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HSBC Bank plc
Annual Report and Accounts 2021
Registered number - 00014259
Contents
Page
Strategic Report
Highlights
Key themes of 2021
Key financial metrics
About HSBC Group
Purpose and strategy
Our Global Businesses
How we do business
Key Performance Indicators
Economic background and outlook
Financial summary
Risk overview
Report of the Directors
Risk
–  Our approach to risk
–  Top and emerging risks
–  Areas of special interest
–  Our material banking and insurance risks
Corporate Governance Report
–  Directors
–  Company Secretary
–  Board of Directors
–  Directors‘ emoluments
–  Board committees
–  Dividends
–  Internal control
93
–  Employees
–  Auditors
–  Articles of association, conflicts of interest and indemnification of
directors
–  Statement on going concern
–  Statement of directors' responsibilities in respect of the financial
statements
Independent Auditors’ Report
Financial Statements
Financial statements
107
Notes on the financial statements
118
Presentation of Information
This document comprises the Annual Report and Accounts 2021
for HSBC Bank plc (‘the bank’ or 'the company') and its
subsidiaries (together ‘the group’). ’We’, ‘us’ and ‘our’ refer to
HSBC Bank plc together with its subsidiaries. It contains the
Strategic Report, the Report of the Directors, the Statement of
Directors’ Responsibilities and Financial Statements, together with
the Independent Auditors’ Report, as required by the UK
Companies Act 2006. References to ‘HSBC’, 'HSBC Group' or
‘Group’ within this document mean HSBC Holdings plc together
with its subsidiaries.
HSBC Bank plc is exempt from publishing information required by
The Capital Requirements Country-by-Country Reporting
Regulations 2013, as this information is published by its parent,
HSBC Holdings plc. This information is available on HSBC’s
website: www.hsbc.com.
Pillar 3 disclosures for the group are also available on
www.hsbc.com, under Investors.
All narrative disclosures, tables and graphs within the Strategic
Report and Report of the Directors are unaudited unless otherwise
stated.
Our reporting currency is £ sterling.
Unless otherwise specified, all $ symbols represent US dollars.
Cautionary Statement Regarding Forward-
Looking Statements
This Annual Report and Accounts 2021 contains certain forward-
looking statements with respect to the financial condition, results
of operations and business of the group.
Statements that are not historical facts, including statements
about the group’s beliefs and expectations, are forward-looking
statements. Words such as ‘expects’, ‘anticipates’, ‘intends’,
‘plans’, ‘believes’, ‘seeks’, ‘estimates’, ‘potential’ and ‘reasonably
possible’, variations of these words and similar expressions are
intended to identify forward-looking statements. These statements
are based on current plans, estimates and projections, and
therefore undue reliance should not be placed on them. Forward-
looking statements speak only as of the date they are made. HSBC
Bank plc makes no commitment to revise or update any forward-
looking statements to reflect events or circumstances occurring or
existing after the date of any forward-looking statement.
Forward-looking statements involve inherent risks and
uncertainties. Readers are cautioned that a number of factors
could cause actual results to differ, in some instances materially,
from those anticipated or implied in any forward-looking
statement.
HSBC Bank plc Annual Report and Accounts 2021
1
Highlights
For the year ended 31 December 2021
Reported profit/(loss) before tax (£m)
£1,023m
(2020: £(1,614)m)
Reported revenue (£m)
£6,120m
(2020: £5,900m)
Reported risk-weighted assets at period end (£bn)
£104bn
(2020: £122bn)
.
Adjusted profit/(loss) before tax (£m)
£1,577m
(2020: £(184)m)
Total assets at period end (£bn)
£597bn
(2020: £681bn)
Common equity tier 1 ratio at period end (%)
17.3%
(2020: 14.7%)
Strategic Report | Highlights
2
HSBC Bank plc Annual Report and Accounts 2021
Key themes of 2021
HSBC Bank plc continued to support the Group through progress
on our strategic aims, although challenges in the geopolitical and
economic environment remain.
Financial Performance
Performance reflected an improvement in global economic
conditions and the impact of lower interest rates. Revenue
increased, there were releases of expected credit loss allowances,
and operating expenses were lower reflecting the impact of our
transformation programme. All of our global businesses generated
higher profits compared with 2020. The outlook for net interest
income is now more positive, although risks remain as inflation is
anticipated to increase across Europe. Read more on pages 13 to
18.
Strategic Transformation
We have continued to progress in our areas of strength and
develop our digital capabilities. During the year we announced the
planned sale of our retail banking business in France. We have
formulated our response to the requirement for an Intermediate
Parent Undertaking (‘IPU’) in line with European Union ('EU')
Capital Requirements Directive, as a result of which our subsidiary
HSBC Continental Europe plans to acquire HSBC Trinkaus &
Burkhardt AG (‘HSBC Germany’), HSBC Malta and HSBC Private
Bank Luxembourg. More information can be found on pages 4 and
5.
Climate Ambition
As demonstrated at COP26, the Group is playing a leading role in
helping to mobilise the transition to a global net zero economy.
Since 2020, HSBC Bank plc has supported our customers’
transition to net zero and a sustainable future by providing them
with $65.2bn of financing and investment; this contributes
towards the Group's ambition to provide and facilitate $750bn to
$1tn of sustainable financing and investment by 2030. In May
2021, a climate change resolution proposed by the Group's Board
was backed by more than 99% of the Group’s shareholders at its
Annual General Meeting, including a commitment to publish a
policy to phase out the financing of coal-fired power and thermal
coal mining, by 2030 in the European Union ('EU') / Organisation
for Economic Cooperation and Development ('OECD'), and 2040 in
all other markets. We are also working with peers and industry
bodies to take action on climate change, biodiversity and nature.
Key financial metrics
2021
            2020
For the year (£m)
Profit/(loss) before tax (reported basis)
1,023
(1,614)
Profit/(loss) before tax (adjusted basis)1
1,577
(184)
Net operating income before change in expected credit losses and other credit impairment charges (reported basis)2
6,120
5,900
Profit/(loss) attributable to the parent company
1,041
(1,488)
At year-end (£m)
Total equity attributable to shareholders of the parent company
23,584
23,666
Total assets
596,611
681,150
Risk-weighted assets3
104,314
122,392
Loans and advances to customers (net of impairment allowances)
91,177
101,491
Customer accounts
205,241
195,184
Capital ratios (%)3
Common equity tier 1
17.3
14.7
Tier 1
21.0
18.1
Total capital
31.7
27.3
Performance, efficiency and other ratios (annualised %)
Return on average ordinary shareholders’ equity4
4.3
(7.9)
Return on tangible equity (%)5
6.1
(2.7)
Cost efficiency ratio (reported basis)6
89.2
113.6
Cost efficiency ratio (adjusted basis)6
80.9
89.6
Ratio of customer advances to customer accounts
44.4
52.0
1Adjusted performance is computed by adjusting reported results for the effect of significant items as detailed on pages 15 to 16.
2Net operating income before change in expected credit losses and other credit impairment charges is also referred to as revenue.
3Unless otherwise stated, regulatory capital ratios and requirements are based on the transitional arrangements of the Capital Requirements
Regulation in force at the time. These include the regulatory transitional arrangements for IFRS 9 'Financial Instruments', which are explained
further on page 73. References to EU regulations and directives (including technical standards) should, as applicable, be read as references to the
UK's version of such regulation and/or directive, as onshored into UK law under the European Union (Withdrawal) Act 2018, and as may be
subsequently amended under UK law.
4The return on average ordinary shareholders’ equity is defined as profit attributable to shareholders of the parent company divided by the average
total shareholders’ equity.
5The RoTE is calculated by adjusting reported profit attributable to ordinary shareholders by excluding movements in PVIF and significant items (net
of tax), divided by average tangible shareholders' equity excluding fair value of own debt, debt valuation adjustment (‘DVA’) and other
adjustments for the period. The calculation of this measure includes the UK bank levy incurred for the first time in 2021, which was previously paid
by Group. Comparative data have not been re-presented.
