value
Shares
Value
Maximum at grant
1,131,488
£1,925,000
881,679
£1,500,000
Reduction for pre-grant test
(249,809)
(£425,000)
(235,114)
(£400,000)
Award granted
881,679
£1,500,000
646,565
£1,100,000
Reduction for pre-vest test
Amount post performance tests
881,679
£1,500,000
646,565
£1,100,000
Increase in value due to share price
£677,747
£497,016
Estimated vesting value
£2,177,747
£1,597,016
(1)
Share price at grant was £1.701 and the estimated vesting value was based on share price of £2.47, the average over the three-month period from October to December 2022.
Reconciliation to reported figures and footnotes
Amount
Go-forward group
return measure
Go-forward
income excluding
notable items
Reported figure
16.9%
£13.1 billion
Base rate adjustment
£0.8 billion
(10)
(2.3%)
(£0.8 billion)
Gains from interest and FX risk management derivatives not in accounting hedge
relationships/own credit adjustments/profit from insurance liabilities
£0.5 billion
(10)
(1.4%)
Timing of FX and conduct losses
£0.4 billion
(10)
(1.3%)
Deferred tax asset and tax rate
£0.4 billion
(10)
(1.7%)
Figures used in bonus scorecard
10.2%
£12.3 billion
(1)
For the purpose of assessment under the bonus scorecard, the Go-forward group return measure adjusts the published Go-forward group RoTE to exclude material factors outside
of management’s control. Items will only be adjusted if this results in an impact of at least 0.25% to the RoTE figure. For performance year 2022, these include:
a.
Material changes in base rate from that assumed at the beginning of the year;
b.
Gains from interest and FX risk management derivatives not in accounting hedge relationships, own credit adjustments, profit from insurance liabilities and the timing of FX and
litigation and conduct charges; and
c.
Deferred tax asset and effective tax rate changes.
(2)
Similarly, for income, the definition for the purpose of the scorecard excludes the material changes in base rate from that assumed at the beginning of the year. No adjustments are
required to the reported figure for gains from interest and FX risk management derivatives not in accounting hedge relationships, own credit adjustments, profit from insurance
liabilities and FX losses as notable items are already excluded from the definition of the reported figure.
(3)
On-target income has been set at £11.5 billion, in line with the ‘above £11.0 billion’ market guidance issued at the beginning of 2022.
(4) Capital has been assessed on a qualitative basis against the range.
(5)
The initial Climate transition plan was deemed ‘on target’ performance as it has been published although work will continue on the plan.
(6)
As NPS is not available for NatWest Markets, an internal Customer Touchpoint Rating is applied to assess NatWest Markets’ customer performance. The aggregated view reflects
the contribution of each franchise to NatWest Group’s income. Targets: NatWest Retail Banking NPS 14 or be 2
nd
or better; NatWest Premier Banking NPS 19; Coutts NPS 48;
NatWest Business Banking NPS 0 and be 3
rd
or better; NatWest Commercial & Corporate Banking NPS 24 and 1
st
; RBS International NPS 33; NatWest Markets Customer Touchpoint
Rating 70. We met or exceeded 5 out of the 7 customer goals set for 2022. The weighted average rating across these 7 targets means that the Customer outcome is 5.25%.
(7)
The targets set at the start of 2022 were to increase the percentage of females in the top three layers by 3% on aggregate and to increase the percentage of colleagues from ethnic
minority backgrounds by 1% on aggregate. Note that NatWest Group’s management structures were revised during 2022. The representation targets were set based on the
management structures in place at the start of financial year 2022 with performance assessed against these at 31 December 2022. This will differ from the year-end position quoted
elsewhere in our reporting suite, which uses the structures in place as at 31 December 2022.
(8)
Enterprise target aimed at supporting the recovery and prioritising support for harder to reach groups with higher barriers to entering and growing a business. The support was to
be distributed as follows: 75% support to UK regions outside London & South East, 60% support to females, 20% support to individuals from ethnic minority backgrounds, and 20%
to people intending to create purpose-led businesses. Minimum target: 33,250 businesses and 237,500 interactions, Maximum target: 38,500 businesses and 275,000 interactions
(same percentage distribution as target).
(9)
The articulation of the 2022 target in last year’s report was to reach 4 million people through financial capability interactions. The intent was to deliver 4 million interactions during
the year rather than reaching 4 million people. This is consistent with our overarching ambition of delivering 15 million financial capability interactions by 2023 and the wording
used to describe the financial capability measure in last year’s report, which was based on the number of interactions. Performance has therefore been assessed against the
intended target.
(10) Amounts quoted are pre tax whereas RoTE impacts are post tax.
NatWest Group
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154
2020 LTI award – Pre-vest performance assessment framework
LTI awards were made in early 2020 following an assessment of performance over the 2019 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 2019 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 2019.
YES
Has there been
a material fall
in the NatWest
Group share
price over
the period?
NO
The share price
has risen rather
than fallen since
the end of 2019.
Has Net
Promoter Score
(NPS) fallen
across the
business?
Some declines
but declines not
deemed within
management’s
control or not
related to 2019.
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
2019.
Has the culture
index from
Our View or
the Financial
Services Culture
Board (FSCB)
(1)
survey position
fallen materially?
NO
No material
deterioration in
culture scores,
most are
improved or flat.
Have colleague
engagement
scores fallen
materially?
NO
No, since 2019
scores improved
and remain
above Financial
Services Norm.
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
Since the declines in some customer metrics were not within management’s control or related to 2019,
there was no deterioration in financial, customer, risk and culture performance that would merit a reduction
prior to vesting. The committee noted the investigation of Financial Crime and CDD remediation had
resulted in adjustments to prior LTI vestings through the risk underpin. Since the timeline for financial
crime return to appetite had not worsened over the course of 2022, no further adjustments were
considered necessary as part of the 2020 LTI pre-vest assessment.
(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 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 underpins to
consider any
significant risk,
stakeholder or
reputational
matters not
already captured
in the performance
assessment, with
advice from the
BRC and the SBC.
Evidenced by
Analysis
Potential underperformance?
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| 2022 Annual Report and Accounts
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FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Windfall gains
The 2020 LTI award was granted in March 2020 at a time
when the true impact of COVID-19 was just beginning
to emerge. Following the grant, the committee noted
shareholder expectations on the need to consider
whether this grant could result in potential windfall gains.
In line with guidance issued by shareholders in 2020, we
implemented and disclosed a framework to assess any
windfall gains related to our LTI awards. Under this
framework, we take into account factors such as:
a.
the level of grant price in comparison to
pre-COVID-19 levels;
b.
share price appreciation over the pre-vest period,
including any share price appreciation specific to
NatWest Group which would be indicative of
strong management performance;
c.
the level of share price appreciation that would
indicate exceptional share price performance, such
as an upper decile share price, suggesting a windfall
gain may have arisen; and
d.
reductions already applied to the executive directors’
pay and award levels during the pre-grant and
pre-vest performance period of the relevant
LTI grant.
For the 2020 LTI award, the committee’s assessment
considered the following factors:
The share price for the March 2020 LTI award was
35% below the prior grant. However, the grant was
not made at the lowest point of the market as both the
NatWest Group share price and the FTSE saw further
significant falls in the period following grant, due to the
impact of COVID-19. It is only this further drop after the
grant date which saw a quick recovery over 2020 as
market uncertainty was removed.
During the pre-vest period following the grant of
the 2020 LTI award, NatWest Group’s share price
performed strongly (+87%), which exceeded that of
the FTSE350 Banking Index (+20%) and the FTSE100
index (+25%). This upward trend reflected the significant
improvement in NatWest Group’s performance over the
same period, evidenced by factors such as:
our strong capital position and continued capital
generation meaning we are well placed to invest
for growth;
improvement in operating performance including
achievement of cost reduction targets during the
pre-vest performance period; and
return of surplus capital, with shareholder returns
increasing from £0.4 billion in 2020 to £3.8 billion
for 2021 and £5.1 billion for 2022.
The committee also noted that the NatWest Group
LTI construct was different to a more traditional LTIP
construct in that LTI awards delivered lower maximum
opportunity but more predictable levels of pay. Our LTI
awards have the main performance test prior to grant
with a further assessment prior to vesting to ensure
the performance has been sustainable.
Annual remuneration report
continued
Under this construct, the March 2020 LTI grant to the CEO
and CFO for performance year 2019, was reduced to 78%
and 73% of maximum respectively, based on performance
against pre-set and unadjusted targets. The committee
considered this was another important consideration in
making the windfall gain assessment. As the shares from the
2020 LTI award will vest between 2023 and 2027, followed
by a 12-month retention period after each vesting, this will
ensure there is long-term alignment with the interests
of shareholders.
For the 2020 performance year, the pay for the CEO
and CFO was reduced through voluntary waivers and
a COVID-19 related reduction respectively. In April 2020,
the CEO voluntarily decided to forgo 25% of her total fixed
pay for the remainder of 2020 (reducing her fixed share
allowance by £426,000). In addition, the CEO confirmed
she did not wish to receive an LTI award for the 2020
performance year which the committee determined to
be £899,000 as noted in the 2020 Directors’ remuneration
report. In total, the CEO waived £1,325,000 of her 2020
pay. The CFO’s LTI award for 2020 after adjustment for
performance was reduced by a further £418,000 (38%)
to reflect the impact of COVID-19.
The committee noted that this was a complex area and
one which required them to apply judgement and to make a
holistic assessment of whether, based on all relevant facts and
circumstances, a windfall gain could be said to have arisen in
respect of the 2020 LTI awards held by the executive directors.
Whilst the committee acknowledged there was a share price
fall prior to grant and a subsequent improvement, given the
mitigating factors set out above, it concluded that no windfall
gain had arisen and that no further adjustment was required
to be made to the 2020 LTI awards prior to vesting.
The committee Chair discussed our windfall gains assessment
framework in detail with our key shareholders and proxy
advisors as part of the recent engagement programme, and the
stakeholders at these meetings noted our proposed approach.
Share price comparison over post-grant period
250
200
150
Mar
2020
Sep
2020
Jun
2020
Dec
2020
Mar
2021
Sep
2021
Jun
2021
Dec
2021
Mar
2022
Sep
2022
Jun
2022
Dec
2022
50
100
NatWest Group
FTSE100
FTSE350 Banking
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| 2022 Annual Report and Accounts
156
Scheme interests – LTI awards granted during 2022 (audited)
Grant date
Face value
Award price
Shares
awarded
(1)
Vesting levels
Performance requirements
Alison Rose
7 March
2022
£1,598,000
£1.8205
877,781
Between
0% – 100%
with no set
minimum
vesting
The award was subject to a pre-grant
assessment of performance over 2021.
A further assessment will take place
following the end of the 2024 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 2020 LTI award pre-vest assessment,
as set out above.
Katie Murray
7 March
2022
£1,057,500
£1.8205
580,885
(1)
The conditional share awards granted to Ms Rose and Ms Murray equated to 145% and 141% of base salary respectively. The number of shares was calculated taking into account
performance and the maximum potential award. 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 2025 and 2029. 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.
RSP awards to be granted for 2022 (audited)
RSP awards are granted provided the committee considers performance over the prior year has been satisfactory, based on an
assessment against our internal performance management framework. The determination of whether satisfactory performance has
been achieved is based on our internal ratings scale (one to five) with a rating of three or above normally resulting in the RSP award
being granted at maximum. A three rating means performance goals have been fully achieved throughout the year and behaviours
have been demonstrated at the required level. Performance against regulatory accountabilities are also considered.
The maximum RSP award under the Policy in the first year of implementation was limited to 125% of base salary. The CEO and CFO
received ratings of four and three respectively for 2022, meaning performance goals were fully achieved or exceeded and behaviours
were demonstrated at the required level. All regulatory responsibilities were also met. Noting the achievements by both executive
directors over the year and the subsequent performance ratings, the committee agreed that RSP awards would be granted at
maximum, in line with the Policy.
As a result, the CEO and CFO will receive RSP awards of £1,395,625 and £951,563 respectively. The awards will be delivered
entirely in shares and subject to conditions before vesting as well as significant holding periods to create long-term alignment with
the experience of shareholders. Malus and clawback provisions will also apply.
Pre-vest underpin
The committee will make an assessment at the end of the three-year performance period (covering financial years 2023 to 2025)
to determine whether sustainable performance has been achieved. Before vesting, the outcome will be reviewed using the underpin
criteria below. Following the assessment, RSP awards may vest in full, in part or lapse in their entirety, with discretion to consider
other factors and apply discretion before deciding the final vesting outcome. This will mitigate any potential unintended outcomes
that might arise and ensure that there is a fair outcome.
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.
Vests in equal amounts
between 2026 and 2030,
with a 12-month
retention period
after each vesting.
Pre-grant
performance
Year
of grant
Start of vesting
3.
Any material deterioration
in the risk or regulatory
compliance profile or
control environment of
NatWest Group, or a
serious conduct or
reputational event.
2023
2022
2026
Criteria before vesting
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| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Remuneration for the Chairman and non-executive directors in 2022
The basic Board fee was increased from £80,000 to £82,000 per annum from 1 May 2022. This was the first change to the basic
Board fee since 2017 and the decision was made after considering the fees paid by other major UK banks as well as salary increases
for the wider workforce. The 2.5% increase was lower than the 3.6% average salary increase applied across our global workforce
from April 2022. The fees for the Chairs of the Group Audit Committee, Group Board Risk Committee and the Group Performance
and Remuneration Committee were increased from £68,000 to £73,000 per annum to bring the rates closer to market practice and
to acknowledge the considerable time commitment of these roles in a regulated major bank. The composite fee for Frank Dangeard
was increased from £264,000 to £270,000 to reflect the change in the basic Board fee and in view of his commitments and
responsibilities as Chairman of NatWest Markets Plc. All of the changes were within the scope of the remuneration policy
approved by shareholders and no directors were involved in decisions regarding their own remuneration.
For NatWest Group plc Board directors who also serve on the Boards and Committees of NatWest Holdings Limited, National
Westminster Bank Plc and The Royal Bank of Scotland plc, the fees below reflect membership of all four 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 2022 (audited)
Fees
Benefits
(1)
Total
Chairman (composite fee)
2022
£000
2021
£000
2022
£000
2021
£000
2022
£000
2021
£000
Howard Davies
750
750
14
13
764
763
Non-executive directors
Board
£000
N&G
£000
GAC
£000
BRC
£000
RemCo
£000
SBC
£000
TIC
£000
SID
£000
CAP
£000
Other
£000
Fees
2022
£000
2021
£000
Benefits
(2)
2022
£000
2021
£000
Total
2022
£000
2021
£000
Frank Dangeard
(3)
268
268
262
3
1
271
263
Roisin Donnelly
(4)
21
21
6
27
Patrick Flynn
81
15
72
34
30
232
227
5
1
237
228
Morten Friis
81
15
34
72
202
197
44
22
246
219
Robert Gillespie
(5)
78
14
33
33
52
210
227
17
2
227
229
Yasmin Jetha
81
30
60
171
170
4
1
175
171
Mike Rogers
81
34
60
4
179
172
15
194
172
Mark Seligman
81
15
34
34
34
198
191
5
1
203
192
Lena Wilson
81
4
34
45
30
11
205
195
17
5
222
200
(1)
The benefits column for Howard Davies, Chairman, includes private medical cover, life cover and expenses in connection with attendance at Board meetings.
(2)
Non-executive directors are reimbursed expenses incurred in connection with travel and attendance at Board meetings. The value of benefits had fallen in 2020 and 2021 due to less
travel during the COVID-19 restrictions but have returned to more typical levels in 2022.
(3) Under the ‘Other’ column, Frank Dangeard received a composite fee as Chairman of the NatWest Markets Plc Board.
(4) Roisin Donnelly was appointed to the Board with effect from 1 October 2022.
(5) Robert Gillespie stepped down from the Board with effect from 15 December 2022.
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
Payments for loss of office and payments to past directors (audited)
There were no payments for loss of office made to directors in 2022. Ross McEwan stepped down from the Board as CEO in October
2019 and qualified for good leaver treatment in respect of his LTI awards. Mr McEwan received his final LTI award over 942,907
shares in 2020 with the award level reduced by 31% following the application of the pre-grant performance assessment. In line with
the position for the current executive directors, no further reduction was made under the pre-vest test. The shares are due to vest
between 2023 and 2027, subject to good leaver criteria continuing to be met. The value of the shares was £1,597,016, based on
the average share price over October to December 2022. There are no other payments to past directors to disclose for 2022.
Annual remuneration report
continued
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| 2022 Annual Report and Accounts
158
Implementation of remuneration policy in 2023
Pay arrangements
Both executive directors will receive annual bonus and RSP awards in March 2023 in respect of the 2022 performance year. You can
find details of these awards on pages 152 and 157. A 3% increase to the base salary of each executive director has been agreed from
1 April 2023, which is less than half the expected average salary increase for the global workforce at 6.4%. Pay arrangements for the
2023 performance year are set out below.
Salary
(1 Jan 2023)
Salary
(1 Apr 2023)
Standard
benefits
(1)
Pension
Fixed share
allowance
(2)
Maximum bonus
award for 2023
(3)
Maximum RSP
award for 2023
(4)
Alison Rose
£1,122,000
£1,155,660
£26,250
10% of salary
100% of salary
£1,147,245
£1,720,868
Katie Murray
£765,000
£787,950
£26,250
10% of salary
100% of salary
£782,213
£1,173,319
(1)
Amounts shown relates to standard benefit funding. Executive directors are also entitled to benefits such as travel assistance and security arrangements in line with the Policy.
We will disclose the value of benefits received each year. Executive directors are eligible to participate in all-employee share plan arrangements on the same basis as colleagues.
(2)
Fixed share allowance is payable broadly in arrears, currently in four instalments per year. The shares will be released in equal amounts over a five-year period.
(3)
The maximum bonus award under the Policy is set at 100% of base salary and is calculated on salary earned over the year. The award is expected to vest at 50% where on-target
performance is achieved across the scorecard.
(4)
The maximum RSP award under the Policy is set at 150% of base salary and is calculated on salary earned over the year. The award is normally expected to vest in full, subject to
underpin criteria that will ensure there is no payment for failure. The maximum remuneration receivable by the CEO and CFO would increase by £860,434 and £586,659 respectively
in the event there was a 50% increase in the NatWest Group plc share price over the RSP three-year period from grant to vest.
Annual bonus performance assessment for 2023
The annual 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. The main updates to the measures for 2023 are retiring our
reduction in carbon emissions from own operations as this transitions to business as usual and supporting the initial Climate
transition plan by targeting progress against sectoral targets.
For 2023, financial performance will represent 60% of the scorecard with target ranges set in line with the budget. Non-financial
measures will be focused across climate, customer, purpose, culture and people, and enterprise and capability. These measures
represent an aggregate of 35% of the scorecard and reflect our ESG priority areas as well as the importance of good customer
outcomes. The remaining 5% will be assessed on Personal measures based on a discretionary assessment of the performance of
each executive director over the year. A downward Risk modifier will also apply, enabling risk performance to be assessed and
awards reduced, potentially to zero.
Threshold and maximum targets will be disclosed retrospectively at the end of the performance period in the 2023 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 measures and targets for 2023
Category
Performance measures
Target
Weighting %
Financial
Financial
(60%)
Group RoTE.
Targets set and the extent of their achievement
will be disclosed in the 2023 Annual Report as the
committee considers them to be commercially
sensitive at this point in time.
30%
Group underlying income excluding notable items.
£14.8 billion
10%
Group operating expenses, excluding litigation and
conduct costs.
£7.6 billion
10%
Progress to medium-term capital target.
CET1 target range of 13-14%
10%
Non-Financial
Strategic
(35%)
Climate
Funding and financing committed to
climate and sustainable finance.
Implementation of the initial Climate
transition plan.
Funding and financing target of £25.3 billion towards
the £100 billion target.
Four sectors on target with one of the two Assets
Under Management and Retrofit milestones achieved.
10%
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| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Category
Performance measures
Target
Weighting %
Strategic
(35%)
Customer
Net promoter score (NPS) and
Customer Touchpoint Rating (CTR)
for our brands.
Consumers: Improve NatWest Retail Main Bank NPS
to +23 or 3
rd
(from +22 and 3
rd
). Businesses: Improve
NatWest Business Banking £0-750k NPS to -6 or 3
rd
(from -8 and 3
rd
) and maintain NatWest Commercial
Mid-Market £750k+ NPS at +17 or 1
st
. Private
Banking: Improve Premier NPS to +31 or 3
rd
(from
+29 and 3
rd
). Achieve Coutts NPS (12MR) of +36
(from +38) or Coutts NPS (3MR) of +49 (from +28).
RBSI: Maintain NPS of +35. NatWest Markets:
maintain average CTR of 72%.
10%
Purpose,
culture and
people
Progress against purpose targets.
Progress against culture targets.
Number of females in senior roles.
Number of colleagues from ethnic
minority backgrounds in senior roles.
Purpose target from Our View = 87
Culture target from Our View = 80
Increase percentage in the top three layers to 42%
on aggregate
Increase percentage in the top four layers in the UK
to 12.5% on aggregate
10%
Enterprise &
capability
Support the sustainable growth
ambitions of our customers. Prioritise
support for harder to reach groups
with higher barriers to entering and
growing a business.
Encourage youth participation
in enterprise.
Number of financial capability
interactions which require active
engagement, give knowledge or
skills or change behaviour.
Support 35,000 businesses through enterprise
programmes with 275,000 customer interactions.
Support being distributed as follows: 75% to UK regions
outside London & South East; 50% to females; 20% to
individuals from ethnic minority backgrounds.
50,000 young adults engaged in Enterprise and
Entrepreneurship activity.
Deliver 4 million financial capability interactions from
key initiatives (MoneySense, Financial Health Checks,
Spending Feature and Know My Credit Score).
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%
RSP performance assessment for 2023
RSP awards are granted entirely in shares creating simple and effective alignment with the returns that shareholders receive over the
long term. This is supported by annual bonus arrangements, which ensure 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 Policy.
Pre-grant test
Executive directors will be granted an RSP award in 2024 provided the committee considers performance over 2023 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.
Annual remuneration report
continued
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160
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.
Chairman and non-executive directors’ shareholding policy and annual fees for 2023
The Chairman and non-executive directors typically hold shares in NatWest Group, recognising this is a practice that shareholders
generally encourage. The shares have been acquired on a voluntary basis to date with no guidance on the level of expected
shareholding. Having reflected on our current arrangements, and after considering the position at other major UK banks, the
Board has decided to introduce a formal shareholding policy for these individuals from 1 January 2023. The policy does not apply
to directors who are due to step down from the Board within 12 months of 1 January 2023.
Under the shareholding policy, NatWest Group will retain a portion of the net monthly basic fees (10% for the Chairman and 25%
for non-executive directors) which will be used to purchase shares every quarter. The Chairman will be required to build towards a
shareholding equivalent to four times the basic annual Board fee (currently £328,000) and for non-executive directors the target is
one times the basic annual Board fee (currently £82,000). Once the target is achieved, monthly deductions and quarterly purchases
will continue at a reduced percentage of net monthly fees (5% for the Chairman and 10% for non-executive directors). The shares
purchased under the shareholding policy will be held in a nominee account with dividends reinvested and shares retained until the
director steps down from the Board.
We believe this is a progressive and proportionate approach to shareholder alignment that will provide consistency and ultimately
higher levels of shareholdings for this cohort. It will also ensure there is a continuous element of shareholder alignment as the
Chairman and non-executive directors will continue to acquire shares over their entire tenure. The annual fees for 2023 are
set out below, with the fees delivered in a combination of cash and shares in line with the shareholding policy above.
Fees for NatWest Group plc Board
(1)
Rates from
1 January 2023
Chairman (composite fee)
£750,000
Non-executive director basic fee
£82,000
Senior Independent Director
£34,000
Fees for NatWest Group plc Board Committees
(1)
Member
Chairman
Group Board Risk Committee
£34,000
£73,000
Group Audit Committee
£34,000
£73,000
Group Performance and Remuneration Committee
£34,000
£73,000
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)
£270,000
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.
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.
161
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FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
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,
from the 2022 performance year onwards, annual bonus awards. As no bonus awards were made to the executive directors for
the 2021 performance year, there is no prior year comparison in the table below. 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. The data for non-executive directors below reflects the value of benefits mainly falling in 2020 and 2021,
due to less travel during the COVID-19 restrictions, before returning to more typical levels in 2022.
2021 to 2022
2020 to 2021
2019 to 2020
Annual percentage change
Salary
Benefits
(1)
Annual
Bonus
Salary
Benefits
(1)
Annual
Bonus
Salary
Benefits
(1)
Annual
Bonus
UK employees
(2)
5.20%
6.34%
42.48%
2.02%
4.68%
35.24%
2.86%
1.70%
-32.4%
Executive directors
Alison Rose
(3)
1.5%
0%
0%
0%
n/a
n/a
Katie Murray
1.5%
0%
0%
0%
n/a
0%
0%
n/a
Chairman and non-executive directors
Fees
Benefits
Annual
Bonus
Fees
Benefits
Annual
Bonus
Fees
Benefits
Annual
Bonus
Howard Davies
0%
8%
n/a
0%
8%
n/a
0%
9%
n/a
Frank Dangeard
2%
200%
n/a
1%
0%
n/a
0%
-75%
n/a
Roisin Donnelly
(4)
n/a
n/a
n/a
Patrick Flynn
2%
400%
n/a
0%
-67%
n/a
2%
-70%
n/a
Morten Friis
3%
100%
n/a
17%
214%
n/a
14%
-80%
n/a
Robert Gillespie
(4)
-7%
750%
n/a
3%
-33%
n/a
-3%
-84%
n/a
Yasmin Jetha
(4)
1%
300%
n/a
33%
100%
n/a
n/a
Mike Rogers
4%
n/a
1%
-100%
n/a
0%
-83%
n/a
Mark Seligman
4%
400%
n/a
1%
0%
n/a
-4%
-88%
n/a
Lena Wilson
5%
240%
n/a
8%
25%
n/a
16%
-64%
n/a
(1)
Standard benefit funding for executive directors has remained unchanged. The figures above exclude 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 the average full time equivalent salary and benefit 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.
The average percentage change relates to salaries and benefits awarded in the respective financial years for UK employees and therefore may differ from figures quoted
elsewhere in the report, for example, the proposed salary increases announced in December 2022 to be awarded from April 2023.
(3) Alison Rose, CEO, was appointed on 1 November 2019 and therefore the annual change comparison to 2020 is not applicable.
(4)
Roisin Donnelly joined the Board on 1 October 2022 and Yasmin Jetha re-joined the Board on 1 April 2020, so there are no prior year comparisons. Robert Gillespie stepped down
from the Board with effect from 15 December 2022.
CEO to employee pay ratios
The ratios on the next page compare the total pay of the CEO, as set out in the single figure of remuneration table in this report,
against the pay of three employees whose earnings represent the lower, median and upper quartiles of the UK employee population.
A significant proportion of the CEO’s total remuneration is delivered through long-term incentive arrangements, linked to performance
and share price movements, which means this part of the ratio can fluctuate significantly from one year to the next. None of the three
employees identified this year received equivalent long-term incentive arrangements. 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. For the
total remuneration comparison, the median employee for 2022 works in Services and the median pay ratio is consistent with the pay
and reward policies for UK employees as a whole. We are determined to pay 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 our supporting ESG Disclosures Report at natwestgroup.com. The change in the median pay ratio since 2018 is
largely driven by the more volatile nature of performance-related pay for the CEO. In April 2020, the CEO decided to forgo 25% of
her fixed pay for the rest of the year which contributed to the ratio falling in 2020 before rising in 2021.
The median pay ratio has increased further in 2022 primarily due to the CEO receiving an annual bonus award for the first time under
the new Policy and a higher vesting value for the LTI award compared to last year, as a result of strong share price performance.
The single figure of remuneration for the CEO, on which the pay ratio is based, includes a combination of our new and old Policies
this year and this may impact the ratio in future years as any outstanding LTI awards complete their three-year performance cycle.
The total remuneration for employees at the lower, median and upper quartiles have all increased year-on-year. On a comparison of
salary only, the trend continues to be stable.
Annual remuneration report
continued
NatWest Group
| 2022 Annual Report and Accounts
162
CEO to employee pay ratios
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
2022
A
Total remuneration
177:1
119:1
71:1
Total remuneration
5,249
30
44
74
Salary only
42:1
28:1
19:1
Salary only
1,117
27
40
58
Supplementary information on the pay ratio table:
(1)
The data for 2022 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 25
th
, 50
th
and 75
th
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. 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.
Remuneration of Material Risk Takers (MRTs) in 2022
Each year, we disclose the remuneration paid to individuals whose activities have a material influence over NatWest Group’s
performance or risk profile, known as MRTs. The disclosures are made in line with regulatory requirements and full details can be
found in our Pillar 3 reports on natwestgroup.com. The tables below summarise the total pay for staff identified as MRTs for one or
more entities across NatWest Group along with the number of individuals earning more than €1 million for the year. Note that the
number of MRTs excludes colleagues who left NatWest Group prior to 31 December 2022 in line with regulatory requirements.
Number of MRTs
704
Number of >€1m earners
Remuneration (£millions)
€1.0 million to below €1.5 million
53
Total fixed pay
£196.33
€1.5 million to below €2.0 million
17
Total variable pay
£106.16
€2.0 million to below €2.5 million
6
Total remuneration
£302.49
€2.5 million to below €3.0 million
3
€3.0 million to below €3.5 million
1
€3.5 million to below €4.0 million
€4.0 million to below €4.5 million
1
Total
81
72.13%
18.58%
8.03%
1.26%
50,894 employees earned total remuneration up to £50,000
5,667 employees earned total remuneration between £100,000 and £250,000
13,107 employees earned total remuneration between £50,000 and £100,000
889 employees earned total remuneration over £250,000
Summary of remuneration levels for employees in 2022
The disclosure of remuneration levels for employees includes anyone employed by NatWest Group during the year.
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FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Directors’ interests in NatWest Group plc shares (audited)
Under the shareholding requirements, the CEO and CFO need to build up and maintain shares to the value of 500% of salary
and 300% 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 149.
As set out earlier in this report, the Chairman and non-executive directors will be subject to a separate shareholding policy from 2023.
Share interests held by directors
Alison
Rose
Katie
Murray
Howard
Davies
Frank
Dangeard
Roisin
Donnelly
(1)
Patrick
Flynn
Morten
Friis
(3)
Robert
Gillespie
Yasmin
Jetha
Mike
Rogers
Mark
Seligman
(4)
Lena
Wilson
Shares held
(2)
2,117,170
1,044,209
102,142
4,642
18,571
18,570
23,214
27,857
18,571
27,857
27,857
Shareholding
requirement
500% of
salary
300% of
salary
Position against
requirement
603% of
salary
398% of
salary
(1) Roisin Donnelly was appointed to the Board from 1 October 2022.
(2)
Shares owned beneficially as at 31 December 2022 or at the date of stepping down from the Board if earlier. Includes shares held by persons closely associated with the directors.
As at 16 February 2023, 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 2022, at which point both executive directors exceeded the requirement based on the closing price of £2.652 on 30 December 2022.
(3) The share interest held is over 9,285 American Depositary Receipts representing 18,570 ordinary shares.
(4)
9,285 shares are held in the name of M Seligman & Co Limited, of which Mr Seligman and Louise Seligman are shareholders.
(5) The share interest figures above have been adjusted to reflect the 13 for 14 share consolidation on 30 August 2022.
Share awards under share plans
Year
Awards held
1 Jan 2022
Awards
granted
Award price
£
Awards
vested
Awards
lapsed
Awards
forfeited
Awards held
31 Dec 2022
Expected vesting dates
Alison Rose
LTI award
2017
167,758
2.41
55,920
111,838
(1)
07.03.23 – 07.03.24
LTI award
2018
368,560
2.66
92,140
276,420
(1)
07.03.23 – 07.03.25
LTI award
2019
568,829
2.64 107,319
32,234
429,276
(1)
07.03.23 – 07.03.26
LTI award
2020
881,679
1.70
881,679
(2)
07.03.23 – 07.03.27
LTI award
2022
877,781
1.82
877,781
(2)
07.03.25 – 07.03.29
1,986,826 877,781
255,379
32,234
2,576,994
Total LTI awards subject to service
817,534
(1)
Total LTI awards subject to performance and service
1,759,460
(2)
Katie Murray
Deferred award
(4)
2017
17,084
2.41
17,084
LTI award
2017
31,191
2.41
31,191
Deferred award
2018
53,591
2.66
26,796
26,795
(1)
07.03.23 – 07.03.23
Deferred award
2019
208,945
2.64
41,790
167,155
(1)
07.03.23 – 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
LTI award
2022
580,885
1.82
580,885
(2)
07.03.25 – 07.03.29
1,367,838
580,885
116,861
1,831,862
Total LTI and deferred awards subject to service
193,950
(1)
Total LTI awards subject to performance and service
1,634,712
(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 2020 LTI award. The first vesting of this award is due to take place in March 2023, which will be reflected in next year’s table together with any 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.
(4)
Deferred awards relate to annual bonus awards granted to Ms Murray for performance prior to becoming an executive director, with payments deferred in line with
regulatory requirements.
Annual remuneration report
continued
NatWest Group
| 2022 Annual Report and Accounts
164
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.
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.
CEO pay over the same period
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
Total remuneration (£000s)
(1)
AR
1,401
2,615
3,588
5,249
RM
393
1,878
3,492
3,702
3,487
3,578
4,066
SH
1,235
Annual bonus against
maximum opportunity
AR
68%
SH
0%
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
LTI vesting rates against
maximum opportunity
AR
60%
82%
83%
78%
RM
73%
62%
56%
89%
41%
78%
SH
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.
Relative importance of spend on pay £m (% change on 2021)
2022
2021
Remuneration paid to all employees
(1)
Distributions to holders of preference shares and paid-in equity
Distributions to holders of ordinary shares
(2)
3,156
693
318
3,179
(+0.73%)
1,205
(+73.88%)
249
(-21.70%)
(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)
Reflects distributions to shareholders through dividend payments during the financial year. The Board has confirmed its intention to pay a dividend of 10.0p per ordinary share in
respect of financial year 2022, which will be paid in 2023 subject to approval by shareholders at the forthcoming Annual General Meeting.
250
200
150
100
50
0
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
NatWest Group
FTSE100
FTSE UK Banks
165
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| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Statement of shareholder voting
At the AGM held on 28 April 2022, the resolutions to approve the Policy and the Annual remuneration report received strong levels
of support.
Directors’ Remuneration Policy
Annual remuneration report
Vote
Number of shares
Percentage
Vote
Number of shares
Percentage
For
33,883,943,928
92.75%
For
36,237,314,672
98.87%
Against
2,649,384,392
7.25%
Against
414,528,384
1.13%
Withheld
126,953,196
Withheld
8,356,700
The Group Performance and Remuneration Committee
Principal areas of focus
Wider workforce
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.
Executive remuneration
Reviewing performance assessments and remuneration arrangements for the committee’s ‘in scope’ population.
Setting performance objectives for senior executives for the year ahead.
Approving the outcomes of variable pay 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.
Governance and regulatory
Approving agenda planners and ensuring the committee is meeting all its obligations under its terms of reference (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.
Annual remuneration report
continued
NatWest Group
| 2022 Annual Report and Accounts
166
The Group Performance and Remuneration Committee continued
Membership
All members of the committee are independent non-executive directors. In order to be considered for the role of
committee Chair, an individual must first have served on a remuneration committee for at least 12 months. During
2022, Robert Gillespie was the committee Chair until 24 September 2022 when he stepped down and Lena Wilson
became Chair, having been a member of the committee since April 2020. Frank Dangeard, Mike Rogers and Mark
Seligman were members throughout 2022. The committee held six scheduled meetings in 2022 and a further three
ad hoc meetings. You can find further details on members and attendance in the Corporate governance report on
page 91.
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 ToR of the committee is reviewed annually and available on natwestgroup.com
Operation of
the policy
The remuneration policy operated broadly as intended during the year, with pay awarded to executive directors
for 2022 broadly in line with that expected for the year. Strong performance across the annual bonus scorecard
resulted in above target outcomes. The committee spent a considerable amount of time discussing the support
to be provided to the wider workforce in response to the cost-of-living crisis, with a range of enhancements to
colleagues’ remuneration being announced.
Managing
conflicts
To mitigate potential conflicts of interest, directors are not involved in decisions regarding their own remuneration. It
is the committee, rather than management, that appoints 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 2022, 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 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 2022 in relation to directors’ remuneration amounted to £186,945 in total excluding
VAT (2021 – £211,041 excluding VAT).
Performance
evaluation
The 2022 evaluation was conducted internally by the Chief Governance Officer and Company Secretary.
The committee acknowledged the former Chairman’s stewardship through a period of significant change from
a remuneration perspective, including the introduction of two new executive director remuneration policies.
The committee also recognised the positive impact of recent improvements made by the new Chair to simplify the
remuneration governance framework. Such improvements were designed to reflect feedback from the committee
and other board committees during 2021. Reflecting on the success of the remuneration governance review, the
committee requested management to explore opportunities to optimise remuneration policies and processes during
2023. The committee discussed the focus on wider workforce pay during 2022. In recent years, pay proposals
relating to the population below executive level had increasingly become a feature of the committee’s oversight
responsibility, as required by the UK Corporate Governance Code. Given the impact of the cost-of-living crisis, the
focus on wider workforce pay had understandably become even more pronounced during 2022. The committee
agreed that it was important that it continued to have significant oversight of wider workforce pay in future.
Lena Wilson, CBE
Chair of the Group Performance and Remuneration Committee
16 February 2023
167
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| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
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 2022, 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.
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 directors are involved in decisions
regarding their own remuneration. A copy of the Code can
be found at frc.org.uk.
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 2022 to
16 February 2023, 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.
Compliance report
NatWest Group
| 2022 Annual Report and Accounts
168
Throughout 2022 work continued to deliver enhancements to
the control environment relating to financial crime risk. NatWest
Group takes its responsibility to prevent and detect financial
crime extremely seriously and continues to make multi- year
investments to strengthen and improve its overall financial crime
framework with prevention systems and capabilities. NatWest
Group also recognises the requirement to continue to invest in
payments systems and remediate end of life systems in line with
agreed prioritisation. A payment review was initiated in late
2022 to assess control enhancements in response to manual
payment risk.
NatWest Group continued to make enhancements to other
aspects of the wider control environment in 2022. This has
included the implementation of end-to-end risk and control
self-assessments with a strategic effort to focus on control
automation. This is part of the broader enterprise-wide risk
management framework activity, which will continue throughout
2023. NatWest Group 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 2022. 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 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.
The control environment remained largely stable in 2022. 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 Regulation 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.
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 2022.
NatWest Group has assessed the effectiveness of its internal
control over financial reporting as of 31 December 2022 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 2022, NatWest Group’s internal control over
financial reporting is effective.
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 2022 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 2022. 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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| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
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 corporate 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 2022 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 2022 is set out in the Group Audit Committee report
on pages 108 to 116.
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
(which requires that a majority of members of the committee
should be independent non-executive directors). 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 Performance and Remuneration Committee 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 2022, NatWest Group plc has
complied with all of the provisions of the Code (subject to the
exceptions 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.
Compliance report
continued
NatWest Group
| 2022 Annual Report and Accounts
170
The directors present their report together with the audited
accounts for the year ended 31 December 2022.
Other information incorporated into this report by reference can
be found at:
Page/Note
Strategic report
Our colleagues
46
Climate-related financial disclosures
58
Stakeholder engagement
Section 172(1) statement
40
Viability statement
68
Financial review
72
Board of directors and secretary
86
Corporate governance
90
Segmental analysis
319
Share capital and other equity
362
Post balance sheet events
376
Risk factors
404
Disclosures required pursuant to Large and Medium-sized
Companies and Groups (Accounts and Reports) Regulations
2008 (as amended) (‘2008 Regs’) are located on the
following pages:
Employee engagement (Paras 11 and 11A, Schedule 7,
2008 Regs):
Pages 36 to 41 (stakeholder engagement and section
172(1) statement)
Page 46 (Colleagues)
Pages 99 to 100 (Corporate governance report,
workforce engagement)
Engagement with suppliers, customers and others (Para 11B,
Schedule 7, 2008 Regs):
Pages 36 to 41 (stakeholder engagement and section
172(1) statement)
Page 98 (Corporate governance report,
stakeholder engagement)
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 9 of the parent company financial statements
and a full list of subsidiary undertakings and overseas branches
is shown in Note 12 of the parent company financial statements.
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. In June 2022 the trading plan was extended for a
further 12 month term to August 2023.
In March 2022, the company carried out an off-market
purchase of 550 million of its ordinary shares from HMT.
At 31 December 2022, HMT’s holding in the total voting rights
of the company was 45.97%. The percentage was correct as
at the date of notification on 21 December 2022.
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 2022, NatWest Group plc’s distributable
profits were £33,134 million.
The profit attributable to the ordinary shareholders of NatWest
Group plc for the year ended 31 December 2022 amounted to
£3,340 million compared with a profit of £2,950 million for the
year ended 31 December 2021, as set out in the consolidated
income statement on page 299.
In 2022 NatWest Group paid an interim dividend of £364 million,
or 3.5p per ordinary share (2021 – £347 million, or 3p per
ordinary share).
In addition, the company also paid a special dividend of
£1,750 million, or 16.8p per ordinary share.
The company has announced that the directors have
recommended a final dividend of £1.0 billion, or 10.0p per
ordinary share (2021 – £844 million or 7.5p per ordinary share).
The final dividend recommended by directors is subject to
shareholders’ approval at the Annual General Meeting on
25 April 2023.
Report of the directors
171
NatWest Group
| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
If approved, payment will be made on 2 May 2023 to
shareholders on the register at the close of business on
17 March 2023. The ex-dividend date will be 16 March 2023.
Subject to the above mentioned condition, the payment of
interim dividends on ordinary shares is at the discretion of
the Board.
Colleagues
As at 31 December 2022, NatWest Group employed 61,000
people (excluding temporary staff). Details of all related costs
are included in Note 3 to the consolidated accounts.
Employment for disabled persons
NatWest Group makes workplace adjustments to support
colleagues with disabilities to 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.
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 or help to 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 403 to 424.
NatWest Group’s regulatory capital resources and significant
developments in 2022 and anticipated future developments are
detailed in the Capital, liquidity and funding section on pages
244 to 263. This section also describes NatWest Group’s funding
and liquidity profile, including changes in key metrics and the
build up of liquidity reserves.
The directors have prepared the financial statements on a
going concern basis after assessing the principal risks, forecasts,
projections and other relevant evidence over the twelve months
from the date the financial statements are approved.
UK Code for Financial Reporting Disclosure
NatWest Group plc’s 2022 financial statements have been
prepared in compliance with the principles set out in the Code
for Financial Reporting Disclosure published by UK Finance. 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 Regulation Authority, published its phase 2 report
recommendations in December 2019.
NatWest Group plc’s 2022 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 2022 shareholders authorised
the company to make market purchases of up to 1,122,905,024
ordinary shares. The authority was amended at the General
Meeting held on 25 August 2022 to preserve the position as if
the share consolidation had not taken place and shareholders
will be asked to renew the authority at the Annual General
Meeting in 2023.
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.
Phase 1 of the Programme commenced on 2 August 2021 and
completed on 18 January 2022. 340,537,460 ordinary shares
(nominal value £340,537,460) were purchased by the company
at an average purchase price of 220.0199p per ordinary share
for the total consideration of £749,250,031. Phase 2 of the
Programme commenced on 21 February 2022 and completed
on 15 July 2022. A further 346,835,822 ordinary shares
(nominal value £346,835,822) were purchased by the company
at an average purchase price of 216.2406p per ordinary share
for the total consideration of £749,999,999 All of the purchased
ordinary shares were cancelled, representing 11.23% of the
company’s issued ordinary share capital.
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
issued ordinary share capital in any 12-month period 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 2022 and amended at the General Meeting
held on 25 August 2022 to preserve the position as if the share
consolidation had not taken place. Shareholders will be asked to
renew the authority at the Annual General Meeting in 2023.
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
Report of the directors
continued
NatWest Group
| 2022 Annual Report and Accounts
172
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 76,513,524 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 2022 was
114,011,084. The figure has been adjusted to reflect
the 13 for 14 share consolidation on 30 August 2022.
The company utilised the authority it obtained at the 2021
AGM to make an off-market purchase of 549,851,147 ordinary
shares (nominal value £549,851,147) in the company from HMT
on 28 March 2022, at a price of 220.5p per ordinary share for
the total consideration of £1,212,421,779, representing 4.91%
of the company’s issued ordinary share capital. The company
cancelled all of the purchased ordinary shares.
At the 2021 Annual General Meeting, shareholders authorised
the company to make an off-market purchase of preference
shares in the company. In December 2021 the company used
this authority to purchase 157,546 5.5% cumulative preference
shares and 259,314 11% cumulative preference shares. The
company cancelled all of the purchased preference shares.
Shareholders will be asked to renew the authority at the
Annual General Meeting in 2023.
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.
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 present in person
or by proxy and entitled to vote, shall have four votes for every
share held, and holders of cumulative preference shares shall
have one vote for each 25p nominal amount 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 2023
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.
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,
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 86 to 89.
Howard Davies, Frank Dangeard, Patrick Flynn, Morten Friis,
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.
Roisin Donnelly was appointed on 1 October 2022 and
Robert Gillespie resigned from the Board on 15 December 2022.
Mike Rogers and Morten Friis have confirmed their intention
to resign as non-executive directors on 25 April 2023 and
31 July 2023 respectively.
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. Mr Rogers will not be standing for re-election
at the company’s 2023 AGM, having confirmed his intention
to resign on 25 April 2023.
Directors’ interests
The interests of the directors in the shares of the company
at 31 December 2022 are shown on page 164. 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 2022 to 16 February 2023.
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FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
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 2022.
Ordinary shares
(millions)
% of issued share
capital with
voting rights held
Solicitor for the Affairs of His
Majesty’s Treasury as Nominee for
His Majesty’s Treasury
4,443
45.97
Norges Bank
323
3.07
(1) The ordinary shares figures above have been adjusted to reflect the 13 for 14
share consolidation on 30 August 2022 which left the percentages held by the
shareholders unchanged. Percentages provided were correct at the date of
notification on 21 December 2022 and 5 November 2021, respectively.
On 2 February 2023 a notification under Rule 5 of the Disclosure
and Transparency Rules (‘DTR’) was received from HMT notifying
that they held 4,254 million ordinary shares, representing
43.97% of the issued share capital with voting rights.
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 Material contracts on page 425.
Political donations
At the Annual General Meeting in 2022, 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 2022, 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 2023.
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
16 February 2023
NatWest Group plc
is registered in Scotland No. SC45551
Report of the directors
continued
NatWest Group
| 2022 Annual Report and Accounts
174
This statement should be read in conjunction with the responsibilities of the auditor set out in their report on pages 286 to 298.
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 and International Financial Reporting Standards as
issued by the International Accounting Standards Board. 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 and International Financial
Reporting Standards as issued by the International Accounting Standards Board, 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
16 February 2023
Alison Rose-Slade DBE
Group Chief Executive Officer
Katie Murray
Group Chief Financial Officer
Board of directors
Chairman
Executive directors
Non-executive directors
Howard Davies
Alison Rose-Slade DBE
Katie Murray
Frank Dangeard
Roisin Donnelly
Patrick Flynn
Morten Friis
Yasmin Jetha
Mike Rogers
Mark Seligman
Lena Wilson
Statement of directors’
responsibilities
175
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FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Risk and capital
management
In this section
178
Presentation of information
178
Risk management framework
178 Introduction
178 Culture
179 Governance
181
Risk appetite
182
Identification and measurement
182 Mitigation
182
Testing and monitoring
182
Stress testing
186
Credit risk
186
Definition, sources of risk and key developments
186
Governance and risk appetite
186
Identification and measurement
187 Mitigation
187
Assessment and monitoring
188
Problem debt management
189 Forbearance
190
Impairment, provisioning and write-offs
193
Significant increase in credit risk and asset lifetimes
195
Economic loss drivers and UK
economic uncertainty
202
Measurement uncertainty and ECL
sensitivity analysis
204
Measurement uncertainty and ECL adequacy
205
Banking activities
240
Trading activities
244
Capital, liquidity and funding risk
244
Definitions and sources of risk
245
Capital, liquidity and funding management
248
Key points
250
Minimum requirements
251 Measurement
264
Market risk
264
Non-traded market risk
272
Traded market risk
275
Market risk – linkage to balance sheet
276
Pension risk
277
Compliance & conduct risk
277
Financial crime risk
278
Climate risk
280
Operational risk
282
Model risk
282
Reputational risk
NatWest Group
| 2022 Annual Report and Accounts
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GOVERNANCE
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FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Risk and capital management
NatWest Group
Annual Report and Accounts 2022
178
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Presentation of information
Where marked as audited in the section header, certain
information in the Risk and capital management section (pages
176 to 283) is within the scope of the Independent auditor’s
report.
Risk management framework
Introduction
NatWest Group operates an enterprise-wide risk management
framework, which is centred on the embedding of a strong risk
culture. The framework ensures the governance, capabilities
and methods are in place to facilitate risk management and
decision-making across the organisation.
The framework ensures that NatWest Group’s principal risks –
which are detailed in this section – are appropriately controlled
and managed. It sets out the standards and objectives for risk
management as well as defining the division of roles and
responsibilities.
This seeks to ensure a consistent approach to risk management
across NatWest Group and its subsidiaries. It aligns risk
management with NatWest Group’s overall strategic objectives.
The framework, which is designed and maintained by NatWest
Group’s independent Risk function, is owned by the Chief Risk
Officer. It is reviewed and approved annually by the Board. The
framework incorporates risk governance, NatWest Group’s
three lines of defence operating model and the Risk function’s
mandate.
Risk appetite, supported by a robust set of principles, policies
and practices, defines the levels of tolerance for a variety of
risks and provides a structured approach to risk-taking within
agreed boundaries.
While all NatWest Group colleagues are responsible for
managing risk, the Risk function provides oversight and
monitoring of risk management activities, including the
implementation of the framework and adherence to its
supporting policies, standards and operational procedures. 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.
In addition, there is a process to identify and manage top and
emerging threats, which are those that could have a significant
negative impact on NatWest Group’s ability to meet its strategic
objectives. Both top and emerging threats 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 Group’s risk
management framework and its risk management practice. In
2022, the approach to risk culture was refreshed under the
new banner of Intelligent Risk Taking to re-intensify focus on
robust risk management behaviours and practices. NatWest
Group expects leaders to act as role models for strong risk
behaviours and practices building clarity, developing capability
and motivating employees to reach the required standards set
out in the Intelligent Risk Taking approach. Colleagues are
expected to:
Consistently role-model the values and behaviours in Our
Code, based on strong ethical standards which underpin
Our Purpose.
Empower others to take risks aligned to NatWest Group’s
strategy, explore issues from a fresh perspective, and tackle
challenges in new and better ways across organisational
boundaries.
Manage risk in line with appropriate risk appetite.
Ensure each decision made keeps NatWest Group,
colleagues, customers, communities and shareholders safe
and secure.
Understand their role in managing risk, remaining clear and
capable, grounded in knowledge of regulatory obligations.
Consider risk in all actions and decisions.
Escalate risks and issues early; taking action to mitigate
risks and learning from mistakes and near-misses, reporting
and communicating these transparently.
Challenge others’ attitudes, ideas and actions.
The target Intelligent Risk Taking behaviours are embedded in
NatWest Group’s Critical People Capabilities and are clearly
aligned to the core values of inclusive, curious, robust,
sustainable and ambitious. These aim to act as an effective
basis for a strong risk culture because the Critical People
Capabilities form the basis of all recruitment and selection
processes.
Training
Enabling employees to have the capabilities and confidence to
manage risk is core to NatWest Group’s learning strategy.
NatWest Group offers a wide range of learning, both technical
and behavioural, across the risk disciplines. This training may
be mandatory, role-specific or for personal development.
Mandatory learning for all staff is focused on keeping
employees, customers and NatWest Group safe. This is easily
accessed online and is assigned to each person 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 standards of
conduct that support the values. The code explains the effect of
decisions that are taken and describes the principles 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 with commercial
strategy and actions. The embedding of these principles
facilitates sound decision-making and a clear focus on good
customer outcomes.
Where appropriate, if conduct falls short of NatWest Group’s
required standards, the accountability review process is used to
assess how this should be reflected in pay outcomes for the
individuals concerned (for more information on this process
refer to page 144). The NatWest Group remuneration policy
ensures that the remuneration arrangements for all employees
reflect the principles and standards prescribed by the PRA
rulebook and the FCA handbook. Any employee falling short of
the expected standards would also be subject to internal
disciplinary policies and procedures. If appropriate, the relevant
authority would be notified.
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
179
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Risk management framework continued
Governance
Committee structure
The diagram shows NatWest Group’s risk committee structure in 2022 and the main purposes of each committee.
(1)
In addition, the Group Technical Asset & Liability Management Committee, chaired by the Group Treasurer, provides oversight of capital and balance sheet management in line with
approved risk appetite under normal and stress conditions. Reviews and challenges the financial strategy, risk management, balance sheet and remuneration and policy implications
of the Group’s pension schemes.
(2)
The EDC ESG Disclosures Steering Group has been established by the Group CFO to review NatWest Group’s Climate related and ESG Disclosures reports and contributions to any
ESG related surveys on her behalf and making recommendations to Group EDC as required.
.
NatWest Group plc Board
Reviews and approves the Enterprise-Wide Risk Management Framework (EWRMF) (including the Group’s risk appetite
framework) and approves the risk appetite for principal risks.
Considers material risks and approves, as appropriate,
actions recommended by the Group Board Risk Committee. Monitors performance against risk appetite. Receives
reports on and reviews the effectiveness of the risk management and internal control systems of NatWest Group.
Group Board Risk Committee
Provides oversight and advice to the Board
on current and future risk exposures of the
Group and its subsidiaries; future risk profile
including Group risk appetite; the approval
and effectiveness of the EWRMF and
internal controls required to manage risk.
Approves the Key Risk Policies and provides
input to remuneration decisions.
Reviews the
operating model, adequacy and
effectiveness
of Risk resource.
Group Asset & Liability
Management Committee
(1)
Supports the Group CFO in
overseeing the effective
management of NatWest Group’s
current and future balance sheet
in line with Board-approved
strategy and
risk appetite, under normal and
under stress conditions. This
includes reviewing the NatWest
Group capital plan; reviewing the
capital and leverage positions of
NatWest Group; reviewing
NatWest Group’s funding plan and
liquidity profile; reviewing and
supporting the Group CFO’s and
Group CRO’s recommendation to
Group BRC of the assumptions,
scenarios and metrics used for
stress tests and reviewing the
Group’s credit rating strategy and
performance.
Group Executive Risk
Committee
Supports the Group CEO and
other accountable executives
in discharging risk
management accountabilities.
Reviews, challenges and
debates all material risk
exposures across the Group
Reviews NatWest Group’s
EWRMF (including NatWest
Group’s risk appetite
framework) and supports the
Group CRO’s and Group
CEO’s recommendation of it to
Group BRC. It reviews the
performance of the Group
relative to risk appetite and
monitors any risk trends and
concentrations.
It considers
the Group’s risk profile relative
to current and future strategy
and oversees implementation
of the EWRMF.
Group Executive
Committee
Supports the Group CEO in
discharging her individual
accountabilities including
matters relating to
strategy, financials, capital,
risk and operational issues.
It monitors the
implementation of cultural
change within NatWest
Group and the promotion
and adoption of Group-
wide culture and values. It
supports the Group CEO in
identifying matters required
or appropriate for
escalation to the Board or
an appropriate Board
Committee and in forming
recommendations on
relevant items before their
escalation
.
Group Executive
Disclosure Committee
Supports the Group CFO in
discharging her
accountabilities relating to the
production and integrity of
NatWest Group’s financial
information and disclosures.
Ensures that all significant
NatWest Group disclosures
are accurate, complete and
fairly represent the business
and financial condition of
NatWest Group. It ensures
that there are no material
misstatements or omissions in
the NatWest Group
disclosures. It supports the
Group CRO in reviewing and
evaluating all significant
expected credit losses and the
Group CFO in reviewing and
evaluating related provisions
and valuations
.
.
Group Audit Committee
Assists the Board in carrying out its responsibilities
relating to accounting policies, internal control and
financial reporting functions, including consideration
of any relevant non-financial disclosures or related
controls which may impact the financial statements.
It reviews the effectiveness of internal controls
systems relating to financial management and
compliance with financial reporting, asset
safeguarding and accounting standards.
Risk and capital management
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Risk management structure
The diagram shows NatWest Group’s risk management structure in 2022 and key risk management responsibilities.
(1)
The Group Chief Executive Officer also performs the NWH Chief Executive Officer role.
(2)
The Group Chief Risk Officer also performs the NWH Chief Risk Officer role, is a member of NatWest Group Exco, NatWest Group ERC and an attendee at NatWest Group BRC.
(3)
The NWH Risk function provides risk management services across NWH, including to the NatWest Group Chief Risk Officer and – where agreed – to NWM and RBSI Chief Risk
Officers. These services are managed, as appropriate, through service level agreements.
(4)
The NWH Risk function is independent of the NWH customer-facing business segments 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 &
Institutional Banking (Ring-Fenced Bank); Wealth Businesses; Financial & Strategic Risk and Non-Financial Risk), the Head of Restructuring and the Chief Operating Officer report to
the NWH Chief Risk Officer. The Director of Risk, Ulster Bank Ireland DAC 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 dual 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 Risk
Officer
NWH
Chief Risk
Officer
Leads the NatWest Group Risk function. Defines and delivers
the risk, conduct, compliance and financial crime strategies.
Defines overall risk service provision requirements 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 member of the
Executive Committee.
RBSI
Chief Executive
Officer
NWH
Chief Executive
Officer
NWM
Chief Executive
Officer
RBS Chief
Executive
Group
Chief Risk
Officer
RBSI
Chief Risk
Officer
Group
Chief Executive
Officer
Leads the NWH Risk function. Responsibilities include policy,
governance, frameworks, oversight and challenge, risk
culture and reporting. Delivers risk services across NatWest
Group governed by appropriate service level agreements.
Contributes to NWH strategy as a member of the NWH
Executive Committee. Member of NatWest Group Exco.
Leads the NWM Risk function. Responsibilities include policy,
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. Responsibilities 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 management
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Risk management framework continued
Three lines of defence
NatWest Group uses the industry-standard three lines of
defence model to articulate accountabilities and responsibilities
for managing risk. This supports the embedding of effective risk
management throughout the organisation. All roles below the
CEO sit within one of the three lines. The CEO ensures the
efficient use of resources and the effective management of
risks as stipulated in the risk management framework and is
therefore considered to be outside the three lines of defence
principles.
First line of defence
The first line of defence incorporates most roles in NatWest
Group, including those in the customer-facing businesses,
Technology and Services as well as support functions such as
People and Transformation, Legal and Finance.
The first line of defence is empowered to take risks within the
constraints of the risk management framework, policies, risk
appetite statements and measures set by the Board.
The first line of defence is responsible for managing its direct
risks, and with the support of specialist functions, 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 continuous
monitoring activities to confirm that NatWest Group engages in
permissible and sustainable risk-taking activities.
The second line of defence advises on, monitors, challenges,
approves and escalates where required and reports on the risk-
taking activities of the first line, ensuring that these are within
the constraints of the risk management framework, policies,
risk appetite statements and measures set by the Board.
Third line of defence
The third line of defence is the Internal Audit function and is
independent of the first and second lines.
The third line of defence is responsible for providing
independent assurance to the Board, its subsidiary legal entity
boards and executive management on the overall design and
operating effectiveness of the risk management framework and
its components. This includes the adequacy and effectiveness
of key internal controls, governance and the risk management
in place to monitor, manage and mitigate the principal risks to
NatWest Group and its subsidiary companies achieving their
objectives.
The third line of defence executes its duties freely and
objectively in accordance with the Chartered Institute of
Internal Auditors’ Code of Ethics and International Standards
on independence and objectivity.
Risk appetite
Risk appetite defines the type and aggregate level of risk
NatWest Group is willing to accept in pursuit of its strategic
objectives and business plans. Risk 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 breaching
constraints determined by regulatory capital and liquidity
requirements, the operational environment, and from a conduct
perspective. Establishing risk capacity helps determine where
risk appetite should be set, ensuring there is a buffer between
internal risk appetite and NatWest Group’s ultimate capacity to
absorb losses.
Risk appetite framework
The risk appetite framework supports effective risk
management by promoting sound risk-taking through a
structured approach, within agreed boundaries. It also ensures
emerging threats and risk-taking activities that might be out of
appetite are identified, assessed, escalated and addressed in a
timely manner.
To facilitate this, a detailed annual review of the framework is
carried out. The review includes:
Assessing the adequacy of the framework compared to
internal and external expectations.
Ensuring the framework remains effective and acts as a
strong control environment for risk appetite.
Assessing the level of embedding of risk appetite across the
organisation.
The Board reviews and approves the risk appetite framework
annually.
Establishing risk appetite
In line with the risk appetite framework, risk appetite is
maintained across NatWest Group 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 qualitative statements of
appetite supported by risk limits and triggers that operate as a
defence against excessive risk-taking. Risk measures and their
associated limits are an integral part of the risk appetite
approach and a key part of embedding risk appetite in day-to-
day risk management decisions. A clear tolerance for each
principal risk is set in alignment with business activities.
The annual process of reviewing and updating risk appetite
statements is completed alongside the business and 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 long-
term targets, even in challenging economic environments. This
supports NatWest Group in remaining resilient and secure as it
pursues its strategic business objectives.
NatWest Group’s risk profile is continually monitored and
frequently reviewed. Management focus is concentrated on all
principal risks as well as the top and emerging threats that may
correlate to them. Risk profile relative to risk appetite is
reported regularly to senior management and the Board.
NatWest Group policies directly support the qualitative aspects
of risk appetite. They define the qualitative expectations,
guidance and standards that stipulate the nature and extent of
permissible risk-taking and are consistently applied across
NatWest Group and its subsidiaries.
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Identification and measurement
Identification and measurement within the risk management
process comprises:
Regular assessment of the overall risk profile, incorporating
market developments and trends, as well as external and
internal factors.
Monitoring of the risks associated 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 unusual
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 used across
NatWest Group. The Risk Directory is subject to annual review
to ensure it continues to fully reflect the risks that NatWest
Group faces.
Mitigation
Mitigation is a critical aspect of ensuring that risk profile
remains within risk appetite. Risk mitigation strategies are
discussed and agreed within NatWest Group.
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 to
evaluate results. Early identification, and effective management
of changes in legislation and regulation are critical to the
successful mitigation of compliance and conduct risk. The
effects of all changes are managed to ensure the timely
achievement of compliance. Those changes assessed as having
a high or medium-high impact are managed more closely.
Emerging threats 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
analysis, including the stress testing of exposures, is also carried
out.
Testing and monitoring
Specific activities relating to compliance and conduct, credit and
financial crime risks are subject to testing and monitoring by the
Risk function. This confirms to both internal and external
stakeholders – including the Board, senior management, the
customer-facing businesses, Internal Audit and NatWest Group’s
regulators – that risk policies and procedures are being
correctly implemented and that they are operating adequately
and effectively. Selected key controls are also reviewed for
adequacy and effectiveness. Thematic reviews and targeted
reviews are also carried out where relevant to ensure
appropriate customer outcomes.
Independent testing and monitoring is completed on principal
risk processes and controls impacting the financial statements –
within the scope of section 404.
The Risk Testing & Monitoring Forum assesses and validates the
annual plan as well as the ongoing programme of reviews.
Stress testing
Stress testing – capital management
Stress testing is a key risk management tool and a fundamental
component of NatWest Group’s approach to capital
management. It is used to quantify and evaluate the potential
impact of specified changes to risk factors on the financial
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 factors.
Sensitivity testing, which examines the impact of an
incremental change to one or more risk factors.
The process for stress testing consists of four broad stages:
Define
scenarios
Identify macro and NatWest Group
specific vulnerabilities and risks.
Define and calibrate scenarios to
examine risks and vulnerabilities.
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 inform
business and capital plans.
Develop and
agree
management
actions
Scenario results are analysed by
subject matter experts. Appropriate
management actions are then
developed.
Scenario results and management
actions are reviewed by the relevant
Executive Risk Committees and Board
Risk Committees. Approval of scenarios
is delegated to the NatWest Group
Board Risk Committee by the NatWest
Group Board
Stress testing is used widely across NatWest Group. The
diagram below summarises key areas of focus.
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Specific areas that involve capital management include:
Strategic financial and capital planning
– by assessing the
impact of sensitivities and scenarios on the capital plan and
capital ratios.
Risk appetite
– by gaining a better understanding of the
drivers of, and the underlying risks associated with, risk
appetite.
Risk monitoring
– by monitoring the risks and horizon-
scanning events that could potentially affect NatWest
Group’s financial strength and capital position.
Risk mitigation
– by identifying actions to mitigate risks, or
those that could be taken, in the event of adverse changes
to the business or economic environment. Principal risk
mitigating actions are documented in NatWest Group’s
recovery plan.
Reverse stress testing is also carried out in order to identify and
assess scenarios that would cause NatWest Group’s business
model to become unviable. Reverse stress testing allows
potential vulnerabilities in the business model to be examined
more fully.
Capital sufficiency – going concern forward-looking view
Going concern capital requirements are examined on a
forward-looking basis – including as part of the annual
budgeting process – by assessing the resilience of capital
adequacy and leverage ratios under hypothetical future states.
These assessments include assumptions about regulatory and
accounting factors (such as IFRS 9). They incorporate
economic variables and key assumptions on balance sheet and
P&L drivers, such as impairments, to demonstrate that NatWest
Group and its operating subsidiaries maintain sufficient capital.
A range of future states are tested. In particular, capital
requirements are assessed:
Based on a forecast of future business performance, given
expectations of economic and market conditions over the
forecast period.
Based on a forecast of future business performance under
adverse economic and market conditions over the forecast
period. Scenarios of different severity may be examined.
The potential impact of normal and adverse economic and
market conditions on capital requirements is assessed through
stress testing, the results of which are not only used widely
across NatWest Group but also by the regulators to set specific
capital buffers. NatWest Group takes part in stress tests run by
regulatory authorities to test industry-wide vulnerabilities under
crystallising global and domestic systemic risks.
Stress and peak-to-trough movements are used to help assess
the amount of capital NatWest Group needs to hold in stress
conditions in accordance with the capital risk appetite
framework.
Internal assessment of capital adequacy
An internal assessment of material risks is carried out annually
to enable an evaluation of the amount, type and distribution of
capital required to cover these risks. This is referred to as the
Internal Capital Adequacy Assessment Process (ICAAP). The
ICAAP consists of a point-in-time assessment of exposures and
risks at the end of the financial year together with a forward-
looking stress capital assessment. The ICAAP is approved by
the Board and submitted to the PRA.
The ICAAP is used to form a view of capital adequacy
separately to the minimum regulatory requirements. The ICAAP
is used by the PRA to assess NatWest Group’s specific capital
requirements through the Pillar 2 framework.
Capital allocation
NatWest Group has mechanisms to allocate capital across its
legal entities and businesses. These aim to optimise the use of
capital resources taking into account applicable regulatory
requirements, strategic and business objectives and risk
appetite. The framework for allocating capital is approved by
the CFO with support from the Asset & Liability Management
Committee.
Governance
Capital management is subject to substantial review and
governance. The Board approves the capital plans, including
those for key legal entities and businesses 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 stress test the
liquidity and funding risks on the balance sheet. Limit
frameworks are in place to control the level of liquidity risk,
asset and liability mismatches and funding concentrations.
Liquidity and funding risks are reviewed at significant legal
entity and business levels daily, with performance reported to
the Asset & Liability Management Committee on a regular
basis. Liquidity Condition Indicators are monitored daily. This
ensures any build-up of stress is detected early and the
response escalated appropriately through recovery planning.
Internal assessment of liquidity
Under the liquidity risk management framework, NatWest
Group maintains the Internal Liquidity Adequacy Assessment
Process. This includes assessment of net stressed liquidity
outflows under a range of severe but plausible stress scenarios.
Each scenario evaluates either an idiosyncratic, market-wide or
combined stress event as described in the table below.
Type
Description
Idiosyncratic
scenario
The market perceives NatWest Group to be
suffering from a severe stress event, which
results in an immediate assumption 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 affected 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 stress occurring
at once, severely affecting funding markets
and the liquidity of some assets.
NatWest Group uses the most severe outcome to set the
internal stress testing scenario which underpins its internal
liquidity risk appetite. This complements the regulatory liquidity
coverage ratio requirement.
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Stress testing – recovery and resolution planning
The NatWest Group recovery plan explains how NatWest Group
and its subsidiaries – as a consolidated group – would identify
and respond to a financial stress event and restore its financial
position so that it remains viable on an ongoing basis.
The recovery plan ensures risks that could delay the
implementation of a recovery strategy are highlighted and
preparations are made to minimise the impact of these risks.
Preparations include:
Developing a series of recovery indicators to provide early
warning of potential stress events.
Clarifying roles, responsibilities and escalation 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 different stress
conditions.
Appointing dedicated option owners to reduce the risk of
delay and capacity concerns.
The plan is intended to enable NatWest Group to maintain
critical services and products it provides to its customers,
maintain its core business lines and operate within risk appetite
while restoring NatWest Group’s financial condition. It is
assessed for appropriateness on an ongoing basis and is
updated annually. The plan is reviewed and approved by the
Board prior to submission to the PRA each year. Individual
recovery plans are also prepared for NatWest Holdings Limited,
NatWest Markets Plc, RBS International Limited, and NatWest
Markets N.V.. These plans detail the recovery options, recovery
indicators and escalation routes for each entity.
Fire drill simulations of possible recovery events are used to
test the effectiveness of NatWest Group and individual legal
entity recovery plans. The fire drills are designed to replicate
possible financial stress conditions and allow senior
management to rehearse the responses and decisions that may
be required in an actual stress event. The results and lessons
learnt from the fire drills are used 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 assessment of its
preparations for resolution, submit a report of the assessment
to the PRA and publish a summary of this report.
Resolution would be implemented if NatWest Group was
assessed by the UK authorities to have failed and the
appropriate regulator put it into resolution. The process of
resolution is owned and implemented by the Bank of England
(as the UK resolution authority). NatWest Group ensures
ongoing maintenance and enhancements of its resolution
capabilities, in line with 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 overview of NatWest
Group’s banking book interest rate exposure. The report
includes detailed product information analysed by interest rate
driver and other characteristics, including accounting
classification, currency and counterparty type.
Scenario analysis based on hypothetical 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 internal 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, equity risk
and accounting volatility risk. The ICAAP is completed with a
combination of value and earnings 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 historical volatility,
produced with a 99% confidence level. Methodologies are
reviewed by NatWest Group Model Risk and the results are
approved by the NatWest Group Technical Asset & Liability
Management Committee.
Non-traded market risk stress results are combined with those
for other risks into the capital plan presented to the Board. The
cross-risk capital planning process is conducted once a year,
with a planning horizon of five years. The scenario 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. Vulnerability-
based stress testing is used for internal management
information and is not subject to limits. The results for relevant
scenarios are reported to senior management.
Traded market risk
NatWest Group carries out regular market risk stress testing to
identify vulnerabilities and potential losses in excess of, or not
captured in, value-at-risk. The calculated stresses measure the
impact of changes in risk factors on the fair values of the
trading portfolios.
NatWest Group conducts historical, macroeconomic and
vulnerability-based stress testing. Historical stress testing is a
measure that is used for internal management. Using the
historical simulation framework employed for value-at-risk, the
current portfolio is stressed using historical data since 1
January 2005. This methodology simulates the impact of the
99.9 percentile loss that would be incurred by historical risk
factor movements over the period, assuming variable holding
periods specific to the risk factors and the businesses.
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Historical stress tests form part of the market risk limit
framework and their results are reported regularly to senior
management. Macroeconomic stress tests are carried out
periodically as part of the bank-wide, cross-risk capital
planning process. The scenario narratives are translated into
risk factor shocks using historical events and insights by
economists, risk managers and the first line.
Market risk stress results are combined with those for other
risks into the capital plan presented to the Board. The cross-
risk capital planning process is conducted once a year, with a
planning horizon of five years. The scenario 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. Vulnerability-
based stress testing is used for internal management
information and is not subject to limits. The results for relevant
scenarios are reported to senior management.
Internal scenarios
During 2022, NatWest Group ran a number of internal
scenarios developed in the immediate aftermath of Russia’s
invasion of Ukraine.
These scenarios considered different outcomes to the conflict,
including an assumed broadening of the conflict, and how
those might manifest in terms of macroeconomic impact. This
included commodity market and associated inflationary
pressures, supply chain impacts, financial sector linkages and
broader knock-on impacts to the UK labour and asset markets.
Impacts on operational aspects to NatWest Group were also
considered.
Applying the macro-scenarios to NatWest Group’s earnings,
capital, liquidity and funding positions did not result in a breach
of any regulatory thresholds.
Regulatory stress testing
The Bank of England returned to the annual cyclical scenario
(ACS) stress test framework in 2022 and published the scenario
on 26 September 2022. This follows two years of COVID-19
crisis-related stress testing and the decision to postpone the
test in March following Russia’s invasion of Ukraine. NatWest
Group has participated in this stress test and the results will be
published in summer 2023 and, along with other relevant
information, will be used to help inform NatWest Group capital
buffers (both the UK countercyclical capital buffer rate and PRA
buffers).
The 2022 stress test aims to assess the impact of a UK and
global macroeconomic stress on UK banks, spanning a five-
year period from Q3 2022 to Q2 2027. It is a coherent ‘tail risk’
scenario designed to be severe and broad enough to assess the
resilience of UK banks to a range of adverse shocks.
The stress scenario is broadly similar to the 2019 ACS and
more severe overall than the global financial crisis, with the key
difference being elevated levels of inflation. Annual UK inflation
averages around 11% over the first three years of the scenario,
while peaking at 17% in early 2023 and does not begin to fall
until the second half of the year.
The stress is based on an end-of-June 2022 balance sheet
starting position.
Further details on the scenario and ACS stress test can be
found at https://www.bankofengland.co.uk/stress-
testing/2022/key-elements-of-the-2022-stress-test
Following the UK’s exit from the European Union on 31
December 2020, only relevant European subsidiaries of
NatWest Group will take part in the European Banking
Authority stress tests going forward. NatWest Group itself will
not participate.
NatWest Group also took part in the Bank of England’s Climate
Biennial Exploratory Scenario conducted in late 2021 and early
2022. Refer to page 69 for further details.
Risk and capital management
continued
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Credit risk
Definition
(audited)
Credit risk is the risk that customers, counterparties or issuers
fail to meet their contractual obligation to settle outstanding
amounts.
Sources of risk
(audited)
The principal sources of credit risk for NatWest Group are
lending, off-balance sheet products, derivatives and securities
financing, and debt securities. NatWest Group is also exposed to
settlement risk through foreign exchange, trade finance and
payments activities.
Key developments in 2022
Across both Personal and Wholesale, the credit profile
remains stable, but the outlook is uncertain from inflationary
pressure, compounded by rising interest rates and
geopolitical tensions. NatWest Group has yet to see signs of
financial stress materially affecting customers’ ability to
repay.
Expected credit loss (ECL) reduced during 2022, reflecting
the phased withdrawal of Ulster Bank RoI, plus continued
positive trends in portfolio performance alongside a related
net release of judgemental post model adjustments and
write-off activity. Overall, ECL coverage decreased due to
the withdrawal, a change in product mix and a reduction in
judgemental post model adjustments which more than offset
increases from the deteriorating economic outlook.
Personal lending grew as a result of strong mortgage and
resilient unsecured lending demand. Personal lending criteria
were unwound to a level similar to pre-COVID-19 norms
during 2022. Affordability assumptions remain under
continuous review and adjustments were made to ensure
new business continues to be assessed appropriately.
In Wholesale, balance sheet reduction in 2022 compared to
2021 was mainly due to a decrease in central items held in
the course of treasury related management activities. There
was growth in Commercial & Institutional. Sector appetite is
reviewed regularly and where appropriate adjusted for those
sectors most affected by current economic and geopolitical
conditions.
A number of high materiality IFRS 9 models were
redeveloped in 2022, most notably all probability of default
(PD) and some loss given default (LGD) models for Personal
lending and the two most material economic response
models for Wholesale lending.
NatWest Group continued to progress embedding climate
change considerations in credit assessment and monitoring,
including scenario analysis to assess the materiality of
climate change risks.
Governance
(audited)
The Credit Risk function provides oversight and challenge of
frontline credit risk management activities.
Governance activities include:
Defining credit risk appetite measures 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 mitigate them.
Approving and monitoring operational limits for business
segments and credit limits for customers.
Oversight of the first line of defence to ensure that credit
risk remains within the appetite set by the Board and that
controls are being operated adequately and effectively.
Assessing the adequacy of ECL provisions including
approving key IFRS 9 inputs (such as significant increase in
credit risk (SICR) thresholds) and any necessary in-model
and post model adjustments through NatWest Group and
business unit provisions and model committees.
Development and approval of credit grading models.
Risk appetite
Credit risk appetite aligns to the strategic risk appetite set by
the Board and is set and monitored through risk appetite
frameworks tailored to NatWest Group’s Personal and
Wholesale segments.
Personal
The Personal credit risk appetite framework sets limits that
control the quality and concentration of both existing and new
business for each relevant business segment.
These risk appetite measures consider the segments’ ability to
grow sustainably and the level of losses expected under stress.
Credit risk is further controlled through operational limits
specific to customer or product characteristics.
Wholesale
For Wholesale credit, the framework has been designed to
reflect factors that influence the ability to operate within risk
appetite. Tools such as stress testing and economic capital are
used to measure credit risk volatility and develop links between
the framework and risk appetite limits.
Four formal frameworks are used, classifying, measuring and
monitoring credit risk exposure across single name, sector and
country concentrations and product and asset classes with
heightened risk characteristics.
The framework is supported by a suite of transactional
acceptance standards that set out the risk parameters within
which businesses should operate.
Credit policy standards are in place for both the Wholesale and
Personal portfolios. They are expressed as a set of mandatory
controls.
Identification and measurement
Credit stewardship
(audited)
Risks are identified through relationship management and credit
stewardship of customers and portfolios. Credit risk stewardship
takes place throughout the customer relationship, beginning
with the initial approval. It includes the application of credit
assessment standards, credit risk mitigation and collateral,
ensuring that credit documentation is complete and appropriate,
carrying out regular portfolio or customer reviews and problem
debt identification and management.
Asset quality
(audited)
All credit grades map to an asset quality (AQ) scale, used for
financial reporting. This AQ scale is based on Basel probability
of defaults. Performing loans are defined as AQ1-AQ9 (where
the 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 defaulted when the payment status becomes 90
days 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 obligations of customers
under derivative and securities financing transactions.
NatWest Group mitigates counterparty credit risk through
collateralisation and netting agreements, which allow amounts
owed by NatWest Group to a counterparty to be netted against
amounts the counterparty owes NatWest Group.
Risk and capital management
continued
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Credit risk continued
Mitigation
Mitigation techniques, as set out in the appropriate credit
policies and transactional acceptance standards, are used in the
management of credit portfolios across NatWest Group. These
techniques mitigate credit concentrations in relation to an
individual customer, a borrower group or a collection of related
borrowers. Where possible, customer credit balances are netted
against obligations. Mitigation tools can include structuring a
security interest in a physical or financial asset, the use of credit
derivatives including credit default swaps, credit-linked debt
instruments and securitisation structures, and the use of
guarantees and similar instruments (for example, credit
insurance) from related and third parties.
Property is used to mitigate credit risk across a number of
portfolios, in particular residential mortgage lending and
commercial real estate (CRE).
The valuation methodologies for collateral in the form of
residential mortgage property and CRE are detailed below.
Residential mortgages
NatWest Group takes collateral in the
form of residential property to mitigate the credit risk arising
from mortgages. NatWest Group values residential property
individually during the loan underwriting process, either by
obtaining an appraisal by a suitably qualified appraiser (for
example, Royal Institution of Chartered Surveyors (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 Retail Banking
UK residential property values quarterly using country
(Scotland, Wales and Northern Ireland) or English regional
specific Office for National Statistics House Price indices.
Within the Private Banking and RBSI segments, properties
securing loans greater than £2.5 million or €3 million are
revalued every three years.
The current indexed value of the property is a component of the
ECL provisioning calculation.
Commercial real estate valuations
– NatWest Group has an
actively managed panel of chartered surveying firms that cover
the spectrum of geography and property sectors in which
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. In the
UK, an independent third-party market indexation is applied to
update external valuations for commercial property once they
are more than a year old. For obligations in excess of £2.5
million and where the charged property has a book value in
excess of £0.5 million, a formal valuation review is
commissioned at least every three years. In the Republic of
Ireland, assets are revalued in line with the Central Bank of
Ireland threshold requirements, which permits indexation for
lower value residential assets, but demands regular valuations
for higher value assets.
Assessment and monitoring
Practices for credit stewardship – including credit assessment,
approval and monitoring as well as the identification and
management of problem debts – differ between the Personal
and Wholesale portfolios.
Personal
Personal customers are served through a lending approach that
entails offering a large number of small-value loans. To ensure
that these lending decisions are made consistently, NatWest
Group analyses internal credit information as well as external
data supplied by credit reference agencies (including historical
debt servicing behaviour of customers with respect to both
NatWest Group and other lenders). NatWest Group then sets its
lending rules accordingly, developing different rules for different
products.
The process is then largely automated, with each customer
receiving an individual credit score that reflects both internal
and external behaviours and this score is compared with the
lending rules set. For relatively high-value, complex personal
loans, including some residential mortgage lending, specialist
credit managers make the final lending decisions. These
decisions are made within specified delegated authority limits
that are issued dependent on the experience of the individual.
Underwriting standards and portfolio performance are
monitored on an ongoing basis to ensure they 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
operational limits. The limits apply to a range of credit risk-
related measures including projected credit default rates across
products and the loan-to-value (LTV) ratio of the mortgage
portfolios. Where operational limits identify areas of concern
management action is taken to adjust credit or business
strategy.
Wholesale
Wholesale customers – including corporates, banks and other
financial institutions – are grouped by industry sectors 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 transaction. Credit
approvals are subject to environmental, social and governance
risk policies which restrict exposure to certain highly carbon
intensive industries as well as those with potentially heightened
reputational impacts. Customer specific climate risk
commentary is now mandatory.
In response to COVID-19, a new framework was introduced to
categorise clients in a consistent manner across the Wholesale
portfolio, based on the effect of COVID-19 on their financial
position and outlook in relation to the sector risk appetite. This
framework has been retained, updated and aligned with the
Risk of Credit Loss framework (further details below) to consider
viability impacts more generally beyond those directly related to
COVID-19 and classification via the framework is now
mandatory and must be refreshed at least annually. The
framework extends to all Wholesale borrowing customers in
assessing whether customers exhibit a SICR, if support is
considered to be granting forbearance and the time it would
take for customers to return to operating within transactional
acceptance standards.
Risk and capital management
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Credit risk continued
For lower risk transactions below specific thresholds, credit
decisions can be approved through self-sanctioning within the
business. This process is facilitated through an auto-decision
making system, which utilises scorecards, strategies and policy
rules.
For all other transactions, credit is only granted to customers
following joint approval by an approver from the business and
the credit risk function or by two credit officers. The joint
business and credit approvers act within a delegated approval
authority under the Wholesale Credit Authorities Framework
Policy. The level of delegated authority 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 accountable
for the quality of each decision taken, although the credit risk
approver holds ultimate sanctioning authority.
Transactional acceptance standards provide detailed
transactional lending and risk acceptance 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.
Credit grades (PD) and LGD are reviewed and if appropriate
reapproved annually. The review process assesses borrower
performance, including reconfirmation or adjustment of risk
parameter estimates; the adequacy of security; compliance with
terms and conditions; and refinancing risk.
Problem debt management
Personal
Early problem identification
Pre-emptive triggers are in place to help identify customers that
may be at risk of being in financial difficulty. These triggers are
both internal, using NatWest Group data, and external using
information from credit reference agencies. Proactive contact is
then made with the customer to establish if they require help
with managing their finances. By adopting this approach, the
aim is to prevent a customer’s financial position deteriorating
which may then require intervention from the Collections and
Recoveries teams.
Personal customers experiencing financial difficulty are
managed by the Collections team. If the Collections team is
unable to provide appropriate support after discussing suitable
options with the customer, management of that customer
moves to the Recoveries team.
If at any point in the collections
and recoveries process, the customer is identified as being
potentially vulnerable, the customer will be separated from the
regular process and supported by a specialist team to ensure
the customer receives appropriate support for their
circumstances.
Collections
When a customer exceeds an agreed limit or misses a regular
monthly payment the customer is contacted by NatWest Group
and requested to remedy the position. If the situation is not
regularised then, where appropriate, 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 short-term
account restructuring, refinance loans and forbearance which
can include interest suspension and ‘breathing space’. All
treatments available to customers experiencing financial
difficulties are reviewed to ensure they remain appropriate for
customers impacted by current economic conditions.
In the event that an affordable and sustainable agreement with
a customer cannot be reached, the debt will transition to the
Recoveries team.
For provisioning purposes, under IFRS 9, exposure to customers
managed by the Collections team is categorised as Stage 2 and
subject to a lifetime loss assessment, unless it is 90 days past
due or has triggered any other unlikeliness to pay indicators, in
which case it is categorised as Stage 3.
Recoveries
The Recoveries team will issue a notice of intention to default to
the customer and, if appropriate, a formal demand, while also
registering the account with credit reference agencies where
appropriate. Following this, the customer’s debt may then be
placed with a third-party debt collection agency, or alternatively
a solicitor, in order to agree an affordable repayment plan with
the customer. An option that may also be considered, is the sale
of unsecured debt. Exposures subject to formal debt recovery
are defaulted and, under IFRS 9, categorised as Stage 3.
Wholesale
Early problem identification
Each segment and sector have defined early warning indicators
to identify customers experiencing financial difficulty, and to
increase monitoring if needed. Early warning indicators may be
internal, such as a customer’s bank account activity, or
external, such as a publicly-listed customer’s share price. If
early warning indicators show a customer is experiencing
potential or actual difficulty, or if relationship managers or credit
officers identify other signs of financial difficulty, they may
decide to classify the customer within the Risk of Credit Loss
framework. Broader macro-economic trends including
commodity prices, foreign exchange rates and consumer and
government spend are also tracked, helping inform decisions on
sector risk appetite. Customer level early warning indicators are
regularly reviewed to ensure alignment with prevailing
economic conditions, ensuring both the volume and focus of
alerts is aligned to the point-in-time risk within each sector.
The aligned Risk of Credit Loss and viability framework
This framework focuses on all Wholesale customers to provide
early identification of credit deterioration, support intelligent
risk-taking, ensure fair and consistent customer outcomes and
provide key insights into Wholesale lending portfolios. Expert
judgment is applied by experienced credit risk officers to classify
cases into categories that reflect progressively deteriorating
credit risk to NatWest Group. There are two classifications in the
framework that apply to non-defaulted customers who are in
financial stress – Heightened Monitoring and Risk of Credit Loss.
For the purposes of provisioning, all exposures categorised as
Heightened Monitoring or Risk of Credit Loss are categorised as
Stage 2 and subject to a lifetime loss assessment. The
framework also applies to those customers that have met
NatWest Group’s default criteria (AQ10 exposures). Defaulted
exposures are categorised as Stage 3 impaired for provisioning
purposes.
Heightened Monitoring customers are performing customers
that have met certain characteristics, which have led to
significant credit deterioration. Collectively, characteristics
reflect circumstances that may affect the customer’s ability to
meet repayment obligations. Characteristics include trading
issues, covenant breaches, material PD downgrades and past
due facilities.
Heightened Monitoring customers require pre-emptive actions
(outside the customer’s normal trading patterns) to return or
maintain their facilities within NatWest Group’s current risk
appetite.
Risk and capital management
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Credit risk continued
Risk of Credit Loss customers are performing customers that
have met the criteria for Heightened 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 successful.
Once classified as either Heightened Monitoring or Risk of Credit
Loss, a number of mandatory actions are taken in accordance
with policies. Actions include a review of the customer’s credit
grade, facility and security documentation and the valuation of
security. Depending on the severity of the financial difficulty and
the size of the exposure, the customer relationship strategy is
reassessed by credit officers, by specialist credit risk or
relationship management units in the relevant business, or by
Restructuring.
Agreed customer management strategies are regularly
monitored by both the business and credit teams. The largest
Risk of Credit Loss exposures are regularly reviewed by a Risk
of Credit Loss forum. The forum members are experienced
credit, business and restructuring specialists. The purpose of the
forum is to review and challenge the strategies undertaken for
customers that pose the largest risk of credit loss to NatWest
Group.
Appropriate corrective action is taken when circumstances
emerge that may affect the customer’s ability to service its debt
(refer to Heightened Monitoring characteristics). Corrective
actions may include granting a customer various types of
concessions. Any decision to approve a concession will be a
function of specific appetite, the credit quality of the customer,
the market environment and the loan structure and security. All
customers granted forbearance are classified Heightened
Monitoring as a minimum.
Other potential outcomes of the relationship review are to:
return the customer to a satisfactory status, offer additional
lending and continue monitoring, transfer the relationship to
Restructuring if appropriate, or exit the relationship.
The aligned Risk of Credit Loss and viability framework does not
apply to problem debt management for business banking
customers. These customers are, where necessary, managed by
specialist problem debt management teams, depending on the
size of exposure or by the business banking recoveries team
where a loan has been impaired.
Restructuring
Where customers are categorised as Risk of Credit Loss and the
lending exposure is above £1 million, relationships are supported
by the Restructuring team. The objective of Restructuring is to
protect NatWest Group’s capital. Restructuring does this by
working with corporate and commercial customers in financial
difficulty to help them understand their options and how their
restructuring or repayment strategies can be delivered. Helping
viable customers return to financial health and restoring a
normal banking relationship is always the preferred outcome,
however, where this is not possible, NatWest Group will work
with customers to achieve a solvent outcome. Throughout this
period, the mainstream relationship manager will remain an
integral part of the customer relationship. Insolvency is
considered as a last resort and if deemed necessary, NatWest
Group will work to recover its capital in a fair and efficient
manner, while upholding the fair treatment of customers and
NatWest Group’s core values.
Forbearance
(audited)
Forbearance takes place when a concession 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 restore the customer
to financial health while minimising risk. To ensure that
forbearance is appropriate for the needs of the customer,
minimum standards are applied when assessing, recording,
monitoring and reporting forbearance.
A credit exposure may be forborne more than once, generally
where a temporary concession has been granted and
circumstances warrant another temporary or permanent
revision of the loan’s terms.
Loans are reported as forborne until they meet the exit criteria
as detailed in the appropriate regulatory guidance. These
include being classified as performing for two years since the
last forbearance event, making regular repayments and the
loan/debt being less than 30 days past due.
Types of forbearance
Personal
In the Personal portfolio, forbearance may involve payment
concessions and loan rescheduling (including extensions in
contractual maturity), capitalisation of arrears. Forbearance
support is provided for both mortgages and unsecured lending.
Wholesale
In the Wholesale portfolio, forbearance may involve covenant
waivers, amendments to margins, payment concessions and
loan rescheduling (including extensions in contractual maturity),
capitalisation of arrears, and debt forgiveness or debt-for-equity
swaps.
Monitoring of forbearance
Personal
For Personal portfolios, forborne loans are separated and
regularly monitored and reported while the forbearance
strategy is implemented, until they exit forbearance.
Wholesale
In the Wholesale portfolio, customer PDs and facility LGDs are
reassessed prior to finalising any forbearance arrangement. The
ultimate outcome of a forbearance strategy is highly dependent
on the co-operation of the borrower and a viable business or
repayment outcome. Where forbearance is no longer
appropriate, NatWest Group will consider other options such as
the enforcement of security, insolvency proceedings or both,
although these are options of last resort.
Provisioning requirements on forbearance are detailed in the
Provisioning for forbearance section.
Credit grading models
Credit grading models is the collective term used to describe all
models, frameworks and methodologies used to calculate 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 calculation or wider risk
management purposes.
Risk and capital management
continued
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Credit risk continued
Impairment, provisioning and write-offs
(audited)
In the overall assessment of credit risk, impairment provisioning
and write-offs are used as key indicators of credit quality.
NatWest Group’s IFRS 9 provisioning models, which use existing
Basel models as a starting point, incorporate term structures
and forward-looking information. Regulatory conservatism
within the Basel models has been removed as appropriate to
comply with the IFRS 9 requirement for unbiased ECL estimates.
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 indicators that have most
influence on credit loss for each portfolio and the severity of
impact (this leverages existing stress testing models which
are reviewed annually).
The build of term structures to extend the determination of
the risk of loss beyond 12 months that will influence the
impact of lifetime loss for exposures in Stage 2.
Model application:
The assessment of the SICR and the formation of a
framework capable of consistent application.
The determination of asset lifetimes that reflect behavioural
characteristics while also representing management actions
and processes (using historical data and experience).
The choice of forward-looking economic scenarios and their
respective probability weights.
Refer to Accounting policy 2.3 for further details.
IFRS 9 ECL model design principles
(audited)
Modelling of ECL for IFRS 9 follows the conventional approach
to divide the estimation of credit losses into its component parts
of PD, LGD and EAD.
To meet IFRS 9 requirements, the PD, LGD and EAD parameters
differ from their Pillar 1 internal ratings based (IRB) 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 reflect actual economic
conditions at the reporting date instead of long-run average
or downturn conditions.
Forward-looking – IFRS 9 PD estimates and, where
appropriate, EAD and LGD estimates reflect forward-looking
economic conditions.
Lifetime measurement – IFRS 9 PD, LGD and EAD are
provided as multi-period term structures up to exposure
lifetimes instead of over a fixed one-year horizon.
IFRS 9 requires that at each reporting date, an entity shall
assess whether the credit risk on an account has increased
significantly since initial recognition. Part of this assessment
requires a comparison to be made between the current lifetime
PD (i.e. the PD over the remaining lifetime at the reporting date)
and the equivalent lifetime PD as determined at the date of
initial recognition.
For assets originated before IFRS 9 was introduced, comparable
lifetime origination PDs did not exist. These have been
retrospectively created using the relevant model inputs
applicable at initial recognition.
PD estimates
Personal models
Personal PD models follow a discrete multi-horizon survival
approach, predicting quarterly PDs up to lifetime at account
level, with a key driver being scores from related IRB PD
models. Forward-looking economic information is brought in by
economic response models, which leverage the existing stress
test model suite. The current suite of PD models was introduced
in 2022 replacing the previous, first-generation models to
remediate a range of model weaknesses.
Wholesale models
Wholesale PD models use a point-in-time/through-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 credit cycle indices (CCIs) for a
comprehensive set of region/industry segments. Further detail
on CCIs is provided in the Economic loss drivers section.
One year point-in-time PDs are extended 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 IRB LGD models with bespoke adjustments to
ensure estimates are unbiased and, where relevant, forward-
looking.
Personal
Forward-looking information has only been incorporated for the
secured portfolios, where changes in property prices can be
readily accommodated. Analysis has shown minimal impact of
economic conditions on LGDs for the other Personal portfolios.
Wholesale
Forward-looking economic information is incorporated into LGD
estimates using the existing CCI framework. For low default
portfolios, including sovereigns and banks, loss data is too
scarce to substantiate estimates that vary with economic
conditions. Consequently, for these portfolios, LGD estimates
are assumed to be constant throughout the projection 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 incorporating a term structure
based on time to default.
Amortising products use an amortising schedule, where a
formula is used to calculate the expected balance based on
remaining terms and interest rates.
Analysis has indicated that there is minimal impact on EAD
arising from changes in the economy for all Personal portfolios
except mortgages. Therefore, forward-looking information is
only incorporated in the mortgage EAD model (through forecast
changes in interest rates).
Wholesale
For Wholesale, EAD values are projected using product specific
credit conversion factors (CCFs), closely following the product
segmentation and approach of the respective Basel model.
However, the CCFs are estimated over multi-year time horizons
and contain no regulatory conservatism or downturn
assumptions.
Risk and capital management
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Credit risk continued
No explicit forward-looking information is incorporated, on the
basis of analysis showing the temporal variation in CCFs is
mainly attributable to changes in exposure management
practices rather than economic conditions.
Governance and post model adjustments
(audited)
The IFRS 9 PD, EAD and LGD models are subject to NatWest
Group’s model risk policy that stipulates periodic model
monitoring, periodic re-validation and defines approval
procedures and authorities according to model materiality.
Various post model adjustments were applied where
management judged they were necessary to ensure an
adequate level of overall ECL provision. All post model
adjustments were subject to formal approval through
provisioning governance, and were categorised as follows
(business level commentary is provided below):
Deferred model calibrations – ECL adjustments where PD
model monitoring indicated that actual defaults 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 on default levels in the past
two years. As a consequence, any potential ECL release was
deferred and retained on the balance sheet until modelled
ECL levels are affirmed by new model parallel runs or
similar analyses.
Economic uncertainty – ECL adjustments primarily arising
from uncertainties associated with the high inflation
environment as well as supply chain disruption, along with
the residual effect of COVID-19 and government support
schemes. In all cases, management judged that additional
ECL was required until further credit performance data
became available as the full effects of these issues matures.
Other adjustments – ECL adjustments where it was judged
that the modelled ECL required amendment.
Post model adjustments will remain a key focus area of NatWest
Group’s ongoing ECL adequacy assessment process. A holistic
framework has been established including reviewing a range of
economic data, external benchmark information and portfolio
performance trends with a particular focus on segments of the
portfolio (both commercial and consumer) that are likely to be
more susceptible to the high inflation environment and supply
chain disruption.
Risk and capital management
continued
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Credit risk continued
ECL post model adjustments
The table below shows ECL post model adjustments.
Retail Banking
Mortgages
Other
Private
Banking
Commercial &
Institutional
Central items (1)
Total
2022
£m
£m
£m
£m
£m
£m
Economic uncertainty
102
51
6
191
2
352
Other adjustments
8
20
16
15
59
Total
110
71
6
207
17
411
Of which:
- Stage 1
62
27
3
63
155
- Stage 2
32
44
3
139
16
234
- Stage 3
16
5
1
22
2021
Deferred model calibrations
58
97
62
2
219
Economic uncertainty
60
99
5
391
29
584
Other adjustments
37
5
156
198
Total
155
196
5
458
187
1,001
Of which:
- Stage 1
9
5
15
5
34
- Stage 2
126
164
5
443
33
771
- Stage 3
20
27
149
196
(1)
Excludes £18 million (2021 – £49 million) of post model adjustments (other £18 million (2021 – mortgages £4 million; other £45 million)) for Ulster Bank RoI disclosed as transfers to
disposal groups.
Post model adjustments have reduced significantly since 31
December 2021, with notable shifts in all categories. This
reflected:
The reclassification of the Ulster Bank RoI mortgage
portfolio, in Q3 2022, from amortised cost to fair value
through profit or loss and continued activity on the strategic
shift to exit the market.
Removal of deferred model calibration post model
adjustments following the implementation of new models as
well as COVID-19 adjustments no longer being required.
Economic uncertainty adjustments significantly reduced as
many COVID-19 adjustments were no longer required, plus
the deteriorating economic outlook and improved modelling
approaches, resulted in increases in modelled ECL.
Retail Banking
– The judgemental post model adjustment
for deferred model calibrations of £155 million held at 31
December 2021 was no longer required in the second half
of 2022. This was due, firstly, to the removal of the
mortgage element because of the implementation of a new
IFRS 9 PD model in Q1 2022. Furthermore, the
implementation of new PD models on unsecured portfolios
implemented at H1 2022 negated the need for management
judgement on PD calibration adjustments.
The post model adjustments for economic uncertainty were
held at a broadly consistent level to 31 December 2021,
totalling £153 million (2021 – £159 million). The primary
element of the economic uncertainty adjustment was a
£127 million ECL uplift to capture the risk on segments of
the Retail portfolio that are more susceptible to the effects
of a high inflation environment and the impacts on
affordability.