6Reported cost efficiency ratio is defined as total operating expenses (reported) divided by net operating income before change in expected credit
losses and other credit impairment charges (reported), while adjusted cost efficiency ratio is defined as total operating expenses (adjusted) divided
by net operating income before change in expected credit losses and other credit impairment charges (adjusted).
HSBC Bank plc Annual Report and Accounts 2021
3
About HSBC Group
With assets of $3.0tn and operations in 64 countries and territories
at 31 December 2021, HSBC is one of the largest banking and
financial services organisations in the world. Approximately 40
million customers bank with the Group and the Group employs
around 220,000 full-time equivalent staff. The Group has around
187,000 shareholders in 128 countries and territories.
Purpose and strategy
HSBC's purpose and ambition
The Group's purpose is ‘Opening up a world of opportunity’ and
the Group's ambition is to be the preferred international finance
partner for the Group's clients.
HSBC values
HSBC values help define who we are as an organisation and are
key to our long-term success.
We value difference
Seeking out different perspectives.
We succeed together
Collaborating across boundaries.
We take responsibility
Holding ourselves accountable and taking the long view.
We get it done
Moving at pace and making things happen.
HSBC Group strategy
The Group is implementing its strategy at pace across the four
strategic pillars aligned to its purpose, values and ambition
announced in February 2021.
The Group's strategy centres on four key areas: focus on our areas
of strength, digitise at scale to adapt our operating model for the
future; energise our organisation for growth and lead the transition
to net zero.
Focus on our strengths: in each of our global businesses, the
Group will focus on areas where we are strongest and have
significant opportunities for growth.
Digitise at scale: the Group will focus investments in areas such
as technology, to improve our customers’ experience while
ensuring security and resilience. These investments in technology
will also help drive down costs, including through automating our
middle and back offices and building solutions to free up office
footprint.
Energise for growth: the Group is moving to a leaner and
simpler organisation that is energised and fit for the future. The
Group aim to inspire a dynamic culture and champion inclusion
across the organisation, as well as help employees develop future
skills.
Transition to net zero: the Group ambition is to support the
transition to a net zero global economy. The Group have set out an
ambitious plan to become a net zero bank, to support customers
in their transition, and to unlock new climate solutions.
HSBC in Europe
Europe is an important part of the global economy, accounting for
nearly 40% of global trade and one quarter of global Gross
Domestic Product. In addition, Europe is the world’s top exporter
of services and second largest exporter of manufactured goods
(UNCTAD, 2020). HSBC Bank plc facilitates trade within Europe
and between Europe and other jurisdictions where the HSBC
Group has a presence.
With assets of £597bn at 31 December 2021, HSBC Bank plc is
one of Europe’s largest banking and financial services
organisations. We employ around 15,000 people across our
locations. HSBC Bank plc is responsible for HSBC’s European
business, apart from UK retail and most UK commercial banking
activity which, post ring-fencing, are managed by HSBC UK Bank
plc.
HSBC Bank plc's ambition is to simplify its operating model; with a
wholesale banking hub for the European Union ('EU') in Paris and
a wholesale banking hub for western markets in London.
HSBC Bank plc operates in 20 markets1 through the three principal
operating units detailed below.
The London hub consists of the UK non-ring fenced bank, which
provides overall governance and management for the Europe
region as a whole and is a global centre of excellence for
wholesale banking for the Group.
HSBC Continental Europe, comprises our Paris hub and its EU
branches (Belgium, Czech Republic, Greece, Ireland, Italy,
Luxembourg, Netherlands, Poland, Spain and Sweden) and
Switzerland. We are creating an integrated Continental European
bank anchored on Paris to better serve our clients and simplify our
organisation.
HSBC Germany Holdings GmbH serves the European Union’s
largest economy and one of the leading export nations globally.
HSBC Germany’s business proposition mirrors the importance of
trade and global connectivity.
1Full list of markets where HSBC Bank plc has a presence: Armenia,
Belgium, Channel Islands and Isle of Man, Czech Republic, France,
Germany, Greece, Ireland, Italy, Israel, Luxembourg, Malta,
Netherlands, Poland, Russia, South Africa, Spain, Sweden,
Switzerland and the UK.
HSBC Bank plc's strategy and progress on our
2021 commitments
We have a clear vision to be the leading international wholesale
bank in Europe, complemented by a targeted wealth and personal
banking business (see our global businesses on page 6).
HSBC Bank plc exists to open up a world of opportunity for our
customers by connecting them to international markets. Europe is
the largest trading region in the world and Asia is Europe’s biggest
and fastest growing external trading partner (UNCTAD, 2020).
Below we provide a progress update on our commitments and
strategic initiatives for 2021, in line with the Group's strategy.
Focus on our strengths
Through our transformation programme we are building a leaner,
simpler bank with a sharper strategic focus. We have an ambition
to grow, leveraging our industry leading positions in transaction
banking, trade, capital markets and financing. We intend to be a
market leader in sustainable financing and help the Group meet its
ambition for net zero in its operations and supply chain by 2030.
New regulation in the EU provides an opportunity to simplify our
structure. In response to the requirement for an IPU in line with
the EU Capital Requirements Directive for European Union
banking entities, our subsidiary HSBC Continental Europe plans to
acquire HSBC Trinkaus & Burkhardt AG (‘HSBC Germany’), HSBC
Malta, and HSBC Private Bank Luxembourg. HSBC Germany
would then be transferred into a newly created branch of HBCE in
Germany. This legal entity restructuring remains subject to
regulatory approvals.
Following the announcement in June 2021 regarding the planned
sale of our French retail operations, a binding Framework
Agreement was signed between HSBC Continental Europe and
Promontoria MMB SAS (‘My Money Group’), its subsidiary Banque
des Caraïbes SA (the ‘Purchaser’) and My Money Bank (‘MMB’) on
25 November 2021. This step marks the start of an
implementation process expected to complete in the second half
of 2023, subject to obtaining the authorization of the competent
financial, government and regulatory bodies. Until such point, the
business remains part of, and will be managed by HSBC
Strategic Report | About HSBC Group | Purpose and strategy
4
HSBC Bank plc Annual Report and Accounts 2021
Continental Europe. See Note 34 on page 174 for further financial
information on the transaction.
We intend to establish a Paris branch of HSBC Private
Luxembourg, from which French clients will be served. The project
is due to be completed during 2022 following the conclusion of
the associated social process last year. This will enable us to
provide an enhanced product range to clients leveraging our high
quality infrastructure in Luxembourg.
Digitise at scale
We continue to focus our investments in areas that help optimise
our technology capabilities and operations, as well as enhance
client experience. Our main areas of focus are Transaction
Banking, comprising Global Liquidity and Cash Management
(‘GLCM’), Global Trade and Receivable Finance (‘GTRF’) and
Foreign Exchange (‘FX’), which are central to our strategy.
Global Liquidity and Cash Management is focused on enhancing
our digital and self-serve capabilities for our clients and improving
our customer experience. In 2021, we continued to advance our
proposition, an example of this involved developing our Liquidity
Management Dashboard to facilitate customer cash flow
forecasts. Looking ahead, we will continue to develop our offering,
to improve our customer experience.
Our ambition for Global Trade and Receivables Finance is to make
trade safer, faster and easier. In 2021, we improved key aspects of
our proposition by taking steps to: simplify and digitise the client
experience, upgrade our infrastructure and connect customers to
technology partners. We aim to continue to invest in the future of
trade by further developing our capabilities across key areas such
as real-time credit decisioning, structured trade and sustainable
trade finance.
In Foreign Exchange we further enhanced our electronic trading
infrastructure to provide improved risk management to our clients.
Our focus is to support customers' FX and cross-border payment
needs through improved pricing tools and e-trading.
Our Wealth and Private Banking business in the Channel Islands
and Isle of Man has focussed on digitising documentation, with
the business saving over 600,000 pieces of paper through
customers migrating to e-statements and telephone PINs being
distributed vis SMS messaging.
During the same period, our technology investments have helped
reduce operating costs across the bank.
Energise for growth
In February 2021, we committed to continuing to energise our
people, which fundamentally contributes to a more effective, agile
and empowered organisation. The main areas of focus are to
inspire a dynamic culture, champion inclusion and develop future
skills.
Since then, we have been engaging colleagues through numerous
initiatives to apply our purpose and values to the delivery of our
strategy, how we work and how we serve our customers. 
Recruiting the right talent and diversifying our workforce remains
important to us as is ensuring we create an environment for our
colleagues to learn and grow. We are committed to increasing
diverse representation in Europe, especially at senior levels. Our
new pan-European Employee Resource Group 'Inclusive Europe'
and the Diversity & Inclusion Council has sponsorship from our
leaders and will support our actions.
We continue to energise our colleagues through initiatives that
help develop their future skills and learning opportunities. During
the year we promoted and engaged our employees with an
expanded Future Skills curriculum that now incorporates the key
strategic skills of Personal, Digital, Data and Sustainability.
Transition to net zero
Becoming a Net Zero Bank
In 2020, the HSBC Group set out ambitions to achieve net zero in
the Group’s operations and supply chain by 2030 or sooner and to
align the Group’s financed emissions to the Paris Agreement goal
to achieve net zero by 2050 or sooner. To help achieve HSBC’s
ambitions, the Group passed a climate change resolution in the
2021 Annual General Meeting. The resolution included a
commitment to set out the next steps in the Group’s transition to
net zero, including setting sector-based targets, publishing a
thermal coal phase-out policy and reporting annually on progress.
The resolution was backed by more than 99% of the Group’s
shareholders.
In 2021, the HSBC Group was one of 43 founding members of the
Net Zero Banking Alliance (‘NZBA’), which seeks to reinforce,
accelerate, and support the implementation of decarbonisation
strategies for the banking sector. The Group also launched a new
climate leadership training programme for its top 250 leadership
team, in which HSBC Bank plc non-executive directors and
executives are included.
In 2021, travel restrictions and lower energy usage due to the
Covid-19 outbreak favourably impacted HSBC Bank plc’s
greenhouse gas emissions figures. More detail can be found in our
Environmental Social and Governance ('ESG') metrics disclosure
on page 8.
Supporting our Customers
The Group's climate ambition is to support customers in their
transition to net zero and a sustainable future. As part of this, the
Group aims to provide and facilitate between $750bn and $1tn of
sustainable finance and investment by 2030. To date, HSBC Bank
plc has contributed $65.2bn to this ambition led by strong
performance from debt capital markets, representing 51% of the
Group’s cumulative contribution towards sustainable finance and
investments.
The breakdown of the Group’s sustainable finance and investment
progress is included in its ESG Data pack. The detailed definitions
of the contributing activities for sustainable finance are available in
the Group's revised Sustainable Finance Data Dictionary 2021. For
the Group's ESG Data Pack, Sustainable Finance Data Dictionary
and PwC Assurance Report, see www.hsbc.com/who-we-are/esg-
and-responsible-business/esg-reporting-centre.
Case study: Debt Management Office
In September 2021, HSBC Bank plc acted as Joint Structuring
Adviser and Joint Lead Manager on the United Kingdom Debt
Management Office's £10bn 12-year inaugural Green gilt
transaction with the proceeds to be used on projects to help the
UK finance its Green Industrial Revolution. As Joint Structuring
Adviser, we supported with establishing the UK Government’s
Green Financing Framework published in June 2021.
Unlocking New Climate Solutions
HSBC Group partnered with the World Resources Institute and
World Wildlife Fund ("WWF") to launch the $100m Climate
Solutions Partnership with the aim to accelerate support for
innovative solutions tackling climate change. The programme will
run for five years, as a part of this, there are two projects located
in France in partnership with the French National Forestry Office
and the Earthworm Foundation. Both of these local nature-based
projects will contribute to net zero goals by better enabling CO2
capture, preserving biodiversity and engaging the community.
HSBC also launched a Business Plan for the Planet campaign to
help business transition to a sustainable model. In France,
Germany and Malta we issued leadership content around carbon
neutrality, ESG and Agrofood. These topics were illustrated with
client case studies, content articles, videos and infographics
published on our websites, media partnerships and social media.
We also engaged on live sessions webinars series with HSBC
experts, clients and partners to help small and medium companies
transition.
HSBC Bank plc Annual Report and Accounts 2021
5
Our Global Businesses
The Group manages its products and services through its three global businesses: Global Banking and Markets ('GBM'); Commercial
Banking ('CMB'); Wealth and Personal Banking ('WPB'); and the Corporate Centre (comprising, certain legacy assets, central stewardship
costs, and interests in our associates and joint ventures).
Business segments
Our operating model has the following material segments: WPB; CMB; a GBM business which is further split into 3 reportable segments
MSS, GB and GBM Other reflecting the reorganisation of the GBM management structure during the year and a Corporate Centre. These
segments are supported by Digital Business Services and 11 global functions, including Risk, Finance, Compliance, Legal, Marketing and
Human Resources.
Markets &
Securities
Services (‘MSS’)
Global Banking
(‘GB’)
GBM Other
Commercial Banking
(‘CMB’)
Wealth and Personal
Banking ('WPB')
Markets & Securities Services
is a products group that
services all of the Bank's
clients, from those in Global
Banking to Commercial
Banking and Wealth and
Personal Banking. We offer
clients a range of services
and capabilities including
Trading, Financing and
Securities Services across
asset classes and
geographies, supported by
dedicated sales and research
teams.
Our European teams play a
key role in providing cross-
asset services, bridging
Emerging and Developed
Markets, and collaborating
with other global businesses
to provide clients across the
Group with bespoke products
and solutions that support
their growth ambitions.
We continue to invest in
technology and digital
transformation to enhance
client experience, improve
operational efficiencies and
future proof the business. We
have taken actions to
streamline our cost base,
optimise the usage of
financial resources and
enhance returns. Conduct is
at the heart of everything we
do and we are determined to
have the highest conduct
standards in the industry.
HSBC Global Banking
delivers tailored financial
solutions to corporate and
institutional clients
worldwide opening up
opportunities through the
strength of our global
network and capabilities.
We provide a
comprehensive suite of
services including
corporate banking, capital
markets, advisory, trade
services and global liquidity
and cash management.
Our European teams take a
client-centric approach
bringing together
relationship and product
expertise to deliver financial
solutions customised to suit
our clients’ growth
ambitions and financial
objectives. We work closely
with our business partners
including MSS, WPB and
CMB, to provide a range of
tailored products and
services that meet the
needs of clients across the
bank. Global Banking
Europe operates as an
integral part of the global
business and contributes
significant revenues to
other regions through our
European client base,
supporting the Europe
ambition to be the leading
international wholesale
bank.
GBM Other primarily comprises
Principal Investments (‘PI’) and
GBM’s share of the Bank’s
Markets Treasury function.
The Principal Investments
portfolio (‘PI’) is focused on
delivering investments that align
to the group’s strategy and
seeks to deliver strong returns
across a diversified portfolio.
Our commitment to sustainable
private equity funds contributes
directly to the Group’s aim to
provide and facilitate $750bn
and $1tn of sustainable finance
and investment by 2030.
We have a clear strategy to be the
Leading International Corporate
Bank in Europe. We help to
connect our European customers
to our international network of
relationship managers and product
specialists; supporting their
growth ambitions and targets. Our
products, which are designed to
help our customers seize growth
opportunities, range from term
loans to region-wide treasury and
trade solutions. Commercial
Banking is at the centre of
creating revenue synergies within
the Group: we collaborate closely
with our Global Banking and
Markets colleagues to provide
expertise in capital finance and
advisory solutions to support our
Commercial Banking clients. Our
trade teams within Commercial
Banking also provide import and
export finance solutions to Global
Banking and Markets clients. We
also enable customers to gain
visibility over their liquidity
positions through our main hubs
in France and Germany, which in
turn helps clients to unlock
efficiencies in their Treasury
structures. As the European
economy pivots to a net zero
carbon economy, we are
expanding our services and
products to provide customers
with innovative sustainable
finance solutions and ensuring our
relationship managers are
informed to match these to our
clients’ net zero ambitions.