Risk and capital management
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This focuses on key affordability lenses, including customers
with lower incomes in fuel poverty, over-indebted borrowers
and customers vulnerable to a potential mortgage rate shock
impact on their affordability. This adjustment superseded the
previously held £26 million for COVID-19 payment holiday high-
risk customers and the £69 million judgemental ECL release
holdback at 31 December 2021. The current post model
adjustment allocates more ECL to Stage 1 given the forward-
looking nature of the risks on affordability driven by the high
inflation environment, whereas the previous COVID-19 post
model adjustments were focused on Stage 2, due to specific
customer events (for example, high-risk payment holiday cases
migrated into Stage 2).
Other judgmental overlays included a £20 million uplift to
reflect forward-looking provisions relating to credit cards EAD
and limit utilisation modelling considerations. There is also an
ECL adjustment for higher risk residential interest only
mortgages of £7 million. The £14 million post model adjustment
previously held for cladding risk was removed due to
management’s view on the positive developments in this
segment.
Commercial & Institutional
– The post model adjustment for
economic uncertainty reduced from £391 million to £191 million
during the year. It included an overlay of £108 million to cover
the residual risks from COVID-19, including the risk that
government support schemes could affect future recoveries
and concerns surrounding associated debt, to customers that
have utilised government support schemes. Inflation and supply
chain issues present significant headwinds for a number of
sectors which are not fully captured in the models. An £83
million mechanistic adjustment, via a sector-level downgrade,
was applied to the sectors that were considered most at risk
from these headwinds.
The judgemental overlay for deferred model calibrations on the
business banking portfolio was removed as COVID-19 no longer
impedes the mechanistic modelling approach.
Other adjustments included an overlay of £13 million to
mitigate the effect of operational timing delays in the
identification and flagging of a SICR.
Significant increase in credit risk (SICR)
(audited)
Exposures that are considered significantly credit deteriorated
since initial recognition are classified in Stage 2 and assessed
for lifetime ECL measurement (exposures not considered
deteriorated carry a 12 month ECL). NatWest Group has
adopted a framework to identify deterioration based primarily
on relative movements in lifetime PD supported by additional
qualitative backstops. The principles applied are consistent
across NatWest Group and align to credit 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 based on the relative
deterioration in forward-looking lifetime PD and is assessed
monthly. To assess whether credit deterioration has
occurred, the residual lifetime PD at balance sheet date
(which PD is established at date of initial recognition (DOIR))
is compared to the current PD. If the current lifetime PD
exceeds the residual origination PD by more than a
threshold amount, deterioration is assumed to have
occurred and the exposure transferred into Stage 2 for a
lifetime loss assessment. For Wholesale, 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 deteriorate more than
higher risk exposures, as outlined in the following table:
Qualitative high-risk backstops –
the PD assessment is
complemented with the use of qualitative high-risk
backstops to further inform whether significant
deterioration in lifetime risk of default has occurred. The
qualitative high-risk backstop assessment includes the use
of the mandatory 30+ days past due backstop, as
prescribed by IFRS 9 guidance, and other features such as
forbearance support, Wholesale exposures managed within
the Risk of Credit Loss framework, and adverse credit
bureau results for Personal customers.
Persistence (Personal and business banking customers only)
the persistence rule ensures that accounts which have
met the criteria for PD driven deterioration are still
considered to be significantly deteriorated for three months
thereafter. This additional rule enhances the timeliness of
capture in Stage 2. The persistence 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
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The criteria are based on a significant amount of empirical
analysis and seek to meet three key objectives:
Criteria effectiveness –
the criteria should be effective in
identifying significant credit deterioration and prospective
default population.
Stage 2 stability –
the criteria should not introduce
unnecessary volatility in the Stage 2 population.
Portfolio analysis –
the criteria should produce results which
are intuitive when reported as part of the wider credit
portfolio.
Monitoring the effect on relative PD deterioration when
originating new lending at times of weaker economic outlook
(therefore, higher PDs at initial recognition) is important to
ensure SICR criteria remains effective.
Provisioning for forbearance
(audited)
Personal
The methodology used for provisioning in respect of Personal
forborne loans will differ depending 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 can include capitalisation
of principal and interest in arrears, where the loan may be
returned to the performing book if the customer has
demonstrated an ability to meet regular payments and is likely
to continue to do so.
The loan would continue to be reported as forborne until it
meets the exit criteria set out by the appropriate regulatory
guidance.
For ECL provisioning, all forborne but performing exposures
are categorised as Stage 2 and are subject to a lifetime loss
provisioning assessment. Where the forbearance treatment
includes the cessation of interest on the customer balance (i.e.
non-accrual), this will be treated as a Stage 3 default.
For non-performing forborne loans, the Stage 3 loss
assessment process is the same as for non-forborne loans.
Wholesale
Provisions for forborne loans are assessed in accordance with
normal provisioning policies. The customer’s financial position
and prospects – as well as the likely effect of the forbearance,
including any concessions granted, and revised PD or LGD
gradings – are considered in order to establish whether an
impairment provision increase is required.
Wholesale loans granted forbearance are individually credit
assessed in most cases. Performing loans subject to
forbearance treatment are categorised as Stage 2 and subject
to a lifetime loss assessment.
Forbearance may result in the value of the outstanding debt
exceeding the present value of the estimated future cash flows.
This difference will lead to a customer being classified as non-
performing.
In the case of non-performing forborne loans, an individual loan
impairment provision assessment generally takes place prior to
forbearance being granted. The amount of the loan impairment
provision may change once the terms of the forbearance are
known, resulting in an additional provision charge or a release
of the provision in the period the forbearance is granted.
The transfer of Wholesale loans from impaired to performing
status follows assessment by relationship managers and credit.
When no further losses are anticipated and the customer is
expected to meet the loan’s revised terms, any provision is
written-off or released and the balance of the loan can be
returned to performing status once exit criteria, as set out by
regulatory guidance, is met.
Asset lifetimes
(audited)
The choice of initial recognition and asset duration is another
critical judgment in determining the quantum of lifetime losses
that apply.
The date of initial recognition reflects the date that a
transaction (or account) was first recognised on the
balance sheet; the PD recorded at that time provides the
baseline used for subsequent determination 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 appropriate (such as,
expected prepayment and amortisation).
Revolving facilities – for Personal portfolios (except
credit cards), asset duration is based on behavioural
life and this is normally greater than contractual life
(which would typically be overnight). For Wholesale
portfolios, asset duration is based on annual customer
review schedules and will be set to the next review
date.
In the case of credit cards, the most significant judgment is to
reflect the operational practice of card reissuance and the
associated credit assessment as enabling a formal re-
origination trigger. As a consequence, a capped lifetime
approach of up to 36 months is used on credit card balances. If
the approach was uncapped the ECL impact is estimated at
approximately £80 million (2021 – £70 million). However, credit
card balances originated under the 0% balance transfer
product, and representing approximately 19% of performing
card balances, have their ECL calculated on a behavioural
lifetime approach as opposed to being capped at a maximum
of three years.
The capped approach reflects NatWest Group practice of a
credit-based review of customers prior to credit card issuance
and complies with IFRS 9. Benchmarking information indicates
that peer UK banks use behavioural approaches in the main for
credit card portfolios with average durations between three
and ten years. Across Europe, durations are shorter and are, in
some cases, as low as one year.
Risk and capital management
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Economic loss drivers
(audited)
Introduction
The portfolio segmentation and selection of economic loss
drivers for IFRS 9 follow closely the approach used in stress
testing. To enable robust modelling the forecasting models for
each portfolio segment (defined by product or asset class and
where relevant, industry sector and region) are based on a
selected, small number of economic variables, (typically three to
four) that best explain the temporal variations in portfolio loss
rates. The process to select economic loss drivers 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 corporates
UK stock price index, UK GDP, Bank of
England base rate
UK commercial
real estate
UK stock price index, UK commercial
property price index, UK GDP, Bank of
England base rate
(1)
This is not an exhaustive list of economic loss drivers but shows the most material
drivers for the most significant portfolios.
Economic scenarios
At 31 December 2022, the range of anticipated future economic
conditions was defined by a set of four internally developed
scenarios and their respective probabilities. In addition to the
base case, they comprised upside, downside and extreme
downside scenarios. The scenarios primarily reflected the
current risks faced by the economy, particularly related to high
inflation resulting in a fall in real household income, economic
slowdown, a rise in unemployment and asset price declines.
For 2022, the four scenarios were deemed appropriate in
capturing the uncertainty in economic forecasts and the non-
linearity in outcomes under different scenarios. These four
scenarios were developed to provide sufficient coverage across
potential rises in unemployment, inflation, asset price declines
and the degree of permanent damage to the economy, around
which there remains pronounced levels of uncertainty.
Upside
– This scenario assumes a robust growth through 2023
as consumers dip into excess savings built up since the COVID-
19 pandemic and further helped by fiscal support and strong
business investment. The labour market remains resilient, with
the unemployment rate remaining below pre-COVID-19 levels.
Inflation retraces sharply and that does not necessitate
significantly more tightening. The housing market slows down
compared to the previous year but still remains robust.
Base case
– High inflation and significant monetary policy
tightening leads to a mild recession in 2023. Fiscal support
remains key in containing the impact. Unemployment rate rises
modestly but job losses are contained. Inflation moderates over
medium-term and falls to the target levels in 2024. Housing
market experiences price decline and lower activity but the
extent of the decline is lower than that experienced during prior
stresses.
Since 31 December 2021, the outlook has deteriorated as
energy prices surged and cost of living crisis intensified. As a
result, the base case is more pessimistic. The mild recession in
2023 contrasts with last year’s assumption of a muted growth.
House price correction contrasts with previous year’s
assumptions of a modest growth. In previous scenario,
unemployment rate was expected to increase very modestly
while inflation and interest rate rises last year were also
relatively muted.
Downside
– Inflation rises on the back of further energy price
spikes. The high inflation environment leads to the economy
falling under recession. As demand dries up, inflation rapidly
declines. Policy rates are raised initially but then quickly eased
to assist in recovery. Unemployment is more than the base case
scenario while house prices experience declines comparable to
previous episodes of stress.
Extreme downside
– This scenario assumes high and persistent
inflation. Households see the highest recorded decline in real
income. Policy rate rises to levels last seen in early 2000.
Resulting economic recession is deep and leads to widespread
job losses. House prices lose approximately a third of their value
while unemployment rate rises to level above those seen during
the 2008 financial crisis.
The previous year’s extreme downside also included a deep
recession, labour market deterioration and asset price falls, but
the current scenario explores these risks in a high inflation, high
rates environment.
Risk and capital management
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Economic loss drivers
(audited)
The tables and commentary below provide details of the key economic loss drivers under the four scenarios.
The main macroeconomic variables for each of the four scenarios used for ECL modelling are set out in the main macroeconomic
variables table below. The compound annual growth rate (CAGR) for GDP is shown. It also shows the five-year average for
unemployment and the Bank of England base rate. The house price index and commercial real estate figures show the total
change in each asset over five years.
Main macroeconomic variables
2022
2021
Upside
Base case
Downside
Extreme
downside
Weighted
average
Upside
Base case
Downside
Extreme
downside
Weighted
average
Five-year summary
%
%
%
%
%
%
%
%
%
%
GDP - CAGR
1.6
0.8
0.2
(0.2)
0.7
2.4
1.7
1.4
0.6
1.8
Unemployment - average
3.9
4.6
5.1
7.2
5.0
3.5
4.2
4.8
6.7
4.2
House price index - total change
21.5
(1.3)
(6.0)
(22.4)
(1.3)
22.7
12.1
4.3
(5.3)
12.8
Bank of England base rate - average
2.6
3.3
1.5
4.9
3.1
1.5
0.8
0.7
(0.5)
0.9
Commercial real estate price - total change
(0.1)
(14.4)
(17.2)
(38.3)
(16.1)
18.2
7.2
5.5
(6.4)
9.5
Consumer price index - CAGR
2.4
3.0
3.1
7.0
3.6
2.7
2.5
3.1
1.5
2.6
UK stock price index - total change
22.6
13.9
1.8
(8.5)
9.5
36.6
24.9
12.5
0.2
24.7
World GDP - CAGR
3.7
3.3
1.6
1.0
2.7
3.5
3.2
2.6
0.6
3.1
Probability weight
18.6
45.0
20.8
15.6
30.0
45.0
20.0
5.0
(1)
The five year period starts after Q3 2022 for 31 December 2022 and Q3 2021 for 31 December 2021.
(2)
CAGR and total change figures are not comparable with 31 December 2021 data, as the starting quarters differ.
Probability weightings of scenarios
A subjective approach for assigning probability weight was used
during COVID-19 due to the scale of the economic effect of
COVID-19 and the range of recovery paths. Similarly, a
subjective approach was used at 30 September 2022, to reflect
the deteriorating outlook and shifting balance of risks in the
given set of scenarios. However, NatWest Group’s quantitative
approach to IFRS 9 multiple economic scenarios (MES) involves
selecting a suitable set of discrete scenarios to characterise the
distribution of risks in the economic outlook and assigning
appropriate probability weights. This quantitative approach has
been reinstated and is used for 31 December 2022.
The approach involves comparing UK GDP paths for NatWest
Group’s scenarios against a set of 1,000 model runs, following
which, a percentile in the distribution is established that most
closely corresponded to the scenario. Probability weight for
base case is set first based on judgement, while probability
weights for the alternate scenarios are assigned based on these
percentiles scores.
The assigned probability weights were judged to be aligned with
the subjective assessment of balance of the risks in the
economy. Since 31 December 2021, high inflation posed
significant challenge to the economy and there is considerable
uncertainty to the economic outlook, with respect to persistence
and range of outcomes on inflation and its subsequent effects
on household real income and economic activity. Given that
backdrop, NatWest Group judges it appropriate to assign higher
probability weights on downside-biased scenarios than at 31
December 2021. It presents good coverage to the range of
outcomes assumed in the scenarios, including the potential for a
robust recovery on the upside and exceptionally challenging
outcomes on the downside. A 18.6% weighting was applied to
the upside scenario, a 45.0% weighting applied to the base case
scenario, a 20.8% weighting applied to the downside scenario
and a 15.6% weighting applied to the extreme downside
scenario. Compared to 30 June 2022, the probability weights
were broadly similar, but with additional modest downside skew.
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Economic loss drivers
UK gross domestic product (£bn)
Q1 2022
Q1 2023
Q1 2024
Q1 2025
Q1 2026
Q1 2027
2000
2100
2200
2300
2400
2500
Upside
Base case
Downside
Extreme downside
Bank of England base rate (%)
Q1 2019
Q1 2020
Q1 2021
Q1 2022
Q1 2023
Q1 2024
Q1 2025
Q1 2026
Q1 2027
0
1
2
3
4
5
6
7
Upside
Base case
Downside
Extreme downside
UK unemployment rate (%)
Q1 2019
Q1 2020
Q1 2021
Q1 2022
Q1 2023
Q1 2024
Q1 2025
Q1 2026
Q1 2027
0
1
2
3
4
5
6
7
8
9
Upside
Base case
Downside
Extreme downside
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Economic loss drivers
(audited)
Annual figures
GDP - annual growth
Commercial real estate price - four quarter change
Upside
Base case
Downside
Extreme
downside
Weighted
average
Upside
Base case
Downside
Extreme
downside
Weighted
average
%
%
%
%
%
%
%
%
%
%
2022
4.4
4.4
4.4
4.4
4.4
2022
(2.6)
(2.6)
(2.6)
(2.6)
(2.6)
2023
2.2
(0.9)
(2.8)
(3.1)
(1.1)
2023
2.1
(8.4)
(19.7)
(22.4)
(11.0)
2024
1.9
0.7
(0.4)
(1.6)
0.4
2024
1.9
(0.5)
2.8
(29.1)
(3.2)
2025
1.2
1.0
1.9
1.2
1.3
2025
2.7
1.3
3.7
6.7
2.6
2026
1.2
1.4
1.2
1.2
1.3
2026
2.2
1.0
3.8
8.5
2.6
2027
1.4
1.5
1.1
1.2
1.4
2027
0.6
1.0
2.3
8.6
2.0
Unemployment rate - annual
average
Consumer price index - four quarter change
Upside
Base case
Downside
Extreme
downside
Weighted
average
Upside
Base case
Downside
Extreme
downside
Weighted
average
%
%
%
%
%
%
%
%
%
%
2022
3.8
3.8
3.8
3.8
3.8
2022
11.2
11.2
11.2
11.2
11.2
2023
3.9
4.4
5.0
6.0
4.7
2023
2.2
3.7
6.0
17.0
6.0
2024
3.9
4.9
5.7
8.4
5.4
2024
1.0
2.7
1.0
8.8
3.1
2025
4.0
4.8
5.2
8.0
5.2
2025
2.0
2.0
2.0
2.7
2.1
2026
4.0
4.6
5.0
7.4
5.0
2026
2.0
1.9
2.0
2.3
2.0
2027
4.0
4.3
5.1
6.7
4.8
2027
2.0
1.9
2.0
2.0
2.0
House price index - four quarter change
UK stock price index - four quarter change
Upside
Base case
Downside
Extreme
downside
Weighted
average
Upside
Base case
Downside
Extreme
downside
Weighted
average
%
%
%
%
%
%
%
%
%
%
2022
6.9
6.9
6.9
6.9
6.9
2022
(3.4)
(3.4)
(3.4)
(3.4)
(3.4)
2023
7.5
(7.8)
(13.7)
(10.4)
(6.6)
2023
9.1
4.1
(20.6)
(45.0)
(7.8)
2024
4.5
(0.9)
(7.7)
(15.2)
(3.2)
2024
4.0
1.9
9.7
24.9
5.9
2025
3.0
2.9
4.8
(8.3)
1.8
2025
4.5
4.0
8.8
16.7
6.4
2026
3.5
3.4
8.3
7.2
4.8
2026
4.9
4.4
7.0
11.0
5.8
2027
3.4
3.4
6.3
6.6
4.3
2027
4.0
4.3
6.6
9.9
5.4
Bank of England base rate - annual average
Upside
Base case
Downside
Extreme
downside
Weighted
average
%
%
%
%
%
2022
1.49
1.49
1.49
1.49
1.49
2023
3.27
3.94
2.94
5.38
3.83
2024
2.71
3.75
1.00
5.95
3.33
2025
2.29
3.25
1.00
5.28
2.92
2026
2.25
3.00
1.00
4.46
2.67
2027
2.06
2.75
1.00
3.64
2.40
Worst points
31 December 2022
31 December 2021
Downside
Extreme
downside
Weighted
average
Downside
Extreme
downside
Weighted
average
%
Quarter
%
Quarter
%
%
Quarter
%
Quarter
%
GDP
(3.9)
Q4 2023
(5.4)
Q4 2023
(1.5)
(1.8)
Q1 2022
(7.9)
Q1 2022
Unemployment rate (peak)
6.0
Q1 2024
8.5
Q3 2024
5.4
5.4
Q1 2023
9.4
Q4 2022
4.5
House price index
(21.3)
Q1 2025
(31.7)
Q3 2025
(10.6)
(3.0)
Q3 2023
(26.0)
Q2 2023
Bank of England base rate
4.0
Q1 2023
6.0
Q1 2024
4.1
1.5
Q4 2022
(0.5)
Q2 2022
1.2
Commercial real estate price
(26.8)
Q4 2023
(50.3)
Q3 2024
(21.8)
(2.5)
Q1 2022
(29.8)
Q3 2022
Consumer price index
15.7
Q1 2023
17.0
Q4 2023
11.7
7.9
Q4 2022
4.3
Q1 2022
5.5
UK stock price index
(24.0)
Q4 2023
(47.3)
Q4 2023
(11.7)
(12.2)
Q1 2022
(37.1)
Q2 2022
(1.2)
(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 the consumer price index, the figures
show the highest annual percentage change. 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 2022 for 31 December 2022 scenarios.
Risk and capital management
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Credit risk continued
Economic loss drivers
(audited)
Use of the scenarios in Personal lending
Personal lending follows a discrete scenario approach. The PD
and LGD values for each discrete scenario are calculated using
product specific economic response models. Each account has
a PD and LGD calculated as probability weighted averages
across the suite of economic scenarios.
Use of the scenarios in Wholesale lending
The Wholesale lending ECL methodology is based on the
concept of CCIs. The CCIs represent, similar to the exogenous
component in Personal, all relevant economic loss drivers for a
region/industry segment 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 to loss rates at long-run average levels, a positive
CCI value corresponds to loss rates below long run average
levels and a negative CCI value corresponds to loss rates above
long-run average levels.
The individual economic scenarios are translated into forward-
looking projections of CCIs using a set of econometric models.
Subsequently the CCI projections for the individual scenarios
are averaged into a single central CCI projection according to
the given scenario probabilities. The central CCI projection is
then overlaid with an additional mean reversion assumption to
gradually revert to the long-run average CCI value of zero in
the outer years of the projection horizon.
Finally, ECL is calculated using a Monte Carlo approach by
averaging PD and LGD values arising from many CCI paths
simulated around the central CCI projection.
The rationale for the Wholesale approach is the long-standing
observation that loss rates in Wholesale portfolios tend to follow
regular cycles. This allows NatWest Group to enrich the range
and depth of future economic conditions embedded in the final
ECL beyond what would be obtained from using the discrete
macro-economic scenarios alone.
Business Banking, while part of the Wholesale segment for
reporting purposes, utilises the Personal lending rather than the
Wholesale lending methodology.
UK economic uncertainty
The high inflation environment and supply chain disruption are
presenting significant headwinds for some businesses and
sectors. These are a result of various factors and in many
cases are compounding and look set to remain a feature of the
economic environment into 2023. NatWest Group has
considered where these are most likely to affect the customer
base. Furthermore, the rising cost of borrowing during 2022 for
both businesses and consumers presents an additional
affordability challenge for many borrowers.
The effects of these risks are not expected to be fully captured
by forward-looking credit modelling, particularly given the
unique high inflation environment, low unemployment base-
case outlook. Any incremental ECL effects for these risks will
be captured via post model adjustments and are detailed
further in the Governance and post model adjustments section.
Risk and capital management
continued
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Credit risk continued
Economic loss drivers
(audited)
Model monitoring and enhancement
Throughout 2022, default rates in the UK Personal and
Wholesale portfolios moderately increased but remained
generally at, or somewhat below, pre-COVID-19 levels. This is
based on a normalised view removing the effects of the new
definition of default, introduced from 1 January 2022, in
accordance with new prudential regulation. As in 2021, model
recalibrations to adjust for overprediction have been deferred
where applicable, based on the judgment that default rate
actuals may still be supressed as a result of government
support provided throughout COVID-19.
The suite of UK Personal PD models and some Personal LGD
models were redeveloped in 2022 removing the need for a
number of previously applied post model ECL adjustments to
account for model weaknesses.
In Wholesale lending, new economic response models were
introduced in 2022 for the UK corporate segments, that follow
an improved modelling approach and put higher weight on
stock price indices compared to previous models.
The economic response models for Personal and Wholesale do
not include direct inflation drivers, due to low inflation seen
throughout the data history available for modelling (typically
starting in early 2000s with some variation across products).
The effect of inflation is deemed to be partially reflected
through other drivers present in the models, especially in
Wholesale lending, where new models with a higher weight on
stock price indices were introduced for the most material
portfolios.
As detailed in the Governance and post model adjustments
section, ECL adjustments were applied where management
judged inflation risk was not fully reflected through the models.
The use of direct inflation drivers in the economic response
models will be reviewed considering additional credit outcome
data in 2023.
Government guarantees
A number of support schemes were introduced in response to
COVID-19 with the UK government guaranteeing part of the
loan. The Bounce Back Loan Scheme is 100% guaranteed. For
the Coronavirus Business Interruption Loan Scheme and the
Coronavirus Large Business Interruption Loan Scheme the
government guarantee is 80%. NatWest Group recognises lower
LGDs for these lending products as a result, with 0% applied to
the government-guaranteed part of the exposure. NatWest
Group does not directly adjust the measurement of PD due to
the government guarantee and continues to move exposures
into Stage 2 and Stage 3 where a significant deterioration in
credit risk or a default is identified.
Wholesale support schemes*
The table below shows the sector split for BBLS as well as associated debt split by stage. Associated debt refers to the non-BBLS
lending to customers who also have BBLS lending.
Gross carrying amount
BBL
Associated debt
ECL on associated debt
Stage 1
Stage 2
Stage 3
Total
Stage 1
Stage 2
Stage 3
Total
Stage 1
Stage 2
Stage 3
31 December 2022
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Wholesale
Property
1,029
197
51
1,277
908
217
61
1,186
10
15
27
Financial institutions
24
4
28
9
2
11
1
Sovereigns
5
1
1
7
2
2
Corporate
3,165
629
338
4,132
2,302
872
116
3,290
26
56
69
Of which:
Agriculture
221
74
4
299
819
297
22
1,138
6
14
11
Airlines and aerospace
3
1
4
1
1
Automotive
221
34
10
265
100
37
5
142
1
2
3
Chemicals
6
1
7
9
1
10
Health
165
23
4
192
271
92
9
372
2
4
4
Industrials
131
21
5
157
77
20
4
101
1
2
2
Land transport & logistics
122
25
8
155
51
16
4
71
1
2
3
Leisure
471
108
28
607
336
161
27
524
5
12
16
Mining & metals
5
1
6
5
1
6
Oil and gas
6
1
7
2
2
4
Power utilities
3
1
4
3
4
7
Retail
554
102
26
682
283
94
14
391
4
7
10
Shipping
2
2
1
3
4
Water & waste
15
2
1
18
10
3
13
Total
4,223
831
390
5,444
3,221
1,091
177
4,489
36
71
97
Risk and capital management
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Credit risk continued
Economic loss drivers
(audited)
Gross carrying amount
BBL
Associated debt
ECL on associated debt
Stage 1
Stage 2
Stage 3
Total
Stage 1
Stage 2
Stage 3
Total
Stage 1
Stage 2
Stage 3
31 December 2021
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Wholesale
Property
1,480
218
99
1,797
1,232
165
55
1,452
3
13
18
Financial institutions
33
5
1
39
9
20
3
32
1
Sovereigns
7
1
8
2
2
Corporate
4,593
703
334
5,630
2,481
1,087
84
3,652
10
66
34
Of which:
Agriculture
302
86
6
394
827
396
14
1,237
3
17
4
Airlines and aerospace
5
1
1
7
1
1
2
Automotive
309
43
21
373
119
39
2
160
1
2
1
Chemicals
10
1
11
6
1
7
Health
233
26
7
266
287
131
13
431
1
7
3
Industrials
181
23
8
212
79
25
2
106
2
1
Land transport & logistics
180
32
19
231
57
26
2
85
2
1
Leisure
706
122
55
883
367
208
25
600
1
15
9
Mining & metals
6
1
1
8
6
1
7
Oil and gas
8
2
1
11
3
1
4
Power utilities
4
1
5
4
4
8
Retail
800
109
47
956
310
127
8
445
2
7
4
Shipping
3
3
3
3
6
Water & waste
23
3
1
27
11
4
15
Total
6,113
927
434
7,474
3,724
1,272
142
5,138
13
80
52
*Not within audit scope.
Measurement uncertainty and ECL sensitivity
analysis
(audited)
The recognition and measurement of ECL is complex and
involves the use of significant judgment and estimation,
particularly in times of economic volatility and uncertainty. This
includes the formulation and incorporation of multiple forward-
looking economic conditions into ECL to meet the measurement
objective of IFRS 9. The ECL provision is sensitive to the model
inputs and economic assumptions underlying the estimate.
The focus of the simulations is on ECL provisioning
requirements on performing exposures in Stage 1 and Stage 2.
The simulations are run on a stand-alone basis and are
independent of each other; the potential ECL impacts reflect
the simulated impact at 31 December 2022. Scenario impacts
on SICR should be considered when evaluating the ECL
movements of Stage 1 and Stage 2. In all scenarios the total
exposure was the same but exposure by stage varied in each
scenario.
Stage 3 provisions are not subject to the same level of
measurement uncertainty – default is an observed event as at
the balance sheet date. Stage 3 provisions therefore were not
considered in this analysis.
The impact arising from the base case, upside, downside and
extreme downside scenarios was simulated. These scenarios
are used in the methodology for Personal multiple economic
scenarios as described in the Economic loss drivers section. In
the simulations, NatWest Group has assumed that the
economic macro variables associated with these scenarios
replace the existing base case economic assumptions, giving
them a 100% probability weighting and therefore serving as a
single economic scenario.
These scenarios were applied to all modelled portfolios in the
analysis below, with the simulation impacting both PDs and
LGDs. Post model adjustments included in the ECL estimates
that were modelled were sensitised in line with the modelled
ECL movements, but those that were judgmental in nature,
primarily those for deferred model calibrations and economic
uncertainty, were not (refer to the Governance and post model
adjustments section). As expected, the scenarios create
differing impacts on ECL 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 factors would also
have an impact, for example, potential customer behaviour
changes and policy changes by lenders that might impact on
the wider availability of credit.
NatWest Group’s core criterion to identify a SICR is founded on
PD deterioration, as discussed above. Under the simulations,
PDs change and result in exposures moving between Stage 1
and Stage 2 contributing to the ECL impact.
Risk and capital management
continued
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Credit risk continued
Measurement uncertainty and ECL sensitivity analysis
(audited)
2022
Actual
Base scenario
Moderate upside
scenario
Moderate
downside
scenario
Extreme
downside
scenario
Stage 1 modelled loans (£m)
Retail Banking - mortgages
163,705
164,479
170,648
162,649
152,339
Retail Banking - unsecured
7,845
8,032
8,589
7,772
6,375
Wholesale - property
26,748
27,626
28,175
25,750
17,447
Wholesale - non-property
106,837
112,045
115,167
100,159
79,525
305,135
312,182
322,579
296,330
255,686
Stage 1 modelled ECL (£m)
Retail Banking - mortgages
71
72
76
70
65
Retail Banking - unsecured
172
175
176
176
141
Wholesale - property
107
81
63
135
130
Wholesale - non-property
250
233
204
287
292
600
561
519
668
628
Stage 1 coverage (%)
Retail Banking - mortgages
0.04%
0.04%
0.04%
0.04%
0.04%
Retail Banking - unsecured
2.19%
2.18%
2.05%
2.26%
2.21%
Wholesale - property
0.40%
0.29%
0.22%
0.52%
0.75%
Wholesale - non-property
0.23%
0.21%
0.18%
0.29%
0.37%
0.20%
0.18%
0.16%
0.23%
0.25%
Stage 2 modelled loans (£m)
Retail Banking - mortgages
18,819
18,045
11,876
19,875
30,185
Retail Banking - unsecured
3,126
2,939
2,382
3,199
4,596
Wholesale - property
4,411
3,533
2,984
5,409
13,712
Wholesale - non-property
20,660
15,452
12,330
27,338
47,972
47,016
39,969
29,572
55,821
96,465
Stage 2 modelled ECL (£m)
Retail Banking - mortgages
61
57
40
65
97
Retail Banking - unsecured
389
373
304
398
553
Wholesale - property
105
77
51
134
573
Wholesale - non-property
440
311
236
523
1,309
995
818
631
1,120
2,532
Stage 2 coverage (%)
Retail Banking - mortgages
0.32%
0.32%
0.34%
0.33%
0.32%
Retail Banking - unsecured
12.44%
12.69%
12.76%
12.44%
12.03%
Wholesale - property
2.38%
2.18%
1.71%
2.48%
4.18%
Wholesale - non-property
2.13%
2.01%
1.91%
1.91%
2.73%
2.12%
2.05%
2.13%
2.01%
2.62%
Stage 1 and Stage 2 modelled loans (£m)
Retail Banking - mortgages
182,524
182,524
182,524
182,524
182,524
Retail Banking - unsecured
10,971
10,971
10,971
10,971
10,971
Wholesale - property
31,159
31,159
31,159
31,159
31,159
Wholesale - non-property
127,497
127,497
127,497
127,497
127,497
352,151
352,151
352,151
352,151
352,151
Stage 1 and Stage 2 modelled ECL (£m)
Retail Banking - Mortgages
132
129
116
135
162
Retail Banking - Unsecured
561
548
480
574
694
Wholesale - property
212
158
114
269
703
Wholesale - non-property
690
544
440
810
1,601
1,595
1,379
1,150
1,788
3,160
Stage 1 and Stage 2 coverage (%)
Retail Banking - Mortgages
0.07%
0.07%
0.06%
0.07%
0.09%
Retail Banking - Unsecured
5.11%
4.99%
4.38%
5.23%
6.33%
Wholesale - property
0.68%
0.51%
0.37%
0.86%
2.26%
Wholesale - non-property
0.54%
0.43%
0.35%
0.64%
1.26%
0.45%
0.39%
0.33%
0.51%
0.90%
Reconciliation to Stage 1 and Stage 2 ECL (£m)
ECL on modelled exposure
1,595
1,379
1,150
1,788
3,160
ECL on UBIDAC modelled exposures
39
39
39
39
39
ECL on non-modelled exposures
41
41
41
41
41
Total Stage 1 and Stage 2 ECL (£m)
1,675
1,459
1,230
1,868
3,240
Variance to actual total Stage 1 and Stage 2 ECL (£m)
(216)
(445)
193
1,565
Risk and capital management
continued
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Measurement uncertainty and ECL sensitivity analysis continued
(audited)
Moderate
Moderate
Extreme
Base
upside
downside
downside
2022
Actual
scenario
scenario
scenario
scenario
Reconciliation to Stage 1 and Stage 2 Flow Exposure (£m)
Modelled loans
352,151
352,151
352,151
352,151
352,151
UBIDAC loans
4,171
4,171
4,171
4,171
4,171
Non-modelled loans
21,566
21,566
21,566
21,566
21,566
Other asset classes
178,133
178,133
178,133
178,133
178,133
(1)
Variations in future undrawn exposure values across the scenarios are modelled, however the exposure position reported is that used to calculate modelled ECL as at 31 December
2022 and therefore does not include variation in future undrawn exposure values.
(2)
Reflects ECL for all modelled exposure 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 continuing operations were not 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 basis and are independent of each other, with the potential ECL impact reflecting the simulated impact as at 31 December 2022.
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 section for details of economic scenarios.
(6)
Refer to the NatWest Group 2021 Annual Report and Accounts for 2021 comparatives.
Risk and capital management
continued
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Financial review
Credit risk continued
Measurement uncertainty and ECL adequacy
(audited)
During 2022, overall modelled ECL increased reflecting
portfolio growth alongside a deteriorating view on economic
outlook. Judgmental ECL post model adjustments, although
reduced in value terms since 31 December 2021, continued
to reflect economic uncertainty with the expectation of
increased defaults in 2023 and beyond, and represented
12% of total ECL (2021 – 26%).
If the economics were as negative as observed in the
extreme downside, total Stage 1 and Stage 2 ECL was
simulated to increase by £1.6 billion (approximately 93%). In
this scenario, Stage 2 exposure increased significantly and
was the key driver of the simulated ECL rise. The movement
in Stage 2 balances in the other simulations was less
significant.
In the Wholesale portfolio, there was a significant increase in
ECL under both a moderate and extreme downside
scenario. The Wholesale property ECL increase was driven
by commercial real estate prices which show negative
growth until 2024 and significant deterioration in the stock
index. The non-property increase was mainly due to GDP
contraction and significant deterioration in the stock index.
The changes in the economic outlook and scenarios used in
the IFRS 9 MES framework at 31 December 2022 resulted in
an increase in modelled ECL. Given that continued
uncertainty remains due to the high inflation environment
and supply chain disruption, NatWest Group utilised a
framework of quantitative and qualitative measures to
support the directional change and levels of ECL coverage,
including economic data, credit performance insights and
problem debt trends. This was particularly important for
consideration of post model adjustments.
As the effects of the high inflation environment and supply
chain disruption evolve during 2022 and into 2023 and
government support schemes have to be serviced, there is a
risk of credit deterioration. However, the income statement
effect of this will be mitigated by the forward-looking
provisions retained on the balance sheet at 31 December
2022.
There are a number of key factors that could drive further
downside to impairments, through deteriorating economic
and credit metrics and increased stage migration as credit
risk increases for more customers. Such factors would
include an adverse deterioration in GDP and unemployment
in the economies in which NatWest Group operates.
Movement in ECL provision*
The table below shows the main ECL provision movements during the year.
ECL provision
£m
At 1 January 2022
3,806
Transfers to disposal groups and reclassifications
(338)
Changes in economic forecast
341
Changes in risk metrics and exposure: Stage 1 and Stage 2
14
Changes in risk metrics and exposure: Stage 3
576
Judgmental changes: changes in post model adjustments for Stage 1, Stage 2 and Stage 3
(428)
Write-offs and other
(537)
At 31 December 2022
3,434
At 1 January 2021
6,186
2021 movements
(2,380)
At 31 December 2021
3,806
*Not within audit scope.
Risk and capital management
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Financial review
Credit risk – Banking activities
Introduction
This section details the credit risk profile of NatWest Group’s banking activities. Refer to Accounting policy 2.3 and Note 15 to the
consolidated financial statements for policies and critical judgments relating to impairment loss determination.
Presentation of discontinued operations and assets and liabilities of disposal groups
Three legally binding agreements for the sale of UBIDAC business have been announced as part of the phased withdrawal from
the Republic of Ireland. Material developments since the beginning of 2022 are set out below.
Agreement with Allied Irish Banks, p.l.c. (AIB) for the transfer of performing commercial loans.
Successful migration of six tranches of performing commercial loans to AIB was completed during 2022, with €2.1 billion of gross
performing loans being fully migrated by year-end. It is expected that remaining migrations of commercial customers will be
materially completed in phases over H1 2023. Colleagues who are wholly or mainly assigned to supporting this part of the business
are in the process of getting transferred to AIB under Transfer of Undertakings, Protection of Employment (TUPE) arrangements,
with more than half having completed their move by the end of 2022. Losses on disposal of €123 million have been recognised in
2022 in respect of the migrations completed to date.
Agreement with Permanent TSB Group Holdings p.l.c. (PTSB) for the sale of performing non-tracker mortgages, the
performing loans in the micro-SME business, the UBIDAC Asset Finance business, including its Lombard digital platform,
and 25 Ulster Bank branch locations in the Republic of Ireland.
c.€5 billion of performing non-tracker mortgages migrated to PTSB in November 2022, with the remaining balances expected to
migrate during H1 2023. In January 2023, 25 branches transferred to PTSB. The remaining performing non-tracker mortgages,
micro-SME loans, Lombard Asset Finance business and all remaining eligible colleagues who will move under TUPE regulations,
are also expected to transfer in 2023.
Agreement with AIB for the sale of performing tracker and linked mortgages.
In January 2023 the Competition and Consumer Protection Commission (CCPC) granted approval on the portfolio sale of
performing tracker and linked mortgages to AIB. Completion of this sale is expected to occur in Q2 2023.
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. Comparatives have been re-presented from those previously published to reclassify certain items as
discontinued operations. Ulster Bank RoI continuing operations are now reported within Group central items & other. In 2022 we
reclassified mortgage loans to fair value through profit or loss, which resulted in a €453 million reduction in mortgage financial
assets in UBIDAC to 31 December 2022. This reclassification applies across both our continuing and discontinued operations.
Refer to Note 8 to the consolidated financial statements for further details.
Financial instruments within the scope of the IFRS 9 ECL framework
(audited)
Refer to Note 10 to the consolidated financial statements for balance sheet analysis of financial assets that are classified as
amortised cost or fair value through other comprehensive income (FVOCI), the starting point for IFRS 9 ECL framework
assessment. The table below excludes loans in disposal group of £1.5 billion (2021 – £9.1 billion).
31 December 2022
31 December 2021
Gross
ECL
Net
Gross
ECL
Net
£bn
£bn
£bn
£bn
£bn
£bn
Balance sheet total gross amortised cost and FVOCI
554.3
596.1
In scope of IFRS 9 ECL framework
550.3
590.9
% in scope
99%
99%
Loans to customers - in scope - amortised cost
370.1
3.3
366.8
361.9
3.7
358.2
Loans to customers - in scope - FVOCI
0.1
0.1
0.3
0.3
Loans to banks - in scope - amortised cost
6.9
6.9
7.6
7.6
Total loans - in scope
377.1
3.3
373.8
369.8
3.7
366.1
Stage 1
325.2
0.6
324.6
330.8
0.3
330.5
Stage 2
46.8
0.9
45.9
34.0
1.4
32.6
Stage 3
5.1
1.8
3.3
5.0
2.0
3.0
Other financial assets - in scope - amortised cost
156.4
156.4
184.4
184.4
Other financial assets - in scope - FVOCI
16.8
16.8
36.7
36.7
Total other financial assets - in scope
173.2
173.2
221.1
221.1
Stage 1
172.4
172.4
220.8
220.8
Stage 2
0.8
0.8
0.3
0.3
Out of scope of IFRS 9 ECL framework
4.0
na
4.0
5.2
na
5.2
Loans to customers - out of scope - amortised cost
(0.4)
na
(0.4)
0.8
na
0.8
Loans to banks - out of scope - amortised cost
0.2
na
0.2
0.1
na
0.1
Other financial assets - out of scope - amortised cost
4.1
na
4.1
4.0
na
4.0
Other financial assets - out of scope - FVOCI
0.1
na
0.1
0.3
na
0.3
na = not applicable
Risk and capital management
continued
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Additional information
Financial review
Credit risk – Banking activities
Financial instruments within the scope of the
IFRS 9 ECL framework continued
(audited)
The assets outside the scope of IFRS 9 ECL framework were as
follows:
Settlement balances, items in the course of collection, cash
balances and other non-credit risk assets of £4.3 billion
(2021 – £3.7 billion). These were assessed as having no ECL
unless there was evidence that they were defaulted.
Equity shares of £0.4 billion (2021 – £0.3 billion) as not
within the IFRS 9 ECL framework by definition.
Fair value adjustments on loans hedged by interest rate
swaps, where the underlying loan was within the IFRS 9
ECL scope – £(0.6) billion (2021 – £0.8 billion).
NatWest Group originated securitisations, where ECL was
captured on the underlying loans of £nil billion (2021 – £0.4
billion).
Contingent liabilities and commitments
In addition to contingent liabilities and commitments disclosed
in Note 26 to the consolidated financial statements,
reputationally-committed limits were also included in the scope
of the IFRS 9 ECL framework. These were offset by £(0.1)
billion (2021 – £0.8 billion) out of scope balances primarily
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 liabilities (including financial
guarantees) and commitments within IFRS 9 ECL scope of
£137.2 billion (2021 – £127.9 billion) comprised Stage 1 £119.2
billion (2021 – £119.5 billion); Stage 2 £17.3 billion (2021 – £7.8
billion); and Stage 3 £0.7 billion (2021 – £0.6 billion).
The ECL relating to off balance sheet exposures was £0.1
billion (2021 – £0.1 billion). The total ECL in the remainder of
the Credit risk section of £3.4 billion (2021 – £3.8 billion)
included ECL for both on and off balance sheet exposures for
non-disposal groups.
Risk and capital management
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Financial review
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.
Retail Banking
Private Banking
Commercial &
Institutional
Central items &
other
Total
2022
£m
£m
£m
£m
£m
Loans - amortised cost and FVOCI
Stage 1
174,727
18,367
108,791
23,339
325,224
Stage 2
21,561
801
24,226
245
46,833
Stage 3
2,565
242
2,166
123
5,096
Of which: individual
168
905
48
1,121
Of which: collective
2,565
74
1,261
75
3,975
Subtotal excluding
disposal group loans
198,853
19,410
135,183
23,707
377,153
Disposal group loans
1,502
1,502
Total
25,209
378,655
ECL provisions
(1)
Stage 1
251
21
342
18
632
Stage 2
450
14
534
45
1,043
Stage 3
917
26
747
69
1,759
Of which: individual
26
251
10
287
Of which: collective
917
496
59
1,472
Subtotal excluding ECL provisions
on disposal group loans
1,618
61
1,623
132
3,434
ECL on disposal group loans
53
53
Total
185
3,487
ECL provisions coverage
(2)
Stage 1 (%)
0.14
0.11
0.31
0.08
0.19
Stage 2 (%)
2.09
1.75
2.20
18.37
2.23
Stage 3 (%)
35.75
10.74
34.49
56.10
34.52
ECL provisions coverage excluding
disposal group loans
0.81
0.31
1.20
0.56
0.91
ECL provisions coverage on
disposal group loans
3.53
3.53
Total
0.73
0.92
Impairment (releases)/losses
ECL (release)/charge
(3)
229
(2)
122
(12)
337
Stage 1
(146)
2
(135)
(11)
(290)
Stage 2
268
(7)
108
24
393
Stage 3
107
3
149
(25)
234
Of which: individual
3
57
(6)
54
Of which: collective
107
92
(19)
180
Continuing operations
229
(2)
122
(12)
337
Discontinued operations
(71)
(71)
Total
(83)
266
Amounts written-off
216
15
224
27
482
Of which: individual
15
153
168
Of which: collective
216
71
27
314
For the notes to this table refer to the following page.
Risk and capital management
continued
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208
Financial statements
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Additional information
Financial review
Credit risk – Banking activities continued
Segment analysis – portfolio summary
(audited)
Retail Banking
Private Banking
Commercial &
Institutional
Central items &
other
Total
2021
£m
£m
£m
£m
£m
Loans - amortised cost and FVOCI
Stage 1
168,013
17,600
107,368
37,843
330,824
Stage 2
13,594
967
18,477
943
33,981
Stage 3
1,884
270
2,081
787
5,022
Of which: individual
270
884
61
1,215
Of which: collective
1,884
1,197
726
3,807
Subtotal excluding disposal group loans
183,491
18,837
127,926
39,573
369,827
Disposal group loans
9,084
9,084
Total
48,657
378,911
ECL provisions
(1)
Stage 1
134
12
129
27
302
Stage 2
590
29
784
75
1,478
Stage 3
850
37
751
388
2,026
Of which: individual
37
313
13
363
Of which: collective
850
438
375
1,663
Subtotal excluding ECL provisions
on disposal group loans
1,574
78
1,664
490
3,806
ECL provisions on disposal group loans
109
109
Total
599
3,915
ECL provisions coverage
(2)
Stage 1 (%)
0.08
0.07
0.12
0.07
0.09
Stage 2 (%)
4.34
3.00
4.24
7.95
4.35
Stage 3 (%)
45.12
13.70
36.09
49.30
40.34
ECL provisions coverage excluding
disposal group loans
0.86
0.41
1.30
1.24
1.03
ECL provisions coverage on disposal
group loans
1.20
1.20
Total
1.23
1.03
Impairment (releases)/losses
ECL (release)/charge
(3,4)
(36)
(54)
(1,160)
77
(1,173)
Stage 1
(387)
(45)
(872)
(13)
(1,317)
Stage 2
157
(15)
(299)
(7)
(164)
Stage 3
194
6
11
97
308
Of which: individual
6
16
(2)
20
Of which: collective
194
(5)
99
288
Continuing operations
(36)
(54)
(1,160)
77
(1,173)
Discontinued operations
(162)
(162)
Total
(85)
(1,335)
Amounts written-off
220
6
562
88
876
Of which: individual
6
449
455
Of which: collective
220
113
88
421
(1)
Includes loans to customers and banks.
(2)
Includes £3 million (2021 – £5 million) related to assets classified as FVOCI and £0.1 billion (2021 – £0.1 billion) related to off-balance sheet exposures.
(3)
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.
(4)
Includes a £3 million charge (2021 – £3 million release) related to other financial assets, of which nil (2021 – £2 million release) related to assets classified as FVOCI; and £5 million
release (2021 – £34 million release) related to contingent liabilities.
(5)
The table shows gross loans only and excludes amounts that were 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 £143.3 billion (2021 –
£176.3 billion) and debt securities of £29.9 billion (2021 – £44.9 billion).
Stage 1 and Stage 2 modelled ECL increased due to
deterioration in forward-looking economics, although the
Stage 2 growth was more than offset by reductions in post
model adjustments.
Stage 2 loans increased during 2022 in line with portfolio
growth alongside deterioration in forward-looking
economics as a result of the high inflation environment and
supply chain disruption growing throughout the second half
of the year.
Stage 3 loans increased, as write-offs and repayments were
more than offset by the effect of the new regulatory
definition of default, which in isolation led to an increase of
approximately £0.7 billion in Stage 3 balances, mostly in
mortgages.
Underlying flows into default remained subdued during
2022. However, it is expected that defaults will increase in
2023 as growing inflationary pressures on businesses,
consumers and the broader economy continue to evolve.
There was a significant reduction in loans, ECL, and
coverage in Central items & other due to the phased
withdrawal of Ulster Bank RoI.
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
209
Financial statements
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Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Segment analysis – portfolio summary
(audited)
The table below shows Ulster Bank RoI disposal groups for Personal and Wholesale, by stage, for gross loans, off-balance sheet
exposures and ECL. The tables in the rest of the Credit risk section are shown on a continuing basis and therefore exclude these
exposures.
Loans - amortised cost
Off-balance sheet
and FVOCI
ECL provisions
Stage 1
Stage 2
Stage 3
Total
Loan
commitments
Contingent
liabilities
Stage 1
Stage 2
Stage 3
Total
2022
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Personal
Wholesale
1,269
193
40
1,502
413
19
17
19
17
53
Total
1,269
193
40
1,502
413
19
17
19
17
53
2021
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
(1)
Ulster Bank mortgages moves to fair value in 2023 and are no longer subject to ECL assessment. Due to fair value treatment this portfolio is no longer included in the 2022 figures
of credit risk tables for either disposal or non-disposal groups.
Risk and capital management
continued
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Additional information
Financial review
Credit risk – Banking activities continued
Segmental loans and impairment metrics
(audited)
The table below shows gross loans and ECL provisions, by days past due, by segment and stage, within the scope of the ECL
framework.
Gross loans
ECL provisions
(2)
Stage 2
(1)
Stage 2
(1)
Stage 1
Not past
due
1-30 DPD
>30 DPD
Total
Stage 3
Total
Stage 1
Not past
due
1-30 DPD
>30 DPD
Total
Stage 3
Total
2022
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Retail Banking
174,727
20,653
605
303
21,561
2,565
198,853
251
406
14
30
450
917
1,618
Private Banking
18,367
730
39
32
801
242
19,410
21
14
14
26
61
Personal
15,182
122
35
16
173
207
15,562
5
1
1
17
23
Wholesale
3,185
608
4
16
628
35
3,848
16
13
13
9
38
Commercial
& Institutional
108,791
22,520
956
750
24,226
2,166
135,183
342
491
26
17
534
747
1,623
Personal
2,475
17
17
7
41
46
2,562
3
1
1
12
16
Wholesale
106,316
22,503
939
743
24,185
2,120
132,621
339
490
26
17
533
735
1,607
Central items
& other
23,339
234
4
7
245
123
23,707
18
42
1
2
45
69
132
Personal
54
70
3
6
79
13
146
1
11
1
2
14
11
26
Wholesale
23,285
164
1
1
166
110
23,561
17
31
31
58
106
Total loans
325,224
44,137
1,604
1,092
46,833
5,096
377,153
632
953
41
49
1,043
1,759
3,434
Of which:
Personal
192,438
20,862
660
332
21,854
2,831
217,123
260
419
15
32
466
957
1,683
Wholesale
132,786
23,275
944
760
24,979
2,265
160,030
372
534
26
17
577
802
1,751
2021
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
& Institutional
107,368
17,352
455
670
18,477
2,081
127,926
129
750
23
11
784
751
1,664
Personal
2,647
21
17
11
49
57
2,753
2
1
1
10
13
Wholesale
104,721
17,331
438
659
18,428
2,024
125,173
127
749
23
11
783
741
1,651
Central items & other
37,843
837
58
48
943
787
39,573
27
69
3
3
75
388
490
Personal
5,165
510
52
46
608
609
6,382
7
15
3
3
21
301
329
Wholesale
32,678
327
6
2
335
178
33,191
20
54
54
87
161
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
For the notes to this table refer to the following page.
Risk and capital management
continued
NatWest Group
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211
Financial statements
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Additional information
Financial review
Credit risk – Banking activities continued
Segmental loans and impairment metrics
(audited)
The table below shows ECL and ECL provisions coverage, by days past due, by segment and stage, within the scope of the ECL
framework.
ECL provisions coverage
ECL
Stage 2
(1,2)
Stage 1
Not past due
1-30 DPD
>30 DPD
Total
Stage 3
Total
Total
(release) /
charge (3)
Amounts
written-off
2022
%
%
%
%
%
%
%
£m
£m
Retail Banking
0.14
1.97
2.31
9.90
2.09
35.75
0.81
229
216
Private Banking
0.11
1.92
1.75
10.74
0.31
(2)
15
Personal
0.03
0.82
0.58
8.21
0.15
(3)
2
Wholesale
0.50
2.14
2.07
25.71
0.99
1
13
Commercial & Institutional
0.31
2.18
2.72
2.27
2.20
34.49
1.20
122
224
Personal
0.12
5.88
2.44
26.09
0.62
4
2
Wholesale
0.32
2.18
2.77
2.29
2.20
34.67
1.21
118
222
Central items & other
0.08
17.95
25.00
28.57
18.37
56.10
0.56
(12)
27
Personal
1.85
15.71
33.33
33.33
17.72
84.62
17.81
11
1
Wholesale
0.07
18.90
18.67
52.73
0.45
(23)
26
Total loans
0.19
2.16
2.56
4.49
2.23
34.52
0.91
337
482
Of which:
Personal
0.14
2.01
2.27
9.64
2.13
33.80
0.78
241
221
Wholesale
0.28
2.29
2.75
2.24
2.31
35.41
1.09
96
261
2021
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 & Institutional
0.12
4.32
5.05
1.64
4.24
36.09
1.30
(1,160)
562
Personal
0.08
4.76
2.04
17.54
0.47
1
Wholesale
0.12
4.32
5.25
1.67
4.25
36.61
1.32
(1,160)
561
Central items & other
0.07
8.24
5.17
6.25
7.95
49.30
1.24
77
88
Personal
0.14
2.94
5.77
6.52
3.45
49.43
5.16
97
76
Wholesale
0.06
16.51
16.12
48.88
0.49
(20)
12
Total loans
0.09
4.35
4.56
4.13
4.35
40.34
1.03
(1,173)
876
Of which:
Personal
0.08
4.13
4.29
7.44
4.26
42.38
0.94
62
300
Wholesale
0.11
4.51
5.15
1.60
4.42
37.81
1.15
(1,235)
576
2019
Retail Banking
0.08
3.15
4.35
7.79
3.44
43.27
0.88
Private Banking
0.05
1.26
0.00
2.17
1.19
14.01
0.27
Personal
0.03
1.11
0.00
2.44
1.07
11.98
0.24
Wholesale
0.12
1.34
0.00
0.00
1.31
40.00
0.38
Commercial & Institutional
0.15
1.79
4.35
2.60
1.86
47.84
1.23
Personal
0.04
3.70
0.00
0.00
2.00
18.46
0.48
Wholesale
0.15
1.78
4.63
2.66
1.86
48.64
1.25
Central items & other
0.11
2.77
5.77
6.02
3.22
34.02
2.27
Personal
0.11
2.12
6.25
5.71
2.79
31.49
4.57
Wholesale
0.12
4.09
0.00
7.14
4.20
63.75
0.71
Total loans
0.11
2.47
4.27
5.99
2.70
41.19
1.13
Of which:
Personal
0.08
3.04
4.23
7.15
3.35
35.90
1.10
Wholesale
0.14
1.86
4.44
3.04
1.94
49.53
1.16
(1)
30 DPD – 30 days past due, the mandatory 30 days past due backstop as prescribed by IFRS 9 for a SICR.
(2)
ECL provisions on contingent liabilities and commitments are included within the Financial assets section so as not to distort ECL coverage ratios.
Risk and capital management
continued
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Financial statements
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Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Segmental loans and impairment metrics
(audited)
Retail Banking
– Balance sheet growth during 2022 was
primarily within mortgages with new lending a result of
strong housing demand and re-mortgage activity and
increased buy-to-let lending. Unsecured lending balances
also increased as consumer demand and spending
recovered following the easing of COVID-19 restrictions and
with selective relaxation of lending criteria. Total ECL
coverage reduced slightly during 2022, reflective of low
unemployment and stable portfolio performance, while
maintaining sufficient ECL coverage for key portfolios
above 2019 levels, given increased inflationary and
economic pressures. Increasing Stage 2 size and portfolio
coverage in the second half of the year reflected the
deterioration in economic outlook, with portfolio
performance remaining broadly stable. Stage 3 ECL
increased overall, mainly because of the IFRS 9 alignment
to the new regulatory default definition, implemented on 1
January 2022. The implementation of new mortgage IFRS 9
models resulted in lower Stage 3 ECL coverage due to
reduced loss estimates for cases where the customer was
not subject to repossession activity and was the primary
reason for the change in overall retail Stage 3 coverage
during 2022.
Commercial & Institutional
– There was growth in
Commercial & Institutional, particularly as a result of
increased exposure to financial institutions, notably
leveraged funds, and larger corporate customers, primarily
within information technology, telecommunications and
power utilities. There were also continued repayments of
COVID-19 government lending schemes, and strategic
reductions in certain sectors. Sector appetite continues to
be reviewed regularly, with particular focus on sector
clusters and sub-sectors that are vulnerable to inflationary
pressures or deemed to represent a heightened risk. Stage
1 and Stage 2 ECL increased due to deterioration in
forward-looking economics, although the Stage 2 growth
was more than offset by reductions in post model
adjustments. Coverage decreased with the reduction in
COVID-19 post model adjustments, but coverage on Stage
1 and Stage 2 was significantly above 2019 levels, reflecting
current inflationary and economic pressures.
Other
– Balance sheet reduction in 2022 compared to 2021
was mainly due to a reduction in central items held in the
course of treasury related management activities, and a
decrease due to the phased withdrawal of Ulster Bank RoI.
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
213
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 geographical region.
Personal
Wholesale
Mortgages (1)
Credit cards
Other
personal
Total
Property
Corporate
FI
Sovereign
Total
Total
2022
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Loans by geography
202,957
4,460
9,706
217,123
32,574
73,677
48,138
5,641
160,030
377,153
- UK
202,957
4,420
9,602
216,979
31,452
62,318
32,480
4,285
130,535
347,514
- RoI
40
104
144
34
1,102
74
1,210
1,354
- Other Europe
623
4,670
6,967
475
12,735
12,735
- RoW
465
5,587
8,617
881
15,550
15,550
Loans by stage
202,957
4,460
9,706
217,123
32,574
73,677
48,138
5,641
160,030
377,153
- Stage 1
182,245
3,275
6,918
192,438
27,542
53,048
46,738
5,458
132,786
325,224
- Stage 2
18,787
1,076
1,991
21,854
4,316
19,153
1,353
157
24,979
46,833
- Stage 3
1,925
109
797
2,831
716
1,476
47
26
2,265
5,096
- Of which: individual
172
13
185
314
564
33
25
936
1,121
- Of which: collective
1,753
109
784
2,646
402
912
14
1
1,329
3,975
Loans - past due analysis
(3,4)
202,957
4,460
9,706
217,123
32,574
73,677
48,138
5,641
160,030
377,153
- Not past due
200,634
4,335
8,825
213,794
31,366
70,034
47,824
5,633
154,857
368,651
- Past due 1-30 days
916
33
86
1,035
608
2,490
278
1
3,377
4,412
- Past due 31-90 days
510
29
104
643
302
551
5
7
865
1,508
- Past due 91-180 days
380
24
79
483
49
34
24
107
590
- Past due >180 days
517
39
612
1,168
249
568
7
824
1,992
Loans - Stage 2
18,787
1,076
1,991
21,854
4,316
19,153
1,353
157
24,979
46,833
- Not past due
17,951
1,039
1,872
20,862
3,866
17,915
1,344
150
23,275
44,137
- Past due 1-30 days
588
19
53
660
185
754
5
944
1,604
- Past due 31-90 days
248
18
66
332
265
484
4
7
760
1,092
Weighted average life*
- ECL measurement (years)
8
2
6
5
4
6
3
1
5
5
Weighted average 12 months
PDs*
- IFRS 9 (%)
0.50
2.62
4.78
0.71
1.88
2.11
0.23
0.19
1.41
1.01
- Basel (%)
0.65
2.97
3.11
0.79
1.03
1.44
0.16
0.19
0.92
0.85
ECL provisions by geography
376
257
1,050
1,683
441
1,228
63
19
1,751
3,434
- UK
376
254
1,027
1,657
404
985
42
14
1,445
3,102
- RoI
3
23
26
13
66
1
80
106
- Other Europe
16
72
7
1
96
96
- RoW
8
105
13
4
130
130
ECL provisions by stage
376
257
1,050
1,683
441
1,228
63
19
1,751
3,434
- Stage 1
81
62
117
260
107
218
32
15
372
632
- Stage 2
62
122
282
466
105
457
14
1
577
1,043
- Stage 3
233
73
651
957
229
553
17
3
802
1,759
- Of which: individual
18
10
28
80
163
13
3
259
287
- Of which: collective
215
73
641
929
149
390
4
543
1,472
ECL provisions coverage (%)
0.19
5.76
10.82
0.78
1.35
1.67
0.13
0.34
1.09
0.91
- Stage 1 (%)
0.04
1.89
1.69
0.14
0.39
0.41
0.07
0.27
0.28
0.19
- Stage 2 (%)
0.33
11.34
14.16
2.13
2.43
2.39
1.03
0.64
2.31
2.23
- Stage 3 (%)
12.10
66.97
81.68
33.80
31.98
37.47
36.17
11.54
35.41
34.52
ECL (release)/charge
(74)
56
259
241
126
(47)
19
(2)
96
337
- UK
(74)
57
247
230
118
(67)
14
(3)
62
292
- RoI
(1)
12
11
1
(26)
(2)
(27)
(16)
- Other Europe
4
1
5
5
- RoW
3
46
6
1
56
56
Amounts written-off
31
67
123
221
33
188
40
261
482
*Not within audit scope.
For the notes to this table refer to page 216.
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
214
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
Mortgages
(1)
Credit
cards
Other
person
Total
Property
Corporate
FI
Sovereign
Total
Total
2022
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Loans by residual maturity
202,957
4,460
9,706
217,123
32,574
73,677
48,138
5,641
160,030
377,153
- <1 year
3,347
2,655
3,368
9,370
6,740
24,297
36,192
2,958
70,187
79,557
- 1-5 year
10,968
1,805
5,387
18,160
17,523
32,127
10,380
1,819
61,849
80,009
- > 5 years
188,642
951
189,593
8,311
17,253
1,566
864
27,994
217,587
Other financial assets by asset
quality
(2)
49
25
14,704
158,416
173,194
173,194
- AQ1-AQ4
11
14,156
158,416
172,583
172,583
- AQ5-AQ8
49
14
548
611
611
Off-balance sheet
18,782
15,848
8,547
43,177
15,793
57,791
19,555
710
93,849
137,026
- Loan commitments
18,782
15,848
8,496
43,126
15,302
54,651
18,223
710
88,886
132,012
- Financial guarantees
51
51
491
3,140
1,332
4,963
5,014
Off-balance sheet by asset quality
(2)
18,782
15,848
8,547
43,177
15,793
57,791
19,555
710
93,849
137,026
- AQ1-AQ4
17,676
436
7,353
25,465
12,477
35,960
17,899
606
66,942
92,407
- AQ5-AQ8
1,089
15,048
1,170
17,307
3,282
21,496
1,655
84
26,517
43,824
- AQ9
2
74
4
80
5
24
29
109
- AQ10
15
290
20
325
29
311
1
20
361
686
For the notes to this table refer to page 216.
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
215
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
Mortgages (1)
Credit cards
Other
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 31-90 days
592
25
73
690
256
448
19
1
724
1,414
- Past due 91-180 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 31-90 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
(5)
46
(14)
30
62
(477)
(723)
(38)
3
(1,235)
(1,173)
- UK
(52)
(14)
31
(35)
(457)
(647)
(12)
3
(1,113)
(1,148)
- RoI
98
(1)
97
(5)
(23)
2
(26)
71
- 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 the following page.
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
216
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
Mortgages
Credit
cards
Other
personal
Total
Property
Corporate
FI
Sovereign
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 years
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
(1)
Includes a portion of Private Banking lending secured against 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)
30 DPD – 30 days past due, the mandatory 30 days past due backstop as prescribed by IFRS 9 for a SICR.
(3)
AQ bandings are based on Basel PDs and mapping 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 (2021 – £0.3 billion) of AQ10 Personal balances primarily relate to loan commitments, the drawdown of which is effectively prohibited.
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
217
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 Personal portfolio and selected sectors of the Wholesale portfolios.
Off-balance sheet
Loans - amortised cost and FVOCI
ECL provisions
Stage 1
Stage 2
Stage 3
Total
Loan
commitments
Contingent
liabilities
Stage 1
Stage 2
Stage 3
Total
2022
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Personal
192,438
21,854
2,831
217,123
43,126
51
260
466
957
1,683
Mortgages
182,245
18,787
1,925
202,957
18,782
81
62
233
376
Credit cards
3,275
1,076
109
4,460
15,848
62
122
73
257
Other personal
6,918
1,991
797
9,706
8,496
51
117
282
651
1,050
Wholesale
132,786
24,979
2,265
160,030
88,886
4,963
372
577
802
1,751
Property*
27,542
4,316
716
32,574
15,302
491
107
105
229
441
Financial institutions**
46,738
1,353
47
48,138
18,223
1,332
32
14
17
63
Sovereigns
5,458
157
26
5,641
710
15
1
3
19
Corporate
53,048
19,153
1,476
73,677
54,651
3,140
218
457
553
1,228
Of which:
Agriculture*
3,646
1,034
93
4,773
968
24
21
31
43
95
Airlines and aerospace*
483
1,232
19
1,734
1,715
174
2
40
8
50
Automotive*
5,776
1,498
30
7,304
4,009
99
18
18
11
47
Chemicals*
384
117
1
502
650
12
1
2
1
4
Health
3,974
1,008
141
5,123
475
8
19
30
48
97
Industrials*
2,148
1,037
82
3,267
3,135
195
10
16
24
50
Land transport & logistics*
3,788
1,288
66
5,142
3,367
190
13
33
17
63
Leisure*
3,416
3,787
260
7,463
1,907
102
27
147
115
289
Mining & metals*
173
230
5
408
545
5
1
5
6
Oil and gas*
953
159
60
1,172
2,157
248
3
3
31
37
Power utilities*
4,228
406
6
4,640
6,960
1,182
9
11
1
21
Retail*
6,497
1,746
150
8,393
4,682
416
21
29
68
118
Shipping*
161
151
14
326
110
22
7
6
13
Water & waste*
3,026
335
7
3,368
2,143
101
4
4
4
12
Total
325,224
46,833
5,096
377,153
132,012
5,014
632
1,043
1,759
3,434
2021
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
Sovereigns
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:
Agriculture*
3,722
1,229
133
5,084
993
24
11
39
78
128
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
Chemicals*
355
43
1
399
663
14
1
1
Health
3,818
1,235
133
5,186
799
9
9
58
48
115
Industrials*
2,311
620
28
2,959
2,770
243
4
15
13
32
Land transport & 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
Mining & metals*
336
42
4
382
627
131
2
4
6
Oil and gas*
1,482
141
52
1,675
1,126
453
1
14
28
43
Power utilities*
3,844
220
6
4,070
5,622
404
2
3
1
6
Retail*
6,380
1,342
180
7,902
4,872
410
8
29
66
103
Shipping*
506
334
27
867
90
12
1
11
10
22
Water & waste*
2,714
230
4
2,948
1,850
91
2
5
2
9
Total
330,824
33,981
5,022
369,827
123,582
4,314
302
1,478
2,026
3,806
* Wholesale sectors marked with an asterisk contain an element of exposure classified as heightened climate-related risk. Elements of the personal mortgage portfolio are also exposed
to heightened climate-related risk. The classification of sectors into heightened climate-related risk mentioned within this footnote is not within audit scope.
**Financial institutions (FI) include transactions, such as securitisations, where the underlying assets may be in other sectors.
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
218
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Wholesale forbearance
(audited)
The table below shows Wholesale forbearance, Heightened Monitoring and Risk of Credit Loss by sector. Personal forbearance is
disclosed in the Personal portfolio section. The table shows current exposure but reflects risk transfers where there is a guarantee
by another customer.
Property
FI
Other corporate
Total
2022
£m
£m
£m
£m
Forbearance (flow)
746
105
2,575
3,426
Forbearance (stock)
933
107
4,709
5,749
Heightened Monitoring and Risk of Credit Loss
976
112
3,445
4,533
2021
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
Sector analysis – portfolio summary
(audited)
Loans by geography and sector
– In line with NatWest
Group’s strategic focus, exposures continued to be mainly
in the UK. Exposure to the Republic of Ireland reduced
during the year as part of the phased withdrawal noted
previously. In Personal, balance sheet growth was a result
of strong mortgage demand during the year. In Wholesale,
there was a reduction in the balance sheet in Q4, following
a period of growth up to Q3. This was mainly due to a
reduction in central items held in the course of treasury
related management activities. There was growth in
Commercial & Institutional, particularly as a result of
increased exposure to financial institutions, notably
leveraged funds, and larger corporate customers, primarily
within information technology, telecommunications and
power utilities. Repayment performance under COVID-19
government lending schemes is closely tracked and
exposure continued to decrease due to scheduled
repayment activity and account closures. Exposures under
the Bounce Bank Loan Scheme (BBLS) that benefit from the
100% government guarantee account for approximately
70% of remaining government scheme exposures. BBLS
missed repayment rate and recoveries stock have increased
but volumes continue to be in line with other lenders.
Loans by stage
– In both Wholesale and Personal,
deterioration in forward-looking economics resulted in a
larger proportion of accounts exhibiting a SICR compared
to 2021. There was, therefore, a migration of exposures
from Stage 1 into Stage 2 during 2022. Personal customers
who had accessed payment holiday support, and where
their risk profile was identified as relatively high, are no
longer collectively migrated into Stage 2. The relevance of
this collective SICR identification was no longer considered
as pertinent in the context of the current high inflation
environment and related uncertainty.
Loans – Past due analysis
– Overall, the past due profile of
the key portfolios remained broadly stable. The
implementation of the new regulatory default definition
included refinements to the days past due calculations. This
contributed to an increase in arrears in H1 2022 in
Personal, however this moderated through the year.
Particularly in mortgages, the exit from the Republic of
Ireland also contributed to the reduction in past due
exposures. In Wholesale, there was an increase in past due
1-30 days in corporates.
Weighted average 12 months PDs
– In Personal, the Basel II
point-in-time PDs improved slightly during 2022 due to
stable credit performance in the portfolios. For IFRS 9 PDs,
there were increases across mortgages and other personal
lending as a result of new PD model implementations during
the year, coupled with the deteriorating economic outlook
in the second half of the year. For credit cards, the new
IFRS 9 PD model implementation drove a net reduction in
PD levels, primarily resulting from more accurate modelling
of defaults driven by shifts in general unemployment. In
Wholesale, the Basel II PDs were based on a through-the-
cycle approach and improved reflecting positive portfolio
performance.
The IFRS 9 PDs increased due the deterioration in forward-
looking economics. For further details refer to the Asset
quality section.
ECL provision by geography
– In line with loans by
geography, the vast majority of ECL related to exposures in
the UK, noting the reduction in RoI was mostly due to the
phased withdrawal of Ulster Bank RoI and moving of assets
to discontinued operations and reclassifications.
ECL provisions by stage
– As mentioned above, Stage 1 and
Stage 2 ECL increased due to deterioration in forward-
looking economics, although the Stage 2 growth was more
than offset by reductions in post model adjustments. Stage
3 provisions have yet to be materially affected by the high
inflation environment and supply chain disruption, with
increases relating to the introduction of the new regulatory
definition of default, largely offset by write offs.
ECL provisions coverage
– Overall provisions coverage
reduced, due to the phased withdrawal of Ulster Bank RoI,
a change in product mix and a decrease in judgemental
post model adjustments which more than offset increases
from the deteriorating economic outlook.
The ECL charge and loss rate
– ECL charge and loss rate
was low, with charges from a deterioration in forward-
looking economics countered by reductions in post model
adjustments and the continued stable portfolio performance
and low default trends.
Loans by residual maturity
– The maturity profile of the
portfolios remained consistent with prior periods. In
mortgages, as expected, the vast majority of exposures
were greater than five years. In unsecured lending – cards
and other – exposures were concentrated in less than five
years. In Wholesale, in financial institutions and sovereigns,
lending was concentrated in less than one year, In the rest
of Wholesale, most of the lending was for residual maturity
of one to five years.
Other financial assets by asset quality
– Consisting almost
entirely of cash and balances at central banks and debt
securities, held in the course of treasury related
management activities, these assets were mainly within the
AQ1-AQ4 bands.
Off-balance sheet exposures by asset quality
– In Personal,
undrawn exposures were reflective of available credit lines
in credit cards and current accounts. Additionally, the
mortgage portfolio had undrawn exposures, where a formal
offer had been made to a customer but had not yet drawn
down; the value increased in line with the pipeline of offers.
There was also a legacy portfolio of flexible mortgages
where a customer had the right and ability to draw down
further funds. The asset quality was aligned to the wider
portfolio. In Wholesale, growth was primarily loan
commitments to financial institutions and corporate sectors
in the AQ1-AQ4 bands.
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
219
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Sector analysis – portfolio summary
continued
(audited)
Wholesale forbearance
– Forbearance flow and stock
decreased in 2022 compared to 2021, noting that 2021 was
adversely affected by COVID-19. Increased levels of
forbearance were observed in Q4 2022. The retail & leisure,
property and services sectors represented the largest share
of forbearance flow. Labour shortages, the high inflation
environment, rising fuel and energy costs, interest rate
impacts and supply chain issues continue to weigh on these
sectors. Payment holidays and covenant waivers were the
most common forms of forbearance granted.
Heightened Monitoring and Risk of Credit Loss
Economic
headwinds continue to present an uncertain outlook. Risk of
Credit Loss framework exposures and inflows decreased in
2022 compared to 2021, noting again that 2021 was
adversely affected by COVID-19. Inflows into the
framework began to increase in Q4 2022. The sector
breakdown of exposures within the framework remained
consistent with prior periods. Retail SME customers do not
form part of the Wholesale Risk of Credit Loss framework.
Customers in this group, that are in financial difficulty, are
instead managed by specialist problem debt management
teams. The number of customers in arrears and recoveries
increased significantly during 2022, driven by BBLS
exposures. Excluding BBLS, the number of customers in this
population in problem debt remains stable.
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
220
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Credit risk enhancement and mitigation
(audited)
The table below shows exposures of modelled portfolios within the scope of the ECL framework and related credit risk
enhancement and mitigation (CREM).
Maximum credit risk
CREM by type
CREM coverage
Exposure post
CREM
Gross
exposure
ECL
Total
Stage 3
Financial
(1)
Property
Other (2)
Total
Stage 3
Total
Stage 3
2022
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
Financial assets
Cash and balances at central banks
143.2
143.2
143.2
Loans - amortised cost
(3)
377.2
3.3
373.9
3.4
31.8
243.1
21.7
296.6
3.0
77.3
0.4
Personal
(4)
217.2
1.7
215.5
1.9
0.9
202.1
203.0
1.7
12.5
0.2
Wholesale
(5)
160.0
1.6
158.4
1.5
30.9
41.0
21.7
93.6
1.3
64.8
0.2
Debt securities
29.9
29.9
29.9
Total financial assets
550.3
3.3
547.0
3.4
31.8
243.1
21.7
296.6
3.0
250.4
0.4
Contingent liabilities and commitments
Personal
(6,7)
43.2
43.2
0.3
0.7
4.4
5.1
38.1
0.3
Wholesale
93.9
0.1
93.8
0.4
3.1
7.4
4.0
14.5
0.1
79.3
0.3
Total off-balance sheet
137.0
0.1
136.9
0.7
3.8
11.8
4.0
19.6
0.1
117.3
0.6
Total exposure
687.3
3.4
683.9
4.1
35.6
254.9
25.7
316.2
3.1
367.7
1.0
2021
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
(1)
Includes cash and securities collateral.
(2)
Includes guarantees, charges over trade debtors, other 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 respect of individual 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 debtors; and guarantees of lending from parties other than the borrower. NatWest
Group obtains collateral in the form of securities in reverse repurchase agreements. Collateral 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 credit risk enhancement and mitigation in Wholesale mainly represent enterprise value and the impact of written down collateral values; an individual
assessment to determine ECL will consider multiple scenarios and in some instances allocate a probability weighting to a collateral value in excess of the written down value.
(6)
£0.3 billion (2021
£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 £14.0 billion (2021
£11.8 billion) in respect of pipeline mortgages where a committed offer has been made to a customer but where
the funds have not yet been drawn down. When drawn down, the exposure would be covered by a security over the borrower’s property.
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
221
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 portfolio section include drawn exposure (gross of provisions).
2022
2021
Retail
Banking
Private
Banking
Commercial &
Institutional
Central items
& other
Total
Retail
Banking
Private
Banking
Commercial &
Institutional
Central items &
other
Total
Personal lending
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Mortgages
186,891
13,709
2,357
202,957
172,707
12,781
2,444
6,164
194,096
Of which:
Owner occupied
168,790
12,096
1,541
182,427
158,059
11,219
1,597
5,563
176,438
Buy-to-let
18,101
1,613
816
20,530
14,648
1,562
847
601
17,658
Interest only - variable
3,515
3,286
258
7,059
4,348
4,889
346
120
9,703
Interest only - fixed
17,954
8,591
261
26,806
14,255
5,957
209
3
20,424
Mixed
(1)
9,768
1
16
9,785
8,616
1
17
34
8,668
ECL provisions
(2)
355
9
6
370
429
7
8
318
762
Other personal lending
(3)
11,935
1,853
267
143
14,198
10,829
1,974
305
218
13,326
ECL provisions
(2)
1,257
15
3
26
1,301
1,140
19
2
11
1,172
Total personal lending
198,826
15,562
2,624
143
217,155
183,536
14,755
2,749
6,382
207,422
Mortgage LTV ratios
- Owner occupied
52%
59%
56%
53%
54%
59%
57%
50%
54%
- Stage 1
52%
59%
56%
53%
54%
59%
56%
48%
54%
- Stage 2
52%
61%
60%
52%
52%
59%
62%
57%
52%
- Stage 3
45%
59%
74%
47%
49%
64%
77%
56%
53%
- Buy-to-let
50%
59%
53%
51%
50%
57%
53%
52%
51%
- Stage 1
51%
59%
53%
52%
50%
58%
53%
51%
51%
- Stage 2
49%
53%
48%
49%
52%
55%
50%
56%
52%
- Stage 3
47%
55%
57%
50%
51%
53%
60%
66%
56%
Gross new mortgage lending
41,227
2,968
327
44,522
35,290
2,874
340
40
38,544
Of which:
Owner occupied
36,305
2,701
221
39,227
33,630
2,583
206
40
36,459
Weighted average LTV
(4)
69%
65%
65%
69.0%
69%
65%
67%
62%
68%
Buy-to-let
4,922
267
106
5,295
1,660
292
134
2,086
Weighted average LTV
(4)
64%
66%
60%
64.0%
63%
65%
63%
60%
64%
Interest only - variable rate
24
329
11
364
25
832
37
894
Interest only - fixed rate
5,299
2,335
51
7,685
2,388
1,563
36
3,987
Mixed
(1)
2,309
2
2,311
2,256
7
2,263
Mortgage forbearance
Forbearance flow
(5)
182
7
4
193
316
19
4
50
389
Forbearance stock
1,015
16
8
1,039
1,156
3
8
944
2,111
Current
649
8
6
663
727
5
616
1,348
1-3 months in arrears
133
2
135
146
2
1
58
207
>3 months in arrears
233
8
241
283
1
2
270
556
(1)
Includes accounts which have an interest only sub-account and a capital and interest sub-account to provide a more comprehensive view of interest only exposures.
(2)
Retail Banking excludes a non-material amount of provisions held on relatively small legacy portfolios.
(3)
Comprises unsecured lending except for Private Banking, which includes both secured and unsecured lending. It excludes loans that are commercial in nature.
(4)
The new lending LTV in the comparative has been amended to reflect LTV at the time of lending origination rather than LTV at the reporting period.
(5)
Forbearance flows only include an account once per year, although some accounts may be subject to multiple forbearance deals. Forbearance deals post default are excluded from
these flows.
The mortgage portfolio grew steadily during 2022, benefiting
from buoyant housing market activity and customers re-
mortgaging as interest rates rose across the market.
LTV ratios improved as house prices increased as a result of
housing market demand.
The existing mortgage stock and new business were closely
monitored against agreed risk appetite parameters. These
included loan-to-value ratios, buy-to-let concentrations,
new-build concentrations and credit quality. Affordability
assessments and assumptions were continuously reviewed
considering inflationary pressure, interest rate rises and
taxation changes during the year.
The buy-to-let portfolio grew in 2022. This growth was
expected and within risk appetite following strategy and
customer journey simplification implemented in H2 2021.
Aligned to strong overall portfolio quality and low levels of
early arrears, forbearance flows have decreased compared
to the prior year.
Unsecured lending increased during 2022, with resilient
customer demand after the easing of COVID-19 restrictions.
As noted previously, ECL increased, for further detail of
movements in ECL provisions at product level refer to the
Flow statements section.
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
222
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 not within the scope of IFRS 9
ECL reflected portfolios carried at fair value.
Mortgages
ECL provisions
ECL provisions coverage (2)
Retail Banking
Stage 1
Stage 2
Stage 3
Not within
IFRS 9
ECL scope
Total
Of which;
gross
lending
Stage 1
Stage 2
Stage 3
Total (1)
Stage 1
Stage 2
Stage 3
Total
2022
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
%
%
%
%
≤50%
71,321
8,257
1,036
61
80,675
7,467
26
20
121
167
0.2
11.7
0.2
>50% and ≤70%
68,178
7,792
616
7
76,593
14,088
32
30
71
133
0.4
11.5
0.2
>70% and ≤80%
17,602
1,602
62
1
19,267
11,154
7
6
11
24
0.4
17.7
0.1
>80% and ≤90%
7,918
944
17
1
8,880
7,127
6
5
5
16
0.1
0.5
29.4
0.2
>90% and ≤100%
1,409
18
6
1,433
1,389
3
2
5
0.2
33.3
0.3
>100%
35
7
10
52
2
2
4
6
5.7
40.0
11.5
Total with LTVs
166,463
18,620
1,747
70
186,900
41,227
76
61
214
351
0.3
12.3
0.2
Other
59
1
1
61
3
1
4
5.1
100.0
6.6
Total
166,522
18,621
1,748
70
186,961
41,227
79
61
215
355
0.3
12.3
0.2
2021
≤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
(1)
Excludes a non-material amount of provisions held on relatively small legacy portfolios.
(2)
ECL provisions coverage is ECL provisions divided by mortgages.
The reduced coverage level in the lower LTV bands for
Retail Banking, relative to 31 December 2021, reflected the
implementation of a new IFRS 9 LGD model with a modelling
approach that now captures a reduced loss expectation
from non-repossession recovery action.
Continued stable portfolio performance alongside the new
IFRS 9 PD and LGD model implementations resulted in
reduced coverage across most LTV bands in Stage 2 and
Stage 3. The increased ECL across Stage 1 LTV bands was
mainly due to higher Stage 1 PDs as a result of the new PD
model implementation and also the proportionate allocation
of the economic uncertainty post model adjustment to Stage
1.
Risk and capital management
continued
NatWest Group
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Credit risk – Banking activities continued
Personal portfolio
(audited)
Retail Banking mortgage LTV distribution by region
The table below shows gross mortgage lending by LTV band for Retail Banking, by geographical region.
Flood risk*
≤50%
50%≤80%
80%≤100%
>100%
Total
Weighted
average LTV
Other
Total
Total
lending at
high/very high
risk**
2022
£m
£m
£m
£m
£m
%
£m
£m
%
%
South East
15,856
17,670
1,396
1
34,923
51
3
34,926
19
4.1
Greater London
15,200
17,550
1,336
1
34,087
51
3
34,090
18
2.3
Scotland
5,024
6,174
1,163
1
12,362
54
1
12,363
7
3.2
North West
7,670
8,672
1,236
2
17,580
52
2
17,582
9
2.2
South West
7,874
7,922
627
16,423
50
1
16,424
9
3.0
West Midlands
5,477
7,014
862
1
13,354
53
1
13,355
7
1.2
East of England
9,241
11,492
987
2
21,722
52
2
21,724
12
2.1
Rest of the UK
14,312
19,408
2,712
43
36,475
54
48
36,523
19
3.2
Total
80,654
95,902
10,319
51
186,926
52
61
186,987
100
2.8
2021
South East
13,160
18,298
886
1
32,345
53
3
32,348
19
4.4
Greater London
13,308
16,716
1,477
1
31,502
53
3
31,505
18
2.5
Scotland
4,493
6,529
559
2
11,583
54
1
11,584
7
3.5
North West
6,598
9,212
654
3
16,467
53
2
16,469
10
2.4
South West
6,140
8,619
499
1
15,259
53
2
15,261
9
3.4
West Midlands
4,323
7,449
553
1
12,326
55
1
12,327
6
1.8
East of England
7,467
11,679
820
1
19,967
54
2
19,969
12
2.6
Rest of the UK
10,937
20,278
2,001
26
33,242
56
2
33,244
19
3.6
Total
66,426
98,780
7,449
36
172,691
54
16
172,707
100
3.1
*Not within audit scope.
**Flood hazard is modelled by looking at the four different types of flooding (surface water, ground water, coastal and river) and
calculating the frequency and depth of flooding nationally to derive flood maps. Flood defences are considered where available.
Flood scores are allocated per property based on the potential flood damage to property dependent on the type, frequency and
depth of flooding modelled across different return periods. The scoring ranges from 0 to 53, with 0 being lowest and 53 being the
highest risk. We consider a score of 11 and above to be high risk and properties with a score of 31 and above within the very high
risk category after flood mitigants are taken into account. This is not within audit scope.
Risk and capital management
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Retail Banking mortgages by Energy Performance Certificate (EPC) rating*
The table below represents the energy efficiency of Retail Banking residential mortgages.
31 December 2022
31 December 2021
Owner
Occupied
Buy-to-let
Total
Owner
Occupied
Buy-to-let
Total
EPC rating
£bn
£bn
£bn
£bn
£bn
£bn
A
424
12
436
282
8
290
B
19,874
1,342
21,216
15,719
852
16,571
C
28,049
5,228
33,277
22,138
3,178
25,316
D
47,497
6,033
53,530
41,814
4,187
46,001
E
17,153
1,687
18,840
16,238
1,332
17,570
F
3,691
86
3,777
3,637
113
3,750
G
789
21
810
734
27
761
Unclassified
51,313
3,692
55,005
57,497
4,951
62,448
Total
168,790
18,101
186,891
158,059
14,648
172,707
*Not within audit scope.
As at 31 December 2022, £138.8 billion, 68%, of the total UK residential mortgages portfolio, including both Private Banking and
Retail Banking mortgages had Energy Performance Certificate (EPC) data available (2021 – £116.2 billion, 62%). Of which, 41.5%
were rated as EPC A to C (2021 – 38.3%). EPC data source and limitations are provided in section 5.2 of the 2022 NatWest Group
Climate-related Disclosures Report
Commercial real estate (CRE)*
The CRE portfolio comprises exposures to entities involved in the development of, or investment in, commercial and residential
properties (including house builders but excluding housing associations, construction and the building materials sub-sector). The
sector is reviewed regularly by senior executive committees. Reviews include portfolio credit quality, capital consumption and
control frameworks.
2022
2021
UK
RoI
Other
Total
UK
RoI
Other
Total
By geography and sub-sector (1)
£m
£m
£m
£m
£m
£m
£m
£m
Investment
Residential
(2)
4,583
2
13
4,598
4,326
10
16
4,352
Office
(3)
2,781
10
2,791
3,030
13
10
3,053
Retail
(4)
3,754
3,754
4,157
24
4,181
Industrial
(5)
2,939
184
3,123
2,758
2
106
2,866
Mixed/other
(6)
876
7
46
929
1,175
24
49
1,248
14,933
19
243
15,195
15,446
73
181
15,700
Development
Residential
(2)
1,693
7
1,700
1,775
34
2
1,811
Office
(3)
81
81
79
79
Retail
(4)
56
56
48
48
Industrial
(5)
90
90
67
67
Mixed/other
(6)
14
1
15
20
2
22
1,934
8
1,942
1,989
36
2
2,027
Total
16,867
27
243
17,137
17,435
109
183
17,727
*Not within audit scope.
(1)
Geographical 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 residential.
Risk and capital management
continued
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Credit risk – Banking activities continued
Commercial real estate (CRE)
CRE LTV distribution by stage
(audited)
The table below shows CRE current exposure and related ECL by LTV band.
Current exposure (gross of provisions)
ECL provisions
ECL provisions coverage
(2)
Stage 1
Stage 2
Stage 3
Not within
IFRS 9 ECL
scope (1)
Total
Stage 1
Stage 2
Stage 3
Total
Stage 1
Stage 2
Stage 3
Total
2022
£m
£m
£m
£m
£m
£m
£m
£m
£m
%
%
%
%
≤50%
7,010
658
57
67
7,792
36
12
16
64
0.5
1.8
28.1
0.8
>50% and ≤70%
3,515
798
43
19
4,375
23
18
12
53
0.7
2.3
27.9
1.2
>70% and ≤100%
259
82
156
7
504
1
3
42
46
0.4
3.7
26.9
9.1
>100%
102
10
23
1
136
1
1
14
16
1.0
10.0
60.9
11.8
Total with LTVs
10,886
1,548
279
94
12,807
61
34
84
179
0.6
2.2
30.1
1.4
Total portfolio
average LTV%
45%
52%
75%
44%
47%
Other
(3)
1,800
627
55
86
2,568
9
15
27
51
0.5
2.4
49.1
2.0
Development
(4)
1,553
332
57
7
1,949
13
8
28
49
0.8
2.4
49.1
2.5
Total
14,239
2,507
391
187
17,324
83
57
139
279
0.6
2.3
35.6
1.6
2021
≤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
127
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
293
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
(3)
2,271
293
61
83
2,708
4
13
28
45
0.2
4.4
45.9
1.7
Development
(4)
1,736
228
62
77
2,103
3
6
34
43
0.2
2.6
54.8
2.0
Total
15,733
1,578
416
910
18,637
15
50
151
216
0.1
3.2
36.3
1.2
(1)
Includes exposures relating to non-modelled portfolios and other exposures carried at fair value.
(2)
ECL provisions coverage is ECL provisions divided by gross loans.
(3)
Relates mainly to business banking, rate risk management products and unsecured corporate lending.
(4)
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 was
aligned across NatWest Group.
2022 trends
– The commercial property cycle turned around
mid-year as rising interest rates started to put upward
pressure on property yields. Commercial property values
declined by an average of approximately 20% from their
mid-year peak, ending the year approximately 14% lower.
The industrial sector saw values fall fastest to date, yet it
continues to attract strong occupier demand and may,
therefore, be the first sector to see values stabilise.
Secondary offices which don’t match modern sustainability
standards appear most at risk from further value loss. The
residential sector has yet to show significant value declines,
but transaction activity has slowed materially and is
expected to remain weak until values have adjusted. The
spike in mortgage costs last year would be expected to push
prices down across the market in 2023. In contrast,
residential rents appreciated rapidly in 2022 and
professionally managed rental assets are expected to be
relatively robust in 2023.
Credit quality
– Credit quality was stable for the first nine
months of the year but the impacts from the increase in
base rate, projected capital value falls, inflationary pressures
and concerns over recession for some customers began to
materialise. Inflows into the Risk of Credit Loss framework
picked up in Q4, but remained relatively low in volume
terms, compared to previous downturns.
Risk appetite
– Lending appetite is subject to regular review
with some level of tightening undertaken in 2022. Demand
for facilities reduced significantly in Q4 as the market
reacted to the various negative news points.
Risk and capital management
continued
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Credit risk – Banking activities continued
Flow statements
(audited)
The flow statements that follow show the main ECL and related
income statement movements. They also show the changes in
ECL as well as the changes in related financial assets used in
determining ECL. Due to differences in scope, exposures may
differ from
those reported in other tables, principally in relation
to exposures in Stage 1 and Stage 2. These differences do not
have a material ECL effect. Other points to note:
Financial assets include treasury liquidity portfolios,
comprising balances at central banks and debt securities,
as well as loans. Both modelled and non-modelled portfolios
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 transitioning to a
worse stage being a primary driver of income statement
charges. Similarly, there is an ECL benefit for accounts
improving stage.
Changes in risk parameters shows the reassessment of the
ECL within a given stage, including any ECL overlays and
residual income statement gains or losses at the point of
write-off or accounting write-down.
Other (P&L only items) includes any subsequent changes in
the value of written-down assets (for example, fortuitous
recoveries) along with other direct write-off items such as
direct recovery costs. Other (P&L only items) affects the
income statement but does not affect 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 default events.
The effect of any change in post model adjustments during
the year is typically reported under changes in risk
parameters, as are any effects arising from 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 suspended interest
during the year reported under currency translation and
other adjustments.
Stage 1
Stage 2
Stage 3
Total
Financial
assets
ECL
Financial
assets
ECL
Financial
assets
ECL
Financial
assets
ECL
NatWest Group total
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January 2022
546,178
302
35,557
1,478
5,238
2,026
586,973
3,806
Currency translation and other adjustments
6,129
144
3
56
33
6,329
36
Transfers from Stage 1 to Stage 2
(55,848)
(226)
55,848
226
Transfers from Stage 2 to Stage 1
31,657
827
(31,657)
(827)
Transfers to Stage 3
(621)
(4)
(3,679)
(265)
4,300
269
Transfers from Stage 3
485
34
842
77
(1,327)
(111)
Net re-measurement of ECL on stage transfer
(701)
1,090
352
741
Changes in risk parameters
286
(399)
140
27
Other changes in net exposure
(12,164)
125
(7,911)
(293)
(1,969)
(96)
(22,044)
(264)
Other (P&L only items)
(5)
(162)
(167)
Income statement (releases)/charges
(290)
393
234
337
Transfers to disposal groups and fair value
(8,277)
(11)
(657)
(42)
(590)
(286)
(9,524)
(339)
Amounts written-off
(5)
(5)
(477)
(477)
(482)
(482)
Unwinding of discount
(91)
(91)
At 31 December 2022
507,539
632
48,482
1,043
5,231
1,759
561,252
3,434
Net carrying amount
506,907
47,439
3,472
557,818
At 1 January 2021
446,666
519
81,667
3,081
6,524
2,586
534,857
6,186
2021 movements
99,512
(217)
(46,110)
(1,603)
(1,286)
(560)
52,116
(2,380)
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
Risk and capital management
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Credit risk – Banking activities continued
Flow statements
(audited)
Stage 1
Stage 2
Stage 3
Total
Financial
assets
ECL
Financial
assets
ECL
Financial
assets
ECL
Financial
assets
ECL
Retail Banking - mortgages
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January 2022
159,966
24
10,748
155
1,267
250
171,981
429
Currency translation and other adjustments
10
8
10
8
Transfers from Stage 1 to Stage 2
(18,858)
(9)
18,858
9
Transfers from Stage 2 to Stage 1
8,261
69
(8,261)
(69)
Transfers to Stage 3
(53)
(1,286)
(36)
1,339
36
Transfers from Stage 3
42
1
395
18
(437)
(19)
Net re-measurement of ECL on stage transfer
(66)
95
(13)
16
Changes in risk parameters
59
(93)
32
(2)
Other changes in net exposure
15,906
1
(1,622)
(17)
(389)
(11)
13,895
(27)
Other (P&L only items)
(2)
(62)
(64)
Income statement (releases)/charges
(6)
(17)
(54)
(77)
Amounts written-off
(1)
(1)
(28)
(28)
(29)
(29)
Unwinding of discount
(40)
(40)
At 31 December 2022
165,264
79
18,831
61
1,762
215
185,857
355
Net carrying amount
165,185
18,770
1,547
185,502
At 1 January 2021
132,390
23
28,079
227
1,291
236
161,760
486
2021 movements
27,576
1
(17,331)
(72)
(24)
14
10,221
(57)
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
Despite the strong portfolio growth during 2022, ECL levels
for mortgages reduced during the year, primarily as a result
of stable portfolio performance alongside the
implementation of new IFRS 9 models in Q1 2022.
More specifically, in H1 2022, strong credit performance
resulted in the migration of assets from Stage 2 into Stage
1, with an associated decrease from lifetime ECL to a 12
month ECL. ECL levels increased in the second half of the
year as the portfolio continued to grow and the economic
outlook deteriorated, increasing IFRS 9 PDs and the level of
migrations from Stage 1 into Stage 2.
The economic uncertainty post model adjustment allocated
more ECL to Stage 1 given the forward-looking nature of
the inflation threat on customer affordability, whereas the
previous COVID-19 post model adjustment was focused on
Stage 2 (for example, high risk payment holiday cases
migrated into Stage 2). Refer to the Governance and post
model adjustments section for more information.
The Stage 3 inflow was amplified by the adoption of the
new regulatory definition of default in January 2022.
However, Stage 3 ECL levels decreased since 31 December
2021, primarily due to reduced LGD estimates as a result of
the new model implementation in Q1 2022 alongside stable
underlying default levels. The relatively small ECL cost for
net re-measurement on stage transfer included 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 typically occurs once the repossessed property
has been sold and there is a residual shortfall balance
remaining outstanding. This would typically be within five
years from default but can be longer.
Risk and capital management
continued
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Credit risk – Banking activities continued
Flow statements
(audited)
Stage 1
Stage 2
Stage 3
Total
Financial
assets
ECL
Financial
assets
ECL
Financial
assets
ECL
Financial
assets
ECL
Retail Banking - credit cards
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January 2022
2,740
58
947
141
91
60
3,778
259
Currency translation and other adjustments
1
1
1
1
Transfers from Stage 1 to Stage 2
(1,278)
(41)
1,278
41
Transfers from Stage 2 to Stage 1
942
101
(942)
(101)
Transfers to Stage 3
(23)
(1)
(102)
(42)
125
43
Transfers from Stage 3
2
1
9
3
(11)
(4)
Net re-measurement of ECL on stage transfer
(64)
161
29
126
Changes in risk parameters
7
(29)
15
(7)
Other changes in net exposure
679
(92)
(54)
(27)
(1)
560
(55)
Other (P&L only items)
(6)
(6)
Income statement (releases)/charges
(57)
78
37
58
Amounts written-off
(66)
(66)
(66)
(66)
Unwinding of discount
(6)
(6)
At 31 December 2022
3,062
61
1,098
120
113
71
4,273
252
Net carrying amount
3,001
978
42
4,021
At 1 January 2021
2,250
52
1,384
220
114
75
3,748
347
2021 movements
490
6
(437)
(79)
(23)
(15)
30
(88)
At 31 December 2021
2,740
58
947
141
91
60
3,778
259
Net carrying amount
2,682
806
31
3,519
ECL remained broadly stable during 2022 reflecting stable
portfolio performance and the unwind of ECL held for
COVID-19 related risks in the first half of the year that
resulted in reduced levels of SICR identification and ECL
requirement. In addition, a new credit card PD model
implementation resulted in a net ECL decrease of £26
million. This is included in changes in risk parameters for
Stage 1 and Stage 2.
Similar to mortgages, ECL levels increased in the second
half of the year as the economic outlook deteriorated,
increasing IFRS 9 PDs and the level of migrations from
Stage 1 into Stage 2.
Credit card balances grew since 31 December 2021, in line
with industry trends in the UK, as unsecured borrowing
demand increased.
Reflecting the strong credit performance observed during
2022, Stage 3 inflows remained subdued and the effect of
the adoption of the new regulatory definition of default was
minimal for credit cards.
Charge-off (analogous to partial write-off) typically occurs
after 12 missed payments.