In Europe, Wealth and Personal
Banking serves customers with
their financial needs through
Private Banking, Retail Banking,
Wealth Management, Insurance
and Asset Management.
Our core retail proposition offers a
full suite of products including
personal banking, mortgages,
loans, credit cards, savings,
investments and insurance.
Alongside this, WPB offers various
propositions in certain markets,
including Jade, Premier, and
Advance; as well as wealth
solutions, financial planning and
international services. In the
Channel Islands and the Isle of
Man, we serve local Islanders as
well as international customers
through our HSBC Expat
proposition.
Our Private Banking proposition
serves high net worth and ultra-
high net worth clients with
investable assets greater than
$5m in Channel Islands and Isle of
Man, France and Germany. The
range of services available to
private banking clients includes
investment management, Private
Wealth Solutions and bespoke
lending such as lending against
financial assets and residential
mortgage financing for high-end
properties.
Private Banking hosts a ‘Next
Generation’ programme of events
to support our client’s next
generation in building and
retaining the wealth within the
family. The Private bank offers this
through its philanthropy advisory
to our clients, which looks at
business succession planning. We
continue to focus on meeting the
needs of our customers, the
communities we serve, and our
people, whilst working to build the
bank of the future.
Adjusted profit/(loss) before tax
£(8)m
£589m
£99m
£490m
£323m
(2020: £20m)
(2020: £55m)
(2020: £(52)m)
(2020: £152m)
(2020: £(132)m)
Our global businesses are presented on an adjusted basis, which is consistent with the way in which we assess the performance of our
global businesses. 
Strategic Report | Our Global Businesses
6
HSBC Bank plc Annual Report and Accounts 2021
How we do business
We conduct our business to support the sustained success of our
customers, employees and other stakeholders.
Our approach
The Group recognises that it is important to be clear about who
we are and what we stand for to create long-term value for our
stakeholders. This will help the Group deliver the strategy and
operate our business in a way that is sustainable. Following an
extensive consultation with the Group's people and customers, the
Group refined our purpose and values. The Group's new purpose
is ‘Opening up a world of opportunity’ with the ambition to be the
preferred international financial partner for clients. To achieve this
in a way that is sustainable, we are guided by values: we value
difference; we succeed together; we take responsibility; and we
get it done.
In 2021, our ability to help our stakeholders was more important
than ever, as we continued to promote and encourage good
conduct through our employees' behaviours and the decisions we
take during these unprecedented times. The Group define conduct
as delivering fair outcomes for its customers and not disrupting
the orderly and transparent operation of financial markets. This is
central to the Group's long-term success and ability to serve
customers. We have clear policies, frameworks and governance in
place to protect them. For further information on conduct, see
page 81. Details on our conduct framework are available at
www.hsbc.com/conduct.
Fair outcomes
Our conduct approach guides us to do the right thing and to focus
on the impact we have for our customers and the financial
markets in which we operate. It complements our purpose and
values and – together with more formal policies and the tools we
have to do our jobs – provides a clear path to achieving our
purpose and delivering our strategy. For further information on
conduct, see page 4. For further details on our purpose-led
conduct approach framework, see www.hsbc.com/who-we-are.
Our section 172 statement, detailing our Directors’ responsibility
to stakeholders, can be found on page 9.
Our Covid-19 actions
Having a clear purpose and strong values has never been more
important, with the Covid-19 pandemic testing us all in ways we
could never have anticipated. Since the world changed in 2020,
we adapted to new ways of working and endeavoured to provide
support to our customers during this challenging period. In the
following section, we have set out further ways that we continued
to support our stakeholders.
Our colleagues
We believe diversity makes us stronger and we are dedicated to
building a diverse and connected workforce. In 2021, HSBC Bank
plc increased representation of women in senior roles to 24.0%
narrowly missing our target of 24.3%. However, as we progress
beyond the Transformation and into growth mode, we are
committed to stretching our gender target further and have set a
target of 26.4% (2.4% higher than the 2021 actuals).
In July 2020, the Group set out HSBC’s global race commitments,
which included the goal of doubling the number of Black
employees in senior roles over the following five years. In Europe,
we continue to place a strong focus on the quality and
transparency of our ethnicity data in countries where it is legally
permissible. We are committed to improving our ethnic diversity
and put in place important foundations in 2021 through leadership
development programmes, inclusive hiring, and investing in the
next generation of high-performing diverse talent.
Our Future Skills programme helps prepare our people for the
changing skills required in the future workplace. We are
encouraging our employees to take ownership of their
development and supporting them to do so.
During our Future Skills Summer campaign our new Degreed
Learning Experience Platform was formally launched to help
colleagues shape their development using both internal and
external learning content. As part of the campaign colleagues
were encouraged to identify four skills they wanted to personally
develop. By the end of 2021, 8,200 colleagues had successfully
registered and accessed the platform. More than 8,500 hours of
learning were completed by over 3,000 colleagues.
Our Climate ambition
We're playing a leading role in helping to mobilise the transition to
a global net zero economy, not just by financing it, but by helping
to shape and influence the global policy agenda. The Group has
set on-balance sheet financed emissions targets for the oil and
gas, and power and utilities sectors, aligned to the IEA’s net zero
scenario, underpinned by a clear science-based strategy. To
support the Group's ambition of net zero financed emissions,
unlocking transition finance for our portfolio of clients will be
crucial. The Group has changed how disclosures are provided
against the Task Force on Climate-Related Disclosures (‘TCFD’)
framework by embedding the content previously provided in a
stand-alone TCFD Update within the HSBC Holdings plc Annual
Report and Accounts 2021. The summary TCFD disclosure can be
found on page 63 of the HSBC Holdings plc Annual Report and
Accounts 2021.
Engaging with our stakeholders
Engaging with our stakeholders is core to being a responsible
business. To determine material topics that our stakeholders are
interested in, we conduct a number of activities throughout the
year, including engagements outlined in the table below.
Our
stakeholders
How we engage
Material topics
highlighted by the
engagement
Customers
Our customers’ voices are heard
through our interactions with them,
surveys and by listening to their
complaints
Customer advocacy
Employees
Our colleagues’ voices are heard
through our employee Snapshot
survey, Exchange meetings and our
‘speak-up’ channels, including our
global whistleblowing platform, HSBC
Confidential
Future Skills and
Diversity & Inclusion
Investors
Our ordinary shares are held by our
parent HSBC Holdings plc, however
external parties invest in our bond
issuance. We engage with these
investors via our investor relations
programme which enables investor
queries alongside a broader
programme of management meetings
and market engagement
Coal financing policies
Communities
We welcome dialogue with external
stakeholders, including non-
governmental organisations (‘NGOs’)
and other civil societies groups. We
engage directly on specific issues and
by taking part in external forums and
working groups
Financial Inclusion
and Community
Investment
Regulators and
governments
We proactively engage with regulators
and governments to facilitate strong
relationships via virtual and in-person
meetings, responses to consultations
individually and jointly via the industry
bodies
Anti-bribery and
Corruption
Suppliers
Our ethical and environmental code of
conduct for suppliers of goods and
services sets out how we engage with
our suppliers on ethical and
environmental performance
Suppliers ability to
service HSBC at an
appropriate cost, risk
profile and ability to
meet the demand by
the bank
Supporting our stakeholders through Covid-19
The Covid-19 pandemic continues to create a great deal of
uncertainty and disruption for the people, businesses and
communities we serve around the world. It is affecting everyone in
different ways, with markets at different stages of the crisis.
HSBC Bank plc Annual Report and Accounts 2021
7
The outbreak continued to pose significant challenges for our
customers. Our immediate priority has been to do what we can to
provide them with support and flexibility; with customers doing
more of their banking online, we have also deployed new
technology to help enable them to engage with us in new ways.
Employee well-being remains a top priority as we transition to new
ways of working and continue to navigate through the pandemic.
The support we provide is driven by the feedback from our people
surveys. In 2021, we launched new tools and training to support
mental, physical and financial health. We are also enabling more
colleagues to work flexibly and continue to follow social
distancing and protection measures in line with local guidance.
We firmly believe that helping our people to be healthy and happy
is a key enabler of our strategy, and benefits the people and
communities we serve.
Our ESG metrics and targets 
The Group has established targets, that guide how we do
business, including how we operate and how we serve our
customers. These include targets designed to help us to make our
business – and those of our customers – more environmentally
and socially sustainable. They also help us to improve employee
advocacy and diversity at senior levels as well as strengthen our
market conduct.
The 2021 annual incentive scorecards of the Group Chief
Executive, Group Chief Financial Officer and members of the
Group Executive Committee have 30% weightings for measures
linked to outcomes that underpin the ESG metrics below. ESG
metrics are also incorporated into the Europe Chief Executive and
Executive Committee member scorecards.
Our Environmental metrics:
HSBC Holdings plc refreshed a number of metrics and targets to
better align with its strategy and the vision for ESG, including its
ambition to achieve zero net operational emissions by 2030. HSBC
Bank plc reports emissions following the Greenhouse Gas
Protocol, which incorporates the scope 2 market-based emissions
methodology. We report greenhouse gas emissions resulting from
the energy used in our buildings and employees’ business travel.
Due to the nature of our primary business, carbon dioxide is the
main type of greenhouse gas applicable to our operations. While
the amount is immaterial, our current reporting also incorporates
methane and nitrous oxide for completeness. We do not report
employee home working emissions. In 2021 we collected data on
energy use and business travel for our operations in Europe in
France, Germany, Malta, and Switzerland, which accounted for
approximately 67% of our FTEs in HSBC Bank plc1.
At the end of 2021, HSBC Bank plc achieved a 12% reduction in
greenhouse gas emissions compared to 2020. Emissions in 2021
were 0.61 tonnes CO2e per FTE.
For further information regarding our environmental footprint,
please visit https://www.hsbc.com/who-we-are/our-climate-
strategy/becoming-a-net-zero-bank.
Our Social metrics:
•Employee engagement was 48% as at the end of 2021, up by
by 2% compared to 20201.
•Employee gender diversity, our target was 24.3% of women in
senior leadership roles by the end of 2021. The outcome for
2021 was 24.0% of women in senior leadership roles2.
Our Governance metrics:
•Sustained delivery of global conduct outcomes, with 97.8% of
staff having completed conduct training in 2021. Our target for
2021 was 98%3.
1To estimate the proportion of FTEs in HSBC Bank plc covered by the
emissions data collected, we have calculated FTEs reporting into
HSBC Bank plc in the relevant countries where emissions data is
collected as a proportion of total FTEs in HSBC Bank plc. 
2Performance is based on our employee Snapshot results. We
transitioned to the employee engagement index in 2020. 
3Senior leadership is classified as those at band 3 and above in the
Group's global career band structure. We narrowly missed our 2021
target, our focus on improving gender balance in senior leadership
across Europe remains a priority for HSBC Bank plc's executive
committee for 2022.
4The completion rate shown relates to the 2021 financial crime
training module. The 2021 regulatory conduct training has been
launched in January 2022 and will run through the first quarter of
2022.
Responsible Business Culture
We have the responsibility to protect our customers, our
communities and the integrity of the financial system. In this
section, we outline our requirements under the Non-Financial
Reporting Directive.
Environmental matters
In 2021, the Group joined the Net Zero Banking Alliance, a group
of 43 international banks to establish a robust and transparent
framework for monitoring progress and setting the standard for
the banking industry.
In fulfilment of the Group's commitment approved by shareholders
at the Group AGM in May 2021, the Group published a policy to
phase out thermal coal financing in EU and OECD markets by
2030, and globally by 2040. This incorporates project finance,
direct lending, or arranging or underwriting of capital markets
transactions to in-scope clients, as well as the refinancing of
existing finance facilities.
More information about the Group's assessment of climate risk
can be found in the HSBC Holdings plc annual report, under the
Task Force on Climate-related Financial Disclosures and climate
strategy. HSBC has actively created opportunities for cross
sectoral dialogue to advance the topic of sustainability, across key
markets. In Germany, HSBC Bank plc and the International
Chamber of Commerce organised a two day Pre COP event on
climate action, global challenges, international climate policy and
the role of business, involving international and national experts
from the United Nations, European Union, governments, COP-
Presidency (UK), civil society, business and academia. HSBC
Armenia also organised, in partnership with the British Embassy,
the first conference to promote sustainable finance, titled ‘Joining
for a Green Future’.
Employee matters
We want to encourage a dynamic and inclusive culture where our
colleagues can expect to be treated with dignity, and respect. We
are proud to be an organisation that takes action where we find
behaviours that falls short of this expectation. We monitor
achievement against this goal through metrics that we value.
Listening to our colleagues is critical to the business we conduct
and is reflected in our purpose and values, which were established
through enterprise wide listening and engagement activities. We
continue to seek innovative ways that encourage and provide
opportunities for our people to speak up about things that are
important to them. We recognise that at times people may not feel
comfortable speaking up through the usual channels. HSBC
Confidential is the Group's global whistleblowing channel, open to
colleagues past and present as an anonymous route through
which they can raise concerns confidentially at their discretion.
The development of our people is core to the success of our
organisation. We continue to develop and implement practices
that build employee capability and identify, develop and deploy
talented employees; this ensures an appropriate supply of high
calibre individuals with the right values, skills and experience for
current and future senior management positions.
Since the launch of HSBC University in 2017, we have continued
to add to the portfolio of world class leadership and professional
development programmes for leaders and people managers
including our flagship programmes, Accelerate into Leadership,
Accelerating Female Leadership and Leading Business and
Functions.
Strategic Report | How we do business
8
HSBC Bank plc Annual Report and Accounts 2021
Communities
We have a responsibility to invest in the communities where we
operate. We recognise that the world is evolving at a rapid pace
and that a range of new and different skills are now needed for
people to succeed. For this reason, much of our focus is on
charitable partnerships that develop employability and financial
capability skills. We also back climate solutions and innovation,
and contribute to disaster relief efforts based on need. In 2021 in
Europe, we contributed £1.7m to charitable programmes and our
employees volunteered 4,200 hours to community activities during
the working day.
Human rights
Our commitment to respecting human rights, principally as they
apply to our employees, our suppliers and through our financial
services lending, is set out in our Human Rights Statement. This
statement, along with our statements under the UK’s Modern
Slavery Act (‘MSA’), is available on  www.hsbc.com/who-we-are/
esg-and-responsible-business/esg-reporting-centre.
Anti-corruption and anti-bribery
We are committed to high standards of ethical behaviour and
operate a zero-tolerance approach to bribery and corruption. Our
anti-bribery and corruption policy sets the framework for the
Group and this is followed throughout HSBC Bank plc, to comply
with anti-bribery and corruption legislation in all jurisdictions in
which we operate, and gives practical effect to global initiatives,
such as the OECD Convention on Combating Bribery of Foreign
Public Officials in International Business Transactions. Where local
legislation is in place in a jurisdiction, local policies are in place as
appropriate, for example in France the Sapin II law requirements is
adhered to.
The principal risks addressed by our anti-bribery and corruption
policy are the risk that our employees, associated persons or
customers engage in bribery or corruption, or that the Group does
so through its strategic activities.
HSBC conducts business with the commitment to supporting the
sustained success of our customers, people and communities.