Risk and capital management
continued
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Additional information
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Credit risk – Banking activities continued
Flow statements
(audited)
Stage 1
Stage 2
Stage 3
Total
Financial
assets
ECL
Financial
assets
ECL
Financial
assets
ECL
Financial
assets
ECL
Retail Banking - other personal unsecured
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January 2022
4,548
52
1,967
294
629
540
7,144
886
Currency translation and other adjustments
(1)
9
10
9
9
Transfers from Stage 1 to Stage 2
(2,797)
(85)
2,797
85
Transfers from Stage 2 to Stage 1
1,948
225
(1,948)
(225)
Transfers to Stage 3
(40)
(1)
(356)
(111)
396
112
Transfers from Stage 3
5
3
39
20
(44)
(23)
Net re-measurement of ECL on stage transfer
(177)
296
115
234
Changes in risk parameters
38
(34)
35
39
Other changes in net exposure
1,120
56
(471)
(55)
(90)
(26)
559
(25)
Other (P&L only items)
Income statement (releases)/charges
(83)
207
124
248
Amounts written-off
(121)
(121)
(121)
(121)
Unwinding of discount
(11)
(11)
At 31 December 2022
4,784
111
2,028
269
779
631
7,591
1,011
Net carrying amount
4,673
1,759
148
6,580
At 1 January 2021
3,385
59
3,487
450
596
495
7,468
1,004
2021 movements
1,163
(7)
(1,520)
(156)
33
45
(324)
(118)
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
Overall, there was a modest ECL increase, mainly due to
portfolio growth in the personal loan portfolio during 2022
and Stage 3 ECL, linked to the adoption of the new
regulatory definition of default in January 2022, with
underlying Stage 3 inflows remaining stable.
Similar to the other personal portfolios, after reductions in
the first half of the year, Stage 2 ECL levels increased in the
second half of the year as the economic outlook
deteriorated, increasing IFRS 9 PDs and the level of
migrations from Stage 1 into Stage 2.
Unsecured retail lending balances grew since 31 December
2021, in line with industry trends in the UK, as unsecured
borrowing demand increased.
Write-off occurs once recovery activity with the customer
has been concluded or there are no further recoveries
expected, but no later than six years after default.
Risk and capital management
continued
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Credit risk – Banking activities continued
Flow statements
(audited)
Stage 1
Stage 2
Stage 3
Total
Financial
assets
ECL
Financial
assets
ECL
Financial
assets
ECL
Financial
assets
ECL
Commercial & Institutional total
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January 2022
152,224
129
19,731
785
2,155
750
174,110
1,664
Currency translation and other adjustments
3,336
(1)
146
(1)
23
4
3,505
2
Inter-group transfers
Transfers from Stage 1 to Stage 2
(30,103)
(80)
30,103
80
Transfers from Stage 2 to Stage 1
18,729
400
(18,729)
(400)
Transfers to Stage 3
(232)
(1)
(1,667)
(65)
1,899
66
Transfers from Stage 3
217
29
194
27
(411)
(56)
Net re-measurement of ECL on stage transfer
(371)
505
212
346
Changes in risk parameters
172
(256)
68
(16)
Other changes in net exposure
16,181
65
(5,063)
(137)
(1,248)
(48)
9,870
(120)
Other (P&L only items)
(1)
(4)
(83)
(88)
Income statement (releases)/charges
(135)
108
149
122
Amounts written-off
(4)
(4)
(220)
(220)
(224)
(224)
Unwinding of discount
(29)
(29)
At 31 December 2022
160,352
342
24,711
534
2,198
747
187,261
1,623
Net carrying amount
160,010
24,177
1,451
185,638
At 1 January 2021
131,307
296
42,290
1,836
2,998
1,249
176,595
3,381
2021 movements
20,917
(167)
(22,559)
(1,051)
(843)
(499)
(2,485)
(1,717)
At 31 December 2021
152,224
129
19,731
785
2,155
750
174,110
1,664
Net carrying amount
152,095
18,946
1,405
172,446
(1)
Flows relating to the SME portion of Commercial & Institutional is included in the relevant sector sub-sector tables.
Exposure growth was mainly due to increased exposure to
larger corporate customers and financial institutions,
notably leveraged funds, information technology,
telecommunications and power utilities.
Stage 1 and Stage 2 ECL levels increased in the second half
of the year as the economic outlook deteriorated,
increasing IFRS 9 PDs and the level of migrations from
Stage 1 into Stage 2.
Stage 2 ECL increases were more than offset by reductions
in post model adjustments.
There were significant flows into Stage 3 due to defaults on
government scheme lending, principally BBLS, with
exposure reductions where payments on guarantees have
been received.
Risk and capital management
continued
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Credit risk – Banking activities continued
Flow statements
(audited)
Stage 1
Stage 2
Stage 3
Total
Financial
assets
ECL
Financial
assets
ECL
Financial
assets
ECL
Financial
assets
ECL
Commercial & Institutional - corporate
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January 2022
49,066
91
15,305
643
1,378
527
65,749
1,261
Currency translation and other adjustments
656
124
(1)
18
7
798
6
Inter-group transfers
1
(3)
(2)
Transfers from Stage 1 to Stage 2
(21,063)
(60)
21,063
60
Transfers from Stage 2 to Stage 1
13,594
305
(13,594)
(305)
Transfers to Stage 3
(161)
(1)
(1,143)
(49)
1,304
50
Transfers from Stage 3
117
23
126
21
(243)
(44)
Net re-measurement of ECL on stage transfer
(283)
389
157
263
Changes in risk parameters
95
(223)
(2)
(130)
Other changes in net exposure
7,079
39
(3,098)
(105)
(906)
(30)
3,075
(96)
Other (P&L only items)
(2)
(77)
(79)
Income statement (releases)/charges
(149)
59
48
(42)
Amounts written-off
(4)
(4)
(154)
(154)
(158)
(158)
Unwinding of discount
(14)
(14)
At 31 December 2022
49,288
210
18,779
423
1,397
497
69,464
1,130
Net carrying amount
49,078
18,356
900
68,334
Exposure growth was driven by increased exposure to
larger corporate customers, information technology,
telecommunications and power utilities.
Stage 1 and Stage 2 ECL levels increased in the second half
of the year as the economic outlook deteriorated, increasing
IFRS 9 PDs and the level of migrations from Stage 1 into
Stage 2.
Stage 2 ECL increases were more than offset by reductions
in post model adjustments.
There were significant flows into Stage 3 due to defaults on
government scheme lending, principally BBLS, with exposure
reductions where payments on guarantees have been
received.
Risk and capital management
continued
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Credit risk – Banking activities continued
Flow statements
(audited)
Stage 1
Stage 2
Stage 3
Total
Financial
assets
ECL
Financial
assets
ECL
Financial
assets
ECL
Financial
assets
ECL
Commercial & Institutional - property
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January 2022
26,991
22
3,128
99
678
208
30,797
329
Currency translation and other adjustments
29
1
(9)
29
(8)
Inter-group transfers
(1)
(1)
Transfers from Stage 1 to Stage 2
(5,654)
(17)
5,654
17
Transfers from Stage 2 to Stage 1
2,672
47
(2,672)
(47)
Transfers to Stage 3
(49)
(431)
(16)
480
16
Transfers from Stage 3
56
6
61
6
(117)
(12)
Net re-measurement of ECL on stage transfer
(46)
94
44
92
Changes in risk parameters
71
(27)
28
72
Other changes in net exposure
2,089
17
(1,439)
(30)
(375)
(18)
275
(31)
Other (P&L only items)
(1)
(7)
(8)
Income statement (releases)/charges
41
37
47
125
Amounts written-off
(24)
(24)
(24)
(24)
Unwinding of discount
(13)
(13)
At 31 December 2022
26,134
100
4,301
96
642
220
31,077
416
Net carrying amount
26,034
4,205
422
30,661
Stage 1 and Stage 2 ECL levels increased in the second half
of the year as the economic outlook deteriorated,
increasing IFRS 9 PDs and the level of migrations from
Stage 1 into Stage 2.
Stage 2 ECL increases were partially offset by reductions in
post model adjustments.
There were significant flows into Stage 3 due to defaults on
government scheme lending, principally BBLS, with
exposure reductions where payments on guarantees have
been received.
Risk and capital management
continued
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Credit risk – Banking activities continued
Flow statements
(audited)
Stage 1
Stage 2
Stage 3
Total
Financial
assets
ECL
Financial
assets
ECL
Financial
assets
ECL
Financial
assets
ECL
Commercial & Institutional - other
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January 2022
76,167
16
1,298
43
99
15
77,564
74
Currency translation and other adjustments
2,649
22
5
4
2,676
4
Inter-group transfers
(1)
5
(2)
2
Transfers from Stage 1 to Stage 2
(3,387)
(4)
3,387
4
Transfers from Stage 2 to Stage 1
2,464
48
(2,464)
(48)
Transfers to Stage 3
(21)
(93)
(1)
114
1
Transfers from Stage 3
45
7
(52)
Net re-measurement of ECL on stage transfer
(43)
22
12
(9)
Changes in risk parameters
7
(6)
41
42
Other changes in net exposure
7,013
9
(526)
(4)
34
(1)
6,521
4
Other (P&L only items)
2
2
Income statement (releases)/charges
(27)
12
54
39
Amounts written-off
(41)
(41)
(41)
(41)
Unwinding of discount
(1)
(1)
At 31 December 2022
84,930
32
1,631
15
159
30
86,720
77
Net carrying amount
84,898
1,616
129
86,643
(1)
Commercial & Institutional other includes FIs, Sovereigns, and non-wholesale elements of Commercial & Institutional.
Stage 1 and Stage 2 ECL levels increased in the second half
of the year as the economic outlook deteriorated,
increasing IFRS 9 PDs and the level of migrations from
Stage 1 into Stage 2.
Stage 2 ECL increases were more than offset by reductions
in post model adjustments.
The reduction in post model adjustments more than offset
ECL increases from deteriorating economics.
Risk and capital management
continued
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Credit risk – Banking activities continued
Stage 2 decomposition – arrears status and contributing factors
The tables below show Stage 2 decomposition for the Personal and Wholesale portfolios.
UK mortgages
Credit cards
Other
Total
Loans
ECL
Loans
ECL
Loans
ECL
Loans
ECL
2022
£m
£m
£m
£m
£m
£m
£m
£m
Personal
Currently >30 DPD
205
1
10
5
52
18
267
24
Currently <=30 DPD
18,582
61
1,066
117
1,939
264
21,587
442
- PD deterioration
16,342
56
805
97
1,093
150
18,240
303
- PD persistence
867
2
200
13
185
16
1,252
31
- Other driver (adverse credit, forbearance etc)
1,373
3
61
7
661
98
2,095
108
Total Stage 2
18,787
62
1,076
122
1,991
282
21,854
466
2021
Personal
Currently >30 DPD
397
9
11
6
88
16
496
31
Currently <=30 DPD
10,593
148
922
135
2,412
300
13,927
583
- PD deterioration
2,400
56
549
96
1,028
178
3,977
330
- PD persistence
3,088
38
270
23
791
92
4,149
153
- Other driver (adverse credit, forbearance etc)
5,105
54
103
16
593
30
5,801
100
Total Stage 2
10,990
157
933
141
2,500
316
14,423
614
The deterioration in economic outlook during the second
half of the year resulted in increased account level IFRS 9
PDs at the year end. Consequently, compared to 2021, a
larger proportion of accounts exhibited significant PD
deterioration causing Stage 2 exposures to increase
significantly since 30 June 2022.
Higher risk Personal customers who had accessed COVID-
19 payment holiday support are no longer collectively
migrated into Stage 2 with the focus of high risk segment
monitoring now shifting to the effects of a high inflation
environment on customers. In UK mortgages at 31
December 2021, approximately £0.8 billion of exposures
were previously collectively migrated from Stage 1 into
Stage 2.
Accounts that are less than 30 days past due continue to
represent the vast majority of the Stage 2 population. As
expected, ECL coverage was higher in accounts that were
more than 30 days past due than those in Stage 2 for other
reasons.
Property
Corporate
Financial
institutions
Sovereign
Total
Loans
ECL
Loans
ECL
Loans
ECL
Loans
ECL
Loans
ECL
2022
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Wholesale
Currently >30 DPD
259
3
476
11
3
7
745
14
Currently <=30 DPD
4,057
102
18,677
446
1,350
14
150
1
24,234
563
- PD deterioration
2,739
68
15,399
351
1,230
10
79
19,447
429
- PD persistence
87
3
263
9
5
355
12
- Other driver (forbearance, RoCL etc)
1,231
31
3,015
86
115
4
71
1
4,432
122
Total Stage 2
4,316
105
19,153
457
1,353
14
157
1
24,979
577
2021
Wholesale
Currently >30 DPD
239
3
390
8
19
648
11
Currently <=30 DPD
2,862
108
15,214
705
713
39
121
1
18,910
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
15,604
713
732
39
121
1
19,558
864
The deteriorating economic outlook, including lower
growth in GDP and the stock index as well as a reduction
in commercial real estate prices, resulted in a significant
increase in IFRS 9 PDs. Consequently, compared to 2021,
a larger proportion of exposure exhibited a SICR and
migrated into Stage 2, resulting in an increase in Stage 2
exposure.
PD deterioration remained the primary trigger for
identifying a SICR and Stage 2 treatment, proportionally
increasing due to the deteriorating economic outlook.
There was a decrease in Risk of Credit Loss partially due
to PD deterioration being the primary trigger. Overall,
there was a decrease in flows on to the Risk of Credit
Loss framework, although inflows into the framework
began to increase in Q4 2022.
Risk and capital management
continued
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Credit risk – Banking activities continued
Stage 2 decomposition – by a significant increase in credit risk trigger
UK mortgages
Credit cards
Other
Total
2022
£m
%
£m
%
£m
%
£m
%
Personal trigger
(1)
PD movement
16,477
87.7
814
75.7
1,129
56.7
18,420
84.3
PD persistence
866
4.6
200
18.6
186
9.3
1,252
5.7
Adverse credit bureau recorded with credit
reference agency
929
4.9
52
4.8
96
4.8
1,077
4.9
Forbearance support provided
101
0.5
1
0.1
17
0.9
119
0.5
Customers in collections
153
0.8
2
0.2
4
0.2
159
0.7
Collective SICR and other reasons
(2)
195
1.0
7
0.7
546
27.4
748
3.4
Days past due >30
66
0.4
13
0.7
79
0.4
18,787
100.0
1,076
100.0
1,991
100.0
21,854
100.0
2021
Personal trigger
(1)
PD movement
2,707
24.6
560
60.1
1,091
43.6
4,358
30.2
PD persistence
3,103
28.2
270
28.9
792
31.7
4,165
28.9
Adverse credit bureau recorded with credit
reference agency
3,657
33.3
60
6.4
73
2.9
3,790
26.3
Forbearance support provided
178
1.6
2
0.2
34
1.4
214
1.5
Customers in collections
82
0.8
3
0.3
48
1.9
133
0.9
Collective SICR and other reasons
(2)
1,197
10.9
38
4.1
455
18.2
1,690
11.7
Days past due >30
66
0.6
7
0.3
73
0.5
10,990
100
933
100
2,500
100
14,423
100
For the notes to this table refer to the following page.
During the first half of the year, the stable credit
performance of the portfolio resulted in either decreased
or stable account level IFRS 9 PDs for most products. UK
mortgages was the exception, where the implementation
of a new IFRS 9 PD model in Q1 2022 increased the
proportion of accounts exhibiting significant PD
deterioration.
However, in the second half of the year, the economic
uncertainty and high inflation environment, which is
reflected in the recent updates to the IFRS 9 MES
scenarios, resulted in PDs increasing again. This is
reflected both in an increase in Stage 2 across all
products compared to 31 December 2021 and an
increased proportion of Stage 2 driven by PD
deterioration.
Personal customers who had accessed COVID-19
payment holiday support, and where their risk profile
was identified as relatively high risk are no longer
collectively migrated into Stage 2, given the lack of
default emergence from these segments and with the
focus of high risk segment monitoring now shifting to the
effects of a high inflation environment on customers. In
UK mortgages at 31 December 2021, approximately £0.8
billion of exposures were previously collectively migrated
from Stage 1 into Stage 2.
Risk and capital management
continued
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Credit risk – Banking activities continued
Stage 2 decomposition – by a significant increase in credit risk trigger continued
Property
Corporate
Financial institutions
Sovereign
Total
2022
£m
%
£m
%
£m
%
£m
%
£m
%
Wholesale trigger
(1)
PD movement
2,807
65.0
15,645
81.7
1,231
91.0
79
50.3
19,762
79.2
PD persistence
88
2.0
263
1.4
5
0.4
356
1.4
Risk of Credit Loss
618
14.4
1,587
8.3
32
2.4
55
35.0
2,292
9.2
Forbearance support provided
44
1.0
473
2.5
19
1.4
536
2.1
Customers in collections
13
0.3
44
0.2
57
0.2
Collective SICR and other reasons
(2)
575
13.3
946
4.9
64
4.7
16
10.2
1,601
6.4
Days past due >30
171
4.0
195
1.0
2
0.1
7
4.5
375
1.5
4,316
100.0
19,153
100.0
1,353
100.0
157
100.0
24,979
100.0
2021
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
(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 cases where a PD assessment cannot be made and accounts where the PD has deteriorated beyond a prescribed backstop threshold aligned to risk management
practices.
PD deterioration continued to be the primary trigger of
migration of exposures from Stage 1 into Stage 2. There
was an increase in cases triggering PD deterioration
reflecting the deteriorating economic outlook.
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 decreased over the period due to the increase in
PD deterioration.
PD persistence related to the Business Banking portfolio
only. A reduction in PDs in 2021 meant that some Business
Banking customers returned to Stage 1 in early 2022,
although a number of these customers returned through PD
movement in the second half of the year due to the
deteriorating economic outlook.
Stage 3 vintage analysis
The table below shows estimated vintage analysis of the material Stage 3 portfolios.
2022
2021
Retail Banking
mortgages
Wholesale
Retail Banking
mortgages
Wholesale
Stage 3 loans (£bn)
1.7
2.5
1.2
2.1
Vintage (time in default):
<1 year
43%
29%
26%
19%
1-3 years
26%
12%
30%
20%
3-5 years
12%
7%
13%
7%
5-10 years
9%
52%
17%
54%
>10 years
10%
14%
100%
100%
100%
100%
Retail
Banking mortgages
– The increase in the proportion of
loans in Stage 3 for less than one year was mainly due to the
adoption of the new regulatory definition of default in
January 2022.
Wholesale
– Exposures which were 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 process.
Risk and capital management
continued
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Credit risk – Banking activities continued
Asset quality
(audited)
The table below shows asset quality bands of gross loans and ECL, by stage, for the Personal portfolio.
Gross loans
ECL provisions
ECL provisions coverage
Stage 1
Stage 2
Stage 3
Total
Stage 1
Stage 2
Stage 3
Total
Stage 1
Stage 2
Stage 3
Total
2022
£m
£m
£m
£m
£m
£m
£m
£m
%
%
%
%
UK mortgages
AQ1-AQ4
116,559
9,208
125,767
45
24
69
0.04
0.26
0.05
AQ5-AQ8
65,510
8,962
74,472
36
34
70
0.1
0.4
0.1
AQ9
176
617
793
4
4
0.7
0.5
AQ10
1,925
1,925
233
233
12.1
12.1
182,245
18,787
1,925
202,957
81
62
233
376
0.0
0.3
12.1
0.2
RoI mortgages
AQ1-AQ4
AQ5-AQ8
AQ9
AQ10
Credit cards
AQ1-AQ4
98
98
AQ5-AQ8
3,172
1,036
4,208
61
112
173
1.9
10.8
4.1
AQ9
5
40
45
1
10
11
20.0
25.0
24.4
AQ10
109
109
73
73
67.0
67.0
3,275
1,076
109
4,460
62
122
73
257
1.9
11.3
67.0
5.8
Other personal
AQ1-AQ4
1,047
128
1,175
11
17
28
1.1
13.3
2.4
AQ5-AQ8
5,843
1,732
7,575
104
224
328
1.8
12.9
4.3
AQ9
28
131
159
2
41
43
7.1
31.3
27.0
AQ10
797
797
651
651
81.7
81.7
6,918
1,991
797
9,706
117
282
651
1,050
1.7
14.2
81.7
10.8
Total
AQ1-AQ4
117,704
9,336
127,040
56
41
97
0.1
0.4
0.1
AQ5-AQ8
74,525
11,730
86,255
201
370
571
0.3
3.2
0.7
AQ9
209
788
997
3
55
58
1.4
7.0
5.8
AQ10
2,831
2,831
957
957
33.8
33.8
192,438
21,854
2,831
217,123
260
466
957
1,683
0.1
2.1
33.8
0.8
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
238
Financial statements
Strategic report
Governance
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
Stage 2
Stage 3
Total
Stage 1
Stage 2
Stage 3
Total
Stage 1
Stage 2
Stage 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
In the Personal portfolio, the asset quality distribution
improved overall with high quality new business written
during 2022 and existing portfolio quality being maintained.
The majority of exposures were in AQ1-AQ4, with a
significant proportion in AQ5-AQ8. As expected, mortgage
exposures have a higher proportion in AQ1-AQ4 than
unsecured borrowing.
The increase in AQ10/Stage 3 balances was mainly because
of the IFRS 9 alignment to the new regulatory default
definition, implemented on 1 January 2022. This change
resulted in an increase in Stage 3 exposures of
approximately £0.7 billion, mostly in mortgages.
In other Personal, the relatively high level of exposures in
AQ10 reflected that impaired assets can be held on the
balance sheet, with commensurate ECL provision for up to
six years after default.
ECL provisions coverage shows the expected trend with
increased coverage in the weaker asset quality bands, and
also by stage.
Across the majority of asset quality bands, migration from
Stage 1 into Stage 2 was observed as the effect of updated
economic scenarios increased IFRS 9 PDs and therefore
Stage 2 exposure.
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
239
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Asset quality
(audited)
The table below shows asset quality bands of gross loans and ECL, by stage, for the Wholesale portfolio.
Gross loans
ECL provisions
ECL provisions coverage
Stage 1
Stage 2
Stage 3
Total
Stage 1
Stage 2
Stage 3
Total
Stage 1
Stage 2
Stage 3
Total
2022
£m
£m
£m
£m
£m
£m
£m
£m
%
%
%
%
Property
AQ1-AQ4
14,818
600
15,418
17
4
21
0.11
0.67
0.14
AQ5-AQ8
12,712
3,618
16,330
90
95
185
0.7
2.6
1.1
AQ9
12
98
110
6
6
6.1
5.5
AQ10
716
716
229
229
32.0
32.0
27,542
4,316
716
32,574
107
105
229
441
0.4
2.4
32.0
1.4
Corporate
AQ1-AQ4
17,447
5,184
22,631
23
37
60
0.1
0.7
0.3
AQ5-AQ8
35,567
13,643
49,210
195
398
593
0.6
2.9
1.2
AQ9
34
326
360
22
22
6.8
6.1
AQ10
1,476
1,476
553
553
37.5
37.5
53,048
19,153
1,476
73,677
218
457
553
1,228
0.4
2.4
37.5
1.7
Financial institutions
AQ1-AQ4
44,257
914
45,171
18
5
23
0.0
0.6
0.1
AQ5-AQ8
2,479
429
2,908
14
9
23
0.6
2.1
0.8
AQ9
2
10
12
AQ10
47
47
17
17
36.2
36.2
46,738
1,353
47
48,138
32
14
17
63
0.1
1.0
36.2
0.1
Sovereign
AQ1-AQ4
5,319
75
5,394
15
1
16
0.3
1.3
0.3
AQ5-AQ8
139
82
221
AQ9
AQ10
26
26
3
3
11.5
11.5
5,458
157
26
5,641
15
1
3
19
0.3
0.6
11.5
0.3
Total
AQ1-AQ4
81,841
6,773
88,614
73
47
120
0.1
0.7
0.1
AQ5-AQ8
50,897
17,772
68,669
299
502
801
0.6
2.8
1.2
AQ9
48
434
482
28
28
6.5
5.8
AQ10
2,265
2,265
802
802
35.4
35.4
132,786
24,979
2,265
160,030
372
577
802
1,751
0.3
2.3
35.4
1.1
2021
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
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
240
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Credit risk – Banking activities continued
Asset quality
(audited)
Across the Wholesale portfolio, asset quality remained
stable. The majority of the portfolio was within the AQ1-
AQ4, and AQ5-AQ8 bands. Distribution differs across
segments reflective of the underlying quality of
counterparties, with financial institutions and sovereigns
mostly in the AQ1-AQ4 bands, and property and corporates
mostly in the AQ5-AQ8 bands.
Customer credit grades were reassessed as and when a
request for financing was made, a scheduled customer
credit review was performed or a material credit event
specific to that customer occurred. Credit grades are
reassessed for all customers at least annually.
ECL provisions coverage showed the expected trend, with
increased coverage in the weaker asset quality bands within
Stage 2 compared to Stage 1, and again within Stage 3
compared to Stage 2.
Credit risk – Trading activities
This section details the credit risk profile of NatWest Group’s trading activities.
Securities financing transactions and collateral
(audited)
The table below shows securities funding transactions in NatWest Markets and Treasury. Balance sheet captions include balances
held at all classifications under IFRS.
Reverse Repos
Repos
Total
Of which
can be offset
Outside netting
arrangements
Total
Of which can be
offset
Outside netting
arrangements
2022
£m
£m
£m
£m
£m
£m
Gross
61,775
61,241
534
55,226
50,743
4,483
IFRS offset
(20,211)
(20,211)
(20,211)
(20,211)
Carrying value
41,564
41,030
534
35,015
30,532
4,483
Master netting arrangements
(2,445)
(2,445)
(2,445)
(2,445)
Securities collateral
(38,387)
(38,387)
(28,087)
(28,087)
Potential for offset not recognised under IFRS
(40,832)
(40,832)
(30,532)
(30,532)
Net
732
198
534
4,483
4,483
2021
Gross
78,909
78,259
650
73,858
72,712
1,146
IFRS offset
(32,016)
(32,016)
(32,016)
(32,016)
Carrying value
46,893
46,243
650
41,842
40,696
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
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
241
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
Credit risk – Trading activities continued
Derivatives
(audited)
The table below shows derivatives by type of contract. The master netting agreements and collateral shown do not result in a net
presentation on the balance sheet under IFRS. A significant proportion of the derivatives relate to trading activities in NatWest
Markets. The table also includes hedging derivatives in Treasury.
2022
2021
Notional
GBP
USD
Euro
Other
Total
Assets
Liabilities
Notional
Assets
Liabilities
£bn
£bn
£bn
£bn
£bn
£m
£m
£bn
£m
£m
Gross exposure
118,275
116,158
114,100
109,403
IFRS offset
(18,730)
(22,111)
(7,961)
(8,568)
Carrying value
2,913
4,301
5,527
1,184
13,925
99,545
94,047
12,100
106,139
100,835
Of which:
Interest rate
(1)
2,602
2,895
4,967
278
10,742
53,480
48,535
8,919
67,458
61,206
Exchange rate
309
1,401
552
906
3,168
45,829
45,237
3,167
38,517
39,286
Credit
2
5
8
15
236
275
14
154
343
Equity and commodity
10
Carrying value
13,925
99,545
94,047
12,100
106,139
100,835
Counterparty mark-to-market netting
(77,365)
(77,365)
(85,006)
(85,006)
Cash collateral
(14,079)
(9,761)
(15,035)
(9,909)
Securities collateral
(4,571)
(1,185)
(2,428)
(2,913)
Net exposure
3,530
5,736
3,670
3,007
Banks
(2)
648
711
393
413
Other financial institutions
(3)
1,732
1,969
1,490
1,584
Corporate
(4)
1,068
2,969
1,716
938
Government
(5)
82
87
71
72
Net exposure
3,530
5,736
3,670
3,007
UK
1,271
2,878
1,990
1,122
Europe
1,196
2,015
714
1,028
US
753
626
645
653
RoW
310
217
321
204
Net exposure
3,530
5,736
3,670
3,007
Asset quality of uncollateralised
derivative assets
AQ1-AQ4
3,014
2,939
AQ5-AQ8
500
674
AQ9-AQ10
16
57
Net exposure
3,530
3,670
(1)
The notional amount of interest rate derivatives includes £8,065 billion (2021 – £6,173 billion) in respect of contracts cleared through central clearing counterparties.
(2)
Transactions with certain counterparties with whom NatWest Group has netting arrangements but collateral is not posted on a daily basis; certain transactions with specific terms
that may not fall within netting and collateral arrangements; derivative positions in certain jurisdictions where the collateral agreements are not deemed to be legally enforceable.
(3)
Includes transactions with securitisation 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 supranational entities with no collateral arrangements, collateral arrangements that are not considered enforceable, or one-way collateral agreements in their
favour
.
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
242
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
Credit risk – Trading activities continued
Derivatives: settlement basis and central counterparties
(audited)
The table below shows the third party derivative notional and fair value by trading and settlement method.
Notional
Traded over the counter
Asset
Liability
2022
Traded on
recognised
exchanges £bn
Settled by central
counterparties £bn
Not settled by
central
counterparties £bn
Total
£bn
Traded on
recognised
exchanges £m
Traded over
the counter
£m
Traded on
recognised
exchanges £m
Traded over
the counter
£m
Interest rate
707
8,065
1,970
10,742
113
53,367
33
48,502
Exchange rate
2
3,166
3,168
45,829
45,237
Credit
15
15
236
275
Equity and commodity
Total
709
8,065
5,151
13,925
113
99,432
33
94,014
2021
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
Debt securities
(audited)
The table below shows debt securities held at mandatory fair value through profit or loss by issuer as well as ratings based on the
lowest of Standard & Poor’s, Moody’s and Fitch.
Central and local government
UK
US
Other
Financial
institutions
Corporate
Total
2022
£m
£m
£m
£m
£m
£m
AAA
469
766
3
1,238
AA to AA+
2,345
1,042
1,114
21
4,522
A to AA-
2,205
372
77
29
2,683
BBB- to A-
916
149
296
1,361
Non-investment grade
65
49
114
Unrated
1
3
4
Total
2,205
2,345
2,799
2,172
401
9,922
Short positions
(2,313)
(1,293)
(3,936)
(1,875)
(107)
(9,524)
2021
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)
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
243
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
Credit risk – Cross border exposure
Cross border exposures comprise both banking and trading activities, including reverse repurchase agreements. Exposures
comprise loans and advances, including finance leases and instalment credit receivables, and other monetary assets, such as debt
securities. The geographical breakdown is based on the country of domicile of the borrower or guarantor of ultimate risk. Cross
border exposures include non-local currency claims of overseas offices on local residents but exclude exposures to local residents
in local currencies. The table shows cross border exposures greater than 0.5% of NatWest Group’s total assets.
Government
Banks
Other
Total
Short positions
Net of short
positions
2022
£m
£m
£m
£m
£m
£m
Western Europe
5,608
7,385
19,018
32,011
4,438
27,573
Of which: France
1,875
1,911
3,958
7,744
1,414
6,330
Germany
794
3,717
839
5,350
1,053
4,297
Italy
1,094
116
729
1,939
1,126
813
United States
8,080
3,852
12,931
24,863
1,429
23,434
2021
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
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Capital, liquidity and funding risk
NatWest Group continually ensures a comprehensive approach
is taken to the management of capital, liquidity and funding,
underpinned by frameworks, risk appetite and policies, to
manage and mitigate capital, liquidity and funding risks. The
framework ensures the tools and capability are in place to
facilitate the management and mitigation of risk ensuring
NatWest Group operates within its regulatory requirements and
risk appetite.
Definitions
(audited)
Regulatory capital consists of reserves and instruments issued
that are available, have a degree of permanency and are
capable of absorbing losses. A number of strict conditions set
by regulators must be satisfied to be eligible as capital.
Capital risk is the risk that there is or will be insufficient capital
and other loss-absorbing
debt
instruments to operate
effectively including meeting minimum regulatory requirements,
operating within Board approved risk appetite and supporting
its strategic goals.
Liquidity consists of assets that can be readily converted to
cash within a short timeframe at a reliable value. Liquidity risk
is the risk of being unable to meet financial obligations as and
when they fall due.
Funding consists of on-balance sheet liabilities that are used to
provide cash to finance assets. Funding risk is the risk of not
maintaining a diversified, stable and cost-effective funding
base.
Liquidity and funding risks arise in a number 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; and
Depositor and investor behaviour.
Sources of risk
(audited)
Capital
The eligibility of instruments and financial resources as
regulatory capital is laid down by applicable regulation. Capital
is categorised under two tiers (Tier 1 and Tier 2) according to
the ability to absorb losses, degree of permanency and the
ranking of absorbing losses on either a going or gone concern
basis. There are three broad categories of capital 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 shares issued
and retained earnings.
Additional Tier 1 (AT1) capital -
This is the second type of
loss absorbing capital and must be capable of absorbing
losses on a going concern basis. These instruments are
either written down or converted into CET1 capital when
the CET1 ratio falls below a pre-specified level.
Tier 2 capital -
Tier 2 capital is supplementary capital and
provides loss absorption on a gone concern basis. Tier 2
capital absorbs losses after Tier 1 capital. It typically
consists of subordinated debt securities with a minimum
maturity of five years at the point of issuance.
Minimum requirement for own funds and eligible liabilities
(MREL)
In addition to capital, other specific loss-absorbing instruments,
including senior notes issued by NatWest Group, may be used
to cover certain gone concern capital requirements, which is
referred to as MREL. Gone concern refers to the situation in
which resources must be available to enable an orderly
resolution, in the event that the Bank of England (BoE) deems
that NatWest Group has failed or is likely to fail.
Liquidity
NatWest Group maintains a prudent approach to the definition
of liquidity resources. NatWest Group manages its liquidity to
ensure it is always available when and where required, taking
into account regulatory, legal and other constraints. Following
ring-fencing legislation, liquidity is no longer considered
fungible across NatWest Group. Principal liquidity portfolios are
maintained in the UK Domestic Liquidity Sub-Group (UK
DoLSub) (primarily in NatWest Bank Plc), UBIDAC, NatWest
Markets Plc, RBS International Limited 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 secondary
liquidity as follows:
Primary liquid assets include cash and balances at central
banks, Treasury bills and other high quality government
and supranational securities.
Secondary liquid assets are eligible as collateral for local
central bank liquidity facilities. These assets include own-
issued securitisations or whole loans that are retained on
balance sheet and pre-positioned with a central bank so
that they may be converted into additional sources of
liquidity at very short notice.
Funding
NatWest Group maintains a diversified set of funding sources,
including customer deposits, wholesale deposits and term debt
issuance. NatWest Group also retains access to central bank
funding facilities.
For further details on capital constituents and the regulatory
framework covering capital, liquidity and funding requirements,
please refer to the 2022 NatWest Group Pillar 3 Report.
Risk and capital management
continued
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Capital, liquidity and funding risk continued
Capital management
Capital management ensures that there is sufficient capital and
other loss-absorbing instruments to operate effectively
including meeting minimum regulatory requirements, operating
within Board-approved risk appetite, maintaining its credit
rating and supporting its strategic goals.
Capital management is critical in supporting the businesses and
is enacted through an end-to-end framework across businesses
and legal entities. Capital is managed within the organisation at
the following levels; NatWest Group consolidated, NWH Group
sub consolidated, NatWest Markets Plc, NatWest Markets N.V.
and RBS International Limited. The banking subsidiaries within
NWH Group are governed by the same principles, processes
and management as NatWest Group. Note that although the
aforementioned entities are regulated in line with Basel III
principles, local implementation of the framework differs across
geographies.
Capital planning is integrated into NatWest Group’s wider
annual budgeting process and is assessed and updated at least
monthly. Regular returns are submitted to the PRA which
include a two-year rolling forecast view. Other elements of
capital management, including risk appetite and stress testing,
are set out on pages 181 and 182.
Produce
capital
plans
Capital plans are produced for NatWest Group, its
key operating entities and its businesses over a
five year planning horizon under expected and
stress conditions. Stressed capital plans are
produced to support internal stress testing in the
ICAAP for regulatory purposes.
Shorter term forecasts are developed frequently
in response to actual performance, changes in
internal and external business environment and
to manage risks and opportunities.
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 requirements.
Capital resources and capital requirements are
assessed across a defined planning horizon.
Impact assessment captures input from across
NatWest Group including from businesses.
Inform
capital
actions
Capital planning informs potential capital actions
including buy backs, redemptions, dividends and
new issuance to external investors or via internal
transactions.
Decisions on capital actions will be influenced by
strategic and regulatory requirements, risk
appetite, costs and prevailing market conditions.
As part of capital planning, NatWest Group will
monitor its portfolio of external capital securities
and assess the optimal blend and most cost
effective means of financing.
Capital planning is one of the tools that NatWest Group uses to
monitor and manage capital risk on a going and gone concern
basis, including the risk of excessive leverage.
Liquidity risk management
NatWest Group manages its liquidity risk taking into account
regulatory, legal and other constraints to ensure sufficient
liquidity is available where required to cover liquidity stresses.
The principal levels at which liquidity 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.
NatWest Bank Europe GmbH
The UK DoLSub is PRA regulated and comprises NatWest
Group’s three licensed deposit-taking UK banks: National
Westminster Bank Plc (NWB Plc), The Royal Bank of Scotland
plc (RBS plc) and Coutts & Company. Ulster Bank Limited was
removed from the UK DoLSub effective 1 January 2022 and its
banking license was officially revoked following regulatory
approval on 29 December 2022.
NatWest Group categorises its liquidity portfolio, including its
locally managed liquidity portfolios, into primary and secondary
liquid assets. The size of the liquidity portfolios are determined
by referencing NatWest Group’s liquidity risk appetite. NatWest
Group retains a prudent approach to setting the composition of
the liquidity portfolios, which is subject to internal policies
applicable to all entities and limits over quality 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 determined by taking
current market prices and applying a discount or haircut, to
give a liquidity value that represents 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 monitors the funding risk on
the balance sheet including quantitative and qualitative analysis
of the behavioural aspects of its assets and liabilities as well as
the funding concentration.
Risk and capital management
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Capital, liquidity and funding risk continued
Prudential regulation changes that may
impact capital requirements
NatWest Group faces numerous changes in prudential
regulation that may impact the minimum amount of capital it
must hold and consequently may increase funding costs and
reduce return on equity. Regulatory changes are actively
monitored by NatWest Group, including engagement with
industry associations and regulators and participation in
quantitative impact studies. Monitoring the changing regulatory
landscape forms a fundamental part of capital planning and
management of its business. NatWest Group believes that its
strategy to focus on simpler, lower risk activities within a more
resilient recovery and resolution framework will enable it to
manage the impact of these.
UK and EU implementation of Basel framework
The European Union (EU) implemented the initial phase of the
Basel III capital framework through the CRR and the Capital
Requirements Directive (CRD). On 7 June 2019, amendments to
the CRR and CRD (known as CRR2 and CRD5 respectively)
were published in the Official Journal of the European Union.
The majority of these changes were implemented in June 2021.
Further changes relating to the Basel 3.1 standard will be
implemented in EU by CRR3 and CRD6 for which the European
Commission issued a proposal in October 2021. The
implementation of these changes is not expected until January
2025 however the impact of those will be limited to NatWest
Group’s EU subsidiaries.
From 1 January 2021, NatWest Group has been regulated under
the onshored CRR and associated onshored binding technical
standards which were created by the European Union
(Withdrawal) Act 2018 and amending statutory instruments.
As
the Withdrawal Act applied to the CRR in place as of 31
December 2020, changes to the CRR in the EU are not reflected
in the UK CRR unless separately legislated and amended by
statutory instruments. Going forward, the Financial Services Bill
gives the PRA the power to write prudential rules directly into
the PRA rulebook and they will co-ordinate with HM Treasury to
implement any required changes to the UK CRR.
As detailed above, the changes to the EU CRR included the
substantial CRR2 amendments and equivalent reforms were
eventually implemented in UK on 1 January 2022.
On 30 November 2022, the PRA published its consultation paper
CP16/22 setting out its proposed rules and expectations with
respect to the Basel 3.1 standards that remain to be
implemented in the UK. This will complete the implementation of
post-global financial crisis prudential reforms, which were
designed to i) increase the quantity of capital in the system, per
unit of risk; ii) increase the quality of capital held by firms; and
iii) improve the accuracy of risk-management firms, reducing
the variability of risk-weighted assets (RWAs). The changes
mainly impact capital requirements for STD (Standardised) and
IRB (Internal Ratings Based) Credit Risk, Market Risk, CVA,
Counterparty Credit Risk and Operational Risk. An aggregate
“output floor” is also being introduced to ensure that total RWAs
for firms using advanced or internally modelled methods and
subject to the floor cannot fall below 72.5% of RWAs under the
standardised approach. The proposal did not include further
changes to the Leverage Ratio, Large Exposures and Liquidity
Risk frameworks.
Implementation of the PRA proposals is scheduled to align with
that of the European Union, with a projected compliance date of
1 January 2025. The PRA’s consultation period will end on 31
March 2023. See summary table for further details on PRA’s
proposal.
Other developments
On 29 November 2022, the PRA published PS9/22 which
contained amendments to PRA’s approach to identifying other
systemically important institutions (O-SIIs). The amendments
mainly aimed at removing EBA’s scoring methodology from the
O-SII identification process and changing specific indicators and
weights in PRA’s scoring methodology. In its policy statement,
the PRA clarified that O-SII designation does not automatically
result in higher loss absorbency requirements in the form of an
O-SII buffer or otherwise. An O-SII buffer can only apply to O-
SIIs, or part of an O-SII that are ring-fenced bodies (RFBs).
On the same date, the PRA also published its 2022 list of firms
designated as O-SIIs. NatWest Group is part of PRA’s O-SII list.
Simultaneously, the PRA published a statement confirming a
freeze of firms’ O-SII buffer rates in 2022. O-SII buffers will be
maintained at 2019 levels and the PRA will assess rates in 2023
based on its revised methodology. The decision on O-SII buffer
rates taken in December 2023 will be based on end-2022
financial results and will take effect from January 2025 in line
with PRA’s policy. This PRA statement is therefore relevant to
NatWest Holdings Limited which is currently subject an O-SII
buffer.
Risk and capital management
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Capital, liquidity and funding risk continued
Summary of future changes to prudential regulation in UK that may impact NatWest Group
The table below covers expected future changes to prudential regulation in the UK which may impact NatWest Group at a
consolidated level. Certain entities within the group will be exposed to changes in prudential regulation from other legislative
bodies and/or local supervisory authorities where NatWest Group’s entities are authorised (e.g. EU and Jersey) on a solo basis and
these changes may be different in substance, scope and timing than those highlighted below.
Area of development
Key changes
Source of changes/implementation date
Leverage ratio
framework
Binding leverage ratio at individual bank level for
material entities i.e. LREQ firms.
SS45/15 – UK Leverage ratio framework
Implementation: 1 January 2023
Capital – Output floor
Level of application: Applies at highest level of
application: Consolidated level for UK Groups; sub-
consolidated level for Ring Fenced sub-groups.
Capital stack: Applies to full capital stack including
capital buffers.
Transitional period for the application; starting
with 50% at 1 January 2025 through to 72.5% at 1
January 2030.
PRA Basel 3.1 CP16/22
Expected implementation: 1 January 2025
Credit Risk (STD, IRB,
FIRB)
Significant revisions to standardised credit risk,
including to unrated corporates, SMEs, specialised
lending, mortgages & equity exposures.
Changes to IRB; restrictions on IRB modelling
(switch to standardised on central governments,
switch to FIRB on financial institutions and large
corporates), inclusion of input floors and other
modelling changes.
Removal of SME & Infrastructure supporting
factors (IRB & standardised).
Amendments to credit risk mitigation, including the
withdrawal of some internal modelling approaches,
the removal of double default and a new risk
weight substitution approach on some exposures.
PRA Basel 3.1 CP16/22
Expected implementation: 1 January 2025
Market Risk
Implementation of FRTB - new standardised &
modelled approaches (Expected Shortfall replaces
VaR), revised banking/trading book boundary.
Model approval applications to be provided by 1
January 2024.
This includes permissions for
standardised MR & CVA.
PRA Basel 3.1 CP16/22
Expected implementation: 1 January 2025
CVA & Counterparty
Credit Risk
Removal of modelled approach.
New standardised approach, aligned to Basel
framework, including the removal of CVA
exemptions on sovereigns, non-financial
counterparties and pension funds.
Reduced SA-CCR alpha factor from 1.4 to 1 for
non-financial counterparties and pension funds.
PRA Basel 3.1 CP16/22
Expected implementation: 1 January 2025
Operational Risk
Internal loss multiplier (ILM) set to 1.
Changes to the income requirements in scope of
the business indicator.
PRA Basel 3.1 CP16/22
Expected implementation: 1 January 2025
Pillar 2
PRA commitment to review Pillar 2A
methodologies in 2024, to adjust requirements
ahead of implementation of the Pillar 1.
PRA Basel 3.1 CP16/22
Expected implementation: 1 January 2025
Risk and capital management
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Capital, liquidity and funding risk continued
Key points
CET1 ratio
The CET1 ratio decreased 400 basis points over the period, due to a
£3.6 billion decrease in CET1 and a £19.1 billion increase in RWAs
(movement in RWA explained below).
The CET1 decrease of £3.6 billion is mainly driven by:
the directed buy back of £1.2 billion;
interim and special dividends of £2.1 billion;
foreseeable charge for the on-market buyback programme
of £0.8 billion;
foreseeable final ordinary dividend of £1.0 billion and
adjustment for pension trusts of £0.4 billion;
the removal of the adjustment for prudential amortisation
on software development costs of £0.4 billion;
a £0.3 billion decrease in the IFRS 9 transitional adjustment.
These reductions were offset by the £3.3 billion attributable profit in
the period.
MREL (LAC)
Loss absorbing capital decreased by £6.9 billion to £55.5 billion
primarily due to a £3.6 billion decrease in CET1 (explained above), a
£0.6 billion decrease in AT1 capital, a £0.7 billion decrease in Tier 2
capital and a £2.1 billion decrease in MREL eligible instruments. There
has been a £0.5 billion decrease in ineligible subordinated debt
instruments primarily driven by redemptions in the period, and a £1.6
billion decrease in senior unsecured debt driven by new issuances
offset by redemptions, instruments now classified as ineligible and FX
movements.
RWA
Total RWAs increased by £19.1 billion to £176.1 billion mainly
reflecting:
An increase in credit risk RWAs of £21.8 billion, primarily
due to model adjustments applied as a result of new
regulation applicable to IRB models from 1 January 2022, in
addition to drawdowns and new facilities within
Commercial & Institutional. This was partially offset by a
reduction in the Ulster RoI portfolio and improved risk
metrics within Commercial & Institutional and Retail
Banking.
A reduction in operational risk RWAs of £1.9 billion following
the annual recalculation.
A reduction in counterparty credit risk RWAs of £1.2 billion,
mainly driven by external factors faced in the final quarter
of the period including excess margin received and
increases in the Mark-to-Market uncollateralised
counterparties. This was partially offset by the
implementation of SA-CCR, affecting the RWA calculation
for the non-internally modelled exposure.
UK leverage
The leverage ratio at 31 December 2022 is 5.4% and has been
calculated in accordance with changes to the UK’s leverage ratio
framework. As at 31 December 2021, the UK leverage ratio was 5.9%,
which was calculated under the prior year’s UK leverage
methodology. The key driver of the decrease is a £4.2 billion decrease
in Tier 1 capital.
Liquidity portfolio
The liquidity portfolio decreased by £60.9 billion to £225.5 billion, with
primary liquidity decreasing by £47.0 billion to £161.6 billion. The
decrease in primary liquidity is driven by increase in lending,
decrease in deposits, shareholder distributions (share buyback and
dividends), redemption of senior debt and maturing commercial paper
and certificates of deposit. The reduction in secondary liquidity is due
to a reduction in the pre-positioned collateral at the Bank of England.
18.2%
14.2%
2021
2022
£62.4bn
£55.5bn
2021
2022
£157.0bn
£176.1bn
2021
2022
5.9%
5.4%
2021
2022
£286.4bn
£225.5bn
2021
2022
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Key points continued
Liquidity coverage ratio
The Liquidity Coverage Ratio (LCR) decreased to 145% during the
year driven by a decrease in the liquidity portfolio and a lower than
proportionate reduction in net outflows. The decrease in liquidity
portfolio was primarily driven by growth in customer lending and
reduced customer deposits in NatWest Holdings along with
shareholder distributions during the year.
NSFR
The net stable funding ratio (NSFR) was 145% compared to 157% in
prior year.
The decrease is due to lower deposits and shareholder
distributions combined with higher lending.
172%
145%
2021
2022
157%
145%
2021
2022
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Capital, liquidity and funding risk continued
Minimum requirements
Maximum Distributable Amount (MDA) and Minimum Capital Requirements
NatWest Group is subject to minimum capital requirements relative to RWAs. The table below summarises the minimum capital
requirements (the sum of Pillar 1 and Pillar 2A), and the additional capital buffers which are held in excess of the regulatory
minimum requirements and are usable in stress.
Where the CET1 ratio falls below the sum of the minimum capital and the combined buffer requirement, there is a subsequent
automatic restriction on the amount available to service discretionary payments (including AT1 coupons), known as the MDA. Note
that different capital requirements apply to individual legal entities or sub-groups and the table shown does not reflect any
incremental PRA buffer requirements, which are not disclosable.
The current capital position provides significant headroom above both our minimum requirements and our MDA threshold
requirements.
Type
CET1
Total Tier 1
Total capital
Pillar 1 requirements
4.5%
6.0%
8.0%
Pillar 2A requirements
1.7%
2.3%
3.0%
Minimum Capital Requirements
6.2%
8.3%
11.0%
Capital conservation buffer
2.5%
2.5%
2.5%
Countercyclical capital buffer
(1)
0.8%
0.8%
0.8%
MDA threshold
(2)
9.5%
n/a
n/a
Overall capital requirement
9.5%
11.6%
14.3%
Capital ratios at 31 December 2022
14.2%
16.4%
19.3%
Headroom
(3)
4.7%
4.8%
5.0%
(1)
The Financial Policy Committee increased UK CCyB rate from 0% to 1% effective from 13 December 2022.
A further increase from 1% to 2% is anticipated from 5 July 2023
(2)
In June 2022, the Central Bank of Ireland announced that the CCyB on Irish exposures will increase from 0% to 0.5%, applicable from 15 June 2023.
This is the first step towards a
gradual increase which, conditional on macro-financial developments, would see a CCyB of 1.5% announced by mid-2023, which is expected to be applicable from June 2024.
(3)
Pillar 2A requirements for NatWest Group are set as a variable amount with the exception of some fixed add-ons.
(4)
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 under the binding PRA UK leverage framework
applicable for NatWest Group.
Type
CET1
Total Tier 1
Minimum ratio
2.44%
3.25%
Countercyclical leverage ratio buffer
(1)
0.3%
0.3%
Total
2.74%
3.55%
(1)
The countercyclical leverage ratio buffer is set at 35% of NatWest Group’s CCyB. As noted above the UK CCyB is anticipated to increase from 1% to 2% from 5 July 2023. Foreign
exposures may be subject to different CCyB rates depending on the rate set in those jurisdictions.
(2)
Certain NatWest Group legal entities that are not currently in scope of the minimum leverage ratio capital requirements are expected to manage their leverage ratio at the same level
as firms in scope 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 metrics under the PRA framework. The
binding requirement for NSFR became effective as of 1 January 2022.
Type
Liquidity coverage ratio (LCR)
100%
Net stable funding ratio (NSFR)
100%
Risk and capital management
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Capital, liquidity and funding risk continued
Measurement
Capital, risk-weighted assets and leverage: Key metrics
The table below sets out the key capital and leverage ratios. NatWest Group is subject to the requirements set out in the PRA
Rulebook. The capital and leverage ratios are therefore being presented under these frameworks on a transitional basis.
2022
2021
Capital adequacy ratios
(1)
%
%
CET1
14.2
18.2
Tier 1
16.4
21.0
Total
19.3
24.7
RWAs
£m
£m
Credit risk
141,963
120,116
Counterparty credit risk
6,723
7,907
Market risk
8,300
7,917
Operational risk
19,115
21,031
Total RWAs
176,101
156,971
Capital
£m
£m
CET1
24,992
28,596
Tier1
28,867
33,042
Total
33,920
38,748
Leverage ratios
£m
£m
Tier 1 capital
28,867
33,042
UK average Tier 1 capital
(2)
29,564
33,804
UK average leverage exposure
(2)
531,429
568,802
UK average leverage ratio (%)
(2)
5.6%
5.9%
UK leverage ratio (%)
(3)
5.4%
5.9%
(1)
Based on the current PRA rules, therefore includes the transitional relief on grandfathered capital instruments and the transitional arrangements for the capital impact of IFRS 9
expected credit loss (ECL) accounting. The impact of the IFRS 9 transitional adjustments at 31 December 2022 was £0.4 billion for CET1 capital, £36 million for total capital and £71
million RWAs (31 December 2021 – £0.6 billion CET1 capital, £0.5 billion total capital and £36 million RWAs). Excluding these adjustments, the CET1 ratio would be 14.0% (31
December 2021 – 17.8%). The transitional relief on grandfathered instruments at 31 December 2022 was £75 million (31 December 2021 - £0.9 billion). Excluding both the
transitional relief on grandfathered capital instruments and the transitional arrangements for the capital impact of IFRS 9 expected credit loss (ECL) accounting, the end-point Tier 1
capital ratio would be 16.2% (31 December 2021 – 20.3%) and the end-point Total capital ratio would be 19.2% (31 December 2021 – 23.8%).
(2)
Based on the daily average of on-balance sheet items and three month-end average of off-balance sheet items.
(3)
The UK leverage exposure and transitional Tier 1 capital are calculated in accordance with current PRA rules. Excluding the IFRS 9 transitional adjustment, the UK leverage ratio
would be 5.3% (31 December 2021 – 5.8%).
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Capital, liquidity and funding risk continued
Capital flow statement
The table below analyses the movement in CET1, AT1 and Tier 2 capital for the year ended 31 December 2022. It is being
presented on a transitional basis based on current PRA rules.
CET1
AT1
Tier 2
Total
£m
£m
£m
£m
At 31 December 2021
28,596
4,446
5,706
38,748
Attributable profit for the period
3,340
3,340
Ordinary interim dividend paid
(364)
(364)
Special dividend paid
(1,746)
(1,746)
Directed buyback
(1,212)
(1,212)
Foreseeable ordinary dividends
(967)
(967)
Adjustment for trust assets
(1)
(365)
(365)
Foreseeable charges - on-market share buyback
(800)
(800)
Foreign exchange reserve
273
273
FVOCI reserve
(371)
(371)
Own credit
(79)
(79)
Share capital and reserve movements in respect of employee share schemes
113
113
Goodwill and intangibles deduction
(804)
(804)
Deferred tax assets
(151)
(151)
Prudential valuation adjustments
(1)
(1)
End of 2021 transitional relief on grandfathered instruments
(571)
(232)
(803)
Net dated subordinated debt instruments
(522)
(522)
Foreign exchange movements
(254)
540
286
Adjustment under IFRS 9 transitional arrangements
(260)
(260)
Other movements
44
(439)
(395)
At 31 December 2022
24,992
3,875
5,053
33,920
(1)
Prudent deduction in respect of agreement with the pension fund to establish new legal structure. See Notes 5 and 33.
The CET1 decrease of c.£3.6 billion is mainly driven by the
directed buyback of £1.2 billion, interim and special
dividends paid £2.1 billion, foreseeable charge for
additional on-market ordinary share buyback programme
of £0.8 billion, foreseeable final ordinary dividend of £1.0
billion and adjustment for pension trusts of £0.4 billion, the
removal of the adjustment for prudential amortisation on
software development costs of £0.4 billion and a £0.3
billion decrease in the IFRS 9 transitional adjustment.
These reductions were offset by the £3.3 billion attributable
profit in the period.
The AT1 and Tier 2 movements are due to the end of the
2021 transitional relief on grandfathered instruments,
impact of liability management exercise in August offset by
a £0.7 billion issuance of subordinated Tier 2 notes in
November 2022 and FX movements.
In Tier 2 there was also a £0.4 billion decrease in the Tier 2
surplus provisions.
Risk and capital management
continued
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Capital, liquidity and funding risk continued
Risk-weighted assets
The table below analyses the movement in RWAs during the year, by key drivers.
Credit risk
Counterparty
credit risk
Market risk
Operational risk
Total
£bn
£bn
£bn
£bn
£bn
At 31 December 2021
120.2
7.9
7.9
21.0
157.0
Foreign exchange movement
1.5
1.5
Business movements
6.3
(1.5)
0.2
(1.9)
3.1
Risk parameter changes
(4.0)
(4.0)
Methodology changes
0.1
0.4
0.5
Model updates
21.3
(0.1)
0.2
21.4
Acquisitions and disposals
(3.4)
(3.4)
At 31 December 2022
142.0
6.7
8.3
19.1
176.1
The table below analyses the movement in RWAs by segment during the year.
Retail Banking
Private Banking
Commercial &
Institutional
Central items &
other (1)
Total NatWest
Group
Total RWAs
£bn
£bn
£bn
£bn
£bn
At 31 December 2021
36.7
11.3
98.1
10.9
157.0
Foreign exchange movement
1.3
0.2
1.5
Business movements
2.9
(0.1)
2.0
(1.7)
3.1
Risk parameter changes
(1.2)
(2.8)
(4.0)
Methodology changes
0.5
0.5
Model updates
16.3
4.1
1.0
21.4
Acquisitions and disposals
(3.4)
(3.4)
At 31 December 2022
54.7
11.2
103.2
7.0
176.1
Credit risk
47.7
10.0
78.3
6.0
142.0
Counterparty credit risk
0.1
6.6
6.7
Market risk
0.2
8.1
8.3
Operational risk
6.7
1.2
10.2
1.0
19.1
Total RWAs
54.7
11.2
103.2
7.0
176.1
(1)
£5.4 billion of Central items & other relates to Ulster RoI.
Total RWAs increased by £19.1 billion during the period mainly reflecting;
An increase in model updates totalling £21.4 billion,
primarily due to model adjustments applied as a result of
new regulation applicable to IRB models from 1 January
2022 within Retail Banking and Commercial &
Institutional.
An increase in business movements totalling £3.1 billion,
driven by increased credit risk exposures within Retail
Banking and Commercial & Institutional. This was
partially offset by a reduction in credit risk exposures
within Ulster Bank RoI.
A reduction in risk parameters totalling £4.0 billion,
reflecting improved risk metrics within Commercial &
Institutional and Retail Banking.
An increase in disposals leading to a £3.4 billion
reduction in RWAs relating to the phased withdrawal
from the Republic of Ireland.
Risk and capital management
continued
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Annual Report and Accounts 2022
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Capital, liquidity and funding risk continued
Leverage exposure
31 December
31 December
2022
2021
£m
£m
Cash and balances at central banks
144,832
177,757
Trading assets
45,577
59,158
Derivatives
99,545
106,139
Financial assets
404,374
412,817
Other assets
18,864
17,106
Assets of disposal groups
6,861
9,015
Total assets
720,053
781,992
Derivatives
- netting and variation margin
(100,356)
(110,204)
- potential future exposures
18,327
35,035
Securities financing transactions gross up
4,147
1,397
Other off balance sheet items
46,144
44,240
Regulatory deductions and other adjustments
(7,114)
(8,980)
Claims on central banks
(141,144)
(174,148)
Exclusion of bounce back loans
(5,444)
(7,474)
UK leverage exposure
534,613
561,858
UK leverage ratio (%)
(1)
5.4
5.9
(1)
The UK leverage exposure and transitional Tier 1 capital are calculated in accordance with the PRA Rulebook. Excluding the IFRS 9 transitional adjustment, the UK leverage ratio
would be 5.3% (31 December 2021 – 5.8%).
Liquidity key metrics
The table below sets out the key liquidity and related metrics monitored by NatWest Group.
2022
2021
NatWest Group
UK DoLSub
NatWest Group
UK DoLSub
Liquidity coverage ratio
145%
131%
172%
169%
Stressed outflow coverage
(1)
150%
131%
194%
195%
Net stable funding ratio
145%
137%
157%
151%
(1)
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 three 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.
Weighted undrawn commitments
The table below provides a breakdown of weighted undrawn commitments.
2022
2021
£bn
£bn
Unconditionally cancellable credit cards
1.9
1.8
Other unconditionally cancellable items
3.6
3.1
Unconditionally cancellable items
(1)
5.5
4.9
Undrawn commitments <1 year which may not be cancelled
1.7
1.7
Other off-balance sheet items with 20% credit conversion factor (CCF)
0.3
0.3
Items with a 20% CCF
2.0
2.0
Revolving credit risk facilities
28.4
27.5
Term loans
4.4
3.3
Mortgages
Other undrawn commitments >1 year which may not be cancelled & off-balance sheet
1.0
1.1
Items with a 50% CCF
33.8
31.9
Items with a 100% CCF
4.9
5.3
Total
46.2
44.1
(1)
Based on a 10% CCF.
Risk and capital management
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Capital, liquidity and funding risk continued
Loss-absorbing capital
The following table illustrates the components of estimated loss-absorbing capital (LAC) in NatWest Group plc and operating
subsidiaries and includes external issuances only. The table is prepared on a transitional basis, including the benefit of regulatory
capital instruments issued from operating companies, to the extent they meet MREL criteria.
The roll-off profile relating to senior debt and subordinated debt instruments is set out on page 257.
2022
2021
Par value (1)
Balance
sheet value
Regulatory
value (2.5)
LAC value (3)
Par value
Balance
sheet value
Regulatory
value
LAC value
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
CET1 capital
(4)
25.0
25.0
25.0
25.0
28.6
28.6
28.6
28.6
Tier 1 capital: end-point CRR compliant AT1
of which: NatWest Group plc (holdco)
3.9
3.9
3.9
3.9
3.9
3.9
3.9
3.9
of which: NatWest Group plc operating
subsidiaries (opcos)
3.9
3.9
3.9
3.9
3.9
3.9
3.9
3.9
Tier 1 capital: end-point CRR non compliant
(6)
of which: holdco
0.6
0.6
0.5
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
Tier 2 capital: end-point CRR compliant
of which: holdco
6.0
5.5
4.9
5.4
7.1
7.1
4.9
6.0
of which: opcos
0.1
0.1
0.3
0.3
6.1
5.6
4.9
5.4
7.4
7.4
4.9
6.0
Tier 2 capital: end-point CRR non compliant
(6)
of which: holdco
of which: opcos
0.3
0.5
0.1
0.6
0.9
0.3
0.1
0.3
0.5
0.1
0.6
0.9
0.3
0.1
Senior unsecured debt securities
of which: holdco
23.4
22.3
21.2
22.8
23.4
22.8
of which: opcos
26.1
22.9
22.7
22.6
49.5
45.2
21.2
45.5
46.0
22.8
Tier 2 capital
Other regulatory adjustments
0.5
0.5
0.5
0.5
Total
84.9
80.3
33.9
55.5
86.7
87.5
38.7
62.4
RWAs
176.1
157.0
UK leverage exposure
534.6
561.9
LAC as a ratio of RWAs
31.5%
39.8%
LAC as a ratio of UK leverage exposure
10.4%
11.1%
(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
December 2021 (updating 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 year remaining to maturity, structured debt, operating company senior debt, and other
instruments that do not meet the MREL criteria. The LAC calculation includes Tier 1 and Tier 2 securities before the application of any regulatory caps or adjustments.
(4)
Corresponding shareholders’ equity was £36.5 billion (2021 - £41.8 billion).
(5)
Regulatory amounts reported for AT1, Tier 1 and Tier 2 includes grandfathered instruments as per the transitional provisions allowed under CRR2 (until 28 June 2025).
(6)
(i) CRR1 non-compliant instruments (2021) - all Tier 1 and Tier 2 instruments that were grandfathered under CRR1 compliance have lost their regulatory value and no longer form
part of our regulatory capital resources from 1 January 2022. As at 31 December 2021, these are reported under the "Tier 1 capital: end-point CRR non-compliant" and "Tier 2
capital: end-point CRR non-compliant" categories.
(ii) CRR2 non-compliant instruments (2022) - From January 2022, all Tier 1 and Tier 2 instruments that were grandfathered under CRR2 compliance (until 28 June 2025) are
reported under "Tier 1 capital: end-point CRR non-compliant" and "Tier 2 capital: end-point CRR non-compliant" category.
Risk and capital management
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Capital, liquidity and funding risk continued
Loss-absorbing capital
The following table illustrates the components of the stock of outstanding issuance in NatWest Group plc and its operating
subsidiaries including external and internal issuances
.
NatWest
Group plc
NatWest
Holdings
Limited
NWB Plc
RBS plc
UBIDAC
NWM Plc
NatWest
Markets
N.V.
NWM
Securities Inc.
RBS
International
Limited
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
Tier 1 (inclusive of AT1)
Externally issued
3.9
0.1
Tier 1 (inclusive of AT1)
Internally issued
3.7
2.5
1.0
0.9
0.2
0.3
3.9
3.7
2.6
1.0
0.9
0.2
0.3
Tier 2
Externally issued
5.5
0.1
0.1
0.1
0.3
Tier 2
Internally issued
4.6
2.9
1.5
1.5
0.1
0.3
5.5
4.6
3.0
1.5
0.1
1.6
0.4
0.3
Senior unsecured
Externally issued
22.3
Senior unsecured
Internally issued
10.4
6.4
0.4
0.5
3.2
0.3
22.3
10.4
6.4
0.4
0.5
3.2
0.3
Total outstanding issuance
31.7
18.7
12.0
2.9
0.6
5.7
0.6
0.3
0.6
(1)
The balances are the IFRS balance sheet carrying amounts, which may differ from the amount which the instrument contributes to regulatory capital. Regulatory balances exclude,
for example, issuance costs and fair value movements, while 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 UBIDAC represents 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 management
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Capital, liquidity and funding risk continued
Roll-off profile
The following table illustrates the roll-off profile and weighted average spreads of NatWest Group’s major wholesale funding
programmes.
Roll-off profile
Senior debt roll-off profile
(1)
As at and for year
ended 31
December
H1 2023
H2 2023
2024
2025
2026 & 2027
2028 & later
NatWest Group plc
- amount (£m)
22,266
1,350
874
2,142
2,904
6,049
8,947
- weighted average rate spread (bps)
190
309
266
164
176
195
174
NWM Plc
- amount (£m)
18,283
3,380
887
3,664
5,213
4,380
759
- weighted average rate spread (bps)
60
62
42
67
64
36
111
NatWest Bank Plc
- amount (£m)
1,664
1,641
23
- weighted average rate spread (bps)
17
17
(6)
NWM N.V.
- amount (£m)
1,884
682
556
532
66
48
- weighted average rate spread (bps)
(104)
(175)
(141)
3
(49)
95
NWM S.I.
- amount (£m)
216
83
74
59
- weighted average rate spread (bps)
131
98
138
168
RBSI
- amount (£m)
839
645
194
- weighted average rate spread (bps)
44
40
58
Securitisation
- amount (£m)
859
296
375
188
- weighted average rate spread (bps)
3
8
Covered bonds
- amount (£m)
2,842
751
2,091
- weighted average rate spread (bps)
127
44
157
Total notes issued - amount (£m)
48,853
8,449
2,534
8,512
8,479
10,878
10,001
Weighted average rate spread (bps)
113
70
78
105
96
122
164
Subordinated debt instruments roll-off profile
(2)
NatWest Group plc (£m)
5,521
126
537
1,298
918
875
1,767
NWM Plc (£m)
142
122
18
2
NatWest Bank Plc (£m)
72
72
NWM N.V. (£m)
323
83
240
UBIDAC (£m)
76
76
Total (£m)
6,134
403
537
1,298
918
893
2,085
(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 table above does not include debt
accounted Tier 1 instruments although those instruments form part of the total subordinated debt balance.
(3)
The weighted average spread reflects the average net funding cost to NatWest Group and is calculated on an indicative basis and are quoted over term SONIA.
(4)
The roll-off table is based on sterling-equivalent balance sheet values.
Risk and capital management
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Capital, liquidity and funding risk continued
Liquidity portfolio
(audited)
The table below shows the liquidity portfolio by product, with primary liquidity aligned to internal stressed outflow coverage and
regulatory LCR categorisation. Secondary liquidity comprises assets eligible for discount at central banks, which do not form part
of the liquid asset portfolio for LCR or stressed outflow purposes.
Liquidity value
2022
2021
NatWest
Group (1)
NWH
Group (2)
UK DoL
Sub
NatWest
Group
NWH
Group
UK DoL
Sub
£m
£m
£m
£m
£m
£m
Cash and balances at central banks
(3)
140,820
106,869
103,708
174,328
140,562
136,154
AAA to AA- rated governments
18,589
9,843
9,843
31,073
21,710
21,123
A+ and lower rated governments
317
25
Government guaranteed issuers, public sector entities and
government sponsored entities
134
120
100
307
295
174
International organisations and multilateral
development banks
1,734
1,112
1,021
2,720
1,807
1,466
LCR level 1 bonds
20,774
11,075
10,964
34,125
23,812
22,763
LCR level 1 assets
161,594
117,944
114,672
208,453
164,374
158,917
LCR level 2 assets
117
Non-LCR eligible assets
Primary liquidity
161,594
117,944
114,672
208,570
164,374
158,917
Secondary liquidity
(3)
63,917
63,849
63,849
77,849
77,660
76,573
Total liquidity value
225,511
181,793
178,521
286,419
242,034
235,490
(1)
NatWest Group includes the UK Domestic Liquidity Sub-Group (UK DoLSub), NatWest Markets Plc and other significant operating subsidiaries that hold liquidity portfolios. These
include The Royal Bank of Scotland International Limited, NWM N.V., Ulster Bank Ireland DAC and NatWest Bank Europe GmbH who hold managed portfolios that comply with local
regulations that may differ from PRA rules.
(2)
NWH Group comprises UK DoLSub, Ulster Bank Ireland DAC and NatWest Bank Europe GmbH who hold managed portfolios that comply with local regulations that may differ from
PRA rules.
(3)
Comprises assets eligible for discounting at the Bank of England and other central banks.
(4)
NatWest Markets Plc liquidity portfolio is reported in the NatWest Markets Plc Annual Report and Accounts.
Risk and capital management
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Capital, liquidity and funding risk continued
Funding sources
(audited)
The table below shows the carrying values of the principal funding sources based on contractual maturity. Balance sheet captions
include balances held at all classifications under IFRS 9.
2022
2021
Short-term less
than 1 year
Long-term more
than 1 year
Total
Short-term less
than 1 year
Long-term more
than 1 year
Total
£m
£m
£m
£m
£m
£m
Bank Deposits
Repos
1,446
1,446
7,912
7,912
Other bank deposits
(1)
6,353
12,642
18,995
5,803
12,564
18,367
7,799
12,642
20,441
13,715
12,564
26,279
Customer Deposits
Repos
9,575
254
9,829
14,541
14,541
Non-bank financial institutions
50,226
9
50,235
57,885
67
57,952
Personal
224,706
1,209
225,915
230,525
829
231,354
Corporate
164,314
25
164,339
175,850
113
175,963
448,821
1,497
450,318
478,801
1,009
479,810
Trading liabilities
(2)
Repos
(3)
23,740
23,740
19,389
19,389
Derivatives collateral
17,680
17,680
17,718
17,718
Other bank and customer deposits
413
654
1,067
849
704
1,553
Debt securities in issue - Medium term notes
54
743
797
178
796
974
41,887
1,397
43,284
38,134
1,500
39,634
Other financial liabilities
Customer deposits
253
797
1,050
568
568
Debt securities in issue:
Commercial paper and certificates of
deposit
5,587
85
5,672
9,038
115
9,153
Medium term notes
6,934
31,750
38,684
6,401
29,451
35,852
Covered bonds
804
2,038
2,842
53
2,833
2,886
Securitisation
(5)
859
859
867
867
13,578
35,529
49,107
16,060
33,266
49,326
Subordinated liabilities
974
5,286
6,260
1,375
7,054
8,429
Total funding
513,059
56,351
569,410
548,085
55,393
603,478
Of which: available in resolution
(4)
24,899
29,624
(1)
Includes £12.0 billion (2021 – £12.0 billion) relating to Term Funding Scheme with additional incentives for Small and Medium-sized Enterprises participation.
(2)
Excludes short positions of £9.5 billion (2021 – £25.0 billion).
(3)
Comprises central & other bank repos of £1.6 billion (2021 – £0.8 billion), other financial institution repos of £19.4 billion (2021 – £17.0 billion) and other corporate repos of £2.7
billion (2021 – £1.6 billion).
(4)
Eligible liabilities (as defined 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 by the Bank of England in December 2021 (updating June 2018). The balance consists of £20.0 billion
(2021 – £23.4 billion) under debt securities in issue (senior MREL) and £4.9 billion (2021 – £6.2 billion) under subordinated liabilities.
(5)
NatWest Group transfers credit risk on originated loans and mortgages without the transfer of assets to a structured entity, whereby it enters credit derivative and financial
guarantee contracts with consolidated structured entities and they in turn issue debt securities to investors. This funding is legally ringfenced in the structured entity and is restricted
to specifically cover investor credit protection claim payments in respect of the associated loans and mortgages.
Risk and capital management
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260
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Capital, liquidity and funding risk continued
Contractual maturity
(audited)
This table shows the residual maturity of financial instruments, based on contractual date of maturity of NatWest Group’s banking
activities, including hedging derivatives. Trading activities, comprising mandatory fair value through profit or loss (MFVTPL) assets
and held-for-trading (HFT) liabilities have been excluded from the maturity analysis and are shown in total in the table below.
Banking activities
Less than 1
motnhs
1-3 months
3-6 months
6 months - 1
year
Subtotal
1-3 years
3-5 years
More than 5
years
Total
Trading
activites
Total
2022
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Cash and balances
at central banks
144,832
144,832
144,832
144,832
Trading assets
45,577
45,577
Derivatives
5
10
15
69
55
4
143
99,402
99,545
Settlement balances
2,572
2,572
2,572
2,572
Loans to banks -
amortised cost
5,020
3
1,646
6,669
17
250
203
7,139
7,139
Loans to customers -
amortised cost
(1)
34,417
17,111
13,655
22,366
87,549
60,959
42,484
178,671
369,663
369,663
Personal
4,533
2,348
3,247
6,397
16,525
23,596
21,809
154,938
216,868
216,868
Corporate
20,366
4,997
4,422
9,108
38,893
29,570
18,231
22,342
109,036
109,036
Non-bank financial
institutions
9,518
9,766
5,986
6,861
32,131
7,793
2,444
1,391
43,759
43,759
Other financial assets
736
1,140
1,150
2,857
5,883
7,634
7,661
8,930
30,108
787
30,895
Total financial assets
187,577
18,259
16,461
25,223
247,520
68,679
50,450
187,808
554,457
145,766
700,223
2021
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
2022
Bank deposits
excluding repos
5,050
177
522
604
6,353
4,442
8,200
18,995
18,995
Bank repos
961
485
1,446
1,446
1,446
Customer repos
9,559
6
10
9,575
254
9,829
9,829
Customer deposits
excluding repos
414,135
13,749
6,868
4,494
439,246
1,223
20
440,489
440,489
Personal
216,530
3,019
2,984
2,173
224,706
1,209
225,915
225,915
Corporate
151,945
7,184
3,221
1,964
164,314
5
20
164,339
164,339
Non-bank financial
institutions
45,660
3,546
663
357
50,226
9
50,235
50,235
Settlement balances
2,012
2,012
2,012
2,012
Trading liabilities
52,808
52,808
Derivatives
10
10
17
31
68
63
1
132
93,915
94,047
Other financial liabilities
1,220
4,789
4,941
2,628
13,578
17,789
10,944
6,796
49,107
49,107
CPs and CDs
1,134
2,246
858
1,349
5,587
73
12
5,672
5,672
Medium term notes
36
1,623
4,079
1,196
6,934
15,161
9,989
6,600
38,684
38,684
Covered bonds
50
750
4
804
2,038
2,842
2,842
Securitisations
296
375
188
859
859
Customer deposits DFV
170
83
253
221
568
8
1,050
1,050
Subordinated liabilities
73
14
228
659
974
2,194
1,458
1,634
6,260
6,260
Notes in circulation
3,218
3,218
3,218
3,218
Lease liabilities
13
23
34
67
137
229
180
572
1,118
1,118
Total financial liabilities
436,251
19,253
12,620
8,483
476,607
26,194
20,782
9,023
532,606
146,723
679,329
2021
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
(1)
Loans to customers excludes £3.3 billion (2021 – £3.7 billion) of impairment provisions.
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
261
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Capital, liquidity and funding risk continued
Senior notes and subordinated liabilities - residual maturity profile by instrument type
(audited)
The table below shows NatWest Group’s debt securities in issue and subordinated liabilities by residual maturity.
Trading
liabilities
Other financial liabilities
Debt securities in issue
Debt securities
in issue MTNs
Commercial
paper and CDs
MTNs
Covered
bonds
Securitisation
Subordinated
liabilities
Total
Total notes in
issue
2022
£m
£m
£m
£m
£m
£m
£m
£m
Less than 1 year
54
5,587
6,934
804
974
14,299
14,353
1-3 years
475
73
15,161
2,038
296
2,195
19,763
20,238
3-5 years
35
12
9,989
375
1,458
11,834
11,869
More than 5 years
233
6,600
188
1,633
8,421
8,654
Total
797
5,672
38,684
2,842
859
6,260
54,317
55,114
2021
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
The table below shows the currency breakdown.
GBP
USD
EUR
Other
Total
2022
£m
£m
£m
£m
£m
Commercial paper and CDs
1,838
1,031
2,803
5,672
MTNs
3,746
18,750
14,217
2,768
39,481
Covered bonds
1,775
1,067
2,842
Securitisation
859
859
Subordinated liabilities
2,679
2,618
963
6,260
Total
10,897
22,399
19,050
2,768
55,114
2021
10,084
26,600
19,872
1,605
58,161
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
262
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Capital, liquidity and funding risk continued
Funding gap: maturity and segment analysis
The contractual maturity of balance sheet assets and liabilities reflects the maturity transformation role banks perform, lending
long-term but mainly obtaining funding through short-term liabilities such as customer deposits. In practice, the behavioural profiles
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, despite being repayable on demand or at short notice, have demonstrated very stable
characteristics even in periods of acute stress.
In its analysis to assess and manage asset and liability maturity gaps, NatWest Group determines the expected customer behaviour
through qualitative and quantitative techniques. These incorporate observed customer behaviours over long periods of time. This
analysis is subject to governance through NatWest Group ALCo Technical committee down to a segment level. The net behavioural
funding surplus/(gap) and contractual maturity analysis is set out below.
Contractual maturity
Behavioural maturity
Loans to customers
Customer accounts
Net surplus/(gap)
Net surplus/(gap)
Less
than
1 year
1-5
years
Greater
than 5
years
Total
Less
than 1
year
1-5
years
Greater
than 5
years
Total
Less
than 1
year
1-5 years
Greater
than 5
years
Total
Less
than 1
year
1-5
years
Greater
than 5
years
Total
2022
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
Retail Banking
12
41
144
197
187
1
188
175
(40)
(144)
(9)
(7)
1
(3)
(9)
Private Banking
3
6
10
19
41
41
38
(6)
(10)
22
6
5
11
22
Commercial
& Institutional
57
56
26
139
214
1
215
157
(55)
(26)
76
6
68
2
76
Central items & other
1
1
8
8
7
7
7
7
Total
73
103
180
356
450
2
452
377
(101)
(180)
96
12
74
10
96
2021
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
Total
87
90
166
343
475
2
477
388
(88)
(166)
134
11
109
14
134
(1)
Loans to customers and customer accounts include trading assets and trading liabilities respectively and excludes reverse repos and repos.
The net customer funding surplus has decreased by £38
billion during 2022 to £96 billion driven by a £25 billion
decline in deposits and a £13 billion increase in loans to
customers.
Customer deposits and loans to customers are broadly
matched from a behavioural perspective.
The net funding surplus in 2022 is mainly concentrated in
the longer dated buckets, reflecting stable characteristics of
customer deposits.
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
263
Financial statements
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Governance
Risk and capital management
Additional information
Financial review
Capital, liquidity and funding risk continued
Encumbrance
(audited)
NatWest Group evaluates the extent to which assets can be
financed in a secured form (encumbrance), but certain asset
types lend themselves more readily to encumbrance. The typical
characteristics that support encumbrance are an ability to
pledge those assets to another counterparty or entity through
operation of law without necessarily requiring prior notification,
homogeneity, predictable and measurable cash flows, and a
consistent and uniform underwriting and collection process.
Retail assets including residential mortgages, credit card
receivables and personal loans display many of these features.
NatWest Group categorises its assets into four broad groups,
those that are:
Already encumbered and used to support funding currently
in place through own-asset securitisations, covered bonds
and securities repurchase agreements.
Pre-positioned with central banks as part of funding
schemes and those encumbered under such schemes.
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 segregated liquidity
buffers covering at least 50% of their annual fixed
overheads.
Not currently encumbered. In this category, NatWest Group
has in place an enablement programme which seeks to
identify assets capable of being encumbered and to identify
the actions to facilitate such encumbrance whilst not
affecting customer relationships or servicing.
Programmes to manage the use of assets to actively support
funding are established within UK DoLSub, UBIDAC and
NatWest Markets Plc.
Balance sheet encumbrance
The table shows the retained encumbrance assets of NatWest Group.
Encumbered as a result of
transactions with counterparties other
than central banks
Unencumbered assets not pre-positioned
with central banks
Total
Covered
debts &
securitisations
(1)
SFT,
derivatives and
similar (2,3)
(4)
Pre-positioned &
encumbered assets
held at central
banks (5)
Collateral ring-
fenced to meet
regulatory
requirement
(6)
Readily
available
(7)
Other
available
(8)
Cannot be
used (9)
Total
Total
(10)
2022
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
Cash and balances at central
banks
5.3
5.3
139.5
139.5
144.8
Trading assets
21.7
21.7
1.3
1.1
21.5
23.9
45.6
Derivatives
99.5
99.5
99.5
Settlement balances
2.6
2.6
2.6
Loans to banks - amortised cost
0.1
0.1
5.9
0.8
0.3
7.0
7.1
Loans to customers - amortised
cost
10.4
0.4
10.8
99.9
92.2
122.5
40.9
255.6
366.3
Residential mortgages
- UK
7.0
7.0
99.9
80.0
15.0
95.0
201.9
- Rol
Credit cards
4.1
0.2
4.3
4.3
Personal loans
5.4
2.2
1.4
9.0
9.0
Other
3.4
0.4
3.8
2.7
105.1
39.5
147.3
151.1
Other financial assets
6.3
6.3
1.8
21.2
0.2
1.4
22.8
30.9
Intangible assets
7.1
7.1
7.1
Other assets
2.5
6.7
9.2
9.2
Assets of disposal groups
(11)
1.1
1.1
5.8
5.8
6.9
Total assets
11.5
33.8
45.3
99.9
1.8
260.1
127.1
185.8
573.0
720.0
2021
Total assets
11.9
59.1
71.0
126.2
2.0
267.9
123.5
191.4
582.8
782.0
(1)
Covered debts and securitisations include securitisations, conduits, covered bonds and secured 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 banking operations. Securities financing transactions (SFT) include collateral given to secure derivative liabilities.
(3)
Derivative cash collateral of £13 billion (2021 - £12 billion) has been included in the encumbered assets basis the regulatory requirement.
(4)
Total assets encumbered as a result of transactions with counterparties other than central banks are those that have been pledged to provide security and are therefore not available
to secure funding or to meet other collateral needs.
(5)
Assets pre-positioned at the central banks include loans provided as security as part of funding schemes 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 central banks but not pre-positioned; cash and high quality debt securities that form part of
NatWest Group’s liquidity portfolio and unencumbered debt securities.
(8)
Other assets that are capable of being encumbered are those assets on the balance sheet that are available for funding and collateral purposes but are not readily realisable in their
current form. These assets include loans that could be 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.
(11)
The majority of UBIDAC assets are in contracted loan sale agreements as part of its phased withdrawal strategy and are unavailable for any alternative contingent liquidity
arrangements. UBIDAC has in place a committed unsecured liquidity line from NatWest Bank to support the withdrawal.
Risk and capital management
continued
NatWest Group
Annual Report and Accounts 2022
264
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
Market risk
(audited)
NatWest Group is exposed to non-traded market risk through
its banking activities and to traded market risk through its
trading activities. Non-traded and traded market risk exposures
are managed and discussed separately. The non-traded market
risk section begins below. The traded market risk section
begins on page 272. Pension-related activities also give rise to
market risk. Refer to page 276 for more information 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 such as interest rates,
foreign exchange rates and equity 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 information on each of
these risk types, refer to the separate sub-sections following
the VaR table below.
Key developments in 2022
Interest rates in the UK increased sharply in 2022, to levels
higher than expected at the end of 2021. The Bank of
England base rate rose from 0.25% at 31 December 2021 to
3.5% at 31 December 2022. The five-year sterling overnight
index interest rate swap rate rose from 1.05% at 31
December 2021 to 4.10% at 31 December 2022. The
corresponding ten-year rate rose from 0.95% to 3.75%.
Overall, non-traded VaR decreased over the year, driven by
a decrease in credit spread VaR. This reflected reduced
holdings of bonds in the liquidity portfolio. Interest rate VaR
rose, reflecting higher interest rate volatility, particularly in
sterling. By year-end, interest rate risk had displaced credit
spread risk as the main driver of non-traded VaR.
NatWest Group’s structural hedge notional increased to
£230 billion at 31 December 2022 from £206 billion at 31
December 2021 as more balances were included in the
hedging programme.
Higher swap rates were reflected in a higher yield on the
structural hedge, which rose from 0.75% in 2021 to 0.96% in
2022.
The sensitivity of net interest earnings to a 25-basis-point
upward shift in the yield curve fell to a cumulative £886
million over three years at 31 December 2022, from £1,107
million at 31 December 2021. The main contributors to
lower sensitivity were lower deposit volumes and increased
structural hedging.
Sterling weakened against the US dollar, to 1.21 at 31
December 2022 compared to 1.35 at 31 December 2021. It
also weakened against the euro, to 1.13 at 31 December
2022 compared to 1.19 at 31 December 2021. Residual
structural foreign currency exposures decreased over the
year by £1.5 billion, in sterling equivalent terms, mainly due
to increased hedging.
Governance
(audited)
Responsibility for identifying, measuring, monitoring and
controlling market risk arising from non-trading activities lies
with the relevant business. Oversight is provided by the
independent Risk function.
Risk positions are reported regularly to the Executive Risk
Committee, the Board Risk Committee, and the Board as well
as to the Asset & Liability Management Committee. Non-traded
market risk policy sets out the governance and risk
management framework.
Risk
appetite
NatWest Group’s qualitative appetite is set out in the non-
traded market risk appetite statement.
Its quantitative appetite is expressed in terms of value-at-risk
(VaR), stressed value-at-risk (SVaR), sensitivity and stress limits,
and earnings-at-risk limits.
The limits are reviewed to reflect changes in risk appetite,
business plans, portfolio composition and the market and
economic environments. To ensure approved limits are not
breached and that NatWest Group remains within its risk
appetite, triggers have been set and are actively managed. For
further information on risk appetite and risk controls, refer to
pages 181 and 182.
Risk and capital management
continued
NatWest Group
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265
Financial statements
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Governance
Risk and capital management
Additional information
Financial review
Financial statements
Strategic report
Governance
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 internal banking book value-at-risk (VaR) at a 99% confidence level, split by risk type. VaR
values for each year are calculated based on one-day values for each of the 12 month-end reporting dates.
NatWest Group’s VaR metrics are explained on page 272. Each of the key risk types are discussed in greater detail in their
individual sub-sections following this table.
2022
2021
Average
Maximum
Minimum
Period end
Average
Maximum
Minimum
Period end
£m
£m
£m
£m
£m
£m
£m
£m
Interest rate
30.4
60.7
7.6
37.7
10.2
13.7
6.4
8.6
Credit spread
36.3
86.6
19.9
20.3
102.9
113.5
92.4
100.9
Structural foreign exchange rate
8.9
11.3
6.1
11.3
11.4
13.2
9.2
12.0
Equity
18.1
22.2
13.7
14.7
12.4
14.6
11.1
14.3
Pipeline risk
(1)
1.5
4.5
0.3
2.4
0.5
1.2
0.3
1.2
Diversification
(2)
(36.9)
(34.9)
(12.9)
(35.6)
Total
58.3
91.2
45.5
51.5
124.5
147.1
101.4
101.4
(1)
Pipeline risk is the risk of loss arising from personal 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 taking 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 particular time. The diversification factor is the sum of the VaR on individual risk types less the total portfolio VaR.
Overall, non-traded VaR decreased over the year, driven by
a decrease in credit spread VaR. This reflected reduced
holdings of bonds in the liquidity portfolio.
Interest rate VaR increased, reflecting higher interest rate
volatility, particularly in sterling. By year-end, interest rate
risk had displaced credit spread risk as the main driver of
non-traded VaR.
Risk and capital management
continued
NatWest Group
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266
Financial statements
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Governance
Risk and capital management
Additional information
Financial review
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
Non-traded market risk continued
Interest rate risk
Non-traded interest rate risk (NTIRR) arises from the provision
to customers of a range of banking products with differing
interest rate characteristics. When aggregated, these products
form portfolios of assets and liabilities with varying degrees of
sensitivity to changes in market interest rates. Mismatches can
give rise to volatility in net interest 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 depends
on whether changes to the term structure of interest rates
occur consistently across the yield curve (parallel risk) or
differentially by period (non-parallel risk).
Basis risk: captures the impact of relative changes in
interest rates for financial instruments that have similar
tenors but are priced using different interest rate indices, or
on the same interest rate indices but with different tenors.
Option risk: arises from option derivative positions or from
optional elements embedded in assets, liabilities and/or off-
balance sheet items, where NatWest Group or its customer
can alter the level and timing of their cash flows. Option
risk also includes pipeline risk.
To manage exposures within its risk appetite, NatWest Group
aggregates interest rate positions and hedges its residual
exposure, primarily with interest rate swaps.
Structural hedging aims to reduce gap risk and the sensitivity
of earnings to interest rate shocks. It also provides some
protection against prolonged periods of falling rates. Structural
hedging is explained in greater detail below, followed by
information on how NatWest Group measures NTIRR from both
an economic value-based and an earnings-based perspective.
Structural hedging
NatWest Group has a significant pool of stable, non and low interest-bearing liabilities, principally comprising current accounts and
savings, in addition to its equity and reserves. A proportion of these balances are hedged, either by investing directly in longer-
term fixed-rate assets (such as fixed-rate mortgages) or by using interest rate swaps, which are generally booked as cash flow
hedges of floating-rate assets, in order to provide a consistent and predictable revenue stream.
After hedging the net interest rate exposure externally, NatWest Group allocates income to equity or products in structural hedges
by reference to the relevant interest rate swap curve. Over time, this approach has provided a basis for stable income attribution
for management purposes to products and interest rate returns. The programme aims to track a time series of medium-term swap
rates, but the yield will be affected by changes in product volumes and NatWest Group’s equity capital.
The table below shows the total income and total yield, incremental income, and the period-end and average notional balances
allocated to equity and products in respect of the structural hedges managed by NatWest Group. Total income represents the fixed
leg of the hedge, while incremental income represents the difference between total income and short-term cash rates.
2022
2021
Incremental
income
Total
income
Period end
notional
Average
notional
Total yield
Incremental
income
Total income
Period end
nontional
Average
nontional
Total yield
£m
£m
£bn
£bn
%
£m
£m
£bn
£bn
%
Equity
71
363
21
21
1.77
426
448
21
22
2.05
Product
(973)
1,571
184
176
0.89
744
861
161
145
0.59
Other
(112)
201
25
26
0.77
139
115
24
23
0.51
Total
(1,014)
2,135
230
223
0.96
1,309
1,424
206
190
0.75
Equity structural hedges refer to income allocated primarily to equity and reserves. At 31 December 2022, the equity structural
hedge notional was allocated between NWH Group and NWM Group in a ratio of approximately 77%/23% respectively.
Product structural hedges refer to income allocated to customer products by NWH Group Treasury, mainly current account and
savings balances in Commercial & Institutional and Retail Banking. Other structural hedges refer to hedges managed by the Coutts
& Co, RBS International and UBIDAC legal entities.
At 31 December 2022, approximately 94% by notional of total structural hedges were sterling-denominated.
Risk and capital management
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Non-traded market risk continued
The following table presents the incremental income associated with product structural hedges at segment level.
2022
2021
£m
£m
Retail Banking
(463)
346
Commercial & Institutional
(510)
398
Total
(973)
744
The increase in hedge notional, on a period-end basis,
mainly resulted from increased hedging of Personal and
Commercial deposits.
The increase in total income reflected not only the increase
in hedge notional but also higher yields. The total yield of
the structural hedge also rose to 0.96% in 2022 from 0.75%
in 2021, although the yield on the equity hedge fell as
higher yielding hedges matured.
The five-year sterling swap rate rose to 4.10% at the end of
December 2022 from 1.05% at the end of December 2021.
The ten-year sterling swap rate also rose, from 0.95% to
3.75%.
Incremental income, which measures the difference
between total yield and short term interest rates, turned
negative. This reflects the relative stability of the total yield
of the structural hedge. Compared to the 21-basis-point
increase in the structural hedge total yield, the sterling
overnight index average (SONIA) increased 324 basis points
to 3.43% at 31 December 2022 from 0.19% at 31 December
2021.
NTIRR can be measured using value-based or earnings-based approaches. Value-based approaches measure the change in value
of the balance sheet assets and liabilities including all cash flows. Earnings-based approaches measure the potential impact on the
income statement of changes in interest rates over a defined horizon, generally one to three years.
NatWest Group uses VaR as its value-based approach and sensitivity of net interest earnings as its earnings-based approach.
These two approaches provide complementary views of the impact of interest rate risk on the balance sheet at a point in time. The
scenarios employed in the net interest earnings sensitivity approach may incorporate assumptions about how NatWest Group and
its customers will respond to a change in the level of interest rates. In contrast, the VaR approach measures the sensitivity of the
balance sheet at a point in time. Capturing all cash flows, VaR also highlights the impact of duration and repricing risks beyond the
one-to-three-year period shown in earnings sensitivity calculations.
Value-at-risk
VaR is a statistical estimate of the potential change 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 and a confidence level of 99% – are
based on interest rate repricing gaps at the reporting date. Daily rate moves are modelled using observations from the last 500
business days. These incorporate customer products plus associated funding and hedging transactions as well as non-financial
assets and liabilities. Behavioural assumptions are applied as appropriate.
The non-traded interest rate risk VaR metrics for NatWest Group’s retail and commercial banking activities are included in the
banking book VaR table presented earlier in this section. The VaR captures the risk resulting from mismatches in the repricing
dates of assets and liabilities.
It also includes any mismatch between the maturity profile of external hedges and NatWest Group’s target maturity profile for the
hedge.
Risk and capital management
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Non-traded market risk continued
Sensitivity of net interest earnings
Net interest earnings are sensitive to changes in the level of
interest rates, mainly because maturing structural hedges are
replaced at higher or lower rates and changes to coupons on
managed rate customer products do not always match changes
in market rates of interest or central bank policy rates.
Earnings sensitivity is derived from a market-implied forward
rate curve, which will incorporate expected changes in central
bank policy rates such as the Bank of England base rate. A
simple scenario is shown that projects forward earnings based
on the 31 December 2022 balance sheet, 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 market-implied projection
and the shock gives an indication of underlying sensitivity to
interest rate movements.
Reported sensitivities should not be considered a forecast of
future performance in these rate scenarios. Actions that could
reduce interest earnings sensitivity include changes in pricing
strategies on customer loans and deposits 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 interest earnings –
for both structural hedges and managed rate accounts – on a
one, two and three-year forward-looking basis to an upward or
downward interest rate shift of 25 basis points.
In all scenarios, yield curves are assumed to move in parallel.
+25 basis points upward shift
-25 basis points downward shift
Year 1
Year 2
Year 3
Year 1
Year 2
Year 3
2022
£m
£m
£m
£m
£m
£m
Structural hedges
50
158
260
(50)
(158)
(260)
Managed margin
148
141
136
(170)
(140)
(129)
Total
198
299
396
(220)
(298)
(389)
2021
Structural hedges
40
132
224
(40)
(132)
(224)
Managed margin
269
203
239
(245)
(199)
(177)
Total
309
335
463
(285)
(331)
(401)
(1)
Earnings sensitivity considers only the main drivers, namely structural hedging and margin management.
(2)
Following a change in the basis of preparation of this table, it now excludes UBIDAC.
The overall sensitivity to shifts in the yield curve decreased
year on year, mainly driven by increased structural hedge
volumes and lower managed margin deposit volumes.
The sensitivity of the structural hedge increased because of
the rise in hedged volumes, which increased the sensitivity
to hedges maturing through the projection.
The increased volume of hedges reduces managed margin
sensitivity because a significant part of the managed
margin component is the residual sensitivity of unhedged
deposit volumes.
Managed margin sensitivity further reduced due to lower
deposit volumes at 31 December 2022 compared to 31
December 2021.
One-year 25 and 100-basis-point sensitivity table
The following table analyses the one-year scenarios by currency. The sensitivity to a downward 100-basis-point shift in the yield
curve has been introduced for 2022.
This shift was not presented for 2021, when yield curves were already close to zero (or were
negative in euros).
2022
2021
Shifts in yield curve
Shifts in yield curve
+25 basis points
-25 basis points
+100 basis points
-100 basis points
+25 basis points
-25 basis points
+100 basis points
£m
£m
£m
£m
£m
£m
£m
Euro
13
(12)
48
(50)
7
15
64
Sterling
172
(194)
698
(784)
260
(265)
950
US dollar
10
(11)
42
(53)
40
(33)
143
Other
3
(3)
13
(16)
2
(2)
11
Total
198
(220)
801
(903)
309
(285)
1,168
(1)
Following a change in the basis of preparation of this table, it now excludes UBIDAC.
Risk and capital management
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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 liquidity portfolio at fair value. Valuation changes that are not hedged (or not in
effective hedge accounting relationships) are recognised in FVOCI reserves.
Interest rate swaps are used to implement the structural hedging programme and also hedging of some personal and commercial
lending portfolios, primarily fixed-rate mortgages. Generally, these swaps are booked in hedge accounting relationships. Changes
in the valuation of swaps that are in effective cash flow hedge accounting relationships are 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. Cash flow
hedges are assumed to be fully effective and interest rate hedges of bonds in the liquidity portfolio are also assumed to be subject
to fully effective hedge accounting. No change in the spread between bonds and swaps is assumed. Hedge accounting
ineffectiveness would result in deviation from the results below, with gains or losses recognised in P&L instead of reserves. Hedge
ineffectiveness P&L is monitored, and the effectiveness of cash flow and fair value hedge relationships is regularly tested in
accordance with IFRS requirements. Note that a movement in the FVOCI reserve would have an impact on CET1 capital but a
movement in the cash flow hedge reserve would not be expected to do so. Volatility in both reserves affects tangible net asset
value.
2022
2021
+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
(3)
2
(13)
5
(46)
45
(187)
174
Cash flow hedge reserves
(278)
281
(1,097)
1,138
(210)
214
(820)
877
Total
(281)
283
(1,110)
1,143
(256)
259
(1,007)
1,051
The sensitivity of FVOCI and cash flow hedge reserves increased in 2022, mainly due to increased cash flow hedging, partly
offset by a reduction in FVOCI sensitivity as a result of bond disposals.
Risk and capital management
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Non-traded market risk continued
Credit spread risk
Credit spread risk arises from the potential adverse economic
impact of a change in the spread between bond yields and
swap rates, where the bond portfolios are accounted at fair
value through other comprehensive income.
NatWest Group’s bond portfolios primarily comprise high-quality
securities maintained as a liquidity buffer to ensure it can
continue to meet its obligations in the event that access to
wholesale funding markets is restricted. Additionally, other high-
quality bond portfolios are held for collateral purposes and to
support payment systems.