Non-Financial Information Statement
Disclosures required pursuant to the Companies, Partnerships and
Groups (Accounts and Non-Financial Reporting) Regulations 2016
can be found on the following pages:
Environmental matters (including the impact of the
company’s business on the environment)
Page 8
The company’s employees
Pages 7 to 10 and 94 to 95
Social matters
Page 8
Respect for human rights
Page 9
Anti-corruption and anti-bribery matters
Page 9
Business model
Page 6
Principal risks
Page 19
HSBC creates value by providing products and services to meet
our customers' needs. We aim to do so in a way that fits
seamlessly into their lives. This helps us to build long-lasting
relationships with our customers. HSBC maintains trust by striving
to protect our customers’ data and information, and delivering fair
outcomes for them and if things go wrong, we need to address
complaints in a timely manner. Operating with high standards of
conduct is central to our long-term success and underpins our
ability to serve our customers. Our Conduct Framework guides
activities to strengthen our business and increases our
understanding of how the decisions we make affect customers
and other stakeholders. Details on our Conduct Framework are
available at www.hsbc.com.
Section 172 statement
This section, from pages 9 to 11 forms our section 172 statement.
It describes how the Directors have performed their duty to
promote the success of the bank, including how they have
considered and engaged with stakeholders and, in particular, how
they have taken account of the matters set out in section 172(1)(a)
to (f) of the Companies Act 2006 (the 'Act').
The Board considered a range of factors when making decisions
and is supported in the discharge of its duties by:
a.an induction programme and ongoing training to provide an
understanding of our business and financial performance and
prospects;
b.management processes which help ensure that proposals
presented to Board and committee meetings for decision
include information relevant to determine the action that would
most likely promote the success of the bank and involve
engagement with stakeholders where relevant to support
appropriate decision making; and
c.agenda planning for Board and committee meetings to provide
sufficient time for the consideration and discussion of key
matters.
Stakeholder Engagement
The Board understands the importance of effective engagement
with its stakeholders and is committed to open and constructive
dialogue. This helps build trust and allows the Board to better
understand the impact of the bank's actions on its stakeholders
and respond to the challenges facing the bank. Depending on the
nature of the issue in question, however, the relevance of each
stakeholder group may differ and not every decision the Board
makes will necessarily result in a positive outcome for all
stakeholders.
The Board continued to focus its engagement with the bank's six
key stakeholders, namely the bank’s customers, employees,
shareholders and investors, communities, suppliers, and
regulators and governments. In discharging its responsibilities, the
Board seeks to understand, and have regard to, the interests and
priorities of these stakeholders.
For further details regarding the role of the Board and the way in
which it makes decisions, including key activities during 2021,
please see page 89.
The Board regularly receives reports from management on issues
concerning its stakeholders, which it takes into account in its
discussions and in its decision-making process as part of their
duties under section 172. In addition to this, the Board seeks to
understand the interests and views of the bank's stakeholders by
engaging with them directly as appropriate. The ongoing impact of
the Covid-19 pandemic has restricted the Board’s ability to engage
with stakeholders face-to-face, but examples of how the Directors
engaged with stakeholders are set out below:
Customers
Customers are at the core of the bank's business model: without
customers there would be no bank. The Board strives to ensure it
has a broad understanding of customers, their needs and
challenges, and to give full consideration to these.
During the year, the CEO and his senior management team
continued to engage directly with customers, while the Board
continued to monitor the bank’s approach to supporting
customers. The Board received regular reports from senior
management on interaction with customers, which included key
performance indicators measuring the impacts and challenges to
customers as a result of the ongoing Covid-19 pandemic and
associated Covid-19 relief payment moratoria, the impact of the
free trade agreement between the EU and UK which excluded EU-
wide arrangements for financial services, the bank's Europe
transformation programme and associated conduct
considerations. Dedicated deep dive sessions were also held, with
one such session focused on HSBC Life and the Insurance
business.
Employees
Employees are critical to the successful operation of the bank and
its long-term future.
During the year the Board received regular updates from senior
management on various metrics and feedback tools in relation to
employees, including updates on Diversity and Inclusion and the
Gender Pay Gap. Updates were also provided on the impact on
employee wellbeing and how the bank was supporting its staff.
HSBC Bank plc Annual Report and Accounts 2021
9
The focus on employees by the Board was also heightened
through the frequent updates provided to the Board on the bank's
Europe transformation programme and how staff were being
impacted by the level of change. These updates considered key
areas of people risk and the future of work in a post-pandemic
environment.
Shareholders and Investors
The bank is a wholly owned subsidiary of the HSBC Holdings plc
and, as such, the Board took into account the implications of its
decisions with regard to its ultimate shareholder, HSBC Holdings
plc, and its debt security investors.
During the course of the year, the Group Chairman held a number
of principal subsidiary chair conferences which were attended by
the Chairman of the Board. In addition, Chairs of the Audit and
Risk Committees participated in regional Audit and Risk
committee forums hosted by their Group counterparts. These were
attended both by the bank's Directors as well as Audit and Risk
Committee Chairs of material subsidiaries. The Board also received
updates from management on the bank's debt issuance
programmes.
Regulators and Governments
Directors periodically meet with the bank’s regulators, the
Financial Conduct Authority ('FCA') and Prudential Regulatory
Authority ('PRA'). It is central to the success of the bank that it has
strong relationships with these stakeholders and that there is a
mutual understanding on expectations and challenges given their
impact on customers, the business model and the bank’s strategy.
During the year, members of the Board met regularly with
regulators both in the UK and Europe and engagement continued
during 2021 notwithstanding the logistical challenges posed by
the impact and continued national and regional lock-downs due to
the Covid-19 pandemic. The Board held a dedicated deep dive
session on how HSBC interacts with regulators globally and at the
European level to better understand the scope of engagement at
executive level with relevant regulators in the region.
Suppliers
Suppliers are critical to supporting the infrastructure and
operations of the business and have contractual relationships with
the bank.
During the year, the Board received an update on the bank’s
performance against its statutory reporting obligations in respect
of the payment of third party suppliers. This also provided an
insight into the impact of its procurement processes and
procedures on suppliers.
Communities and Environment
The bank has legal, regulatory and social responsibilities to the
community and its environment.
During the year the Board received updates on the Group’s
evolving climate and sustainable finance strategy and net zero
ambition. As we go into 2022, and as a sustainable finance
strategy tailored for European business is further developed, the
Board will receive updates on the bank’s delivery against the
ambition and strategy execution.
Employee Engagement
The Chief Executive Officer and senior management are actively
involved in the engagement of employees through leadership calls
and quarterly all employee webcasts to keep the workforce up-to-
date on business developments and answer questions. In addition,
the Chief Executive Officer issues a Europe-wide newsletter which
updates employees on initiatives across the region. The Board
receives regular updates from the Chief Executive Officer and the
Head of HR on employee matters, including feedback received
through Town Halls and Exchanges, as well as through regular
employee surveys. One of the non-executive Directors also has a
particular focus on employee matters to enhance the Board's view
of people issues and to gain a better understanding of the
employee perspective. Further details of the bank’s engagement
with employees can be found on pages 7 to 10 and 94 to 95.
Principal Decisions
Set out below are some of the principal decisions made by the
Board during 2021. In each case, in taking such decisions, the
Directors exercised their statutory duties, including the duty to act
in the way that they consider, in good faith, would be most likely
to promote the success of the bank for the benefit of its members
as a whole.
Europe Transformation Programme
Following a revision of the bank’s operating plan in 2020 in
response to the revised Group strategy, in 2021 the Board
continued to oversee and challenge management in their
execution of the bank’s Europe transformation programme.  The
bank’s continued focus on simplification of its presence in the
region included a proposal being brought to the Board in May
2021 for the disposal of the group’s non-core retail banking
business in France. 