Credit spread risk is monitored daily through sensitivities and
VaR measures (refer to the non-traded VaR table earlier in this
section). Exposures and limit utilisations are reported to senior
management on a regular basis. Dealing mandates in place for
the bond portfolios further mitigate the risk by imposing
constraints by duration, asset class and credit rating.
Foreign exchange risk
Non-traded foreign exchange risk arises from three main
sources:
Structural foreign exchange rate risk – mainly arises from
the capital deployed in foreign subsidiaries and branches.
Transactional 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 currencies – NatWest
Group assesses its potential exposure to forecast foreign
currency income and expenses. NatWest Group hedges
forward some forecast expenses.
The most material non-traded open currency positions are the
structural foreign exchange exposures arising from investments
in foreign subsidiaries and branches. These exposures are
assessed and managed to predefined risk appetite levels under
delegated authority agreed by the CFO with support from the
Asset & Liability Management Committee. NatWest Group seeks
to limit the potential volatility impact on its CET1 ratio from
exchange rate movements by deliberately maintaining a
structural open currency position. Gains or losses arising from
the retranslation of net investments in overseas operations are
recognised in other comprehensive income and reduce the
sensitivity of capital 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 ratio of the structural open position to RWAs
equals the CET1 ratio.
The sensitivity of this ratio to exchange rates is monitored
monthly and reported to the Asset & Liability Management
Committee at least quarterly. Foreign exchange exposures
arising from customer transactions are hedged by businesses on
a regular basis in line with NatWest Group policy.
Foreign exchange risk
(audited)
The table below shows structural foreign currency exposures.
Net investments in
foreign operations
Net investment
hedges
Structural foreign
currency exposures
pre-economic hedges
Economic hedges
(1)
Residual Structural
foreign currency
exposures
2022
£m
£m
£m
£m
£m
US dollar
1,278
(303)
975
(975)
Euro
6,189
(4,164)
2,025
2,025
Other non-sterling
996
(431)
565
565
Total
8,463
(4,898)
3,565
(975)
2,590
2021
US dollar
1,275
(260)
1,015
(1,015)
Euro
6,222
(2,669)
3,553
3,553
Other non-sterling
990
(421)
569
569
Total
8,487
(3,350)
5,137
(1,015)
4,122
(1)
Economic hedges of US dollar net investments in foreign operations represent US dollar AT1 equity securities that do not qualify as net investment hedges for accounting purposes.
They provide an offset to structural foreign exchange exposures to the extent that there are net assets in overseas operations available, but they are accounted for at historical cost
under IFRS until redemption.
Residual structural foreign currency exposures fell in
2022, mainly due to increased hedging of net
investments in euro operations.
Changes in foreign currency exchange rates affect
equity in proportion to structural foreign currency
exposure pre economic hedges. For example, a 5%
strengthening or weakening in foreign currencies against
sterling would result in a gain or loss of £0.2 billion in
equity respectively.
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Non-traded market risk continued
Equity risk
(audited)
Non-traded equity risk is the potential variation in income and reserves arising from changes in equity valuations. Equity exposures
may arise through strategic acquisitions, through participations in industry schemes (for example, SWIFT) or through private equity
arrangements (for example, the Big Society scheme).
Investments, acquisitions or disposals of a strategic nature are referred to the Acquisitions & Disposals Committee. Once approved
by the CFO with support from the Acquisitions & Disposals Committee for execution, such transactions are referred for approval to
the Board, the Executive Committee, the Chief Executive, the Chief Financial Officer or as otherwise required. Decisions to acquire
or hold equity positions in the non-trading book that are not of a strategic nature are taken by authorised persons with delegated
authority.
Equity positions are carried at fair value on the balance sheet based on market prices where available. If market prices are not
available, fair value is based on appropriate valuation techniques or management estimates.
The table below shows the balance sheet carrying value of equity positions in the banking book.
2022
2021
£m
£m
Exchange-traded equity
154
16
Private equity and other
170
226
324
242
The exposures may take the form of (i) equity shares listed on a recognised exchange, (ii) private equity shares defined as unlisted
equity shares with no observable market parameters or (iii) other unlisted equity shares such as participation in SWIFT.
2022
2021
£m
£m
Net realised gains arising from disposals
106
8
Unrealised gains included in Tier 1 or Tier 2 capital
(1)
89
88
(1)
Includes gains or losses on FVOCI instruments only.
The increase in equity investments mainly reflects the acquisition of new investments in PTSB and Vodeno in H2 2022, partly
offset by disposals.
Accounting volatility risk
Accounting volatility risk arises when an exposure is accounted
for at amortised cost but economically hedged by a derivative
that is accounted for at fair value. Although this is not an
economic risk, the difference in accounting between the
exposure and the hedge creates volatility in the income
statement.
Accounting volatility can be mitigated through hedge
accounting. However, residual volatility will remain in cases
where accounting rules mean that hedge accounting is not an
option, or where there is some hedge ineffectiveness.
Accounting volatility risk is reported to the Asset & Liability
Management Committee monthly and capitalised as part of the
Internal Capital Adequacy Assessment Process (ICAAP).
Risk and capital management
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Traded market risk
Definition
(audited)
Traded market risk is the risk arising from changes in fair value
on positions, assets, liabilities or commitments in trading
portfolios as a result of fluctuations in market prices.
Sources of risk
(audited)
Traded market risk mainly arises from NatWest Group’s trading
activities. These activities provide a range of financing, risk
management and investment services to clients − including
corporations and financial institutions − around the world. From
a market risk perspective, activities are focused on rates;
currencies; and traded credit. NatWest Group undertakes
transactions in financial instruments including debt securities,
as well as securities financing and derivatives.
All material traded market risk resides in NatWest Markets. The
key categories are interest rate risk, credit spread risk and
foreign currency price risk.
Trading activities may also give rise to counterparty credit risk.
For further detail refer to the Credit risk section.
Key developments in 2022
The year was marked by periods of increased market
volatility reflecting UK political developments, global
inflationary concerns and the invasion of Ukraine
The significant volatility in Gilts, sterling swaps and inflation
entered the rolling window for VaR calculation during 2022.
However, traded VaR and SVaR remained within appetite
and, on an average basis, decreased compared to 2021,
aided by NatWest Group’s continued disciplined approach
to risk-taking.
Governance
(audited)
Market risk policy statements set out the governance and risk
management framework. Responsibility for identifying,
measuring, monitoring and controlling market risk arising from
trading activities lies with the relevant trading business. The
Market Risk function independently advises on, monitors and
challenges the risk-taking activities undertaken by the trading
business ensuring these are within the constraints of the
market risk framework, policies, and risk appetite statements
and measures.
Risk appetite
NatWest Group’s qualitative appetite for traded market risk is
set out in the traded market risk appetite statement.
Quantitative appetite is expressed in terms of exposure limits.
The limits at NatWest Group level comprise value-at-risk (VaR),
stressed value-at-risk (SVaR) and stress-testing limits. More
details on these are provided on the following pages.
For each trading business, a document known as a dealing
authority compiles details of all applicable limits and trading
restrictions. The desk-level mandates comprise qualitative limits
related to the product types within the scope of each desk, as
well as quantitative metrics specific to the desk’s market risk
exposures. These additional limits and metrics aim to control
various risk dimensions such as exposure size, aged inventory,
currency and tenor.
The limits are reviewed to reflect changes in risk appetite,
business plans, portfolio composition and the market and
economic environments and recalibrated to ensure that they
remain aligned to NatWest Group RWA targets. Limit reviews
focus on optimising the alignment between traded market risk
exposure and capital usage.
To ensure approved limits are not breached and that NatWest
Group remains within its risk appetite, triggers have been set
such that if exposures exceed a specified level, action plans are
developed by the relevant business and the Market Risk
function and implemented. For more detail on risk appetite and
risk controls, refer to pages 181 and 182.
Monitoring and mitigation
Traded market risk is identified and assessed by gathering,
analysing, monitoring and reporting market risk information at
desk, business, business segment and NatWest Group-wide
levels. Industry expertise, continued system developments and
techniques such as stress testing are also used to enhance the
effectiveness of the identification and assessment of all material
market risks.
Traded market risk exposures are monitored against limits and
analysed daily. A daily report summarising the position of
exposures against limits at desk, business, business segment
and NatWest Group levels is provided to senior management
and market risk managers across the function. Limit reporting
is supplemented with regulatory capital and stress testing
information as well as ad-hoc reporting.
A risk review of trading businesses 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 triggers which, if breached, require
a remedial action plan to be agreed between the Market Risk
function and the business. The loss triggers are set using both a
fall-from-peak approach and an absolute loss level. In addition,
regular updates on traded market risk positions are provided to
the Executive Risk Committee, the Board Risk Committee and
the Board.
Measurement
NatWest Group uses VaR, SVaR and the incremental risk
charge to measure traded market risk. Risks that are not
adequately captured by VaR or SVaR are captured by the Risks
Not In VaR (RNIV) framework to ensure that NatWest Group is
adequately capitalised for market risk. In addition, stress testing
is used to identify any vulnerabilities and potential losses.
The key inputs into these measurement methods are market
data and risk factor sensitivities. Sensitivities refer to the
changes in trade or portfolio value that result from small
changes in market parameters that are subject to the market
risk limit framework. Revaluation ladders are used in place of
sensitivities to capture the impact of large moves in risk factors
or the joint impact of two risk factors.
These methods have been designed to capture 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 characteristics
of each risk type.
Value-at-risk
For internal risk management purposes, VaR assumes a time
horizon of one trading day and a confidence level of 99%.
The internal VaR model – which captures all trading book
positions including those products approved by the regulator –
is based on a historical simulation, utilising market data from
the previous 500 days on an equally-weighted basis.
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Traded market risk continued
The model also captures the potential impact of interest rate
risk; credit spread risk; foreign currency price risk; equity price
risk; and commodity price risk.
When simulating potential movements in such risk factors, a
combination of absolute, relative and rescaled returns is used.
The performance and adequacy of the VaR model are tested
regularly through the following processes:
Back-testing: Internal and regulatory back-testing is
conducted on a daily basis. Information on internal 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 significantly.
Model Risk Management review: 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 portfolio
profile. For further detail on the independent model
validation carried out by Model Risk Management refer to
page 282. More information relating to pricing and market
risk models is presented in the Pillar 3 Report.
One-day 99% traded internal VaR
Traded VaR (1-day 99%)
(audited)
The table below shows one-day 99% internal VaR for NatWest Group’s trading portfolios, split by exposure type.
2022
2021
Average
Maximum
Minimum
Period end
Average
Maximum
Minimum
Period end
£m
£m
£m
£m
£m
£m
£m
£m
Interest rate
7.3
12.6
4.1
9.0
10.4
25.3
4.5
8.9
Credit spread
7.8
12.0
6.0
6.4
11.3
13.4
9.4
10.7
Currency
3.1
8.0
1.2
1.5
3.4
9.4
1.7
2.2
Equity
0.3
0.4
0.8
0.2
Commodity
0.1
0.5
Diversification
(1)
(7.5)
(6.8)
(12.3)
(10.5)
Total
10.7
15.1
7.2
10.1
13.3
23.9
9.3
11.5
(1)
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 particular time. The diversification factor is the sum of the VaR on individual risk types less the total portfolio VaR.
On an average basis, total traded VaR was lower in 2022
than in 2021 despite the increased market volatility related
to sterling Gilts, swaps and inflation entering the rolling
window for VaR calculation during 2022.
The decrease in average interest rate VaR reflected the
lower tenor basis risk in sterling flow trading in 2022 than in
2021. This followed the application of a regulator-approved
update to the VaR model in Q3 2021 to address the impact
of the transition from LIBOR to alternative risk-free rates.
Credit spread VaR also decreased, mainly because the
heightened market volatility in March 2020, resulting from
the onset of the COVID-19 crisis, dropped out of the VaR
window during H1 2022.
0
2
4
6
8
10
12
14
16
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Total Trading VaR
Interest Rate VaR
Credit VaR
FX VaR
Equity VaR
Commodity VaR
£m
Risk and capital management
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Traded market risk
VaR back-testing
The main approach employed to assess the VaR model’s
ongoing performance is back-testing, which counts the number
of days when a loss exceeds the corresponding daily VaR
estimate, measured at a 99% confidence level.
Two types of profit and loss (P&L) are used in back-testing
comparisons: Actual P&L and Hypothetical P&L. For more
details on the back-testing approach, refer to the Pillar 3
Report.
The table below shows internal back-testing exceptions in the major NatWest Markets businesses for the 250-business-day period
to 31 December 2022. Internal back-testing compares one-day 99% traded internal VaR with Actual and Hypothetical (Hypo) P&L.
Back-testing exceptions
Actual
Hypo
Rates
2
6
Currencies
7
Credit
xVA
1
1
The exceptions in the Rates business were mainly driven by
market moves in sterling, euro and US dollar rates and
sterling inflation.
The exceptions in the Currencies business were mainly
driven by market moves related to sterling, the euro and
the US dollar.
The total xVA loss was driven by a loss due to the default of
a counterparty.
Stressed VaR (SVaR)
As with VaR, the SVaR methodology produces estimates of the potential change in the market value of a portfolio, over a specified
time horizon, at a given confidence level. SVaR is a VaR-based measure using historical data from a one-year period of stressed
market conditions.
A simulation of 99% VaR is run on the current portfolio for each 250-day period from 2005 to the current VaR date, moving
forward one day at a time. The SVaR is the worst VaR outcome of the simulated results.
This is in contrast with VaR, which is based on a rolling 500-day historical data set. A time horizon of ten trading days is assumed
with a confidence level of 99%.
The internal traded SVaR model captures all trading book positions.
2022
2021
Average
Maximum
Minimum
Period end
Average
Maximum
Minimum
Period end
£m
£m
£m
£m
£m
£m
£m
£m
Total internal traded SVaR
70
206
34
40
95
175
46
66
Traded SVaR was, on an average basis, lower in 2022 than in 2021, following the reduction in tenor basis risk in sterling flow
trading resulting from the VaR model update in Q3 2021.
Risks Not In VaR (RNIVs)
The RNIV framework is used to identify and quantify market
risks that are not fully captured by the internal VaR and SVaR
models.
RNIV calculations form an integral part of ongoing model and
data improvement efforts to capture all market risks in scope
for model approval in VaR and SVaR.
For further qualitative and quantitative disclosures on RNIVs,
refer to the Market risk section of the Pillar 3 Report.
Stress testing
For information on stress testing, refer to page 182.
Incremental risk charge (IRC)
The IRC model quantifies the impact of rating migration and
default events on the market value of instruments with
embedded credit risk (in particular, bonds and credit default
swaps) held in the trading book. It further captures basis risk
between different instruments, maturities and reference
entities. For further qualitative and quantitative disclosures on
the IRC, refer to the Market risk section of the Pillar 3 Report.
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Market risk – linkage to balance sheet
The table below analyses NatWest Group’s balance sheet by non-trading and trading business.
2021
Total
Non-trading
business
Trading
business
Total
Non-trading
business
Trading
business
£bn
£bn
£bn
£bn
£bn
£bn
Primary market risk factor
Assets
Cash and balances at central
banks
144.8
144.8
177.8
177.8
Interest rate
Trading assets
45.6
1.2
44.4
59.2
0.7
58.5
Reverse repos
21.5
21.5
20.7
20.7
Interest rate
Securities
9.9
9.9
25.0
25.0
interest rate, credit spreads, equity
Other
14.2
1.2
13.0
13.5
0.7
12.8
Interest rate
Derivatives
99.5
1.3
98.2
106.1
1.6
104.5
Interest rate, credit spreads, equity
Settlement balances
2.6
0.2
2.4
2.1
0.2
1.9
Settlement
Loans to banks
7.1
7.0
0.1
7.7
7.6
0.1
Interest rate
Loans to customers
366.3
366.2
0.1
359.0
358.9
0.1
Interest rate
Other financial assets
30.9
30.9
46.1
46.1
Interest rate, credit spreads, equity
Intangible assets
7.1
7.1
6.7
6.7
Interest rate, credit spreads, equity
Other assets
9.3
9.3
8.3
8.3
Assets of disposal groups
6.9
6.9
9.0
9.0
Total assets
720.1
574.9
145.2
782.0
616.9
165.1
Liabilities
Bank deposits
20.4
20.4
26.3
26.3
Interest rate
Customer deposits
450.3
450.3
479.8
479.8
Interest rate
Settlement balances
2.0
2.0
2.1
2.1
Settlement
Trading liabilities
52.8
52.8
64.6
0.1
64.5
Repos
23.7
23.7
19.4
19.4
Interest rate
Short positions
9.5
9.5
25.0
25.0
Interest rate, credit spreads
Other
19.6
19.6
20.2
0.1
20.1
Interest rate
Derivatives
94.0
1.5
92.5
100.8
3.6
97.2
Interest rate, credit spreads
Other financial liabilities
49.1
49.0
0.1
49.3
48.9
0.4
Interest rate
Subordinated liabilities
6.3
6.3
8.4
8.4
Interest rate
Notes in circulation
3.2
3.2
3.0
3.0
Interest rate
Other liabilities
5.5
5.5
5.9
5.9
Total liabilities
683.6
536.2
147.4
740.2
576.0
164.2
(1)
Non-trading businesses are entities that primarily have exposures 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 denominated 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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Pension risk
Definition
Pension risk is defined in a consistent manner to the regulatory
definition as the inability to meet contractual obligations and
other liabilities to the established employee or related company
pension scheme.
Sources of risk
NatWest Group has exposure to pension risk through its
defined benefit schemes worldwide. The Main section of The
NatWest Group Pension Fund (the Main section) is the largest
source of pension risk with £34.0 billion of assets and £24.7
billion of liabilities at 31 December 2022 (2021 – £52.0 billion of
assets and £42.0 billion of liabilities). Refer to Note 5 to the
consolidated financial statements, for further details on
NatWest Group’s pension obligations, including sensitivities to
the main risk factors.
Pension scheme liabilities vary with changes in long-term
interest rates and inflation as well as with pensionable salaries,
the longevity of scheme members and legislation. Pension
scheme assets vary with changes in interest rates, inflation
expectations, credit spreads, exchange rates, and equity and
property prices. NatWest Group is exposed to the risk that the
schemes’ assets, together with future returns and additional
future contributions, are estimated to be insufficient to meet
liabilities as they fall due. In such circumstances, NatWest
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 2022
There were no material changes to NatWest Group’s
exposure to pension risk during the year. Despite market
volatility, the Main section remained resilient, primarily due
to its interest rate and inflation hedging strategy, as well as
its limited exposure to equities. Furthermore, the Main
section held sufficient collateral in relation to its liability
hedging portfolio, without the need to sell assets to meet
collateral requirements. Some of NatWest Group’s smaller
schemes faced more challenging dynamics, with reductions
in funding levels, but continued to be able to raise collateral
as required. Any impact was not material at NatWest Group
level.
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 Main section,
following the share buyback in Q1 2022.
Since 31 December 2022, it has been agreed with the
Trustee of the Main section, that remaining contributions of
£471 million previously due to the Main section under the
Memorandum of Understanding signed in April 2018, will
instead be paid into a new legal structure.
For further
details, refer to Note 5 to the consolidated financial
statements.
As part of the ongoing phased withdrawal from the
Republic of Ireland, in December 2022, an agreement was
reached with the Trustees of NatWest Group’s defined
benefit pension schemes in the Republic of Ireland to secure
the long-term strategy for the schemes.
Governance
Chaired by the Chief Financial Officer, the Group Asset &
Liability Management Committee is a key component of
NatWest Group’s approach to managing pension risk. It
considers the pension impact of the capital plan for NatWest
Group and reviews the performance of NatWest Group’s
material pension funds and other issues material to NatWest
Group’s pension strategy. It also considers investment strategy
proposals from the Trustee of the Main section.
For further information on governance, refer to page 179.
Risk appetite
NatWest Group maintains an independent view of the risk
inherent in its pension funds. NatWest Group has an annually
reviewed pension risk appetite statement incorporating defined
metrics against which risk is measured.
Policies and standards are in place to provide formal controls
for pension risk reporting, modelling, governance and stress
testing. A pension risk policy, which sits within the NatWest
Group enterprise-wide risk management framework, is also in
place and is subject to associated framework controls.
Monitoring and measurement
Pension risk is monitored by the Executive Risk Committee and
the Board Risk Committee, whilst the Asset & Liability
Management Committee receives updates on the performance
of NatWest Group’s material pension funds.
NatWest Group also undertakes stress tests on its 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 includes 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 purposes. The results of the
stress tests and their consequential impact on NatWest Group’s
balance sheet, income statement and capital position are
incorporated into the overall NatWest Group stress test results.
NatWest Bank Plc (a subsidiary of NatWest Group) 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 protected against
interest rate and inflation risks and is being run on a low
investment risk basis with relatively small equity risk
exposure.
The Main section also uses derivatives to manage the
allocation of the portfolio to different asset classes and to
manage risk within asset classes.
The potential impact of climate change is one of the factors
considered in managing the assets of the Main section. The
Trustee monitors the risk to its investments from changes in the
global economy and invests, where return justifies the risk, in
sectors that reduce the world’s reliance on fossil fuels, or that
may otherwise promote environmental benefits. Further details
regarding the Main section Trustee’s approach to managing
climate change risk can be found in its Responsible Ownership
Policy and its net zero commitment. During the year, the
Trustee also produced its first climate disclosures as required
by The Occupational Pension Schemes (Climate Change
Governance and Reporting) Regulations 2021.
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Compliance and conduct risk
Definition
Compliance risk is the risk that NatWest Group fails to observe
the letter and spirit of all relevant laws, codes, rules, regulations
and standards of good market practice.
Conduct risk is the risk of inappropriate behaviour towards
customers, or in the markets in which NatWest Group operates,
which leads to unfair or inappropriate customer outcomes.
The consequences of failing to meet compliance and/or
conduct responsibilities can be significant and could result, for
example, in legal action, regulatory enforcement, material
financial loss and/or reputational damage.
Sources of risk
Compliance and conduct risks exist across all stages of
NatWest Group’s relationships with its customers and arise
from a variety of activities including product design, marketing
and sales, complaint handling, staff training, and handling of
confidential inside information.
As set out in Note 26 to the consolidated financial statements,
members of NatWest Group are party to legal proceedings and
are subject to investigation and other regulatory action in the
UK, the US and other jurisdictions.
Key developments in 2022
Further progress was made on the compliance agenda
during 2022. The first line of defence ring-fencing hub
which was established to provide an aggregated view of
ring-fencing compliance and risk management continues to
work across business segments, functions and legal entities.
From a conduct risk perspective, the focus on consumer
protection increased significantly during 2022, given the
cost-of-living challenges and their impact on customers in
vulnerable situations. The FCA’s increased expectations
under its Consumer Duty initiative was also a key
development, and the establishment of the consumer duty
‘One Bank’ programme will ensure continued focus on the
required ‘paradigm shift’ in the levels of consumer
protection.
In December 2021, NatWest Markets Plc pled 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 and,
separately, during approximately three months in 2018. In
line with the plea agreement with DOJ, an independent
monitor was appointed in 2022.
The monitor will be
engaged in working with NatWest Markets over a three-
year period.
More generally, work is also ongoing to further enhance the
conduct and compliance risk framework so that it is aligned
to a wider programme of work on the overall risk
management framework.
Governance
NatWest Group defines appropriate standards of compliance
and conduct and ensures adherence to those standards
through its risk management framework. Relevant compliance
and conduct matters are escalated through the Executive Risk
Committee and Board Risk Committee.
Risk appetite
Risk appetite for compliance and conduct risks is set at Board
level. Risk appetite statements articulate the levels of risk that
legal entities, businesses and functions work within when
pursuing their strategic objectives and business plans.
A range of controls are operated to ensure the business
delivers good customer outcomes and are conducted in
accordance with legal and regulatory requirements. A suite of
policies addressing compliance and conduct risks set
appropriate standards across NatWest Group. Examples
include policies relating to customers in vulnerable situations,
complaints management, cross-border activities and market
abuse. Continuous monitoring and targeted assurance are
carried out as appropriate.
Monitoring and measurement
Compliance and conduct risks are measured and managed
through continuous assessment and reporting to NatWest
Group’s senior risk committees and at Board level. The
compliance and conduct risk framework facilitates the
consistent monitoring and measurement of compliance with
laws and regulations and the delivery 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 NatWest Group with specific areas of
focus in the customer-facing businesses and legal entities.
Examples of mitigation include consideration of customer needs
in business and product planning, targeted training, conflicts of
interest management, market conduct surveillance, complaints
management, mapping of priority regulatory requirements and
independent monitoring activity. Internal policies help support a
strong customer focus across NatWest Group.
Financial crime risk
Definition
Financial crime risk is the risk that NatWest
Group's products
and services are intentionally or unintentionally used to
facilitate financial crime in the form of money laundering,
terrorist financing, bribery and corruption, sanctions and tax
evasion, as well as external or internal fraud.
Sources of risk
Financial crime risk may be present if NatWest Group’s
customers, employees or third parties undertake or facilitate
financial crime, or if NatWest Group’s products or services are
used intentionally or unintentionally to facilitate such crime.
Financial crime risk is an inherent risk across all lines of
business.
Key developments in 2022
Significant investment continued to be made to support
delivery of the multi-year transformation plan across
financial crime risk management.
Enhancements were made to technology and data analytics
to improve the effectiveness of systems used to monitor
customers and transactions.
A financial crime and fraud goal was rolled out to
approximately 55,000 colleagues across NatWest Group.
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Financial crime risk continued
Financial crime roadshows were held throughout the year
to further embed financial crime risk management culture
and behaviours.
Systematic Anti-Money Laundering Programme
assessment. In January 2022, NatWest Group received the
Skilled Person’s final report in connection with governance
arrangements for two financial crime change programmes
in respect of which the Skilled Person had been appointed
under section 166 of the Financial Services and Markets Act
2000 to provide assurance. The FCA confirmed in March
2022 that the section 166 review had been concluded.
Governance
The Financial Crime Executive Steering Group, which is jointly
chaired by the Chief Risk Officer and the Group Chief
Information Officer (previously the Chief Administration
Officer), is the core governance committee for financial crime
risk (excluding fraud). It oversees financial crime risk
management, operational performance, and transformation
matters including decision-making and escalations to the
Executive Risk Committee, Board Risk Committee and NatWest
Group Executive Committee.
The Fraud Executive Steering Group, which is chaired by the
Chief Information Officer, is the core governance committee for
fraud. It oversees fraud risk management, operational
performance, and investment matters including decision-
making and escalations to relevant senior committees.
Risk appetite
There is no appetite to operate in an environment where
systems and controls do not enable the effective identification,
assessment, monitoring, management and mitigation of
financial crime risk. NatWest Group’s systems and controls
must be comprehensive and proportionate to the nature, scale
and complexity of its businesses
NatWest Group operates a framework with preventative and
detective controls designed to mitigate the risk that it could
facilitate financial crime. These controls are supported by a
suite of policies, procedures and guidance to ensure they
operate effectively.
Monitoring and measurement
Financial crime risks are identified and reported through
continuous risk management and regular reporting to 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, relevant policies,
systems, processes and controls are used to mitigate and
manage financial crime risk. This includes the use of dedicated
screening and monitoring systems and controls to identify
people, organisations, transactions and behaviours that may
require further investigation or other actions. Centralised
expertise is available to detect and disrupt threats to NatWest
Group and its customers.
Intelligence is shared with law enforcement, regulators and
government bodies to strengthen national and international
defences against those who would misuse the financial system
for criminal motives.
Climate risk
Definition
Climate risk is the threat of financial loss or adverse non-
financial impacts associated with climate change and the
political, economic and environmental responses to it.
Sources of risk
Physical risks may arise from climate and weather-related
events such as heatwaves, droughts, floods, storms and sea
level rises. They can potentially result in financial losses,
impairing asset values and the creditworthiness of borrowers.
NatWest Group could be exposed to physical risks directly by
the effects on its property portfolio and, indirectly, by the
impacts on the wider economy as well as on the property and
business interests of its customers.
Transition risks may arise from the process of adjustment
towards a low-carbon economy. Changes in policy, technology
and sentiment could prompt reassessment of customers’
financial risk and may lead to falls in the value of a large range
of assets. NatWest Group could be exposed to transition risks
directly through the costs of adaptation within economic
sectors and markets as well as supply chain disruption leading
to financial impacts on it and its customers. Potential indirect
effects include the erosion of NatWest Group’s competitiveness,
profitability, reputational damage and liability risk.
Key developments in 2022
The enhancement of scenario generation capability,
building on our internal scenario analysis capability
developed over 2021 that supported risk management and
participation in the PRA Climate Biennial Exploratory
Scenario (CBES).
To support the management of credit risk, the application
of first generation qualitative climate risk scorecards within
customer conversations, and initiation of testing of
enhanced scorecards including quantitative elements.
Improved oversight of management of climate-related risk
through regular reporting and review of climate risk
appetite measures and key risk indicator trends informing
monthly risk committee updates.
The assessment of potential greenwashing risks driven by a
hypothetical risk scenario where increased competition in
the green finance market leads to less efficient product
designs and diminished robustness of governance.
The preparation of an initial iteration of the NatWest Group
Climate Transition plan including identification and analysis
of potential impacts associated with proposed actions.
Governance
The Board is responsible for monitoring and overseeing
climate-related risk within NatWest Group’s overall business
strategy and risk appetite. The potential impact, likelihood and
preparedness of climate-related risk are reported regularly to
the Board Risk Committee and the Board.
The Chief Risk Officer shares accountability with the CEO
under the Senior Managers and Certification Regime for
identifying and managing the financial risks arising from
climate change. This includes ensuring that the financial risks
from climate change are adequately reflected in risk
management frameworks, and that NatWest Group can
identify, measure, monitor, manage and report on its exposure
to these risks.
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Climate risk continued
The Climate Change Executive Steering Group is responsible
for overseeing the direction of and progress against NatWest
Group’s climate-related commitments. During 2022, the
Executive Steering Group focused on overseeing the
preparation of the initial iteration of NatWest Group’s Climate
Transition Plan, progression in establishing partnerships and
opportunities including oversight of progress against the
NatWest Group climate and sustainable funding and financing
target, and ensuring the effective management of climate-
related risks. The Executive Steering Group will continue to
supervise strategic implementation and delivery, supported by
the Climate Centre of Excellence.
Risk appetite
NatWest Group’s ambition is to be a leading bank in the UK in
helping to address climate change. This ambition is
underpinned by activity to reduce the climate impact of
financing activity by at least 50% by 2030 and to achieve net
zero by 2050.
Work continued in 2022 to mature NatWest Group’s climate-
related risk capabilities in accordance with the risk
management framework. In December 2022, the Board
approved the adoption of enhanced climate risk appetite
measures into the enterprise-wide risk management
framework, which are designed to provide a heightened focus
on balance sheet exposure to financed emissions.
Combined with segment-specific risk measures, this suite of
metrics will enable reporting of climate risk appetite to senior
risk management forums and links risk management to
NatWest Group’s strategic goals and priorities.
Monitoring and measurement
NatWest Group focused on developing the capabilities to use
scenario analysis to identify the most material climate risks and
opportunities for its customers, seeking to harness insights to
inform risk management practices and maximise the
opportunities arising from a transition to a low-carbon
economy.
Scenario analysis allows NatWest Group to test a range of
possible future climate pathways and understand the nature
and magnitude of the risks they present. The purpose of
scenario analysis is not to forecast the future but to understand
and prepare to manage risks that could arise.
Key priorities in 2022 have included enhancing our climate
scenario analysis capabilities to both address ongoing
regulatory expectations and building on the infrastructure
required by NatWest Group to meet current and future climate
scenario analysis objectives. NatWest Group made significant
investment in developing a variety of internal scenario analysis
tools which support the development of commercial strategy,
products and services and help manage risks, including
managing exposures efficiently and removing unmitigated risks
from future climate impacts.
NatWest Group recognises a number of key use cases for
climate scenario analysis, including, but not restricted to, the
following:
Regulatory stress testing requirements.
Heightened climate risk sector classifications.
Sector/sub-sector risk appetite.
Lending pricing.
Portfolio management.
Strategic decision-making.
NatWest Group made material progress in developing internal
climate modelling capabilities, building on the learnings from
our internal scenario analysis carried out in 2021 and
participation in the CBES. NatWest Group has enhanced its
scenario generation capabilities to support future integration of
climate risk into strategic planning, Internal Capital Adequacy
Assessment Processes (ICAAP) and IFRS 9. Modelling
infrastructure to execute scenarios matured in 2022, giving
increased flexibility for scenario analysis capability for short,
medium and long-term scenarios. Incorporation into the
NatWest Group strategic plan and ICAAP ensures that NatWest
Group factors climate into strategic planning and appropriately
capitalises for the most material source of climate risk over the
capital planning horizon. Developing internal methodologies
also enhances the capacity to integrate scenario analysis with
customer journeys. This builds on NatWest Group’s ability not
only to effectively develop tools for risk management but also
to develop products and processes that support NatWest
Group’s customers’ transition.
NatWest Group also focused on developing an internal
methodology for forecasting its counterparties’ corporate
transition risk via counterparty level modelling infrastructure
and climate risk customer scorecards. NatWest Group is
actively targeting the minimisation of reliance on third party
models, whilst recognising there is likely to be some reliance on
them over the medium-to-long term given the specialist and
evolving nature of climate financial risk management.
Enhancement of this infrastructure links very closely with the
scenario analysis noted above. Further information on this can
be found in NatWest Group’s 2022 Climate-related Disclosures
Report.
Internal scenario analysis carried out to support participation in
the CBES focused on the application of three climate scenarios
(early policy action, late policy action and no additional action
and a counterfactual scenario) to quantify climate risk across
NatWest Group’s lending portfolio. This showed that NatWest
Group was most exposed to a late transition scenario with a
concentrated period of losses between 2030 and 2035, the
point at which disruptive transition policy is implemented,
resulting in an economic recession. The early action scenario
resulted in more gradual losses through the stress horizon, with
the earlier onset of transition curtailing impairments in
comparison to the sharp onset in the late action scenario. A
key conclusion for transition risk is that supporting customers’
transition to net zero is critical to manage NatWest Group’s
exposures to transition risk.
The effects of physical risk were explored through the no
additional action scenario which produced lower total
cumulative impairments compared to the early action and late
action scenarios. This comparatively lower level of impairments
is reflective of NatWest Group’s diversified book and
geographic exposure. NatWest Group’s results broadly aligned
with the key findings and aggregate outcome for banks (across
both physical and transition risk).
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Climate risk continued
However, NatWest Group recognises the industry data and
methodology limitations for physical risk and therefore
recognises that the no additional action scenario does not
capture the severe long-term effects of irreversible climate
change. Further information on results, limitations and
conclusions can be found in NatWest Group’s 2022 Climate-
related Disclosures Report.
There are a number of challenges with climate scenario
analysis, for example in relation to climate data. NatWest
Group continues to participate in a number of industry forums
including the United Nations Principles for Responsible Banking,
which provides a unique framework for banks to align strategy
and practice with the Sustainable Development Goals and Paris
Climate Agreement. In addition, NatWest Group is also
represented on the Climate Financial Risk Forum established by
the PRA and FCA to shape the financial services industry’s
response to the challenges posed by climate risk and continues
to work with a number of UK and international bodies to
develop climate scenario analysis best practices.
NatWest Group is continuing to make progress in embedding
climate risk analytics as appropriate across customer journeys
and in supporting decision-making at customer and strategic
portfolio levels. Leveraging qualitative and quantitative outputs
from scenario analysis, will enable NatWest Group to integrate
outcomes into risk appetite measures and customer origination
processes. Developing the ability to incorporate these outcomes
enables NatWest Group to manage and mitigate both the risks
but also the opportunities that are presented by climate risk.
Operational risk
Definition
Operational risk is the risk of loss resulting from inadequate or
failed internal processes, people and systems, or external
events. It arises from day-to-day 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. This can take
the form of human error, an inability to deliver change
adequately or on time, the non-availability of technology
services, or the loss of customer data. Systems failure, theft of
NatWest Group property, information loss and the impact of
natural, or man-made, disasters – as well as the threat of
cyber-attacks – are sources of operational risk. Operational risk
can also arise from a failure to account for changes in law or
regulations or to take appropriate measures to protect assets.
Key developments in 2022
A review of the NatWest Group Risk Directory was
completed, allowing greater risk visibility and improved risk
reporting.
The NatWest Group Impact Classification Matrix was
updated to align to industry materiality, ensuring focus on
the most material risks.
An Early Event Escalation Process was implemented to
ensure material events are escalated in a timely manner.
A Risk & Control Self-Assessment approach was developed
to identify risks across end-to-end processes, refocusing
existing risk assessment, towards materiality.
A payments review has been initiated in late 2022 to assess
control enhancements in response to manual payment risk.
Governance
The governance arrangements in place for operational risk are
aligned to the requirements set out in the Board approved
enterprise-wide risk management framework and are
consistent with achieving safety, soundness and sustainable
risk outcomes.
Aligned to this, a strong operational risk management oversight
function is vital to support NatWest 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 effective 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. NatWest Group’s operational risk
appetite statement encompasses the full range of operational
risks faced by its legal entities, businesses and functions.
Mitigation
The Control Environment Certification (CEC) process is a half-
yearly self-assessment by the CEOs of NatWest Group’s
customer-facing business areas, as well as the heads of the
bank’s support functions. It provides a consistent and
comparable view on the adequacy and effectiveness of the
internal control environment.
CEC covers material risks and the underlying key controls,
including financial, operational and compliance controls, as well
as their supporting risk management frameworks. The CEC
outcomes, including forward-looking assessments for the next
two half-yearly cycles and progress on control environment
improvements, are reported to the Group Audit Committee 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-Oxley 404 requirements
concerning internal control over financial reporting and certain
requirements of the UK Corporate Governance Code.
Risks are mitigated by applying key preventative and detective
controls This is an integral step in the risk self-assessment
methodology which determines residual risk exposure. Control
owners are accountable for the design, execution, performance
and maintenance of key controls. Key controls are regularly
assessed for adequacy and tested for effectiveness. The results
are monitored and, where a material change in performance is
identified, the associated risk is re-evaluated.
Monitoring and measurement
Risk and control self-assessments are used across all business
areas and support functions to identify and assess material
operational risks, conduct risks and key controls. All risks and
controls are mapped to NatWest Group’s Risk Directory. Risk
assessments are refreshed at least annually to ensure they
remain relevant and that they capture any emerging risks and
also ensure that these risks are reassessed.
The process is designed to confirm that risks are effectively
managed in line with risk appetite. Controls are tested at the
appropriate frequency to verify that they remain fit-for-purpose
and operate effectively to reduce the identified risks.
NatWest Group uses the standardised approach to calculate its
Pillar 1 operational risk capital requirement. This is based on
multiplying three years’ average historical gross income by
coefficients set by the regulator based on business line.
Risk and capital management
continued
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Annual Report and Accounts 2022
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Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Operational risk continued
As part of the wider Internal Capital Adequacy Assessment
Process an operational risk economic capital model is used 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-looking scenario analysis to provide a risk-sensitive
view of NatWest Group’s Pillar 2A capital requirement.
Scenario analysis is used to assess how severe but plausible
operational risks will affect NatWest Group. It provides a
forward-looking basis for evaluating and managing operational
risk exposures.
Refer to the Capital, liquidity and funding risk section for the
operational risk capital requirement figures.
Operational resilience
NatWest Group manages and monitors operational resilience
through its risk and control self-assessment methodology. This
is underpinned by setting and monitoring of risk indicators and
performance metrics for the operational resilience of key
business services. Progress continued on embedding regulator
expectations for operational resilience, with involvement in a
number of industry-wide operational resilience forums. This
enables a cross-sector view of the operational resilience risk
profile and the pace of ongoing innovation and change, both
internally and externally.
NatWest Group operates layered security controls and its
network architecture is designed to provide inherent protection
against threats.
This approach avoids reliance on any one type
or method of security control.
Minimum security control
requirements are set out in Key Risk policies, standards,
processes and procedures.
Through 2023 NatWest Group will
monitor and manage the threat landscape focusing on:
Attack Surface Vulnerabilities - such as the rising number of
zero-days and code vulnerabilities impacting organisations
Initial Access Brokers and Nation States – increasingly
sophisticated attacks from ransomware gangs and ongoing
challenges following Russia’s invasion of Ukraine which has
raised international tensions increasing the likelihood of
disruptive cyber-attacks.
As cyberattacks evolve and become more sophisticated,
NatWest Group continues to invest in additional capability
designed to defend against emerging threats.
Event and loss data management
The operational risk event and loss data management process
ensures NatWest Group captures and records operational risk
financial and non-financial events that meet defined criteria.
Loss data is used for regulatory and industry reporting and is
included in capital modelling when calculating economic capital
for operational risk. The most serious events are escalated in a
simple, standardised process to all senior management, by way
of a ‘Early Event Escalation Process’.
All financial impacts and recoveries associated with an
operational risk event are reported against the date they were
recorded in NatWest Group’s financial accounts. A single event
can result in multiple losses (or recoveries) that may take time
to crystallise. Losses and recoveries with a financial accounting
date in 2021 may relate to events that occurred, or were
identified in, prior years. NatWest Group purchases insurance
against specific losses and to comply with statutory or
contractual requirements.
Percentage and value of events
At 31 December 2022, events aligned to the clients, products
and business practices (CPBP) event category accounted for
76% of NatWest Group’s operational risk losses (compared to
80% in 2021). The decrease reflects lower conduct-related
provisions were recorded during 2022 compared to prior years.
Value of events
Volume of events (1)
£m
Proportion
Proportion
2022
2021
2022
2021
2022
2021
Fraud
34
71
17%
16%
90%
81%
Clients, products and business practices
153
366
76%
80%
2%
7%
Execution, delivery and process management
14
9
7%
2%
7%
8%
Employment practices and workplace safety
6
1%
1%
3%
Technology and infrastructure failures
1
3
1%
1%
Disasters and public safety
202
455
100%
100%
100%
100%
(1)
The calculation in the above table is based on the volume and value of events (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 management
continued
NatWest Group
Annual Report and Accounts 2022
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Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Model risk
Definition
Model risk is the risk of inaccurate financial assessments or
decisions made as a result of incorrect or misused model
outputs and reports
.
NatWest Group defines a model as a
quantitative method, system, or approach that applies
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 outputs
to support customer decisioning, measuring and assessing risk
exposures (including credit, market, and climate risk), as well
as calculating regulatory capital and liquidity requirements.
Model applications may give rise to different risks depending on
the business segment in which they are used. Model risk is
therefore assessed separately for each business segment in
addition to the overall assessment made for NatWest Group.
Key developments in 2022
NatWest Group’s model risk management practices
continued to evolve, driven through a dedicated Model
Management Programme. This delivered an enhanced
model management committee structure, a new model risk
governance team operating model and an improved model
inventory.
Aligned to the implementation of the enterprise-wide risk
management framework, new model risk management
procedures were approved to support the identification,
assessment and monitoring of model risk.
NatWest Group provided a comprehensive response to the
PRA’s Consultation Paper on Model Risk Management
(CP6/22). A self-assessment of the bank’s current Model
Risk Policy compared to the PRA’s draft Supervisory
Statement was completed and gaps identified. A
programme of work will be established in 2023 to continue
to evolve the bank’s model risk management framework in
line with regulatory expectations and industry best practice.
Governance
A governance framework is in place to ensure policies and
processes relating to models are appropriate and effective.
Two roles are key to this – model risk owners and model risk
officers. Model risk owners are responsible for model approval
and ongoing performance monitoring. Model risk officers, in the
second line, are responsible for oversight, including ensuring
that models are independently validated prior to use and on an
ongoing basis aligned to the model’s risk rating. Model risk
matters are escalated to senior management in several ways.
These include model risk oversight committees, as well as the
relevant business and function model management committees.
A new NatWest Group Model Risk Oversight Committee will
further enhance model risk governance by providing a direct
escalation route to the NatWest Group Executive Risk
Committee and, where applicable, onwards to the NatWest
Group Board Risk Committee.
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 course of its
business activities. The model risk appetite statement and
measures are approved by the board on BRC’s
recommendation. Business areas are responsible for monitoring
performance against appetite and remediating models outside
appetite.
Monitoring and measurement
Policies and procedures related to the development, validation,
approval, implementation, use and ongoing monitoring of
models are in place to ensure adequate control across the
lifecycle of an individual model.
Validation of material models is conducted by an independent
risk function comprising of skilled, well-informed subject matter
experts. This is completed for new models or amendments to
existing models and as part of an ongoing periodic programme
to assess model performance. The frequency of periodic
validation is aligned to the risk rating of the model. The
independent validation focuses on a variety of model features,
including modelling approach, the nature of the assumptions
used, the model’s predictive ability and complexity, the data
used in the model, its implementation and its compliance with
regulation.
The level of risk relating to an individual model is assessed
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 approach provides the
basis for model risk appetite measures and enables model risk
to be robustly monitored and managed across NatWest Group.
Ongoing performance monitoring is conducted by model
owners and overseen by the model validators to ensure
parameter estimates and model constructs remain fit for
purpose, model assumptions remain valid and that models are
being used consistently with their intended purpose. This allows
timely action to be taken to remediate poor model performance
and/or any control gaps or weaknesses.
If a model risk issue arises due to an operational control
weakness (and the residual risk meets the operational risk
thresholds, then an operational risk issue would be raised.
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 – due to changes in
market conditions, business assumptions or processes – and by
applying adjustments to model outputs (either quantitative or
based on expert opinion). Enhancements may also be made to
the process within which the model output is used in order to
further limit risk levels.
Reputational risk
Definition
Reputational risk is defined as the risk of damage to
stakeholder trust due to negative consequences arising from
internal actions or external events.
Sources of risk
Reputational risks can originate from internal actions and
external events. The three primary drivers of reputational risk
have been identified as: failure in internal execution; a conflict
between NatWest Group’s values and the public agenda; and
contagion (when NatWest Group’s reputation is damaged by
failures in the wider financial sector).
Risk and capital management
continued
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Annual Report and Accounts 2022
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Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Reputational risk continued
Key developments in 2022
A new reputational risk policy was implemented to manage
reputational risk at an organisational level.
The NatWest Group Reputational Risk Register was further
embedded into the organisation, the results of which are
reported to the NatWest Group Reputational Risk
Committee.
All Environmental, Social & Ethical (ESE) risk acceptance
criteria underwent a review to align with Our Purpose.
Governance
A reputational risk policy supports reputational risk
management across NatWest Group. Reputational risk
committees review relevant issues at an individual business or
entity level, while the NatWest Group Reputational Risk
Committee opines on issues, cases, sectors and themes that
represent material reputational risks. The NatWest Group
Board Risk Committee oversees the identification and reporting
of reputational risk.
Risk appetite
NatWest Group manages and articulates its appetite for
reputational risk through a qualitative reputational risk appetite
statement and associated quantitative measures. NatWest
Group seeks to identify, measure and manage risk aligned to
stakeholder trust. However, reputational risk is inherent in
NatWest Group’s operating environment and public trust is a
specific factor in setting reputational risk appetite.
Monitoring and measurement
Relevant internal and external factors are monitored through
regular reporting to the reputational risk committees at
business or entity level and escalated, where appropriate, to
the NatWest Group Reputational Risk Committee or the
NatWest Group Board Risk Committee.
Mitigation
Standards of conduct are in place across NatWest Group
requiring strict adherence to policies, procedures and ways of
working to ensure business is transacted in a way that meets –
or exceeds – stakeholder expectations.
External events that could cause reputational damage are
identified and mitigated through NatWest Group’s Top and
Emerging Threats process (where sufficiently material) as well
as through the NatWest Group and business segment-level risk
registers.
NatWest Group has in recent years 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 Litigation
and regulatory matters section of Note 26 to the consolidated
financial statements for details of material matters currently
affecting NatWest Group.
Financial
statements
In this section
286
Independent auditor’s report
299
Consolidated income statement
300
Consolidated statement of
comprehensive income
301
Consolidated balance sheet
302
Consolidated statement of changes in equity
304
Consolidated cash flow statement
306
Accounting policies
314
Notes on the consolidated accounts
314
Net interest income
315
Non-interest income
316
Operating expenses
319
Segmental analysis
323 Pensions
329
Auditor’s remuneration
329 Tax
333
Discontinued operations and assets and liabilities
of disposal groups
334
Earnings per share
334
Financial instruments - classification
339
Financial instruments - valuation
348
Financial instruments - maturity analysis
350
Trading assets and liabilities
351 Derivatives
356
Loan impairment provisions
357
Other financial assets
358
Intangible assets
359
Other assets
359
Other financial liabilities
360
Subordinated liabilities
361
Other liabilities
362
Share capital and other equity
364
Structured entities
365
Asset transfers
366
Capital resources
367
Memorandum items
372
Analysis of the net investment in business interests
and intangible assets
373
Analysis of changes in financing during the year
373
Analysis of cash and cash equivalents
374
Directors’ and key management remuneration
374
Transactions with directors and key management
375
Related parties
376
Post balance sheet events
377
NatWest Group plc financial statements
and notes
NatWest Group
| 2022 Annual Report and Accounts
284
285
NatWest Group
| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Independent auditors’ report to the members of
NatWest Group plc
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Strategic report
Governance
Risk and capital management
Additional information
Financial review
In our opinion:
the financial statements of NatWest Group plc (the ‘Parent Company’) and its subsidiaries (together, the ‘Group’) give a true
and fair view of the state of the Group’s and of the Parent Company’s affairs as at 31 December 2022 and of the Group’s profit
for the year then ended;
the Group financial statements have been properly prepared in accordance with UK adopted international accounting standards
and IFRS as issued by the International Accounting Standards Board (‘IASB’);
the Parent Company financial statements have been properly prepared in accordance with UK adopted international
accounting standards as applied in accordance with section 408 of the Companies Act 2006 and IFRS as issued by the IASB;
and
the financial statements have been prepared in accordance with the requirements of the Companies Act 2006.
We have audited the financial statements (see table below) of the Parent Company and the Group for the year ended 31 December
2022 which comprise:
Group
Consolidated balance sheet as at 31 December 2022;
Consolidated income statement for the year then ended;
Consolidated statement of comprehensive income for the
year then ended;
Consolidated statement of changes in equity for the year
then ended;
Consolidated cash flow statement for the year then
ended;
Accounting policies;
Related Notes 1 to 33 to the financial statements;
Annual Remuneration Report identified as ‘audited’; and
Risk and capital management section identified as
‘audited’; and
The Capital Requirements (Country-by-Country
Reporting) Regulations report identified as ‘audited’
Parent Company
Balance sheet as at 31 December 2022;
Statement of changes in equity for the year then ended;
Cash flow statement for the year then ended; and
Related notes 1 to 12 to the financial statements
including a summary of critical accounting policies
The financial reporting framework that has been applied in their preparation is applicable law and UK adopted international
accounting standards, IFRS as issued by the IASB, and as regards the Parent Company financial statements, as applied in
accordance with section 408 of the Companies Act 2006.
Basis for opinion
We conducted our audit in accordance with International Standards on Auditing (UK) (ISAs (UK)) and applicable law. Our
responsibilities under those standards are further described in the Auditor’s responsibilities for the audit of the financial statements
section of our report. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our
opinion.
Independence
We are independent of the Group and Parent Company in accordance with the ethical requirements that are relevant to our audit
of the financial statements in the UK, including the FRC’s Ethical Standard as applied to listed public interest entities, and we have
fulfilled our other ethical responsibilities in accordance with these requirements.
The non-audit services prohibited by the FRC’s Ethical Standard were not provided to the Group or the Parent Company and we
remain independent of the Group and the Parent Company in conducting the audit.
Conclusions relating to going concern
In auditing the financial statements, we have concluded that the directors’ use of the going concern basis of accounting in the
preparation of the financial statements is appropriate. Our evaluation of the directors’ assessment of the Group and Parent
Company’s ability to continue to adopt the going concern basis of accounting included:
In conjunction with our walkthrough of the Group’s financial close process, we confirmed our understanding of management’s
Going Concern assessment process and also engaged with management early to ensure all key factors were considered in their
assessment;
We evaluated management’s going concern assessment which included reviewing their evaluation of long-term business and
strategic plans, capital adequacy, liquidity and funding positions. It also assessed these positions considering internal stress tests
which included consideration of principal and emerging risks. The Group’s risk profile and risk management practices were
considered including credit risk, market risk, compliance and conduct risk, climate risk and operational risk;
We evaluated management’s assessment by considering the Group’s ability to continue in operation and meets its liabilities
under different scenarios including the impact of the Group’s strategic plans, and the current uncertain geopolitical and
economic outlook. We used economic specialists in assessing the macroeconomic assumptions in the forecast through
benchmarking to institutional forecasts, HMT consensus and peer comparative economic forecasts. We also considered other
commitments of the Group including those in respect of its subsidiaries;
Considered the results of the Bank’s stress testing and Bank of England 2022 solvency stress test; and
We reviewed the Group’s going concern disclosures included in the annual report in order to assess that the disclosures were
appropriate and in conformity with the reporting standards.
Independent auditors’ report to the members of NatWest Group plc
continued
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Additional information
Financial review
Based on the work we have performed, we have not identified any material uncertainties relating to events or conditions that,
individually or collectively, may cast significant doubt on the Group and Parent Company’s ability to continue as a going concern
over the twelve months from the date when the financial statements are authorised for issue.
In relation to the group and parent company’s reporting on how they have applied the UK Corporate Governance Code, we have
nothing material to add or draw attention to in relation to the directors’ statement in the financial statements about whether the
directors considered it appropriate to adopt the going concern basis of accounting.
Our responsibilities and the responsibilities of the directors with respect to going concern are described in the relevant sections of
this report. However, because not all future events or conditions can be predicted, this statement is not a guarantee as to the
Group’s ability to continue as a going concern.
An overview of the scope of the Parent Company and Group audits
Tailoring the scope
Our assessment of audit risk, our evaluation of materiality and our allocation of performance materiality determine our audit scope
for each company within the Group. Taken together, this enables us to form an opinion on the consolidated financial statements.
We take into account the size and risk profile of the component and its activities, the organisation of the Group and effectiveness of
group-wide controls, changes in the business environment and other factors such as recent internal audit results when assessing
the level of work to be performed at each component.
In assessing the risk of material misstatement to the Group financial statements, and to ensure we had adequate quantitative
coverage of significant accounts in the financial statements, of the four reporting components of the Group, we selected four
components based on size and risk, which represent the principal reporting legal entities within the Group.
The scoping for the current year is as follows:
Component
Scope
Key locations
NatWest Holdings (NWH)
Full
United Kingdom
NatWest Markets (NWM)
Full
United Kingdom, United States, and
Netherlands
RBS International
Specific
Channel Islands
RBS AA Holdings
Specific
United Kingdom
The table below illustrates the coverage obtained from the work performed by our audit teams. We considered total assets, total
equity and total income to verify we had appropriate overall coverage.
Full scope
(1)
Specific scope
(2)
Other procedures
(3)
Total
Total assets
94%
6%
0%
100%
Total equity
92%
8%
0%
100%
Total income
95%
4%
1%
100%
(1)
Full scope: audit procedures on all significant accounts.
(2)
Specific scope: audit procedures on selected accounts.
(3)
Other procedures: considered in analytical procedures.
The audit scope of the specific scope components may not have included testing of all significant accounts within the components.
However, the testing will have contributed to the total coverage of significant accounts tested for the overall Group.
Involvement with component teams
In establishing our overall approach to the Group audit, we determined the type of work that needed to be undertaken at each of
the components by us, as the primary audit engagement team, or by component auditors from other EY global network firms
operating under our instruction.
The primary audit engagement team interacted regularly with the component audit teams where appropriate throughout the
course of the audit, which included holding planning meetings, maintaining regular communications on the status of the audits,
reviewing key working papers and taking responsibility for the scope and direction of the audit process. The primary audit team
continued to follow a programme of oversight visits that has been designed to ensure that the Senior Statutory Auditor, or another
Group audit partner, has ongoing interaction with all full scope and specific scope locations outside the United Kingdom. The
primary team interacted regularly with the component teams and maintained a continuous and open dialogue with component
teams, as well as holding formal closing meetings quarterly, to ensure that the primary team were fully aware of their progress
and results of their procedures. The primary team also reviewed key working papers and were responsible for the scope and
direction of the audit process. This, together with the additional procedures at Group level, gave us appropriate evidence for our
opinion on the Group financial statements
Climate change
Stakeholders are increasingly interested in how climate change will impact the Group. The Group has determined that the most
significant future impacts from climate change on its operations will be from credit risk, operational risk, reputational risk, conduct
risk and regulatory compliance risk. These are explained in the required Task Force for Climate related Financial Disclosures in the
Strategic Report, and in the Climate Risk section within the Risk and capital management section. The Group has also explained
their climate commitments in the Strategic Report. All of these disclosures form part of the “Other information”, rather than the
audited financial statements. Our procedures on these unaudited disclosures therefore consisted solely of considering whether they
are materially inconsistent with the financial statements or our knowledge obtained in the course of the audit or otherwise appear
to be materially misstated, in line with our responsibilities on “Other information”.
Independent auditors’ report to the members of NatWest Group plc
continued
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Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
The Group has explained in the Accounting Policy note how they have reflected the impact of climate change in their financial
statements, and the significant judgements and estimates relating to climate change. These disclosures also explain the uncertainty
regarding policy response, including the effect of wider geo-political uncertainty on governmental ambitions regarding climate
transition and the effect of decarbonisation on wider economic growth and customer behaviours. Many of the impacts arising will
be longer term in nature, with an inherent level of uncertainty, and have limited effect on accounting judgments and estimates for
the current period under the requirements of UK adopted international accounting standards and IFRS as issued by the IASB. The
Group has also explained within the Accounting Policies, their approach to quantifying the impact of
climate transition policy on
macroeconomic factors in the future years, and the limitations on the ability to make a reliable estimate for 2022 reporting.
Our audit effort in considering the impact of climate change on the financial statements was focused on evaluating the Group’s
assessment of the impact of climate risk, their climate commitments and the significant judgements and estimates disclosed in the
Accounting Policies, and whether these have been appropriately reflected in the asset values where these are impacted by future
cash flows, and in the timing and nature of liabilities recognised following the requirements of UK adopted international accounting
standards and IFRS as issued by the IASB. As part of this evaluation, we performed our own risk assessment, supported by our
climate change specialists, to determine the risk of material misstatement in the financial statements from climate change which
needed to be considered in our audit. We also evaluated the Directors’ considerations of climate change risks in their assessment
of going concern and viability and associated disclosures. Where considerations of climate change were relevant to our assessment
of going concern, these are described above.
Based on our work we have considered the impact of climate change on the financial statements to impact certain key audit
matters. Details of our procedures and findings are included in our explanation of key audit matters below.
Key audit matters
Key audit matters are those matters that, in our professional judgment, were of most significance in our audit of the financial
statements of the current period and include the most significant assessed risks of material misstatement (whether or not due to
fraud) that we identified. These matters included those which had the greatest effect on: the overall audit strategy, the allocation of
resources in the audit; and directing the efforts of the engagement team. These matters were addressed in the context of our audit
of the financial statements as a whole, and in our opinion thereon, and we do not provide a separate opinion on these matters.
Independent auditors’ report to the members of NatWest Group plc
continued
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Additional information
Financial review
Risk
Our response to the risk
Expected Credit Loss Provisions
At 31 December 2022 the Group reported total
gross loans – amortised cost and FVOCI of
£377.2 billion (2021: £369.8 billion) and £3.4
billion of expected credit losses (ECL) (2021: £3.8
billion).
Management’s judgments and estimates are
especially subjective due to significant
uncertainty associated with the assumptions
used. These include the current uncertain
geopolitical and economic outlook and the
impact of climate change which were both
considered in our risk assessment.
Aspects with
increased complexity in respect of the timing and
measurement of ECL include:
Staging -
Allocation of assets to stage 1, 2, or
3 on a timely basis using criteria in
accordance with IFRS 9;
Model estimations -
Accounting
interpretations, modelling assumptions and
data used to build and run the Probability of
Default (‘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
multiple economic scenarios particularly those
influenced by the current uncertain
geopolitical and economic outlook including
any changes to scenarios required through 31
December 2022;
Controls testing
- We evaluated the design and operating effectiveness of
controls across the processes relevant to ECL, including the judgments and
estimates noted. These controls, among others, included those over:
the allocation of assets into stages including management’s monitoring of
stage effectiveness;
model governance including monitoring and model validation;
data accuracy and completeness;
credit monitoring;
multiple economic scenarios;
the governance and review of post-model adjustments;
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, assumptions and adjustments
to the ECL were discussed and approved, among other procedures.
Overall assessment
- We performed an overall assessment of the ECL
provision levels by stage to determine if they were reasonable by considering
the overall credit quality of the Group’s portfolios, risk profile, impact of the
current uncertain geopolitical and economic outlook and climate change on
the Group’s customers. We performed peer benchmarking where available
to assess overall staging and provision coverage levels. We also performed
sensitivity analysis to assess the impact of changing assumptions on the ECL
provision.
Based on our assessment of the key judgments we used EY specialists to
support the audit team in the areas of economics, modelling and collateral
and business valuations.
Adjustments -
Appropriateness, completeness
and valuation of model adjustments which
represent approximately 12% of total ECL
including any adjustments due to the ongoing
geopolitical and economic uncertainty, and
the identification of vulnerable customers
which increases the risk of management
override; and
Individual provisions -
Measurement of
individual provisions including the assessment
of multiple scenarios considering the impact of
the current uncertain geopolitical and
economic outlook on exit strategies, collateral
valuations and time to collect.
Staging
- We evaluated the criteria used to allocate a financial asset to stage
1, 2 or 3 in accordance with IFRS 9; this included peer benchmarking 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 impact of performing collective staging downgrades to
industries and geographic regions particularly impacted by climate change.
To test credit monitoring which drives the probability of default estimates
used in the staging calculation, we recalculated the risk ratings for a sample
of performing loans and focused our testing on high risk industries, such as
commercial real estate and leisure. We also assessed the timing of the
annual review performed by management on each wholesale loan exposure
in our sample to evaluate whether it appropriately considered risk factors by
considering independent publicly available information.
Model estimations
- We performed a risk assessment on all models involved
in the ECL calculation to select a sample of models to test, which included
new models implemented in the year. 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 assessing model design
and formulae, alternative modelling techniques, recalculating the PD, LGD
and EAD, and model implementation. We also considered the results of the
Group’s internal model validation results. We performed an assessment of
the extent to which model methodologies developed using historic
experience were able to respond to the current economic conditions,
including Consumer Price Index and Bank of England base rates. Where we
identified model limitations, we tested the extent to which these effects have
been appropriately captured in Post Model Adjustments.
To evaluate data quality, we agreed a sample of ECL calculation data points
to source systems, including balance sheet date data used to run the models
and historic loss data to monitor models. We also tested the ECL data points
from the calculation engine through to the general ledger and disclosures.
Independent auditors’ report to the members of NatWest Group plc
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Strategic report
Governance
Risk and capital management
Additional information
Financial review
Risk
Our response to the risk
Expected Credit Loss Provisions (continued)
Economic scenarios
- We involved EY economic specialists to assist us in
evaluating the base case and alternative economic scenarios, including
evaluating probability weights and considering contrary evidence by
comparing these to other scenarios from a variety of external sources. This
assessment included the latest developments related to the current uncertain
geopolitical and economic outlook at 31 December 2022.
We assessed
whether forecasted macroeconomic variables, such as GDP, unemployment
rate, Consumer Price Index, Bank of England base rates and the House Price
Index were complete and appropriate. With the support of our modelling
specialists we evaluated the correlation and translation of the
macroeconomic factors to the ECL.
Post Model Adjustments (PMAs)
- We evaluated and tested the
appropriateness, adequacy and completeness of PMAs held at year end,
including those applied in response to the current geopolitical and economic
outlook and the impact of certain economic factors. This included
challenging the identification of retail customers vulnerable to price and rate
increases and the identification of commercial sub-sectors more susceptible
to inflation and supply chain issues as well as the method by which those
PMAs were measured. We have also challenged those PMAs which
continued to be applied as a result of COVID-19 related to recovery periods
and the associated debt issued to borrowers that obtained government
supported loans during Covid-19. With our modelling specialists, we assessed
the risk of bias and the completeness of these adjustments by considering
the data, judgments, methodology, sensitivities, and governance of these
adjustments as well as considering model shortcomings.
Individual provisions
- We recalculated and challenged the scenarios,
assumptions and cash flows for a sample of individual provisions including
the alternative scenarios and evaluating probability weights assigned,
involving EY valuation specialists where appropriate.
The sample was based
on a number of factors, including higher risk sectors identified with reference
to external sources, such as commercial real estate, agriculture, oil and gas,
mining, retail and leisure, and materiality. We considered the impact of the
current geopolitical and economic outlook and climate change had on
collateral valuations and time to collect as well as whether planned exit
strategies remained viable.
Disclosure
- We tested the data flows used 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 for the impairment of loans were reasonable and recognised in accordance with IFRS 9. We
highlighted the following matters to the Group Audit Committee:
Overall provision levels were reasonable which also considered available peer information and our understanding of the credit
environment;
Control deficiencies were identified in the processes used to calculate the ECL for which compensating controls were identified
to mitigate a risk of material misstatement;
Our testing of models and model assumptions identified some instances of over and under estimation. We aggregated these
differences and were satisfied that the overall estimate recorded was reasonable;
The post-model adjustments recorded were within a reasonable range to reflect risk in the portfolios;
We recalculated the staging of retail and wholesale exposures in material portfolios and noted no material differences. We also
performed sensitivity analysis on the staging criteria and noted that substantial changes would be needed to the criteria to
result in a material difference;
and
For individually assessed impairments, in a few instances we identified judgmental differences in respect of the extent of the
impairment identified, however, none of these differences, individually or in aggregate, were considered material.
Relevant references in the Annual Report and Accounts
Report of the Group Audit Committee
Credit Risk section of the Risk and capital management section
Accounting policies
Note 15 to the financial statements
Independent auditors’ report to the members of NatWest Group plc
continued
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Governance
Risk and capital management
Additional information
Financial review
Risk
Our response to the risk
Provisions for customer redress, litigation and other regulatory matters.
At 31 December 2022, the Group has reported
£1.1 billion (2021 - £1.3 billion) of provisions for
liabilities and charges, including £0.7 billion (2021
- £0.8 billion) for customer redress, litigation and
other regulatory matters as detailed in Note 21
of the financial statements.
Regulatory scrutiny and the continued litigious
environment give rise to a high level of
management judgment in determining
appropriate provisions and disclosures for
specific customer redress, litigation and other
regulatory matters. Management judgment is
needed to determine whether a present
obligation exists and a provision should be
recorded at 31 December 2022 in accordance
with the accounting criteria set out under IAS 37.
The most significant areas of judgment are:
Judgment and risk of management
bias
- Auditing the adequacy of
these provisions is complex because
judgment is involved in the selection
and use of assumptions in the
estimation of specific customer
redress, litigation and other
regulatory matters. There is also a
risk of management bias in the
determination of whether an outflow
in respect of identified material
customer redress, litigation and
other regulatory matters is probable
and can be estimated reliably; and
Disclosure
- Judgment is required to assess
the adequacy of disclosures of provisions and
contingent liabilities given the underlying
estimation uncertainty in the provisions, and
other uncertainties and assumptions.
Controls testing
: We evaluated the design and operating effectiveness of
controls over the identification, estimation, monitoring and disclosure of
provisions and other uncertainties and assumptions related to customer
redress, litigation and other regulatory matters considering the potential for
management override of controls. The controls tested, among others,
included those to identify and monitor claims, determine when a provision is
required and to ensure the completeness and accuracy of data used to
estimate provisions.
Examination of regulatory correspondence
: We examined the relevant
regulatory and legal correspondence to assess developments in certain
cases.
We also considered regulatory developments to identify actual or
possible non-compliance with laws and regulations that might have a
material effect on the financial statements.
For cases which were settled
during the period, we compared the actual outflows with the provision that
had been recorded, considered whether further risk existed, and evaluated
the level of disclosures provided.
Inquiry of legal counsel
: For significant legal matters, we received
confirmations from the Group’s external legal counsel to evaluate the
likelihood of the obligation and management’s estimate of the outflow at
year-end. We also conducted inquiries with internal legal counsel over the
existence of the legal obligations and related provision. We performed a test
for unrecorded provisions to assess if there were cases not considered in the
provision estimate by assessing against external legal confirmations and
discussing with internal counsel.
Testing of assumptions
: Where appropriate, we involved our conduct risk
and forensics specialists to assist us in evaluating the provision for specific
customer redress, litigation and other regulatory matters. We tested the
underlying data and assumptions used in the determination of the provisions
recorded, including expected claim rates, legal costs, and the timing of
settlement. We evaluated the accuracy of management’s historical estimates
by comparing the actual settlement to the provision and considered peer
bank settlement in similar cases. We assessed the reasonableness of the
assumptions used by management by comparing to the results of our
independently performed benchmarking and sensitivity analysis. We also
developed our own range of reasonable alternative estimates and compared
them to management’s provision. We tested utilisations of remaining
provisions during the year and assessed the sufficiency of the remaining
provisions yet to be paid for specific customer redress, litigation and other
regulatory matters.
Disclosure
: We evaluated the disclosures provided on customer redress,
litigation and other regulatory matters to assess whether they complied with
accounting standards.
Key observations communicated to the Group Audit Committee
We are satisfied that provisions for customer redress, litigation and other regulatory matters are reasonable and recognised in
accordance with IFRS. We concurred with the recognition, measurement and level of disclosures of provisions and contingent
liabilities relating to customer redress, litigation and other regulatory matters. We did not identify any material unrecorded
provisions. We highlighted the following matters to the Group Audit Committee:
The level of provisions by their nature incorporates significant judgments to be made and may change as a result of future
developments; and
Continued vigilance in assessing conduct risks from the impact of cost of living crisis and Consumer Duty Act, which may not
manifest until after the current economic conditions take effect or implementation deadline, respectively.
Relevant references in the Annual Report and Accounts
Report of the Group Audit Committee
Accounting policies
Note 21 and 26 to the financial statements
Independent auditors’ report to the members of NatWest Group plc
continued
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Governance
Risk and capital management
Additional information
Financial review
Risk
Our response to the risk
Valuation of financial instruments with higher risk characteristics including related income from trading activities
As reported in Note 11 to the financial
statements, as at 31 December 2022 the Group
held financial instruments with higher risk
characteristics. This included (but is not limited
to) reported level 3 assets of £2.3 billion (2021 -
£2.0 billion) and level 3 liabilities of £1.0 billion
(2021 - £0.6 billion) whose value is dependent
upon unobservable inputs.
The valuation of those financial instruments 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 behaviour and interest rate and
foreign exchange options with exotic features;
Illiquid inputs
- Pricing inputs and calibrations
for illiquid instruments, including fair value
loan exposures for which there is no active
market. Additionally, derivative instruments
whose valuation is dependent on discount
rates associated with complex collateral
arrangements;
Fair value adjustments
- The appropriateness
and completeness of fair value adjustments
made to derivatives valuations including
Funding Valuation Adjustments (FVA), Credit
Valuation Adjustments (CVA), relating to
derivative counterparties whose credit spread
may not be observable and material product
and deal specific adjustments on long dated
derivative portfolios; and
The manipulation of revenue recognition is
most likely to arise through the inappropriate
valuation of these instruments given the level
of judgment involved.
Controls testing
: We evaluated the design and operating effectiveness of
controls relating to financial instrument valuation and related income
statement measurement including independent price verification, valuation
models governance, collateral management, income statement analysis,
and the associated controls over relevant information technology systems.
We also observed the Valuation Committees where valuation inputs,
assumptions and adjustments were discussed and approved.
We involved our financial instrument valuation and modelling specialists to
assist us in performing procedures including the following:
Complex models
: Testing complex model-dependent valuations by
performing independent revaluation to assess the appropriateness of
models and the adequacy of assumptions and inputs used by the Group;
Illiquid inputs
: Independently re-pricing instruments that had been valued
using illiquid pricing inputs, using alternative pricing sources where
available, to evaluate management’s valuation;
Fair value adjustments
: Comparing fair value adjustment methodologies
to current market practice and assessing the appropriateness and
adequacy of the valuation adjustment framework in light of emerging
market practice and changes in the risk profile of the underlying
portfolio; and revaluing a sample of counterparty level FVA and CVA,
comparing funding spreads to third party data, independently
challenging illiquid CVA inputs, and testing material product and deal
specific adjustments on the long-dated derivatives portfolio.
Throughout our audit procedures we considered the current uncertain
geopolitical and economic outlook, including market volatility and the
impact of climate change on the valuation of financial instruments,
particularly in relation to long-dated illiquid positions.
In addition, we assessed whether there were any indicators of aggregate
bias in financial instrument marking and methodology assumptions.
We performed back-testing analysis of recent trade activity and asset
disposals to evaluate the drivers of significant differences between book
value and trade value and to assess the impact on the fair value of similar
instruments within the portfolio. We performed an analysis of significant
collateral discrepancies with counterparties to assess the potential impact
on the fair value of the underlying (and similar) financial instruments.
Key observations communicated to the Group Audit Committee
We are satisfied that the assumptions used by management to reflect the fair value of financial instruments with higher risk
characteristics and the recognition of related income is reasonable and in accordance with IFRS. We highlighted the following
matters to the Group Audit Committee:
Complex model-dependent valuations were appropriate based on the output of our independent revaluations, 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 financial instruments appropriately reflected pricing information available at
31 December 2022; and
Valuation adjustments applied to derivative portfolios for credit, funding and other risks were recorded in accordance
with the requirements of IFRS considering trade activity for positions with common risk characteristics, analysis of
market data and peer benchmarking.
Relevant references in the Annual Report and Accounts
Report of the Group Audit Committee
Accounting policies
Note 11 to the financial statements
Independent auditors’ report to the members of NatWest Group plc
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Governance
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Additional information
Financial review
Risk
Our response to the risk
Recognition of deferred tax assets, impairment of goodwill and, in the Parent Company’s accounts, investments in group
undertakings.
At 31 December 2022, the Group had reported
goodwill of £5.5 billion (2021: £5.5 billion) and
deferred tax assets of £2.0 billion (2021: £0.8
billion). The parent company has reported
investments in group undertakings of £52.8
billion (2021: £48.8 billion).
The recognition and carrying value of goodwill,
deferred tax and, in the Parent Company’s
accounts, investments in group undertakings are
based on estimates of future profitability, which
require significant management judgment and
include the risk of management bias. The
recognition of deferred tax also considers the
future profit forecasts of the legal entities as well
as interpretation of recent changes to tax rates
and laws.
The judgments and assumptions used are
especially complex and subjective due to their
forward-looking nature and inherent
uncertainties. These include:
Revenue forecasts
which are inherently
challenging due to the current uncertain
geopolitical and economic outlook including
the impacts of climate change which are
driven by delivery of the Group’s Strategy;
Cost forecasts
given the strategic ambitions of
the bank and potential headwinds from
inflation and supply chain issues;
Macroeconomic and model assumptions
used
in the forecasting and valuation assessments
(discount rates, growth rates, macroeconomic
assumptions) including the current uncertain
geopolitical and economic outlook and the
impact of climate change 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 testing performed.
Controls testing
: We evaluated the design and operating effectiveness of
controls over the preparation and review of the forecasts, and the
significant assumptions (such as discount rate and long-term growth rate)
inputs, calculations, methodologies and judgments used in the value-in-use
model. This included testing controls over the selection of macroeconomic
assumptions in addition to controls over the preparation and review of the
revenue and cost projections. In evaluating the governance processes we
reviewed the Board meeting materials and minutes where forecasts were
discussed and approved, and we observed the committee meetings where
the value-in-use model and outcomes were discussed and approved.
Macroeconomic and model assumptions
: With the support of our internal
economic specialists, we tested whether macroeconomic assumptions used
in the Group’s forecasts were reasonable by comparing these to other
scenarios from a variety of external sources.
We evaluated how the
discount rates and long-term growth rates used by management compared
to our ranges which were developed using peer practice, external market
data and calculations performed by our valuation specialists. We also
assessed changes to valuation methodology and benchmarked this against
industry practice with the assistance of our valuation specialists.
Revenue forecasts
: We evaluated the underlying business strategies,
comparing to expected market trends and considering anticipated balance
sheet growth. We obtained an understanding of the Group’s strategy
including their consideration of the impact of climate change and
considered its expected impact on the forecasts
and
the extent to which
decisions had been factored
into
the forecasts,
where appropriate,
in
accordance with the relevant accounting standards.
We
also
inspected the
findings from the review
performed by management including their own
sensitivity analysis of the forecasts.
Cost forecasts
: We tested how previous management forecasts, including
the impact of cost reduction programmes, compared to actual results to
evaluate the accuracy of the forecasting process. We also tested the
reasonableness of key performance indicators against peers with the help
of our valuation specialists to assess the reasonableness of the Group’s cost
forecast.
Deferred Tax Model:
With the support of our taxation specialists, we
reviewed the deferred tax model including an assessment of the time
horizon used for the recoverability of losses and other temporary
differences.
Sensitivity analysis
: We evaluated how management considered alternative
assumptions and performed our own sensitivity and scenario analyses on
certain assumptions such as cost and revenue forecasts, discount rate,
long-term growth rate and other key performance indicators on both the
detailed forecasts and on an overall basis.
Disclosure
: We evaluated the adequacy of disclosures in the financial
statements including the appropriateness of assumptions and sensitivities
disclosed. We tested the data and calculations included in the disclosures.
Independent auditors’ report to the members of NatWest Group plc
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Additional information
Financial review
Risk
Our response to the risk
Recognition of deferred tax assets, impairment of goodwill and, in the Parent Company’s accounts, investments in group
undertakings.
Key observations communicated to the Group Audit Committee
We are satisfied that management methodologies, judgments and assumptions supporting the carrying value of goodwill,
deferred tax assets and, in the Parent Company’s accounts, investments in group undertakings, were reasonable and in
accordance with IFRS.
We are also satisfied with management’s conclusion that goodwill is not a critical accounting policy, as
disclosed in note 1 of the financial statements, and that there is no plausible scenario in which this would change in the 12
months from the reporting date.
We highlighted the following matters to the Group Audit Committee:
There is inherent uncertainty in predicting revenue and costs over the five-year forecast period, particularly with
respect to the impact of the current macro-economic environment on the ability of the bank to achieve strategic
objectives, the impact of regulatory and climate change developments, and the impact of competition and disruption in
banking business models over an extended period;
Control deficiencies were identified in the determination of the value in use for which compensating controls were
identified to mitigate the risk of material misstatement;
We are satisfied with management’s conclusion that goodwill remains recoverable in the Retail, Commercial and RBSI
CGUs as at 31 December 2022;
We are satisfied that management has exercised appropriate judgment in assessing the extent to which it is probable
that there will be future taxable profits to recover deferred tax assets; and
Management impaired NatWest Group’s investment in NWM, in addition they recognised a reversal in accumulated
impairments in NWH due to the significant headroom as a result of the improved economic outlook. The sensitivity
analyses we reviewed, and our independent procedures supported these assessments.
Relevant references in the Annual Report and Accounts
Accounting policies
Note 7 and Note 17 to the Group financial statements and Note 9 to the Parent Company financial statements
Risk
Our response to the risk
Pension valuation and net pension asset
The Group operates a number of defined
benefit schemes which in aggregate are
significant in the context of the overall
balance sheet. At 31 December 2022, the
Group reported a net pension asset of £220
million (2021 - £488 million) comprising £318
million of schemes in surplus and £98 million
of schemes in deficit (2021 - £602 million and
£114 million respectively). The net pension
asset is sensitive to changes in the key
judgments and estimates, including the
effects of current uncertain geopolitical and
economic outlook, including market volatility,
which include:
Assumptions
-
Actuarial
assumptions and inputs including
discount rate, inflation, pension
payment and longevity to
determine the valuation of
retirement benefit liabilities;
Valuations
-
Pricing inputs and
calibrations for illiquid or complex
model-dependent valuations of
certain investments held by the
schemes; and
Funding
– the pension schemes
have adequate liquidity to cover for
any shortfall in derivative asset
prices as a result of current
economic conditions.
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 assumptions 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 specialists to evaluate the actuarial
assumptions by comparing them to independently obtained third party sources
and market practice. We assessed the impact on pension liabilities due to
changes in financial, demographic and longevity assumptions over the year, and
whether these were supported by objective external evidence and rationales,
including the effects of current uncertain geopolitical and economic outlook,
including market volatility.
Valuations
- We tested the fair value of scheme assets by independently
calculating fair value for a sample of the assets held. Our sample included cash,
equity and debt instruments, derivative financial instruments and illiquid assets.
We involved our valuation specialists to assess the appropriateness of
management’s valuation methodology including the judgments made in
determining significant assumptions used in the valuation of complex and illiquid
pension assets, including the effects of current uncertain geopolitical and
economic outlook, including market volatility. We independently re-priced illiquid
and complex assets that had been valued using unobservable market inputs,
using alternative pricing sources where available, to evaluate management’s
valuations.
Funding – in the performance of our procedures we consider whether the
pension schemes have adequate funding to cover for any shortfall in derivative
asset prices.
Augmentation cap and equalisation adjustments
- We involved our actuarial
specialists to test the estimation of the augmentation cap including the inputs
used in the calculation. We also assessed the methodology and judgments made
in calculating these estimates and the associated accounting treatment in
accordance with IAS 19 and IFRIC 14.
Disclosure
-
We assessed the adequacy of the disclosures made in the financial
statements, including the appropriateness of the assumptions, sensitivities and
disclosures over investment strategy and risk management..
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Additional information
Financial review
Key observations communicated to the Group Audit Committee
We are satisfied that the valuation and disclosure of the net pension balance are reasonable and in accordance with IFRS. We
highlighted the following matters to the Group Audit Committee:
Our benchmarking of key actuarial assumptions including the discount rate, inflation, longevity and pension payments
concluded that assumptions were within a reasonable range;
No material differences were identified through our independent valuation testing for a sample of pension assets; and
Management’s estimate of the impact of the augmentation cap was materially consistent with our independent
estimate using our own model.]
Relevant references in the Annual Report and Accounts
Accounting policies
Note 5 to the financial statements
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 changes are made in an
appropriate manner. This risk is also
impacted by the greater dependency on third
parties, increasing use of cloud platforms,
decommissioning of legacy systems, and
migration to new systems.
Such controls
contribute to mitigating the risk of potential
fraud or errors as a result of changes to
applications and data.
The Group has implemented user access
management controls across IT applications,
databases and operating systems. We have
identified user access-related deficiencies in
the past and whilst the number of deficiencies
has reduced year over 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 that are relevant to financial
reporting.
Controls testing
We tested user access by assessing the controls in place for in-scope
applications, in particular testing the addition and periodic recertification of
users’ access. We continue to focus on key controls enforced by the Group’s
user access management tools, including the completeness of user data,
automated identification of movers and leavers and the adequacy of the overall
control environment.
During the current audit period, the Identity and Access Management tool used
in NatWest Markets was decommissioned and replaced with the Group’s
strategic tool. We tested the governance process around the migration and
onboarding of users to the Identity and Access Management tool and noted no
deficiencies, with the suite of access management controls supported by the
two tools remaining consistent throughout the year.
A number of systems are outsourced to third party service providers. For these
systems, we tested IT general controls through evaluating the relevant Service
Organisation Controls (“SOC”) reports (where available). This included
assessing the timing of the reporting, the controls tested 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 risks to financial reporting. Several systems have been
migrated to a cloud-hosted infrastructure model, however access management
processes and controls remained in-house and they formed part of our testing.
Where control deficiencies were identified, we tested remediation activities
performed by management and compensating controls in place and assessed
what additional testing procedures were necessary to mitigate any residual risk.
We also performed a further analysis of access management deficiencies
identified by EY, Management and Internal 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 effectively. The following matters were
reported to the Group Audit Committee:
We have seen an overall reduction in the number of discrete IT control deficiencies identified compared to prior year.
Improvements were made to further standardise access management processes and controls across the Group, which was
one of the drivers for the reduced number of deficiencies; and
Particular attention should continue to be paid to controls over user access management including ensuring the completeness
and accuracy of the data used to perform access controls. Where issues were noted in relation to access management, these
were remediated by year end or mitigated by compensating controls. We performed additional testing in response to
deficiencies identified, where required;
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Additional information
Financial review
Our application of materiality
We apply the concept of materiality in planning and performing the audit, in evaluating the effect of identified misstatements on the
audit and in forming our audit opinion.
Materiality
The magnitude of an omission or misstatement that, individually or in the aggregate, could reasonably be expected to influence the
economic decisions of the users of the financial statements. Materiality provides a basis for determining the nature and extent of
our audit procedures.
We determined materiality for the Group to be £208 million (2021: £157 million), which is 5% (2021: 5%) of the profit before tax of
the Group of £5,132 million (2021: £4,032million) adjusted for non-recurring conduct and litigation costs. We believe removing these
non-recurring charges reflects the most useful measure for users of the financial statements and is consistent with the prior
year.
The 5% basis used for Group materiality is consistent with the wider industry, and is the standard for listed and regulated
entities.
We determined materiality for the Parent Company to be £208 million (2021 - £157 million) which is 0.4% (2021 - 0.3%) of equity of
the Parent Company. We believe this reflects the most useful measure for users of the financial statements as the Parent
Company’s primary purpose is to act as a holding company with investments in the Group’s subsidiaries, not to generate operating
profits and therefore a profit based measure is not relevant.
Performance materiality
The application of materiality at the individual account or balance level.
It is set at an amount to reduce to an appropriately low
level the probability that the aggregate of uncorrected and undetected misstatements exceeds materiality.
On the basis of our risk assessments, together with our assessment of the Group’s overall control environment, our judgment was
that performance materiality was 75% (2021: 75%) of our planning materiality, namely £156 million (2021: £118 million). We have
based the percentage of performance materiality on a number of considerations, including the number and amount of identified
misstatements, the effectiveness of the control environment and other factors affecting the entity and its financial reporting. Audit
work at component teams for the purpose of obtaining audit coverage over significant financial statement accounts is undertaken
based on a percentage of total performance materiality. The performance materiality set for each component is based on the
relative scale and risk of the component to the Group as a whole and our assessment of the risk of misstatement at that
component.
In the current year, the range of performance materiality allocated to components was £47 million to £136 million
(2021: £35 million to £106 million).
Reporting threshold
An amount below which identified misstatements are considered as being clearly trivial.
We agreed with the Audit Committee that we would report to them all uncorrected audit differences in excess of £10 million (2021
- £8 million), which is set at 5% of planning materiality, as well as differences below that threshold that, in our view, warranted
reporting on qualitative grounds.
We evaluate any uncorrected misstatements against both the quantitative measures of materiality discussed above and in light of
other relevant qualitative considerations in forming our opinion.
Other information
The other information comprises the information included 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 Committee, Report of the Group Sustainable Banking Committee, Report of the
Technology and Innovation Committee, Report of the directors,
Risk and capital management, Non-IFRS financial measures, Risk
factors, Material contracts, and Additional information, other than the financial statements and our auditor’s report thereon. The
directors are responsible for the other information contained within the annual report.
Our opinion on the financial statements does not cover the other information and, except to the extent otherwise explicitly stated
in this report, we do not express any form of assurance conclusion thereon.
Our responsibility is to read the other information and, in doing so, consider whether the other information is materially
inconsistent with the financial statements or our knowledge obtained in the course of the audit, or otherwise appears to be
materially misstated. If we identify such material inconsistencies or apparent material misstatements, we are required to determine
whether this gives rise to a material misstatement in the financial statements themselves. If, based on the work we have
performed, we conclude that there is a material misstatement of the other information, we are required to report that fact.
We have nothing to report in this regard.
Independent auditors’ report to the members of NatWest Group plc
continued
NatWest Group
Annual Report and Accounts 2022
297
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Opinions on other matters prescribed by the Companies Act 2006
In our opinion, based on the work undertaken in the course of the audit:
the information given in the Strategic report and the Report of the directors for the financial year for which the financial
statements are prepared is consistent with the financial statements and those reports have been prepared in accordance with
applicable legal requirements;
the information about internal control and risk management systems in relation to financial reporting processes and about
share capital structures, given in compliance with rules 7.2.5 and 7.2.6 in the Disclosure Rules and Transparency Rules
sourcebook made by the Financial Conduct Authority (the FCA Rules), is consistent with the financial statements and has been
prepared in accordance with applicable legal requirements; and
information about the Group’s corporate governance statement and practices and about its administrative, management and
supervisory bodies and their committees complies with rules 7.2.2, 7.2.3 and 7.2.7 of the FCA Rules.
Matters on which we are required to report by exception
In the light of the knowledge and understanding of the Group and the Parent Company and its environment obtained in the course
of the audit, we have not identified material misstatements in the;
Strategic report or the Report of the directors; or
the information about internal control and risk management systems in relation to financial reporting processes and about
share capital structures, given in compliance with rules 7.2.5 and 7.2.6 of the FCA Rules.
We have nothing to report in respect of the following matters in relation to which the Companies Act 2006 requires us to report to
you if, in our opinion:
adequate accounting records have not been kept by the Parent Company, or returns adequate for our audit have not been
received from branches not visited by us; or
the Parent Company financial statements and the part of the Directors’ Remuneration Report to be audited are not in
agreement with the accounting records and returns; or
certain disclosures of directors’ remuneration specified by law are not made; or
we have not received all the information and explanations we require for our audit, or
a Corporate Governance Statement has not been prepared by the Group
Corporate Governance Statement
We have reviewed the directors’ statement in relation to going concern, longer-term viability and that part of the Corporate
Governance Statement relating to the group and company’s compliance with the provisions of the UK Corporate Governance Code
specified for our review by the Listing Rules.
Based on the work undertaken as part of our audit, we have concluded that each of the following elements of the Corporate
Governance Statement is materially consistent with the financial statements or our knowledge obtained during the audit:
Directors’ statement with regards to the appropriateness of adopting the going concern basis of accounting and any material
uncertainties identified;
Directors’ explanation as to its assessment of the company’s prospects, the period this assessment covers and why the period
is appropriate;
Directors’ statement on fair, balanced and understandable;
Director’s statement on whether it has a reasonable expectation that the group will be able to continue in operation and meets
its liabilities;
Board’s confirmation that it has carried out a robust assessment of the emerging and principal risks;
The section of the annual report that describes the review of effectiveness of risk management and internal control systems;
and;
The section describing the work of the audit committee.
Responsibilities of directors
As explained more fully in the Statement of directors’ responsibilities, the directors are responsible for the preparation of the
financial statements and for being satisfied that they give a true and fair view, and for such internal control as the directors
determine is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to
fraud or error.
In preparing the financial statements, the directors are responsible for assessing the Group and Parent Company’s ability to
continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of
accounting unless the directors either intend to liquidate the Group or the Parent Company or to cease operations, or have no
realistic alternative but to do so.
Auditor’s responsibilities for the audit of the financial statements
Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material
misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a
high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material
misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the
aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial
statements.
Independent auditors’ report to the members of NatWest Group plc
continued
NatWest Group
Annual Report and Accounts 2022
298
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Explanation as to what extent the audit was considered capable of detecting irregularities, including fraud
Irregularities, including fraud, are instances of non-compliance with laws and regulations. We design procedures in line with our
responsibilities, outlined below, to detect irregularities, including fraud.
The risk of not detecting a material misstatement due to
fraud is higher than the risk of not detecting one resulting from error, as fraud may involve deliberate concealment by, for
example, forgery or intentional misrepresentations, or through collusion. The extent to which our procedures are capable of
detecting irregularities, including fraud is detailed below.
However, the primary responsibility for the prevention and detection of fraud rests with both those charged with governance of the
company and management.
We obtained an understanding of the legal and regulatory frameworks that are applicable to the Group and determined that
the most significant are the regulations, licence conditions and supervisory requirements of the Prudential Regulation Authority
(PRA) and the Financial Conduct Authority (FCA); Companies Act 2006; and the Sarbanes Oxley Act (SOX).
We understood how the Group is complying with those frameworks by making inquiries of management, internal audit and
those responsible for legal and compliance matters. We also reviewed correspondence between the Group and regulatory
bodies; reviewed minutes of the Board and Risk Committees; and gained an understanding of the Group’s governance
framework.
Conducted a review of correspondence with and reports from the regulators, including the Prudential Regulation Authority
(‘PRA’) and Financial Conduct Authority (‘FCA’).
Carried out an assessment of matters reported on the group’s whistleblowing programmes where these related to the financial
statements.
We assessed the susceptibility of the Group’s financial statements to material misstatement, including how fraud might occur by
considering the controls established to address risks identified to prevent or detect fraud. We also identified the risks of fraud in
our key audit matters as described above and identified areas that we considered when performing our fraud procedures, such
as cybersecurity, segregation of duties testing, user access testing and the appropriateness of sources used when performing
confirmation testing on accounts such as cash, loans and securities. Our procedures over our key audit matters and other
significant accounting estimates included challenging management on the assumptions and judgements made in determining
these estimates.
We designed our audit procedures to identify non-compliance with
laws and regulations. Our procedures involved inquiries of
legal counsel, executive management, and internal audit. We also tested controls and performed procedures to respond to the
fraud risks as identified in our key audit matters. These procedures were performed by both the primary team and component
teams with oversight from the primary team.
Identified and tested journal entries, including those posted with certain descriptions or unusual characteristics, backdated
journals or posted by infrequent and unexpected users.
The Group operates in the banking industry which is a highly regulated environment. As such, the Senior Statutory Auditor
considered the experience and expertise of the engagement team to ensure that the team had the appropriate competence
and capabilities, involving specialists where appropriate.
A further description of our responsibilities for the audit of the financial statements is located on the Financial Reporting
Council’s website at https://www.frc.org.uk/auditorsresponsibilities. This description forms part of our auditor’s report.
Other matters we are required to address
Following the recommendation from the Group Audit Committee, we were appointed by the Group at its annual general
meeting on 4 May 2016 to audit the financial statements for the year ending 31 December 2016 and subsequent financial
periods.
The period of total uninterrupted engagement including previous renewals and reappointments is 7 years, covering periods
from our appointment through 31 December 2022.
The audit opinion is consistent with the additional report to the Group Audit Committee.
Use of our report
This report is made solely to the company’s members, as a body, in accordance with Chapter 3 of Part 16 of the Companies Act
2006.
Our audit work has been undertaken so that we might state to the company’s members those matters we are required to
state to them in an auditor’s report and for no other purpose. To the fullest extent permitted by law, we do not accept or assume
responsibility to anyone other than the company and the company’s members as a body, for our audit work, for this report, or for
the opinions we have formed.
Micha Missakian (Senior statutory auditor)
for and on behalf of Ernst & Young LLP, Statutory Auditor
London, United Kingdom
16 February 2023
Consolidated income statement
for the year ended 31 December 2022
NatWest Group
Annual Report and Accounts 2022
299
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
2022
2021 (1)
2020 (1)
Note
£m
£m
£m
Interest receivable
12,637
9,234
9,711
Interest payable
(2,795)
(1,699)
(2,322)
Net interest income
1
9,842
7,535
7,389
Fees and commissions receivable
2,915
2,694
2,704
Fees and commissions payable
(623)
(574)
(722)
Trading income
1,133
323
1,125
Other operating income
(111)
451
(93)
Non-interest income
2
3,314
2,894
3,014
Total income
13,156
10,429
10,403
Staff costs
(3,716)
(3,676)
(3,878)
Premises and equipment
(1,112)
(1,133)
(1,222)
Other administrative expenses
(2,026)
(2,026)
(1,845)
Depreciation and amortisation
(833)
(923)
(913)
Operating expenses
3
(7,687)
(7,758)
(7,858)
Profit before impairment losses/releases
5,469
2,671
2,545
Impairment (losses)/releases
15
(337)
1,173
(3,098)
Operating profit/(loss) before tax
5,132
3,844
(553)
Tax charge
7
(1,275)
(996)
(74)
Profit/(loss) from continuing operations
3,857
2,848
(627)
(Loss)/profit from discontinued operations, net of tax
(3)
8
(262)
464
193
Profit/(loss) for the year
3,595
3,312
(434)
Attributable to:
Ordinary shareholders
3,340
2,950
(753)
Preference shareholders
19
26
Paid-in equity holders
249
299
355
Non-controlling interests
6
44
(62)
3,595
3,312
(434)
Earnings per ordinary share - continuing operations
9
36.5p
23.0p
(8.4p)
Earnings per ordinary share - discontinued operations
9
(2.7p)
4.3p
1.7p
Total earnings per share attributable to ordinary shareholders - basic
9
33.8p
27.3p
(6.7p)
Earnings per ordinary share - fully diluted continuing operations
9
36.2p
22.9p
(8.4p)
Earnings per ordinary share - fully diluted discontinued operations
9
(2.6p)
4.3p
1.7p
Total earnings per share attributable to ordinary shareholders - fully diluted
9
33.6p
27.2p
(6.7p)
(1)
Comparative results have been re-presented from those previously published to reclassify certain items as discontinued operations as described in Note 8 to the consolidated
financial statements.
(2)
At the General Meeting and Class Meeting on 25 August 2022, the shareholders approved the proposed special dividend and share consolidation. On 30 August the issued ordinary
share capital was consolidated in the ratio of 14 existing shares for 13 new shares. The average number of shares and earnings per share have been adjusted retrospectively.
(3)
The results of discontinued operations, comprising the 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 314 to 376, the Accounting policies on pages 306 to 313 and the audited sections of the
Financial review and Risk and capital management sections on pages 72 to 83 and 176 to 283 form an integral part of these
financial statements.
Consolidated statement of
comprehensive income
for the year ended 31 December 2022
NatWest Group
Annual Report and Accounts 2022
300
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
2022
2021
2020
£m
£m
£m
Profit/(loss) for the year
3,595
3,312
(434)
Items that do not qualify for reclassification
Remeasurement of retirement benefit schemes
(1)
(840)
(669)
4
Changes in fair value of credit in financial liabilities designated at FVTPL
50
(29)
(52)
FVOCI financial assets
59
13
(64)
Tax
187
164
42
(544)
(521)
(70)
Items that do qualify for reclassification
FVOCI financial assets
(457)
(100)
44
Cash flow hedges
(2)
(3,277)
(848)
271
Currency translation
241
(382)
276
Tax
1,067
213
(89)
(2,426)
(1,117)
502
Other comprehensive (loss)/income after tax
(2,970)
(1,638)
432
Total comprehensive income/(loss) for the year
625
1,674
(2)
Attributable to:
Ordinary shareholders
370
1,308
(338)
Preference shareholders
19
26
Paid-in equity holders
249
299
355
Non-controlling interests
6
48
(45)
625
1,674
(2)
(1)
Following the purchase of ordinary shares from UKGI in Q1 2022, 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. Other material movements came from asset underperformance
relative to movements in the schemes’ liabilities over the year. In line with our policy, the present value of defined benefit 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.
(2)
The unrealised losses on cash flow hedge reserves is mainly driven by deferment of losses on GBP net received fixed swaps as interest rates have increased.
The accompanying notes on pages 314 to 376, the Accounting policies on pages 306 to 313 and the audited sections of the
Financial review and Risk and capital management sections on pages 72 to 83 and 176 to 283 form an integral part of these
financial statements.
Consolidated balance sheet
as at 31 December 2022
NatWest Group
Annual Report and Accounts 2022
301
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
2022
2021
Note
£m
£m
Assets
Cash and balances at central banks
10
144,832
177,757
Trading assets
13
45,577
59,158
Derivatives
14
99,545
106,139
Settlement balances
2,572
2,141
Loans to banks - amortised cost
10
7,139
7,682
Loans to customers - amortised cost
10
366,340
358,990
Securities subject to repurchase agreements
2,901
11,746
Other financial assets excluding securities subject to repurchase agreements
27,994
34,399
Other financial assets
16
30,895
46,145
Intangible assets
17
7,116
6,723
Other assets
18
9,176
8,242
Assets of disposal groups
8
6,861
9,015
Total assets
720,053
781,992
Liabilities
Bank deposits
10
20,441
26,279
Customer deposits
10
450,318
479,810
Settlement balances
2,012
2,068
Trading liabilities
13
52,808
64,598
Derivatives
14
94,047
100,835
Other financial liabilities
19
49,107
49,326
Subordinated liabilities
20
6,260
8,429
Notes in circulation
3,218
3,047
Other liabilities
21
5,346
5,797
Total liabilities
683,557
740,189
Ordinary shareholders' interests
32,598
37,412
Other owners' interests
3,890
4,384
Owners' equity
22
36,488
41,796
Non-controlling interests
8
7
Total equity
36,496
41,803
Total liabilities and equity
720,053
781,992
The accompanying notes on pages 314 to 376, the Accounting policies on pages 306 to 313 and the audited sections of the
Financial review and Risk and capital management sections on pages 72 to 83 and 176 to 283 form an integral part of these
financial statements.
The accounts were approved by the Board of directors on 16 February 2023 and signed on its behalf by:
Howard Davies
Alison Rose-Slade DBE
Katie Murray
NatWest Group plc
Chairman
Group Chief Executive Officer
Group Chief Financial Officer
Registered No. SC45551
Consolidated statement of
changes in equity
for the year ended 31 December 2022
NatWest Group
Annual Report and Accounts 2022
302
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
2022
2021
2020
£m
£m
£m
Called-up share capital - at 1 January
11,468
12,129
12,094
Ordinary shares issued
37
35
Share cancellation
(1,2)
(929)
(698)
At 31 December
10,539
11,468
12,129
Paid-in equity - at 1 January
3,890
4,999
4,058
Reclassified
(3)
(2,046)
(1,277)
Issued
937
2,218
At 31 December
3,890
3,890
4,999
Share premium - at 1 January
1,161
1,111
1,094
Ordinary shares issued
50
17
At 31 December
1,161
1,161
1,111
Merger reserve - at 1 January and 31 December
10,881
10,881
10,881
FVOCI reserve
- at 1 January
269
360
138
Unrealised (losses)/gains
(6)
(570)
32
76
Realised losses/(gains)
(4)
59
(122)
152
Tax
140
(1)
(6)
At 31 December
(102)
269
360
Cash flow hedging reserve - at 1 January
(395)
229
35
Amount recognised in equity
(7)
(2,973)
(687)
321
Amount transferred from equity to earnings
(304)
(161)
(50)
Tax
901
224
(77)
At 31 December
(2,771)
(395)
229
Foreign exchange reserve - at 1 January
1,205
1,608
1,343
Retranslation of net assets
512
(484)
297
Foreign currency (losses)/gains on hedges of net assets
(266)
88
(55)
Tax
32
(17)
6
Recycled to profit or loss on disposal of businesses
(5)
10
17
At 31 December
1,478
1,205
1,608
Capital redemption reserve - at 1 January
722
Share cancellation
(1,2)
929
698
Redemption of preference shares
24
At 31 December
1,651
722
Retained earnings - at 1 January
12,966
12,567
13,946
Profit/(loss) attributable to ordinary shareholders and other equity owners
- continuing operations
3,851
2,804
(565)
- discontinued operations
(262)
464
193
Equity preference dividends paid
(19)
(26)
Paid-in equity dividends paid
(249)
(299)
(355)
Ordinary dividends paid
(1,205)
(693)
Special dividends paid
(1,746)
Shares repurchased
(1,2)
(2,054)
(1,423)
Unclaimed dividends
2
Redemption of preference shares
(8)
(750)
(24)
Redemption/reclassification of paid-in equity
(3)
- gross
134
(358)
- tax
(36)
16
3
Realised gains/(losses) on FVOCI equity shares
- gross
113
3
(248)
- tax
(9)
Remeasurement of retirement benefit schemes
- gross
(5)
(840)
(669)
4
- tax
(5)
192
168
22
Changes in fair value of credit in financial liabilities designated at FVTPL
- gross
50
(29)
(52)
- tax
(2)
3
8
For the notes to this table refer to the following page.
Consolidated statement of changes in equity for the year ended 31 December 2022
continued
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Annual Report and Accounts 2022
303
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Strategic report
Governance
Risk and capital management
Additional information
Financial review
2022
2021
2020
£m
£m
£m
Employee share schemes
6
8
(11)
Share-based payments
- gross
(7)
(55)
5
- tax
1
10
(1)
At 31 December
10,019
12,966
12,567
Own shares held - at 1 January
(371)
(24)
(42)
Shares vested under employee share schemes
113
36
95
Own shares acquired
(1)
(383)
(77)
At 31 December
(258)
(371)
(24)
Owners’ equity at 31 December
36,488
41,796
43,860
Non-controlling interests - at 1 January
7
(36)
9
Currency translation adjustments and other movements
4
17
Profit/(loss) attributable to non-controlling interests
6
44
(62)
Dividends paid
(5)
(5)
At 31 December
8
7
(36)
Total equity at 31 December
36,496
41,803
43,824
Attributable to:
Ordinary shareholders
32,598
37,412
38,367
Preference shareholders
494
494
Paid-in equity holders
3,890
3,890
4,999
Non-controlling interests
8
7
(36)
36,496
41,803
43,824
(1)
In March 2022, there was an agreement with HM Treasury to buy 549.9 million (March 2021 - 591 million) ordinary shares in NatWest Group plc from UK Government Investments
Ltd, at 220.5 pence per share (March 2021 - 190.5 pence per share) for the total consideration of £1.22 billion (March 2021 - £1.13 billion). NatWest Group cancelled all 549.9 million
of the purchased ordinary shares (March 2021 - NatWest Group cancelled 391 million of the purchased ordinary shares and held the remaining 200 million in own shares held). The
nominal value of the share cancellation has been transferred to the capital redemption reserve.
(2)
NatWest Group plc repurchased and cancelled 379.3 million (2021 - 310.8 million) shares for total consideration of £829.3 million (2022 £676.2 million) excluding fees as part of the
On Market Share Buyback Programme which has now concluded. The nominal value of the share cancellations has been transferred to the capital redemption reserve.
(3)
In July 2021, paid-in equity was reclassified to liabilities as the result of a call in August 2021 of US$2.65 billion AT1 capital notes.
(4)
In 2020, the completion of the Alawwal bank merger resulted in the derecognition of the associate investment in Alawwal bank and recognition of a new investment in SABB held at
fair value through other comprehensive income (FVOCI).
(5)
Following the purchase of ordinary shares from UKGI in Q1 2022, 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. Other material movements came from asset underperformance
relative to movements in the schemes’ liabilities over the year. In line with our policy, the present value of defined benefit 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.
(6)
Certain assets within this category have been hedged with derivatives which are not in an accounting hedge relationship. The effect of this creates a temporary difference between
other comprehensive income and the income statement due to the difference in recognition criteria. This temporary difference is expected to reverse through the income statement
over the duration of the hedge.
(7)
The unrealised losses on cash flow hedge reserves is mainly driven by deferment of losses on GBP net received fixed swaps as interest rates have increased.
(8)
Following an announcement of a Regulatory Call in February 2022, the Series U preference shares were reclassified to liabilities. A £254 million loss was recognised in retained
earnings as a result of FX unlocking.
The accompanying notes on pages 314 to 376, the Accounting policies on pages 306 to 313 and the audited sections of the
Financial review and Risk and capital management sections on pages 72 to 83 and 176 to 283 form an integral part of these
financial statements.
Consolidated cash flow
statement
for the year ended 31 December 2022
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2022
2021
2020
Note
£m
£m
£m
Cash flows from operating activities
Operating profit/(loss) before tax from continuing operations
(1)
5,132
3,844
(553)
Operating (loss)/profit before tax from discontinued operations
(1)
(262)
467
202
Adjustments for:
Impairment losses/(releases)
266
(1,335)
3,242
Amortisation of discounts and premiums of other financial assets
6
203
267
Depreciation and amortisation
833
923
914
Change in fair value taken to profit or loss of other financial assets
1,267
1,771
(1,474)
Change in fair value taken to profit or loss on other financial liabilities and subordinated
(2,400)
(1,083)
962
liabilities
Elimination of foreign exchange differences
10
2,446
(2,497)
Other non-cash items
(261)
(164)
(2)
Income receivable on other financial assets
(591)
(581)
(518)
Loss/(profit) on sale of other financial assets
172
(118)
(96)
(Profit)/loss on disposal of subsidiaries and associates
(48)
16
Share of loss/(profit) of associates
30
(216)
30
Loss/(profit) on sale of other assets and net assets/liabilities
154
23
(16)
Interest payable on MRELs and subordinated liabilities
1,103
964
1,182
Loss on redemption of own debt
161
145
324
Charges and releases on provisions
248
478
296
Defined benefit pension schemes
205
215
215
Net cash flows from trading activities
6,073
7,934
2,494
Decrease in trading assets
14,991
7,751
4,147
Decrease/(increase) in derivative assets
3,621
59,697
(16,173)
(Increase)/decrease in settlement balance assets
(431)
156
2,090
Increase in loans to banks
(202)
(252)
(554)
(Increase)/decrease in loans to customers
(7,628)
2,721
(33,748)
(Increase)/decrease in other financial assets
(328)
(128)
221
(Increase)/decrease in other assets
(255)
(57)
8
Increase in assets of disposal groups
(4,117)
(9,015)
(Decrease)/increase in bank deposits
(5,838)
5,673
113
(Decrease)/increase in customer deposits
(29,492)
48,071
62,492
Decrease in settlement balance liabilities
(56)
(350)
(1,652)
Decrease in trading liabilities
(11,790)
(7,658)
(1,693)
(Decrease)/increase in derivative liabilities
(6,788)
(59,870)
13,826
Increase/(decrease) in other financial liabilities
989
938
(1,085)
Increase in notes in circulation
171
392
546
Decrease in other liabilities
(1,294)
(1,463)
(1,723)
Changes in operating assets and liabilities
(48,447)
46,606
26,815
Income taxes paid
(1,223)
(856)
(214)
Net cash flows from operating activities
(2,3)
(43,597)
53,684
29,095
For the notes to this table refer to the following page.
Consolidated cash flow statement for the year ended 31 December 2022
continued
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2022
2021
2020
Note
£m
£m
£m
Cash flows from investing activities
Sale and maturity of other financial assets
36,975
16,859
25,952
Purchase of other financial assets
(23,510)
(10,150)
(18,825)
Income received on other financial assets
659
581
518
Net movement in business interests and intangible assets
27
5,420
(3,489)
(70)
Sale of property, plant and equipment
154
165
348
Purchase of property, plant and equipment
(639)
(901)
(376)
Net cash flows from investing activities
19,059
3,065
7,547
Cash flows from financing activities
Movement in MRELs
(1,974)
2,736
636
Movement in subordinated liabilities
(3,419)
(3,452)
(2,381)
Share repurchased
(2,054)
(1,806)
(2)
Dividends paid
(3,205)
(1,016)
(381)
Issue of paid-in equity
937
2,218
Net cash flows from financing activities
28
(10,652)
(2,601)
90
Effects of exchange rate changes on cash and cash equivalents
2,933
(2,641)
1,879
Net (decrease)/increase in cash and cash equivalents
(32,257)
51,507
38,611
Cash and cash equivalents at 1 January
190,706
139,199
100,588
Cash and cash equivalents at 31 December
29
158,449
190,706
139,199
(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 £12,638 million (2021 - £9,696 million, 2020 - £10,007 million) and interest paid of £2,357 million (2021 - £1,668 million, 2020 - £2,414 million).
(3)
The total cash outflow for leases is £170 million (2021: £195 million; 2020: £220 million), including payment of principal amount of £145 million (2021: £164 million; 2020: £179 million)
which are included in the operating activities.
The accompanying notes on pages 314 to 376, the Accounting policies on pages 306 to 313 and the audited sections of the
Financial review and Risk and capital management sections on pages 72 to 83 and 176 to 283 form an integral part of these
financial statements.
Accounting policies
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This section includes the basis of preparation, critical and significant accounting policies used to prepare the financial statements.
Our accounting policies are the specific principles, bases, conventions, rules, and practices we apply in preparing and presenting
the financial statements. Further information is provided where judgment and estimation is applied to critical accounting policies
and key sources of estimation uncertainty.
Future accounting developments details new, or amendments to existing, accounting standards, when they are effective from and
where we are assessing their impact on future financial statements.
1. Presentation of financial statements
NatWest Group plc is incorporated in the UK and registered in
Scotland. The financial statements are presented in the
functional currency, pounds sterling.
The audited financial statements include audited sections of the
Risk and capital management section. The directors have
prepared the financial statements on a going concern basis
after assessing the principal risks, forecasts, projections and
other relevant evidence over the twelve months from the date
the financial statements are approved (see the Report of the
directors) and in accordance with UK adopted International
Accounting Standards (IAS), and International Financial
Reporting Standards (IFRS) as issued by the International
Accounting Standards Board (IASB). The critical and significant
accounting policies and related judgments are set out below.
The financial statements are presented on a historical cost basis
except for certain financial instruments which are stated at fair
value.
The effect of the amendments to IFRS effective from 1 January
2022 on our financial statements was immaterial.
Our consolidated financial statements incorporate the results of
NatWest Group plc and the entities it controls. Control arises
when we have 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 through voting rights. The consolidated financial
statements are prepared under consistent accounting policies.
On acquisition of a subsidiary, the identifiable assets, liabilities
and contingent liabilities are included in the consolidated
financial statements at their fair value. A subsidiary is included
in the consolidated financial statements from the date it is
controlled by us until the date we cease to control it through a
sale or a significant change in circumstances. Changes in our
interest in a subsidiary that does not result in us ceasing to
control that subsidiary are accounted for as equity transactions.
We apply accounting for associates and joint arrangements
(including joint ventures) to entities where we have significant
influence, but not control, over the operating and financial
policies.
We assess significant influence by reference to a
presumption of voting rights of more than 20%, but less than
50%, supplemented by a qualitative assessment of substantive
rights which include representation at the Board of Directors,
significant exchange of managerial personnel or technology
amongst others. Joint ventures are arrangements where we
have joint control and rights to the net assets of the entity.
Investments in associates and joint ventures are recorded upon
initial recognition at cost, increased or decreased each period
by the share of the subsequent levels of profit or loss, and other
changes in equity are considered in line with their nature.
Transactions and balances between Group companies are
eliminated in the consolidated financial statements to show only
those transactions and balances external to us.
The judgments and assumptions involved in our 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 or models that differ
from those adopted by us would affect our reported results.
How Climate risk affects our accounting judgments and
estimates
Business planning
Key financial estimates are based on management's latest five-
year revenue and cost forecasts. The outputs from this forecast
affect forward-looking accounting estimates. Measurement of
deferred tax and expected credit losses are highly sensitive to
reasonably possible changes in those anticipated conditions. In
2022, our scenario planning supported the development of
NatWest Group’s initial iteration climate transition plan,
including the assessment of climate-related risks and
opportunities.
The initial iteration of our Climate transition plan includes
an assessment of:
changes in business operations, products and
services to support customer decarbonisation;
financial plans linked to business operations and
strategy. During 2022, the financial planning
process has been enhanced to incorporate climate
related opportunities included in the climate
transition plan. In 2023, we will link specific
actions that are needed to align to our climate
ambitions into the financial forecasts.
development in UK Government policies, aligned
with the Committee on Climate Change Sixth
carbon Budget published in 2021. We also assume
certain broader policy responses and
technological innovation to enable the wider
transition of the economy.
There remains considerable uncertainty regarding this
policy response, including the effect of wider geo-political
uncertainty on governmental ambitions regarding climate
transition and the effect of decarbonisation on wider
economic growth, technology development and customer
behaviours.
Information used in other accounting estimates
We make use of reasonable and supportable information to
make accounting judgments and estimates. This includes
information about the observable effects of the physical and
transition risks of climate change on the current
creditworthiness of borrowers, asset values and market
indicators. It also includes the effect on our competitiveness and
profitability. Many of the effects arising from climate change will
be longer term in nature, with an inherent level of uncertainty,
and have limited effect on accounting judgments and estimates
for the current period. Some physical and transition risks can
manifest in the shorter term. The following items represent the
most significant effects:
Accounting policies
continued
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The classification of financial instruments linked to climate,
or other sustainability indicators: consideration is given to
whether the effect of climate related terms prevent the
instrument cashflows being solely payments of principal
and interest.
The measurement of expected credit loss considers the
ability of borrowers to make payments as they fall due.
Future cashflows are discounted, so long dated cashflows
are less likely to affect current expectations on credit loss.
Our assessment of sector specific risks, and whether
additional adjustments are required, include expectations of
the ability of those sectors to meet their financing needs in
the market. Changes in credit stewardship and credit risk
appetite that stem from climate considerations, such as oil
and gas, will directly affect our positions.
The use of market indicators as inputs to fair value is
assumed to include current information and knowledge
regarding the effect of climate risk.
Effect of climate change in the estimation of expected credit
loss
Since the implementation of IFRS 9 in January 2018 loan losses
reflect expected credit losses taking account of relevant and
reliable forward looking information. We are evaluating the
effect of the physical and transition consequences of climate
change on our experience of loan loss. We use available
information regarding the effect of climate transition policy
largely driven by carbon prices as an adjustment to
macroeconomic factors that are used as inputs to the models
that generate PD and LGD outcomes, which are key inputs to
the ECL calculation. The determination of whether specific loss
drivers and climate events generate specific losses is ongoing
and is necessary to determine how sensitive changes in ECL
could be to climate inputs. As at 31 December 2022, our
quantification of the impact due to physical risk and how other
climate risks may impact the ECL is ongoing.
An impact assessment on how climate risk factors may require
adjustment in our IFRS 9 model suite has also not been finalised.
We judged that this information was not sufficiently complete to
make a reliable estimate and given the immaterial change in
ECL it indicated, determined it was not appropriate to adjust
ECL.
When this information is reliable, possibly during 2023, it could
be used in our ECL calculation. A key part of this is determining
that any adjustment resulting from the inclusion of new climate-
related inputs does not double count or omit credit losses arising
from other inputs. We will continue to develop our data, models
and methodologies relating to climate evaluation and market
practice will continue to evolve and this will affect the estimation
of climate effect in ECL on an ongoing basis. We expect that the
effect of climate risks on ECL will increase as government
policy, organisations and individuals react to changes in climate
as well as the probable increased occurrence of climate-related
loss events (such as flooding and wildfire).
2. Critical accounting policies
The judgments and assumptions involved in our accounting
policies that are considered by the Board to be the most
important to the portrayal of our financial condition are noted
below. The use of estimates, assumptions or models that differ
from those adopted by us would affect our reported results.
Management’s consideration of uncertainty is outlined in the
relevant sections of this document, including the ECL estimate in
the Risk and capital management section.
Information used for significant estimate
Key financial estimates are based on management's latest five-
year revenue and cost forecasts. Changes in judgments and
assumptions could result in a material adjustment to those
estimates in future reporting periods. Consideration of this
source of estimate uncertainty has been set out in the notes
below (as applicable).
Policy
Judgment
Estimate
Further
information
Deferred tax
Determination of whether sufficient taxable
profits will be generated in future years to
recover DTA.
Our estimates are based on the five-year
revenue and cost forecasts (which include
inherent uncertainties).
Note 7
Fair value –
financial
instruments
Classification of a fair value instrument as level
3, where the valuation is driven by
unobservable inputs.
Estimation of the fair value, where it is
reasonably possible to have alternative
assumptions in determining the FV.
Note 11
Loan
impairment
provisions
Definition of default against which to apply PD,
LGD and EAD models.
Criteria for a significant increase in credit risk.
Identification of risks not captured by the
models.
ECL estimates contain a number of
measurement uncertainties (such as the
selection of multiple economic scenarios) and
disclosures include sensitivities to show impact
on other reasonably possible scenarios.
Note 15
Provisions
for liabilities
and charges
Determination of whether a present obligation
exists in respect of customer redress, litigation
and other regulatory, property and other
provisions.
Legal proceedings often require a high degree
of judgment and these are likely to change as
the matter progresses.
Provisions remain sensitive to the assumptions
used in the estimate. We consider a wide range
of possible outcomes. It is often not practical to
meaningfully quantify ranges of possible
outcomes, given the uncertainties involved.
Note 21
Accounting policies
continued
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2.1. Deferred tax
Deferred tax is the tax expected to be payable or recoverable
in respect of temporary differences between the carrying
amount of an asset or liability for accounting purposes and the
carrying amount for tax purposes. Deferred tax liabilities are
generally recognised for all taxable temporary differences and
deferred tax assets are recognised 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 business combination) that at the time
of the transaction affects neither accounting nor taxable profit
or loss. Deferred tax is calculated using tax rates expected to
apply in the periods when the assets will be realised or the
liabilities settled, based on tax rates and laws enacted, or
substantively enacted, at the balance sheet date.
Deferred tax assets and liabilities are offset where we have 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 that intend, in future periods,
to settle current tax liabilities and assets on a net basis or on a
gross basis simultaneously.
Deferred tax asset recoverability is based on the level of
supporting offsetable deferred tax liabilities we have and of our
future taxable profits. These future taxable profits are based on
our five-year revenue and cost forecasts and the expectation of
long term economic growth beyond this period. The five-year
forecast takes account of management’s current expectations
on competitiveness and profitability. The long term growth rate
reflects external indicators which will include market
expectations on climate risk. We do not consider any additional
adjustments to this indicator.
2.2. Fair value – financial instruments
Financial instruments classified as mandatory fair value
through profit or loss; held-for-trading; designated fair value
through profit or loss and fair value through other
comprehensive income are recognised in the financial
statements at fair value. All derivatives are measured at fair
value.
Fair value is the price that would be received to sell an asset or
paid to transfer a liability in an orderly transaction between
market participants at the measurement date. A fair value
measurement considers the characteristics of the asset or
liability and the assumptions that a market participant would
consider when pricing the asset or liability.
We manage some portfolios of financial assets and financial
liabilities based on our net exposure to either market or credit
risk. In these cases, the fair value is derived from the net risk
exposure of that portfolio with portfolio level adjustments
applied to incorporate bid-offer spreads, counterparty credit
risk, and funding costs (see ‘Valuation Adjustments’).
Where the market for a financial instrument is not active, fair
value is established using a valuation technique. These
valuation techniques involve a degree of estimation, the extent
of which depends on the instrument’s complexity and the
availability of market-based data. The complexity and
uncertainty in the financial instrument’s fair value is
categorised using the fair value hierarchy.
The use of market indicators as inputs to fair value is assumed
to include current information and knowledge regarding the
effect of climate risk.
2.3. Loan impairment provisions: expected credit losses
(ECL)
At each balance sheet date each financial asset or portfolio of
financial assets measured at amortised cost or at fair value
through other comprehensive income, issued financial
guarantee and loan commitment (other than those classified as
held for trading) is assessed for impairment. Any change in
impairment is reported in the income statement.
Loss allowances are forward-looking, based on 12-month ECL
where there has not been a significant increase in credit risk
rating, otherwise allowances are based on lifetime expected
losses.
ECL are a probability-weighted estimate of credit losses. The
probability is determined by the risk of default 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. Following a
significant increase in credit risk, ECL are adjusted from 12
months to lifetime. This will lead to a higher impairment charge.
The measurement of expected credit loss considers the ability
of borrowers to make payments as they fall due. Future
cashflows are discounted, so long-dated cashflows are less
likely to affect current expectations on credit loss. Our
assessment of sector specific risks, and whether additional
adjustments are required, include expectations of the ability of
those sectors to meet their financing needs in the market.
Changes in credit stewardship and credit risk appetite that
stem from climate considerations, such as oil and gas, will
directly affect our positions.
Judgment is exercised as follows:
Models
in certain low default portfolios, Basel parameter
estimates are also applied for IFRS 9.
Non-modelled portfolios
– use a standardised capital
requirement under Basel II. Under IFRS 9, they have
bespoke treatments for the identification of significant
increase in credit risk. Benchmark PDs, EADs and LGDs are
reviewed annually for appropriateness. The ECL calculation
is based on expected future cash flows, which is typically
applied at a portfolio level.
Multiple economic scenarios (MES)
– the central, or base,
scenario is most critical to the ECL calculation, 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 shall assess whether the
credit risk on an account has increased significantly since
initial recognition. Part of this assessment requires a
comparison to be made between the current lifetime PD
(i.e. the current probability of default over the remaining
lifetime) with the equivalent lifetime PD as determined at
the date of initial recognition.
On restructuring where a financial asset is not derecognised,
the revised cash flows are used in re-estimating the credit loss.
Where restructuring causes derecognition of the original
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 orderly realisation of a loan, it is
exchanged for equity shares or property, the exchange is
accounted for as the sale of the loan and the acquisition of
equity securities or investment property. Where our acquired
interest is in equity shares, relevant policies for control,
associates and joint ventures apply.
Accounting policies
continued
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Impaired financial assets are written off and therefore
derecognised from the balance sheet when we conclude that
there is no longer any realistic prospect of recovery of part, or
all, of the loan. For financial assets that are individually
assessed for impairment, the timing of the write-off is
determined on a case-by-case basis. Such financial assets are
reviewed regularly and write-off will be prompted by
bankruptcy, insolvency, re-negotiation, and similar events.
The typical time frames from initial impairment to write-off for
our collectively assessed portfolios are:
Retail mortgages: write-off usually occurs within five years,
or earlier, when an account is closed, but can be longer
where the customer engages constructively;
Credit cards: the irrecoverable amount is typically written
off after twelve arrears cycles or at four years post default
any remaining amounts outstanding are written 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 Business loans are generally
written off within five years.
2.4. Provisions and contingent liabilities
We recognise a provision for a present obligation resulting from
a past event when it is more likely than not that we will be
required to pay to settle the obligation and the amount of the
obligation can be estimated reliably.
Provision is made for restructuring costs, including the costs of
redundancy, when we have a constructive obligation. An
obligation exists when we have a detailed formal plan for the
restructuring and have raised a valid expectation in those
affected either by starting to implement the plan or by
announcing its main features.
We recognise any onerous cost of the present obligation under
a contract as a provision. An onerous cost is the unavoidable
cost of meeting our contractual obligations that exceed the
expected economic benefits. When we intend to vacate a
leasehold property or right of use asset, the asset would be
tested for impairment and a provision may be recognised for
the ancillary contractual occupancy costs.
Contingent liabilities are possible obligations arising from past
events, whose existence will be confirmed only by uncertain
future events, or present obligations arising from past events
that are not recognised because either an outflow of economic
benefits is not probable, or the amount of the obligation cannot
be reliably measured. Contingent liabilities are not recognised
but information about them is disclosed unless the possibility of
any outflow of economic benefits in settlement is remote.
3. Significant accounting polices
3.1. Revenue recognition
Interest receivable and payable 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 through other
comprehensive income; and the effective part of any related
accounting hedging instruments. Finance lease income is
recognised at a constant periodic rate of return before tax on
the net investment on the lease.
Other interest relating to financial instruments measured at fair
value is recognised as part of the movement in fair value and is
reported in income from trading activities or other operating
income as relevant. Fees in respect of services are recognised
as the right to consideration accrues through the performance
of each distinct service obligation to the customer. 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.
3.2. Discontinued operations, Held for sale and Disposal
group
The results of discontinued operations (comprising the post-tax
profit or loss of discontinued operations and the post-tax results
of either the ongoing measurement at fair value less costs to
sell or on disposal of the discontinued operation) are excluded
from the results of continuing operations and are presented as
a single amount as profit/(loss) from discontinued operations,
net of tax in the income statement. Comparatives are
represented for the income statement, 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 we will recover its carrying amount principally
through a sale transaction rather 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 measurement provisions of IFRS apply. These are
presented as single amounts; comparatives are not
represented.
3.3. Staff costs
Employee costs, such as salaries, paid absences, and other
benefits are recognised over the period in which the employees
provide the related services to us. Employees may receive
variable compensation in cash, in deferred cash or debt
instruments of NatWest Group or in ordinary shares of NatWest
Group plc subject to deferral, clawback and forfeiture criteria.
We operate a number of share-based compensation schemes
under which we grant awards of NatWest Group plc shares
and share options to our employees. Such awards are subject
to vesting conditions.
Variable compensation that is settled in cash or debt
instruments is charged to the income statement on a straight-
line basis over the period during which services are provided,
taking account of forfeiture and clawback criteria. The value of
employee services received in exchange for NatWest Group plc
shares and share options is recognised as an expense over the
vesting period, subject to deferral, clawback, cancelation and
forfeiture criteria with a corresponding increase in equity. The
fair value of shares granted is the market price adjusted for the
expected effect of dividends as employees are not entitled to
dividends until shares are vested.
The fair value of options granted is determined using option
pricing models to estimate the numbers of shares likely to vest.
These consider the exercise price of the option, the current
share price, the risk-free interest rate, the expected volatility of
the share price over the life of the option and other relevant
factors such as the dividend yield.
Accounting policies
continued
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Defined contribution pension scheme
A scheme where we pay fixed contributions and there is no
legal or constructive obligation to pay further contributions or
benefits. Contributions are recognised in the income statement
as employee service costs accrue.
Defined benefit pension scheme
A scheme that defines the benefit an employee will receive on
retirement and is dependent on one or more factors 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. The defined benefit obligation
is measured on an actuarial basis. The charge to the income
statement for pension costs (mainly 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 benefit asset or liability due to
changes in actuarial measurement assumptions) are recognised
in other comprehensive income in full in the period in which
they arise, and not subject to recycling to the income
statement.
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 asset ceiling test are met.
This requires the net defined benefit surplus to be limited to the
present value of any economic benefits available to us in the
form of refunds from the plan or reduced contributions to it.
We will recognise a liability where a minimum funding
requirement exists for any of our defined benefit pension
schemes. This reflects agreed minimum funding and the
availability of a net surplus as determined as described above.
When estimating the liability for minimum funding requirements
we only include contributions that are substantively or
contractually agreed and do not include contingent and
discretionary features, including dividend-linked contributions
or contributions subject to contingent events requiring future
verification.
We will recognise a net defined benefit asset when the net
defined benefit surplus can generate a benefit in the form of a
refund or reduction in future contributions to the plan. The net
benefit pension asset is recognised at the present value of the
benefits that will be available to us excluding interest and the
effect of the asset ceiling (if any, excluding interest). Changes
in the present value of the net benefit pension asset are
recognised immediately in other comprehensive income.
In instances where Trustees have the ability to declare
augmented benefits to participants, we do not recognise a
defined benefit pension asset and write-off the surplus
immediately in other comprehensive income.
3.4. Intangible assets and goodwill
Intangible assets are identifiable non-monetary assets without
physical substance acquired by us, and are stated at cost less
accumulated amortisation and impairment losses. Amortisation
is a method to spread the cost of such assets over time in the
income statement.
This is charged to the income statement over the assets'
estimated useful economic lives using methods that best reflect
the pattern of economic benefits.
The estimated useful economic lives are:
Computer software
3 to 12 years
Other acquired intangibles
5 to 10 years
Expenditure on internally generated goodwill and brands is
charged to the income statement as incurred.
Direct costs relating to the development of internal-use
computer software are reported on the balance sheet after
technical feasibility and economic viability have been
established.
These direct costs include payroll, the costs of materials and
services, and directly attributable overheads. Capitalisation of
costs ceases when the software can operate as intended.
During and after development, accumulated costs are reviewed
for impairment against the benefits that the software is
expected to generate. Costs incurred prior to the establishment
of technical feasibility and economic viability are expensed to
the income statement as incurred, as are all training costs and
general overheads. The costs of licences to use computer
software that are expected to generate economic benefits
beyond one year are also reported on the balance sheet
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 subsidiary and the amount of any non-
controlling interest measured either at fair value or at its share
of the subsidiary’s net assets over the net fair value of the
subsidiary’s identifiable assets, liabilities, 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.
3.5. Impairment of non-financial assets
At each balance sheet date, we assess whether there is any
indication that its intangible assets or property, plant and
equipment are impaired. If any such indication exists, we
estimate the recoverable amount of the asset and compares it
to its balance sheet value to calculate if an impairment loss
should be charged to the income statement. The balance sheet
value of the asset is reduced by the amount of the impairment
loss. A reversal of an impairment loss on intangible assets or
property, plant and equipment is recognised in the income
statement provided the increased carrying value is not greater
than it would have been had no impairment loss been
recognised.
Goodwill is tested for impairment annually or more frequently if
events or changes in circumstances indicate that it might 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 other assets or
groups of assets, is determined as part of the cash-generating
unit to which the asset belongs. A cash-generating unit is the
smallest identifiable group of assets that generates cash inflows
that are largely independent of the cash inflows from other
assets or groups of assets. For the purposes of impairment
testing, goodwill acquired in a business combination is allocated
to our cash-generating units or groups of cash-generating units
expected to benefit from the combination.
The recoverable amount of an asset or cash-generating unit is
the higher of its fair value less cost to sell or its value in use.
Value in use is the present value of future cash flows from the
asset or cash-generating unit discounted at a rate that 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.
Accounting policies
continued
NatWest Group
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Additional information
Financial review
The assessment of asset impairment is based upon value in
use. This represents the value of future cashflows and uses our
five-year revenue and cost forecasts and the expectation of
long term economic growth beyond this period. The five-year
forecast takes account of management’s current expectations
on competitiveness and profitability. The long term growth rate
reflects external indicators which will include market
expectations on climate risk. We do not consider any additional
adjustments to this indicator.
3.6. Foreign currencies
Foreign exchange differences arising on the settlement of
foreign currency transactions and from the translation of
monetary assets and liabilities are reported in income from
trading activities except for differences arising on cash flow
hedges and hedges of net investments in foreign operations.
Non-monetary items denominated in foreign currencies that
are stated at fair value are translated into the functional
currency at the foreign exchange rates ruling at the dates the
values are determined. Translation differences are recognised
in the income statement except for differences arising on non-
monetary financial assets classified as fair value through other
comprehensive income.
Income and expenses of foreign subsidiaries and branches are
translated into sterling at average exchange rates unless these
do not approximate the foreign exchange rates ruling at the
dates of the transactions. Foreign exchange differences arising
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 statement on
disposal of a foreign operation.
3.7. 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. Tax
consequences arising from servicing financial instruments
classified as equity are recognised in the income statement.
Current tax is tax payable or recoverable in respect of the
taxable profit or loss for the year arising in the income
statement, other comprehensive income or equity. Provision is
made for current tax at rates enacted, or substantively
enacted, at the balance sheet date.
Accounting for taxes is judgmental and carries a degree of
uncertainty because tax law is subject to interpretation, which
might be questioned by the relevant tax authority. We
recognise the most likely current and deferred tax liability or
asset, assessed for uncertainty using consistent judgments and
estimates. Current and deferred tax assets are only recognised
where their recovery is deemed probable, and current and
deferred tax liabilities are recognised at the amount that
represents the best estimate of the probable outcome having
regard to their acceptance by the tax authorities.
3.8. Financial instruments
Financial instruments are measured at fair value on initial
recognition on the balance sheet.
Monetary financial assets are classified into one of the following
subsequent measurement categories (subject to business model
assessment and review of contractual cash flow for the
purposes of sole payments of principal and interest where
applicable):
amortised cost
measured at cost using the effective interest
rate method, less any impairment allowance;
fair value through other comprehensive income (FVOCI)
measured at fair value, using the effective interest rate
method and changes in fair value through other
comprehensive income;
mandatory fair value through profit or loss (MFVTPL)
measured at fair value and changes in fair value reported in
the income statement; or
designated at fair value through profit or loss (DFV)
measured at fair value and changes in fair value reported in
the income statement.
Classification by business model reflects how we manage our
financial assets to generate cash flows. A business model
assessment helps to ascertain the measurement approach
depending on whether cash flows result from holding financial
assets to collect the contractual cash flows, from selling those
financial assets, or both.
Business model assessment of assets is made at portfolio level,
being the level at which they are managed to achieve a
predefined business objective. This is expected to result in the
most consistent classification of assets because it aligns with
the stated objectives for the portfolio, its risk management,
manager’s remuneration and the ability to monitor sales of
assets from a portfolio. When a significant change to our
business is communicated to external parties, we reassess our
business model for managing those financial assets. We
reclassify financial assets if we have a significant change to the
business model. A reclassification is applied prospectively from
the reclassification date.
The contractual terms of a financial asset; any leverage
features; prepayment and extension terms; and discounts or
penalties to interest rates that are part of meeting
environmental, social and governance targets as well as other
contingent and leverage features, non-recourse arrangements
and features that could modify the timing and/or amount of the
contractual cash flows 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 designated at fair value
through profit or loss (DFV) upon initial recognition if such
designation eliminates, or significantly reduces, accounting
mismatch
.
Equity shares are measured at fair value through profit or loss
unless specifically elected 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 assets and for non-
monetary assets (equity shares) the cumulative gains or losses
are transferred directly to retained earnings.
Accounting policies
continued
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Regular way purchases and sales of financial assets classified
as amortised cost are recognised on the settlement date; all
other regular way transactions in financial assets are
recognised on the trade date.
Financial liabilities are classified into one of following
measurement categories:
amortised cost
measured at cost using the effective interest
rate method;
held for trading
measured at fair value and changes 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 reported in the income
statement except changes in fair value attributable to the
credit risk component recognised in other comprehensive
income when no accounting mismatch occurs.
3.9. Derecognition
A financial asset is derecognised (removed from the balance
sheet) when the contractual right to receive cash flows from
the asset has expired or when it has been transferred and the
transfer qualifies for derecognition. Conversely, an asset is not
derecognised in a contract under which we retain substantially
all the risks and rewards of ownership.
A financial liability is removed from the balance sheet when the
obligation is paid, or is cancelled, or expires. Cancellation
includes the issuance of a substitute instrument on substantially
different terms.
3.10. Netting
Financial assets and financial liabilities are offset, and the net
amount presented on the balance sheet when, and only when,
we currently have a legally enforceable right to set off the
recognised amounts and we intend either to settle on a net
basis or to realise the asset and settle the liability
simultaneously. We are party to a number of arrangements,
including master netting agreements, that give us the right to
offset financial assets and financial liabilities, but where we do
not intend to settle the amounts net or simultaneously, the
assets and liabilities concerned are presented separately on the
balance sheet.
3.11. Capital instruments
We classify a financial instrument that we issue as a liability if it
is a contractual obligation to deliver cash or another financial
asset, or to exchange financial assets or financial liabilities on
potentially unfavourable terms and as equity if we evidence a
residual interest in our assets after the deduction of liabilities.
Incremental costs and related tax that are directly attributable
to an equity transaction are deducted from equity.
The consideration for any ordinary shares of NatWest Group
plc purchased by us (known as treasury shares or own shares
held) is deducted from equity. On the cancellation of treasury
shares their nominal value is removed from equity and any
excess of consideration over nominal value is treated in
accordance with the capital maintenance provisions of the
Companies Act 2006.
On the sale or re-issue of treasury shares the consideration
received and related tax are credited to equity, net of any
directly attributable incremental costs.
3.12. Derivatives and hedging
Derivatives are reported on the balance sheet at fair value.
We use derivatives as part of our trading activities, to manage
our own risk such as interest rate, foreign exchange, or credit
risk or in certain customer transactions. Not all derivatives used
to manage risk are in hedge accounting relationships (an IFRS
method to reduce accounting mismatch from changes in the
fair value of the derivatives reported in the income statement).
Gains and losses arising from changes in the fair value of
derivatives that are not in hedge relationships are recognised in
the income statement in Income from trading activities except
for gains and losses on those derivatives that are managed
together with financial instruments designated at fair value;
these gains and losses are included in Other operating income.
Hedge accounting
We enter into three types of hedge accounting relationships
(see later). Hedge accounting relationships are designated and
documented at inception in line with the requirements of IAS 39
Financial instruments – Recognition and Measurement.
The documentation identifies the hedged item, the hedging
instrument and details of the risk that is being hedged and the
way in which effectiveness will be assessed at inception and
during the period of the hedge. When designating a hedging
relationship, we consider: the economic relationship between
the hedged item (including the risk being hedged) and the
hedging instrument; the nature of the risk; the risk
management objective and strategy for undertaking the hedge;
and the appropriateness of the method that will be used to
assess hedge effectiveness. Designated hedging relationships
must be expected to be highly effective both on a prospective
and retrospective basis. Effectiveness is assessed by reference
to the degree of offsetting between the changes in fair value or
cash flows attributable to the hedged risk and the changes in
fair value of the designated hedging derivatives.
Fair value hedge
- the gain or loss on the hedging instrument
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 designated hedge
relationship is recognised in other comprehensive income and
the ineffective portion in the income statement. When the
hedged item (forecasted cash flows) results in the recognition
of a financial asset or financial liability, the cumulative gain or
loss is reclassified from equity to the income statement in the
same periods in which the hedged forecasted 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 recognised in
other comprehensive income. Any ineffective portion is
recognised in profit or loss. Non-derivative financial liabilities as
well as derivatives may be designated as a hedging instrument
in a net investment hedge.
Discontinuation of hedge accounting
Hedge accounting is discontinued if the hedge no longer meets
the criteria for hedge accounting i.e. the hedge is not highly
effective in offsetting changes in fair value or cash flows
attributable to the hedged risk, consistent with the documented
risk management strategy; the hedging instrument expires or is
sold, terminated or exercised; or if hedge designation is
revoked.
Accounting policies
continued
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Financial review
For fair value hedging any cumulative adjustment is amortised
to the income statement over the 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 cumulative unrealised
gain or loss is reclassified from equity to the income statement
when the hedged cash flows occur or, if the forecast
transaction results in the recognition of a financial asset or
financial liability, when the hedged forecast cash flows affect
the income statement. Where a forecast transaction is no
longer expected to occur, the cumulative unrealised gain or
loss is reclassified from equity to the income statement
immediately.
For net investment hedging on disposal or partial disposal of a
foreign operation, the amount accumulated in equity is
reclassified from equity to the income statement.
4. Future accounting developments
International Financial Reporting Standards
Effective 1 January 2023
IFRS 17 Insurance Contracts (Amendments to IFRS 17
Insurance Contracts);
Deferred Tax related to Assets and Liabilities arising from a
Single Transaction (Amendments to IAS 12);
Definition of Accounting Estimates (Amendments to IAS 8);
and
Disclosure of Accounting Policies (Amendments to IAS 1
and IFRS Practice Statement 2).
Effective 1 January 2024
Classification of Liabilities as Current or Non-current
(Amendments to IAS 1);
Non-current Liabilities with Covenants (Amendments to IAS
1)
Lease Liability in a sale and Leaseback (Amendments to
IFRS 16).
We are assessing the effect of adopting these standards and
amendments on our financial statements but do not expect the
effect to be material.
Notes to the consolidated
financial statements
NatWest Group
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1 Net interest income
Net interest income is the difference between the interest NatWest Group earns from its interest-bearing assets, such as loans,
balances with central banks and other financial assets, and the interest paid on its interest-bearing liabilities, such as deposits and
subordinated liabilities.
Interest receivable on financial instruments classified as amortised cost, debt instruments classified as FVOCI and the interest
element of the effective portion of any designated hedging relationships are measured using the effective interest rate, which
allocates the interest receivable or interest payable over the expected life of the financial instrument at the rate that exactly
discounts all estimated future cash flows to equal the financial instrument's initial carrying amount. Calculation of the effective
interest rate takes into account fees payable or receivable that are an integral part of the financial instrument’s yield, premiums or
discounts on acquisition or issue, early redemption fees and transaction costs. All contractual terms of a financial instrument are
considered when estimating future cash flows. Negative interest on financial
assets is presented in interest payable and negative
interest on
financial liabilities is presented in interest receivable.
Included in interest receivable is finance lease income of £314 million (2021 - £298 million; 2020 - £289 million) which is recognised
at a constant periodic rate of return before tax on the net investment.
For accounting policy information see Accounting policies note 3.1.
2022
2021 (1)
2020 (1)
Continuing operations
£m
£m
£m
Balances at central banks and loans to banks - amortised cost
1,987
445
336
Loans to customers - amortised cost
10,085
8,536
8,892
Other financial assets
565
253
483
Interest receivable
12,637
9,234
9,711
Balances with banks
379
204
144
Customer deposits
785
556
911
Other financial liabilities
1,196
670
846
Subordinated liabilities
370
267
402
Internal funding of trading businesses
65
2
19
Interest payable
2,795
1,699
2,322
Net interest income
9,842
7,535
7,389
(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 consolidated financial statements
continued
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2 Non-interest income
There are three main categories of non-interest income: net fees and commissions, trading income , and other operating income.
Net fees and commissions is the difference between fees received from customers for services provided by NatWest Group, such as
credit card annual fees, mortgage arrangement fees, underwriting fees, payment services, brokerage fees, trade finance,
investment management fees, trustee and fiduciary services, and fees incurred in the provision of those services, such as credit
card interchange fees, customer incentives, loan administration, foreign currency transaction charges, brokerage fees, and
mortgage valuation reports.
Trading income is earned from short-term financial assets and financial liabilities to either make a spread between purchase and
sale price or held to take advantage of movements in prices and yields.
Other operating income includes revenue from other operating activities which are not related to the principal activities of the
company, such as share of profit or loss from associate, operating lease income, the profit or loss on the sale of a subsidiary or
property, plant and equipment, profit or loss on own debt, and changes in the fair value of financial assets and liabilities designated
at fair value through profit or loss.
For accounting policy information see Accounting policies note 3.1 and 3.6.
2022
2021 (1)
2020 (1)
Continuing operations
£m
£m
£m
Net fees and commissions
(2)
2,292
2,120
1,982
Trading income
Foreign exchange
305
364
569
Interest rate
(3)
752
(130)
541
Credit
17
83
3
Changes in fair value of own debt and derivative liabilities attributable to own credit risk
- debt securities in issue
42
6
(24)
Equities, commodities and other
17
36
1,133
323
1,125
Other operating income
Loss on redemption of own debt
(161)
(145)
(324)
Rental income on operating lease assets and investment property
230
225
232
Changes in fair value of financial assets and liabilities designated at fair value
through profit or loss
(4)
17
(8)
(54)
Changes in fair value of other financial assets at fair value through profit or loss
(5,6)
(45)
5
2
Hedge ineffectiveness
(20)
25
24
Loss on disposal of amortised cost assets and liabilities
(15)
(15)
(18)
(Loss)/profit on disposal of fair value through other comprehensive income assets
(168)
117
96
(Loss)/profit on sale of property, plant and equipment
(7)
(5)
(30)
13
Share of (losses)/profits of associated entities
(30)
216
(30)
Profit/(loss) on disposal of subsidiaries and associates
48
(16)
Other income
(8,9)
86
13
(18)
(111)
451
(93)
3,314
2,894
3,014
(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)
Includes fair value changes on derivatives which have not been designated in a hedge accounting relationship and gains and losses from the management of the NatWest Group’s
funding requirements involving the use of derivatives including FX. These are aimed at managing the interest rate and foreign exchange risk that NatWest Group is exposed to.
(4)
Includes related derivatives.
(5)
2022 includes a £19 million gain from reclassification of mortgages from amortised cost to fair value through profit or loss. Refer to Note 10 for further details.
(6)
Includes instruments that have failed solely payments of principal and interest testing under IFRS 9.
(7)
2021 includes £44 million loss on the purchase of freeholds for properties where the Group was the primary leaseholder.
(8)
2022 includes £92 million profit from insurance liabilities.
(9)
2020 includes £58 million loss on acquisition of a £3.0 billion prime UK mortgages portfolio from Metro Bank plc.
Notes to the consolidated financial statements
continued
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3 Operating expenses
Operating expenses are expenses NatWest Group incurs in the running of the business such as all staff costs (for 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 administrative expenses.
For accounting policy information see Accounting policies note 3.3, 3.4 and 3.5.
2022
2021
2020
Continuing operations
£m
£m
£m
Salaries
2,250
2,295
2,494
Bonus awards
334
267
232
Temporary and contract costs
234
240
258
Social security costs
328
300
316
Pension costs
363
354
340
- defined benefit schemes (see Note 5)
205
215
215
- defined contribution schemes
158
139
125
Other
207
220
238
Staff costs
3,716
3,676
3,878
Premises and equipment
1,112
1,133
1,222
UK bank levy
101
99
167
Depreciation and amortisation
(1,2)
833
923
913
Other administrative expenses
(3)
1,925
1,927
1,678
Administrative expenses
3,971
4,082
3,980
7,687
7,758
7,858
(1)
Include depreciation on right of use assets of £119 million (2021 - £167 million; 2020 - £209 million).
(2)
2021 includes impairment of goodwill of £85 million.
(3)
Includes litigation and conduct costs, net of amounts recovered. Refer to Note 21 for further details.
The average number of persons employed, rounded to the nearest hundred, during the year, excluding temporary staff, was
60,000 (2021- 59,200; 2020 – 61,400). The average number of temporary employees during 2022 was 2,500 (2021 – 2,500; 2020 –
3,200).
The number of persons employed at 31 December, excluding temporary staff, by reportable segment, was as follows:
Continuing operations
2022
2021
2020
Retail Banking
14,800
15,800
17,200
Private Banking
2,100
1,900
1,900
Commercial & Institutional
12,200
11,400
13,300
Central items & other
(1)
31,900
28,700
26,800
Total
61,000
57,800
59,200
UK
41,200
40,600
42,500
USA
300
300
300
India
15,700
13,500
13,200
Poland
1,500
1,400
1,200
Republic of Ireland
1,400
1,200
1,400
Rest of the World
900
800
600
Total
61,000
57,800
59,200
(1)
Central items & other includes Ulster Bank RoI. Total number of persons employed in Ulster Bank RoI of 2,200 (2021 – 2,400; 2020 – 2,600) includes 400 people employed in
discontinued operations at 31 December 2022 (2021 – 700; 2020 – 700).
Notes to the consolidated financial statements
continued
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Additional information
Financial review
3 Operating expenses continued
Share-based payments
As described in the Remuneration report, NatWest Group grants share-based awards to employees principally on the following
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
2023 to 2027
Deferred performance
awards
All
Awards of ordinary shares
and conditional shares
Continuing employment or
leavers in certain circumstances
2023 to 2030
Long-term incentives
(2)
(3)
Senior employees
Awards of ordinary shares
and conditional shares
Continuing employment or
leavers in certain circumstances
and/or satisfaction of the pre-
vest assessment and underpins
2023 to 2029
(1)
All awards have vesting conditions which may not be met.
(2)
Long-term incentives include buy-out awards 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.
(3)
The existing Long-term incentive scheme has been closed to new awards and members as at 31 December 2022. The scheme will be replaced by
a new Restricted share plan
scheme with similar granting and vesting conditions. No awards have been granted at the end of the reporting period.
The fair value of Sharesave options granted in 2022 was determined using a pricing model that included: expected volatility of
shares determined at the grant date based on historical volatility over a period of up to five years; expected option lives that equal
the vesting period; estimated dividend yield on equity shares; and risk-free interest rates determined from UK gilts with terms
matching the expected lives of the options.
The exercise price of options and the fair value on granting awards of fully paid shares is the average market price over the five
trading days (three trading days for Sharesave) preceding grant date. When estimating the fair value of the award, the number of
shares granted, and the prevailing market price as defined on page 149 are used.
The fair value of the award is recognised as
services are provided over the vesting period.
Sharesave
2022
2021
2020
Average exercise
price
Average exercise
price
Average exercise
price
£
Shares under
option (million)
£
Shares under
option (miilion)
£
Shares under
option (miilion)
At 1 January
1.61
95
1.64
96
2.01
84
Granted
1.86
25
1.80
24
1.12
35
Exercised
1.88
(15)
1.76
(10)
1.83
Cancelled
1.60
(6)
2.02
(15)
2.20
(23)
At 31 December
1.63
99
1.61
95
1.64
96
Options are exercisable within six months of vesting; 5.1 million options were exercisable at 31 December 2022 (2021 – 6.0 million;
2020 – 6.3 million). The weighted average share price at the date of exercise of options was £2.59 (2021 - £2.19; 2020 - £1.57). At
31 December 2022, exercise prices ranged from £1.12 to £2.27 (2021 - £1.12 to £2.27; 2020 - £1.12 to £2.27) and the remaining
average contractual life was 2 years (2021 – 2.1 years; 2020 – 2.3 years). The fair value of options granted in 2022 was £22.1
million (2021 - £17 million; 2020 - £8 million).
Deferred performance awards
2022
2021
2020
Value at grant
Shares awarded
(million)
Value at grant
Shares awarded
(million)_
Value at grant
Shares awarded
(million)_
£m
£m
£m
At 1 January
132
65
169
77
196
76
Granted
46
20
61
32
109
67
Forfeited
(4)
(2)
(10)
(5)
(5)
(2)
Vested
(81)
(37)
(88)
(39)
(131)
(64)
At 31 December
93
46
132
65
169
77
The awards granted in 2022 vest in equal tranches on their anniversaries, predominantly over three years.
Long-term incentives
2022
2021
2020
Value at grant
Shares awarded
(million)
Value at grant
Shares awarded
(million)_
Value at grant
Shares awarded
(million)_
£m
£m
£m
At 1 January
44
21
50
24
63
25
Granted
16
7
6
3
14
10
Vested/exercised
(10)
(4)
(12)
(6)
(17)
(7)
Lapsed
(1)
(1)
(10)
(4)
At 31 December
49
23
44
21
50
24
The market value of awards vested/exercised in 2022 was £11.7 million (2021- £13 million; 2020 - £13 million).
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
318
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 2022.
2022
2021
Change
£m
£m
%
Non-deferred cash awards
(1)
40
38
5%
Deferred cash awards
270
214
26%
Deferred share awards
60
49
22%
Total deferred bonus awards
330
263
25%
Total bonus awards
(2)
370
301
23%
Bonus awards as a % of operating profit before tax
(3)
7%
7%
Proportion of bonus awards that are deferred
89%
87%
of which
- deferred cash awards
82%
81%
- deferred share awards
18%
19%
2022
2021
2020
Reconciliation of bonus awards to income statement charge
£m
£m
£m
Bonus awarded
370
301
206
Less: deferral of charge for amounts awarded for current year
(127)
(99)
(77)
Income statement charge for amounts awarded in current year
243
202
129
Add: current year charge for amounts deferred from prior years
94
80
114
Less: forfeiture of amounts deferred from prior years
(3)
(15)
(11)
Income statement charge for amounts deferred from prior years
91
65
103
Income statement charge for bonus awards
(2)
334
267
232
(1)
Non-deferred cash awards are limited to £2,000 for all employees.
(2)
Excludes other performance related compensation.
(3)
Operating profit before tax and bonus expense.
Actual
Expected
2024
2020
2021
2022
2023
and beyond
Year in which income statement charge is expected to
be taken for deferred bonus awards
£m
£m
£m
£m
£m
Bonus awards deferred from 2020 and earlier
114
80
19
8
4
Bonus awards deferred from 2021
75
8
8
Less: forfeiture of amounts deferred from prior years
(11)
(15)
(3)
Bonus awards for 2022 deferred
105
22
103
65
91
121
34
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
319
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
4 Segmental analysis
NatWest Group analyses its performance between the different operating segments of the Group as required by IFRS 8, Operating
segments. The presentation is consistent with internal financial reporting and how senior management assesses the performance
of each operating segment.
Changes in reportable segments:
Two changes to reportable segments have been made:
On 27 January 2022, NatWest Group announced that a new business segment, Commercial & Institutional, would be created,
bringing together the Commercial, NatWest Markets and RBSI businesses to form a single business segment, with common
management and objectives, to best support our customers across the full non-personal customer lifecycle.
Following good progress with respect to the phased withdrawal from the Republic of Ireland, announced in February 2021,Ulster
Bank RoI continuing operations are now included in Central items & other.
Comparatives have been re-presented. The re-presentation of operating segments does not change the consolidated financial
results of NatWest Group.
Reportable operating segments:
The business is organised into the following reportable segments: Retail Banking, Private Banking, Commercial & Institutional, and
Central items & other.
Retail Banking
serves personal customers in the UK and includes Ulster Bank customers in Northern Ireland.
Private Banking
serves UK connected high-net-worth individuals and their business interests.
Commercial & Institutional
brings together our Commercial Banking, NatWest Markets and RBS International businesses, to
support our customers across the full non-personal customer lifecycle, both domestically and internationally. Our Markets offering
helps our customers manage financial risks across different geographies, while our International offering provides full-service
banking operations in the Channel Islands, Isle of Man, Gibraltar and Luxembourg.
Central items & other
includes corporate functions, such as NatWest Group Treasury, finance, risk management, compliance,
legal, communications and human resources. Central functions manages NatWest Group capital resources and NatWest Group-
wide regulatory projects and provides services to the reportable segments. Balances in relation to litigation issues and the
international private banking business are included in Central items in the relevant periods. Ulster Bank RoI is no longer an
operating segment and its continuing operations now form part of Central items & other.
Allocation of central balance sheet items
NatWest Group allocates all central costs relating to Services and Functions to the business using appropriate drivers; these are
reported as indirect costs in the segmental income statements. Assets and risk-weighted assets held centrally, mainly relating to
NatWest Group Treasury, are allocated to the business using appropriate drivers
.
Retail Banking
Private Banking
Commercial
&
Institutional
Central items &
other
Total
2022
£m
£m
£m
£m
£m
Continuing operations
Net interest income
5,224
777
4,171
(330)
9,842
Net fees and commissions
422
250
1,580
40
2,292
Other non-interest income
29
662
331
1,022
Total income
5,646
1,056
6,413
41
13,156
Depreciation and amortisation
(161)
(672)
(833)
Other operating expenses
(2,593)
(622)
(3,583)
(56)
(6,854)
Impairment (losses)/releases
(229)
2
(122)
12
(337)
Operating profit/(loss)
2,824
436
2,547
(675)
5,132
2021
(1)
Continuing operations
Net interest income
4,074
480
2,974
7
7,535
Net fees and commissions
377
258
1,440
45
2,120
Other non-interest income
(6)
78
424
278
774
Total income
4,445
816
4,838
330
10,429
Depreciation and amortisation
(85)
(173)
(665)
(923)
Other operating expenses
(2,428)
(520)
(3,584)
(303)
(6,835)
Impairment releases/(losses)
36
54
1,160
(77)
1,173
Operating profit/(loss)
1,968
350
2,241
(715)
3,844
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
320
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
4 Segmental analysis continued
Retail Banking
Private Banking
Commercial &
Institutional
Central items &
other
Total
2020
(1)
£m
£m
£m
£m
£m
Continuing operations
Net interest income
3,868
489
3,054
(22)
7,389
Net fees and commissions
379
257
1,303
43
1,982
Other non-interest income
(66)
17
1,221
(140)
1,032
Total income
4,181
763
5,578
(119)
10,403
Depreciation and amortisation
(8)
(182)
(723)
(913)
Operating expenses
(2,540)
(447)
(3,849)
(109)
(6,945)
Impairment losses
(792)
(100)
(2,074)
(132)
(3,098)
Operating profit/(loss)
849
208
(527)
(1,083)
(553)
Total revenue
(2)
Retail Banking
Private Banking
Commercial
&
Institutional
Central items &
other
Total
Year ended 31 December 2022
£m
£m
£m
£m
£m
Continuing operations
External
5,773
874
6,747
3,180
16,574
Inter-segmental
389
116
(505)
Total
5,773
1,263
6,863
2,675
16,574
Year ended 31 December 2021 (1)
Continuing operations
External
5,419
792
5,168
1,323
12,702
Inter-segmental
14
127
123
(264)
Total
5,433
919
5,291
1,059
12,702
Year ended 31 December 2020 (1)
Continuing operations
External
5,386
702
6,223
1,136
13,447
Inter-segmental
39
163
80
(282)
Total
5,425
865
6,303
854
13,447
Total income
Retail Banking
Private Banking
Commercial
&
Institutional
Central items &
other
Total
Year ended 31 December 2022
£m
£m
£m
£m
£m
Continuing operations
External
5,646
780
6,777
(47)
13,156
Inter-segmental
276
(364)
88
Total
5,646
1,056
6,413
41
13,156
Year ended 31 December 2021
(1)
Continuing operations
External
4,433
801
5,041
154
10,429
Inter-segmental
12
15
(203)
176
Total
4,445
816
4,838
330
10,429
Year ended 31 December 2020 (1)
Continuing operations
External
4,157
700
5,960
(414)
10,403
Inter-segmental
24
63
(382)
295
Total
4,181
763
5,578
(119)
10,403
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
321
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
4 Segmental analysis continued
Analysis of net fees and commissions
Retail Banking
Private Banking
Commercial
&
Institutional
Central items &
other
Total
2022
£m
£m
£m
£m
£m
Continuing operations
Fees and commissions receivable
- Payment services
314
25
642
43
1,024
- Credit and debit card fees
401
15
227
18
661
- Lending and financing
17
8
673
3
701
- Brokerage
43
6
44
93
- Investment management, trustee
and fiduciary services
(3)
4
219
46
269
- Underwriting fees
120
120
- Other
3
88
(44)
47
Total
779
276
1,840
20
2,915
Fees and commissions payable
(357)
(26)
(260)
20
(623)
Net fees and commissions
422
250
1,580
40
2,292
2021 (1)
Continuing operations
Fees and commissions receivable
- Payment services
306
35
577
49
967
- Credit and debit card fees
344
10
149
19
522
- Lending and financing
13
10
643
4
670
- Brokerage
48
6
42
96
- Investment management, trustee
and fiduciary services
(3)
3
230
45
2
280
- Underwriting fees
127
127
- Other
35
109
(112)
32
Total
714
326
1,692
(38)
2,694
Fees and commissions payable
(337)
(68)
(252)
83
(574)
Net fees and commissions
377
258
1,440
45
2,120
2020 (1)
Fees and commissions receivable
- Payment services
264
28
543
41
876
- Credit and debit card fees
299
9
131
21
460
- Lending and financing
42
7
625
2
676
- Brokerage
54
6
94
1
155
- Investment management, trustee
and fiduciary services
3
225
41
2
271
- Underwriting fees
183
183
- Other
1
26
89
(33)
83
Total
663
301
1,706
34
2,704
Fees and commissions payable
(284)
(44)
(403)
9
(722)
Net fees and commissions
379
257
1,303
43
1,982
2022
2021
2020
Assets
Liabilities
Assets
Liabilities
Assets
Liabilities
£m
£m
£m
£m
£m
£m
Retail Banking
226,375
192,282
209,973
192,715
197,618
178,617
Private Banking
29,867
41,491
29,854
39,388
26,206
32,457
Commercial & Institutional
404,817
383,768
425,718
411,757
491,544
460,338
Central items & other
58,994
66,016
116,447
96,329
84,123
84,255
Total
720,053
683,557
781,992
740,189
799,491
755,667
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
322
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
4 Segmental analysis continued
Segmental analysis of goodwill
The total carrying value of goodwill at 31 December 2022 and 2021 was £5,522 million comprising Retail Banking £2,607 million;
Commercial & Institutional £2,906 million; and Private Banking £9 million. See note 17 for further details.
Geographical segments
The geographical analysis in the tables below has been compiled on the basis of location of office where the transactions are
recorded.
UK
USA
Europe
RoW
Total
2022
£m
£m
£m
£m
£m
Continuing operations
Total revenue
15,795
117
558
104
16,574
Interest receivable
12,242
37
344
14
12,637
Interest payable
(2,567)
(2)
(221)
(5)
(2,795)
Net fees and commissions
1,983
44
207
58
2,292
Trading income
1,208
1
(104)
28
1,133
Other operating income
(140)
14
12
3
(111)
Total income
(4)
12,726
94
238
98
13,156
Operating profit/(loss) before tax
5,716
(46)
(620)
82
5,132
Total assets
589,758
25,979
101,164
3,152
720,053
Total liabilities
579,476
27,039
75,092
1,950
683,557
Contingent liabilities and commitments
117,915
8,649
17
126,581
2021 (1)
Continuing operations
Total revenue
12,100
87
482
33
12,702
Interest receivable
8,949
20
257
8
9,234
Interest payable
(1,483)
(2)
(211)
(3)
(1,699)
Net fees and commissions
1,820
27
231
42
2,120
Trading income
247
53
(1)
24
323
Other operating income
387
2
62
451
Total income
(4)
9,920
100
338
71
10,429
Operating profit/(loss) before tax
4,143
48
(387)
40
3,844
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
551
174
13,447
Interest receivable
9,479
210
22
9,711
Interest payable
(2,163)
(158)
(1)
(2,322)
Net fees and commissions
1,637
33
215
97
1,982
Trading income
911
170
33
11
1,125
Other operating income
(117)
(22)
42
4
(93)
Total income
(4)
9,747
181
342
133
10,403
Operating (loss)/profit before tax
(193)
(85)
(363)
88
(553)
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
(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 receivable, income from trading activities and other operating income.
(3)
Comparisons with prior periods are impacted by the transfer of the Private Client Advice business to Private Banking from 1 January 2021.
(4)
Total income excludes internal service fee income which has been calculated on a cost plus mark-up basis.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
323
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 defined contribution schemes
invest contributions in a choice of funds and the accumulated contributions and investment returns are used by the employee to
provide benefits on retirement, there is no legal or constructive obligation for NatWest Group to pay any further contributions or
benefits. The defined benefit schemes provide pensions in retirement based on employees’ pensionable salary and service.
NatWest Group’s balance sheet includes any defined benefit
pension scheme surplus or deficit as a retirement benefit asset
or liability reported in other assets and other liabilities. The
surplus or deficit is the difference between the liabilities to be
paid from the defined benefit scheme, and the assets held by
the scheme to meet these liabilities. The liabilities are calculated
by external actuaries using a number of financial and
demographic assumptions.
For some NatWest Group defined benefit schemes where there
is a net defined benefit surplus in excess of the present value of
any economic benefits that can be obtained from that surplus,
the application of accounting standards means we do not
recognise that surplus on the balance sheet.
For accounting policy information see Accounting policies note
3.3.
Defined contribution schemes
NatWest Group sponsors several defined contribution schemes
in different territories, which new employees are entitled to join.
NatWest Group pays specific contributions into individual
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 NatWest
Group Pension Fund (the Main section) which operates under
UK trust law and is managed and 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 each fund and
ensure benefits are paid in accordance with the scheme rules
and national law. The trustees are the legal owner of a
scheme’s assets, and have a duty to act in the best interests of
all scheme members.
The schemes generally provide a pension of one-sixtieth of final
pensionable salary for each year of service prior to retirement
up to a maximum of 40 years and are contributory for current
members. These have been closed to new entrants for over ten
years, although active members continue to build up additional
pension benefits, currently subject to 2% maximum annual
salary inflation, while they remain employed by NatWest 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 Board of the
Trustee comprises four member trustee directors selected from
eligible active staff, deferred and pensioner members who
apply and six appointed by NatWest Group. Under UK
legislation, a defined benefit pension scheme is required to
meet the statutory funding objective of having sufficient and
appropriate assets to cover its liabilities (the pensions that have
been promised to members).
Similar governance principles apply to NatWest Group’s other
defined benefit pension schemes.
Investment strategy
The assets of the Main section, which is typical of other group
schemes, represent 91% of all plan assets at 31 December 2022
(2021 - 90%) and are invested as shown below.
The Main section employs physical, derivative and non-
derivative instruments to achieve a desired asset class
exposure and to reduce the section’s interest rate, inflation,
and currency risk. This means that the net funding position is
considerably less sensitive to changes in market conditions
than the value of the assets or liabilities in isolation. In
particular, movements in interest rate and inflation are
substantially hedged by the Trustee.
Over the year, increases in bond yields resulted in many
pension schemes in the UK having to raise additional collateral
to support Liability-driven investments positions held as part of
their hedging strategies. Liability-driven investments (LDI) refer
to assets that are expected to move broadly in line with
liabilities on a specific basis. All of the Group’s schemes
affected by this were able to raise the collateral needed from
existing assets, with no additional support from the Group. The
Trustee of the Group Pension Fund takes a prudent approach
to liquidity and collateral and holds sufficient collateral to
withstand substantial rises in gilt yields. The level of collateral
held by some of the Group’s smaller schemes was increased
over the year, so as to ensure they could withstand further
large rises in gilt yields if required.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
324
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
5 Pensions continued
2022
2021
Quoted
Unquoted
Total
Quoted
Unquoted
Total
Major classes of plan assets as a percentage of
total plan assets of the Main section
%
%
%
%
%
%
Equities
0.1
7.7
7.8
3.7
4.7
8.4
Index linked bonds
37.7
37.7
46.7
46.7
Government bonds
18.4
18.4
9.8
9.8
Corporate and other bonds
15.3
6.7
22.0
10.7
4.4
15.1
Real estate
6.0
6.0
4.4
4.4
Derivatives
8.2
8.2
8.8
8.8
Cash and other assets
(0.1)
(0.1)
6.8
6.8
71.5
28.5
100.0
70.9
29.1
100.0
The Main section’s holdings of derivative instruments are summarised in the table below:
2022
2021
Fair value
Fair value
Notional
am
ounts
Assets
Liabilities
Notional
amounts
Assets
Liabilities
£bn
£m
£m
£bn
£m
£m
Inflation rate swaps
21
1,873
990
20
1,408
796
Interest rate swaps
103
14,317
12,546
172
8,385
4,421
Currency forwards
12
310
113
12
61
98
Equity and bond call options
1
Equity and bond put options
2
70
1
3
Other
1
14
19
1
9
10
Swaps have been executed at prevailing market rates and within standard market bid/offer spreads with a number of
counterparties, including NWB Plc.
At 31 December 2022, the gross notional value of the swaps was £124 billion (2021 - £192 billion) and had a net positive fair value
of £2,642 million (2021 - £4,573 million) against which the counterparties had posted approximately 112% collateral.
The schemes do not invest directly in NatWest Group but may have exposure to NatWest Group through indirect holdings. The
trustees of the respective UK schemes are responsible for ensuring that indirect investments in NatWest Group do not exceed the
regulatory limit of 5% of plan assets.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
325
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
5 Pensions continued
Main section
All schemes
Fair value
of plan
assets
Present value
of defined
benefit
obligation (1)
Asset
ceiling/minimu
m funding
Net pension
assets/(liability)
Fair value of
plan assets
Present vlaue
of defined
benefit (2)
Asset
ceiling/minimu
m funding
Net pension
assets (2)
Changes in value of net pension
assets/(liability)
£m
£m
£m
£m
£m
£m
£m
£m
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 - operating expenses
713
(767)
(105)
(159)
795
(901)
(109)
(215)
Other comprehensive income
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 settlement
Benefits paid
(1,569)
1,569
(1,793)
1,793
At 1 January 2022
52,021
(42,020)
(10,001)
57,787
(46,808)
(10,491)
488
Currency translation and other adjustments
78
(65)
(11)
2
Income statement - operating expenses
Net interest expense
932
(744)
(180)
8
1,041
(834)
(191)
16
Current service cost
(143)
(143)
(194)
(194)
Past service cost
(5)
(5)
(6)
(6)
Loss on curtailments and settlements
(21)
(21)
932
(892)
(180)
(140)
1,041
(1,055)
(191)
(205)
Other comprehensive income
Return on plan assets excluding
recognised interest income
(3)
(18,180)
(18,180)
(20,326)
(20,326)
Experience gains and losses
(2,053)
(2,053)
(2,137)
(2,137)
Effect of changes in actuarial
financial assumptions
(3)
18,744
18,744
20,714
20,714
Effect of changes in actuarial
demographic assumptions
23
23
(7)
(7)
Asset ceiling adjustments
898
898
916
916
(18,180)
16,714
898
(568)
(20,326)
18,570
916
(840)
Contributions by employer
708
708
775
775
Contributions by plan participants and
other scheme members
7
(7)
13
(13)
Assets/liabilities extinguished upon settlement
(113)
113
Benefits paid
(1,472)
1,472
(1,657)
1,657
At 31 December 2022
34,016
(24,733)
(9,283)
37,598
(27,601)
(9,777)
220
(1)
Defined benefit obligations are subject to annual valuation by independent actuaries.
(2)
NatWest Group recognises the net pension 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 requirement 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)
Changes in market conditions during 2022 resulted in a particularly large increase in discount rate, which is the key driver of the effect of changes in actuarial financial assumptions.
Given the level of hedging in place, there was a corresponding reduction in the value of plan assets over the period. The experience losses shown are mainly as a result of inflation
over the year being higher than expected.
(4)
NatWest Group expects to make contributions to the Main section of £196 million in 2023. In 2022 NatWest Group made contributions of £708m to the Main scheme, including a
£500m contribution paid in two instalments in January and March 2022 as required by the ring-fencing agreement 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 shareholders.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
326
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
5 Pensions continued
All schemes
2022
2021
Amounts recognised on the balance sheet
£m
£m
Fund asset at fair value
37,598
57,787
Present value of fund liabilities
(27,601)
(46,808)
Funded status
9,997
10,979
Assets ceiling/minimum funding
(9,777)
(10,491)
220
488
2022
2021
Net pension assets/(liability) comprises
£m
£m
Net assets of schemes in surplus (included in Other assets, Note 18)
318
602
Net liabilities of schemes in deficit (included in Other liabilities, Note 21)
(98)
(114)
220
488
Funding and contributions by NatWest Group
In the UK, the trustees of defined benefit pension schemes are
required to perform funding valuations every three years. The
trustees and the sponsor, with the support of the Scheme
Actuary, agree the assumptions used to value the liabilities and
to determine future contribution requirements. The funding
assumptions incorporate a margin for prudence over and
above the expected cost of providing the benefits promised to
members, taking into account the sponsor’s covenant and the
investment strategy of the scheme. Similar arrangements apply
in the other territories where NatWest Group sponsors defined
benefit pension schemes.
A full triennial funding valuation of the Main section, effective
31 December 2020, was completed during financial year 2021.
This triennial funding valuation determined the funding level to
be 104%, pension liabilities to be £49 billion and the surplus to
be £2 billion, all assessed on the agreed funding basis. 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 meet administrative expenses.
Following the ring-fencing agreement with the Trustee reached
in 2018, additional contributions of up to £500 million p.a. are
payable to the Main section should the Group make
distributions to shareholders of an equal amount.
These contributions are capped at £1.5 billion in total; £500
million was paid in 2022 (2021 – £500 million). The remaining
distribution linked contribution to the Main section would have
fallen due in 2023, but NatWest Bank has agreed with the
Trustee that assets to the value of the contributions falling due
will instead be paid to a new legal structure. These assets will
be restricted and are reserved to ensure they are available
should they be needed by the Trustee according to agreed
criteria in the future. The assets under this arrangement would
be available to the Group to the extent that they are not
needed under the defined trigger events.
The key assumptions used to determine the funding liabilities
were the discount rate, which is determined based on fixed
interest swap and gilt yields plus 0.64% per annum, and
mortality assumptions, which result in life expectancies of
27.7/29.4 years for males/females 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 Group Pension Fund
included an allowance for the estimated impact of guaranteed
minimum pension equalisation, which is reflected in the IAS 19
valuation at 31 December 2022.
Accounting Assumptions
Placing a value on NatWest Group’s defined benefit pension
schemes’ liabilities requires NatWest Group’s management to
make a number of assumptions, with the support of
independent actuaries. The ultimate cost of the defined benefit
obligations depends upon actual future events and the
assumptions made are unlikely to be exactly borne out in
practice, meaning the final cost may be higher or lower than
expected.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
327
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
5 Pensions continued
The most significant assumptions used for the Main section are shown below:
Principal IAS 19 actuarial assumptions
(1)
2022
2021
%
%
Discount rate
5.0
1.8
Inflation assumption (RPI)
3.2
3.3
Rate of increase in salaries
1.8
1.8
Rate of increase in deferred pensions
3.2
3.7
Rate of increase in pensions in payment
2.5
2.5
Lump sum conversion rate at retirement
18
18
Longevity at age 60:
years
years
Current pensioners
Males
27.3
27.3
Females
29.1
29.0
Future pensioners, currently aged 40
Males
28.3
28.2
Females
30.1
30.1
(1)
The above financial assumptions are long term assumptions set with reference to the period over which the obligations are expected to be settled
Discount rate
The IAS 19 valuation uses a single discount rate set by reference to the yield on a basket of ‘high quality’ sterling corporate bonds.
Significant judgment is required when setting the criteria for bonds to be included in the basket of bonds that is used to determine
the discount rate used in the IAS 19 valuations. The criteria include issue size, quality of pricing and the exclusion of outliers.
Judgment is also required in determining the shape of the yield curve at long durations; a constant credit spread relative to gilts is
assumed. Sensitivity to the main assumptions is presented below.
The weighted average duration of the Main section’s defined benefit obligation at 31 December 2022 is 15.3 years (2021 – 20
years). The chart below shows the projected benefit payment pattern for the Main section in nominal terms. These cashflows are
based on the most recent formal actuarial valuation, effective 31 December 2020.
The larger outflow in 2023 represents an assumption in the actuarial valuation of the level of transfers out to 31 December 2023.
0
500
1000
1500
2000
2500
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
Pensioner
Non pensioner
Expected Cashflows (£m)
Year
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
328
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
5 Pensions continued
The table below shows how the net pension asset of the Main section would change if the key assumptions used were changed
independently. In practice the variables have a degree of correlation and do not move completely in isolation.
(Decrease)/increase
in value of assets
(Decrease)/increase
in value of liabilities
Increase in net
pension
(obligations)/assets
2022
£m
£m
£m
0.25% increase in interest rates/discount rate
(2)
(1,389)
(907)
(482)
0.25% increase in inflation
963
632
331
0.25% increase in credit spreads
(3)
(907)
904
Longevity increase of one year
767
(767)
0.25% additional rate of increase in pensions in payment
679
(679)
Increase in equity values of 10%
(1)
267
267
2021
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
(1)
Includes both quoted and private equity.
(2)
A 0.5% increase in interest rates/discount rate would lead to a decrease of £2,689m in the value of assets and a £1,766m decrease in the value of liabilities at 31 December 2022.
The funded status is most sensitive to movements in credit spreads and longevity. Note the longevity sensitivities quoted above
reflect the impact of a one year increase to single life annuities. The table below shows the combined change in the funded status
of the Main section as a result of larger movements in these assumptions, assuming no changes in other assumptions.
Change in life expectancies
- 2 years
- 1 years
No change
+ 1 year
+ 2 years
2022
£bn
£bn
£bn
£bn
£bn
Change in credit spreads
+50 bps
3.2
2.5
1.8
1.1
0.4
No change
1.6
0.8
(0.8)
(1.5)
-50 bps
(0.3)
(1.2)
(2.0)
(2.8)
(3.6)
2021
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)
The defined benefit obligation of the Main section is attributable to the different classes of scheme members in the following
proportions:
2022
2021
Membership category
%
%
Active members
8.4
10.7
Deferred members
41.0
47.6
Pensioners and dependants
50.6
41.7
100.0
100.0
The experience history of NatWest Group schemes is shown below:
Main section
All schemes
2022
2021
2020
2019
2018
2022
2021
2020
2019
2018
History of defined benefit schemes
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Fair value of plan assets
34,016
52,021
51,323
46,555
43,806
37,598
57,787
57,249
51,925
48,752
Present value of plan obligations
(24,733)
(42,020)
(43,870)
(39,669)
(35,466)
(27,601)
(46,808)
(48,864)
(44,115)
(39,607)
Net surplus
9,283
10,001
7,453
6,886
8,340
9,997
10,979
8,385
7,810
9,145
Experience (losses)/gains on plan
liabilities
(2,053)
241
427
275
(122)
(2,137)
237
455
279
(81)
Experience (losses)/gains on plan
assets
(18,180)
841
5,486
3,021
(1,891)
(20,326)
872
6,027
3,556
(2,090)
Actual return on plan assets
(17,248)
1,554
6,422
4,266
(768)
(19,285)
1,667
7,064
4,930
(848)
Actual return on plan assets
(33.2%)
3.0%
13.8%
9.7%
(1.7%)
(33.4%)
2.9%
13.6%
10.1%
(1.7%)
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
329
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
6 Auditor’s remuneration
Amounts payable to NatWest Group's auditors for statutory audit and other services are set out below.
All audit-related and other services are approved by the Group Audit Committee and are subject to strict controls to ensure the
external auditor’s independence is unaffected by the provision of other services. The Group Audit Committee recognises that for
certain assignments, the auditors are best placed to perform the work economically; for other work, NatWest Group selects the
supplier best placed to meet its requirements. NatWest Group’s auditors are permitted to tender for such work in competition with
other firms where the work is permissible under audit independence rules.
2022
2021
2020
£m
£m
£m
Fees payable for:
- the audit of NatWest Group’s annual accounts
(1)
4.7
4.4
4.7
- the audit of NatWest Group plc’s subsidiaries
(1)
31.9
29.6
30.6
- audit-related assurance services
(1,2)
3.9
5.3
4.7
Total audit and audit-related assurance services fees
40.5
39.3
40.0
Other assurance services
1.2
0.4
0.6
Corporate finance services
(3)
0.5
0.5
0.4
Total other services
1.7
0.9
1.0
(1)
The 2022 audit fee was approved by the Group Audit Committee. At 31 December 2022, £16 million has been billed and £13 million paid in respect of the 2022 NatWest Group audit
fees.
(2)
Comprises fees of £1.1 million (2021 - £1.1 million) in relation to reviews of interim financial information, £2.3 million (2021 - £3.5 million) in respect of reports to NatWest Group’s
regulators in the UK and overseas, and £0.4 million (2021 - £0.7 million) in relation to non-statutory audit opinions.
(3)
Comprises fees of £0.5 million (2021 - £0.5 million) in respect of work performed by the auditors as reporting accountants on debt and equity issuances undertaken by NatWest
Group.
7 Tax
NatWest Group’s corporate income tax charge for the period is set out below, together with a reconciliation to the expected tax
charge calculated using the UK standard corporation tax rate and details of the NatWest Group’s deferred tax balances.
For accounting policy information see Accounting policies note 3.7.
Analysis of the tax charge for the year
The tax charge comprises current and deferred tax in respect of profits and losses recognised or originating in the income
statement. Tax on items originating outside the income statement is charged to other comprehensive income or direct to equity (as
appropriate) and is therefore not reflected in the table below.
Current tax is tax payable or recoverable in respect of the taxable profit or loss for the year and any adjustments to tax payable in
prior years. Deferred tax is explained on page 330.
2022
2021
2020
Continuing operations
£m
£m
£m
Current tax
Charge for the year
(1,611)
(1,036)
(191)
Over provision in respect of prior years
100
31
86
(1,511)
(1,005)
(105)
Deferred tax
Credit/(charge) for the year
47
(185)
176
UK tax rate change impact
(1)
(10)
165
75
Net increase/(decrease) in the carrying value of deferred tax assets in respect of UK,
RoI and Netherlands losses
267
12
(130)
(Under)/over provision in respect of prior years
(2)
(68)
17
(90)
Tax charge for the year
(1,275)
(996)
(74)
(1)
It was announced in the UK Government’s budget on 27 October 2021 that the main UK banking surcharge will decrease from 8% to 3% from 1 April 2023. This legislative change
was enacted on 24 February 2022.
(2)
Prior year tax adjustments incorporate refinements to tax computations made on submission and agreement with the tax authorities and adjustments to provisions in respect of
uncertain tax positions.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
330
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 profits reported in the income statement as certain amounts of income and expense may not be taxable
or deductible. In addition, taxable profits may reflect items that have been included outside the income statement (for instance, 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 corporation tax rate of 19% (2021 and 2020 – 19%)
to the Operating profit or loss before tax in the income statement.
The actual tax charge differs from the expected tax charge as follows:
2022
2021
2020
Continuing operations
£m
£m
£m
Expected tax (charge)/credit
(975)
(766)
92
Losses and temporary differences in year where no deferred tax asset recognised
(118)
(51)
(43)
Foreign profits taxed at other rates
(62)
(11)
(29)
Non deductible goodwill impairment
(16)
Items not allowed for tax:
- losses on disposals and write-downs
(10)
(55)
(22)
- UK bank levy
(20)
(18)
(32)
- regulatory and legal actions
(7)
(74)
14
- other disallowable items
(51)
(28)
(70)
Non-taxable items:
- RPI related uplift on index linked gilts
(1)
67
- other non-taxable items
29
73
28
Taxable foreign exchange movements
(19)
8
(3)
Unrecognised losses brought forward and utilised
6
10
16
Net increase/(decrease) in the carrying value of deferred tax assets in respect of:
- UK losses
272
(9)
7
- RoI losses
(5)
(27)
(137)
- Netherlands losses
48
Banking surcharge
(447)
(341)
(27)
Tax on paid-in equity dividends
43
48
61
UK tax rate change impact
(10)
165
75
Adjustments in respect of prior years
32
48
(4)
Actual tax charge
(1,275)
(996)
(74)
(1)
The tax impact of this adjustment (£135 million credit) is allocated across the RPI related uplift on index linked gilts, Adjustments in respect of prior years and Banking surcharge
reconciling items.
Judgment: tax contingencies
NatWest Group’s corporate income tax 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 computations are yet to be agreed with the
tax authorities in a number of jurisdictions. NatWest Group recognises anticipated tax liabilities based on all available evidence and,
where appropriate, in the light of external advice. Any difference between the final outcome and the amounts provided will affect
current and deferred income tax charges in the period when the matter is resolved.
Deferred tax
Deferred tax is the tax expected to be payable or recoverable in respect of temporary differences where the carrying amount of
an asset or liability differs for accounting and tax purposes. Deferred tax liabilities reflect the expected amount of tax payable in
the future on these temporary differences. Deferred tax assets reflect the expected amount of tax recoverable in the future on
these differences.
The net deferred tax asset recognised by the NatWest Group is shown below, together with details of the accounting judgments
and tax rates that have been used to calculate the deferred tax. Details are also provided of any deferred tax assets or liabilities
that have not been recognised on the balance sheet.
Analysis of deferred tax
£m
£m
Deferred tax asset
(2,178)
(1,195)
Deferred tax liability
227
359
Net deferred tax asset
(1,951)
(836)
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
331
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
7 Tax continued
Pension
Accelerated
capital
allowances
Expense
provisions
Financial
instruments (1)
Tax losses
carried forward
Other
Total
£m
£m
£m
£m
£m
£m
£m
At 1 January 2021
(4)
(64)
(85)
480
(905)
(32)
(610)
Charge/(credit) to income statement:
- continuing operations
19
21
(5)
(10)
(1)
(33)
(9)
- discontinued operations
3
3
Charge/(credit) to other comprehensive income
10
(7)
(222)
(5)
(224)
Currency translation and other adjustments
(1)
1
4
4
At 1 January 2022
24
(42)
(97)
248
(899)
(70)
(836)
Charge/(credit) to income statement:
- continuing operations
1
(43)
14
(171)
(51)
14
(236)
- discontinued operations
(Credit)/charge to other comprehensive income
(2)
1
(913)
(2)
(916)
Currency translation and other adjustments
10
31
(2)
(2)
37
At 31 December 2022
23
(75)
(82)
(805)
(952)
(60)
(1,951)
(1)
The in-year movement predominantly relates to cash flow hedges.
Deferred tax assets in respect of carried forward tax losses are recognised if the losses can be used to offset probable future
taxable profits after taking into account the expected reversal of other temporary differences. Recognised deferred tax assets in
respect of tax losses are analysed further below.
2022
2021
£m
£m
UK tax losses carried forward
- NWM Plc
3
56
- NWB Plc
445
608
- RBS plc
452
176
Total
900
840
Overseas tax losses carried forward
- UBIDAC
6
11
- NWM N.V.
46
48
952
899
Critical accounting policy: Deferred tax
NatWest Group has recognised a deferred tax asset of £2,178
million (2021 - £1,195 million) and a deferred tax liability of £227
million (2021 - £359 million). These include amounts recognised
in respect of UK and overseas tax losses of £952 million (2021 -
£899 million).
It was announced in the UK Government’s budget on 27
October 2021 that the UK banking surcharge will decrease from
8% to 3% from 1 April 2023. This legislative change was enacted
on 24 February 2022. NatWest Group’s closing deferred tax
assets and liabilities have therefore been recalculated taking
into account this change of rate and the applicable period the
deferred tax assets and liabilities are expected to crystallise.
Judgment
-
NatWest Group has considered the carrying value of
deferred tax assets and concluded that, based on
management’s estimates, sufficient taxable profits will be
generated in future years to recover recognised deferred tax
assets.
Estimate
- These estimates are partly based on forecast
performance beyond the horizon for management’s detailed
plans. They have regard to inherent uncertainties, such as
climate change. The deferred tax assets in NWM Plc and
UBIDAC are supported by way of future reversing taxable
temporary differences on which deferred tax liabilities are
recognised at 31 December 2022
.
UK tax losses
Under UK tax rules, tax losses can be carried forward
indefinitely. As the recognised tax losses in NatWest Group
arose prior to 1 April 2015, credit in future periods is given
against 25% of profits at the main rate of UK corporation tax,
excluding the Banking Surcharge rate introduced by The
Finance (No. 2) Act 2015.
NWM Plc
– A deferred tax asset of £3 million (2021 - £56 million)
has been recognised in respect of losses of £12 million, and is
now entirely supported by way of future reversing taxable
temporary differences on which deferred tax liabilities are
recognised at 31 December 2022. NWM Plc expects that the
balance of recognised deferred tax asset at 31 December 2022
will be recovered by the end of 2027. Of the losses remaining,
£5,538 million have not been recognised in the deferred tax
balance at 31 December 2022.
NWB Plc
– A deferred tax asset of £445 million (2021 - £608
million) has been recognised in respect of losses of £1,847
million of total losses of £2,718 million carried forward at 31
December 2022. The losses arose principally as a result of
significant impairment and conduct charges between 2009 and
2012 during challenging economic conditions in the UK banking
sector. NWB Plc returned to tax profitability during 2015 and
expects the deferred tax asset to be utilised against future
taxable profits by the end of 2027.
RBS plc
– A deferred tax asset of £452 million (2021 - £176
million) has been recognised in respect of losses of £1,821
million of total losses of £3,692 million carried forward at 31
December 2022. The losses were transferred from NatWest
Markets Plc as a consequence of the ring fencing regulations.
RBS plc expects the deferred tax asset to be utilised against
future taxable profits by the end of 2029.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
332
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
7 Tax continued
Overseas tax losses
UBIDAC
A deferred tax asset of £6 million (2021 - £11 million)
has been recognised in respect of losses of £48 million, and is
now entirely supported by way of future reversing taxable
temporary differences on which deferred tax liabilities are
recognised at 31 December 2022.
NatWest Market N.V. (NWM N.V.)
A deferred tax asset of £46
million (2021 - £48 million) has been recognised in respect of
losses of £186 million of total losses of £2,914 million carried
forward at 31 December 2022. NWM N.V. Group considers it to
be probable, based on its 5 year budget forecast, that future
taxable profit will be available against which the tax losses and
tax credits can be partially utilised. The tax losses and the tax
credits have no expiry date.
Unrecognised deferred tax
Deferred tax assets of £5,534 million (2021 - £5,437 million;
2020 - £4,965 million) have not been recognised in respect of
tax losses and other deductible temporary differences carried
forward of £25,742 million (2021 - £24,699 million; 2020 -
£25,091 million) in jurisdictions where doubt exists over the
availability of future taxable profits. Of these losses and other
deductible temporary differences, £75 million expire within five
years and £4,774 million thereafter. The balance of tax losses
and other deductible temporary differences carried forward has
no expiry date.
Deferred tax liabilities of £257 million (2021 - £302 million; 2020
- £242 million) on aggregate underlying temporary differences
of £1,010 million (2021 - £1,032 million; 2020 £1,021 million)
have not been recognised in respect 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 further taxation. No taxation is
expected to arise in the foreseeable future in respect of held-
over gains on which deferred tax is not recognised. Changes to
UK tax legislation largely exempts from UK tax overseas
dividends received on or after 1 July 2009.
Notes to the consolidated financial statements
continued
NatWest Group
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Additional information
Financial review
8 Discontinued operations and assets and liabilities of disposal groups
Discontinued operations are reported separately on the income statement to allow users to distinguish 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 are also presented separately on the balance sheet.
For accounting policy information see Accounting policies note 3.2.
This note sets out the profit/(loss) from the discontinued operations (represented for comparative periods), the assets and liabilities
of the disposal group and the operating cash flows attributable to the discontinued operations.
Three legally binding agreements for the sale of UBIDAC business have been announced as part of the phased withdrawal from
the Republic of Ireland. Material developments since the beginning of 2022 are set out below.
Agreement with Allied Irish Banks, p.l.c. (AIB) for the transfer of performing commercial loans.
Successful migration of six tranches of performing commercial loans to AIB was completed during 2022, with €2.1 billion of gross
performing loans being fully migrated by year-end. It is expected that remaining migrations of commercial customers will be
materially completed in phases over H1 2023. Colleagues who are wholly or mainly assigned to supporting this part of the business
are in the process of getting transferred to AIB under Transfer of Undertakings, Protection of Employment (TUPE) arrangements,
with more than half having completed their move by the end of 2022. Losses on disposal of €123 million have been recognised in
2022 in respect of the migrations completed to date.
Agreement with Permanent TSB Group Holdings p.l.c. (PTSB) for the sale of performing non-tracker mortgages, the
performing loans in the micro-SME business, the UBIDAC Asset Finance business, including its Lombard digital platform,
and 25 Ulster Bank branch locations in the Republic of Ireland.
c.€5 billion of performing non-tracker mortgages migrated to PTSB in November 2022, with the remaining balances expected to
migrate during H1 2023. In January 2023, 25 branches transferred to PTSB. The remaining performing non-tracker mortgages,
micro-SME loans, Lombard Asset Finance business and all remaining eligible colleagues who will move under TUPE regulations,
are also expected to transfer in 2023.
Agreement with AIB for the sale of performing tracker and linked mortgages.
In January 2023 the Competition and Consumer Protection Commission (CCPC) granted approval on the portfolio sale of
performing tracker and linked mortgages to AIB. Completion of this sale is expected to occur in Q2 2023.
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. Comparatives have been re-presented from those previously published to reclassify certain items as
discontinued operations. This has resulted in a re-presentation of 2021 comparatives: a reduction of Operating profit before tax
and Profit from continuing operations of £188 million, and an increase of Profit from discontinued operations of £188 million.
Total
profit for the year remains unchanged. Ulster Bank RoI continuing operations are now reported within Group central items & other.
In 2022 we reclassified mortgage loans to fair value through profit or loss, which resulted in a €453 million reduction in mortgage
financial assets in UBIDAC to 31 December 2022. This reclassification applies across both our continuing and discontinued
operations.
(a) (Loss)/profit from discontinued operations, net of tax
2022
2021
2020
£m
£m
£m
Interest receivable
177
339
360
Net interest income
177
339
360
Non-interest income
(1)
(472)
13
33
Total income
(295)
352
393
Operating expenses
(38)
(47)
(47)
(Loss)/profit before impairment releases/(losses)
(333)
305
346
Impairment releases/(losses)
71
162
(144)
Operating (loss)/profit before tax
(262)
467
202
Tax charge
(3)
(9)
(Loss)/profit from discontinued operations, net of tax
(262)
464
193
(1)
Excludes gain of £20 million (€24 million) recognised by NatWest Group as a result of acquisition of PTSB shares in relation to disposal of UBIDAC assets to PTSB.
(b) Assets and liabilities of disposal groups
2022
2021
£m
£m
Assets of disposal groups
Loans to customers - amortised cost
1,458
9,002
Other financial assets - loans to customers
5,397
Derivatives
5
Other assets
6
8
6,861
9,015
Liabilities of disposal groups
Other liabilities
15
5
15
5
Net assets of disposal groups
6,846
9,010
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
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Additional information
Financial review
8 Discontinued operations and assets and liabilities of disposal groups continued
(c) Operating cash flows attributable to discontinued operations
2022
2021
2020
£m
£m
£m
Net cash flows from operating activities
1,090
2,212
(816)
Net cash flows from investing activities
6,164
Net increase/(decrease) in cash and cash equivalents
7,254
2,212
(816)
9 Earnings per share
Earnings per share is a metric to measure how much profit NatWest Group makes for each share that is in issue during the
year.
Basic earnings per ordinary share is calculated by dividing the profit attributable to ordinary shareholders by the weighted
average number of ordinary shares outstanding. Diluted earnings per ordinary share is calculated by dividing the basic earnings by
the weighted average number of ordinary shares outstanding plus the weighted average number of ordinary shares that would be
issued on conversion of dilutive share options and convertible securities. The assessment of whether the effect of share options and
convertible securities is dilutive or not, is based on the earnings from continuing operations.
2022
2021
2020
£m
£m
£m
Earnings
Profit/(loss) from continuing operations attributable to ordinary shareholders
3,602
2,486
(946)
(Loss)/profit from discontinued operations attributable to ordinary shareholders
(262)
464
193
Profit/(loss) attributable to ordinary shareholders
3,340
2,950
(753)
Weighted average number of shares (millions)
Weighted average number of ordinary shares outstanding during the year
9,872
10,792
11,231
Effect of dilutive share options and convertible securities
(1)
57
45
Diluted weighted average number of ordinary shares outstanding during the year
9,929
10,837
11,231
(1)
As there was a loss from continuing operations attributable to the parent company for the period to 31 December 2020, the effect of share options and convertible securities was
not dilutive.
(2)
At the General Meeting and Class Meeting on 25 August 2022, the shareholders approved the proposed special dividend and share consolidation. On 30 August 2022 the issued
ordinary share capital was consolidated in the ratio of 14 existing shares for 13 new shares. The average number of shares and earnings per share have been adjusted
retrospectively.
10 Financial instruments – classification
Financial instruments are contracts that give rise to a financial asset of one entity and a corresponding financial liability or equity
instrument of a counterparty entity, such as: cash; derivatives; loans; deposits; and settlement balances.
This note presents
financial instruments classified in accordance with IFRS 9 – Financial Instruments.
Judgment: classification of financial assets
Classification of financial assets between amortised cost and fair value through other comprehensive income requires a degree of
judgment in respect of business models and contractual cashflows.
The business model criteria is assessed at a portfolio level to determine whether assets are classified as held to collect or held
to collect and sell. Information that is considered in determining the applicable business model includes the portfolio’s policies
and objectives, how the performance and risks of the portfolio are managed, evaluated and reported to management; and the
frequency, volume and timing of sales in prior periods, sales expectation for future periods, and the reasons for sales.
The contractual cash flow characteristics of financial assets are assessed with reference to whether the cash flows represent
solely payments of principal and interest. A level of judgment is made in assessing terms that could change the contractual
cash flows so that it would not meet the condition for solely payments of principal and interest, including contingent and
leverage features,
non
-recourse arrangements and features that could modify the time value of money.
We originate loans that include features that change the contractual cash flows based on the borrower meeting certain
contractually specified environmental, social and governance (ESG) targets. These are known as ESG-linked (or sustainability-
linked) loans. As part of the terms of these loans, the contractual interest rate is reduced or increased if the borrower meets (fails
to meet) specific targets linked to the activity of the borrower for example reducing carbon emissions, increase the level of
diversity at Board level, sustainable supply chain, etc. ESG features are first assessed to ascertain whether the adjustment to the
contractual cash flows results in a de minimis exposure to risks or volatility in those contractual cash flows. If this is the case the
classification of the loan is not affected. If the effect of the ESG feature is assessed as being more than de minimis, we apply
judgement to ensure that the ESG features do not generate compensation for risks that are not in line with a basic lending
arrangement. This includes amongst other aspects a review of the consistency of the ESG targets with the asset or activity of the
borrower, consideration of the targets within our risk appetite etc. Some of these loans are an integral part of our climate and
sustainable funding and financing target disclosed on page 25.
For accounting policy information see Accounting policies notes 3.8, 3.9, 3.10 and 3.12.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
335
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
10 Financial instruments - classification continued
Judgment: classification of financial assets
The following tables analyse financial assets and liabilities in accordance with the categories of financial instruments in IFRS 9.