Prior to approval, the Board constructively challenged and
engaged with senior management to consider the financial and
commercial profile of the business itself, alternative proposals in
respect of the retail business and the likely consequences of the
disposal on the bank’s key stakeholders, including customers and
its shareholder and investors. In considering stakeholders, the
Board also considered the consultation undertaken with relevant
French works’ councils, and the interests of the bank’s employees,
in respect of the disposal. Completion of the disposal will involve
engagement with other key stakeholders, including relevant
regulators.
In reaching its decision, the Board acknowledged the rationale for
the transaction in the context of the strategy for the group set by
its shareholder and considered the interests of its shareholder in
undertaking the disposal. It concluded that the disposal would be
a strong enabler in simplifying HSBC’s business in Continental
Europe, allowing management to accelerate the transformation of
the European wholesale banking franchise. Additionally, the Board
had regard to customers. In particular, the Board considered the
terms negotiated as part of the transaction to help to ensure an
effective transition of the business to the buyer in light of the
importance of maintaining ongoing support for customers. 
Furthermore, the proposed sale to an experienced investor, with a
strategic focus on retail banking, was recognised as giving support
to the development of the retail business over the longer term.
Having taken all of these and other factors into account, including
an assessment of the financial merits and risks, and the interests
of employees, the Board agreed to proceed with the proposal on
the basis that it considered that it was in the best interests of the
bank’s members as a whole and would promote the long term
success of the bank, as subsequently announced by HSBC on 18
June 2021.
Legacy Capital Consent Solicitation
A key regulatory responsibility of the bank for a number of years
has been to help facilitate an industry-wide transition from the use
of interbank offered rates (‘Ibors’), such as the London interbank
offered rate (‘Libor’), to using near risk free replacement rates
(‘RFRs’) or alternative reference rates. The bank had two
externally-issued outstanding English law capital instruments (one
of which was issued through a Jersey Limited Partnership vehicle)
that contained provisions requiring the interest rate to be
determined by reference to a GBP Libor rate.
In view of the anticipated demise of GBP Libor from the end of
2021, in July 2021, the Board considered a proposal to seek
consent from the bondholders to amend the terms and conditions
of such instruments, to transition them from using GBP Libor to
calculate the interest rate to instead use the Sterling Overnight
Index Average (‘SONIA’) rate, which is the RFR recognised as the
preferred alternative rate for sterling markets. 
As part of its consideration, the Board took into account the
impact of the project on the bank’s key stakeholders, in particular
its investors in such instruments, and its obligations to, and
relationship with, its regulators. In this respect, the Board
acknowledged the expectations of the regulators that the bank
Strategic Report | How we do business
10
HSBC Bank plc Annual Report and Accounts 2021
seeks to swiftly transition its portfolio of legacy GBP Libor
contracts (which includes these instruments) prior to the
anticipated demise date for GBP Libor. From an investor
perspective, the Board was mindful of the need to adopt transition
terms that were consistent with others in the market and that
included the industry agreed adjustment spread to be added to the
relevant SONIA rate, to compensate investors for the difference
between SONIA and Libor reference rates.
Having considered these factors, the Board recognised and
approved the need for the bank to seek the consent of
bondholders to transition these instruments, acknowledging that
this would be in the best interests of the bank’s members as a
whole and would promote the long term success of the bank.
Tax
Our approach to tax
We are committed to applying both the letter and the spirit of the
law in all territories where we operate, and have adopted the UK
Code of Practice for the Taxation of Banks. As a consequence, we
seek to pay our fair share of tax in the countries in which we
operate. We continue to strengthen our processes to help ensure
our banking services are not associated with any arrangements
known or suspected to facilitate tax evasion.
HSBC continues to apply global initiatives to improve tax
transparency such as:
•the US Foreign Account Tax Compliance Act (‘FATCA’);
•the OECD Standard for Automatic Exchange of Financial
Account Information (also known as the Common Reporting
Standard);
•the Capital Requirements Directive IV (‘CRD IV’) Country by
Country Reporting;
•the OECD Base Erosion and Profit Shifting (‘BEPS’) initiative;
and
•the UK legislation on the corporate criminal offence (‘CCO’) of
failing to prevent the facilitation of tax evasion.
We do not expect the BEPS or similar initiatives adopted by
national governments to adversely impact our results.
Key Performance Indicators
The Board of Directors tracks the group’s progress in
implementing its strategy with a range of financial and non-
financial measures or key performance indicators (‘KPIs’). Progress
is assessed by comparison with the group strategic priorities,
operating plan targets and historical performance. The group
reviews its KPIs regularly in light of its strategic objectives and
may adopt new or refined measures to better align the KPIs to
HSBC’s strategy and strategic priorities.
Financial KPIs
2021
2020
Profit/(loss) before tax (reported) (£m)
1,023
(1,614)
Profit/(loss) before tax (adjusted) (£m)
1,577
(184)
Cost efficiency ratio (reported) (%)
89.2
113.6
Cost efficiency ratio (adjusted) (%)
80.9
89.6
Return on tangible equity (%)
6.1
(2.7)
Common equity tier 1 capital ratio (%)
17.3
14.7
Profit/(loss) before tax (reported/adjusted): Reported profit/
(loss) before tax is the profit/(loss) as reported under IFRS.
Adjusted profit/(loss) before tax adjusts the reported profit/(loss)
for the effect of significant items as detailed on pages 15 to 16.
Reported profit before tax in 2021 was £1,023m compared
with a loss before tax of £(1,614)m in 2020. This was primarily
driven by lower reported operating expenses driven by the non-
recurrence of a £802m impairment of intangible assets in 2020
and lower restructuring and other related costs, including
severance costs, arising from the bank's transformation
programme. Expected credit losses and other credit impairment
charges ('ECL') were significantly lower reflecting an improvement
in the economic outlook. Revenue was higher compared with
2020, notably in our insurance manufacturing business in WPB,
partly offset by higher restructuring and other related costs
comprising disposal losses associated with RWA reductions which
related to the commitments at our February 2020 business update.
Adjusted profit before tax was £1,577m compared with a loss
before tax of £(184)m in 2020. This was driven by lower ECL and
lower operating expenses as well as strong revenue performance.
The increase in revenue included positive market impacts on the
present value of in-force ('PVIF') insurance contracts in insurance
manufacturing in WPB driven by an increase in interest rate yield
curves and favourable movements in valuation adjustments in
Markets and Securities Services ('MSS'). Operating expenses
decreased as a result of the tight control of discretionary spend to
reflect the economic outlook and the initial impact of our
transformation of the bank. This was partly offset by the UK bank
levy incurred in 2021, which was previously paid by the Group. In
addition, there was a gain of £191m compared with a loss of
£(1)m in 2020 recognised from our share of profit/(loss) from
associates.
Reported cost efficiency ratio was 24.4 percentage points
lower compared with 2020 driving by higher revenue and lower
operating expenses. Reported revenue increased by 3.7% and
reported operating expenses decreased by 18.5%, mainly driven
by the factors mentioned above.
Adjusted cost efficiency ratio improved by 8.7 percentage
points from 2020, reflecting higher revenue and lower costs 
Revenue increased by 5.6%, mainly driven by favourable PVIF and
positive valuation adjustments. Operating expenses decreased by
4.7%, mainly driven by lower costs reflecting our transformation
plans partly offset by the UK bank levy and higher variable pay.
Return on tangible equity (‘RoTE’) is computed by adjusting
reported profit attributable to ordinary shareholders by excluding
movements in PVIF and significant items (net of tax), divided by
average tangible shareholders' equity excluding fair value of own
debt, debt valuation adjustment (‘DVA’) and other adjustments for
the period. The adjustment to reported results and reported equity
excludes amounts attributable to non-controlling interests.
We provide RoTE as a way of assessing our performance, which is
closely aligned to our capital positions.
CET1 capital ratio represents the ratio of common equity tier 1
capital to total risk-weighted assets ('RWA'). CET1 capital is the
highest quality form of capital comprising shareholders’ equity and
related non-controlling interests less regulatory deductions and
adjustments.
The group seeks to maintain a strong capital base to support the
development of its business and meet regulatory capital
requirements at all times.