MFVTPL
FVOCI
Amortised cost
Other assets
Total
Assets
£m
£m
£m
£m
£m
Cash and balances at central banks
144,832
144,832
Trading assets
45,577
45,577
Derivatives
(1)
99,545
99,545
Settlement balances
2,572
2,572
Loans to bank - amortised cost
(2)
7,139
7,139
Loans to customers - amortised cost
(3)
366,340
366,340
Other financial assets
(4)
787
16,973
13,135
30,895
Intangible assets
7,116
7,116
Other assets
9,176
9,176
Assets of disposal groups
(5)
6,861
6,861
31 December 2022
145,909
16,973
534,018
23,153
720,053
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
Held-for-trading
DFV
Amortised cost
Other liabilities
Total
Liabilities
£m
£m
£m
£m
£m
Bank deposits
(6)
20,441
20,441
Customer deposits
450,318
450,318
Settlement balances
2,012
2,012
Trading liabilities
52,808
52,808
Derivatives
(1)
94,047
94,047
Other financial liabilities
(7)
2,377
46,730
49,107
Subordinated liabilities
345
5,915
6,260
Notes in circulation
3,218
3,218
Other liabilities
(8)
1,205
4,141
5,346
31 December 2022
146,855
2,722
529,839
4,141
683,557
Bank deposits
(6)
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
(7)
1,671
47,655
49,326
Subordinated liabilities
703
7,726
8,429
Notes in circulation
3,047
3,047
Other liabilities
(8)
1,356
4,441
5,797
31 December 2021
165,433
2,374
567,941
4,441
740,189
(1)
Includes net hedging derivatives assets of £143 million (2021 - £44 million) and net hedging derivatives liabilities of £132 million (2021 - £120 million).
(2)
Includes items in the course of collection from other banks of £229 million (2021 - £67 million).
(3)
Includes finance lease receivables of £8,402 million (2021 - £8,531 million).
(4)
Includes amounts reclassified from amortised cost to FVTPL in relation to a mortgage portfolio. Refer to Note 8 for further information.
(5)
Includes £5,397 million of assets of disposal groups reclassified from amortised cost to FVTPL during the year. The portfolio is classified as level 3 in the fair value hierarchy.
(6)
Includes items in the course of transmission to other banks of £242 million (2021 - £56 million).
(7)
The carrying amount of other customer accounts designated 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.
(8)
Includes lease liabilities of £1,118 million (2021 - £1,263 million) held at amortised cost.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
336
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
10 Financial instruments - classification continued
Reclassification of mortgages from amortised cost to fair value through profit or loss
In June 2022 UBIDAC announced the cessation of new mortgage business to its customers. On 1 July 2022 UBIDAC mortgages in
both its continuing and discontinued businesses were reclassified from amortised cost to fair value through profit or loss, reflecting
the change in business model. We fair value these assets using a discounted cash flow method. Key inputs include assumptions
around cash flows from legally binding sales agreements for those mortgage assets that form part of the assets of disposal groups.
The effect of the reclassification as at 1 July 2022 is shown below:
Amortised cost
MFVTPL
Change in value
£m
£m
£m
Amounts reclassified on balance sheet
Loans to customers
(1)
587
606
19
Assets of disposal groups
(2)
10,676
10,383
(293)
11,263
10,989
(274)
(1)
Change in value recognised in continuing operations.
(2)
Change in value recognised in discontinued operations.
Additional information on finance lease receivables
The following table shows the reconciliation of undiscounted finance lease receivables to net investment in finance leases:
2022
2021
£m
£m
Amount receivable under finance leases
Within 1 year
3,235
3,272
1 to 2 years
2,254
2,044
2 to 3 years
1,388
1,443
3 to 4 years
833
757
4 to 5 years
411
429
After 5 years
1,130
1,423
Lease payments total
9,251
9,368
Unguaranteed residual values
171
225
Future drawdowns
(13)
(21)
Unearned income
(889)
(891)
Present value of lease payments
8,520
8,681
Impairments
(118)
(150)
Net investment in finance leases
8,402
8,531
Additional information on reverse repos and repos
The following table shows the value of reverse repos and repos included within the below balance sheet captions:
2022
2021
£m
£m
Reverse repos
Trading assets
21,537
20,742
Loans to banks - amortised cost
277
189
Loans to customers - amortised cost
19,750
25,962
Repos
Bank deposits
1,446
7,912
Customer deposits
9,829
14,541
Trading liabilities
23,740
19,389
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
337
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
10 Financial instruments - classification continued
Interest rate benchmark reform
NatWest Group continues to work on the transition of USD IBOR exposures to risk free rates in advance of the cessation date of 30
June 2023. Derivatives are expected to transition during April and May 2023 and other exposures in line with fallback provisions or
deferred switches using widely accepted methodologies. The instruments yet to transition reflect an insignificant element of
NatWest Group’s exposures. Instruments with exposures to other rates transitioned at the end of 2021, or at the first contractual
reset date, or at a date agreed with the counterparty.
The level of exposures without explicit or agreed conversion provisions as of the preceding year were as follows:
Rates subject to IBOR reform
GBP LIBOR
USD IBOR
Other IBOR
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
Trading liabilities
31
166
197
Other financial liabilities
2,390
7,023
131
9,544
Subordinated liabilities
90
90
Loan commitments
(1)
1,016
6,366
55
7,437
Derivatives notional (£bn)
4
1,152
1,156
(1)
Certain loan commitments are multi-currency facilities. 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 allocated to the currency with the largest drawn amount.
At 31 December 2021, NatWest Group held certain currency swaps with both legs subject to IBOR reform, for which only the GBP
LIBOR leg has an explicit or agreed conversion 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 IBOR
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 Other IBOR of £0.4 billion with USD IBOR £0.4 billion
AT1 issuances
NatWest Group has issued certain capital instruments, AT1, under which reset clauses are linked to IBOR rates subject to reform.
Where under the contractual terms of the instrument the coupon resets to a rate which has IBOR as a specified component of its
pricing structure, these are subject to IBOR reform and listed below:
31 December
2021
£m
US$1.15 billion 8% notes
734
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
338
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
10 Financial instruments - classification continued
Financial instruments – financial assets and liabilities that can be offset
The tables below present information on financial assets and financial liabilities that are offset on the balance sheet under IFRS or
subject to enforceable master netting agreements together with financial collateral received or given.
Instruments which can be offset
Potential for offset not recognised by IFRS
Gross
IFRS offset
Balance sheet
Effect of
master netting
and similar
agreements
Cash
collateral
Securities
collateral
Net amount after the
effect of netting
agreements and
related collateral
Instruments
outside netting
agreements
Balance
sheet total
2022
£m
£m
£m
£m
£m
£m
£m
£m
£m
Derivative assets
117,606
(18,730)
98,876
(77,365)
(14,079)
(4,571)
2,861
669
99,545
Derivative liabilities
115,177
(22,111)
93,066
(77,365)
(9,761)
(1,185)
4,755
981
94,047
Net position
(1)
2,429
3,381
5,810
(4,318)
(3,386)
(1,894)
(312)
5,498
Trading reverse repos
35,612
(14,510)
21,102
(2,445)
(18,458)
199
435
21,537
Trading repos
33,767
(14,510)
19,257
(2,445)
(16,812)
4,483
23,740
Net position
1,845
1,845
(1,646)
199
(4,048)
(2,203)
Non trading reverse repos
25,630
(5,702)
19,928
(19,928)
98
20,026
Non trading repos
16,977
(5,702)
11,275
(11,275)
11,275
Net position
8,653
8,653
(8,653)
98
8,751
2021
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
(1)
The net IFRS offset balance of £3,381 million (2021 - £607 million) relates to variation margin netting reflected on other balance sheet lines.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
339
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
11 Financial instruments - valuation
Financial instruments recognised at fair value are revalued using techniques that can include observable inputs (pricing information
that is readily available in the market, for example UK Government securities), and unobservable inputs (pricing information that is
not readily available, for example unlisted securities). Gains and losses are recognised in the income statement and statement of
comprehensive income as appropriate.
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 value – financial instruments
Financial instruments classified as mandatory fair value through profit or loss; held-for-trading; designated fair value through profit
or loss and fair value through other comprehensive income are recognised in the financial statements at fair value. All derivatives
are measured at fair value.
Fair value is the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market
participants at the measurement date. A fair value measurement considers the characteristics of the asset or liability and the
assumptions that a market participant would consider when pricing the asset or liability.
NatWest Group manages some portfolios of financial assets and financial liabilities based on its net exposure to either market or
credit risk. In these cases, the fair value is derived from the net risk exposure of that portfolio with portfolio level adjustments
applied to incorporate bid-offer spreads, counterparty credit risk, and funding costs (see ‘Valuation Adjustments’).
Where the market for a financial instrument is not active, fair value is established using a valuation technique. These valuation
techniques involve a degree of estimation, the extent of which depends on the instrument’s complexity and the availability of
market-based data. The complexity and uncertainty in the financial instrument’s fair value is categorised using the fair value
hierarchy.
For accounting policy information see Accounting policies notes 3.8 and 3.12.
Valuation
Fair value hierarchy
Financial instruments carried at fair value have been classified
under the fair value hierarchy. The classification ranges from
level 1 to level 3, with more expert judgment and price
uncertainty for those classified at level 3.
The determination of an instrument’s level cannot be made at
a global product level as a single product type can be in more
than one level. For example, a single name corporate credit
default swap could be in level 2 or level 3 depending on the
level of market activity for the referenced entity
.
Level 1 – instruments valued using unadjusted quoted prices in
active and liquid markets, for identical financial instruments.
Examples include government bonds, listed equity shares and
certain exchange-traded derivatives.
Level 2 - instruments valued using valuation techniques that
have observable inputs. Observable inputs are those that are
readily available with limited adjustments required. Examples
include most government agency securities, investment-grade
corporate bonds, certain mortgage products - including CLOs,
most bank loans, repos and reverse repos, state and municipal
obligations, most notes issued, certain money market
securities, loan commitments and most OTC derivatives.
Level 3 - instruments valued using a valuation technique where
at least one input which could have a significant effect on the
instruments valuation, is not based on observable market data.
Examples include non-derivative instruments which trade
infrequently, certain syndicated and commercial mortgage
loans, private equity, and derivatives with unobservable model
inputs.
Page
Financial instruments
Critical accounting policy: Fair value
339
Valuation
Fair value hierarchy
(D)
339
Valuation techniques
(D)
340
Inputs to valuation models
(D)
340
Valuation control
(D)
340
Key areas of judgment
(D)
341
Table of assets and liabilities split by fair value
hierarchy level
(T)
342
Valuation adjustments
Table of fair value adjustments made
(T)
343
Funding valuation adjustments (FVA)
(D)
343
Credit valuation adjustments (CVA)
(D)
343
Bid-offer
(D)
343
Product and deal specific
(D)
343
Own credit
(D)
343
Level 3 additional information
Level 3 ranges of unobservable inputs
(D)
344
Table of level 3 instruments, valuation
techniques and inputs
(T)
344
Level 3 sensitivities
(D)
345
Alternative assumptions
(D)
345
Other considerations
(D)
345
Table of high and low range of fair value of
level 3 assets and liabilities
(T)
345
Movement in level 3 assets and liabilities
over the reporting period
(D)
346
Table of the movement in level 3 assets and liabilities
346
Fair value of financial instruments measured
at amortised cost
Table showing the fair value of financial instruments
measured at amortised cost on the balance sheet
(T)
347
(D) = Descriptive; (T) = Table
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
340
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 instruments
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 include
equities and most debt securities.
Non-modelled products can fall into any fair value levelling
hierarchy depending on the observable market activity,
liquidity, and assessment of valuation 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 section.
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 floors)
through to more complex derivatives (e.g., balance guarantee
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 taken either directly
or indirectly from available data, where some inputs are also
modelled.
Fair value classification of modelled instruments is either level 2
or level 3, depending on the product/model combination, the
observability and quality of input parameters and other factors.
All these must be assessed to classify a position. The modelled
product is assigned to the lowest fair value hierarchy level of
any significant input used in that valuation.
Most derivative instruments, for example vanilla interest rate
swaps, foreign exchange swaps and liquid single name credit
derivatives, are classified as level 2. This is because they are
vanilla products valued using standard market models and with
observable inputs. Level 2 products range from vanilla to more
complex products, where more complex products remain
classified as level 2 due to the low materiality of any
unobservable 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, incorporating both
funding and credit risk. Values between and beyond available
data points are obtained by interpolation and extrapolation.
The principal inputs to these valuation techniques are as
follows:
Bond prices - quoted prices are generally available for
government bonds, certain corporate securities, and some
mortgage-related products.
Credit spreads - these express the return required over a
benchmark rate or index to compensate for the referenced
credit risk. Where available, these are derived from the price of
credit default swaps or other credit-based instruments, such as
debt securities. When direct prices are not available; credit
spreads are determined with reference to available prices of
entities with similar characteristics.
Interest rates - these are principally based on interest rate
swap prices referencing benchmark interest rates. Benchmark
rates include Interbank Offered Rates (IBOR) and the Overnight
Index Swap (OIS) rate, including SONIA (Sterling Overnight
Interbank Average Rate). Other quoted interest rates may also
be used from both the bond, and futures markets.
Foreign currency exchange rates - there are observable prices
both for spot and forward contracts and futures in the world's
major currencies.
Equity and equity index prices - quoted prices are generally
readily available for equity shares listed on the world's major
stock exchanges and for major indices on such shares.
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 variables are observed
to move together. Variables that move in the same direction
show positive correlation; those that move in opposite
directions are negatively correlated.
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 differs from that of an
instrument that cannot be prepaid. When valuing prepayable
instruments, the value of this prepayment option is considered.
Recovery rates/loss given default - these are used as an input
to valuation models and reserves for asset-backed securities
and other credit products as an indicator of severity of losses
on default. Recovery rates are primarily sourced from market
data providers, the value of the underlying collateral or inferred
from observable credit spreads.
Valuation control
NatWest Group's control environment for the determination of
the fair value of financial instruments includes formalised
procedures for the review and validation of fair values. This
review is performed by an independent price verification (IPV)
team.
IPV is a key element of the control environment. Valuations are
first performed by the business which entered into the
transaction. These valuations are then reviewed by the IPV
team, independent of those trading the financial instruments, in
light of available pricing evidence.
Independent pricing data is collated from a range of sources.
Each source is reviewed for quality and the independent data
applied in the IPV processes using a formalised input quality
hierarchy. Consensus services are one source of independent
data and encompass interest rate, currency, credit, 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 exceeds defined
thresholds, an adjustment is made to bring the valuation to
within the independently calculated fair value range.
IPV takes place at least monthly, for all fair value financial
instruments. The IPV control includes formalised reporting and
escalation of any valuation differences in breach of established
thresholds.
Notes to the consolidated financial statements
continued
NatWest Group
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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 liquidity and
valuation uncertainty of an instrument and forms part of the
information considered when determining fair value hierarchy
classifications.
Initial fair value level classification of a financial instrument is
carried out by the IPV team. These initial classifications are
subject to senior management review. Particular attention is
paid to instruments transferring from one level to another, new
instrument classes or products, instruments where the
transaction price is significantly different from the fair value
and instruments where valuation uncertainty is high.
Valuation Committees are made up of valuation specialists and
senior business representatives from various functions and
oversees pricing, reserving and valuations issues. These
committees meet monthly to review and ratify any
methodology changes. The Executive Valuation Committee
meets quarterly to address key material and subjective
valuation issues, to review items escalated by Valuation
Committees and to discuss other relevant industry matters.
The Group model risk policy sets the policy for model
documentation, testing and review. Governance 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 Risk
Policy.
Key areas of judgment
Over the years the business has simplified, with most products
classified as level 1 or 2 of the fair value hierarchy. However,
the diverse range of products historically traded by NatWest
Group means some products remain classified as level 3. Level
3 indicates a significant level of pricing uncertainty, where
expert judgment is used. As such, 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 judgment 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 volumes of
trading can be seen, but for an over the counter (OTC)
derivative, assessing the liquidity of the market with no central
exchange is more challenging.
A key related matter is where a market moves from liquid to
illiquid or vice versa. Where this movement is considered
temporary, the fair value level is not changed. For example, if
there is little market trading in a product on a reporting date
but at the previous reporting date and during the intervening
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 transfers between levels
are driven by genuine changes in market liquidity and do not
reflect short term or seasonal effects. Material movements
between levels are reviewed quarterly by the Business and IPV.
The breadth and depth of the IPV data allows for a rules-based
quality assessment to be made of market activity, liquidity, and
pricing uncertainty, which assists with the process of allocation
to an appropriate level. Where suitable independent pricing
information is not readily available, the quality assessment will
result in the instrument being assessed as level 3.
Notes to the consolidated financial statements
continued
NatWest Group
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Additional information
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11 Financial instruments - valuation continued
The table below shows the assets and liabilities held by NatWest Group split by fair value hierarchy level. Level 1 are considered
the most liquid instruments, and level 3 the most illiquid, valued using expert judgment and hence carry the most significant price
uncertainty.
2022
2021
Level 1
Level 2
Level 3
Total
Level 1
Level 2
Level 3
Total
£m
£m
£m
£m
£m
£m
£m
£m
Assets
Trading assets
Loans
35,260
395
35,655
33,482
721
34,203
Securities
7,463
2,458
1
9,922
19,563
5,371
21
24,955
Derivatives
5
98,533
1,007
99,545
105,222
917
106,139
Other financial assets
Loans
172
727
899
359
207
566
Securities
10,380
6,278
203
16,861
28,880
7,951
186
37,017
Total financial assets held at fair value
17,848
142,701
2,333
162,882
48,443
152,385
2,052
202,880
As % of total fair value assets
11%
88%
1%
24%
75%
1%
Liabilities
Trading liabilities
Deposits
42,486
1
42,487
38,658
2
38,660
Debt securities in issue
797
797
974
974
Short positions
7,462
2,062
9,524
20,507
4,456
1
24,964
Derivatives
2
93,070
975
94,047
100,229
606
100,835
Other financial liabilities
Debt securities in issue
1,327
1,327
1,103
1,103
Other deposits
1,050
1,050
568
568
Subordinated liabilities
345
345
703
703
Total financial liabilities held at fair value
7,464
141,137
976
149,577
20,507
146,691
609
167,807
As % of total fair value liabilities
5%
94%
1%
12%
88%
0%
(1)
Transfers between levels are 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 through 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 consolidated financial statements
continued
NatWest Group
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Governance
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Additional information
Financial review
11 Financial instruments – valuation
continued
Valuation adjustments
When valuing financial instruments in the trading book,
adjustments are made to mid-market valuations to cover bid-
offer spread, funding and credit risk. These adjustments are
presented in the table below:
Adjustment
2022
£m
2021
£m
Funding – FVA
173
90
Credit – CVA
300
390
Bid – Offer
130
113
Product and deal specific
141
119
744
712
Funding valuation adjustments on the group defined benefit
pension plan increased during the year, primarily driven by
increases in GBP interest rates.
The decrease in CVA was driven by a reduction in exposures,
primarily due to increases in interest rates and trade exit
activity, partially offset by the net impact of credit spreads
widening and specific counterparty activity. The increase in
bid-offer was driven by the net impact of risk changes, wider
bid-offer spreads and an increase in the estimated costs of
exiting certain less liquid risks. The increase in product and
deal specific was driven by credit spreads widening and
specific counterparty activity.
Funding valuation adjustments (FVA)
FVA represents an estimate of the adjustment that a market
participant would make to incorporate funding costs and
benefits that arise in relation to derivative exposures. FVA is
calculated as a portfolio level adjustment and can result in
either a funding charge (positive) or funding benefit (negative).
Funding levels are applied to estimated potential future
exposures. For uncollateralised derivatives, the exposure
reflects the future valuation of the derivative. For collateralised
derivatives, the exposure reflects the difference between the
future valuation of the derivative 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 managed by a credit and
market risk hedging process, and therefore movements in CVA
are partially offset by trading revenue on the hedges.
The CVA is calculated on a portfolio basis reflecting an
estimate of the amount a third party would charge to assume
the credit risk.
Collateral held under a credit support agreement is factored
into the CVA calculation. In such cases where NatWest Group
holds collateral against counterparty exposures, CVA is held to
the extent that residual risk remains.
Bid-offer
Fair value positions are required to be marked to exit,
represented by bid (long positions) or offer (short positions)
levels. Non-derivative positions are typically marked directly to
bid or offer prices. However derivative exposures are adjusted
to exit levels by taking bid-offer reserves calculated on a
portfolio basis. The bid-offer approach is based on current
market spreads and standard market bucketing of risk.
Bid-offer spreads vary by maturity and risk type to reflect
different spreads in the market. For positions where there is no
observable quote, the bid-offer spreads are widened in
comparison to proxies to reflect reduced liquidity or
observability.
Netting is applied on a portfolio basis to reflect the value at
which NatWest Group believes it could exit the net risk of the
portfolio, rather than the sum of exit costs for each of the
portfolio’s individual trades. This is applied where the asset and
liability positions are managed as a portfolio for risk and
reporting purposes.
Product and deal specific
On initial recognition of financial assets and liabilities valued
using valuation techniques which have a significant
dependence on information other 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 over the life of the
transaction; when market data becomes observable; or when
the transaction matures or is closed out as appropriate. On 31
December 2022, net gains of £74 million (2021 - £71 million)
were carried forward. During the year, net gains of £97 million
(2021 - £103 million) were deferred and £94 million (2021 - £94
million) were recognised in the income statement.
Where system generated valuations do not accurately reflect
market prices, manual valuation adjustments are applied either
at a position or portfolio level. Manual adjustments are subject
to the scrutiny of independent control teams and are subject to
monthly review by senior management.
Own Credit
NatWest Group considers the effect of its own credit standing
when valuing financial liabilities recorded at fair value. Own
credit spread adjustments are made when valuing issued debt
held at fair value, including issued structured notes. An own
credit adjustment is applied to positions where it is believed
that counterparties would consider NatWest Group’s
creditworthiness when pricing trades.
Notes to the consolidated financial statements
continued
NatWest Group
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Governance
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Additional information
Financial review
11 Financial instruments - valuation continued
Level 3 additional information
For illiquid assets and liabilities, classified as level 3, additional information is provided on the valuation techniques used and price
sensitivity of the products to those inputs. This is to enable the reader to gauge the level of uncertainty that arises from positions
with significant unobservable inputs or modelling parameters.
Level 3 ranges of unobservable inputs
The table below provides additional information on level 3 instruments and inputs. This shows the valuation technique used for the
fair value calculation, the unobservable input and input range.
2022
2021
Financial instrument
Valuation technique
Unobservable inputs
Units
Low
High
Low
High
Trading assets and Other financial assets
Loans
Price-based
Price
%
113
106
Discount cash flow
Credit spreads
bps
56
114
40
102
Discount cash flow
Discount margin
bps
46
55
Debt securities
Price-based
Price
%
255
240
Equity Shares
Price-based
Price
GBP
34,027
30,378
Price-based
Price
%
30
7
Discount cash flow
Discount margin
%
6
8
6
8
Net asset valuation
Fund NAV
%
80
120
80
120
Derivative assets and liabilities
Credit derivatives
Credit derivative pricing
Credit spreads
bps
7
530
6
635
Option pricing
Correlation
%
(15)
95
(15)
95
Volatility
%
30
80
30
108
Upfront points
%
99
100
Recovery rate
%
60
60
Interest rate & FX
Option pricing
Correlation
%
(50)
100
(50)
100
derivatives
Volatility
%
30
127
17
77
Constant Prepayment
Rate
%
2
21
2
16
Mean Reversion
%
92
92
Inflation volatility
%
1
2
1
2
Inflation rate
%
2
3
2
3
(1)
Valuation for private equity investments may be estimated by looking at past prices of similar stocks and from valuation statements where valuations are usually derived from
earnings measures such as EBITDA or net asset value (NAV). 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 material liabilities measured at fair value that are issued with an inseparable third-party credit enhancement.
Notes to the consolidated financial statements
continued
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Financial review
11 Financial instruments – valuation continued
Level 3 sensitivities
The level 3 sensitivities presented below are calculated at a
trade or low-level portfolio basis rather than an overall portfolio
basis. As individual sensitivities are aggregated with no
reflection of the correlated nature between instruments, the
overall portfolio sensitivity may not be accurately reflected. For
example, some portfolios may be negatively correlated to
others, where a downwards movement in one asset would
produce an upwards movement in another. However, due to
the additive presentation of the above figures this correlation
impact cannot be displayed. As such, the actual potential
downside sensitivity of the total portfolio may be less 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 specified target level of
certainty of 90%.
Alternative assumptions are determined with reference to all
available evidence including consideration of the following:
quality of independent pricing information considering
consistency between different sources, 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 holding of position;
and market intelligence.
Other considerations
Whilst certain inputs used to calculate CVA, FVA and own
credit adjustments are not based on observable market data,
the uncertainty of these inputs is 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 portfolios and
issued debt is not determined by CVA, FVA or own credit
inputs. In addition, any fair value sensitivity driven by these
inputs is not included in the level 3 sensitivities presented.
The table below shows the high and low range of fair value of the level 3 assets and liabilities. This range incorporates the range of
fair value inputs as described in the previous table.
2022
2021
Level 3
Favourable
Unfavourable
Level 3
Favourable
Unfavourable
£m
£m
£m
£m
£m
£m
Assets
Trading assets
Loans
395
10
(10)
721
10
(10)
Securities
1
21
Derivatives
1,007
50
(50)
917
60
(70)
Other financial assets
Loans
727
(10)
207
10
(10)
Securities
203
20
(30)
186
20
(20)
2,333
80
(100)
2,052
100
(110)
Liabilities
Trading liabilities
Deposits
1
2
Debt securities in issue
Short positions
1
Derivatives
975
30
(30)
606
30
(30)
976
30
(30)
609
30
(30)
Notes to the consolidated financial statements
continued
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Additional information
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11 Financial instruments – valuation continued
Movement in level 3 assets and liabilities
The following table shows the movement in level 3 assets and liabilities in the year.
2022
2021
Trading
assets (2)
Other financial
assets (3)
Total
assets
Total
liabilities
Trading
assets (2)
Other
financial
assets (3)
Total
assets
Total
liabilities
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January
1,658
394
2,052
609
1,388
335
1,723
894
Amounts recorded in the income statement
(1)
157
(14)
143
381
(93)
(29)
(122)
(90)
Amounts recorded in the statement of
comprehensive income
(20)
(20)
23
23
Level 3 transfers in
194
532
726
81
125
3
128
20
Level 3 transfers out
(269)
(68)
(337)
(64)
(104)
(6)
(109)
(168)
Purchases/originations
629
185
814
382
965
452
1,416
305
Settlements/other decreases
(115)
(115)
(41)
(47)
(364)
(411)
(28)
Sales
(857)
(101)
(958)
(378)
(573)
(17)
(590)
(321)
Foreign exchange and other
6
22
28
6
(3)
(3)
(6)
(3)
At 31 December
1,403
930
2,333
976
1,658
394
2,052
609
Amounts recorded in the income statement in respect
of balances held at year end:
- unrealised
157
(16)
141
381
(93)
(32)
(126)
(90)
(1)
There were £224 million net losses on trading assets and liabilities (2021 – £3 million net losses) recorded in income from trading activities. Net losses on other instruments of £14
million (2021 – £29 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.
Notes to the consolidated financial statements
continued
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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 and fair value of financial instruments measured at amortised cost on the balance
sheet.
Fair value hierarchy level
Carrying
Fair
Items where fair value
approximates carrying
value
value
value
Level 1
Level 2
Level 3
2022
£bn
£bn
£bn
£bn
£bn
£bn
Financial assets
Cash and balances at central banks
144.8
Settlement balances
2.6
Loans to banks
0.1
7.0
7.0
4.2
2.8
Loans to customers
366.3
354.5
20.3
334.2
Other financial assets - securities
13.1
12.8
3.6
3.2
6.0
2021
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
2022
Financial liabilities
Bank deposits
4.7
15.7
15.3
13.1
2.2
Customer deposits
407.0
43.3
43.3
12.7
30.6
Settlement balances
2.0
Other financial liabilities - debt securities in issue
46.7
46.1
40.7
5.4
Subordinated liabilities
5.9
5.6
5.5
0.1
Notes in circulation
3.2
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 securities 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
The assumptions and methodologies underlying the calculation of fair values of financial instruments at the balance sheet date are
as follows:
Short-term financial instruments
For certain short-term financial instruments, including but not
limited to; cash and balances at central banks, settlement
balances, loans with short-term maturities, notes in circulation
and customer demand deposits, carrying value is deemed a
reasonable approximation of fair value.
Loans to banks and customers
In estimating the fair value of net loans to customers and banks
measured at amortised cost, NatWest Group’s loans are
segregated into appropriate portfolios reflecting the
characteristics of the constituent loans. Two principal methods
are used to estimate fair value:
(a)
Contractual cashflows that are discounted using a market
discount rate that incorporates the current spread for the
borrower or where this is not observable, the spread for
borrowers of a similar credit standing.
(b)
Expected cash flows (unadjusted for credit losses) are
discounted at the current offer rate for the same or similar
products. The current methodology caps all loan values at
par rather than modelling clients’ option to repay loans
early. This approach is adopted for lending portfolios in
Retail Banking, Ulster Bank RoI, Commercial & Institutional
(SME loans) and Private Banking in order to reflect the
homogeneous nature of these portfolios.
Debt securities and subordinated liabilities
Most debt securities are valued using quoted prices in active
markets or from quoted prices of similar financial instruments.
The remaining population is valued using discounted cashflows
at current offer rates
Bank and customer deposits
Fair values of deposits are estimated using discounted cash
flow valuation techniques. Where required, methodologies can
be revised as additional information and valuation inputs
become available.
Notes to the consolidated financial statements
continued
NatWest Group
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12 Financial instruments - maturity analysis
Remaining maturity
This note shows the maturity profile of NatWest Group’s financial assets and liabilities by
contractual date of maturity and
contractual cash flows.
The following table shows the residual maturity of financial instruments, based on contractual date of maturity.
2022
2021
Less than 12
months
More than 12
months
Total
Less than 12
months
More than 12
months
Total
£m
£m
£m
£m
£m
£m
Assets
Cash and balances at central banks
144,832
144,832
177,757
177,757
Trading assets
35,944
9,633
45,577
40,263
18,895
59,158
Derivatives
38,107
61,438
99,545
34,538
71,601
106,139
Settlement balances
2,572
2,572
2,141
2,141
Loans to banks - amortised cost
6,872
267
7,139
7,425
257
7,682
Loans to customers - amortised cost
84,289
282,051
366,340
103,689
255,301
358,990
Other financial assets
6,128
24,767
30,895
11,151
34,994
46,145
Liabilities
Bank deposits
7,799
12,642
20,441
13,715
12,564
26,279
Customer deposits
448,821
1,497
450,318
478,801
1,009
479,810
Settlement balances
2,012
2,012
2,068
2,068
Trading liabilities
42,760
10,048
52,808
41,664
22,934
64,598
Derivatives
39,331
54,716
94,047
34,593
66,242
100,835
Other financial liabilities
13,796
35,311
49,107
16,060
33,266
49,326
Subordinated liabilities
973
5,287
6,260
1,375
7,054
8,429
Notes in circulation
3,218
3,218
3,047
3,047
Lease liabilities
137
981
1,118
238
1,025
1,263
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 payments of interest
of financial assets and liabilities by contractual maturity. The
balances in the following tables do not agree directly with the
consolidated balance sheet, as the tables include all cash flows
relating to principal and future coupon payments, presented on
an undiscounted basis. The tables have been prepared on the
following basis:
Financial assets have been reflected in the time band of the
latest date on which they could be repaid, unless earlier
repayment can be demanded by NatWest Group. Financial
liabilities are included at the earliest date on which the
counterparty can require repayment, regardless of whether or
not such early repayment results in a penalty. 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, regardless of early repayment.
The liability is included in the time band that contains the
earliest possible date on which the conditions could be fulfilled,
without considering the probability of the conditions being met.
For example, if a structured note is automatically prepaid when
an equity index exceeds a certain level, the cash outflow will be
included in the less than three months period, whatever the
level of the index at the year end. The settlement date of debt
securities in issue, issued by certain 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 the cash outflow relating to
securities assumes that each asset will be prepaid at the
earliest possible date. As the repayments of assets and
liabilities are linked, the repayment of assets in securitisations is
shown on the earliest date that the asset can be prepaid, as
this is the basis used for liabilities.
The principal amounts of financial assets and liabilities that are
repayable after 20 years or where the counterparty has no
right to repayment of the principal are excluded from the table,
as are interest payments after 20 years.
The maturity of guarantees and commitments is based on the
earliest possible date they would be drawn in order to evaluate
NatWest Group’s liquidity position.
MFVTPL assets of £145.8 billion (2021 - £165.6 billion) and HFT
liabilities of £146.7 billion (2021 - £165.3 billion) have been
excluded from the following tables.
Notes to the consolidated financial statements
continued
NatWest Group
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Additional information
Financial review
12 Financial instruments – maturity analysis continued
0-3 months
3-12 months
1-3 years
3-5 years
5-10 years
10-20 years
2022
£m
£m
£m
£m
£m
£m
Assets by contractual maturity up to 20 years
Cash and balances at central banks
144,832
Derivatives held for hedging
130
345
28
41
(44)
43
Settlement balances
2,572
Loans to banks - amortised cost
5,254
1,621
17
288
Loans to customers - amortised cost
50,923
43,417
76,278
55,128
85,038
100,085
Other financial assets
(1)
2,771
4,507
8,391
7,835
5,706
2,524
Finance lease
96
267
857
482
549
296
206,578
50,157
85,571
63,774
91,249
102,948
Liabilities by contractual maturity up to 20 years
Bank deposits
6,690
1,445
5,662
8,503
89
Customer deposits
437,830
11,389
1,252
2
14
20
Settlement balances
2,012
Derivatives held for hedging
280
(371)
586
306
116
85
Other financial liabilities
6,720
6,640
18,833
13,906
7,361
294
Subordinated liabilities
96
1,073
2,690
1,897
1,541
328
Other liabilities- Notes in circulation
3,218
Lease liabilities
41
113
260
203
318
254
456,887
20,289
29,283
24,817
9,439
981
Guarantees and commitments - notional amount
Guarantees
(2)
3,150
Commitments
(3)
118,779
121,929
2021
Assets by contractual maturity up to 20 years
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 years
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 amount
Guarantees
(2)
2,055
Commitments
(3)
118,536
120,591
(1)
Other financial assets exclude equity shares.
(2)
NatWest Group is only 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 all facilities to be drawn, and some may lapse before drawdown
.
Notes to the consolidated financial statements
continued
NatWest Group
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350
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Additional information
Financial review
13 Trading assets and liabilities
Trading assets and liabilities comprise assets and liabilities held at fair value and classified as held-for-trading. Financial
instruments are classified as held for trading if they are held for the purpose of selling 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 see Accounting policies note 3.8.
2022
2021
Assets
£m
£m
Loans
Reverse repos
21,537
20,742
Collateral given
13,005
12,047
Other loans
1,113
1,414
Total loans
35,655
34,203
Securities
Central and local government
- UK
2,205
6,919
- US
2,345
3,329
- other
2,799
10,929
Financial institutions and corporate
2,573
3,778
Total securities
9,922
24,955
Total
45,577
59,158
Liabilities
Deposits
Repos
23,740
19,389
Collateral received
17,680
17,718
Other deposits
1,067
1,553
Total deposits
42,487
38,660
Debt securities in issue
797
974
Short positions
9,524
24,964
Total
52,808
64,598
Notes to the consolidated financial statements
continued
NatWest Group
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351
Financial statements
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Governance
Risk and capital management
Additional information
Financial review
14 Derivatives
Derivative is a term covering a wide range of financial instruments that derive their
fair value from an underlying rate or price, for
example interest rates or exchange rates (the underlying). NatWest Group uses derivatives as a part of its trading activities, to
manage its own risks such as interest rate, foreign exchange, or credit risk and in certain customer transactions. This note
shows
contracted volumes of derivatives, how they are used for hedging purposes and more specifically the effects of the application of
hedge accounting.
For accounting policy information see Accounting policies note 3.8 and 3.12.
2022
2021
Notional
Assets
Liabilities
Notional
Assets
Liabilities
£bn
£m
£m
£bn
£m
£m
Exchange rate contracts
3,168
45,829
45,237
3,167
38,517
39,286
Interest rate contracts
10,742
53,480
48,535
8,919
67,458
61,206
Credit derivatives
15
236
275
14
154
343
Equity and commodity contracts
10
99,545
94,047
106,139
100,835
NatWest Group applies hedge accounting to reduce the
accounting mismatch caused in the income statement by using
derivatives to hedge the following risks: interest rate, foreign
exchange and the foreign exchange risk associated with net
investment in foreign operations.
NatWest Group’s interest rate hedging relates to the
management of NatWest Group’s non-trading structural
interest rate risk, caused by the mismatch between fixed
interest rates and floating interest rates on its financial
instruments. NatWest Group manages this risk within approved
limits. Residual risk positions are hedged with derivatives,
principally interest rate swaps.
Suitable larger fixed rate financial instruments are subject to
fair value hedging in line with documented risk management
strategies
Cash flow hedges of interest rate risk relate to exposures to the
variability in future interest payments and receipts due to the
movement of benchmark interest rates on forecast transactions
and on financial assets and financial liabilities. This variability in
cash flows is hedged by interest rate swaps, which convert
variable cash flows into fixed. For these cash flow hedge
relationships, the hedged items are actual and forecast variable
interest rate cash flows arising from financial assets and
financial liabilities with interest rates linked to the relevant
benchmark rates, most notably USD LIBOR, SOFR, EURIBOR,
SONIA and the Bank of England Official Bank Rate. The
variability in cash flows due to movements in the relevant
benchmark rate is hedged; this risk component is identified
using the risk management systems of NatWest Group and
encompasses the majority of cash flow variability risk.
Fair value hedges of interest rate risk involve interest rate
swaps transforming the fixed interest rate risk in financial
assets and financial liabilities to floating. The hedged risk is the
risk of changes in the hedged item’s fair value attributable to
changes in the benchmark interest rate risk component of the
hedged item. The significant benchmarks identified as risk
components are USD LIBOR, SOFR, EURIBOR and SONIA.
These risk components are identified using the risk
management systems of NatWest Group and encompass the
majority 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 forward foreign exchange contracts.
NatWest Group reviews the value of the investments’ net
assets, executing hedges where appropriate to reduce the
sensitivity of capital ratios to foreign exchange rate movement.
Hedge accounting relationships will be designated where
required.
Exchange rate risk also arises in NatWest Group where
payments are denominated in currencies other than the
functional currency. Residual risk positions are hedged with
forward foreign exchange contracts, fixing the exchange 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 Group determines that
there is an adequate level of offsetting between the hedged
item and hedging instrument at inception and on an ongoing
basis. This is achieved by comparing movements in the fair
value of the expected highly probable forecast cash flows/fair
value of the hedged item attributable to the hedged risk with
movements in the fair value of the expected changes in cash
flows from the hedging instruments. The method used for
comparing movements is either regression testing or the dollar
offset method. The method for testing effectiveness and the
period over which the test is performed depends on the
applicable risk management strategy and is applied consistently
to each risk management strategy. Hedge effectiveness is
assessed on a cumulative basis and the determination of
effectiveness is in line with the requirements of IAS39.
NatWest Group uses either the actual ratio between the hedged
item and hedging instrument(s) or one that minimises hedge
ineffectiveness to establish the hedge ratio for hedge
accounting. Hedge ineffectiveness is measured in line with the
requirements of IAS39 and recognised in the income statement
as it arises.
Notes to the consolidated financial statements
continued
NatWest Group
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Additional information
Financial review
14 Derivatives continued
Included in the table below are derivatives held for hedging purposes as follows:
2022
2021
Notional
Assets
Liabilities
Changes in fair
value used for
hedge
ineffectiven
ess (1)
Notional
Assets
Liabilities
Changes in fair
value used for
hedge
ineffectivene
ss (1)
£bn
£m
£m
£m
£bn
£m
£m
£m
Fair value hedging
Interest rate contracts
58.7
1,554
3,009
482
65.6
1,176
2,057
897
Cash flow hedging
Interest rate contracts
167.6
2,681
6,207
(3,342)
133.1
952
1,149
(931)
Exchange rate contracts
6.3
142
112
(3)
7.3
30
109
27
Net investment hedging
Exchange rate contracts
0.5
1
9
4
0.5
11
1
7
233.1
4,378
9,337
(2,859)
206.5
2,169
3,316
IFRS netting/Clearing
house settlements
(4,235)
(9,205)
(2,125)
(3,196)
143
132
44
120
(1)
The change in fair value used for hedge ineffectiveness includes instruments that were derecognised in the year.
Notes to the consolidated financial statements
continued
NatWest Group
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353
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Financial statements
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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 months
3-12 months
1-3 years
3-5 years
5-10 years
10-20 years
20+ years
Total
2022
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
Fair value hedging
Hedging assets - interest rate risk
0.5
1.9
4.7
4.9
4.2
2.5
1.1
19.8
Hedging liabilities - interest rate risk
1.0
2.9
14.6
10.3
9.6
0.5
38.9
Cash flow hedging
Hedging assets
Interest rate risk
6.6
9.4
46.5
21.9
10.1
94.5
Average fixed interest rate (%)
1.36
1.98
1.71
2.04
1.02
3.12
1.72
Hedging liabilities
Interest rate risk
17.3
26.8
15.7
5.1
7.5
0.7
73.1
Average fixed interest rate (%)
1.27
0.95
2.75
1.03
2.68
4.55
1.63
Hedging assets
Exchange rate risk
0.1
0.1
Hedging liabilities
Exchange rate risk
1.1
2.8
2.1
0.2
6.2
Net investment hedging
Exchange rate risk
0.5
0.5
2021
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
For cash flow hedging of exchange rate risk, the average foreign exchange rates applicable across the relationships were as below
for the main currencies hedged.
2022
2021
INR/GBP
100.54
106.58
USD/GBP
1.29
1.38
CHF/GBP
1.15
1.25
JPY/GBP
132.89
132.93
JPY/USD
128.29
n/a
NOK/USD
9.21
n/a
CNH/GBP
n/a
8.74
For net investment hedging of exchange rate risk, the average foreign exchange rates applicable were as below for the main
currencies hedged.
2022
2021
SEK/GBP
13.23
11.74
DKK/GBP
n/a
8.85
NOK/GBP
12.34
12.12
AED/USD
4.42
3.67
USD/GBP
1.20
1.32
Notes to the consolidated financial statements
continued
NatWest Group
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354
Financial statements
Strategic report
Governance
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Additional information
Financial review
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
14 Derivatives continued
The table below analyses assets and liabilities subject to hedging derivatives.
Carrying value of
hedge assets and
liabilities
Impact on hedge items
included in carrying
value
Changes in fair value used as
a basis to determine
ineffectivemness (1)
Impact on hedge items
ceased to be adjusted for
hedging gains or losses
2022
£m
£m
£m
£m
Fair value hedging - interest rate
Loans to banks and customers - amortised cost
5,764
(526)
(1,236)
63
Other financial assets - securities
12,897
(922)
(2,525)
(2)
Total
18,661
(1,448)
(3,761)
61
Bank and customer deposits
565
(3)
3
Other financial liabilities - debt securities in issue
35,856
(2,222)
2,790
Subordinated liabilities
5,504
(547)
526
Total
41,925
(2,772)
3,319
Cash flow hedging - interest rate
Loans to banks and customer - amortised cost
(2)
93,212
5,263
Other financial assets - securities
1,176
73
Total
94,388
5,336
Bank and customer deposits
72,610
(2,008)
Other financial liabilities - debt securities in issue
571
(46)
Total
73,181
(2,054)
Cash flow hedging - exchange rate
Loans to banks and customer - amortised cost
(2)
Other financial assets - securities
Total
Other financial liabilities - debt securities in issue
4,141
(2)
Subordinated liabilities
Other
204
5
Total
4,345
3
2021
Fair value hedging - interest rate
Loans to banks and customers - amortised 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 securities 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
Bank and customer deposits
68,383
(1,084)
Other financial liabilities - debt securities in issue
1,006
(21)
Total
69,389
(1,105)
Cash flow hedging - exchange rate
Loans to banks and customer - amortised cost
21
Other financial assets - securities
2
Total
23
Cash flow hedging - exchange rate
Other financial liabilities - debt securities in issue
6,337
(5)
Subordinated liabilities
742
(12)
Other
200
(10)
Total
7,279
(27)
(1)
The change in fair value used for hedge ineffectiveness includes instruments that were derecognised in the year
.
(2)
Includes cash and balances at central banks.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
355
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Strategic report
Governance
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.
2022
2021
Cash flow hecdge
reserve
Foreign exchange
hedge reserve
Cash flow hecdge
reserve
Foreign exchange
hedge reserve
£m
£m
£m
£m
Continuing
Interest rate risk
(3,576)
(295)
Foreign exchange risk
16
(85)
23
53
De-designated
Interest rate risk
(297)
(297)
Foreign exchange risk
20
(880)
10
(759)
Total
(3,837)
(965)
(559)
(706)
2022
2021
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
(2,997)
(64)
(700)
Foreign exchange risk
24
(202)
13
88
Total
(2,973)
(266)
(687)
88
Amount transferred from equity to earnings
Interest rate risk to net interest income
(252)
(181)
Interest rate risk to non-interest income
(1)
(21)
20
Interest rate risk to operating expenses
(14)
Foreign exchange risk to net interest income
(29)
(4)
2
Foreign exchange risk to non-interest income
15
7
1
(2)
Foreign exchange risk to operating expenses
(3)
3
Total
(304)
7
(161)
(1)
There was £21 million (2021 - £20 million) reclassified with the cash flow reserve to earnings due to forecasted cash flows that are no longer expected to occur.
Hedge ineffectiveness recognised in other operating income comprises:
2022
2021
2020
£m
£m
£m
Fair value hedging
(Loss)/gain on hedged items attributable to the hedged risk
(442)
(846)
877
Gain/(loss) on the hedging instruments
482
897
(875)
Fair value hedging ineffectiveness
40
51
2
Cash flow hedging
Interest rate risk
(60)
(26)
22
Cash flow hedging ineffectiveness
(60)
(26)
22
Total
(20)
25
24
The main sources of ineffectiveness for interest rate risk hedge accounting relationships are:
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 interest rate (fair value hedge).
Differences in the repricing basis between the hedging instrument and hedged cash flows (cash flow hedge); and
Upfront present values on the hedging derivatives where hedge accounting relationships have been designated after the trade
date (cash flow hedge and fair value hedge).
Notes to the consolidated financial statements
continued
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Additional information
Financial review
15 Loan impairment provisions
Loan exposure and impairment metrics
There is a risk that customers and counterparties fail to meet their contractual obligation to settle outstanding amounts, known 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 on current and potential exposures, and contingent liabilities.
For accounting policy information see Accounting policies note 2.3. Further disclosures on credit risk and information on ECL
methodology are shown from page 190.
The table below summarises loans and credit impairment measures within the scope of IFRS 9 Expected credit losses framework.
2022
2021
£m
£m
Loans - amortised cost and FVOCI
Stage 1
325,224
330,824
Stage 2
46,833
33,981
Stage 3
5,096
5,022
Of which: individual
1,121
1,215
Of which: collective
3,975
3,807
377,153
369,827
ECL provisions
(1)
- Stage 1
632
302
- Stage 2
1,043
1,478
- Stage 3
1,759
2,026
Of which: individual
287
363
Of which: collective
1,472
1,663
3,434
3,806
ECL provision coverage
(2)
- Stage 1 (%)
0.19
0.09
- Stage 2 (%)
2.23
4.35
- Stage 3 (%)
34.52
40.34
0.91
1.03
Continuing operations
Impairment (releases)/losses
ECL (release)/charge
(3,4)
337
(1,173)
Stage 1
(290)
(1,317)
Stage 2
393
(164)
Stage 3
234
308
Of which: individual
54
20
Of which: collective
180
288
Amounts written off
482
876
Of which: individual
168
455
Of which: collective
314
421
(1)
Includes loans to customers and banks.
(2)
Includes £3 million (2021 - £5 million) related to assets classified as FVOCI and £0.1 billion (2021 - £0.1 billion related to off-balance sheet exposures.
(3)
ECL provisions coverage is calculated as total ECL provisions divided by loans – amortised cost and FVOCI. It is calculated on third party loans and total ECL provisions.
(4)
Includes a £3 million charge (2021 - £3 million release) related to other financial assets, of which nil (2021 - £2 million release) related to assets classified as FVOCI; and £5
million release (2021 - £34 million release) related to contingent liabilities.
(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 £143.3 billion (2021 –
£176.3 billion) and debt securities of £29.9 billion (2021 – £44.9 billion).
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
357
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
15 Loan impairment provisions continued
Credit risk enhancement and mitigation
For information on Credit risk enhancement and mitigation held
as security, refer to Risk and capital management – Credit risk
enhancement and mitigation section.
Critical accounting policy: Loan impairment provisions
Accounting policies note 2.3 sets out how the expected loss
approach is applied. At 31 December 2022, customer loan
impairment provisions amounted to £3,434 million (2021 -
£3,806 million). A loan is impaired when there is objective
evidence that the cash flows will 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 accordance with the loan agreement,
significant reduction in the value of any security, breach of
limits or covenants, and observable data about relevant
macroeconomic measures.
The impairment loss is the difference between the carrying
value of the loan and the present value of estimated future
cash flows at the loan's original effective interest rate.
The measurement of credit impairment under the IFRS
expected loss model depends on management’s assessment of
any potential deterioration in the creditworthiness of the
borrower, its modelling of expected performance and the
application of economic forecasts. All three elements require
judgments that are potentially significant to the estimate of
impairment losses. For further information and sensitivity
analysis, refer to Risk and capital management – Measurement
uncertainty and ECL sensitivity analysis section.
IFRS 9 ECL model design principles
Refer to Credit risk – IFRS 9 ECL model design principles
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. Refer to Credit risk – Economic
loss drivers - Probability weightings of scenarios section for
further details.
16 Other financial assets
Other financial assets consist of debt securities, equity shares and loans that are not held for trading. Balances consist of local and
central government securities, a component part of NatWest Group’s liquidity portfolio.
For accounting policy information see Accounting policy 3.8.
Debt securities
Central and local government
UK
US
Other
Other debt
Total
Equity shares
Loans
Total
2022
£m
£m
£m
£m
£m
£m
£m
£m
Mandatory fair value through profit or loss
2
2
3
782
787
Fair value through other comprehensive
income
(1)
802
7,175
1,757
6,765
16,499
357
117
16,973
Amortised cost
2,562
937
54
9,582
13,135
13,135
Total
3,364
8,112
1,811
16,349
29,636
360
899
30,895
2021
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
(1)
Upon initial recognition, NatWest Group occasionally 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 are 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 gains are recorded in OCI. Equity instruments at FVOCI are not subject to an impairment assessment.
During the year NatWest Group acquired £146 million of equity shares in Permanent TSB Group Holdings p.l.c. as part
consideration on the sale of certain assets. Refer to Note 8 for additional information on assets of disposal groups. In addition,
NatWest Group acquired £26 million of equity shares in Vodeno Limited.
NatWest Group disposed of equity shares in Visa Inc. of £99 million and UBS Equity Funds of £69 million. There were no significant
disposals in the prior year. There are no significant dividends on equity shares held at FVOCI in either year.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
358
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
17 Intangible assets
Intangible assets, such as internally generated software and goodwill generated on business combinations are not physical in
nature. This note presents the cost of the assets, which is the amount NatWest Group initially paid or incurred, additions and
disposals during the year, and any amortisation or impairment. Amortisation is a charge that reflects the usage of the asset and
impairment is a reduction in value arising from specific events identified during the year.
For accounting policy information see Accounting policies notes 3.4 and 3.5.
2022
2021
Goodwill
Other (1)
Total
Goodwill
Other (1)
Total
Cost
£m
£m
£m
£m
£m
£m
At 1 January
9,939
3,050
12,989
9,939
2,592
12,531
Currency translation and other adjustments
(8)
(3)
(11)
29
29
Additions
743
743
479
479
Disposals and write-off of fully amortised assets
(27)
(27)
(50)
(50)
At 31 December
9,931
3,763
13,694
9,939
3,050
12,989
Accumulated amortisation and impairment
At 1 January
4,417
1,849
6,266
4,332
1,544
5,876
Currency translation and other adjustments
(8)
(4)
(12)
31
31
Disposals and write-off of fully amortised assets
(17)
(17)
(28)
(28)
Impairment of intangible assets
85
2
87
Amortisation charge for the year
341
341
300
300
At 31 December
4,409
2,169
6,578
4,417
1,849
6,266
Net book value at 31 December
5,522
1,594
7,116
5,522
1,201
6,723
(1)
Principally internally generated software.
Intangible assets and goodwill are reviewed for indicators of
impairment. No impairment was indicated at 31 December
2022. In 2021 goodwill in the Retail Banking segment was
impaired by £85 million.
NatWest Group’s goodwill acquired in business combinations is
reviewed for impairment annually at 31 December by cash-
generating unit (CGU) (2022 and 2021: Retail Banking £2,607
million; Commercial Banking £2,606 million; Private Banking £9
million; and RBS International £300 million). Analysis by
reportable segment is in Note 4 Segmental analysis.
Impairment testing involves the comparison of the carrying
value of each CGU with its recoverable amount. The carrying
values of the segments reflect the equity allocations made by
management, which are consistent with NatWest Group’s
capital targets.
Recoverable amount is the higher of fair value less costs of
disposal and value in use. Fair value is the price that would be
received to sell an asset in an orderly transaction between
market participants. Value in use is the present value of
expected future cash flows from the CGU.
The recoverable amounts for all CGUs at 31 December 2022
were based on value in use, using management's latest five-
year revenue and cost forecasts. These are discounted cash
flow projections over five years. The forecast is then
extrapolated in perpetuity using a long-term growth 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 (2022: 1.4% and 2021: 1.6%). The
pre-tax risk discount rates are based on those observed to be
applied to businesses regarded as peers of the CGUs (2022:
15.3% for Retail Banking, Commercial Banking and Private
Banking, 14% for RBS International, and 2021: 13.9% for Retail
Banking, Commercial Banking and Private Banking, 12.1% for
RBS International).
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
359
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
18 Other assets
Other assets are not financial assets and reflect a grouping of assets that are not large enough to present separately on the
balance sheet.
2022
2021
£m
£m
Interests in associates
(1)
688
716
Property, plant and equipment
(2)
4,240
4,230
Pension schemes in net surplus (Note 5)
318
602
Prepayments
340
360
Accrued income
327
248
Tax recoverable
279
190
Deferred tax (Note 7)
2,178
1,195
Acceptances
237
225
Other
569
476
Other assets
9,176
8,242
(1)
Includes interest in Business Growth Fund £677 million (2021 - £700 million).
(2)
The estimated useful lives of NatWest 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 and debt securities in issue.
For accounting policy information see Accounting policies notes 3.8 and 3.11.
2022
2021
£m
£m
Customer deposits - designated as at fair value through profit or loss
1,050
568
Debt securities in issue
- MRELs
22,265
23,422
- Other medium term notes
16,419
12,430
- Commercial paper and certificates of deposit
5,672
9,153
- Covered bonds
2,842
2,886
- Securitisation
859
867
Total
49,107
49,326
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
360
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
20 Subordinated liabilities
Subordinated liabilities are debt securities that, in the event of winding up or bankruptcy, rank below other liabilities for interest
payments and repayment.
For accounting policy information see Accounting policies notes 3.8 and 3.11.
2022
2021
£m
£m
Dated loan capital
5,968
8,051
Undated loan capital
173
259
Preference shares
119
119
6,260
8,429
Certain preference shares issued by the company are classified as liabilities; these securities remain subject to the capital
maintenance rules of the Companies Act 2006.
First call
Maturity
Capital
2022
2021
Dated loan capital
date
date
treatment
£m
£m
Natwest Group plc
$2,250 million
6.13% notes
Dec-22
Tier 2
986
$2,250 million
5.13% notes
May-24
Tier 2
706
956
$2,000 million
6.00% notes
Dec-23
Tier 2
536
1073
£1,000 million
3.622% notes
Aug-25
Aug-30
Tier 2
964
995
£1,000 million
2.105% notes
Aug-26
Nov-31
Tier 2
1001
999
$1,000 million
6.10% notes
Jun-23
Tier 2
126
354
$850 million
3.032% notes
Nov-30
Nov-35
Tier 2
555
584
€750 million
1.043% notes
Jun-27
Sep-32
Tier 2
665
630
$750 million
3.754% notes
Nov-24
Nov-29
Tier 2
626
558
£650 million
7.416% notes
Mar-28
Jun-33
Tier 2
641
$650 million
6.425% notes
Jan-34
Jan-43
Not applicable
554
5,820
7,689
Other subsidiaries
$650 million
6.3% notes
Jan-34
Dec-43
Not applicable
39
€300 million
Floating rate notes
Jun-22
Tier 2
252
€170 million
Floating rate notes
Feb-41
Not applicable
223
331
$150 million
7.125% notes
Oct-93
Not applicable
18
113
€145.6 million
Floating rate notes
Apr-23
Tier 2
122
119
$136 million
7.75% notes
May-23
Not applicable
83
104
6,266
8,647
Undated loan capital
Natwest Group plc
$762 million
7.648% notes
Sep-31
Not applicable
51
Other subsidiaries
£16 million
5.63% notes
Sep-26
Not applicable
18
20
£19 million
5.63% notes
Jun-32
Tier 2
1
£21 million
6.2% notes
Mar-22
Tier 2
22
£31 million
7.38% notes
Not applicable
2
1
£53 million
7.125% notes
Oct-22
Not applicable
56
€31 million
11.375% notes
Tier 2
48
45
£35 million
11.5%
notes
Dec-22
Not applicable
72
31
£11 million
11.75% notes
Tier 2
25
24
£1.1 million
SONIA + 2.8266% notes
Tier 2
2
2
£4.9 million
2.5% fixed notes
Not applicable
6
6
173
259
Preference shares
Other subsidiaries
£140 million
Non-cumulative preference shares of £1
Not applicable
119
119
119
119
Fair Value Hedging
(298)
(596)
6,260
8,429
(1)
Notes redeemed before call date as tax and regulatory benefits discontinued.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
361
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 lease liabilities, amounts due for goods
and services that have been received but not invoiced,
tax due to HMRC, and retirement benefit liabilities. Liabilities which have a
level of uncertainty regarding their timing or the future cost to settle them are included in other liabilities as provisions for liabilities
and charges.
2022
2021
Other liabilities
£m
£m
Lease liabilities
1,118
1,263
Provisions for liabilities and charges
1,138
1,268
Retirement benefit liabilities (Note 5)
98
114
Accruals
1,407
1,508
Deferred income
355
319
Current tax
55
12
Deferred tax (Note 7)
227
359
Acceptances
237
225
Other liabilities
(1)
711
729
5,346
5,797
(1)
Other liabilities include liabilities of disposal groups of £15 million (2021 - £5 million). See Note 8 for further information.
Customer redress
(1)
Litigation and
other regulatory
Property
Financial
commitments and
guarantees
Other (2)
Total
Provisions for liabilities and charges
£m
£m
£m
£m
£m
£m
At 1 January 2022
474
277
231
93
193
1,268
Expected credit loss impairment release
(6)
(6)
Currency translation and other movements
2
20
7
29
Charge to income statement
178
36
31
193
438
Release to income statement
(45)
(14)
(71)
(60)
(190)
Provisions utilised
(178)
(79)
(37)
(107)
(401)
At 31 December 2022
431
240
154
87
226
1,138
(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 have 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 to restructuring costs.
Provisions are liabilities of uncertain timing or amount and are
recognised when 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 the amounts provided will affect the reported
results in the period when the matter is resolved.
For accounting policy information see Accounting policies note
2.4.
Critical accounting policy: Provisions for liabilities
The key judgment is involved in determining whether a present
obligation exists. There is often a high degree of uncertainty
and judgment is based on the specific facts and circumstances
relating to individual events in determining whether there is a
present obligation. Judgment is also involved in estimation of
the probability, timing and amount of any outflows. Where
NatWest Group can look to another party such as an insurer to
pay some or all of the expenditure required to settle a
provision, any reimbursement is recognised when, and only
when, it is virtually certain that it will be received.
Estimates -
Provisions are liabilities of uncertain timing or
amount and are recognised when 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 the amounts
provided will affect the reported results in the period when the
matter is resolved.
Customer redress: Provisions reflect the estimated cost of
redress attributable to claims where it is determined that a
present obligation exists.
Litigation and other regulatory: NatWest Group is engaged
in various legal proceedings, both in the UK and in overseas
jurisdictions, including the US. For further information in
relation to legal proceedings and discussion of the
associated uncertainties, refer to Note 26.
Property: This includes provision for contractual costs
associated with vacant properties.
Other provisions: These materially comprise provisions for
onerous contracts and restructuring costs. Onerous
contract provisions comprise an estimate of the costs
involved in fulfilling the terms and conditions of contracts
net of any expected benefits to be received. This includes
provision for contractual costs associated with vacant
properties. Redundancy and restructuring provisions
comprise the estimated cost of restructuring, including
redundancy costs where an obligation exists.
Background information for all material provisions is given in
Note 26
.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
362
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 shares and is measured as the number of shares allotted and fully paid
multiplied by the nominal value of a share. Other equity includes paid-in equity, merger reserves, capital redemption reserve and
own shares held.
For accounting policy information see Accounting policies note 3.11.
Number of shares
2022
2021
2022
2021
Allotted, called up and fully paid
£m
£m
000s
000s
Ordinary shares of £1.0769
(1)
10,539
11,468
9,786,024
11,467,982
Cumulative preference shares of £1
0.5
0.5
483
483
Non-cumulative preference shares of US$0.01
(2)
10
(1)
The nominal value of ordinary shares without rounding is £1.076923076923077 per share
(2)
The company redeemed the Series U Non-cumulative dollar preference shares on 31 March 2022.
Movement in allotted, called up and fully paid ordinary shares
£m
Number of shares 000s
At 1 January 2021
12,129
12,129,165
Shares issued
38
37,584
Share cancellation
(699)
(698,767)
At 1 January 2022
11,468
11,467,982
Share cancellation
(929)
(929,188)
Share consolidation
(752,770)
At 31 December 2022
10,539
9,786,024
Ordinary shares
At a General Meeting of the company on 25 August 2022,
shareholders approved a share consolidation of the company's
ordinary shares. Every 14 existing ordinary shares of £1 each
in the capital of the company in issue as at 26 August 2022
were consolidated into one intermediate ordinary share of
£14.00 and immediately divided into 13 new ordinary shares of
£1.0769 in the capital of the company.
There is no authorised share capital under the company’s
constitution. At 31 December 2022, the directors had authority
granted at the 2022 Annual General Meeting to issue up to
£561,452,512 nominal of ordinary shares other than by pre-
emption to existing shareholders. This figure was amended to
£520,306,980 at the General Meeting on 25 August 2022 to
preserve the position as if the share consolidation had not
taken place.
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 issued ordinary share capital in any 12-month
period from HM Treasury (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 2022, and amended
at the General Meeting held on 25 August 2022 to preserve the
position as if the share consolidation had not taken place.
Shareholders will be asked to renew the authority at the
Annual General Meeting in 2023.
The company utilised the authority it obtained at the 2021 AGM
to make an off-market purchase of 549,851,147 ordinary
shares (nominal value £549,851,147) in the company from HMT
on 28 March 2022, at a price of 220.5p per ordinary share for
the total consideration of £1,212,421,779, representing 4.91% of
the company’s issued ordinary share capital. The company
cancelled all of the purchased ordinary shares.
At the Annual General Meeting in 2022 shareholders authorised
the company to make market purchases of up to 1,122,905,024
ordinary shares in the company. The authority was amended at
the General Meeting held on 25 August 2022 to preserve the
position as if the share consolidation had not taken place and
shareholders will be asked to renew the authority at the Annual
General Meeting in 2023.
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.
Phase 1 of the Programme commenced on 2 August 2021 and
completed on 18 January 2022. 340,537,460 ordinary shares
(nominal value £340,537,460) were purchased by the company
at an average purchase price of 220.0199p per ordinary share
for the total consideration of £749,250,031. Phase 2 of the
Programme commenced on 21 February 2022 and completed
on 15 July 2022. A further 346,835,822 ordinary shares
(nominal value £346,835,822) were purchased by the company
at an average purchase price of 216.2406p per ordinary share
for the total consideration of £749,999,999. All of the purchased
ordinary shares were cancelled, representing 11.23% of the
company’s issued ordinary share capital.
In 2022 NatWest Group paid an interim dividend of £364 million,
or 3.5p per ordinary share (2021 – £347 million, or 3p per
ordinary share).
In addition, the company also paid a special dividend of £1,750
million, or 16.8p per ordinary share.
The company has announced that the directors have
recommended a final dividend of £1.0 billion, or 10.0p per
ordinary share (2021 – £844 million, or 7.5p per ordinary share)
subject to shareholder approval at the Annual General Meeting
on 25 April 2023.
If approved, payment will be made on 2 May 2023 to
shareholders on the register at the close of business on 17
March 2023. The ex-dividend date will be 16 March 2023.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
363
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
22 Share capital and other equity continued
Cumulative preference shares
At the 2021 Annual General Meeting, shareholders authorised
the company to make an off-market purchase of preference
shares in the company. In December 2021 the company used
this authority to purchase 157,546 5.5% cumulative preference
shares and 259,314 11% cumulative preference shares. The
company cancelled all of the purchased preference shares.
Non-cumulative preference shares
The company announced on 2 February 2022 that it had given
notice to holders of the redemption of the Series U Non-
Cumulative Dollar Preference Shares. On 31 March 2022, the
Series U Dollar Non-cumulative Preference Shares, of amount
outstanding US$1,013,000,000 were redeemed at the
redemption price of US$100,000 per Series U Dollar Preference
Share plus accrued dividends equalling $635.94 per share.
2022
2021
2020
£m
£m
£m
Additional Tier 1 notes
US$1.15 billion 8% notes callable August 2025
(1)
735
735
735
US$2.65 billion 8.625% notes callable August 2021
(2)
2,046
US$1.5 billion 6.000% notes callable
December 2025 - June 2026
(3)
1,220
1,220
1,220
GBP£1.0 billion 5.125% notes callable
May - November 2027
(4)
998
998
998
GBP£0.4 billion – March 2021 issuance
(5)
399
399
US$0.75 billion – June 2021 issuance
(6)
538
538
3,890
3,890
4,999
(1)
Issued in August 2015. In the event of conversion, converted into ordinary shares at a price of $3.295 nominal per £1 share.
(2)
Issued in August 2016. In the event 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 $2.179 (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 $2.448 (translated at applicable exchange rate) per £1 share.
Paid-in equity
-
comprises equity instruments issued by the
company other than those legally constituted as shares.
Additional Tier 1 instruments issued by NatWest Group plc
having the legal form of debt are classified as equity under
IFRS. The coupons on these instruments are non-cumulative
and payable at the company’s discretion. In the event NatWest
Group’s CET1 ratio falls below 7% any outstanding instruments
will be converted into ordinary shares at a fixed price.
Capital recognised for regulatory purposes cannot be
redeemed without Prudential Regulation Authority consent. This
includes ordinary shares, preference shares and additional Tier
1
instruments.
Merger reserve
-
the merger reserve comprises the premium
on shares issued to acquire NatWest Bank Plc less goodwill
amortisation charged under previous GAAP.
Capital redemption reserve
-
under UK companies legislation,
when shares are redeemed or purchased wholly or partly out
of the company's profits, the amount by which the company's
issued share capital is diminished must be transferred to the
capital redemption reserve. The capital maintenance provisions
of UK companies legislation apply to the capital redemption
reserve as if it were part of the company’s paid up share
capital. On 15 June 2017, the Court of Session approved a
reduction of NatWest plc capital so that the amounts which
stood to the credit of the capital redemption reserve were
transferred to retained earnings. The nominal value of the
shares bought back from HM Treasury in March 2021 and via
the Programme during 2022 have been transferred to the
Capital redemption reserve.
Own shares held
-
at 31 December 2022, 13 million ordinary
shares of £1.0769 each of the company (2021 - 15 million) were
held by employee share trusts in respect of share awards and
options granted to employees. During the year, the employee
share trusts purchased no ordinary shares and delivered 2
million ordinary shares in satisfaction of the exercise of options
and the vesting of share awards under the employee share
plans. The company retains the flexibility to use newly issued
shares, shares purchased by the NatWest Group Employee
Share Ownership Trust and any available treasury shares to
satisfy obligations under its employee share plans.
The
company does not use performance conditions or targets
based on earnings per share (EPS), total shareholder return
(TSR), and net asset value (NAV) in connection with its
employee share plans.
As part of the shares bought back from HM Treasury in March
2021, the company transferred 200 million ordinary shares to
treasury. The company has used a total of 76,513,524 treasury
shares to satisfy the exercise of options and the vesting of
share awards under the employee share plans. The balance of
ordinary shares held in treasury as at 31 December 2022 was
114,011,084. The figure has been adjusted to reflect the 13 for
14 share consolidation on 30 August 2022.
NatWest Group plc optimises capital efficiency by maintaining
reserves in subsidiaries, including regulated entities. Certain
preference shares and subordinated debt are also included
within regulatory capital. The remittance of reserves to the
company or the redemption of shares or subordinated capital
by regulated entities may be subject to maintaining the capital
resources required by the relevant regulator.
UK law prescribes that only the reserves of the company are
taken into account for the purpose of making distributions and
in determining permissible applications of the share premium
account.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
364
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
23 Structured entities
A structured entity (SE) is an entity that has been designed such that voting or similar rights are not the dominant factor in
deciding who controls the entity, for example when any voting rights relate to administrative tasks only and the relevant activities
are directed by means of contractual arrangements. SEs are usually established for a specific, limited purpose. They do not carry
out a business or trade and typically have no employees.
Securitisations
In a securitisation, assets, or interests in a pool of assets, are
transferred, or the credit risk is transferred via a derivative or
financial guarantee to a SE which then issues liabilities to third
party investors.
NatWest Group’s involvement in client securitisations takes a
number of forms. It may provide secured finance to, or
purchase asset-backed notes from, client sponsored SEs
secured on assets transferred by the client entity; purchase
asset backed securities issued by client sponsored SEs in the
primary or secondary markets; or provide liquidity facilities to
client sponsored SEs. In addition, NatWest Group arranges or
acts as lead manager or placement agent in client primary
markets securitisations. NatWest Group provides portfolio
structured derivative hedging solutions to clients. NatWest
Group undertakes own-asset securitisations to transfer the
credit risk on portfolios of financial assets.
Other credit risk transfer securitisations
NatWest Group transfers credit risk on originated loans and
mortgages without the transfer of assets to a SE. As part of
this, NatWest Group enters into credit derivative and financial
guarantee contracts with consolidated SEs. At 31 December
2022, debt securities in issue by such SEs (and held by third
parties) were £859 million (2021 - £867 million). The associated
loans and mortgages at 31 December 2022 were £4,361 million
(2021 - £7,137 million).
At 31 December, ECL in relation to non-defaulted assets was
reduced by £20 million (2021 - £28 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 partnerships
to provide security for issues of debt securities. NatWest Group
retains all of the risks and rewards of these assets and
continues to recognise them. The partnerships are consolidated
by NatWest Group and the related covered bonds included
within other financial liabilities. At 31 December 2022, £8,156
million (2021 - £8,965 million) of loans to customers provided
security for debt securities in issue and other borrowing of
£4,132 million (2021 - £3,512 million).
Lending of own issued securities
NatWest Group has issued, retained, and lent debt securities
under securities lending arrangements. Under standard terms
in the UK and US markets, the recipient has an unrestricted
right to sell or repledge collateral, subject to returning
equivalent securities on maturity of the transaction.
NatWest
Group retains all of the risks and rewards of own issued
liabilities lent under such arrangements and does not recognise
them. At 31 December 2022, £2,419 million (2021 - £1,494
million) of secured own issued liabilities have been retained and
lent under securities lending arrangements. At 31 December
2022, £2,244 million (2021 - £1,564 million) of loans and other
debt instruments provided security for secured own issued
liabilities that have been retained and lent under securities
lending arrangements
.
Unconsolidated structured entities
NatWest Group’s interest in unconsolidated structured entities is analysed below.
2022
2021
Asset backed
securitisation
vehicles
Investment
funds and
others
Total
Asset backed
securitisation
vehicles
Investment
funds and
others
Total
£m
£m
£m
£m
£m
£m
Trading assets and derivatives
Trading assets
616
137
753
490
117
607
Derivative assets
343
343
251
18
269
Derivative liabilities
(388)
(22)
(410)
(170)
(1)
(171)
Total
571
115
686
571
134
705
Non trading assets
Loans to customers
2,431
648
3,079
1,692
361
2,053
Other financial assets
6,334
849
7,183
3,645
379
4,024
Total
8,765
1,497
10,262
5,337
740
6,077
Liquidity facilities/loan commitments
1,723
320
2,043
1,403
135
1,538
Guarantees
107
107
Maximum exposure
11,059
2,039
13,098
7,311
1,009
8,320
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
365
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
24 Asset transfers
This note provides an overview of asset transfers which do not qualify for derecognition and therefore continue to be recognised in
NatWest Group’s balance sheet.
For accounting policy information see Accounting policies note 3.9.
Transfers that do not qualify for derecognition
NatWest Group enters into securities repurchase, lending and
total return transactions in accordance with normal market
practice which includes the provision of additional collateral if
necessary. Under standard terms in the UK and 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 repurchase agreements are not
derecognised if NatWest Group retains substantially all the risks
and rewards of ownership. The fair value (and carrying value)
of securities transferred under such transactions included on
the balance sheet, are set out below. All of these securities
could be sold or repledged by the holder.
2022
2021
The following assets have failed derecognition
(1)
£m
£m
Trading assets
6,668
13,084
Loans to bank - amortised cost
16
38
Loans to customers - amortised cost
398
1,837
Other financial assets
2,901
11,746
Total
9,983
26,705
(1)
Associated liabilities were £9,501 million (2021 – £24,747 million).
Assets pledged as collateral
NatWest Group pledges collateral with its counterparties in respect of derivative liabilities and bank and stock borrowings.
2022
2021
Assets pledged against liabilities
£m
£m
Trading assets
15,062
23,601
Loans to banks - amortised cost
66
62
Loans to customers - amortised cost
17,493
20,108
Other financial assets
(1)
3,351
3,624
Total
35,972
47,395
(1)
Includes assets pledged for pension derivatives and stock borrowings.
As part of the covered debt programme £8,156 million of loans to customers and other debt instruments (2021 – £8,965 million)
have been transferred to bankruptcy remote limited liability partnerships within the NatWest Group to provide collateral for issues
of debt securities and other borrowing by the NatWest Group of £4,132 million (2021 – £3,512 million). See Structured Entities Note.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
366
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
25 Capital resources
NatWest Group’s regulatory capital is assessed against minimum requirements that are set out under the Capital Requirements
Regulation to determine the strength of its capital base.
This note shows a reconciliation of shareholders’ equity to regulatory capital.
2022
2021
£m
£m
Shareholders’ equity (excluding non-controlling interests)
Shareholders’ equity
36,488
41,796
Preference shares - equity
(494)
Other equity instruments
(3,890)
(3,890)
32,598
37,412
Regulatory adjustments and deductions
Own credit
(58)
21
Defined benefit pension fund adjustment
(227)
(465)
Cash flow hedging reserve
2,771
395
Deferred tax assets
(912)
(761)
Prudential valuation adjustments
(275)
(274)
Goodwill and other intangible assets
(7,116)
(6,312)
Foreseeable ordinary dividends and pension contributions
(967)
(1,211)
Adjustment for trust assets
(1)
(365)
Foreseeable charges - on-market share buyback programme
(800)
(825)
Adjustment under IFRS 9 transitional arrangements
361
621
Insufficient coverage for non-performing exposures
(18)
(5)
(7,606)
(8,816)
CET1 capital
24,992
28,596
Additional Tier 1 (AT1) capital
Qualifying instruments and related share premium
3,875
3,875
Qualifying instruments and related share premium subject to phase out
571
AT1 capital
3,875
4,446
Tier 1 capital
28,867
33,042
Qualifying Tier 2 capital
Qualifying instruments and related share premium
4,953
4,935
Qualifying instruments issued by subsidiaries and held by third parties
82
314
Other regulatory adjustments
18
457
Tier 2 capital
5,053
5,706
Total regulatory capital
33,920
38,748
(1)
Prudent deduction in respect of agreement with the pension fund to establish new legal structure. See Notes 5 and 33.
It is NatWest Group policy to maintain a strong capital base, to
expand it as appropriate and to utilise it efficiently throughout
its activities to optimise the return to shareholders while
maintaining a prudent relationship between the capital base
and the underlying risks of the business. In carrying out this
policy, NatWest Group has regard to the supervisory
requirements of the PRA. The PRA uses capital ratios as a
measure of capital adequacy in the UK banking sector,
comparing a bank's capital resources with its risk-weighted
assets (the assets and off-balance sheet exposures are
weighted to reflect the inherent credit and other risks); by
international agreement, the Pillar 1 capital ratios should be not
less than 8% with a Common Equity Tier 1 component of not
less than 4.5%. NatWest Group has complied with the PRA’s
capital requirements throughout the year.
A number of subsidiaries and sub-groups within NatWest
Group, principally banking entities, are subject to various
individual regulatory capital requirements in the 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 local regulatory or legal
requirements, the availability of reserves and financial and
operating performance.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
367
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
26 Memorandum items
Contingent liabilities and commitments
NatWest Group provides its customers with a variety of services to support their businesses, such as guarantees. These are
reported as commitments.
Contingent liabilities are possible obligations dependent on a future event or present obligations which
are either not probable or cannot be measured reliably.
For accounting policy information see Accounting policies note 2.4.
The amounts shown in the table below are intended only to provide an indication of the volume of business outstanding at 31
December 2022. Although NatWest Group is exposed to credit risk in the event of a customer’s failure to meet its obligations, the
amounts shown do not, and are not intended to, provide any indication of NatWest Group's expectation of future losses.
2022
2021
£m
£m
Guarantees
3,150
2,055
Other contingent liabilities
1,855
2,004
Standby facilities, credit lines and other commitments
121,576
121,308
Contingent liabilities and commitments
126,581
125,367
Banking commitments and contingent obligations, which have
been entered into on behalf of customers and for which there
are corresponding obligations from customers, are not included
in assets and liabilities. NatWest Group's maximum exposure to
credit loss, in the event of its obligation crystallising and all
counterclaims, collateral or security proving valueless, is
represented by the contractual nominal amount of these
instruments included in the table above. These commitments
and contingent obligations are subject to NatWest Group's
normal credit approval processes.
Guarantees – NatWest Group gives guarantees on behalf of
customers. A financial guarantee represents an irrevocable
undertaking that NatWest Group will meet a customer's
specified obligations to third party if the customer fails to do so.
The maximum amount that NatWest Group could be required
to pay under a guarantee is its principal amount as disclosed in
the table above. NatWest Group expects most guarantees it
provides to expire unused.
Other contingent liabilities - these include standby letters of
credit, supporting customer debt issues and contingent
liabilities relating to customer trading activities such as those
arising from performance and customs bonds, warranties and
indemnities.
Standby facilities and credit lines - under a loan commitment,
NatWest Group agrees to make funds available to a customer
in the future. Loan commitments, which are usually for a
specified term, may be unconditionally cancellable or may
persist, provided all conditions in the loan facility are satisfied
or waived. Commitments to lend include commercial standby
facilities and credit lines, liquidity facilities to commercial paper
conduits and unutilised overdraft facilities.
Other commitments - these include documentary credits, which
are commercial letters of credit providing for payment by
NatWest Group to a named beneficiary against presentation of
specified documents, forward asset purchases, forward
deposits placed and undrawn note issuance and revolving
underwriting facilities, and other short-term trade related
transactions.
Contractual obligations for future expenditure not provided for in the accounts
The following table shows contractual obligations for future expenditure not provided for in the accounts at the year end.
2022
2021
£m
£m
Capital expenditure on property, plant and equipment
8
16
Contracts to purchase goods or services
(1)
677
682
685
698
(1)
Of which due within 1 year: £321 million (2021 – £301 million).
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
368
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
26 Memorandum items continued
Trustee and other fiduciary activities
In its capacity as trustee or other fiduciary role, NatWest Group
may hold or place assets on behalf of individuals, trusts,
companies, pension schemes and others. The assets and their
income are not included in NatWest Group's financial
statements. NatWest Group earned fee income of £266 million
(2021 - £280 million; 2020 - £245 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 compensation if a firm is unable to
meet its obligations. The FSCS funds compensation for
customers by raising management expenses levies and
compensation levies on the industry. In relation to protected
deposits, each deposit-taking institution contributes towards
these levies in proportion to their share of total protected
deposits on 31 December of the year preceding the scheme
year (which runs from 1 April to 31 March), subject to annual
maxima set by the Prudential Regulation Authority. In addition,
the FSCS has the power to raise levies on a firm that has
ceased to participate in the scheme 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 scheme.
Litigation and regulatory matters
NatWest Group plc and certain members of NatWest Group are
party to legal proceedings and involved in regulatory matters,
including as the subject of investigations and other regulatory
and governmental action (Matters) in the United Kingdom (UK),
the United States (US), the European Union (EU) and other
jurisdictions.
NatWest Group recognises a provision for a liability in relation
to these Matters when it is probable that an outflow of
economic benefits will be required to settle an obligation
resulting from past events, and a reliable estimate can be made
of the amount of the obligation.
In many of these Matters, it is not possible to determine
whether any loss is probable, or to estimate reliably the amount
of any loss, either as a direct consequence of the relevant
proceedings and regulatory matters or as a result of adverse
impacts or restrictions on NatWest Group’s reputation,
businesses and operations. Numerous legal and factual issues
may need to be resolved, including through potentially lengthy
discovery and document production exercises and
determination of important factual matters, and by addressing
novel or unsettled legal questions relevant to the proceedings in
question, before a liability can reasonably be estimated for any
claim. NatWest Group cannot predict if, how, or 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 early stage in their
development or where claimants seek substantial or
indeterminate damages.
There are situations where NatWest Group may pursue an
approach that in some instances leads to a settlement
agreement. This may occur in order to avoid the expense,
management distraction or reputational implications of
continuing to contest liability, or in order to take account of the
risks inherent in defending claims or regulatory matters, even
for those Matters for which NatWest Group believes it has
credible defences and should prevail on the merits. The
uncertainties inherent in all such Matters affect the amount and
timing of any potential outflows for both Matters with respect
to which provisions have been established and other contingent
liabilities in respect of any such Matter.
It is not practicable to provide an aggregate estimate of
potential liability for our legal proceedings and regulatory
matters as a class of contingent liabilities.
The future outflow of resources in respect of any Matter may
ultimately prove to be substantially greater than or less than
the aggregate provision that NatWest Group has recognised.
Where (and as far as) liability cannot be reasonably estimated,
no provision has been recognised. NatWest Group expects that
in future periods, additional provisions, settlement amounts and
customer redress payments will be necessary, in amounts that
are expected to be substantial in some instances. Please refer
to Note 21 for information on material provisions.
Matters which are, or could be material, having regard to
NatWest Group, considered as a whole, in which NatWest
Group is currently involved are set out below. We have
provided information on the procedural history of certain
Matters, where we believe appropriate, to aid the
understanding of the Matter.
For a discussion of certain risks associated with NatWest
Group’s litigation and regulatory matters, see the Risk Factors
relating to legal, regulatory and governmental actions and
investigations set out on pages 423 to 424.
Litigation
Residential mortgage-backed securities (RMBS) litigation in
the US
NatWest Group companies continue to defend RMBS-related
claims in the US in which the plaintiff, the Federal Deposit
Insurance Corporation (FDIC), alleges that certain disclosures
made in connection with the relevant offerings of RMBS
contained materially false or misleading statements and/or
omissions regarding the underwriting standards pursuant to
which the mortgage loans underlying the RMBS were issued.
London Interbank Offered Rate (LIBOR) and other rates
litigation
NWM Plc and certain other members of NatWest Group,
including NatWest Group plc, are defendants in a number of
class actions and individual claims pending in the United States
District Court for the Southern District of New York (SDNY)
with respect to the setting of LIBOR and certain other
benchmark interest rates. The complaints allege that certain
members of NatWest Group and other panel banks violated
various federal laws, including the US commodities and
antitrust laws, and state statutory and common law, as well as
contracts, by manipulating LIBOR and prices of LIBOR-based
derivatives in various markets through various means.
Several purported class actions relating to USD LIBOR, as well
as more than two dozen non-class actions concerning USD
LIBOR, are part of a co-ordinated proceeding in the SDNY. The
class actions include claims on behalf of persons who
purchased LIBOR-linked instruments from defendants, bonds
issued by defendants, persons who transacted futures and
options on exchanges, and lenders who made LIBOR-based
loans. The coordinated proceeding is currently in the discovery
phase. In March 2020, NatWest Group companies finalised a
settlement resolving the class action on behalf of bondholder
plaintiffs (those who held bonds issued by non-defendants on
which interest was paid from 2007 to 2010 at a rate expressly
tied to USD LIBOR). The amount of the settlement (which was
covered by an existing provision) was paid into escrow pending
court approval of the settlement.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
369
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
26 Memorandum items continued
Litigation and regulatory matters
The non-class claims filed in the 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 NatWest Group
companies and others in the High Court of Justice of England
and Wales. The action alleges collusion with regard to the
setting of USD LIBOR and that the defendants breached UK
and European competition law, as well as asserting common
law claims of fraud under US law. The 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 trial is currently anticipated to take
place in Q4 2025.
In addition to the USD LIBOR cases described above, there are
two class actions relating to JPY LIBOR and Euroyen TIBOR
that remain outstanding. The first class action, which relates to
Euroyen TIBOR futures contracts, was dismissed by the SDNY
in September 2020 on jurisdictional and other grounds, and
that decision was affirmed by the US Court of Appeals in
October 2022. The plaintiffs have petitioned the court for a
rehearing of their appeal. The second class action, which
relates 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 September 2021.
That dismissal may be the subject of a future appeal
.
Two other IBOR-related class actions, concerning alleged
manipulation of Euribor and Pound Sterling LIBOR, were
previously dismissed by the SDNY for various reasons. The
plaintiffs’ appeals in those two cases remain pending.
In June 2021, NWM Plc and the plaintiffs in the Swiss Franc
LIBOR class action finalised a settlement resolving that case.
The amount of that settlement has been paid into escrow
pending final court approval of the settlement.
Settlements in the class action relating to the Singapore
Interbank Offered Rate and Singapore Swap Offer Rate and the
class action relating to the Australian Bank Bill Swap Reference
Rate received court approval in 2022, such that the settlements
became final and the amounts previously paid into escrow
were released to the plaintiffs.
In August 2020, a complaint was filed in the United States
District Court for the Northern District of California by several
United States retail borrowers against the USD ICE LIBOR
panel banks and their affiliates (including NatWest Group plc,
NWM Plc, NWMSI and NWB Plc), alleging (i) that the very
process of setting USD ICE LIBOR amounts to illegal price-
fixing; and (ii) that banks in the United States have illegally
agreed to use LIBOR as a component of price in variable retail
loans. In September 2022, the district court dismissed the
complaint, subject to re-pleading by the plaintiffs. The plaintiffs
filed an amended complaint in October 2022, which the
defendants are again seeking to have dismissed.
NWM Plc is also named as a defendant in a motion to certify a
class action relating to LIBOR in the Tel Aviv District Court in
Israel. NWM Plc filed a motion for cancellation of service
outside the jurisdiction, which was granted in July 2020. The
claimants appealed that decision and in November 2020 the
appeal was refused and the claim dismissed by the Appellate
Court. The claim could in future be recommenced depending
on the outcome of an appeal to Israel’s Supreme Court in
respect of the dismissal of the substantive case against banks
that had a presence in Israel.
FX litigation
NWM Plc, NWMSI and/or NatWest Group plc are defendants in
several cases relating to NWM Plc’s foreign exchange (FX)
business. In 2015, NWM Plc paid US$255 million to settle the
consolidated antitrust class action filed in the SDNY on behalf
of persons who entered into over-the-counter FX transactions
with defendants or who traded FX instruments 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 against NWM
Plc, NWMSI and other banks.
In April 2019, some of the claimants in the opt-out case
described above, as well as others, served proceedings in the
High Court of Justice of England and Wales, asserting
competition claims against NWM Plc and several other banks.
The claim was transferred from the High Court of Justice of
England and Wales in December 2021 and registered in the UK
Competition Appeal Tribunal (CAT) in January 2022. In
December 2022, NWM Plc reached an agreement in principle,
subject to documentation, to resolve both the SDNY and CAT
cases. The settlement amount to be paid by NWM Plc is
covered by an existing provision.
An FX-related class action, on behalf of ‘consumers and end-
user businesses’, is proceeding in the SDNY against NWM Plc
and others. In March 2022, the SDNY denied the plaintiffs’
motion for class certification. Plaintiffs sought an immediate
appeal of the decision but the appellate court declined to
review the decision. As a result, the case is proceeding on an
individual, non-class basis, and the defendants are seeking
summary judgment dismissing the individual claims.
In May 2019, a cartel class action was filed in the Federal Court
of Australia against NWM Plc and four other banks on behalf of
persons who bought or sold currency through FX spots or
forwards between 1 January 2008 and 15 October 2013 with a
total transaction value exceeding AUD $0.5 million. The
claimant has alleged that the banks, including NWM Plc,
contravened Australian competition law by sharing information,
coordinating conduct, widening spreads and manipulating FX
rates for certain currency pairs during this period. NatWest
Group plc and NWMSI have been named in the action as ‘other
cartel participants’, but are not respondents. The claim was
served in June 2019 and NWM Plc filed its defence in March
2022.
In July and December 2019, two separate applications seeking
opt-out collective proceedings orders were filed in the CAT
against NatWest Group plc, NWM Plc and other banks. Both
applications were brought on behalf of persons who, between
18 December 2007 and 31 January 2013, entered into a
relevant FX spot or outright forward transaction in the EEA
with a relevant financial institution or on an electronic
communications network. In March 2022, the CAT declined to
certify as collective proceedings either of the applications. In
October 2022, the CAT granted permission for the applicants to
appeal that decision to the Court of Appeal. Separately, the
applicants have served judicial review proceedings, which are
due to be heard together with the appeal to the Court of
Appeal in April 2023.
Two motions to certify FX-related class actions were filed in the
Tel Aviv District Court in Israel in September and October 2018,
and were subsequently consolidated into one motion. The
consolidated motion to certify, which names The Royal Bank of
Scotland plc (now NWM Plc) and several other banks as
defendants, was served on NWM Plc in May 2020. The
applicants have sought the court’s permission to amend their
motions to certify the class actions.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
370
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
26 Memorandum items continued
Litigation and regulatory matters
NWM Plc has filed a motion challenging the permission granted
by the court for the applicants to serve the consolidated motion
outside the Israeli jurisdiction. That NWM Plc motion 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 declaration from the court that
anti-competitive FX market conduct described in decisions of
the European Commission (EC) of 16 May 2019 is unlawful,
along with unspecified damages. The claimant has amended its
claim to also refer to a December 2021 decision by the EC,
which also described anti-competitive FX market conduct. The
defendants are contesting the jurisdiction of the Dutch court.
Certain other foreign exchange transaction related claims have
been or may be threatened. NatWest Group cannot predict
whether all or any of these claims will be pursued.
Government securities antitrust litigation
NWMSI and certain other US broker-dealers are defendants in
a consolidated antitrust class action in the SDNY on behalf of
persons who transacted in US Treasury securities or derivatives
based on such instruments, including futures and options. The
plaintiffs allege that the defendants rigged the US Treasury
securities auction bidding process to deflate prices at which
they bought such securities and colluded to increase the prices
at which they sold such securities to the plaintiffs. In March
2022, the SDNY dismissed the complaint, without leave to re-
plead. The plaintiffs are appealing the dismissal.
Class action antitrust claims commenced in March 2019 are
pending in the SDNY against NWM Plc, NWMSI and other banks
in respect of Euro-denominated bonds issued by European
central banks (EGBs). The complaint alleges a conspiracy
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 prices at which customers
sold the bonds. The class consists of those who purchased or
sold EGBs in the US between 2007 and 2012. In March 2022,
the SDNY dismissed the claims against NWM Plc and NWMSI on
the ground that the complaint’s conspiracy allegations are
insufficient. The plaintiffs have filed a motion for permission to
file an amended complaint.
Swaps antitrust litigation
NWM Plc and other members of NatWest Group, including
NatWest Group plc, as well as a number of other interest rate
swap dealers, are defendants in several cases pending in the
SDNY alleging violations of the US antitrust laws in the market
for interest rate swaps. There is a consolidated class action
complaint on behalf of persons who entered into interest rate
swaps with the defendants, as well as non-class action claims
by three swap execution facilities (TeraExchange, Javelin, and
trueEx). The plaintiffs allege that the swap execution facilities
would have successfully established exchange-like trading of
interest rate swaps if the defendants 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 pending.
In June 2021, a class action antitrust complaint was filed
against a number of credit default swap dealers in New Mexico
federal court on behalf of persons who, from 2005 onwards,
settled credit default swaps in the United States by reference to
the ISDA credit default swap auction protocol. The complaint
alleges that the defendants conspired to manipulate that
benchmark through various means in violation of the antitrust
laws and the Commodity Exchange Act.
The defendants include several NatWest Group companies,
including NatWest Group plc. Defendants are seeking dismissal.
Odd lot corporate bond trading antitrust litigation
In October 2021, the SDNY granted the defendants’ motion to
dismiss the class action antitrust complaint alleging that from
August 2006 onwards various securities dealers, including
NWMSI, conspired artificially to widen spreads for odd lots of
corporate bonds bought or sold in the United States secondary
market and to boycott electronic trading platforms that would
have allegedly promoted pricing competition in the market for
such bonds. The plaintiffs have filed an appeal.
Spoofing litigation
In December 2021, three substantially similar class actions
complaints were filed in federal court in the United States
against NWM Plc and NWMSI alleging Commodity Exchange
Act and common law unjust enrichment claims arising from
manipulative trading known as spoofing. The complaints refer
to NWM Plc’s December 2021 spoofing-related guilty plea
(described below under “US investigations relating to fixed-
income securities”) and purport to assert claims on behalf of
those who transacted in US Treasury securities and futures and
options on US Treasury securities between 2008 and 2018. In
July 2022, defendants filed a motion to dismiss these claims,
which have been consolidated into one matter in the United
States District Court for the Northern District of Illinois.
Madoff
NWM N.V. was named as a defendant in two actions filed by
the trustee for the bankrupt estates of Bernard L. Madoff and
Bernard L. Madoff Investment Securities LLC, in bankruptcy
court in New York, which together seek to clawback more than
US$298 million that NWM N.V. allegedly received from certain
Madoff feeder funds and certain swap counterparties. The
claims were previously dismissed, but as a result of an August
2021 decision by the US Court of Appeals, they will now
proceed in the bankruptcy court, where they have now been
consolidated into one action, subject to NWM N.V.’s legal and
factual defences. In May 2022, NWM N.V. filed a motion to
dismiss the amended complaint in the consolidated action.
EUA trading litigation
NWM Plc was a named defendant in civil proceedings before
the High Court of Justice of England and Wales brought in 2015
by ten
companies (all in liquidation) (the ‘Liquidated
Companies’) and their respective liquidators (together, ‘the
Claimants’). The Liquidated Companies previously traded in
European Union Allowances (EUAs) in 2009 and were alleged
to be VAT defaulting traders within (or otherwise connected to)
EUA supply chains of which NWM Plc was a party. In March
2020, the court held that NWM Plc and Mercuria Energy
Europe Trading Limited (‘Mercuria’) were liable for dishonestly
assisting and knowingly being a party to fraudulent trading
during a seven business day period in 2009.
In October 2020, the High Court quantified total 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 Appeal set aside the High
Court’s judgment and ordered that a retrial take place before a
different High Court judge. The claimants have been denied
permission by the Supreme Court to appeal that decision and
the retrial will therefore proceed on a date to be scheduled.
Mercuria has also been denied permission by the Supreme
Court to appeal the High Court’s finding that NWM Plc and
Mercuria were both vicariously liable.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
371
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
26 Memorandum items continued
Litigation and regulatory matters
Offshoring VAT assessments
HMRC issued protective tax assessments in 2018 against
NatWest Group plc totalling £143 million relating to unpaid VAT
in respect of the UK branches of two NatWest Group
companies registered in India. NatWest Group formally
requested reconsideration by HMRC of their assessments, 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 application 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 required to pay
£143 million to HMRC, and payment was made in December
2020. The appeal and the application for judicial review have
both been stayed pending resolution of a separate case
involving another bank.
US Anti-Terrorism Act litigation
NWM N.V. and certain other financial institutions are
defendants in several actions filed by a number of US nationals
(or their estates, survivors, or heirs), 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 defendants 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 terror cells that
committed the attacks, in violation of the US Anti-Terrorism
Act, by agreeing to engage in ‘stripping’ of transactions
initiated by the Iranian banks so that the Iranian nexus to the
transactions would not be detected.
The first of these actions was filed in the United States District
Court for the Eastern District of New York in November 2014.
In September 2019, the district court dismissed the case,
finding that the claims were deficient for several reasons,
including lack of sufficient allegations as to the alleged
conspiracy and causation. On 5 January 2023, the US Court of
Appeals affirmed the district court’s dismissal of this case.
Another action, filed in the SDNY in 2017, was dismissed by the
SDNY in March 2019 on similar grounds as the first case, but
remains subject to appeal to the US Court of Appeals. Other
follow-on actions that are substantially similar to the two that
have now been dismissed are pending in the same courts.
1MDB litigation
A Malaysian court claim was served in Switzerland in
November 2022 by 1MDB, a Sovereign Wealth Fund, in which
Coutts & Co Ltd was named, along with six others, as a
defendant in respect of losses allegedly incurred by 1MDB. It is
claimed that Coutts & Co Ltd is liable as a constructive trustee
for having dishonestly assisted the directors of 1MDB in the
breach of their fiduciary duties by failing (amongst other
alleged claims) to undertake due diligence in relation to a
customer of Coutts & Co Ltd, through which funds totalling
c.US$1 billion were received and paid out between 2009 and
2011. The claimant seeks the return of that amount plus
interest. Coutts & Co Ltd filed an application in January 2023
challenging the validity of service and the Malaysian court’s
jurisdiction to hear the claim. Coutts & Co Ltd is a company
registered in Switzerland and is in wind-down following the
announced sale of its business assets in 2015.
Regulatory matters (including investigations and customer
redress programmes)
NatWest Group’s businesses and financial condition can be
affected by the actions of various governmental and regulatory
authorities in the UK, the US, the EU and elsewhere. NatWest
Group has engaged, and will continue to engage, in discussions
with relevant governmental and regulatory authorities,
including in the UK, the US, the EU and elsewhere, on an
ongoing and regular basis, and in response to informal and
formal inquiries or investigations, regarding operational,
systems and control evaluations and issues including those
related to compliance with applicable laws and regulations,
including consumer protection, investment advice, business
conduct, competition/anti-trust, VAT recovery, anti-bribery,
anti-money laundering and sanctions regimes. NatWest Group
expects government and regulatory intervention in financial
services to be high for the foreseeable future, including
increased scrutiny from competition and other regulators in the
retail and SME business sectors.
Any matters discussed or identified during such discussions and
inquiries may result in, among other things, further inquiry or
investigation, other action being taken by governmental and
regulatory authorities, increased costs being incurred 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 circumstances
mentioned in this paragraph or below could have a material
adverse effect on NatWest Group, its business, authorisations
and licences, reputation, results of operations or the price of
securities issued by it, or lead to material additional provisions
being taken.
NatWest Group is co-operating fully with the matters described
below.
US investigations relating to fixed-income securities
In December 2021, NWM Plc pled guilty in the United States
District Court for the District of Connecticut to one count of
wire fraud and one count of securities fraud in connection with
historical spoofing conduct by former employees in US
Treasuries markets between January 2008 and May 2014 and,
separately, during approximately three months in 2018. The
2018 trading occurred during the term of a non-prosecution
agreement (NPA) between NWMSI and the United States
Attorney's Office for the District of Connecticut (USAO CT),
under which non-prosecution was conditioned on NWMSI and
affiliated companies not engaging in criminal conduct during
the term of the NPA. The relevant trading in 2018 was
conducted by two NWM traders in Singapore and breached
that NPA. The plea agreement reached with the US
Department of Justice and the USAO CT resolved both the
spoofing conduct and the breach of the NPA.
As required by the resolution and sentence imposed by the
court, NWM Plc is subject to a three-year period of probation.
The plea agreement also imposes an independent corporate
monitor. In addition, NWM Plc has committed to compliance
programme reviews and improvements and agreed to
reporting and co-operation obligations.
Other material adverse collateral consequences may occur as
a result of this matter, as further described in the Risk Factors
relating to legal, regulatory and governmental actions and
investigations set out on pages 423 to 424.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
372
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
26 Memorandum items continued
Litigation and regulatory matters
RBSI inspection report and referral to enforcement
The Isle of Man Financial Services Authority undertook an
inspection at The Royal Bank of Scotland International Limited
(RBSI), Isle of Man, in 2021, following which it issued an
inspection report. The inspection was in relation to anti-money
laundering and counter-terrorist financing controls and
procedures relating to specific RBSI customers. In May 2022,
the FSA notified RBSI that it had been referred to its
Enforcement Division in relation to certain issues identified in
the inspection report.
RBSI reliance regime and referral to enforcement
In January 2023, the Jersey Financial Services Commission
notified RBSI that it had been referred to its Enforcement
Division in relation to RBSI’s operation of the reliance regime.
The reliance regime is specific to certain Crown Dependencies
and enables the bank to rely on regulated third parties for
specific due diligence information.
Investment advice review
In October 2019, the FCA notified NatWest Group of its
intention to appoint a Skilled Person under section 166 of the
Financial Services and Markets Act 2000 to conduct a review of
whether NatWest Group’s past business review of investment
advice provided during 2010 to 2015 was subject to
appropriate governance and accountability and led to
appropriate customer outcomes. The Skilled Person’s review
has concluded and, after discussion with the FCA, NatWest
Group has now commenced additional review / remediation
work.
Review and investigation of treatment of tracker mortgage
customers in Ulster Bank Ireland DAC
In December 2015, correspondence was received from the CBI
setting out an industry examination framework in respect of the
sale of tracker mortgages from approximately 2001 until the
end of 2015. The redress and compensation process has now
largely concluded, although certain cases remain outstanding.
UBIDAC customers have lodged tracker mortgage complaints
with the Financial Services and Pensions Ombudsman (FSPO).
UBIDAC is challenging three FSPO adjudications in the Irish
High Court. The outcome and impact of that challenge on those
and related complaints is uncertain but may be material.
Other customer remediation in Ulster Bank Ireland DAC
UBIDAC has identified further legacy business issues and these
remediation programmes are ongoing.
27 Analysis of the net investment in business interests and intangible assets
This note shows cash flows relating to obtaining or losing control of associates or subsidiaries and net assets and liabilities
purchased and sold. These cash flows are presented as investing activities on the cash flow statement.
2022
2021
2020
£m
£m
£m
Acquisition of interests in associates
(1)
Additional investment in associates
(51)
(40)
Net assets/liabilities purchased
(3,128)
Net outflow of cash in respect of acquisitions
(1)
(3,179)
(40)
Sale of interests in associates
27
Disposal of net assets and liabilities
6,270
114
288
(Loss)/profit on disposal of net assets and liabilities
(106)
55
3
Net inflow of cash in respect of disposals
6,164
169
318
Cash expenditure on intangible assets
(743)
(479)
(348)
Net inflow/(outflow) of cash
5,420
(3,489)
(70)
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
373
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
28 Analysis of changes in financing during the year
This note shows cash flows and non-cash movements relating to the financing activities of the Group. These activities reflect
movements in share capital, share premium, paid-in equity, subordinated liabilities and MRELs.
Share capital, share premium,
and paid-in equity
Subordinated liabilities
MRELs
2022
2021
2020
2022
2021
2020
2022
2021
2020
£m
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January
16,519
18,239
17,246
8,429
9,962
9,979
23,423
20,873
19,249
Issue of paid-in equity
937
2,218
Issue of subordinated liabilities
648
1,634
1,631
Redemption of subordinated liabilities
(3,693)
(4,765)
(3,502)
Interest on subordinated liabilities
(374)
(321)
(510)
Issue of MRELs
3,721
3,383
1,309
Maturity and redemption of MRELs
(4,992)
(2)
Interest on MRELs
(703)
(647)
(671)
Net cash inflow/(outflow) from financing
937
2,218
(3,419)
(3,452)
(2,381)
(1,974)
2,736
636
Ordinary shares issued
87
52
Share cancellation
(929)
(698)
Effects of foreign exchange
597
(18)
(234)
1,889
(190)
(514)
Changes in fair value of subordinated
liabilities and MRELs
(594)
(434)
133
(1,806)
(649)
829
Preference shares reclassified to
subordinated liabilities
750
Paid in equity reclassified to subordinated
liabilities
(2,046)
(1,277)
1,915
1,632
Loss on sale of subordinated liabilities
and MRELs
161
145
324
Interest on subordinated liabilities
and MRELs
370
311
509
733
653
673
Other adjustments
(34)
At 31 December
15,590
16,519
18,239
6,260
8,429
9,962
22,265
23,423
20,873
29 Analysis of cash and cash equivalents
In the cash flow statement, cash and cash equivalents comprises cash, loans to banks and treasury bills with an original maturity
of less than three months that are readily convertible to known amounts of cash and subject to insignificant risk of change in value.
2022
2021
2020
£m
£m
£m
At 1 January
190,706
139,199
100,588
Net (decrease)/increase in cash and cash equivalents
(32,257)
51,507
38,611
At 31 December
158,449
190,706
139,199
Comprising:
Cash and balances at central banks
144,832
177,757
124,489
Trading assets
8,551
7,137
9,220
Other financial assets
19
16
173
Loans to banks
(1)
5,047
5,796
5,317
Cash and cash equivalents
158,449
190,706
139,199
(1)
Includes cash collateral posted with bank counterparties in respect of derivative liabilities of £4,895 million (2021 - £4,293 million; 2020 - £7,592 million).
Certain members of NatWest Group are required by law or regulation to maintain balances with the central banks in the
jurisdictions in which they operate. Natwest Markets N.V.
had mandatory reserve deposits with
De Nederlandsche Bank N.V.
of €64
million (2021 - €60 million, 2020 - €81 million).
The Royal Bank of Scotland International (Holdings) Limited had balances with
Central Bank of Luxembourg of £108 million (2021 - £123 million, 2020 - £59 million)
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
374
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
30 Directors' and key management remuneration
Directors and key management are remunerated for services rendered in the period. The executive directors may participate in
the company's long-term incentive plans, executive share option and sharesave schemes and details of their interests in the
company's shares arising from their participation are given in the directors' remuneration report. Details of the remuneration
received by each director are also given in the directors' remuneration report
.
Key management comprises members of the NatWest Group plc and NWH Ltd Boards, members of the NatWest Group plc and
NWH Ltd Executive Committees, and the Chief Executives of NatWest Markets Plc and RBS International (Holdings) Limited. This is
on the basis that these individuals have been identified as Persons Discharging Managerial Responsibilities of NatWest Group plc
under the new governance structure.
2022
2021
Directors' remuneration
£000
£000
Non-executive directors emoluments
1,685
1,641
Chairman and executive directors emoluments
5,804
4,688
7,489
6,329
Amounts receivable under long-term incentive plans and share option plans
542
549
Total
8,031
6,878
Compensation of key management
The aggregate remuneration of directors and other members of key management during the year was as follows:
2022
2021
£000
£000
Short-term benefits
22,175
17,303
Post-employment benefits
732
820
Share-based payments
2,547
2,491
25,454
20,614
Short term benefits include benefits expected to be settled wholly within twelve months of Balance Sheet date. Post-employment
benefits include defined benefit contributions for active members and pension funding to support contributions to the defined
contribution schemes. Share-based payments include awards vesting under rewards schemes.
31 Transactions with directors and key management
This note presents information relating to any transactions with directors and key management. Key management comprises
directors of the company and Persons Discharging Managerial Responsibilities (PDMRs) of NatWest Group plc.
For the purposes of IAS 24 Related party disclosures, key management comprises directors of the company and PDMRs of NatWest
Group plc. Key management have banking relationships with NatWest Group entities which are entered into in the normal course
of business and on substantially the same terms, including interest rates and security, as for comparable transactions with other
persons of a similar standing or, where applicable, with other employees. These transactions did not involve more than the normal
risk of repayment or present other unfavourable features.
Amounts in the table below are attributed to each person at their highest level of NatWest Group key management.
2022
2021
£000
£000
Loans to customers - amortised cost
12,137
9,128
Customer deposits
47,866
51,018
At 31 December 2022, amounts outstanding in relation to transactions, arrangements and agreements entered into by authorised
institutions in NatWest Group, as defined in UK legislation, were £9,636,586 in respect of loans to 8 persons who were directors of
the company at any time during the financial period.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
375
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
32 Related parties
A related party is a person or entity that is related to the entity that is preparing its financial statements. Transactions between an
entity and any related party are disclosed in the financial statements in accordance with both accounting standards and relevant
listing rules to ensure readers are aware of how financial statements may be affected by these transactions
.
UK Government
The UK Government through HM Treasury is the ultimate
controlling party of The NatWest Group plc. The UK
Government’s shareholding is managed by UK Government
Investments Limited, a company wholly owned by the UK
Government. As a result the UK Government and UK
Government controlled bodies are related parties of the Group.
At 31 December 2022 HM Treasury’s holding in the company’s
ordinary shares was 45.97%.
NatWest Group enters into transactions with many of these
bodies. Transactions include the payment of: taxes – principally
UK corporation tax (Note 7) and value added tax; national
insurance contributions; local authority rates; and regulatory
fees and levies (including the bank levy (Note 3) and FSCS levy
(Note 26) - together with banking transactions such as loans
and deposits undertaken in the normal course of banker-
customer relationships.
Bank of England facilities
NatWest Group may participate in a number of schemes
operated by the Bank of England in the normal course of
business.
Members of NatWest Group that are UK authorised institutions
are required to maintain non-interest bearing (cash ratio)
deposits with the Bank of England amounting to 0.403% of their
average eligible liabilities in excess of £600 million. They also
have access to Bank of England reserve accounts: sterling
current accounts that earn interest at the Bank of England Base
rate.
NatWest Group provides guarantees for certain subsidiaries
liabilities to the Bank of England.
Other related parties
In their roles as providers of finance, NatWest Group
companies provide development and other types of capital
support to businesses. These investments are made in the
normal course of business.
To further strategic partnerships, NatWest group may seek
to invest in third parties or allow third parties to hold a
minority interest in a subsidiary of NatWest group. We
disclose as related parties where stakes of 10 per cent or
more are held. Ongoing business transactions with these
entities are on normal commercial terms.
We hold investments and other assets of £871 million and
total liabilities of £4.5 million.
NatWest Group recharges NatWest Group Pension Fund with
the cost of administration services incurred by it. The
amounts involved are not material to NatWest Group.
During February 2023, the Group has entered into an
agreement to establish a new legal structure to hold assets,
consolidated on the Group’s balance sheet, to meet potential
future contributions required by the Main section of the
Group’ Pension Fund. This transaction will require a future
transfer of £471 million to the Reservoir Trust
once the final
dividend for 2022 approved by shareholders. This
transaction does not create a pension liability with the Main
section of the Group Pension Fund.
See further details in
note 5 and note 33.
In accordance with IAS 24, transactions or balances
between NatWest Group entities that have been eliminated
on consolidation are not reported.
The primary financial statements of the parent company
include transactions and balances with its subsidiaries which
have been further disclosed in the relevant notes.
Notes to the consolidated financial statements
continued
NatWest Group
Annual Report and Accounts 2022
376
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
33 Post balance sheet events
A
post balance sheet event is an event that takes place between 31 December 2022 (reporting date) and 16 February 2023 (date
of approval of these financial statements). Significant events are included in the financial statements either to provide new
information about conditions that existed at 31 December 2022, including estimates used to prepare the financial statements
(known as an adjusting event) or to provide new information about conditions that did not exist at 31 December 2022 (non-
adjusting events). This note provides information relating to material non-adjusting events.
On 6 February 2023, NWB reached agreement with the trustees of the Main Section of the Group pension scheme to recognise
that the final distribution linked contribution to the Main Scheme, of up to £471 million, in 2023 is not expected to be required. In its
place, agreement was reached to establish a new legal
structure to hold assets with a value equivalent to £471 million. These
assets would become transferrable to the Main section in the event that future triggers, reflecting a funding requirement, were
met. The assets are not de-recognised from NWB balance sheet but are recorded as encumbered. The Group believes likelihood of
triggers being met are remote given the current funding position of the Main section.
Other than as disclosed in the accounts, there have been no other significant events between 31 December 2022 and the date of
approval of these accounts which would require a change or additional disclosure.
Parent company financial
statements and notes
NatWest Group
Annual Report and Accounts 2022
377
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Balance sheet as at 31 December 2022
2022
2021
Note
£m
£m
Assets
Derivatives with subsidiaries
827
974
Amounts due from subsidiaries
4
25,981
29,962
Other financial assets
668
Investments in Group undertakings
9
52,816
48,835
Other assets
42
38
Total assets
79,666
80,477
Liabilities
Amounts due to subsidiaries
4
30
378
Derivatives
1,380
704
Other financial liabilities
22,229
23,600
Subordinated liabilities
8
5,820
7,740
Other liabilities
95
150
Total liabilities
29,554
32,572
Owners’ equity
50,112
47,905
Total liabilities and equity
79,666
80,477
Owners’ equity of NWG plc as at 31 December 2022 includes the profit for the year of £8,111 million (2021 - £7,147 million).
As permitted by section 408(3) of the Companies Act 2006, the primary financial statements of the company do not include an
income statement or a statement of comprehensive income.
The accompanying notes on pages 380 to 392 form an integral part of these financial statements.
The accounts were approved by the Board of directors on 16 February 2023 and signed on its behalf by:
Howard Davies
Alison Rose-Slade DBE
Katie Murray
NatWest Group plc
Chairman
Group Chief Executive Officer
Group Chief Financial Officer
Registered No. SC45551
Parent company financial statements and notes
continued
NatWest Group
Annual Report and Accounts 2022
378
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Statement of changes in equity for the year ended 31 December 2022
2022
2021
2020
£m
£m
£m
Called-up share capital - at 1 January
11,468
12,129
12,094
Ordinary shares issued
37
35
Share cancellation
(1,2)
(929)
(698)
At 31 December
10,539
11,468
12,129
Paid-in equity - at 1 January
3,875
4,979
4,047
Reclassified
(3)
(2,037)
(1,277)
Issued
933
2,209
At 31 December
3,875
3,875
4,979
Share premium - at 1 January
1,161
1,111
1,094
Ordinary shares issued
50
17
At 31 December
1,161
1,161
1,111
Cash flow hedging reserve - at 1 January
36
42
67
Amount recognised in equity
3
8
4
Amount transferred from equity to earnings
(31)
(12)
(33)
Tax
7
(2)
4
At 31 December
15
36
42
Capital redemption reserve - at 1 January
698
Share cancellation
(1,2)
929
698
At 31 December
1,627
698
Own shares held - at 1 January
(348)
Shares vested under employee share schemes
109
37
Own shares acquired
(1)
(385)
At 31 December
(239)
(348)
Retained earnings - at 1 January
31,015
26,178
36,485
Profit/(loss) attributable to ordinary shareholders and other equity owners
8,111
7,147
(9,573)
Equity preference dividends paid
(19)
(26)
Ordinary dividends paid
(1,205)
(693)
Special dividend paid
(1,746)
Paid-in equity dividends paid
(249)
(299)
(355)
Unclaimed dividend
2
Shares issued under employee share schemes
(1)
Shares repurchased
(1,2)
(2,054)
(1,423)
Redemption of preference shares
(5)
(750)
Redemption/reclassification of paid-in equity
(3)
- gross
125
(358)
- tax
3
Share-based payments - gross
12
At 31 December
33,134
31,015
26,178
Owners’ equity at 31 December
50,112
47,905
44,439
(1)
In March 2022, there was an agreement with HM Treasury to buy 549.9 million (March 2021 - 591 million) ordinary shares in NatWest Group plc from UK Government Investments
Ltd, at 220.5 pence per share (March 2021 - 190.5 pence per share) for the total consideration of £1.22 billion (March 2021 - £1.13 billion). NatWest Group cancelled all 549.9 million
of the purchased ordinary shares (March 2021 - NatWest Group cancelled 391 million of the purchased ordinary shares, and held the remaining 200 million in own shares held). The
nominal value of the share cancellation has been transferred to the capital redemption reserve.
(2)
NatWest Group plc repurchased and cancelled 379.3 million (2021 - 310.8 million) shares for total consideration of £829.3 million (2022 £676.2 million) excluding fees as part of the
respective 2021 and 2022
On Market Share Buyback Programmes that concluded earlier this year . The nominal value of the share cancellations has been transferred to the capital
redemption reserve.
(3)
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.
(4)
The total distributable reserves for NWG plc is £33,134 million (2021 – £31,015 million).
(5)
Following an announcement of a Regulatory Call in February 2022, the Series U preference shares were reclassified to liabilities. A £254 million loss was recognised in P&L reserves
as a result of FX unlocking.
The accompanying notes on pages 380 to 392 form an integral part of these financial statements
.
Parent company financial statements and notes
continued
NatWest Group
Annual Report and Accounts 2022
379
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Cash flow statement for the year ended 31 December 2022
2022
2021
2020
Note
£m
£m
£m
Operating profit/(loss) before tax from continuing operations
7,963
7,133
(9,698)
Adjustments for:
Impairment releases on intercompany loans to bank
(6)
Net impairment (reversals)/charges of investments in Group undertakings
(3,922)
(2,600)
9,606
Change in fair value taken to profit or loss on other financial liabilities and
subordinated liabilities
(845)
(440)
672
Elimination of foreign exchange differences
960
(14)
(540)
Other non-cash items
(32)
(12)
(31)
Dividends receivable from subsidiaries
(4,842)
(4,872)
(485)
Loss on sale of investments in Group undertakings
1
22
Interest payable on MRELs and subordinated liabilities
485
447
537
Loss on redemption of own debt
351
113
324
Charges and releases on provisions
(3)
(8)
Net cash flows from trading activities
119
(232)
377
Decrease/(increase) in derivative assets with subsidiaries
150
614
(598)
Decrease/(increase) in amounts due from subsidiaries
2,794
(1,825)
(792)
Decrease/(increase) in financial assets
665
(89)
(302)
(Increase)/decrease in other assets
(10)
2
(2)
(Decrease)/increase in amounts due to subsidiaries
(253)
(347)
289
Increase/(decrease) in derivative liabilities
676
(398)
391
Increase in other financial liabilities
2
Increase/(decrease) in other liabilities
81
(2)
(33)
Change in operating assets and liabilities
4,103
(2,045)
(1,045)
Income taxes received
38
97
40
Net cash flows from operating activities
(1)
4,260
(2,180)
(628)
Sale of other financial assets
3
Additional investments in Group undertakings
(1,059)
(940)
(27)
Disposals of investments in Group undertakings
999
911
Dividends received from subsidiaries
4,842
4,872
485
Net cash flows from investing activities
4,785
4,843
458
Movement in MRELs
672
1,531
(147)
Movement in subordinated liabilities
(3,623)
(2,256)
(1,972)
Ordinary shares issued
87
109
Share repurchased
(2,054)
(1,808)
Dividends paid
(3,200)
(1,011)
(381)
Issue of paid-in equity
933
2,209
Net cash flows from financing activities
10
(8,205)
(2,524)
(182)
Effects of exchange on cash and cash equivalents
27
4
1
Net increase/(decrease) in cash and cash equivalents
867
143
(351)
Cash and cash equivalents at 1 January
331
188
539
Cash and cash equivalents at 31 December
(2)
1,198
331
188
(1)
Includes interest received of £282 million (2021 - £183 million, 2020 - £344 million) and interest paid of £713 million (2021 - £551 million, 2020 - £816 million).
(2)
Cash and cash equivalents comprise intragroup loans and advances with a maturity of less than 3 months for 2022, 2021 and 2020.
Parent company financial statements and notes
continued
NatWest Group
Annual Report and Accounts 2022
380
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
1. Presentation of financial statements
The accounting policies applied to the parent company financial statements are the same as those applied in the consolidated
financial statements except investment in group undertaking (subsidiaries) are stated at cost less impairment
and that it has no
policy regarding consolidation.
The directors have prepared
the financial statements on a going concern basis based on the directors’ assessment that the parent
company will continue in operational existence for a period of twelve months from the date the financial statements are approved
(refer to the Report of the directors).
2. Critical accounting policies and sources of estimation uncertainty
The reported results of the parent company are sensitive to the accounting policies, assumptions and estimates that underlie the
preparation of its financial statements. The judgments and assumptions involved in the parent company’s accounting policies that
are considered by the Board to be the most important to the portrayal of its financial condition are those involved in assessing the
impairment, if any, in its investment in group undertakings, refer to Note 9.
3 Derivatives with subsidiaries – designated hedges
Fair value hedging is used to hedge loans and other financial liabilities, and cash flow hedging is used to hedge other financial
liabilities and subordinated liabilities.
For accounting policy information see Accounting policies notes 3.8 and 3.12.
Derivatives held for hedging purposes are as follows:
2022
2021
Notional
Assets
Liabilities
Notional
Assets
Liabilities
£bn
£m
£m
£bn
£m
£m
Fair value hedging - interest rate contracts
19.8
93
829
22.2
825
167
Cash flow hedging - exchange rate contracts
1.4
13
4.9
8
Total
93
842
833
167
Parent company financial statements and notes
continued
NatWest Group
Annual Report and Accounts 2022
381
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 assets and liabilities in accordance with the categories of financial instruments in
IFRS 9.
For accounting policy information see accounting policies 3.8, 3.9, 3.10 and 3.12.
Amortised
Other
MFVTPL
FVOCI
cost
assets
Total
Assets
£m
£m
£m
£m
£m
Derivatives with subsidiaries
827
827
Amounts due from subsidiaries
15,243
10,667
71
25,981
Other financial assets
Investment in group undertakings
52,816
52,816
Other assets
42
42
31 December 2022
16,070
10,667
52,929
79,666
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
Held-for-
Amortised
Other
trading
DFV
cost
liabilities
Total
Liabilities
£m
£m
£m
£m
£m
Amounts due to subsidiaries
18
12
30
Derivatives with subsidiaries
1,380
1,380
Other financial liabilities
(1)
8,311
13,918
22,229
Subordinated liabilities
5,820
5,820
Other liabilities
95
95
31 December 2022
1,380
8,311
19,756
107
29,554
Amounts due to subsidiaries
252
113
13
378
Derivatives with subsidiaries
704
704
Other financial liabilities
(1)
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 from/to subsidiaries
2022
2021
£m
£m
Assets
Trading assets
811
Loans to banks and customers - amortised cost
10,667
13,773
Other financial assets
14,432
16,189
Other assets
71
Amounts due from subsidiaries
25,981
29,962
Derivatives
(2)
827
974
Liabilities
Bank and customer deposits
252
Other liabilities
12
13
Subordinated liabilities
18
113
Amounts due to subsidiaries
30
378
Derivatives
(2)
1,380
704
(1)
Other financial liabilities represent MRELs.
(2)
Intercompany derivatives are included within derivative classification on the balance sheet.
Parent company financial statements and notes
continued
NatWest Group
Annual Report and Accounts 2022
382
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
5 Financial instruments
Interest rate benchmark reform
NatWest Group plc continues to work on the transition of USD IBOR exposures to risk free rates in advance of the cessation date
of 30 June 2023. Derivatives are expected to transition during April and May 2023 and other exposures in line with fallback
provisions or deferred switches using widely accepted methodologies. The instruments yet to transition reflect an insignificant
element of NatWest Group plc’s exposures. Instruments with exposures to other rates transitioned at the end of 2021, or at the first
contractual reset date, or at a date agreed with the counterparty.
The level of exposures without explicit or agreed conversion provisions as of the preceding year were as follows:
Rates subject to IBOR reform
GBP LIBOR
USD IBOR
Other IBOR
Total
2021
£m
£m
£m
£m
Amounts due from subsidiaries
9,338
9,338
Other financial assets
665
665
Other financial liabilities
1,320
7,055
97
8,472
Subordinated liabilities
604
604
Derivatives notional - with subsidiaries (£bn)
20.4
20.4
AT1 issuances
As part of its capital management activities NatWest Group plc has acquired certain equity instruments issued by its subsidiaries
which contain reset clauses linked to IBOR rates subject to reform reported in investment in group undertakings.
These are outlined below:
31 December 2021
£m
USD$2 billion 8.0169%
1,581
£300 million 6.597%
300
USD$2.65 billion 7.9916%
1,161
USD$950 million 7.9604%
749
USD$200 million 5.540%
155
6 Financial instruments - fair value of financial instruments not carried at fair value
The following table shows the carrying value and fair value of financial instruments carried at amortised cost on the balance sheet.
2022
2021
Carrying
Carrying
value
Fair value
value
Fair value
£bn
£bn
£bn
£bn
Financial assets
Amounts due from subsidiaries
(1)
10.7
10.3
13.8
13.9
Financial liabilities
Amounts due to subsidiaries
(2)
0.1
0.2
Other financial liabilities - debt securities in issue
(3)
13.9
14.0
17.0
17.5
Subordinated liabilities
(3)
5.8
5.5
7.7
8.2
(1)
Fair value hierarchy level 2 - £5.5 billion (2021 - £5.9 billion) and level 3 - £4.8 billion (2021 - £8.1 billion).
(2)
Fair value hierarchy level 2 in 2021.
(3)
Fair value hierarchy level 2.
Parent company financial statements and notes
continued
NatWest Group
Annual Report and Accounts 2022
383
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 residual maturity of financial instruments based on contractual date of maturity.
2022
2021
Less than
More than
Less than
More than
12 months
12 months
Total
12 months
12 months
Total
£m
£m
£m
£m
£m
£m
Assets
Derivatives with subsidiaries
190
637
827
49
925
974
Amounts due from subsidiaries
(1)
5,756
20,154
25,910
8,276
21,686
29,962
Other financial assets
668
668
Liabilities
Amounts due to subsidiaries
(2)
18
18
254
111
365
Derivatives with subsidiaries
66
1,314
1,380
1
703
704
Other financial liabilities
4,568
17,661
22,229
3,709
19,891
23,600
Subordinated liabilities
693
5,127
5,820
1,018
6,722
7,740
(1)
Amounts due from subsidiaries relating to non-financial instruments of £71 million (2021 - Nil) have been excluded from the table.
(2)
Amounts due to subsidiaries relating to non-financial instruments of £12 million (2021 - £13 million) have been excluded from the table.
Financial liabilities: contractual maturity
The following table shows undiscounted cash flows payable up to 20 years from the balance sheet date, including future interest
payments.
Held-for-trading liabilities amounting to £0.5 billion (2021 - £0.8 billion) have been excluded from the tables.
0-3 months
3-12 months
1-3 years
3-5 years
5-10 years
10-20 years
2022
£m
£m
£m
£m
£m
£m
Liabilities by contractual maturity
Amounts due to subsidiaries
(1)
1
3
3
7
14
Derivatives held for hedging
82
270
398
106
53
Other financial liabilities
2,213
2,081
7,259
8,278
6,850
Subordinated liabilities
18
853
2,660
1,849
1,468
2,313
3,205
10,320
10,236
8,378
14
2021
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
(1)
Amounts due to subsidiaries relating to non-financial instruments have been excluded from the tables.
8 Subordinated liabilities
2022
2021
£m
£m
Dated loan capital
5,820
7,689
Undated loan capital
51
5,820
7,740
For details of subordinated liabilities, please refer Note 20 to the consolidated financial statements and notes.
For accounting policy information see Accounting policies notes 3.8 and 3.11.
Parent company financial statements and notes
continued
NatWest Group
Annual Report and Accounts 2022
384
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 assesses whether there is any indication that its investment in its Group undertakings is
impaired. If any such indication exists, the company undertakes an impairment test by comparing the carrying value of the
investment in its Group undertakings with its estimated recoverable amount. The key judgment is in determining the recoverable
amount. The recoverable amount of an 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 future cash flows of the entity. Impairment testing inherently involves a
number of judgments: the five-year cash flow forecast, the choice of appropriate discount and growth rates, and the estimation of
fair value.
For accounting policy information see Note 1.
Investments in Group undertakings are carried at cost less impairment losses. Movements during the year were as follows:
2022
2021
£m
£m
At 1 January
48,835
46,229
Additional investments in Group undertakings
1,059
940
Disposals of investments in Group undertakings
(1,000)
(934)
Net reversal of impairments of investments
3,922
2,600
At 31 December
52,816
48,835
The recoverable amount of investments 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 measurement is categorised as Level 3 of
the fair value hierarchy. The carrying value of Investments in Group undertakings at 31 December 2022 is supported by the
respective recoverable values of the entities.
In May 2022 the company issued £1,000 million of contingent convertible AT1 notes to NWH Ltd and in June 2022 redeemed
£999.9 million of contingent convertible AT1 notes issued to NWH Ltd. In 2022 the company also invested additional capital of £59
million in its subsidiary, RBS AA Holdings.
In 2022, net reversal of impairments of investments includes a £4,069 million reversal of an earlier impairment of the company's
investment in NatWest Holdings Limited as improved five-year cash flow forecasts increased the value in use and a £147 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. The net reversal of impairments of investments in 2021 was mainly
related to NatWest Holdings Limited’s impairment reversals.
The impact of reasonably possible changes to the more significant variables in the value in use calculations for Natwest Holdings
Limited are presented below. This reflects the sensitivity of the value in use to each variable on its own. In all cases there is
sufficient headroom remaining to absorb changes in the assumptions. It is possible that more than one change may occur at the
same time. The value in use calculations use 15.3% as a pre-tax discount rate and 1.4% as a long term growth rate.
The value in use model shows the following sensitivities:
Potential VIU movement
2022
2021
£bn
£bn
1% adverse movement in discount rate
(6.0)
(4.4)
1% adverse movement in terminal growth rate
(3.1)
(2.0)
£500 million adverse movement in operating profit before tax
(3.8)
(4.3)
The principal subsidiary undertakings of the company are shown below. Their capital consists of ordinary shares, preference
shares and additional Tier 1 notes which are unlisted with the exception of certain preference shares listed by NWB Plc. All of these
subsidiaries are included in NatWest Group’s consolidated financial statements and have an accounting 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 Britain
100%
The Royal Bank of Scotland plc
(3)
Banking
Great Britain
100%
Coutts & Company
(2, 3)
Banking
Great Britain
100%
Ulster Bank Ireland Designated Activity Company
(3)
Banking
Republic of Ireland
100%
NatWest Markets Plc
Banking
Great Britain
100%
NatWest Markets N.V.
(4)
Banking
Netherlands
100%
The Royal Bank of Scotland International Limited
(5)
Financial Institution
Jersey
100%
(1)
The company does not hold any of the preference shares in issue.
(2)
Coutts & Company is incorporated with unlimited liability.
(3)
Owned via NatWest Holdings Limited.
(4)
Owned via NatWest Markets Plc.
(5)
Owned via The Royal Bank of Scotland International (Holdings) Limited.
For full information on all related undertakings, refer to Note 12.
Parent company financial statements and notes
continued
NatWest Group
Annual Report and Accounts 2022
385
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
10 Analysis of changes in financing during the year
Share capital, share premium,
and paid-in equity
Subordinated liabilities
(1)
MRELs
(2)
2022
2021
2020
2022
2021
2020
2022
2021
2020
£m
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January
16,504
18,219
17,235
7,853
8,055
7,763
8,158
6,655
6,440
Ordinary shares issued
87
52
Issue of paid-in equity
933
2,209
Issue of subordinated liabilities
648
1,634
1,631
Redemption of subordinated liabilities
(3,990)
(3,598)
(3,207)
Interest on subordinated liabilities
(281)
(292)
(396)
Issue of MRELs
2,285
598
(3)
Maturity and redemption of MRELs
(1,455)
1,082
(2)
Interest on MRELs
(158)
(149)
(142)
Net cash inflow/(outflow) from financing
1,020
2,261
(3,623)
(2,256)
(1,972)
672
1,531
(147)
Effects of foreign exchange
574
44
(264)
413
(54)
(275)
Changes in fair value of subordinated
liabilities and MRELs
(354)
(309)
173
(491)
(131)
499
Paid in equity reclassified to subordinated liabilities
(2,037)
(1,277)
1,915
1,632
Preference shares reclassified to subordinated
liabilities
750
Loss on sale of subordinated liabilities and MRELs
351
114
324
Interest on subordinated liabilities and MRELs
287
290
399
198
157
138
Shares repurchased
(929)
(698)
At 31 December
15,575
16,504
18,219
5,838
7,853
8,055
8,950
8,158
6,655
(1)
Subordinated liabilities include intercompany subordinated liabilities.
(2)
MRELs balances are shown net of the effect of down streaming funding to subsidiary companies.
11 Directors’ and key management remuneration
Directors’ remuneration is disclosed in Note 30 to the consolidated accounts. The directors had no other reportable related party
transactions or balances with the company.
Parent company financial statements and notes
continued
NatWest Group
Annual Report and Accounts 2022
386
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
12 Related undertakings
Legal entities and activities at 31 December 2022
In accordance with the Companies Act 2006, the company’s related undertakings and the accounting treatment for each are listed
below. All undertakings are wholly-owned by the company or subsidiaries of the company and are consolidated by reason of
contractual control (Section 1162(2) CA 2006), unless otherwise indicated. NatWest Group interest refers to ordinary shares of
equal values and voting rights unless further analysis is provided in the notes. Activities are classified in accordance with Annex I to
the Capital Requirements Directive (CRD V) and the definitions in Article 4 of the UK Capital Requirements 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
treatment
Notes
280 Bishopsgate Finance Ltd
INV
FC
(1)
AD Aggregator Platform Ltd
OTH
FC
(58)
Caledonian Sleepers Rail Leasing Ltd
BF
FC
(1)
Care Homes 1 Ltd
BF
FC
(1)
Care Homes 2 Ltd
BF
FC
(1)
Care Homes 3 Ltd
BF
FC
(1)
Care Homes Holdings Ltd
BF
FC
(1)
Churchill Management Ltd
BF
FC
(1)
Coutts & Company
CI
FC
(16)
Coutts Finance Company
BF
FC
(16)
Desertlands Entertainment Ltd
BF
FC
(1)
Distant Planet Productions Ltd
BF
FC
(1)
East Grove Holding Ltd
INV
DE
(59)
Esme Loans Ltd
BF
FC
(1)
FreeAgent Central Ltd
SC
FC
(29)
FreeAgent Holdings Ltd
SC
FC
(29)
G L Trains Ltd
BF
FC
(19)
Gatehouse Way Developments Ltd
INV
DE
(1)
German Biogas Holdco Ltd
INV
DE
(58)
ITB1 Ltd
BF
FC
(3)
ITB2 Ltd
BF
FC
(3)
KUC Properties Ltd
BF
DE
(3)
Land Options (West) Ltd
INV
DE
(3)
Lombard & Ulster Ltd
BF
FC
(15)
Lombard Business Leasing Ltd
BF
FC
(1)
Lombard Corporate Finance (6) Ltd
BF
FC
(1)
Lombard Corporate Finance (7) Ltd
BF
FC
(1)
Lombard Corporate Finance (11) Ltd
BF
FC
(1)
Lombard Corporate Finance (December 1) Ltd
BF
FC
(1)
Lombard Corporate Finance (December 3) Ltd
BF
FC
(1)
Lombard Corporate Finance (June 2) Ltd
BF
FC
(1)
Lombard Discount Ltd
BF
FC
(1)
Lombard Finance Ltd
BF
FC
(1)
Lombard Industrial Leasing Ltd
BF
FC
(1)
Lombard Lease Finance Ltd
BF
FC
(1)
Lombard Leasing Company Ltd
BF
FC
(1)
Lombard Leasing Contracts Ltd
BF
FC
(1)
Lombard Lessors Ltd
BF
FC
(1)
Lombard Maritime Ltd
BF
FC
(1)
Lombard North Central Leasing Ltd
BF
FC
(1)
Lombard North Central PLC
BF
FC
(1)
Lombard Property Facilities Ltd
BF
FC
(1)
Lombard Technology Services Ltd
BF
FC
(1)
Mettle Ventures Ltd
OTH
FC
(1)
National Westminster Bank Plc
CI
FC
(1)
National Westminster Home Loans Ltd
BF
FC
(1)
NatWest Group Plc
BF
FC
(25)
NatWest Holdings Ltd
INV
FC
(1)
NatWest Markets Plc
CI
FC
(25)
NatWest Markets Secretarial Services Ltd
SC
FC
(1)
NatWest Markets Secured Funding LLP
BF
FC
(18)
NatWest Property Investments Ltd
INV
DE
(1)
NatWest Trustee and Depositary Services Ltd
INV
FC
(1)
NatWest Ventures Investments Ltd
BF
FC
(1)
Regulatory
Entity name
Activity
treatment
Notes
P of A Productions Ltd
BF
FC
(1)
Patalex Productions Ltd
BF
FC
(1)
Patalex V Productions Ltd
BF
FC
(1)
Pittville Leasing Ltd
BF
FC
(1)
Premier Audit Company Ltd
BF
FC
(1)
Price Productions Ltd
BF
FC
(1)
Priority Sites Ltd
INV
DE
(1)
Property Venture Partners Ltd
INV
FC
(3)
R.B. Capital Leasing Ltd
BF
FC
(1)
R.B. Equipment Leasing Ltd
BF
FC
(1)
R.B. Leasing (April) Ltd
BF
FC
(1)
R.B. Leasing (September) Ltd
BF
FC
(1)
R.B. Leasing Company Ltd
BF
FC
(3)
R.B. Quadrangle Leasing Ltd
BF
FC
(1)
R.B.S. Special Investments Ltd
BF
FC
(1)
RB Investments 3 Ltd
OTH
FC
(1)
RBOS (UK) Ltd
BF
FC
(1)
RBS AA Holdings (UK) Ltd
BF
FC
(1)
RBS Asset Management Holdings
BF
FC
(16)
RBS Collective Investment Funds Ltd
BF
FC
(10)
RBS HG (UK) Ltd
BF
FC
(1)
RBS Invoice Finance Ltd
BF
FC
(1)
RBS Management Services (UK) Ltd
SC
FC
(1)
RBS Mezzanine Ltd
BF
FC
(3)
RBS Property Developments Ltd
INV
FC
(25)
RBS Property Ventures Investments Ltd
BF
FC
(3)
RBS SME Investments Ltd
BF
FC
(1)
RBSG Collective Investments Holdings Ltd
BF
FC
(10)
RBSG International Holdings Ltd
BF
FC
(3)
RBSM Capital Ltd
BF
FC
(3)
RBSSAF (2) Ltd
BF
FC
(1)
RBSSAF (25) Ltd
BF
FC
(1)
RoboScot Equity Ltd
BF
FC
(3)
Royal Bank Investments Ltd
BF
FC
(3)
Royal Bank Leasing Ltd
BF
FC
(3)
Royal Bank of Scotland (Industrial Leasing) Ltd
BF
FC
(3)
Royal Bank Ventures Investments Ltd
BF
FC
(3)
Royal Scot Leasing Ltd
BF
FC
(3)
RoyScot Trust Plc
BF
FC
(1)
SIG 1 Holdings Ltd
BF
FC
(3)
SIG Number 2 Ltd
BF
FC
(3)
Silvermere Holdings Ltd
BF
FC
(3)
The One Account Ltd
BF
FC
(1)
The Royal Bank of Scotland Group
Independent Financial Services Ltd
BF
FC
(3)
The Royal Bank of Scotland plc
CI
FC
(25)
Ulster Bank Ltd
BF
FC
(15)
Ulster Bank Pension Trustees Ltd
TR
DE
(15)
Walton Lake Developments Ltd
INV
DE
(1)
West Register (Hotels Number 3) Ltd
INV
DE
(3)
West Register (Property Investments) Ltd
BF
DE
(3)
West Register (Realisations) Ltd
INV
DE
(3)
Winchcombe Finance Ltd
BF
FC
(1)
World Learning Ltd
BF
FC
(26)
Parent company financial statements and notes
continued
NatWest Group
Annual Report and Accounts 2022
387
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
12 Related undertakings continued
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
Airside Properties AB
BF
FC
(2)
Airside Properties ASP Denmark AS
BF
FC
(11)
Airside Properties Denmark AS
BF
FC
(11)
Alcover A.G.
BF
DE
(54)
Alternative Investment Fund B.V.
BF
FC
(12)
Arkivborgen KB
BF
FC
(2)
Artul Koy
BF
FC
(4)
BD Lagerhus AS
BF
FC
(5)
Bilfastighet i Akalla AB
BF
FC
(2)
Bilfastighet i Avesta AB
BF
FC
(2)
Bilfastighet i Bollnas AB
BF
FC
(2)
Bilfastighet i Hemlingby AB
BF
FC
(2)
Bilfastighet i Hudiksvall AB
BF
FC
(2)
Bilfastighet i Ludvika AB
BF
FC
(2)
Bilfastighet i Märsta AB
BF
FC
(17)
Bilfastighet i Mora AB
BF
FC
(2)
Bilfastighet i Uppsala KB
BF
FC
(17)
Bilfastighet Kista AB
BF
FC
(17)
Brödmagasinet KB
BF
FC
(2)
C.J. Fiduciaries Ltd
BF
FC
(14)
Candlelight Acquisition LLC
BF
FC
(6)
Coutts & Co (Cayman) Ltd
BF
FC
(61)
Coutts & Co Ltd
CI
FC
(53)
Coutts General Partner (Cayman) V Ltd
BF
FC
(48)
Eiendomsselskapet Apteno La AS
BF
FC
(5)
Espeland Naering AS
BF
FC
(5)
Eurohill 4 KB
BF
FC
(2)
Fab Ekenäs Formanshagen 4
BF
FC
(4)
Fastighets AB Flöjten I Norrköping
BF
FC
(2)
Fastighets AB Stockmakaren
BF
FC
(17)
Fastighets Aktiebolaget Sambiblioteket
BF
FC
(2)
Fastighetsbolaget Holma I Höör AB
BF
FC
(2)
Financial Asset Securities Corp.
BF
FC
(6)
First Active Ltd
BF
FC
(7)
Forskningshöjden KB
BF
FC
(2)
Förvaltningsbolaget Dalkyrkan KB
BF
FC
(2)
Förvaltningsbolaget Klöverbacken Skola KB
BF
FC
(2)
Fyrsäte Fastighets AB
BF
FC
(2)
Grinnhagen KB
BF
FC
(2)
Hatros 1 AS
BF
FC
(5)
Horrsta 4:38 KB
BF
FC
(2)
IR Fastighets AB
BF
FC
(2)
IR IndustriRenting AB
BF
FC
(2)
Kallebäck Institutfastigheter AB
BF
FC
(2)
Kastrup Commuter K/S
BF
FC
(11)
Kastrup Hangar 5 K/S
BF
FC
(11)
Kastrup V & L Building K/S
BF
FC
(11)
KB Eurohill
BF
FC
(2)
KB Lagermannen
BF
FC
(2)
KB Likriktaren
BF
FC
(2)
KEB Investors, L.P.
BF
FC
(42)
Koy Lohjan Ojamonharjuntie 61
BF
FC
(4)
Koy Vantaan Rasti IV
BF
FC
(4)
Koy Harkokuja 2
BF
FC
(21)
Koy Pennalan Johtotie 2
BF
FC
(4)
Koy Porkkanakatu 2
BF
FC
(4)
Koy Espoon Entresse II
BF
FC
(4)
Koy Helsingin Mechelininkatu 1
BF
FC
(4)
Koy Helsingin Osmontie 34
BF
FC
(4)
Regulatory
Entity name
Activity
treatment
Notes
Koy Helsingin Panuntie 6
BF
FC
(4)
Koy Helsingin Panuntie 11
BF
FC
(4)
Koy Iisalmen Kihlavirta
BF
FC
(4)
Koy Jämsän Keskushovi
BF
FC
(4)
Koy Jasperintie 6
BF
FC
(21)
Koy Kokkolan Kaarlenportti Fab
BF
FC
(4)
Koy Kouvolan Oikeus ja Poliisitalo
BF
FC
(4)
Koy Millennium
BF
FC
(4)
Koy Nummelan Portti
BF
FC
(4)
Koy Nuolialan päiväkoti
BF
FC
(4)
Koy Peltolantie 27
BF
FC
(21)
Koy Porkkanakatu 2
BF
FC
(21)
Koy Puotikuja 2 Vaasa
BF
FC
(4)
Koy Raision Kihlakulma
BF
FC
(4)
Koy Ravattulan Kauppakeskus
BF
FC
(4)
Koy Tapiolan Louhi
BF
FC
(4)
Koy Vapaalan Service-Center
BF
FC
(4)
Kvam Eiendom AS
BF
FC
(5)
Läkten 1 KB
BF
FC
(2)
Leiv Sand Eiendom AS
BF
FC
(5)
LerumsKrysset KB
BF
FC
(2)
Limstagården KB
BF
FC
(2)
Lombard Finance (CI) Ltd
BF
FC
(14)
Lothbury Insurance Company Ltd
BF
DE
(51)
Lundbyfilen 5 AB
BF
FC
(17)
Maja Finance S.R.L.
BF
FC
(40)
Narmovegen 455 AS
BF
FC
(5)
National Westminster International Holdings B.V.
BF
FC
(3)
NatWest Bank Europe GmbH
BF
FC
(30)
NatWest Innovation Services Inc.
OTH
FC
(6)
NatWest Markets Group Holdings Corporation
BF
FC
(6)
NatWest Markets N.V.
CI
FC
(12)
NatWest Markets Securities Inc.
INV
FC
(6)
NatWest Markets Securities Japan Ltd
INV
FC
(62)
NatWest Services (Switzerland) Ltd
SC
FC
(45)
NatWest Services Inc.
SC
FC
(6)
Nordisk Renting AB
BF
FC
(2)
Nordisk Renting AS
BF
FC
(43)
Nordisk Renting Facilities Management AB
BF
FC
(17)
Nordisk Renting OY
BF
FC
(4)
Nordisk Specialinvest AB
BF
FC
(2)
Nordiska Strategifastigheter Holding AB
BF
FC
(2)
Nybergflata 5 AS
BF
FC
(5)
OFH Eiendom AS
BF
FC
(60)
Optimus KB
BF
FC
(2)
R.B. Leasing BDA One Ltd
BF
FC
(56)
Random Properties Acquisition Corp. III
INV
FC
(6)
RBS (Gibraltar) Ltd
BF
FC
(47)
RBS AA Holdings (Netherlands) B.V.
BF
FC
(12)
RBS Acceptance Inc.
BF
FC
(6)
RBS Americas Property Corp.
SC
FC
(6)
RBS Assessoria Ltd
SC
FC
(35)
RBS Asset Management (Dublin) Ltd
BF
FC
(50)
RBS Commercial Funding Inc.
BF
FC
(6)
RBS Deutschland Holdings GmbH
BF
FC
(30)
RBS Employment (Guernsey) Ltd
SC
FC
(52)
RBS Financial Products Inc.
BF
FC
(6)
RBS Group (Australia) Pty Ltd
BF
FC
(27)
RBS Holdings III (Australia) Pty Ltd
BF
FC
(27)
RBS Holdings N.V.
BF
FC
(12)
Parent company financial statements and notes
continued
NatWest Group
Annual Report and Accounts 2022
388
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
12 Related undertakings continued
Regulatory
Entity name
Activity
treatment
Notes
RBS Holdings USA Inc.
BF
FC
(6)
RBS Hollandsche N.V.
BF
FC
(12)
RBS International Depositary Services S.A.
CI
FC
(36)
RBS Investments (Ireland) Ltd
BF
FC
(7)
RBS Netherlands Holdings B.V.
BF
FC
(12)
RBS Nominees (Hong Kong) Ltd
BF
FC
(13)
RBS Nominees (Ireland) Ltd
BF
FC
(7)
RBS Nominees (Netherlands) B.V.
BF
FC
(12)
RBS Polish Financial Advisory Services
Sp. Z o.o.
BF
FC
(44)
RBS Prime Services (India) Private Ltd
OTH
FC
(32)
RBS Services India Private Ltd
SC
FC
(38)
Rigedalen 44 Eiendom AS
BF
FC
(5)
Ringdalveien 20 AS
BF
FC
(5)
Sandmoen Naeringsbygg AS
BF
FC
(5)
SFK Kommunfastigheter AB
BF
FC
(2)
Sjöklockan KB
BF
FC
(2)
Skinnarängen KB
BF
FC
(2)
Sletta Eiendom II AS
BF
FC
(5)
Regulatory
Entity name
Activity
treatment
Notes
Snipetjernveien 1 AS
BF
FC
(5)
Solbänken KB
BF
FC
(2)
Solnorvika AS
BF
FC
(5)
Strand European Holdings AB
BF
FC
(17)
Svenskt Fastighetskapital AB
BF
FC
(2)
Svenskt Energikapital AB
BF
FC
(2)
Svenskt Fastighetskapital Holding AB
BF
FC
(2)
The RBS Group Ireland Retirement Savings
Trustee Ltd
TR
DE
(7)
The Royal Bank of Scotland International
(Holdings) Ltd
BF
FC
(14)
The Royal Bank of Scotland International Ltd
CI
FC
(14)
Tygverkstaden 1 KB
BF
FC
(2)
Ulster Bank (Ireland) Holdings Unlimited Company
INV
FC
(7)
Ulster Bank Dublin Trust Company
Unlimited Company
TR
FC
(7)
Ulster Bank Holdings (ROI) Ltd
BF
FC
(7)
Ulster Bank Ireland Designated Activity Company
CI
FC
(7)
Ulster Bank Pension Trustees (RI) Ltd
TR
DE
(7)
The following table details related undertakings which are 100% owned by NatWest Group ownership but are not
consolidated for accounting purposes
Regulatory
Entity name
Activity
treatment
Notes
Bioenergie Dargun Immobilien GmbH
OTH
DE
(46)
Bioenergie Jessen Immobilien GmbH
OTH
DE
(46)
Bioenergie Wiesenburg GmbH & Co. KG
INV
DE
(46)
Bioenergie Wiesenburg Verwaltungs GmbH
OTH
DE
(46)
Bioenergie Zittau GmbH
OTH
DE
(46)
Bioenergie Zittau Immobilien GmbH
OTH
DE
(46)
Capulet Homes Florida LLC
OTH
DE
(6)
Crook Hill Properties Ltd
OTH
DE
(65)
DBV Deutsche Bioenergie Verbinder GmbH
OTH
DE
(46)
European Investments (Crook Hill) Ltd
OTH
DE
(66)
Montague Homes Florida LLC
OTH
DE
(6)
RBS International Employees' Pension Trustees Ltd
BF
DE
(14)
Reaps Moss Ltd
OTH
DE
(65)
Reppinichen Dritte Biogas Betriebs GmbH
OTH
DE
(46)
Reppinichen Erste Biogas Betriebs GmbH
OTH
DE
(46)
Reppinichen Zweite Biogas Betriebs GmbH
OTH
DE
(46)
Romeo Homes Florida LLC
OTH
DE
(6)
Romeo Homes Georgia LLC
OTH
DE
(6)
Romeo Homes Indiana LLC
OTH
DE
(6)
Romeo Homes Kansas LLC
OTH
DE
(6)
Regulatory
Entity name
Activity
treatment
Notes
Romeo Homes Nevada LLC
OTH
DE
(6)
Romeo Homes North Carolina LLC
OTH
DE
(6)
Romeo Homes Oklahoma LLC
OTH
DE
(6)
Romeo Homes Tennessee LLC
OTH
DE
(6)
Romeo Homes Texas LLC
OTH
DE
(6)
Ventus Investments Ltd
OTH
DE
(66)
West Granite Homes Inc.
INV
DE
(6)
WGH Development LLC
OTH
DE
(6)
WGH Florida LLC
OTH
DE
(6)
WGH Georgia LLC
OTH
DE
(6)
WGH Indiana LLC
OTH
DE
(6)
WGH Kansas LLC
OTH
DE
(6)
WGH Nevada LLC
OTH
DE
(6)
WGH North Carolina LLC
OTH
DE
(6)
WGH Oklahoma LLC
OTH
DE
(6)
WGH Texas LLC
OTH
DE
(6)
Wiesenburg Dritte Biogas Betriebs GmbH
OTH
DE
(46)
Wiesenburg Erste Biogas Betriebs GmbH
OTH
DE
(46)
Wiesenburg Zweite Biogas Betriebs GmbH
OTH
DE
(46)
Wiesenburger Marktfrucht GmbH
OTH
DE
(46)
The following table details active related undertakings incorporated in the UK where NatWest Group ownership is less than
100%
Accounting
Regulatory
Group
Entity name
Activity
treatment
treatment
%
Notes
BGF Group Plc
BF
AHC
PC
25
(19)
Falcon Wharf Ltd
OTH
EAJV
PC
50
(28)
GWNW City Developments Ltd
BF
EAJV
DE
50
(28)
Jaguar Cars Finance Ltd
BF
FC
FC
50
(1)
JCB Finance Ltd
BF
FC
FC
75
(23)
London Rail Leasing Ltd
BF
EAJV
PC
50
(39)
Mortgage Brain Holdings Ltd
OTH
EAA
DE
15
(63)
Accounting
Regulatory
Group
Entity name
Activity
treatment
treatment
%
Notes
Natwest Covered Bonds (LM)
Ltd
BF
IA
PC
20
(18)
Natwest Covered Bonds LLP
BF
FC
FC
73
(19)
Natwest Markets Secured
Funding (LM) Ltd
BF
FC
PC
20
(18)
Pollinate Networks Ltd
OTH
AHC
DE
25
(69)
RBS Sempra Commodities LLP
BF
FC
FC
51
(3)
Vizolution Ltd
OTH
AHC
PC
5
(49)
Parent company financial statements and notes
continued
NatWest Group
Annual Report and Accounts 2022
389
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
Coutts Private Equity Limited
Partnership II
BF
IA
PC
45
(64)
Dunmore Securities No.1 DAC
BF
FC
DE
0
(20)
Eris Finance S.R.L.
BF
IA
PC
45
(40)
Herge Holding B.V.
BF
IA
PC
63
(55)
Lunar Funding VIII Ltd
BF
FC
DE
0
(8)
Lunar Luxembourg SA
BF
FC
DE
0
(57)
Lunar Luxembourg Series
2019- 04
BF
FC
DE
0
(57)
Lunar Luxembourg Series
2019- 05
BF
FC
DE
0
(57)
Lunar Luxembourg Series
2019- 06
BF
FC
DE
0
(57)
Lunar Luxembourg Series
2020- 01
BF
FC
DE
0
(57)
Lunar Luxembourg Series
2020- 02
BF
FC
DE
0
(57)
Lunar Luxembourg Series
2022- 01
BF
FC
DE
0
(57)
Accounting
Regulatory
Group
Entity name
Activity
treatment
treatment
%
Notes
Natwest Secured Funding DAC
BF
FC
FC
0
(37)
Nightingale CRE 2018-1 Ltd
BF
FC
DE
0
(9)
Nightingale LF 2021-1 Ltd
BF
FC
DE
0
(9)
Nightingale Project Finance
2019 1 Ltd
BF
FC
DE
0
(9)
Nightingale Securities 2017-1 Ltd
BF
FC
DE
0
(9)
Nightingale UK Corp
2020 2 Ltd
BF
FC
DE
0
(9)
Pharos Estates Ltd
OTH
AHC
DE
49.49
(34)
PTSB
BF
IA
DE
17
(72)
Sempra Energy
Trading LLC
BF
FC
FC
51
(6)
Solar Funding II Ltd
BF
FC
DE
0
(68)
Thames Asset Global
Securitization No.1 Inc.
BF
FC
FC
0
(31)
The Drive4Growth Company Ltd
OTH
IA
DE
20
(41)
Wiöniowy Management sp. Z.o.o.
SC
AHC
DE
25
(44)
The following table details related undertakings that are not active (actively being dissolved).
Accounting
Regulatory
Group
Entity name
treatment
treatment
%
Notes
AA Merchant Services B.V.
FC
FC
100
(12)
Ardmore Securities No.2 DAC
BF
FC
0
(71)
Belfast Bankers' Clearing
Company Ltd
AHC
OTH
25
(70)
Celtic Residential Irish Mortgage
Securitisation No 10 Plc
FC
DE
0
(22)
Celtic Residential Irish Mortgage
Securitisation No 11 Plc
FC
DE
0
(22)
Accounting
Regulatory
Group
Entity name
treatment
treatment
%
Notes
Lombard Ireland Group
Holdings Unlimited
FC
FC
100
(71)
Lombard Ireland Ltd
FC
FC
100
(71)
Marigold Nominees Ltd
FC
FC
100
(1)
Natwest Nominees Ltd
FC
FC
100
(1)
Priority Sites Investments Ltd
FC
DE
100
(1)
RBS Asia Holdings B.V.
FC
FC
100
(12)
UB SIG (ROI) Ltd
FC
FC
100
(22)
Parent company financial statements and notes
continued
NatWest Group
Annual Report and Accounts 2022
390
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
ANW TDS (Nominee 1) Ltd
FC
DE
100
(1)
ANW TDS (Nominee 2) Ltd
FC
DE
100
(1)
Atlas Nominees Ltd
FC
FC
100
(13)
British Overseas Bank Nominees Ltd
FC
FC
100
(1)
Buchanan Holdings Ltd
FC
FC
100
(1)
Coutts Scotland Nominees Ltd
FC
FC
100
(10)
Custom House Docks Basement
Management No. 2 Ltd
AHC
DE
25
(67)
Dunfly Trustee Ltd
FC
FC
100
(1)
FIT Nominee 2 Ltd
FC
FC
100
(1)
FIT Nominee Ltd
FC
FC
100
(1)
Freehold Managers (Nominees) Ltd
FC
FC
100
(1)
HPUT A Ltd
FC
DE
100
(1)
HPUT B Ltd
FC
DE
100
(1)
JCB Finance Pension Ltd
FC
DE
88
(15)
Mulcaster Street Nominees Ltd
FC
FC
100
(14)
N.C. Head Office Nominees Ltd
FC
FC
100
(3)
National Westminster Bank Nominees
(Jersey) Ltd
FC
FC
100
(33)
NatWest FIS Nominees Ltd
FC
FC
100
(1)
NatWest Group Retirement Savings
Trustee Ltd
FC
FC
100
(1)
NatWest Group Secretarial
Services Ltd
FC
FC
100
(3)
Accounting
Regulatory
Group
Entity name
treatment
treatment
%
Notes
Natwest Invoice Finance Ltd
FC
FC
100
(1)
NatWest Pension Trustee Ltd
NC
DE
100
(1)
NatWest PEP Nominees Ltd
FC
FC
100
(1)
Nextlinks Ltd
FC
FC
100
(1)
Nordisk Renting A/S
FC
FC
100
(5)
Nordisk Renting HB
FC
FC
100
(2)
NWB Nominee 1 Ltd
FC
FC
100
(1)
Project & Export Finance (Nominees) Ltd
FC
FC
100
(1)
R.B. Leasing (March) Ltd
FC
FC
100
(1)
RBOS Nominees Ltd
FC
FC
100
(1)
RBS Investment Executive Ltd
NC
DE
100
(3)
RBSG Collective Investments
Nominees Ltd
FC
FC
100
(10)
RoosterMoney UK Ltd
FC
FC
100
(26)
Sixty Seven Nominees Ltd
FC
FC
100
(1)
Strand Nominees Ltd
FC
FC
100
(16)
Syndicate Nominees Ltd
FC
FC
100
(1)
TDS Nominee Company Ltd
FC
FC
100
(3)
Tilba Ltd
FC
FC
100
(24)
The Royal Bank of Scotland (1727) Ltd
FC
FC
100
(3)
The Royal Bank of Scotland Group Ltd
FC
FC
100
(1)
Voyager Leasing Ltd
FC
FC
100
(1)
W G T C Nominees Ltd
FC
FC
100
(1)
The following table details overseas branches of NatWest Group
Subsidiary
Geographic location
National Westminster Bank Plc
Germany
NatWest Markets Plc
Germany, Hong Kong,
India, Japan, Singapore
Turkey, United Arab Emirates
Subsidiary
Geographic location
NatWest Markets N.V.
France, Germany, Italy, Republic of
Ireland, Sweden, United Kingdom
The Royal Bank of
Scotland International Ltd
Gibraltar, Guernsey, Isle of Man,
Luxembourg, United Kingdom
Parent company financial statements and notes
continued
NatWest Group
Annual Report and Accounts 2022
391
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
12 Related undertakings continued
Key:
BF
Banking and financial institution
CI
Credit institution
INV
Investment (shares or property) holding company
SC
Service company
TR
Trustee
OTH
Other
DE
Deconsolidated
FC
Full consolidation
PC
Pro-rata consolidation
AHC
Associate held at cost
EAJV
Equity accounting – Joint venture
IA
Investment accounting
NC
Not consolidated
Notes
Registered addresses
Country of incorporation
(1)
250 Bishopsgate, London, EC2M 4AA
UK
(2)
Care of Nordisk Renting AB, Jakobsbergsgatan 13, 8th Floor, Box 14044, Stockholm, SE-111 44
Sweden
(3)
RBS Gogarburn, 175 Glasgow Road, Edinburgh, EH12 1HQ
UK
(4)
c/o Epicenter, Mikonkatu 9, 6th Floor, Helsinki, 00100
Finland
(5)
c/o Advokatfirmaet Wiersholm AS, Postboks 1400, 0115 Oslo
Norway
(6)
251, Little Falls Drive, Wilmington, DE, 19808
USA
(7)
Ulster Bank Head Office, Block B Central Park, Leopardstown, Dublin 18, D18 N153
RoI
(8)
Grand Pavilion Commercial Centre, 802 West Bay Road, P.O. Box 31119
Cayman Islands
(9)
44 Esplanade, St Helier, JE4 9WG
Jersey
(10)
6-8 George Street, Edinburgh, EH2 2PF
UK
(11)
C/O Visma Services Danmark A/S, Lyskaer 3C-3D, 2730 Herlev
Denmark
(12)
Claude Debussylaan 94, Amsterdam, 1082 MD
Netherlands
(13)
Level 54, Hopewell Centre, 183 Queen's Road East
Hong Kong
(14)
Royal Bank House, 71 Bath Street, St Helier, JE4 8PJ
Jersey
(15)
11-16 Donegall Square East, Belfast, Co Antrim, BT1 5UB
UK
(16)
440, Strand, London, WC2R OQS
UK
(17)
C/O Nordisk Renting AB, Box 14044, SE-104 40 Stockholm
Sweden
(18)
1 Bartholomew Lane London EC2N 2AX
UK
(19)
1 Princes Street, London, EC2R 8BP
UK
(20)
3rd Floor, Fleming Court, Fleming's Place, Dublin 4, D04 N4X9
RoI
(21)
c/o Nordisk Renting Oy, Mikonkatu 9, 00100, Helsinki
Finland
(22)
One Spencer Dock, Dublin, D01 X9R7
RoI
(23)
The Mill, High Street, Rocester, Staffordshire, ST14 5JW
UK
(24)
2 Athol Street, Douglas, IM1 1JA
Isle Of Man
(25)
36 St Andrew Square, Edinburgh, EH2 2YB
UK
(26)
64 New Cavendish Street, London, W1G 8TB
UK
(27)
Ashurst Australia, South Tower,
80 Collins Street,
Melbourne
Australia
(28)
Gate House, Turnpike Road, High Wycombe, Buckinghamshire, HP12 3NR
UK
(29)
One Edinburgh Quay, 133 Fountainbridge, Edinburgh, EH3 9QG
UK
(30)
Roßmarkt 10, Frankfurt am Main, 60311
Germany
(31)
114 West 47th Street, New York, 10036
USA
(32)
12/14 Veer Nariman Road,
Brady House 4th floor, Fort,
Mumbai, 400001
India
(33)
16 Library Place, St. Helier
Jersey
(34)
24 Demostheni Severi, 1st Floor, Nicosia, 1080
Cyprus
(35)
254, 13 Floor, Rua Boa Vista, Sao Paulo, 01014-907
Brazil
(36)
40, Avenue J.F Kennedy, Kirchberg, L1855
Luxembourg
(37)
5 Harbourmaster Place, Dublin 1, D01 E7E8
RoI
(38)
6th Floor, Building 2, Tower A, GIL IT/ITES SEZ, Candor TechSpace, Sector 21, Gurugram, Haryana, 122016
India
(39)
99 Queen Victoria Street, London, EC4V 4EH
UK
(40)
Via Vittorio Alfieri 1, Conegliano TV, IT-TN 31015
Italy
(41)
c/o Denis Crowley & Co Chartered Accountants, Unit 6 Riverside Grove, Riverstick, P43 W221
RoI
(42)
Clarendon House, Two Church Street, Suite 104, Reid Street, Hamilton, HM 11
Bermuda
Parent company financial statements and notes
continued
NatWest Group
Annual Report and Accounts 2022
392
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
12 Related undertakings continued
Notes
Registered addresses
Country of incorporation
(43)
H. Heyerdahlsgate 1, Postboks 2020 Vika, Oslo, 0125
Norway
(44)
ul. Ilzecka 26, building E, 02-135, Warsaw
Poland
(45)
Lerchenstrasse 18, Zurich, CH 8022
Switzerland
(46)
Liszt Straße 10, Regensburg, D-93053
Germany
(47)
Madison Building, Midtown, Queensway
Gibraltar
(48)
Maples Corporate Services Limited, P.O. Box 309, 121 South Church Street, George Town,
Grand Cayman, KY1-1104
Cayman Islands
(49)
Office Block A, Bay Studios Business Park, Fabian Way, Swansea, SA1 8QB
UK
(50)
One Dockland Central, Guild Street, IFSC, Dublin 1
RoI
(51)
PO Box 230, Heritage Hall, Le Marchant Street, St Peter Port, GY1 4JH
Guernsey
(52)
Regency Court, Glategny Esplanade, St Peter Port, GY1 3AP
Guernsey
(53)
Schuetzengassse 4, CH-8001 Zurich
Switzerland
(54)
Tirolerweg 8, Zug, CH- 6300
Switzerland
(55)
Verlengde Poolseweg 16, Breda, 4818CL
Netherlands
(56)
Victoria Place, 5th Floor, 31 Victoria Street, Hamilton, HM 10
Bermuda
(57)
46A, Avenue J.F Kennedy,L 1855
Luxembourg
(58)
Greencoat Capital, 5 The Peak, Wilton Road, London, Greater London, SW1V 1AN, England
UK
(59)
8 Sackville Street, London, W1S 3DG, England
UK
(60)
Rakkestadsveien 15, 1814 Askim
Norway
(61)
Windward 3, Ocorian Trust (Cayman) Limited, Regatta Office Park, PO Box 1350, Grand Cayman, KY1-1108
Cayman Islands
(62)
5/F Manulife Place, 348 Kwun Tong Road, Kowloon
Hong Kong
(63)
6 The Countryard, Buntsford Gate, Buntsford Drive , Bromsgrove Worcestershire. B60 3DJ
UK
(64)
PO Box 309 GEORGETOWN KY1-1104
Cayman Islands
(65)
2nd floor, Palm Grove House, Road Town, Tortola
British Virgin Islands
(66)
18 Riversway Business Village, Navigation Way, Ashton-on Ribble, Preston, PR2 2YP
UK
(67)
c/o Apleona Real Estate Limited, Landscape House, Landscape Road, Churchtown, DUBLIN 14
RoI
(68)
IFC5, St.Helier, Channel Island JE1 1ST
Jersey
(69)
2nd Floor 120 Old Broad Street, London, EC2N 1AR
UK
(70)
Scottish Provident Building, 7 Donegall Square West, Belfast, BT1 6JH
UK
(71)
13-18 City Quay, Dublin 2
RoI
(72)
56-59 St. Stephen's Green, Dublin 2
RoI
Non-IFRS financial measures
NatWest Group
Annual Report and Accounts 2022
393
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
NatWest Group prepares its financial statements in accordance with generally accepted accounting principles (GAAP). This
document contains a number of adjusted or alternative performance measures, also known as non-GAAP or non-IFRS
performance measures. These measures are adjusted for notable and other defined items which management believes are not
representative of the underlying performance of the business and which distort period-on-period comparison. The non-IFRS
measures provide users of the financial statements with a consistent basis for comparing business performance between financial
periods and information on elements of performance that are one-off in nature. The non-IFRS measures also include the
calculation of metrics that are used throughout the banking industry. These non-IFRS measures are not measures within the scope
of IFRS and are not a substitute for IFRS measures.
1.
Go-forward group
Further
progress with respect to the phased withdrawal from the Republic of Ireland has resulted in Ulster Bank RoI continuing
operations no longer meeting the IFRS definition of an operating segment.
Therefore Ulster Bank RoI is no longer shown
separately and performance on a Go-forward group basis (NatWest Group excluding Ulster Bank RoI) will not be reported going
forward. Selected Go-forward group metrics are still included to align with 2022 targets and guidance previously provided and the
financial measures in 2022 executive director performance assessment.
Go-forward group income excluding notable items
Go-forward group income excluding notable items is calculated as total income excluding Ulster Bank RoI total income and
excluding notable items of the Go-forward group.
The exclusion of notable items aims to remove the impact of one-offs which may distort period-on-period comparisons.
2022
2021
2020
£m
£m
£m
Continuing operations
Total income
13,156
10,429
10,403
Less Ulster Bank RoI total income
53
(145)
(117)
Go-forward group income
13,209
10,284
10,286
Less notable items
(146)
(210)
384
Go-forward group total income excluding notable items
13,063
10,074
10,670
Go-forward group other operating expenses
Other operating expenses is calculated as total operating expenses less litigation and conduct costs. Other operating expenses of
the Go-forward group excludes Ulster Bank RoI.
Our cost target for 2022 is based on this measure and we track progress against it.
2022
2021
2020
£m
£m
£m
Continuing operations
Total operating expenses
7,687
7,758
7,858
Less litigation and conduct costs
(385)
(466)
(385)
Other operating expenses
7,302
7,292
7,473
Less Ulster Bank RoI other operating expenses
(654)
(443)
(434)
Go-forward group other operating expenses
6,648
6,849
7,039
Non-IFRS financial measures
continued
NatWest Group
Annual Report and Accounts 2022
394
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
2. Operating expenses - management view
The management analysis of operating expenses shows litigation and conduct costs on a separate line. These amounts are
included within staff costs and other administrative expenses in the statutory analysis. Other operating expenses excludes litigation
and conduct costs, which are more volatile and may distort comparisons with prior periods.
Year ended
31 December 2022
Litigation
Other
Statutory
and conduct
operating
operating
Operating expenses
costs
expenses
expenses
Continuing operations
Staff expenses
45
3,671
3,716
Premises and equipment
1,112
1,112
Depreciation and amortisation
833
833
Other administrative expenses
340
1,686
2,026
Total
385
7,302
7,687
31 December 2021
Litigation
Other
Statutory
and conduct
operating
operating
Operating expenses
costs
expenses
expenses
Continuing operations
Staff expenses
3,676
3,676
Premises and equipment
1,133
1,133
Depreciation and amortisation
923
923
Other administrative expenses
466
1,560
2,026
Total
466
7,292
7,758
31 December 2020
Litigation
Other
Statutory
and conduct
operating
operating
Operating expenses
costs
expenses
expenses
Continuing operations
Staff expenses
3,878
3,878
Premises and equipment
1,222
1,222
Depreciation and amortisation
913
913
Other administrative expenses
113
1,732
1,845
Total
113
7,745
7,858
Non-IFRS financial measures
continued
NatWest Group
Annual Report and Accounts 2022
395
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
3. Cost:income ratio
NatWest Group uses cost:income ratio (excl. litigation and conduct) in the Outlook guidance. It is calculated as other operating
expenses (total operating expenses less litigation and conduct costs) divided by total income. Litigation and conduct costs are
excluded as they are one-off in nature, difficult to forecast for Outlook purposes and distort period on period comparisons.
The calculation of the cost:income ratio (excl. litigation and conduct) is shown below, along with a comparison to cost:income ratio
calculated using total operating expenses.
Central
Retail
Private
Commercial
items
NatWest
Banking
Banking
& Institutional
& other
Group
Year ended 31 December 2022
£m
£m
£m
£m
£m
Continuing operations
Total operating expenses
2,593
622
3,744
728
7,687
Less litigation and conduct costs
(109)
(12)
(181)
(83)
(385)
Other operating expenses
2,484
610
3,563
645
7,302
Total income
5,646
1,056
6,413
41
13,156
Cost:income ratio
45.9%
58.9%
58.4%
nm
58.4%
Cost:income ratio (excl. litigation and conduct)
44.0%
57.8%
55.6%
nm
55.5%
Year ended 31 December 2021
Continuing operations
Total operating expenses
2,513
520
3,757
968
7,758
Less litigation and conduct costs
(76)
3
(111)
(282)
(466)
Other operating expenses
2,437
523
3,646
686
7,292
Total income
4,445
816
4,838
330
10,429
Cost:income ratio
56.5%
63.7%
77.7%
nm
74.4%
Cost:income ratio (excl. litigation and conduct)
54.8%
64.1%
75.4%
nm
69.9%
Year ended 31 December 2020
Continuing operations
Total operating expenses
2,540
455
4,031
832
7,858
Less litigation and conduct costs
(19)
26
7
(127)
(113)
Other operating expenses
2,521
481
4,038
705
7,745
Total income
4,181
763
5,578
(119)
10,403
Cost:income ratio
60.8%
59.6%
72.3%
nm
75.5%
Cost:income ratio (excl. litigation and conduct)
60.3%
63.0%
72.4%
nm
74.4%
Non-IFRS financial measures
continued
NatWest Group
Annual Report and Accounts 2022
396
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
4. NatWest Group return on tangible equity
Return on tangible equity comprises profit or loss for the period attributable to ordinary shareholders divided by average tangible
equity. Average tangible equity is average total equity excluding average non-controlling interests, average other owners equity
and average intangible assets.
Go-forward group return on tangible equity is calculated as profit for the period less Ulster Bank RoI divided by Go-forward group
total tangible equity. Go-forward RWAe applying factor is the Go-forward group average RWAe as a percentage of total Natwest
Group average RWAe.
This measure shows the return NatWest Group generates on tangible equity deployed. It is used to determine relative performance
of banks and used widely across the sector, although different banks may calculate the rate differently. A reconciliation is shown
below including a comparison to the nearest GAAP measure: return on equity. This comprises profit attributable to ordinary
shareholders divided by average total equity.
Year ended or as at
31 December
31 December
2022
2021
NatWest Group return on tangible equity
£m
£m
Profit attributable to ordinary shareholders
3,340
2,950
Average total equity
38,210
42,727
Adjustment
for other owners equity and intangibles
(11,153)
(11,395)
Adjusted total tangible equity
27,057
31,332
Return on equity
8.7%
6.9%
Return on tangible equity
12.3%
9.4%
Go-forward group return on tangible equity
Profit attributable to ordinary shareholders
3,340
2,950
Less Ulster Bank RoI loss from continuing operations
723
414
Less loss/profit from discontinued operations
262
(464)
Go-forward group profit/(loss) attributable to ordinary shareholders
4,325
2,900
Average total equity
38,210
42,727
Adjustment
for other owners equity and intangibles
(11,153)
(11,395)
Adjusted total tangible equity
27,057
31,332
Go-forward group RWAe applying factor
95%
93%
Go-forward group total tangible equity
25,704
29,139
Return on tangible equity
16.9%
10.0%
Non-IFRS financial measures
continued
NatWest Group
Annual Report and Accounts 2022
397
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
5. Segmental return on equity
Segmental return on equity comprises segmental operating profit or loss, adjusted for preference share dividends, paid-in equity
and tax, divided by average notional equity. Average RWAe is defined as average segmental RWAs incorporating the effect of
capital deductions. This is multiplied by an allocated equity factor for each segment to calculate the average notional tangible
equity.
This measure shows the return generated by operating segments on equity deployed.
Retail
Private
Commercial &
Year ended 31 December 2022
Banking
Banking
Institutional
Operating profit (£m)
2,824
436
2,547
Paid-in equity cost allocation (£m)
(80)
(15)
(187)
Adjustment for tax (£m)
(768)
(118)
(590)
Adjusted attributable profit (£m)
1,976
303
1,770
Average RWAe (£bn)
53.1
11.3
104.0
Equity factor
13.0%
11.0%
14.0%
Average notional equity (£bn)
6.9
1.2
14.6
Return on equity
28.6%
24.5%
12.2%
Year ended 31 December 2021
Operating profit (£m)
1,968
350
2,241
Preference share and paid-in equity cost allocation (£m)
(80)
(20)
(236)
Adjustment for tax (£m)
(529)
(92)
(501)
Adjusted attributable profit (£m)
1,359
238
1,504
Average RWAe (£bn)
36.0
11.2
106.0
Equity factor
14.5%
12.5%
13.0%
Average notional equity (£bn)
5.2
1.4
13.8
Return on equity
26.1%
17.0%
10.9%
Year ended 31 December 2020
Operating profit/(loss) (£m)
849
208
(527)
Preference share and paid-in equity cost allocation (£m)
(88)
(22)
(241)
Adjustment for tax (£m)
(213)
(52)
192
Adjusted attributable profit/(loss) (£m)
548
134
(576)
Average RWAe (£bn)
37.2
10.4
120.7
Equity factor
14.5%
12.5%
13.0%
Average notional equity (£bn)
5.4
1.3
15.7
Return on equity
10.2%
10.3%
(3.7%)
Non-IFRS financial measures
continued
NatWest Group
Annual Report and Accounts 2022
398
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
6. Bank net interest margin
Bank net interest margin is net interest income as a percentage of bank average interest-earning assets. Bank average interest
earning assets are average interest earning assets of the banking business of NatWest Group excluding liquid asset buffer.
Liquid asset buffer consists of assets held by NatWest Group, such as cash and balances at central banks and debt securities in
issue, that can be used to ensure repayment of financial obligations as they fall due. The exclusion of liquid asset buffer presents
net interest margin on a basis more comparable with UK peers and excludes the impact of regulatory driven factors. . A
reconciliation is shown below including a comparison to the nearest GAAP measure: net interest margin. This is net interest income
as a percentage of average interest earning assets.
Year ended
31 December
31 December
31 December
2022
2021
2020
£m
£m
£m
Continuing operations
NatWest Group net interest income
9,842
7,535
7,389
Average interest earning assets (IEA)
544,162
519,304
476,991
Less liquid asset buffer average IEA
(198,927)
(192,036)
(160,281)
Bank average IEA
345,235
327,268
316,710
Net interest margin
1.81%
1.45%
1.55%
Bank net interest margin
2.85%
2.30%
2.33%
Retail Banking
Net interest income
5,224
4,074
3,868
Retail Banking average IEA
210,404
196,043
181,383
Less liquid asset buffer average IEA
(19,581)
(16,913)
(14,443)
Adjusted Retail Banking average IEA
190,823
179,130
166,940
Retail Banking net interest margin
2.74%
2.27%
2.32%
Private Banking
Net interest income
777
480
489
Private Banking average IEA
29,308
27,224
23,806
Less liquid asset buffer average IEA
(10,221)
(8,949)
(7,483)
Adjusted Private Banking average IEA
19,087
18,275
16,323
Private Banking net interest margin
4.07%
2.63%
3.00%
Commercial & Institutional
Net interest income
4,171
2,974
3,054
Commercial & Institutional average IEA
245,316
238,642
232,771
Less liquid asset buffer average IEA
(119,244)
(117,686)
(107,827)
Adjusted Commercial & Institutional average IEA
126,072
120,956
124,944
Commercial & Institutional net interest margin
3.31%
2.46%
2.44%
Non-IFRS financial measures
continued
NatWest Group
Annual Report and Accounts 2022
399
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
7. Tangible net asset value (TNAV) per ordinary share
TNAV per ordinary share is calculated as tangible equity divided by the number of ordinary shares in issue.
This is a measure used by external analysts in valuing the bank and allows for comparison with other per ordinary share metrics
including the share price.
Year ended
31 December
31 December
2022
2021
Ordinary shareholders’ interests (£m)
32,598
37,412
Less intangible assets (£m)
(7,116)
(6,723)
Tangible equity (£m)
25,482
30,689
Ordinary shares in issue (millions)
(1)
9,659
11,272
TNAV per ordinary share (pence)
264p
272p
(1)
The number of ordinary shares in issue excludes own shares held.
Non-IFRS financial measures
continued
NatWest Group
Annual Report and Accounts 2022
400
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Performance metrics not defined under IFRS
Metrics based on GAAP measures, included as not defined under IFRS and reported for compliance with the European Securities
and Markets Authority (ESMA) adjusted performance measure rules.
1. Loan:deposit ratio
Adjusted loan:deposit ratio is calculated as net customer loans held at amortised cost excluding reverse repos divided by total
customer deposits excluding repos. Prior periods have been re-presented. This is a common metric used to assess liquidity. The
removal of repos and reverse repos reduces volatility and presents the ratio on a basis that is comparable to UK peers.
A reconciliation is shown below including a comparison to the nearest GAAP measure: loan:deposit ratio. This is calculated as net
loans to customers held at amortised cost divided by customer deposits.
As at
31 December
31 December
31 December
2022
2021
2020
£m
£m
£m
Loans to customers - amortised cost
366,340
358,990
360,544
Less reverse repos
(19,749)
(25,962)
(25,011)
346,591
333,028
335,533
Customer deposits
450,318
479,810
431,739
Less repos
(9,828)
(14,541)
(5,167)
440,490
465,269
426,572
Loan:deposit ratio (%)
81%
75%
84%
Loan:deposit ratio (excl. repos and reverse repos) (%)
79%
72%
79%
2. Loan impairment rate
Loan impairment rate is the loan impairment charge divided by gross customer loans. This measure is used to assess the credit
quality of the loan book.
3. Funded assets
Funded assets is calculated as total assets less derivative assets. This measure allows review of balance sheet trends exclusive of
the volatility associated with derivative fair values.
4. AUMAs
AUMA comprises both assets under management (AUMs) and assets under administration (AUAs) serviced through the Private
Banking business segments. AUMs comprise assets where the investment management is undertaken by Private Banking on behalf
of Private Banking, Retail Banking and Commercial & Institutional customers. AUAs comprise third party assets held on an
execution-only basis in custody by Private Banking, Retail Banking and Commercial & Institutional for their customers, for which
the execution services are supported by Private Banking. Private Banking receives a fee for providing investment management and
execution services to Retail Banking and Commercial & Institutional business segments.
This measure is tracked and reported as the amount of funds that we manage or administer directly impacts the level of
investment income that we receive.
5. Net new money
Net new money refers to client cash inflows and outflows relating to investment products (this can include transfers from saving
accounts). Net new money excludes the impact of EEA resident client outflows following the UK’s exit from the EU and Russian
client outflows since Q1 2022.
Net new money is reported and tracked to monitor the business performance of new business inflows and management of existing
client withdrawals across Retail Banking, Private Banking and Commercial & Institutional Banking.
6. Wholesale funding
Wholesale funding comprises deposits by banks (excluding repos), debt securities in issue and subordinated liabilities. Funding risk
is the risk of not maintaining a diversified, stable and cost-effective funding base. The disclosure of wholesale funding highlights the
extent of our diversification and how we mitigate funding risk.
7. Third party rates
Third party customer asset rate is calculated as 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 for customer funding rate calculation.
These metrics help investors better understand our net interest margin and interest rate sensitivity.
This report has been prepared for NatWest Group to comply with the Capital Requirements (Country-by-Country Reporting)
Regulations 2013 which implement Article 89 of the Capital Requirements Directive IV.
The Capital Requirements
(Country-by-Country Reporting)
Regulations (Audited)
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Financial review
This report shows the income, profit/(loss) before tax, tax paid/(received), average and spot 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 allocated to the country in which it is resident for tax purposes. The data is consolidated for all the
subsidiaries and branches allocated to each country.
Income and profit/(loss) before tax
Income and profit/(loss) totals are reported in Note 4 within the Geographical segments table.
Tax paid/(received)
Tax paid/(received) disclosed under CRD IV relates to corporation tax.
Corporation tax paid represents net cash taxes paid to/(received) from the tax authorities in each jurisdiction.
Corporation tax paid is reported on a cash basis as opposed to an accounting basis and therefore does not necessarily have a
direct correlation to the reported profits or losses arising in the year. For example, in certain jurisdictions taxable profits may be
reduced as a result of the offset of tax losses brought forward from prior years; or tax payments may be calculated with reference
to prior year profits.
Full time equivalent employees (FTEs)
FTEs are allocated to the country in which they are primarily based for the performance of their employment duties. The figures
disclosed represent the average number of FTEs, including temporary staff, in each country during the period. The FTEs, including
temporary staff, at 31 December 2022, have been added for completeness.
Public subsidies received
No public subsidies were received during the period
.
The Capital Requirements (Country-by-Country Reporting) Regulations (Audited)
continued
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NatWest Group Country-by-Country tax breakdown 2022
Headcount
Income (1,6)
Profit/(loss) before
tax (1,6)
Tax paid/ (received)
Country
£m
£m
£m
Average FTE including
temporary staff
FTE including temporary staff as at
the year end 31 December 2022
UK
12,237
5,401
1,172
40,003
40,418
Guernsey
166
130
4
90
93
Isle of Man
77
25
(1)
357
369
Jersey
246
160
7
717
754
UK region
12,726
5,716
1,182
41,167
41,634
Finland
15
13
3
4
5
France
38
2
61
66
Germany
15
(10)
1
105
118
Gibraltar
41
23
65
70
Greece
(1)
1
1
Republic of Ireland
(417)
(1,024)
2
1,919
1,792
Italy
10
1
(3)
16
16
Luxembourg
79
53
2
62
69
Netherlands
142
51
117
114
Norway
4
4
1
Poland
(2)
1
1,445
1,536
Spain
1
2
Sweden
22
11
3
34
34
Switzerland
(2)
(9)
(7)
3
277
278
Turkey
2
1
2
2
Europe region
(57)
(882)
12
4,110
4,101
USA
94
(46)
1
268
260
US region
94
(46)
1
268
260
Hong Kong
1
1
6
6
India
(2)
18
51
28
14,480
15,703
Japan
17
3
39
39
Singapore
62
27
108
114
Asia Pacific region
98
82
28
14,633
15,862
UK region
12,726
5,716
1,182
41,167
41,634
US region
94
(46)
1
268
260
Europe region
(57)
(882)
12
4,110
4,101
Rest of World region
98
82
28
14,633
15,862
Global total
12,861
4,870
1,223
60,178
61,857
For the notes to this table refer to the following page.
The Capital Requirements (Country-by-Country Reporting) Regulations (Audited)
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NatWest Group Country-by-Country tax breakdown 2021
Headcount
(Loss)/profit
Tax paid/
Average FTE
FTE including temporary
Income (1)
before tax (1)
(received)
including
staff as at the year end
£m
£m
£m
temporary staff
31 December 2021
Country
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
Saudi Arabia
(3)
18
Middle East region
18
UK region
9,920
4,143
796
41,561
40,788
Europe region
691
80
28
3,945
3,980
US region
100
48
2
291
270
Rest of World region
71
40
30
13,325
13,697
Global total
10,782
4,311
856
59,122
58,735
(1)
A full list of NatWest Group subsidiaries' names, nature of activities and geographical locations is available at Note 12 of the parent company accounts.
(2)
Income excludes internal service fee income which has been calculated on a cost plus mark-up basis.
(3)
Tax paid nil (2021 - £18 million) in Saudi Arabia is due to capital gains tax arising on the merger of Alawwal bank with SABB during 2019.
(4)
A list of the principal subsidiaries in each jurisdiction and the nature of their activities is available at Note 9 of the parent company accounts.
(5)
The amounts shown above are presented to the nearest million and as a result any amounts less than £0.5 million have been rounded to zero.
(6)
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
Republic of Ireland totals, Decrease in income: £295 million; Loss before tax: £262 million; Tax paid: nil; Subsidies received: nil; Headcount: 396 (2021- Income: £352 million; Profit
before tax: £467 million; Tax paid: nil; Subsidies received: nil; Headcount: 715).
Risk factors
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Principal Risks and
Uncertainties
Set out below are certain risk factors
that could adversely affect NatWest
Group’s future results, its financial
condition and/or prospects and cause
them to be materially different from
what is forecast or expected, and
directly or indirectly impact the value of
its securities. These risk factors are
broadly categorised and should be read
in conjunction with other sections 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.
Economic and political risk
NatWest Group, its customers and its
counterparties face continued economic
and political risks and uncertainties in
the UK and global markets, including as
a result of high inflation and rising
interest rates, supply chain disruption
and the Russian invasion of Ukraine.
NatWest Group is affected by global
economic and market conditions.
Uncertain and volatile economic
conditions can create a challenging
operating environment for financial
services companies such as NatWest
Group. The outlook for the global
economy has many uncertainties
including: falling economic activity, high
inflation, rising interest rates, elevated
energy prices and higher cost-of-living,
supply chain disruption, changes to
monetary and fiscal policy, and the
impact of armed conflict (in particular
the Russian invasion of Ukraine).
These conditions, including the current
cost-of-living crisis, could be worsened
by a number of factors including:
instability in the global financial system,
market volatility and change, fluctuations
in the value of the pound sterling, new or
extended economic sanctions, the
ongoing effects of the COVID-19
pandemic, economic volatility in
emerging markets, volatility in
commodity prices or concerns regarding
sovereign debt or sovereign credit
ratings. Economic conditions may also
be affected by the changing
demographics in the markets that
NatWest Group serves, increasing social
and other inequalities, or rapid changes
to the economic environment due to the
adoption of technology, automation and
artificial intelligence, or due to climate
change, environmental degradation,
biodiversity loss and/or other
sustainability risks.
NatWest Group is also exposed to risks
arising out of geopolitical events or
political developments, such as exchange
controls and other measures taken by
sovereign governments that may hinder
economic or financial activity levels.
Unfavourable political, military or
diplomatic events, increasing geopolitical
tensions leading to armed conflict,
protectionist policies or trade barriers,
secession movements or the exit of other
member states from the EU, changes to
monetary and fiscal policy, new and
widespread public health crises
(including any epidemics or pandemics),
state and privately sponsored cyber and
terrorist acts or threats, and the
responses to each of the above
economic, political or other scenarios by
various governments and markets, could
negatively affect the business and
performance of NatWest Group,
including as a result of the indirect
impact on regional or global trade and/or
NatWest Group’s customers and
counterparties.
The UK experienced significant political
uncertainty in 2022 that may persist into
the foreseeable future.
This could lead
to a loss of confidence in the UK, that
could in turn, negatively impact
companies operating in the UK. NatWest
Group also faces political uncertainty in
Scotland as a result of a possible second
Scottish independence referendum.
Independence may adversely affect
NatWest Group both in relation to
entities incorporated in Scotland and in
other jurisdictions. Any changes to
Scotland’s relationship with the UK or
the EU may adversely affect the
environment in which NatWest Group
and its subsidiaries operate and may
require further changes to NatWest
Group, independently or in conjunction
with other mandatory or strategic
structural and organisational changes,
any of which could adversely affect
NatWest Group.
The COVID-19 pandemic prompted
many changes that may prove to be
permanent shifts in customer behaviour
and economic activity, such as changes
in spending patterns and significantly
more people working in a more flexible
manner. These changes may affect asset
prices, the economic environment, and
NatWest Group’s customers’ and
counterparties’ financial performance
and needs.
In response to the COVID-19
pandemic, central banks, governments,
regulators, and legislatures in the UK and
elsewhere offered unprecedented levels
of support and various schemes to assist
businesses and individuals, many of
which have since been curtailed or
withdrawn.
However, risks remain as to
whether these loans will be repaid.
The value of NatWest Group’s own and
other securities may be materially
affected by market risk, including as a
result of market fluctuations. Market
volatility, illiquid market conditions and
disruptions in the credit markets may
make it extremely difficult to value
certain of NatWest Group’s own and
other securities, particularly during
periods of market displacement. This
could cause a decline in the value of
NatWest Group’s own and other
securities, which may have an adverse
effect on NatWest Group’s results of
operations in future periods, or
inaccurate carrying values for certain
financial instruments.
In addition, financial markets are
susceptible to severe events evidenced
by rapid depreciation in asset values,
which may be accompanied by a
reduction in asset liquidity. Under these
conditions, hedging and other risk
management strategies may not be as
effective at mitigating losses 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 participants
simultaneously and on a large scale,
increasing NatWest Group’s counterparty
risk. NatWest Group’s risk management
and monitoring processes seek to
quantify and mitigate NatWest Group’s
exposure to more extreme market
moves. However, market events have
historically been difficult to predict, and
NatWest Group, its customers and its
counterparties could realise significant
losses if extreme market events were to
occur.
Any of the above may adversely affect
NatWest Group.
Changes in interest rates have
significantly affected, and will continue to
affect, NatWest Group’s business and
results.
NatWest Group’s performance is affected
by changes in interest rates. Benchmark
overnight interest rates, such as the UK
base rate, increased in 2022 and are
expected to continue to rise in the short-
term accompanied by quantitative
tightening. However, forward rates at 31
December 2022 suggested interest rates
may fall again in the medium-term.
Stable interest rates support predictable
income flow and less volatility in asset
and liability valuations, although
persistently low and negative interest
rates, such as those experienced during
the COVID-19 pandemic, are generally
expected to be less favourable for banks.
Risk factors
continued
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For NatWest Group, persistently low
interest rates may reduce the yield on its
lower interest income.
Volatility in interest rates may also result
in unexpected outcomes both for interest
income and asset and liability valuations
which may adversely affect NatWest
Group. For example, unexpected
movements in spreads between key
benchmark rates such as sovereign and
swap rates in turn affect liquidity
portfolio valuations. Finally, sharp
unexpected rises in rates may also have
negative impacts on some asset and
derivative valuations, for example. Any
of the above may have an adverse effect
on NatWest Group’s future results,
financial condition and/or prospects.
Movements in interest rates also
influence and reflect the macro-
economic situation more broadly,
affecting factors such as business and
consumer confidence, property prices,
default rates on loans and other
indicators that may indirectly affect
NatWest Group and may adversely affect
its future results, financial condition
and/or prospects.
Fluctuations in currency exchange rates
may adversely affect NatWest Group’s
results and financial condition.
Decisions of central banks (including the
Bank of England, the European Central
Bank and the US Federal Reserve) and
political or market events, which are
outside NatWest Group’s control, may
lead to sharp and sudden fluctuations in
currency exchange rates.
Although NatWest Group is principally a
UK focused banking group, it is subject
to structural foreign exchange risk from
capital deployed in NatWest Group’s
foreign subsidiaries, branches and other
strategic equity shareholdings. NatWest
Group also relies on issuing securities in
non-sterling currencies that assist in
meeting NatWest Group’s MREL.
NatWest Group conducts banking
activities in non-sterling currencies (for
example, loans, deposits and dealing
activity) which affects its revenue and
also uses service providers based outside
of the United Kingdom for certain
services and as a result certain operating
results are subject to fluctuations in
currency exchange rates.
NatWest Group maintains policies and
procedures designed to manage the
impact of exposures to fluctuations in
currency exchange rates.
Nevertheless, changes in currency
exchange rates, particularly in the
sterling-US dollar and euro-sterling
rates, may adversely affect various
factors including, the value of assets,
liabilities (including the total amount of
MREL-eligible instruments), foreign
exchange dealing activity, income and
expenses, RWAs and hence the reported
earnings and financial condition of
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 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 (‘Brexit’) and
the 2020 EU-UK Trade and Cooperation
Agreement (‘TCA’) ended the transition
period on 31 December 2020. The TCA
was 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
(‘MoU’), which remains unsigned. Certain
aspects of the services provided by
NatWest Group are therefore subject to
obtaining local licences or are subject to
individual equivalence decisions
(temporary or otherwise) by relevant
regulators. The EU’s equivalence regime
does not cover most lending and deposit
taking, and determinations in respect of
non-EU countries have not, to date,
covered the provision of most financial
investment services. In addition,
equivalence determinations do not
guarantee permanent access rights and
can be withdrawn with short notice. In
late 2021 the European Commission
proposed legislation that would require
non-EU firms to establish a branch or
subsidiary in the EU before providing
‘banking services’ in the EU. If these
proposals become law all ‘banking
services’ will be licensable activities in
each EU member state and member
states will not be permitted to offer
bilateral permissions to financial
institutions outside the EU allowing them
to provide ‘banking services’ in the EU.
Uncertainty remains as to whether
‘banking services’ will also include
investment products.
NatWest Group continues to evaluate 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 or commercially reasonable to
do so. 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
conduct EEA business through an EEA
licensed subsidiary or branch. Certain
permissions are required in order to
maintain the ability to clear euro
payments. Other permissions, including
the ability to have two intermediate EU
parent undertakings, may need to be
obtained, and structural changes may
need to be made, to allow NatWest
Group to continue to serve EEA
customers from both the ring-fenced and
non-ring-fenced banking entities. Any
failure to obtain such permissions or
make such structural changes in a timely
manner, or at all, could adversely affect
NatWest Group and the EEA customers it
serves. Furthermore, transferring
business 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
customers or higher than anticipated
costs. The changes to NatWest Group’s
operating model have been costly and
failure to receive the requested
regulatory permissions and/or further
changes to its business operations,
product offering and customer
engagement could result in further costs
and/or regulatory sanction.
The long-term effects of Brexit and the
uncertainty regarding NatWest Group’s
EU operating model may adversely affect
NatWest Group and its customers and
counterparties who are themselves
dependent on trading with the EU or
personnel from the EU. The long-term
effects of Brexit may also be
exacerbated by wider UK and global
macroeconomic trends and events.
Uncertainties remain as to the extent to
which EU/EEA laws will diverge from UK
law.
Risk factors
continued
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For example, bank regulation in the UK
may diverge from European bank
regulation if the Financial Services and
Markets Bill (‘FSM’) is enacted into law.
The UK government has also proposed
legislation to introduce automatic
‘sunset’ clauses for retained EU law by
the end of 2023 (the Retained EU Law
(Revocation and Reform) Bill 2022),
which if enacted could potentially cause
market disruption and require additional
resources to manage the legal and
regulatory consequences. NatWest
Group may not be able to respond to
these changes effectively, in a timely
manner, or at all. The actions taken by
regulators in response to any new or
revised bank regulation and other rules
affecting financial services, may
adversely affect NatWest Group,
including its business, non-UK
operations, group structure, compliance
costs, intragroup arrangements and
capital requirements.
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 Treasury
may affect the price of NatWest Group
securities.
In its March 2021 Budget, the UK
Government announced its intention to
carry out a programme of sales of
NatWest Group plc ordinary shares with
the objective of selling all of its remaining
shares in NatWest Group plc by 2026.
NatWest Group plc has: (i) carried out
directed buybacks of NatWest Group plc
ordinary shares from UK Government
Investments Limited (‘UKGI’) in March
2021 and in March 2022, (ii) carried out
sales of NatWest Group plc shares by
UKGI by accelerated bookbuild in May
2021 and (iii) made purchases under
NatWest Group plc’s directed and on-
market buyback programmes
announced in July 2021 and in March
2022. As at 17 January 2023, the UK
Government held 44.98% of the ordinary
share capital with voting rights of
NatWest Group plc. NatWest Group may
participate in similar directed or on-
market buybacks in the near- and
medium-term future. The precise timing
and extent of further UKGI’s sell-downs
is uncertain, which could result in a
prolonged period of price volatility for
NatWest Group plc’s ordinary shares and
other securities.
Any offers or sales of a substantial
number of ordinary shares in NatWest
Group plc by UKGI, market expectations
about these sales and any associated
directed, on or off market buyback
activity by NatWest Group, could affect
the prevailing market price for the
outstanding ordinary shares of NatWest
Group plc which may have an adverse
effect on NatWest Group.
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 NatWest Group plc’s
largest single shareholder, HM Treasury
and UKGI (as manager of HM Treasury’s
shareholding) could exercise a significant
degree of influence over NatWest Group
including: 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. HM Treasury or UKGI’s
approach depends on government
policy, which could change.
The manner in which HM Treasury or
UKGI exercises HM Treasury’s rights as
NatWest Group’s 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 change in
government policy, which may in turn
adversely affect NatWest Group.
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.
NatWest Group continues to implement
its purpose-led strategy, which is
designed to champion potential and to
help individuals, families and businesses
to thrive. NatWest Group’s strategy is
intended to reflect the rapidly shifting
environment and backdrop of
unprecedented disruption in society
driven by technology and changing
customer expectations, as accelerated
by the COVID-19 pandemic. Further,
shifting trends include digitalisation,
decarbonisation, automation, e-
commerce and hybrid working, each of
which has resulted in significant market
volatility and change. There is also
increased investor, employee,
stakeholder, regulatory and customer
scrutiny regarding how businesses
address these changes and related
climate change, biodiversity 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.
In recent years, as part of its purpose-led
strategy, NatWest Group has refocused
its NatWest Markets business, and has
also created the Commercial &
Institutional business segments. The
Commercial & Institutional business
segment combined the pre-existing
Commercial, NatWest Markets and RBS
International businesses to form a single
business segment, which focuses on
serving Commercial & Institutional
customers. The Commercial &
Institutional business segment is intended
to allow closer operational and strategic
alignment to support growth, with
increased levels of services being
provided between NatWest Group
entities, with the potential increased risk
of breach of the UK ring-fencing regime
requiring effective conflicts of interest
policies.
Many factors may adversely impact the
successful implementation of NatWest
Group’s purpose-led strategy, including:
macroeconomic challenges including
rising inflation and interest rates and
falling economic activity which may
adversely affect economic growth
and which could in turn impact
certain strategic initiatives and new
venture opportunities for NatWest
Group;
an internal culture shift across
NatWest Group as to how NatWest
Group conducts its business to strive
towards NatWest Group’s One Bank
strategy;
maintaining effective governance,
procedures, systems and controls
giving effect to the purpose-led
strategy whilst also managing
emerging climate, ESG and other
sustainability-related risks and
opportunities;
achieving a number of financial,
capital and operational targets and
expectations, both for the short term
and throughout the implementation
period;
cost-controlling measures, which
may result in material one-off
provisions to lower the NatWest
Group cost base, may divert
investment from other areas, and
may vary considerably from year to
year;
lower customer confidence and
confidence from the wider market,
which may result in a decrease of
customer activity and related income
levels;
changes in the economic, political
and regulatory environment in which
NatWest Group, its customers and its
counterparties operate, regulatory
uncertainty and changes, strong
market competition and industry
disruption and economic volatility;
and
Risk factors
continued
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Additional information
Financial review
any economic downturn which may
adversely affect the strategy as
certain initiatives depend on
achieving growth in new ventures
and opportunities for NatWest Group.
In pursuing its purpose-led strategy,
NatWest Group may not be able to
successfully: (i) implement some or all
aspects of its strategy; (ii) meet 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 initiative. The scale
and scope of its strategy and the
intended changes continue to present
material business, operational and
regulatory (including compliance with the
UK ring-fencing regime), conflicts, 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 governance
and controls frameworks and robust IT
systems; there is a risk that NatWest
Group may not be successful 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 progress in a
manner other than currently expected.
This could lead to additional
management actions by NatWest Group.
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 affect NatWest Group’s ability
to deliver its strategy and meet its
targets and guidance, each of which
could adversely affect NatWest Group’s
future results, financial condition and/or
prospects.
Future acquisitions or divestments by
NatWest Group may not be successful,
and consolidation or fragmentation of
the financial services industry may
adversely affect NatWest Group.
The financial services industry is
experiencing continued competitive
pressure with technological
advancement disrupting traditional
business models. In order to compete
effectively,
NatWest Group may decide, as part of its
purpose-led strategy, to undertake
divestments, restructurings or
reorganisations.
Conversely, it may decide to grow its
business through acquisitions, joint
ventures, investments and/or strategic
partnerships as well as other
transactions and initiatives 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 presence in
existing markets.
There are risks that NatWest Group may
not fully realise the expected benefits
and value from these transactions and
initiatives in the time, or to the degree,
anticipated, or at all. In particular,
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, regarding
synergies and expected commercial
demand; (ii) fail to successfully integrate
any acquired businesses (including in
respect of technologies, existing
strategies, products and human capital)
or to successfully divest or restructure a
business; (iii) fail to retain key employees,
customers and suppliers of any acquired
or restructured business; (iv) be required
or wish to terminate pre-existing
contractual relationships, which could
prove costly and/or be executed at
unfavourable terms and conditions; (v)
fail to discover certain contingent or
undisclosed liabilities in businesses that it
acquires, or its due diligence to discover
any such liabilities may be inadequate;
and (vi) not obtain necessary regulatory
and other approvals or onerous
conditions may be attached to such
approvals. Accordingly, NatWest Group
may not be successful in growing its
business through divestments,
restructurings, reorganisations or
acquisitions, and initiatives and any
particular transaction may not succeed,
may be limited in scope or scale
(including due to NatWest Group’s
current ownership structure) and may
not conclude on the terms contemplated,
or at all. Any of the above may adversely
affect NatWest Group’s future results,
financial condition and/or prospects.
Continued competitive pressure in the
financial services industry, including from
technology companies, may have a
negative impact on NatWest Group’s
business. If NatWest Group Commercial
& Institutional customers merge or are
acquired by other entities that are not
NatWest Group customers,
this may also lead to losses for NatWest
Group. Existing larger banks or financial
institutions (and those that emerge from
mergers and consolidations) may have
more bargaining power in negotiations
than NatWest Group. Each of these
developments may adversely affect
NatWest Group.
NatWest Group’s phased withdrawal
from the Republic of Ireland present
various risks.
NatWest Group’s phased withdrawal
from ROI continues to present significant
commercial, operational, reputational,
legal and execution risks. In particular,
the phased withdrawal from ROI requires
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)
potential stranded capital or an inability
to return capital from Ulster Bank Ireland
DAC to its parent; (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 resource required to mitigate
manual and limited customer switching
and handling processes of Ulster Bank
Ireland DAC, potential counterparties
and other 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, for example, retail and
commercial deposit outflows and
reduced revenues and liquidity; (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 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 reputation, future
results, financial condition and/or
prospects or its ability to execute a
phased withdrawal from ROI.
Additional information
Risk factors
continued
NatWest Group
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The transfer of NatWest Group’s Western
European corporate portfolio involves
certain risks.
To improve efficiencies and best serve
customers following Brexit, NatWest
Group expects that certain of its assets,
liabilities, transactions and activities
(including NatWest Group’s Western
European corporate portfolio principally
consisting of term funding and revolving
credit facilities), may be: (i) transferred
from the ring-fenced subgroup of
NatWest Group to NWM Group and/or (ii)
transferred to the ring-fenced subgroup
of NatWest Group from NWM Group,
subject to regulatory and customer
requirements. The timing, success and
quantum of any of these transfers
remain uncertain as is the impact of
these transactions on its results of
operations. As a result, NatWest Group’s
future results, financial condition and/or
prospects may be adversely affected.
Financial resilience risk
NatWest Group may not meet the targets
it communicates or be in a position to
continue to make discretionary capital
distributions (including dividends to
shareholders).
As part of NatWest Group’s strategy, it
has set a number of financial, capital and
operational targets including in respect
of its: CET1 ratio target, MREL targets,
return on tangible equity (‘ROTE’),
funding plans and requirements,
employee engagement, diversity and
inclusion as well as ESG (including
climate and sustainable funding and
financing targets) and customer
satisfaction targets and discretionary
capital distributions (including dividends
to shareholders). See also, ‘
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.
NatWest Group’s ability to meet its
targets, including its CET1 ratio target,
and make discretionary capital
distributions and to successfully fulfil its
strategy is subject to various internal and
external factors and risks. These include
but are not limited to: UK and global
macroeconomic, political, market and
regulatory uncertainties, operational
risks and risks relating to NatWest
Group’s business model and strategy
(including risks associated with climate,
ESG and other sustainability-related
issues) and litigation, governmental
actions, investigations and regulatory
matters.
See also,
NatWest Group, its customers
and its counterparties face continued
economic and political risks and
uncertainties in the UK and global
markets, including as a result of high
inflation and rising interest rates, supply
chain disruption and the Russian invasion
of Ukraine.
NatWest Group operates in markets that
are highly competitive, with increasing
competitive pressures and technology
disruption.
The markets within which NatWest
Group operates are highly competitive.
NatWest Group expects such competition
to continue and intensify in response to
various changes. These include: evolving
customer behaviour, technological
changes (including digital currencies and
other instruments, stablecoins and the
growth of digital banking, such as from
fintech entrants), competitor behaviour,
new entrants to the market (including
non-traditional financial services
providers such as retail or technology
conglomerates, who may have
competitive advantages in scale,
technology and customer engagement),
competitive foreign-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 services and products, and the
introduction of disruptive technology
may impede NatWest Group’s ability to
grow or retain its share and impact its
revenues and profitability, particularly in
its key UK retail and commercial banking
segments. Moreover, innovations such as
biometrics, artificial intelligence,
automation, the cloud, blockchain,
cryptocurrencies and quantum
computing may rapidly facilitate industry
transformation.
These trends have been 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 administered Alternative
Remedies Package (‘ARP’) benefits grant
recipients and eligible competitors.
The ARP may be more costly than
anticipated and may adversely affect
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 are,
and will become, more technology
intensive, including through digitalisation
and the use of artificial intelligence. For
example, NatWest Group has invested in
a number of fintech ventures, including
Mettle, FreeAgent, Tyl, Rapid Cash,
Rooster Money and Vodeno. NatWest
Group’s ability to develop or acquire
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 business 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 use of
online and mobile technology for banking
as well as selective acquisitions, which
carry associated risks) will be successful
or that it will allow NatWest Group to
continue to maintain or 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 benefits
from disruptive technologies in the
context of rapid technological innovation,
changing customer behaviour and
growing regulatory demands, resulting in
increased competition from traditional
banking businesses as well as new
providers of financial services, including
technology companies with strong brand
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
more advanced 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, such
investments may be insufficient or
ineffective, especially given NatWest
Group’s focus on cost efficiencies.
Risk factors
continued
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This may limit additional investment in
areas such as innovation and could
affect NatWest Group’s offering of
innovative products or technologies for
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, failing which its ability
to offer innovative products may be
compromised.
If NatWest Group is unable to offer
competitive, attractive and innovative
products that are also profitable and
timely, it will lose share, incur losses on
some or all of its initiatives and lose
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 automation
and artificial intelligence. Such initiatives
may result in operational, reputational
and conduct risks if the technology used
is defective, inadequate or is not fully
integrated 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
NatWest Group’s purpose-led strategy
(including in relation to acquisitions,
reorganisations and/or partnerships),
delivery on its climate ambition, cost-
controlling measures, as well as
employee remuneration constraints, may
also have an impact on its ability to
compete effectively and intensified
competition from incumbents,
challengers and new entrants could
affect NatWest Group’s ability to
maintain satisfactory returns. 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
capital and other resources, including
the ability to offer a broader range of
products and services and geographic
diversity, or the emergence of new
competitors. Any of the above may
adversely affect NatWest Group’s future
results, financial condition and/or
prospects.
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 businesses.
NatWest Group’s lending strategy and
associated processes/systems may fail to
identify, anticipate or quickly react to
weaknesses or risks in a particular sector,
market or borrower, or NatWest Group’s
credit risk appetite relative to
competitors, or fail to adequately value
physical 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 the recent UK and global
macroeconomic and political
uncertainties and a further deterioration
in prevailing economic and market
conditions (including a resurgence of the
COVID-19 pandemic or other new health
crises) and by the legal and regulatory
landscape in the UK and countries where
NatWest Group is exposed to credit risk.
Any further deterioration in these
conditions or changes to legal or
regulatory landscapes could worsen
borrower and counterparty credit quality
or impact the enforcement of contractual
rights over security, increasing credit
risk.
An increase in drawings upon 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,
increasing interest rates or higher
inflation, particularly if prolonged.
NatWest Group may be affected by
volatility in property prices (including as
a result of the general UK political or
economic climate) given that NatWest
Group’s mortgage loan and wholesale
property loan portfolios as at 31
December 2022, amounted to £235.5
billion, representing 62% of NatWest
Group’s total customer loan exposure. If
property prices were to weaken this
could lead to higher impairment charges,
particularly if default rates also increase.
In addition, NatWest Group’s credit 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 amount
after accounting for any IFRS 9
provisions already made.
This is most likely to occur during
periods of illiquidity or depressed asset
valuations.
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). Concerns about, or a
default by, a financial institution could
lead to significant liquidity problems and
losses 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 or borrower may lead to
market-wide liquidity problems and
losses for NatWest Group. This systemic
risk may also adversely affect financial
intermediaries, such as clearing
agencies, clearing houses, banks,
securities firms and exchanges with
which NatWest Group interacts 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 scenarios
(MES) together with the determination of
specific overlay adjustments to inform its
IFRS 9 ECL (Expected Credit Loss). 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. The
ECL provision is sensitive to the model
inputs and economic assumptions
underlying the estimate. Going forward,
NatWest Group anticipates observable
credit deterioration of a proportion of
assets resulting in a systematic uplift in
defaults, which is mitigated by those
economic assumption scenarios being
reflected in the Stage 2 ECL across
portfolios, along with a combination of
post model overlays in both wholesale
and retail portfolios reflecting the
uncertainty of credit outcomes. See also,
Risk and capital management - Credit
Risk
’. A credit deterioration would also
lead to RWA increases.
Risk factors
continued
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Furthermore, the assumptions and
judgments used in the MES and ECL
assessment at 31 December 2022 may
not prove to be adequate resulting in
incremental ECL provisions for NatWest
Group.
Due to NatWest Group’s exposure to the
financial industry, it also has exposure to
shadow banking entities (i.e., entities
which carry out activities of a similar
nature to banks but not regulated like
banks). NatWest Group is required to
identify and monitor its exposure to
shadow banking entities, implement and
maintain an internal framework for the
identification, management, control and
mitigation of the risks associated with
exposure to shadow banking entities,
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 effective reporting
and governance in respect of shadow
banking exposure, this may adversely
affect NatWest Group’s future results,
financial condition and/or prospects.
In line with certain mandated COVID-19
pandemic support schemes, NatWest
Group assisted affected customers with
a number of initiatives including NatWest
Group’s participation in BBLS, CBILS and
CLBILS products. NatWest Group has
sought to manage the risks of fraud and
money laundering against the need for
the fast and efficient 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, CBILS or CLBILS or the enforcing
or pursuing repayment of BBLS,CBILS
and CLBILS (or a failure to exercise
forbearance), which may have an
adverse effect on NatWest Group’s
reputation and results of operations. The
implementation of the initiatives and
efforts mentioned above may result in
litigation, regulatory and government
actions and proceedings. These actions
may result in judgments, settlements,
penalties or fines.
If NatWest Group experiences losses and
a reduction in future profitability, this is
likely to affect the recoverable value of
fixed assets, including goodwill and
deferred taxes, which may lead to write-
downs.
NatWest Group may not meet the
prudential regulatory requirements for
regulatory capital and MREL, or manage
its capital effectively, which could trigger
the execution of certain management
actions or recovery options
.
NatWest Group is required by regulators
in the UK, the EU and other jurisdictions
in which it undertakes regulated
activities to maintain adequate financial
resources.
Adequate capital provides NatWest
Group with financial flexibility specifically
in its core UK operations in the face of
turbulence and uncertainty in the UK and
the global economy. It also permits
NatWest Group plc to make discretionary
capital distributions (including dividends
to shareholders).
As at 31 December 2022, NatWest Group
plc’s CET1 ratio was 14.2% and is
targeting a CET1 ratio of 13-14% by the
end of 2023. NatWest Group plc’s target
CET1 ratio is based on a combination of
its expected regulatory requirements and
internal modelling, including stress
scenarios and management’s and/or the
Prudential Regulation Authority’s (‘PRA’)
views on appropriate buffers above
minimum 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 regulatory uplifts
and lending growth and other capital
management initiatives which focus on
improving capital efficiency and ensuring
NatWest Group meets its medium-to-
long term targets. NatWest Group
intends to make capital distributions to
its equity investors of amounts surplus to
its publicly stated CET1 target, subject to
macroeconomic conditions, via a
combination of dividends and buybacks.
In making distribution decisions,
consideration is given to previously
guided ordinary dividend pay-out ratios,
an intention to minimise the
government’s stake in the Group, and
maximising shareholder value.
A number of factors may impact
NatWest Group plc’s ability to maintain
its current CET1 ratio target and achieve
its capital strategy. These include:
a depletion of its capital resources
through increased costs or liabilities
or reduced profits;
an increase in the quantum of
RWAs/Leverage Exposure in excess
of that expected, including due to
regulatory changes, or a failure in
internal controls or procedures to
accurately measure and report
RWAs/ Leverage Exposure;
changes in prudential regulatory
requirements including NatWest
Group plc’s Total Capital
Requirement/ Leverage Requirement
set by the PRA, including Pillar 2
requirements, as applicable, and
regulatory buffers as well as any
applicable scalars; and
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 result
of the Bank of England’s and/or
NatWest Group’s evolving views on
distribution of capital within groups).
A shortage of capital could in turn affect
NatWest Group plc’s capital ratio, and/or
its ability to make capital distributions
and in turn NatWest Group may not
remain a viable, competitive or profitable
banking business.
A minimum level of capital 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 buffer requirement
are subject to restricted discretionary
payments. The resulting 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 breach of
the combined buffer requirement may
necessitate for NatWest Group plc
reducing or ceasing discretionary
payments (including payments of
dividends to shareholders) to the extent
of the breach.
NatWest Group plc 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 at
NatWest Group plc, as the preferred
resolution strategy for NatWest Group.
As a result, NatWest Group plc is the
only entity within NatWest Group that
can externally issue securities that count
towards its MREL, the proceeds of which
can then be downstreamed to meet the
internal MREL of its operating entities
and intermediate holding companies.
If NatWest Group plc is unable to raise
the requisite amount of regulatory
capital or MREL, downstream the
proceeds of MREL to subsidiaries as
required, or to otherwise meet its
regulatory capital,
Risk factors
continued
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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 dividend payments on its ordinary
shares or maintain discretionary
payments on capital instruments.
If, under a stress scenario, the level of
regulatory capital or MREL falls outside
of risk appetite, there are a range of
recovery management actions (focused
on risk reduction and mitigation) that
NatWest Group could take to manage its
capital levels, but any such actions may
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
applicable capital or leverage
requirements may trigger the application
of NatWest Group’s recovery plan to
remediate a deficient capital position.
NatWest 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
instruments issued by NatWest Group plc
will be written-down or converted into
equity and there may be an issue of
additional equity by NatWest Group plc,
which could result in the reduction in
value of the holdings of NatWest Group
plc’s existing shareholders. The success
of such issuances will also be dependent
on favourable market conditions and
NatWest Group may not be able to raise
the amount of capital required on
acceptable terms or at all. Separately,
NatWest Group may address a shortage
of capital by taking action to reduce
leverage exposure and/or RWAs via
asset or business disposals. These
actions may, in turn, affect: NatWest
Group’s product offering, credit ratings,
ability to operate its businesses, pursue
its current strategies and pursue
strategic opportunities, any of which
may adversely affect NatWest Group’s
future results, financial condition and/or
prospects. See also,
NatWest Group may
become subject to the application of UK
statutory stabilisation or resolution
powers which may result in, for example,
the cancellation, transfer or dilution of
ordinary shares, or the write-down or
conversion of certain other of NatWest
Group’s securities.
NatWest Group may not be able to
adequately access sources of liquidity
and funding.
NatWest Group is required to access
sources of liquidity and funding through
retail and wholesale deposits, as well as
through the debt capital markets.
As at 31 December 2022, NatWest Group
plc subsidiaries held £470.7 billion in
deposits. The level of deposits may
fluctuate due to factors outside NatWest
Group’s control, such as a loss of
customers and/or investor confidence
(including in individual NatWest Group
entities), changes in interest rates,
government support, increasing
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 deposits 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, may
adversely affect NatWest Group’s ability
to satisfy its liquidity or funding needs. In
turn, this could require NatWest Group to
adapt its funding plans or change its
operations.
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 regulatory capital,
funding and leverage requirements.
As a
result, NatWest Group and its
subsidiaries could be required to adapt
their funding plans.
This could
exacerbate funding and liquidity risk,
which may adversely affect NatWest
Group.
As at 31 December 2022, NatWest Group
plc’s liquidity coverage ratio was 145%. If
its liquidity position were to come under
stress, and if NatWest Group plc were
unable to raise funds through deposits or
in the debt capital markets on
acceptable terms or at all, its liquidity
position could be adversely affected 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 financing
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 assets to
meet its liabilities, including disposals of
assets not previously identified for
disposal to reduce its funding
commitments or trigger the execution of
certain management actions or recovery
options. In a time of reduced liquidity,
NatWest Group may be unable to sell
some of its assets, or may need to sell
assets at depressed prices, which in
either case may adversely affect
NatWest Group’s future results, financial
condition and/or prospects.
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.
In October 2022, Moody’s changed the
outlook from stable to negative for
NatWest Bank Plc’s issuer rating.
NatWest Group entity credit ratings and
outlooks could be negatively affected
(directly or indirectly) by a number of
factors that can change over time,
including: credit rating agencies’
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 and regions 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 in rating
methodologies; changes in the relative
size of the loss-absorbing buffers
protecting bondholders and depositors;
the competitive environment, political
and economic conditions in NatWest
Group’s key markets (including higher
interest rates and inflation, supply chain
disruptions and the outcome of any
further Scottish independence
referendum); any reduction of the UK’s
sovereign credit rating (currently on
negative outlook by Moody’s, S&P and
Fitch) and market uncertainty. In
addition, credit ratings agencies are
increasingly taking into account
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. See also, ‘
A
reduction in the ESG ratings 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
.’
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 capital
markets, reduce the size of its deposit
base and trigger additional collateral or
other requirements in its funding
arrangements or the need to amend
such arrangements, which could
adversely affect NatWest Group’s (and,
Risk factors
continued
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Additional information
Financial review
in particular, NatWest Group plc’s) cost
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
may in turn adversely affect NatWest
Group’s competitive position and
threaten its prospects in the short to
medium-term.
NatWest Group may be adversely
affected if it fails to meet the
requirements of regulatory stress tests.
NatWest Group is subject to annual
stress tests by its regulator in the UK.
Stress tests are designed to assess 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 tests
reveal that a bank’s existing regulatory
capital buffers are not sufficient to
absorb the impact of the stress, then it is
possible that NatWest Group will need to
take action to strengthen its capital
position.
Failure by NatWest Group to meet the
quantitative and qualitative requirements
of the stress tests as set forth by its UK
regulator may result in: NatWest 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, all of which may adversely
affect its future results, financial
condition and/or prospects.
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 relies 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 stress
testing). Uncertainties relating to the
COVID-19 pandemic has made reliance
on 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.
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 models, and the parameters and
assumptions on which they are based,
are periodically reviewed.
As models analyse scenarios based on
assumed inputs and a conceptual
approach, model outputs therefore
remain uncertain. Failure of models
(including due to errors in model design)
or new data inputs (including non-
representative data sets), for example, to
accurately reflect changes in the micro
and macroeconomic environment in
which NatWest Group operates (for
example to account for high inflation), to
capture risks and exposures at the
subsidiary level and to update for
changes to NatWest Group’s current
business model or operations, or for
findings of deficiencies 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
are poorly developed, implemented or
used, models that are based on
inaccurate or compromised data or as a
result of the modelled outcome being
misunderstood, or by such information
being used for purposes for which it was
not designed.
NatWest Group’s financial statements
are sensitive to underlying accounting
policies, judgments, estimates and
assumptions.
The preparation of financial statements
requires management to make
judgments, estimates and assumptions
that affect the reported amounts of
assets, liabilities, income, expenses,
exposures and RWAs. While estimates,
judgments and assumptions take into
account historical experience and other
factors, (including market practice 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).
Further, accounting policy and financial
statement reporting requirements are
likely to increasingly require
management to adjust existing
judgments, estimates and assumptions
for the effects of climate-related,
sustainability and other matters that are
inherently uncertain and for which there
is little historical experience which may
affect the comparability of NatWest
Group’s future financial results with its
historical results. Actual results may
differ due to the inherent uncertainty in
making climate-related and sustainability
estimates, judgments and assumptions.
Accounting policies deemed critical to
NatWest Group’s results and financial
position, based upon materiality and
significant judgments and estimates,
involve a high degree of uncertainty and
may have a material impact on its
results. For 2022, these include loan
impairments, fair value, deferred tax and
conduct and litigation provisions. These
are set out in ‘
Critical accounting policies
and sources of estimation uncertainty
’.
Changes in accounting standards may
materially impact NatWest Group’s
financial results.
NatWest Group prepares its consolidated
financial statements in conformity with
the requirements of the Companies Act
2006 and in accordance with IFRS as
issued by the International Accounting
Standards Board. 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 significantly impact
the financial results, condition and
prospects of NatWest Group. From time
to time, the International Accounting
Standards Board may issue new
accounting standards or interpretations
that could materially impact how
NatWest Group calculates, reports and
discloses its financial results and financial
condition, and which may affect NatWest
Group capital ratios, including the CET1
ratio. New accounting 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
’.
Risk factors
continued
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Additional information
Financial review
The value or effectiveness of any credit
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 remaining
credit exposure arising from over-the-
counter derivative contracts, mainly
credit default swaps (CDSs), and other
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, depends on
the valuation and the perceived credit
risk of the instrument against which
protection has been bought. Many
market counterparties have been
adversely affected by their exposure to
residential mortgage-linked and
corporate credit products, whether
synthetic or otherwise, and their actual
and perceived creditworthiness may
deteriorate rapidly. If the financial
condition of these counterparties or their
actual or perceived creditworthiness
deteriorates, NatWest Group may record
further credit valuation adjustments on
the credit protection bought from these
counterparties under the CDSs. NatWest
Group also recognises any fluctuations in
the fair value of other credit derivatives.
Any such adjustments or fair value
changes may adversely affect NatWest
Group’s future results, financial condition
and/or prospects.
NatWest Group is subject to Bank of
England and PRA oversight in respect of
resolution, and NatWest Group could be
adversely affected should the Bank of
England in the future deem NatWest
Group’s preparations to be inadequate.
NatWest Group is subject to regulatory
oversight by the Bank of England and
the PRA and is required (under the PRA
rulebook) to carry out an assessment of
its preparations for resolution, submit a
report of the assessment to the PRA, and
disclose a summary of this report.
NatWest Group has dedicated significant
resources towards the preparation of
NatWest Group for a potential resolution
scenario. In June 2022 the Bank of
England communicated its assessment of
NatWest Group’s preparations and did
not identify any shortcomings,
deficiencies or substantive impediments
although two areas were highlighted as
requiring further enhancements.
NatWest Group could be adversely
affected should future Bank of England
assessments deem NatWest Group’s
preparations to be inadequate.
If future Bank of England assessments
identify a significant gap in NatWest
Group’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, 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 NatWest
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. This may also impact NatWest
Group’s strategic plans and may
adversely affect its financial condition
and/or reputation or lead to a loss of
investor confidence.
NatWest Group may become subject to
the application of UK statutory
stabilisation or resolution powers which
may result in, for example, the
cancellation, transfer or dilution of
ordinary shares, or the write-down or
conversion of certain other of NatWest
Group’s securities.
HM Treasury, the Bank of England and
the PRA and FCA (together, the
‘Authorities’) are granted substantial
powers to resolve and stabilise UK-
incorporated financial institutions. Five
stabilisation options exist: (i) transfer of
all of the business of a relevant entity or
the shares of the relevant entity to a
private sector purchaser; (ii) transfer 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 may 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 fail).
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 and may promulgate
provisions with retrospective
applicability.
Under the UK Banking Act, the
Authorities are generally required to
have regard to specified objectives in
exercising the powers provided for by
the Banking Act. One of the objectives
(which is required to be balanced as
appropriate with the other specified
objectives) refers to the protection and
enhancement of the stability of the
financial system of the UK. Moreover, the
‘no creditor worse off’ safeguard
contained in the Banking Act may not
apply in relation to an application of the
separate write-down and conversion
power relating to capital instruments
under the Banking Act, in circumstances
where a stabilisation power is not also
used. Holders of debt instruments 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 issued by
NatWest Group, which may depend on
factors outside of NatWest Group’s
control. Moreover, the Banking Act
provisions remain largely untested in
practice, particularly in respect of
resolutions of large financial institutions
and groups.
If NatWest Group is at or is approaching
the point of non-viability such that
regulatory intervention is required, any
exercise of the resolution regime powers
by the Authorities may adversely affect
holders of NatWest Group plc’s ordinary
shares or other NatWest Group
securities. This may result in various
actions being undertaken in relation to
NatWest Group and any securities of
NatWest Group, including cancellation,
transfer, dilution, write-down or
conversion (as applicable). There may
also be a corresponding adverse effect
on the market price of such ordinary
shares and other NatWest Group
securities.
Risk factors
continued
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Financial review
Climate and sustainability-related risks
NatWest Group and its customers,
suppliers and counterparties face
significant climate and sustainability-
related risks, which may adversely affect
NatWest Group.
Climate-related risks represent a source
of systemic risk in the global financial
system. The financial impacts of climate-
related risks are expected to be
widespread, exacerbating already
existing financial vulnerabilities and may
disrupt the proper functioning of
financial markets and institutions,
including NatWest Group.
Financial and non-financial risks from
climate change and sustainability-related
risks can arise through physical and
transition risks. In addition, physical and
transition risks can trigger further losses,
stemming directly or indirectly from legal
claims, litigation and conduct liability
(referred to as ‘liability risk’). See also,
NatWest Group may be subject to
potential climate, environmental, human
rights and other sustainability-related
litigation, enforcement proceedings,
investigations and conduct risk
.’
There are significant uncertainties as to
the location, extent and timing of the
manifestation of the physical risks of
climate change, such as more severe
and frequent extreme weather events
(storms, flooding, subsidence, heat
waves, droughts and wildfires), rising sea
levels, nature and biodiversity loss,
declining food yields, destruction of
critical infrastructure, supply chain
disruption and resource scarcity.
Damage to NatWest Group customers’,
suppliers’ and counterparties’ 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 those of its critical
outsourced functions may experience
damage or disruption leading to
increased costs and adversely affect
NatWest Group’s reputation, future
results, financial condition and/or
prospects.
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 (defined as the point at which
greenhouse gas emissions from sources
are equal to removals by sinks as set out
in Article 4 of the 2015 Paris
Agreement). An independent review of
the government’s approach to delivering
its net zero target to ensure it is pro-
business and pro-growth was published
in January 2023.
The timing, content and implementation
of the specific policies and proposals
remain uncertain and are subject to
continuous changes and developments.
The transition to a net-zero economy
across all sectors of the economy and
markets in which NatWest Group
operates will be required to meet the
goals of the UN Framework Convention
on Climate Change (1994), the 2015
Paris Agreement, the UK’s Net Zero
Strategy and the European Green Deal
initiatives. The impacts of the extensive
social, commercial, technological, policy
and regulatory changes required to
achieve transition remain uncertain but
are expected to be significant, subject to
continuous changes and developments
and may be disruptive across the global
economy and markets, 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 the oil and gas industry),
mobility (including land transport,
aviation, and shipping industries and the
related manufacturing and infrastructure
industry) and food (including the
agriculture industry) are expected to be
particularly impacted. The timing and
pace of the transition to a net-zero
economy is also uncertain, will depend
on many factors and uncertainties and
may be near-term, gradual and orderly,
or delayed, rapid and disorderly, or a
combination of these. There is also
growing attention on the need for a
'just
transition'
and
‘energy justice’
– in
recognition that the transition to net zero
should not disproportionally affect the
most disadvantaged members of society.
In addition, NatWest Group and its
customers, suppliers and counterparties
may face economic, financial and non-
financial risks arising from broader
sustainability issues such as: (i) risks
relating to degradation of the
environment, such as air, water and land
pollution, water stress, nature and
biodiversity loss and deforestation which
may include for instance loss and/or
decline of the state of nature (including
the state of biodiversity); (ii) social
matter-related risks (including violent
conflicts, geopolitical implications,
impacts on indigenous people, migration,
human rights, diversity, equality and
inclusion, the living wage, fair taxation
and value chains); and (iii) governance-
related risks (including board diversity,
ethics, executive compensation and
management structure).
Financial institutions, including NatWest
Group, are directly and indirectly
exposed to multiple types of
environmental risks (including nature
and biodiversity related risks) through
their activities, including through the risk
of default by clients.
In addition to safeguards and
interventions that focus on reducing
negative impacts on the environment
(including nature and biodiversity), there
is also a growing need to implement
solutions that focus on increasing
positive impacts on environment
(including nature and biodiversity)
through nature-based solutions. In 2021,
NatWest Group classified ‘
Biodiversity
and Nature Loss
’ as an emerging risk for
NatWest Group within its Risk
Management Framework.
The Taskforce on Nature-Related
Financial Disclosures (TNFD) is a global,
market-led initiative with the mission to
develop and deliver a risk management
and disclosure framework for
organisations to report and act on
evolving nature-related risks and
opportunities, with the ultimate aim of
supporting a shift in global financial flows
away from nature-negative outcomes
and toward nature-positive outcomes.
NatWest Group is a member of the
Informal Working Group 2020 of TNFD
and is a Forum Member since 2021.
Measuring the environmental related
financial impacts (including impacts on
nature and biodiversity related financial
impacts) as a result of funding and
financing activities as well as reporting
on these is an evolving and complex
area for the financial services industry
which requires collaborative approaches
with partners, stakeholders, peers and
public sector bodies to help measure and
mitigate the negative impacts of the
activities which NatWest Group finances
on the environment (including nature
and biodiversity), as well as supporting
the growing sector of nature-based
solutions and habitat restoration and
biodiversity markets. NatWest Group is in
the early stages of developing its
approach to assess, manage and
mitigate environmental risks and by
using emerging industry guidance such
as the TNFD beta framework, NatWest
Group is seeking to further its
understanding of how NatWest Group’s
business activities impact nature, the
dependencies NatWest Group and its
customers have on nature, and the risks
and opportunities nature can generate.
There is also increased scrutiny from
NatWest Group’s employees, investors,
customers, counterparties (including its
suppliers), communities, regulators and
other stakeholders regarding how
businesses address social issues,
including tackling inequality, working
conditions, workplace health, safety and
wellbeing,
Risk factors
continued
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diversity and inclusion, data protection
and management, workforce
management, human rights and supply
chain management which may impact
NatWest Group’s employees, suppliers,
customers, and their business activities
or the communities in which they
operate.
These climate and sustainability-related
risks may:
adversely affect economic activity,
asset pricing and valuations of
financial instruments and, in turn, the
wider financial system;
impact economic activities directly
(for example through lower
corporate profitability or the
devaluation of assets) or indirectly
(for example through macro-financial
changes);
also affect the viability or resilience
of business models over the medium
to longer term, particularly those
business models most vulnerable to
climate and sustainability-related
risks;
trigger further losses stemming
directly or indirectly from legal claims
(liability risks) and reputational
damage as a result of the public,
customers, counterparties, suppliers
and/or investors associating NatWest
Group or its customers with adverse
climate and sustainability-related
issues;
intersect with and add further
complexity and challenge to
achieving NatWest Group’s purpose-
led strategy including climate
ambitions and targets;
be drivers of several different risk
categories simultaneously and may
exacerbate existing risks, including
credit risk, operational risk (including
business continuity), market risk
(both traded and non-traded),
liquidity and funding risk (for
example, net cash outflows or
depletion of liquidity buffers), pension
risk and conduct risk; and
if combined, may have a greater
adverse effect on NatWest Group’s
reputation, future results, financial
condition and/or prospects.
If NatWest Group fails in a timely manner
to identify and address climate and
sustainability-related risks and
opportunities and changing regulatory
and market expectations, or to
appropriately identify, measure, manage
and mitigate climate and sustainability-
related physical, transition and liability
risks and opportunities that NatWest
Group, its customers, counterparties and
suppliers face, this may adversely affect
NatWest Group’s reputation, future
results, financial condition and/or
prospects.
NatWest Group’s climate change related
strategy, ambitions, targets and
transition plan entail significant
execution and reputational risk and are
unlikely to be achieved without
significant and timely government policy,
technology and customer behavioural
changes.
In February 2020, NatWest Group
announced its ambition to become a
leading bank in the UK helping to
address the climate challenge. As part of
the implementation of its climate
ambitions, at NatWest Group’s Annual
General Meeting in April 2022, ordinary
shareholders passed an advisory ‘Say on
Climate’ resolution endorsing NatWest
Group’s previously announced strategy
to address climate change, including its
ambitions to at least halve the climate
impact of its financing activity by 2030,
achieve alignment with the 2015 Paris
Agreement and reach net zero by 2050
across its financed emissions, assets
under management and operational
value chain.
Furthermore, as part of its efforts to
support the transition to a net-zero
economy, NatWest Group has
announced its plans to (i) stop lending
and underwriting to companies with
more than 15% of activities related to
thermal and lignite coal, unless they had
a Credible Transition Plan in line with the
2015 Paris Agreement in place by end of
2021; phase out of thermal and lignite
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;
(ii) to stop lending and underwriting to
major oil and gas producers unless they
had a Credible Transition Plan aligned
with the 2015 Paris Agreement in place
by the end of 2021; (iii) from February
2023 stop providing reserve based
lending specifically for the purpose of
financing oil and gas exploration,
extraction and production for new
customers, and, after the 31 December
2025 not to renew, refinance or extend
existing reserve- based lending
specifically for the purpose of financing
oil and gas exploration, extraction and
production; and (iv) stop providing
reserve-based lending and borrowing
base financing to upstream Oil and Gas
companies specifically for the purpose of
financing upstream assets located in
Arctic or Antarctic Waters.
In December 2022, NatWest Group
published its science based targets
validated by Science Based Target
Initiative (SBTi) for its own operational
footprint and for 79% of its loans and
investments (debt securities and equity
shares) on its 2019 balance sheet, at
sector level.
NatWest Group has also announced and
in the future it may also announce other
climate ambitions and targets which
support its overarching strategy to
address climate change.
Making the changes necessary to
achieve NatWest Group’s strategy on
addressing climate change, including its
climate ambitions and targets and
executing its transition plan, may
adversely affect NatWest Group’s
business and operations and will require
significant reductions to its financed
emissions and to its exposure to
customers that do not align with a
transition to net zero or do not have a
credible transition plan in place.
Increases in lending and financing
activities may wholly or partially offset
some or all these reductions, which may
increase the extent of changes and
reductions necessary. It is anticipated
that achieving these reductions, together
with the active management of climate
and sustainability-related risks and other
regulatory, policy and market changes, is
likely to necessitate material and
accelerated changes to NatWest Group’s
business, operating model, its existing
exposures and the products and services
NatWest Group provides to its customers
(potentially on accelerated timescales)
which may adversely affect NatWest
Group’s ability to achieve its financial
targets and generate sustainable returns.
NatWest Group also needs to ensure that
its strategy and business model adapt to
changing national and international
standards, industry and scientific
practices, regulatory requirements and
market expectations regarding climate
change, which remain under continuous
development and are subject to different
interpretations. There can be no
assurance that these standards,
practices, requirements and expectations
will not be interpreted differently than
what was NatWest Group’s
understanding when defining its climate-
related ambitions and targets or change
in a manner that substantially increases
the cost or effort for NatWest Group to
achieve such ambitions and targets. In
addition, NatWest Group’s ambitions and
targets may prove to be considerably
more difficult or even impossible to
achieve under such changing
circumstances. This may be exacerbated
if NatWest Group chooses or is required
to accelerate its climate-related
ambitions or targets as a result of
(among other things) UK or international
regulatory developments or stakeholder
expectations.
NatWest Group’s ability to achieve its
strategy to address climate change,
including achieving its climate ambitions
and targets, will depend to a large extent
Risk factors
continued
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on many factors and uncertainties
beyond NatWest Group’s control.
These include the extent and pace of
climate change, including the timing and
manifestation of physical and transition
risks, the macroeconomic environment,
the timely implementation and
integration of adequate government
policies, the effectiveness of actions of
governments, legislators, regulators,
businesses, investors, customers and
other stakeholders to mitigate the impact
of climate and sustainability-related risks,
changes in customer behaviour and
demand, changes in the available
technology for mitigation, the roll-out of
low carbon infrastructure and the
availability of accurate, verifiable,
reliable, consistent and comparable data.
See also, ‘
There are significant
challenges in accessing reliable,
verifiable and comparable climate and
other sustainability-related data due to
availability, quality and other limitations,
which contribute to the substantial
uncertainties in accurately modelling and
reporting on climate and sustainability
information, as well as making
appropriate important internal decisions
’.
These external factors and other
uncertainties will make it challenging for
NatWest Group to meet its climate
ambitions and targets 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 ambitions and
targets may adversely affect NatWest
Group, its reputation, future results,
financial condition and/or prospects and
may increase the climate and
sustainability-related risks NatWest
Group faces.
There are significant limitations related
to accessing reliable, verifiable and
comparable climate and other
sustainability-related data, including as a
result of lack of standardisation,
consistency and completeness which,
alongside other factors, contribute to
substantial uncertainties in accurately
modelling and reporting on climate and
sustainability information, as well as
making appropriate important internal
decisions.
Meaningful reporting of climate and
sustainability-related risks and
opportunities and their potential impacts
and related metrics depends on access
to accurate, reliable, consistent and
comparable climate and sustainability-
related data from counterparties or
customers. Data may not be generally
available or, if available, may not be
accurate, verifiable, auditable, reliable,
consistent, or comparable.
Any failure of NatWest Group to
incorporate climate and/or sustainability-
related factors into its counterparty and
customer data sourcing and
accompanying analytics, or to collect or
develop accurate, verifiable, auditable,
reliable, consistent and comparable
counterparty and customer data, may
adversely affect NatWest Group’s ability
to prepare meaningful reporting of
climate and sustainability-related risks
and opportunities, and it may adversely
affect NatWest Group’s regulatory
compliance, reputation, business and its
competitive position.
In the absence of other sources,
reporting of financed emissions by
financial institutions, including NatWest
Group, is necessarily based on
aggregated information developed by
third parties that may be prepared in an
inconsistent way using different
methodologies, interpretations, or
assumptions. NatWest Group’s climate
and sustainability-related disclosures use
a greater number and level of
assumptions and estimates than many of
its financial disclosures. These
assumptions and estimates are highly
likely to change over time, and, when
coupled with the longer timeframes used
in these climate and sustainability-
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 counterparty
or customer. There may also be data
gaps that are filled using proxy data,
such as sectoral averages, again
developed in different ways. As a result,
NatWest Group’s climate and
sustainability-related disclosures may be
amended, updated or restated in the
future as the quality and completeness of
NatWest Group’s data and
methodologies continue to improve.
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, to comply
with disclosure requirements and to
monitor and report progress in meeting
ambitions and targets.
Significant risks, uncertainties and
variables are inherent in the assessment,
measurement and mitigation of climate-
related risks.
These include data quality gaps and
limitations mentioned above, as well as
the pace at which climate science,
greenhouse gas accounting standards
and various emissions reduction solutions
develop. In addition, there is significant
uncertainty about how climate change
and the transition to a net-zero economy
will unfold over the coming years and
decades and how and when climate-
related risks will manifest. These
timeframes are considerably longer than
NatWest 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 economic
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 incompleteness 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 depend 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,
rather they explore the possible
implications of different judgments
and assumptions by considering a
series of scenarios;
climate scenarios do not provide a
comprehensive description of all
possible future outcomes;
lack of specialist expertise in banks
such that NatWest Group needs to
rely on third party advice, modelling,
and data which is also subject to
many limitations and uncertainties;
immaturity of modelling of and data
on climate-related risks on financial
assets which will evolve rapidly in the
coming years;
the number of variables and forward-
looking nature of climate scenarios
which makes them challenging to
back test and benchmark;
the significant uncertainty as to how
the climate will evolve over 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;
Risk factors
continued
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the assumptions will be continually
evolving with more data/information
which may affect the baselines for
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 sheet
with regard to emissions.
Accordingly, these risks and
uncertainties coupled with significantly
longer timeframes make the outputs of
climate-related risk modelling, including
emission reduction targets and
pathways, inherently more uncertain
than outputs modelled for traditional
financial planning cycles based on
historical financial information.
Furthermore, there is a lack of scientific,
industry and regulatory consensus
regarding the appropriate metrics,
methodologies, modelling and
standardised reporting to enable the
assessment of the location, acuteness,
and severity of environmental risks
(including nature and biodiversity-related
risks) and the monitoring and mitigation
of these risks in the economy and
financial system.
Capabilities within NatWest Group to
appropriately assess, model, report and
manage climate and sustainability-
related risks and impacts and the
suitability of the assumptions required to
model and manage climate and
sustainability-related risks appropriately
are developing. The development of
NatWest Group’s capabilities to assess,
model, report and manage the impacts
of climate change and broader
environmental risk (including nature and
biodiversity-related risks) is in its early
stages. Even when those capabilities are
developed, 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 adversely affect NatWest
Group’s regulatory compliance,
reputation, future results, financial
condition and/or prospects.
A failure to implement effective climate
change resilient governance, procedures,
systems and controls in compliance with
legal and regulatory expectations to
manage climate and sustainability-
related risks and opportunities could
adversely affect NatWest Group’s ability
to manage those 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. 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 (‘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. In response to the PRA’s SS
3/19, following the submission of initial
plans in October 2019, 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 its original
plan and, as a result, the updated plan
would require additional operating cycles
reaching into 2022 and beyond to prove
embedding. Throughout 2022, NatWest
Group provided the PRA with updates on
how it had addressed the commitments
made in its October 2020 plan, noting
the delivery of a first generation, largely
qualitative in nature, approach to the
supervisory requirements. In 2022, the
PRA has also started actively supervising
firms against their supervisory
expectations and it issued another ‘Dear
CEO letter’ providing a summary of
capabilities which the PRA would expect
firms to be able to demonstrate, setting
out thematic observations on firms’
levels of embeddedness, and providing
examples of effective practices identified.
In June 2021, the Bank of England
launched its 2021 Biennial Exploratory
Scenario (‘2021 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 change
under three climate scenarios. NatWest
Group delivered its first 2021 CBES
submission to the PRA in October 2021
and its submission to the second phase
of the 2021 CBES exercise in the first
quarter of 2022. In May 2022, the PRA
published the results of the 2021 CBES
which has shown that UK banks,
including NatWest Group, need to do
more to understand and manage their
exposure to climate risks and that the
lack of available data on corporates’
current emissions and future transition
plans is a collective issue affecting all
participating firms.
In July 2022, the participating banks in
the 2021 CBES exercise were invited to
discuss methodologies and challenges
with regards to climate risk scenario
analysis.
In October 2022, the Bank of England
and the PRA held a conference to
facilitate discussion on the complex
issues associated with adjusting the
capital framework to take account of
climate-related financial risks with the
aim of providing more guidance on its
approach to climate and capital by the
end of 2022. The Bank of England does
not think capital frameworks should be
used to address the causes of climate
change. However, as set out in the PRA’s
Climate Change Adaptation Report 2021,
and as with any other risk, it does think
the capital framework could be a useful
tool within the broader regulatory
frameworks to ensure that PRA-
regulated firms are resilient to climate
risks.
Any failure of NatWest Group to fully and
timely embed climate-related risks 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
adversely affect NatWest Group’s
regulatory compliance, prudential capital
requirements, liquidity position,
reputation, future results, financial
condition and/or prospects.
Climate and sustainability-related
disclosures are a rapidly evolving area
and increasingly expose NatWest Group
to risk in the face of legal and regulatory
expectations, regulatory enforcement
and class action risk. NatWest Group and
its subsidiaries currently are and in the
future will be subject to increasing entity-
wide climate-related and other non-
financial disclosure requirements,
including pursuant to the
recommendations of the Task Force on
Climate-related Financial Disclosure
(‘TCFD’), the proposed SEC Climate
Disclosure Rules and ISSB sustainability
reporting requirements and under other
regimes. As from February 2022,
NatWest Group is required to provide
enhanced climate-related disclosures
consistent with the TCFD
recommendations to comply with the
FCA Policy Statement on ‘Proposals to
enhance climate-related disclosures by
listed issuers and clarification of existing
disclosure obligations’ (PS 20/17) which
introduced new Listing Rules that require
commercial companies with a UK
premium listing – such as NatWest Group
- to make climate-related disclosures,
Risk factors
continued
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consistent with TCFD, on a ‘comply or
explain’ basis. In addition, as of the
accounting period beginning on or after
1 January 2022, NatWest Group is also in
scope of the FCA Policy Statement
‘Enhancing climate-related disclosures
by standard listed companies’ (PS 21/23)
which confirmed its final policy position
set forth in PS 20/17, extended the scope
of issuers that are subject to the new
Listing Rules and added guidance
provisions on transition plan disclosure
(for issuers in scope of both the PS 20/17
and the new PS 21/23 rules). As of 5
April 2022, NatWest Group is also
required to prepare mandatory climate-
related financial disclosures pursuant to
The Companies (Strategic Report)
(Climate-related Financial Disclosure)
Regulations 2022.
Furthermore, in October 2022, the FCA
published a Consultation Paper on
‘Sustainability Disclosure Requirements
(SDR) and investment labels’ (CP 22/20)
which proposes that the FCA will require
all regulated firms to ensure that from
June 2023 the naming and marketing of
financial products and services in the UK
is clear, fair and not misleading, and
consistent with the sustainability profile
of the products or services, i.e.
proportionate and not exaggerated.
Misrepresenting or over-emphasising the
extent to which an investment, strategy
or other type of product takes into
account environmentally friendly,
sustainable or ethical features and
concerns, using misleading labels and
language in relation to such products
and/or omitting material information
about NatWest Group’s contribution to
the climate crisis (including its direct or
indirect contribution to greenhouse gas
emissions), or other sustainability-related
issues, could potentially result in
complaints, regulatory intervention,
claims and/or litigation and reputational
damage.
Any failure of NatWest Group to
implement robust and effective climate
and sustainability-related disclosure
governance and to embed appropriate
product governance policies, procedures
and controls to make accurate public
statements and claims about how
environmentally friendly, sustainable or
ethical NatWest Group’s products and
services are and to apply these in line
with applicable legal and regulatory
requirements and expectations, may
adversely affect NatWest Group’s
regulatory compliance and reputation
and could give rise to litigation.
Increasing levels of climate,
environmental, human rights and other
sustainability-related laws, regulation
and oversight which are constantly
evolving may adversely affect NatWest
Group.
There is an increasing number of EU, UK
and other regulatory and legislative
initiatives to address issues around
climate change (including promoting the
transition to a net-zero economy),
environment (including nature and
biodiversity), human rights and other
sustainability-related risks and
opportunities. As a result, an increasing
number of laws, regulations and
legislative actions, including proposals,
guidance, policy and regulatory
initiatives many of which have been
introduced or amended recently and are
subject to further changes, is likely to
affect the financial sector and the wider
economy.
Many of these initiatives are focused on
developing standardised definitions and
criteria for green and sustainable criteria
of assets and liabilities, integrating
climate 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 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
adversely affect NatWest Group’s ability
to achieve its strategy and climate and
sustainable funding and financing
ambitions.
In addition, NatWest Group’s EU and
other non-UK subsidiaries and branches
are and will continue to be subject to an
increasing array of the EU/EEA and US
climate and sustainability-related legal
and regulatory requirements. These
requirements (potentially including the
EU Corporate Sustainability Due
Diligence Directive or the EU Corporate
Sustainability Reporting Directive) may
be applicable to UK businesses such as
NatWest Group, or used as the basis for
UK laws and regulations (such as the UK
Green Taxonomy and the FCA’s
Consultation Paper on ‘Sustainability
Disclosure Requirements (SDR) and
investment labels’ (CP 22/20)), or be
regarded by investors and regulators as
best practice standards whether or not
they apply to UK businesses (such as the
EU Green Bond Standard). Any
divergence between UK, EU/EEA and US
climate and sustainability-related legal
and regulatory requirements and their
interpretation may result in NatWest
Group, or any of its subsidiaries, not
meeting regulatory requirements,
investors’ expectations, may increase the
cost of doing business (including
increased operating costs) and
contentious regulatory and litigation risk
and may restrict access of NatWest
Group’s UK business to the EU/EEA and
US market.
NatWest Group is also participating in
various voluntary carbon reporting and
other standard setting initiatives for
disclosing climate and sustainability-
related information, many of which have
differing objectives and methodologies
and are at different stages of
development in terms of how they apply
to financial institutions.
Compliance with these developing and
evolving climate and sustainability-
related legal and regulatory
requirements is likely to require NatWest
Group to implement significant changes
to its business models, products and
other governance, internal controls over
financial reporting, disclosure controls
and procedures, modelling capability and
risk management systems, which may
increase the cost of doing business, and
entail additional change risk and
increased compliance, regulatory
sanctions and litigation (including
settlements) costs.
Failure to implement and comply with
these legal and regulatory requirements
or emerging best practice expectations
may have a material adverse effect on
NatWest Group’s regulatory compliance
and may result in regulatory sanctions,
reputational damage and investor
disapproval each of which may
adversely affect NatWest Group’s future
results, financial condition and/or
prospects.
NatWest Group may be subject to
potential climate, environmental, human
rights 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 litigation,
conduct, enforcement and contract
liability risks related to climate change,
environmental degradation, human
rights violations and other social,
governance and sustainability-related
issues.
Risk factors
continued
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These risks may arise, for example, from
claims pertaining to: (i) failure to meet
obligations, targets or commitments
relating to, or to disclose accurately, or
provide updates on material climate
and/or sustainability-related risks, or
otherwise provide fair, balanced and
appropriate disclosure to investors,
customers, counterparties and other
stakeholders; (ii) conduct, mis-selling and
customer protection claims, including
claims which may relate to alleged
insufficient product understanding,
unsuitable product offering and /or
reliance upon information provided by
NatWest Group or claims alleging unfair
pricing of climate-related products, for
example in relation to products where
limited liquidity or reliable market data
exists for benchmarking purposes or
which may be impacted by future
climate policy uncertainty or other
factors; (iii) marketing that portrays
products, securities, activities or policies
as having positive climate, environmental
or sustainable outcomes to an extent
that may not be the case, or may not
adequately be qualified and/or omits
material information about NatWest
Group’s contribution to the climate crisis
and/or its direct / indirect contribution to
greenhouse gas emissions or other
sustainability-related issues; (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’ duties, for example
by financing various carbon-intensive,
environmentally harmful or otherwise
highly exposed assets, companies, and
industries; (vi) changes in the
understanding of what constitutes
positive climate, environmental or
sustainable outcomes as a result of
developing climate science, leading to
discrepancy between current product
offerings and investor and/or market
and/or broader stakeholder
expectations; (vii) any weaknesses or
failures in specific systems or processes
associated particularly with climate,
environmental or sustainability linked
products, and/or human rights due
diligence, including any failure in the
timely implementation, onboarding
and/or updating of such systems or
processes; or (viii) counterparties,
collaborators, customers to whom
NatWest Group provides services and
third parties in NatWest Group’s value
chain who act, or fail to act, or
undertake due diligence, or apply
appropriate risk management and
product governance in a manner that
may adversely affect NatWest Group’s
reputation or sustainability credentials.
Furthermore, there is a risk that
shareholders, campaign groups,
customers and special interest groups
could seek to take legal action against
NatWest Group for financing or
contributing to climate change,
environmental degradation and human
rights violations and for not supporting
the principles of ‘just 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 private sectors).
There is a risk that as environmental and
climate science develop and societal
understanding of these issues increases
and deepens, courts, regulators and
enforcement authorities may apply the
then current understandings of
environmental, climate and broader
sustainability-related matters
retrospectively when assessing claims
about historical conduct or dealings of
financial institutions, including NatWest
Group. See also, ‘
NatWest Group is
exposed to the risks of various litigation
matters, regulatory and governmental
actions and investigations as well as
remedial undertakings, including
conduct-related reviews, anti-money
laundering and redress projects, the
outcomes of which are inherently difficult
to predict, and which could have an
adverse effect on NatWest Group’
.
These potential litigation, conduct,
enforcement and contract liability risks
may have a material adverse effect on
NatWest Group’s ability to achieve its
strategy, including its climate ambition,
and may adversely affect NatWest
Group’s reputation, future results,
financial condition and/or prospects.
A reduction in the ESG ratings 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
pertaining to NatWest Group’s and/or its
subsidiaries’ securities or being used as a
basis to label financial products and
services as environmentally friendly or
sustainable.
ESG ratings are (i) unsolicited; (ii) subject
to the assessment 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 are beyond NatWest
Group’s control (e.g. any change in
rating methodology). In addition, certain
NatWest Group entities offer or sell
products and services to customers and
counterparties based exclusively or
largely on a rating by an unregulated
ESG rating agency. ESG rating agencies,
at this stage, are not subject to any
specific regulatory or other regime or
oversight (although there are proposals
by regulators in different jurisdictions to
regulate rating agencies and data
providers). Regulators have expressed
concern that harm may arise from
potential conflicts of interest within ESG
rating and review or opinion providers
and there is a lack of transparency in
methodologies and data points, which
renders ratings and reviews
incomparable between agencies or
providers.
There is currently no market
consensus on what precise attributes are
required for a particular asset to be
classified as ‘ESG’. Any reduction in the
ESG ratings of NatWest Group, or a
regulatory sanction or enforcement
action involving an ESG rating agency
used by a NatWest Group entity, could
have a negative impact on NatWest
Group’s reputation, could influence
investors’ risk appetite for NatWest
Group’s and/or its subsidiaries’ securities,
particularly ESG securities, could
increase the cost of issuing securities for
NatWest Group and/or its subsidiaries
and could affect a customer’s willingness
to deal with NatWest Group.
Operational and IT resilience risk
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 loss or
disruption resulting from inadequate or
failed internal processes, procedures,
people or systems, or from external
events, including legal and regulatory
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.
Risk factors
continued
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As a result, operational risks or losses
can arise from a number of internal or
external factors (including for example,
payment errors or financial crime and
fraud), for which there is continued
scrutiny by third parties on NatWest
Group’s compliance with financial crime
requirements; see also, ‘
NatWest Group
is exposed to the risks of various
litigation matters, regulatory and
governmental actions and investigations
as well as remedial undertakings,
including conduct-related reviews, anti-
money laundering and redress projects,
the outcomes of which are inherently
difficult to predict, and which could have
an adverse effect on NatWest Group.
These risks are also present when
NatWest Group relies on critical service
providers (suppliers) or vendors to
provide services to it or its customers, as
is increasingly the case as NatWest
Group outsources certain activities,
including with respect to the
implementation of technologies,
innovation and responding to regulatory
and market changes.
Operational risks continue to be
heightened as a result of the
implementation of NatWest Group’s
purpose-led strategy, and the
organisational and operational changes
involved, including: NatWest Group’s
phased withdrawal from ROI, NatWest
Group’s current cost-controlling
measures, the NatWest Markets
refocusing, the creation of the
Commercial & Institutional business
segment, the progression towards
working as One Bank across NatWest
Group to serve customers and conditions
affecting the financial services industry
generally (including macroeconomic and
other geo-political developments) as well
as the legal and regulatory uncertainty
resulting therefrom. It is unclear 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 best 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, such
measures may not be effective in
controlling each of the operational risks
faced by NatWest Group. Ineffective
management of such risks may
adversely affect NatWest Group’s future
results, financial condition and/or
prospects.
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 designed to
defend against emerging threats. In
2022, NatWest Group and its supply
chain were subjected to a small number
of Distributed Denial of Service (‘DDOS’)
and ransomware attacks, which are a
pervasive and significant threat to the
financial services industry. The focus is
to manage the impact of the attacks and
sustain availability of services for
NatWest Group’s customers. NatWest
Group continues to invest significant
resources in the development and
evolution of cyber security controls that
are designed to minimise the 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 controls
in place to seek to minimise the impact
of any such attacks, 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 the potential negative impacts of
any such attacks from occurring. See
also, ‘
NatWest Group’s operations are
highly dependent on its complex IT
systems 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 customer
services, or loss of data or systems or
other sensitive information (including as
a result of an outage) and may cause
associated reputational damage. Any of
these factors could increase costs
(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 attract
customers. Regulators in the UK, US,
Europe and Asia continue to recognise
cybersecurity as an important systemic
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
reporting or notification of them, as
appropriate. Cyberattacks on NatWest
Group’s counterparties may also damage
NatWest Group’s operations.
Additionally, third parties may also
fraudulently attempt to induce
employees, customers, third-party
providers or other users who have
access to NatWest Group’s systems to
disclose sensitive information in order to
gain access to NatWest Group’s data or
systems 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, human
error, fraud or malice on the part of
NatWest Group’s employees or third
parties, including third party providers,
or may result from technological failure.
Any of the above may have an adverse
effect on NatWest Group’s reputation,
future results, financial condition and/or
prospects.
NatWest Group expects greater
regulatory engagement, supervision and
enforcement to continue at a high level
in relation to its overall resilience to
withstand IT and IT-related disruption,
either through a cyberattack or some
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 may adversely
affect NatWest Group’s future results,
financial condition and/or prospects. Due
to NatWest Group’s reliance on
technology and the increasing
sophistication, frequency and impact of
cyberattacks, such attacks may have an
adverse effect on NatWest Group.
In accordance with the Data Protection
Act 2018 and the European Union
Withdrawal Act 2018, the Data
Protection, Privacy and Electronic
Communications (Amendments Etc.) (EU
Exit) Regulations 2019, as amended 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
Additional information
Risk factors
continued
NatWest Group
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Additional information
Financial review
data of NatWest Group, its customers
and its employees. In order to meet this
requirement, NatWest Group relies on
the effectiveness of its internal policies,
controls and procedures to protect the
confidentiality, integrity and availability
of information held on its IT systems,
networks and devices as well as with
third parties with whom NatWest 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 damage.
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.
Investment is being made in data tools
and analytics, including raising
awareness around data ethical usage
and privacy across NatWest Group. The
availability and accessibility 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
becoming a critical strategic asset, which
is subject to increased regulatory focus.
Failure to have or be able to access 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 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 processes, which could result in a
failure to deliver NatWest Group’s
strategy. These data weaknesses and
limitations, or the unethical or
inappropriate use of data, and/or non-
compliance with data protection laws
could give rise to conduct and litigation
risks and may increase the risk of
operational challenges, losses,
reputational damage or other adverse
consequences due to inappropriate
models, systems, processes, decisions or
other actions.
NatWest Group’s operations are highly
dependent on its complex IT systems and
any IT failure could adversely affect
NatWest Group.
NatWest Group’s operations are highly
dependent on the ability to process a
very large number of transactions
efficiently and accurately while
complying with applicable laws and
regulations. The proper functioning of
NatWest Group’s payment systems,
financial crime, fraud systems and
controls, risk management, credit
analysis and reporting, accounting,
customer service and other IT systems
(some of which are owned and operated
by other entities in NatWest Group or
third parties), as well as the
communication networks 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 significant damage
to: (i) important business services across
NatWest Group and (ii) NatWest Group’s
ability to provide services to its
customers, which could result in
reputational damage, significant
compensation costs and regulatory
sanctions (including fines resulting from
regulatory investigations) or a breach of
applicable regulations and could affect
NatWest Group’s regulatory approvals,
competitive position, business and
brands, which could undermine its ability
to attract and retain customers. NatWest
Group outsources certain functions as it
innovates and offers new digital solutions
to its customers to meet the demand for
online and mobile banking. Outsourcing
alongside hybrid working patterns of
NatWest Group employees, heighten the
above risks.
NatWest Group uses IT systems that
enable remote working interface with
third-party systems, and NatWest Group
could experience service denials or
disruptions 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.
In 2022, NatWest Group continued to
make considerable investments to
further simplify, upgrade and improve 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 seeks to
improve its competitive position through
enhancing controls and procedures and
strengthening the resilience of services
including cyber security. Any failure of
these investment and rationalisation
initiatives to achieve the expected
results, due to cost challenges or
otherwise, may adversely affect NatWest
Group’s operations, its reputation and
ability to retain or grow its customer
business or adversely affect its
competitive position.
NatWest Group relies on attracting,
retaining and developing diverse senior
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 develop
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 efficiency pressures.
NatWest Group’s ability to do this may
be more difficult due to the cost-
controlling measures, a failure to pay
employees competitive compensation,
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 that have
been in receipt of government support
such as NatWest Group). This may
impact the cost of hiring, training and
retaining diverse skilled personnel. In
addition, certain economic, market and
regulatory conditions and political
developments may reduce the pool of
candidates for key management and
non-executive roles, including non-
executive directors with the right skills,
knowledge and experience, or increase
the number of departures of existing
employees. Moreover, a failure to foster
a diverse and inclusive workforce may
adversely affect NatWest Group’s
employee engagement and the
formulation and execution of its strategy
and could also have an adverse effect on
its reputation with customers, investors
and regulators.
The inability to compensate employees
competitively and/or any reduction of
compensation, as a result of negative
economic developments or otherwise,
could have an adverse effect on NatWest
Group’s ability to hire, retain and engage
appropriately qualified employees,
especially at a senior level, which may
adversely affect NatWest Group’s future
results, financial condition and/or
prospects.
Many of NatWest Group’s employees 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 may adversely affect
NatWest Group’s ability to operate its
business effectively.
Risk factors
continued
NatWest Group
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Additional information
Financial review
A failure in NatWest Group’s risk
management framework could adversely
affect NatWest Group, including its ability
to achieve its strategic objectives.
Risk management is an integral part of
all of NatWest Group’s activities and
delivery of its long-term strategy.
NatWest Group’s Enterprise-Wide Risk
Management Framework sets out the
approach for managing risk within the
NatWest Group including in relation to
risk governance and risk appetite. A
failure to adhere to this framework, or
any material weaknesses or deficiencies
in the framework’s controls and
procedures, could adversely affect
NatWest Group’s financial condition and
strategic delivery including in relation to
inaccurate adherence to agreed risk
appetite statements and accurate risk
reporting of risk exposures.
In addition, financial crime risk
management is dependent on the use
and effectiveness of financial crime
assessment, systems and controls. Weak
or ineffective financial crime processes
and controls may risk NatWest Group
inadvertently facilitating financial crime
which may result in regulatory
investigation, sanction, litigation, fines
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, manual processes and
controls, inaccurate data, inadequate IT
systems, unidentified conflicts or
misaligned incentives, lack of
accountability control and governance,
incomplete risk monitoring and
management or insufficient challenges or
assurance processes or a failure to
timely complete risk remediation
projects. Failure to manage risks
effectively, or within regulatory
expectations, could adversely affect
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 reflect
NatWest Group’s customer-focused
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, the
possibility of mis-selling of financial
products and mishandling of customer
complaints. Some of these risks have
materialised in the past and ineffective
management and oversight of conduct
risks may lead to further remediation
and regulatory intervention or
enforcement.
NatWest Group’s businesses are also
exposed to risks from employee
misconduct including non-compliance
with policies and regulations, negligence
or fraud (including financial crimes and
fraud), any of which could result in
regulatory fines or sanctions and serious
reputational or financial harm to
NatWest Group. Remote working
arrangements for NatWest Group
employees continues to place heavy
reliance on the IT systems that enable
remote working 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 caused to customers; and
ensure no increased risk of financial
crime.
NatWest Group has been seeking to
embed a strong risk culture across the
organisation and has implemented
policies and allocated new resources
across all levels of the organisation to
manage and mitigate conduct risk and
expects to continue to invest in risk
management, including the ongoing
development of a risk management
strategy in line with regulatory
expectations. However, such efforts may
not insulate NatWest Group from
instances of misconduct and no
assurance can be given that NatWest
Group’s strategy and control framework
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 subject
to inherent reputational risk.
Reputational risk relates to stakeholder
and public perceptions of NatWest Group
arising from an actual or perceived
failure to meet stakeholder or the
public’s expectations, including with
respect to NatWest Group’s purpose-led
strategy and related targets, the creation
of the Commercial & Institutional
business segment, the progression
towards working as One Bank across the
NatWest Group to serve customers, or
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 oversight,
which are constantly evolving and may
adversely affect NatWest Group.
This
includes harm to its brand, which may
be detrimental to NatWest Group’s
business, including its ability to build or
sustain business relationships with
customers, and may cause low employee
morale, regulatory censure or reduced
access to, or an increase in the cost of,
funding. Reputational risk may arise
whenever there is, or there is perceived
to be, 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 particular,
NatWest Group’s ability to attract and
retain customers (particularly,
corporate/institutional and retail
depositors) and engage with
counterparties may be adversely
affected by factors including: 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 cyberattacks, 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 factors.
Risk factors
continued
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Financial review
Modern technologies, in particular online
social networks and other broadcast
tools that facilitate communication with
large audiences in short timeframes and
with minimal costs, may also significantly
increase and accelerate the impact of
damaging information and allegations.
Although NatWest Group has
implemented a Reputational Risk Policy
to monitor the identification, assessment
and management of customers,
transactions, products and issues, which
represent a reputational risk, NatWest
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 are subject
to substantial regulation and oversight,
which are constantly evolving and may
adversely affect NatWest Group.
NatWest Group is subject to extensive
laws, regulations, guidelines, corporate
governance practice and disclosure
requirements, administrative actions and
policies in each jurisdiction in which it
operates, which represents ongoing
compliance and conduct risks. Many of
these have been introduced or amended
recently and are subject to further
material changes, which may increase
compliance and conduct risks,
particularly as EU/EEA and UK laws
diverge as a result of Brexit. NatWest
Group expects government and
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 manner in
which the business of financial services is
conducted. Measures have included:
enhanced capital, liquidity and funding
requirements, implementation of the UK
ring-fencing regime, implementation and
strengthening of the recovery and
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 requirements,
restrictions on the compensation of
senior management and other
employees, enhanced data protection
and IT resilience requirements, financial
market infrastructure reforms (including
enhanced data protection and IT
resilience requirements) enhanced
regulations in respect of the provision of
‘investment services and activities’, and
increased regulatory focus in certain
areas, including conduct, consumer
protection, competition and disputes
regimes, anti-money laundering, anti-
corruption, anti-bribery, anti-tax evasion,
payment systems, sanctions and anti-
terrorism laws and regulations.
In addition, there is significant oversight
by competition authorities of the
jurisdictions in which NatWest Group
operates. The competitive landscape for
banks and other financial institutions in
the UK, EU/EEA, Asia and the US is
rapidly changing. Recent regulatory and
legal changes have and may continue to
result in new market participants and
changed competitive dynamics in
certain key areas. Regulatory and
competition authorities, including the
CMA, are currently also looking at and
focusing more on how they can support
competition and innovation in digital
and other markets. Recent regulatory
changes, proposed (such as US
proposals to increase regulation around
cybersecurity) or future developments
and heightened levels 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 landscape, changes in other
regulatory requirements and increased
operating costs, and have impacted,
and will continue to impact, product
offerings and business models.
Other areas in which, and examples of
where, governmental policies, regulatory
and accounting changes, and increased
public and regulatory scrutiny could
have an adverse effect (some of which
could be material) on NatWest Group
include, but are not limited to, the
following:
general changes in government,
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 including from the
CMA, FCA and Payment Systems
Regulator (‘PSR’) for the protection
and resilience of, and competition
and innovation in, digital and other
markets, UK payment systems and
retail banking developments relating
to the UK initiative on Open Banking,
Open Finance and the European
directive on payment services;
the ongoing compliance by NatWest
Group with CMA’s Market Orders
including the Retail Banking Market
Order 2017 (the ‘Order’) and SME
Undertakings as well as the ongoing
consultation by the UK Government
to introduce penalties for breaches of
such requirements (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 Mastercard
card schemes;
increased risk of new class action
claims being brought against
NatWest Group in the Competition
Appeal Tribunal for breaches of
competition law;
new or increased regulations relating
to customer data protection as well
as IT controls and resilience, such as
the proposed UK Data Protection and
Digital Information Bill and in India,
the Digital Personal Data Protection
Bill;
the introduction of, and changes 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 tax;
increased regulatory focus on
customer protection (such as the
FCA’s Consumer Duty policy
statement and final rules and
guidance) in retail or other financial
markets;
the potential introduction by the
Bank of England of a Central Bank
Digital Currency which could result in
deposit outflows, higher funding
costs, and/or other implications for
UK banks including NatWest Group;
and
regulatory enforcement in the form
of PRA imposed financial penalties
for failings in banks’ regulatory
reporting governance and controls,
and regulatory scrutiny following the
2019 PRA ‘Dear CEO letter’
regarding PRA’s ongoing focus on:
the integrity of regulatory reporting,
which the PRA considers has equal
standing with financial reporting; the
PRA’s thematic reviews of the
governance, controls and processes
for preparing regulatory returns of
selected UK banks, including NatWest
Group; the publication of the PRA’s
common findings from those reviews
in September 2021; and NatWest
Group’s programme of improvements
to meet PRA expectations.
Risk factors
continued
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These and other recent regulatory
changes, proposed or future
developments and heightened levels 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
landscape, changes in other regulatory
requirements and increased operating
costs, and have impacted, and will
continue to impact, competitive position,
product offerings and business models.
Future competition investigations, market
reviews, or the regulation of mergers
may lead to the imposition of financial
penalties or market remedies that may
adversely affect 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 Group may
offer, its reputation and the value of its
assets, NatWest Group’s operations or
legal entity structure, and the manner in
which NatWest Group conducts its
business. Material consequences could
arise should NatWest Group be found to
be non-compliant with these regulatory
requirements. Regulatory developments
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 timeframes 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 such
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 affect
NatWest Group’s ability to engage in
effective business, capital and risk
management planning.
NatWest Group is exposed to the risks of
various litigation matters, regulatory and
governmental actions and investigations
as well as remedial undertakings,
including conduct-related reviews, anti-
money laundering and redress projects,
the outcomes of which are inherently
difficult to predict, and which could have
an adverse effect on NatWest Group.
NatWest Group’s operations are diverse
and complex and it operates in legal and
regulatory environments that expose it to
potentially significant civil actions
(including those following on from
regulatory sanction), as well as criminal,
regulatory and governmental
proceedings. NatWest Group has
resolved a number of legal and
regulatory actions over the past several
years but continues to be, and may in
the future be, involved in such actions in
the US, the UK, Europe and other
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, including in relation to 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 issues. Legal
and regulatory actions are subject to
many uncertainties, and their outcomes,
including the timing, amount of fines,
damages or settlements or the form of
any settlements, which may be material
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: NWM Plc’s
December 2021 spoofing-related 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. For additional information
relating to this and other legal and
regulatory proceedings and matters to
which NatWest Group is currently
exposed, see ‘
Litigation and regulatory
matters
’ at Note 26 to the consolidated
accounts.
The 2021 guilty plea, other recently
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 consequences
resulting from the need to reapply for
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 and implications 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 failure to
obtain such licences or waivers could
adversely affect NatWest Group’s
business, in particular in the US. This in
turn and/or any fines, settlement
payments or penalties may adversely
affect NatWest Group’s reputation, future
results, financial condition and/or
prospects.
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 measures
or penalties being taken against NatWest
Group. In addition, any failure to
administer conduct redress processes
adequately, or to handle individual
complaints fairly or appropriately, could
result in further claims as well as the
imposition of additional measures 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 replacement risk-
free rates.
UK and international regulators are
driving the transition from the use of
interbank offer rates (‘IBORs’), to
replacement rates generally referred to
as ‘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 used its
powers under the UK Benchmarks
Regulation (‘UK BMR’) to require, for a
limited period of time after 31 December
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)
Risk factors
continued
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Annual Report and Accounts 2022
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Strategic report
Governance
Risk and capital management
Additional information
Financial review
Act 2021 (‘Critical Benchmarks Act’)
which establishes a framework that
allows the ongoing use of Art23A LIBOR
under certain circumstances where
contracts have not pro-actively
transitioned onto the replacement rates.
These concessions provided under UK
BMR and the Critical Benchmarks Act
are temporary. The FCA confirmed that
Art23A will no longer be available from:
(i) the end of 2022 for JPY, (ii) March
2023 for 1- and 6-month GBP LIBOR and
(iii) March 2024 for 3-month GBP LIBOR.
The transition away from these
temporary concessions 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
exposures are permitted to make use of
Art23A LIBOR. Although the formal
cessation date for the remaining USD
LIBOR tenors (as currently determined) is
not until the end of June 2023, US and
UK regulators have clarified that this is
only to support the rundown of existing
USD LIBOR exposures. 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 exposure to
the remaining USD LIBOR tenors until
cessation in June 2023.
NatWest Group has held significant
exposures to various IBORs and has
actively sought to transition away from
these during 2021 and 2022 in
accordance with regulatory expectations
and milestones. Transition measures
have included the pro-active
development of new products using the
replacement rates, restructuring existing
LIBOR exposures to reference these
replacement rates and embedding RFR
transition language into relevant
contracts. Central Counterparty Clearing
houses (CCPs) conducted mass
conversion exercises in December 2021
covering GBP, JPY, CHF and EUR LIBOR,
transitioning derivatives to the relevant
RFR, conversion exercises for USD are
scheduled for May 2023. NWG entities,
along with many of their major
counterparties, have adhered to the
ISDA IBOR fall-backs protocol which
establishes a contractual process to
transition from IBORs to RFRs for
bilateral derivative products.
These transition efforts have involved
extensive engagement with customers,
industry working groups and regulators
to seek to deliver transition in a
transparent and economically
appropriate manner. These changes
coincide with the recognition that market
liquidity is lower than it has been and
whilst it will be inherently difficult to
disaggregate the different impacts from
each other it may be that similar levels
of market liquidity are not reached for
these RFR products, clear and consistent
market conventions for all replacement
products may not be implemented or
they may not be accepted by market
participants including NatWest Group
counterparties. Where there remains an
uncertainty around the manner of
transition to RFRs, NatWest Group,
clients and the financial services industry
are exposed to the related risks.
Examples of these risks include (i) legal
(including litigation) risks relating to
documentation for new and the majority
of existing transactions (including,
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 relevant IBORs,
including cost of funds and relevant risk
management related financial models;
(iii) changes to benchmark rates could
impact pricing, interest rate or
settlement mechanisms for certain
instruments; (iv) operational risks linked
to the adaptation of IT systems, trade
reporting infrastructure and operational
processes, as well as ensuring
compliance with restrictions on new USD
LIBOR usage after December 2021; (v)
conduct risks arising from
communication of the potential impact
on customers, engagement with
customers during and after the transition
period, or non-acceptance by customers
of replacement rates; 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 potential
liability arising out of the switch to
‘synthetic LIBOR’.
Although the majority of NWG’s IBOR
exposure has already been transitioned
to RFRs, there remains a large
population linked to USD LIBOR,
scheduled for transition by June 2023.
Until IBOR transition is complete there is
some uncertainty as to the impact of the
transition, or the potential costs of
implementing any relevant remedial
action including in the event that the
transition is not completed in a timely
manner, or at all. The implementation of
any alternative RFRs may be impossible
or impracticable under the existing terms
of certain financial instruments and may
adversely affect their value or return and
therefore on NatWest Group’s future
results.
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 sources of estimation
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 deferred 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 changes 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 £2,178 million as at
31 December 2022. 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 differ
materially from the amounts provided
depending on the ultimate resolution of
such matters.
Material contracts
NatWest Group
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Additional information
Financial review
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 Capital
Agreement pursuant to which HM
Treasury subscribed for the initial B
shares and the Dividend Access 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 cancel the
Contingent Subscription as a result of
the actions announced in the second 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), and to
trading on the London Stock Exchange
plc, on 14 October 2015. Following such
conversion, HM Treasury no longer 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 reimburse 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 its
affiliates do not so vote
Directed Buyback Contract
On 7 February 2019, the company 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 excess
capital to buy back the company’s
ordinary shares held by HM Treasury.
Under the terms of the Directed 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 conjunction
with any offer or sale by HM Treasury 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 issued
share capital and the aggregate
consideration to be paid will not exceed
4.99%. of the company’s market
capitalisation. The price to be paid for
each ordinary share will be the market
price at the time of purchase or, if the
directed buyback is in conjunction with
an institutional placing, the placing price.
To date, the company has made two
separate off-market purchases under the
Directed Buyback Contract. One
purchase took place in 2021, and
another took place in 2022.
On 19 March 2021, the company
announced that it had agreed with HM
Treasury to make an off-market
purchase under the Directed Buyback
Contract for the total consideration of
£1,125,341,269 for 590,730,325 ordinary
shares representing 4.86% of the
company’s issued share capital at that
point in time.
The following year, on 28 March 2022,
the company announced an additional
off-market purchase of 549,851,147
ordinary shares for the total
consideration of £1,212,421,779. The
purchased ordinary shares represented
4.91% of the company’s issued share
capital at the time (excluding treasury
shares). This took HM Treasury's
ownership in the company below 50% for
the first time since 2008.
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 European
Commission (EC), which was then
approved by the EC under the State Aid
rules on 14 December 2009. The
company agreed a series of measures
which supplemented the measures in the
company’s strategic plan.
The company entered into a State 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 2017, the
revised State Aid Commitment Deed was
amended by a Deed of Variation (as so
amended, the “Revised State Aid
Commitment Deed”) following the EC’s
approval of an alternative remedies
package (the “Alternative Remedies
Package”) to replace the company’s final
outstanding commitment under its State
Aid obligations (to divest the business
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 delivery of the
Alternative Remedies Package (the
“Independent Body”). Under the
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 obligations under
any EC decision approving State Aid 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 banking
services to small and medium-sized
enterprises (“SMEs”) and develop 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”).
Material contracts
continued
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Annual Report and Accounts 2022
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Governance
Risk and capital management
Additional information
Financial review
The company has also agreed to set
aside up to a further £75 million in
funding to cover certain costs customers
may incur as a result of switching under
the Incentivised Switching Scheme. In
addition, under the terms of the
Alternative Remedies Package, should
the uptake within the Incentivised
Switching Scheme not be sufficient, 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 liabilities that
may be incurred in implementing 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.
The Framework and State Aid Deed also
provides that if the EC adopts a decision
that the UK Government must recover
any State Aid (a "Repayment Decision")
and the recovery order of the
Repayment Decision has not been
annulled or suspended by the General
Court or the European Court of Justice,
then the company must repay HM
Treasury any aid ordered to be
recovered under the Repayment
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, pursuant 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 committed 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 put in place
an agreement with any controlling
shareholder (as defined for these
purposes in the Listing Rules). The
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 associates 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 associates will
propose or procure the proposal 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 The
Royal Bank of Scotland Group Pension
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-fencing
legislation and acceleration of the
settlement framework for the 31
December
2017 triennial valuation of the
Main Section
of the Group Fund (brought
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 billion 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 £500
million before tax).
Framework Agreement Relating to the
NatWest Group Pension Fund
On 28 September 2018 the company
entered into a framework agreement
(the
“Framework Agreement”) with the
trustee (“Trustee”) of the NatWest Group
Pension Fund (the
“Group Fund”).
Amongst others, the Framework
Agreement set out the 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 billion in
aggregate linked to the making of future
distributions to NatWest Group
shareholders including ordinary and
special dividends and/or share buy backs
(subject to an annual cap on
contributions of
£471 million before tax).
Pursuant to funding requirements in the
Framework Agreement, the company
made contributions to the Main Section
of the Group Fund in an aggregate
amount of £500m in 2021 and £500m in
2022.
On 6 February 2023, the company and
the Trustee entered into an amendment
to the Framework Agreement, a
supplemental framework agreement and
a revised Schedule of Contributions to,
among others, restructure the
requirement to make a distribution-linked
contribution to the Main Section of the
Group Fund of up to £500 million (before
tax) in 2023. In place of this requirement,
the company and the Trustee agreed to
establish a bankruptcy remote reservoir
trust to hold assets with a value
equivalent to £471 million under the
continuing control of the company.
These assets would become
transferrable to the Main Section of the
Group Fund in the event that specified
payment triggers, reflecting a funding
requirement, were met in two
consecutive financial years.
Additional
information
In this section
430
Financial calendar
430
Shareholder enquiries
431
Analysis of ordinary shareholders
432
Important addresses
432
Principal offices
433
Presentation of information
434
Forward-looking statements
NatWest Group
| 2022 Annual Report and Accounts
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429
NatWest Group
| 2022 Annual Report and Accounts
STRATEGIC REPORT
FINANCIAL REVIEW
GOVERNANCE
RISK AND CAPITAL MANAGEMENT
FINANCIAL STATEMENTS
ADDITIONAL INFORMATION
Shareholder information
NatWest Group
Annual Report and Accounts 2022
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Governance
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Additional information
Financial review
Financial calendar
Dividends
Payment dates
Cumulative
preference
shares
31 May and 29 December 2023
Ordinary shares (2022 final)
2 May 2023
Ex-dividend dates
Cumulative preference
shares
4 May and 30 November 2023
Ordinary shares (2022 final)
16 March 2023
Record dates
Cumulative preference
shares
5 May and 1 December 2023
Ordinary shares (2022 final)
17 March 2023
Annual General Meeting
25 April 2023
Interim results
28 July 2023
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 your shareholding
online’ tab. You will need the shareholder reference number
printed on your share certificate or dividend confirmation
statement to access this information. You can also view any
outstanding payments, update bank account and address
details and download various forms.
NatWest Group is committed to reducing its impact on the
environment. You can choose to receive your shareholder
communications electronically via the ‘Sign up for e-comms’
tab and you will receive an email notification when documents
become available to view on our website.
You can also check your shareholding by contacting our
Registrar:
Computershare Investor Services PLC
The Pavilions
Bridgwater Road
Bristol BS99 6ZZ
Telephone: +44 (0)370 702 0135
Website: www-uk.computershare.com/investor
Braille and audio Strategic report with additional
information
Shareholders requiring a Braille or audio version of the
Strategic report with additional information should contact the
Registrar on +44 (0)370 702 0135.
ShareGift
The company is aware that shareholders who hold a small
number of shares may be retaining these shares because
dealing costs make it uneconomical to dispose of them.
ShareGift is a free charity share donation service operated by
The Orr Mackintosh Foundation (registered charity 1052686) to
enable shareholders to donate shares 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 for UK capital gains tax
purposes. You may be able to claim UK income tax relief on
gifted shares and can do so in various ways. Further
information can be obtained from HM Revenue & Customs.
Should you wish to donate your shares to charity please
contact ShareGift for further information:
ShareGift, The Orr Mackintosh Foundation, 4th Floor, 67/68
Jermyn Street, London SW1Y 6NY, Telephone: +44 (0)20 7930
3737, Website:
www.sharegift.org
Share and bond scams
Share and bond scams are often run from ‘boiler rooms’ where
fraudsters cold-call investors, offering them worthless,
overpriced or even non-existent shares or bonds. They use
increasingly sophisticated tactics to approach investors,
offering to buy or sell shares, often pressuring investors to
make a quick decision or miss out on the deal. Contact can also
be in the form of email, post or word of mouth. Scams are
sometimes advertised in newspapers, magazines or online as
genuine investment opportunities and may offer free gifts or
discounts on dealing charges.
Scammers will request money upfront, as a bond or other form
of security, but victims are often 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 number (FRN)
and address of a firm or individual who is FCA authorised. The
scammer may claim that the genuine firm's contact details on
the FCA Register (Register) are out of date and then use their
own details, or copy the website of an authorised firm, making
subtle changes such as the phone number. They may claim to
be an overseas firm, which won’t always have full contact and
website details listed on the Register.
Shareholder information
continued
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Governance
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Additional information
Financial review
How to protect yourself
Always be wary if you’re contacted out of the blue, pressured
to invest quickly, or promised returns that sound too good to be
true. FCA authorised firms are unlikely to contact you
unexpectedly with an offer to buy or sell shares or bonds.
Please do not give any personal details to any caller unless you
are certain that they are genuine. Check the Register to ensure
the firm contacting you is authorised and also check the FCA’s
Warning List of firms to avoid at www.fca.org.uk/scamsmart.
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.
It is strongly advised that you seek independent professional
advice before making any investment.
Report a scam
If you suspect that you have been approached by fraudsters, or
have any concerns about a potential scam, report this to the
FCA by contacting their Consumer Helpline on 0800 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 other criminals. The
follow-up scam may be completely separate, or may be related
to the previous scam in the form of an offer to get your money
back or buy back the investment on payment of a fee.
Find out more at www.fca.org.uk/consumers
Analysis of ordinary shareholders
Number
At 31 December 2022
Shareholdings
of shares
%
Individuals
166,331
87,164,537
0.89
Banks and nominee companies
1,729
5,183,949,912
52.97
Investment trusts
40
322,237
0.00
Insurance companies
2
2,136
0.00
Other companies
410
49,571,824
0.51
Pension trusts
18
30,765
0.00
Other corporate bodies
69
4,464,982,512
45.63
168,599
9,786,023,923
100.00
Range of shareholdings:
1 - 1,000
147,409
34,325,117
0.35
1,001 - 10,000
19,376
43,758,796
0.45
10,001 - 100,000
885
27,914,542
0.29
100,001 - 1,000,000
537
202,449,763
2.07
1,000,001 - 10,000,000
303
998,301,789
10.20
10,000,001 and over
89
8,479,273,916
86.64
168,599
9,786,023,923
100.00
Shareholder information
continued
NatWest Group
Annual Report and Accounts 2022
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Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Important addresses
Shareholder enquiries
Registrar
Computershare Investor Services PLC
The Pavilions
Bridgwater Road
Bristol BS99 6ZZ
Telephone: +44 (0)370 702 0135
Website: www-uk.computershare.com/investor
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
Telephone: 1-888-269-2377 (US callers – toll free)
Telephone: +1 201 680 6825 (International)
Email: shrrelations@cpushareownerservices.com
Website: www.mybnymdr.com
Corporate, Governance
NatWest Group plc
PO Box 1000, Gogarburn
Edinburgh, EH12 1HQ
Telephone: 0131 556 8555
Investor Relations
250 Bishopsgate, London
EC2M 4AA, England
Telephone: +44 (0)131 556 8555
Email: investor.relations@natwest.com
Registered office
36 St Andrew Square
Edinburgh, EH2 2YB
Telephone: 0131 556 8555
Registered in Scotland No. SC45551
Website
www.natwestgroup.com
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, Belfast, 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 Street
St Helier, JE4 8PJ
Presentation of information
NatWest Group
Annual Report and Accounts 2022
433
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 Group plc, and ‘NatWest
Group’, ‘Group’ or ‘we’ refers to NatWest Group plc and its subsidiaries. The term ‘NWH Group’ refers to NatWest Holdings Limited
(‘NWH’) and its subsidiary and associated undertakings. The term ‘NWM Group’ refers to NatWest Markets Plc (‘NWM Plc’) and its
subsidiary and associated undertakings. The term ‘NWM N.V.’ refers to NatWest Markets N.V. The term ‘NWMSI’ refers to NatWest
Markets Securities, Inc. The term ‘RBS plc’ refers to The Royal Bank of Scotland plc. The term ‘NWB Plc’ refers to National
Westminster Bank Plc. The term ‘UBIDAC’ refers to Ulster Bank Ireland DAC. The term ‘RBSI Limited’ refers to The Royal Bank of
Scotland International Limited. ‘Go-forward group’ excludes Ulster Bank RoI and discontinued operations.
NatWest Group publishes its financial statements in pounds sterling (‘£’ or ‘sterling’). The abbreviations ‘£m’ and ‘£bn’ represent
millions and thousands of millions of pounds sterling (‘GBP’), respectively, and references to ‘pence’ represent pence where
amounts are denominated in pounds sterling. Reference to ‘dollars’ or ‘$’ are to United States of America (‘US’) dollars. The
abbreviations ‘$m’ and ‘$bn’ represent millions and thousands of millions of dollars, respectively. The abbreviation ‘€’ represents
the ‘euro’, and the abbreviations ‘€m’ and ‘€bn’ represent millions and thousands of millions of euros, respectively.
Forward looking statements
Cautionary statement regarding forward-looking statements
Certain sections in this document contain ‘forward-looking statements’ as that term is defined in the United States Private
Securities Litigation Reform Act of 1995, such as statements that include the words ‘expect’, ‘estimate’, ‘project’, ‘anticipate’,
‘commit’, ‘believe’, ‘should’, ‘intend’, ‘will’, ‘plan’, ‘could’, ‘probability’, ‘risk’, ‘Value-at-Risk (VaR)’, ‘target’, ‘goal’, ‘objective’, ‘may’,
‘endeavour’, ‘outlook’, ‘optimistic’, ‘prospects’ and similar expressions or variations on these expressions. In particular, this
document includes forward-looking targets and guidance relating to financial performance measures, such as income growth,
operating expense, RoTE, ROE, discretionary capital distribution targets, impairment loss rates, balance sheet reduction, including
the reduction of RWAs, CET1 ratio (and key drivers of the CET1 ratio including timing, impact and details), Pillar 2 and other
regulatory buffer requirements and MREL and non-financial performance measures, such as NatWest Group’s initial area of focus,
climate and ESG-related performance ambitions, targets and metrics, including in relation to initiatives to transition to a net zero
economy, Climate and Sustainable Funding and Financing (CSFF) and financed emissions. In addition, this document includes
forward-looking statements relating, but not limited to: implementation of NatWest Group’s purpose-led strategy and other
strategic priorities (including in relation to: phased withdrawal from ROI, cost-controlling measures, the NatWest Markets
refocusing, the creation of the Commercial & Institutional business segment and the progression towards working as One Bank
across NatWest Group to serve customers); the timing and outcome of litigation and government and regulatory investigations;
direct and on-market buy-backs; funding plans and credit risk profile; managing its capital position; liquidity ratio; portfolios; net
interest margin and drivers related thereto; lending and income growth, product share and growth in target segments;
impairments and write-downs; restructuring and remediation costs and charges; NatWest Group’s exposure to political risk,
economic assumptions and risk, climate, environmental and sustainability risk, operational risk, conduct risk, financial crime risk,
cyber, data and IT risk and credit rating risk and to various types of market risk, including interest rate risk, foreign exchange rate
risk and commodity and equity price risk; customer experience, including our Net Promotor Score (NPS); employee engagement
and gender balance in leadership positions.
Limitations inherent to forward-looking statements
These statements are based on current plans, expectations, estimates, targets and projections, and are subject to significant
inherent risks, uncertainties and other factors, both external and relating to NatWest Group’s strategy or operations, which may
result in NatWest Group being unable to achieve the current plans, expectations, estimates, targets, projections and other
anticipated outcomes expressed or implied by such forward-looking statements. In addition, certain of these disclosures are
dependent on choices relying on key model characteristics and assumptions and are subject to various limitations, including
assumptions and estimates made by management. By their nature, certain of these disclosures are only estimates and, as a result,
actual future results, gains or losses could differ materially from those that have been estimated. Accordingly, undue reliance
should not be placed on these statements. The forward-looking statements contained in this document speak only as of the date
we make them and we expressly disclaim any obligation or undertaking to update or revise any forward-looking statements
contained herein, whether to reflect any change in our expectations with regard thereto, any change in events, conditions or
circumstances on which any such statement is based, or otherwise, except to the extent legally required.
Financial statements
Strategic report
Governance
Risk and capital management
Additional information
Financial review
Forward looking statements
continued
NatWest Group
Annual Report and Accounts 2022
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Strategic report
Governance
Risk and capital management
Additional information
Financial review
Important factors that could affect the actual outcome of the forward-looking statements
We caution you that a large number of important factors could adversely affect our results or our ability to implement our strategy,
cause us to fail to meet our targets, predictions, expectations and other anticipated outcomes or affect the accuracy of forward-
looking statements described in this document. These factors include, but are not limited to, those set forth in the risk factors and
the other uncertainties described in NatWest Group plc’s Annual Report on Form 20-F and its other filings with the US Securities
and Exchange Commission. The principal risks and uncertainties that could adversely NatWest Group’s future results, its financial
condition and/or prospects and cause them to be materially different from what is forecast or expected, include, but are not limited
to: economic and political risk (including in respect of: political and economic risks and uncertainty in the UK and global markets,
including due to high inflation, supply chain disruption and the Russian invasion of Ukraine); uncertainty regarding the effects of
Brexit; changes in interest rates and foreign currency exchange rates; and HM Treasury’s ownership as the largest shareholder of
NatWest Group plc); strategic risk (including in respect of the implementation of NatWest Group’s purpose-led Strategy; future
acquisitions and divestments; phased withdrawal from ROI and the transfer of its Western European corporate portfolio); financial
resilience risk (including in respect of: NatWest Group’s ability to meet targets and to make discretionary capital distributions; the
competitive environment; counterparty and borrower risk; prudential regulatory requirements for capital and MREL; liquidity and
funding risks; changes in the credit ratings; the requirements of regulatory stress tests; model risk; sensitivity to accounting policies,
judgments, assumptions and estimates; changes in applicable accounting standards; the value or effectiveness of credit protection;
the adequacy of NatWest Group’s future assessments by the Prudential Regulation Authority and the Bank of England; and the
application of UK statutory stabilisation or resolution powers); climate and sustainability risk (including in respect of: risks relating
to climate change and the transitioning to a net zero economy; the implementation of NatWest Group’s climate change strategy,
including publication of an initial climate transition plan in 2023 and climate change resilient systems, controls and procedures;
climate-related data and model risk; the failure to adapt to emerging climate, environmental and sustainability risks and
opportunities; changes in ESG ratings; increasing levels of climate, environmental and sustainability related regulation and
oversight; and climate, environmental and sustainability-related litigation, enforcement proceedings and investigations); operational
and IT resilience risk (including in respect of: operational risks (including reliance on third party suppliers); cyberattacks; the
accuracy and effective use of data; complex IT systems; attracting, retaining and developing senior management and skilled
personnel; NatWest Group’s risk management framework; and reputational risk); and legal, regulatory and conduct risk (including
in respect of: the impact of substantial regulation and oversight; compliance with regulatory requirements; the outcome of legal,
regulatory and governmental actions and investigations; the transition of LIBOR other IBOR rates to replacement risk-free rates;
and changes in tax legislation or failure to generate future taxable profits).
Climate and ESG disclosures
Climate and ESG disclosures in this document are not measures within the scope of International Financial Reporting Standards
(‘IFRS’), use a greater number and level of judgements, assumptions and estimates, including with respect to the classification of
climate and sustainable funding and financing activities, than our reporting of historical financial information in accordance with
IFRS. These judgements, assumptions and estimates are highly likely to change over time, and, when coupled with the longer time
frames used in these disclosures, make any assessment of materiality inherently uncertain. In addition, our climate risk analysis, net
zero strategy, including the implementation of our climate transition plan remain under development, and the data underlying our
analysis and strategy remain subject to evolution over time. The process we have adopted to define, gather and report data on our
performance on climate and ESG measures is not subject to the formal processes adopted for financial reporting in accordance
with IFRS and there are currently limited industry standards or globally recognised established practices for measuring and
defining climate and ESG related metrics. As a result, we expect that certain climate and ESG disclosures made in this document
are likely to be amended, updated, recalculated or restated in the future. Please also refer to the cautionary statement in the
section entitled ‘Climate-related and other forward-looking statements and metrics’ of the NatWest Group 2022 Climate-related
Disclosures Report.
Cautionary statement regarding Non-IFRS financial measures and APMs
NatWest Group prepares its financial statements in accordance with generally accepted accounting principles (GAAP). This
document may contain financial measures and ratios not specifically defined under GAAP or IFRS (‘Non-IFRS’) and/or alternative
performance measures (‘APMs’) as defined in European Securities and Markets Authority (‘ESMA’) guidelines. APMs are adjusted
for notable and other defined items which management believes are not representative of the underlying performance of the
business and which distort period-on-period comparison. Non-IFRS measures provide users of the financial statements with a
consistent basis for comparing business performance between financial periods and information on elements of performance that
are one-off in nature. Any Non-IFRS measures and/or APMs included in this document, are not measures within the scope of IFRS,
are based on a number of assumptions that are subject to uncertainties and change, and are not a substitute for IFRS measures.
The information, statements and opinions contained in this document do not constitute a public offer under any applicable
legislation or an offer to sell or a solicitation of an offer to buy any securities or financial instruments or any advice or
recommendation with respect to such securities or other financial instruments.