The CET1 capital ratio of 17.3% in 2021 increased by 2.6
percentage points from 2020, mainly due to a reduction in RWAs.
Non-financial KPIs
We monitor a range of non-financial KPIs focusing on customers,
people, culture and values including customer service satisfaction,
employee engagement and diversity and sustainability.
For details on customer service and satisfaction please refer
below; for the remaining non-financial KPIs, refer to the Non
financial reporting section on page 8 and Corporate Governance
section on pages 88 to 96.
HSBC Bank plc Annual Report and Accounts 2021
11
Customer service, awards and satisfaction
MSS
Our customers are at the heart of what we do and we are
committed to delivering services and capabilities that meet their
needs and help them fulfil their ambitions.
In 2021, we won numerous awards and consistently ranked highly
with our European clients, including winning Currency Manager of
the Year at the European Pension Awards, Western Europe’s Best
Bank for SMEs by EuroMoney, ranking number one for overall
service quality in Continental Europe in the Coalition Greenwich
Foreign Exchange study, and ranking number one in both the UK
and Ireland as best fund and administration provider in the R&M
Investor Services Survey.
These accolades, coupled with multiple milestones and
achievements in sustainable finance, demonstrate our unique
capabilities to support clients locally and connect them to markets
and expertise in the East, as well the key role Europe plays in
supporting the Group’s strategic priorities.
GB
Within Global Banking Europe we remain committed to providing
excellent customer experience and we continue to strive towards
improving our proposition to meet client needs.
In 2021, HSBC received a number of external awards, recognising
the support we’ve provided to our clients for example, Investment
Bank of the Year for Bonds by The Banker.
Aligned with our strategy of opening up opportunities for our
clients, HSBC was also recognised with an Excellence Award in
International Network Breadth by the Coalition Greenwich Awards
and won seven bond awards from Environmental Finance in 2021.
These awards, in particular, highlight the continued strength and
differentiation of our ESG capabilities globally as well as the role
we play in Europe helping our clients transition to net zero.
CMB
Customer experience and satisfaction are fundamental priorities
for Commercial Banking in Europe. We measure a number of
metrics, track customer service levels and gather direct customer
feedback to ensure our solutions and channels remain relevant
and fit for our customers’ needs today. In 2021, we launched
Europe 1 Form, a single document addressing all of a clients’
onboarding requirements to enable an account being opened.
These type of initiatives help to improve our customers’ journeys
and experience, and ensures that we continue to achieve internal
operating efficiencies. We have also pivoted towards a centralised
booking model, which has enabled us to provide regional
coverage to our customers and helped to support our their needs
on a pan-European basis. Looking ahead, we will continue to
support our customers to formulate transition plans to achieve
their net-zero targets.
WPB
In WPB Europe, enhancing customer experience and improving
satisfaction remains integral to our strategy. This is monitored
through a number of customer satisfaction metrics covering
branch, contact centre and digital channels. We recognise the
importance of customer feedback and continue to enhance our
insights to gain a better understanding of our clients to provide a
more personalised and relevant service.
Digital continues to be a principal area of investment; enhancing
customer experience, reducing processing costs and driving the
sustainability agenda. In Expat we have launched a new mobile
app including the deployment of soft token. This will reduce the
need for over 20,000 hard tokens being sent to customers
globally. Our Private Banking arm is also committed to enhancing
digital offerings, including enhanced capabilities to support our
advisory offering, and improved internal platforms and software to
support our people in delivering excellent client service.
We recognise that enhancing customer satisfaction is an evolving
process and are committed to ensure our investments and focus
are prioritised to achieve this.
Economic background and
outlook
UK
Continued recovery amid high inflation
The UK economy grew by 1% in the fourth quarter of 2021,
bringing the level of output to 0.4% above its pre-pandemic level.
While the UK only tightened restrictions modestly over the winter
in response to concerns surrounding the Omicron variant of
COVID-19, the pace of economic growth slowed and uncertainty
remains high. Much of the expansion through 2021 was driven by
household and government spending. On the other hand, business
investment and exports have been subdued (10% and 18% below
their pre-pandemic peaks). Headwinds related to the UK's exit
from the EU might have played a role.
As the economy has rebounded, it has run into supply constraints,
both in terms of global supply chain disruption, and labour
shortages. The former might be constraining trade and
manufacturing, while the latter has been associated with record
job vacancy levels.
These supply issues, coupled with significant rises in energy prices
– wholesale gas prices in particular – have led to a sharp rise in
inflationary pressure. The annual CPI inflation rate stood at 5.5% in
January 2022, more than double the Bank of England's 2% target.
Inflation is expected to rise further in the near term, with sharp
rises in regulated utility prices set for April.
Looking ahead, HSBC Research expects the UK economy to
continue to normalise following the worst of the pandemic-related
disruption, with GDP growing by 4% in 2022 and by 1.6% in 2023.
As energy and supply-related pressures eventually ease, HSBC
Research expects CPI inflation to start falling back through 2022,
then fall to around the 2% mark in 2023.
UK rates could rise this year
Given inflation strength and 'tightness' in the labour market, the
Bank of England ('BoE') has begun to tighten monetary policy,
with a 15 basis point rise in Bank Rate in December and a 25 basis
point increase in January, lifting the rate to 0.50%. HSBC Research
expects another three rate increases in 2022 bringing Bank Rate
up to 1.25%. The BoE has announced that, with Bank Rate now at
0.50%, it will stop reinvesting maturing government bonds held as
part of its Quantitative Easing ('QE') programme.
Fiscal policy, which has been highly supportive since the onset of
the pandemic, is set to achieve a narrowing in the government
budget deficit over the coming years. As part of the consolidation,
and in order to meet the increasing spending commitments
relating to an ageing population, taxes as a share of the overall
economy are set to rise, according to the government's forecasts,
to levels not seen since early the 1950s.
Eurozone
Recovering from renewed Covid-19 concerns
Even before heightened concerns about the Omicron variant, 
Covid-19 cases were rising sharply in several European countries.
In response, several countries curtailed hospitality-sector opening
hours and tightened restrictions for unvaccinated people. This has
compounded ongoing headwinds from supply chain disruption,
which has weighed on the manufacturing sector in particular. And
economic growth slowed in the fourth quarter, from 2.2% to 0.3%,
though that allowed GDP to return to its pre-pandemic peak. More
recently, case numbers have been in decline and the business
surveys point to a pick-up in near-term growth.
Despite the softening in overall activity at the turn of the year, the
labour market has remained robust. In December 2021, the
eurozone unemployment rate declined from 7.1% to 7.0%. That
compares to a December 2020 peak of 8.4% and a February 2020
level of 7.3%.
Strategic Report | Economic background and outlook
12
HSBC Bank plc Annual Report and Accounts 2021
As a result of sharp rises in energy prices, and supply disruption,
annual eurozone consumer price inflation reached a record high of
5.1% in January 2022. Importantly though, eurozone wage cost
pressures remain fairly contained, keeping a lid on underlying
inflation rates.
HSBC Research expects a continued economic recovery, with
eurozone GDP growing by 3.5% in 2022 and 2.3% in 2023.
Meanwhile, as long as wage pressures remain in check, and
assuming an easing in supply disruption, inflation is likely to fall
sharply over the coming months. HSBC Research sees the
headline inflation rate falling to around the 2% mark in early 2023.
Eurozone interest rates could rise this year
Although eurozone wage pressures appear to remain fairly soft,
significant upside news to inflation, alongside the ongoing
economic recovery, means that the European Central Bank ('ECB')
has signalled the possibility of paring back monetary policy
stimulus. In December the ECB announced that it will end its
Pandemic Emergency Purchase Programme ('PEPP') in March
2022.
Beyond that, HSBC Research expects the ECB to end net asset
purchases under its regular Asset Purchase Programme ('APP') by
the end of  September 2022, paving the way for a 25 basis point
rise in the Deposit Rate (from -0.50% to -0.25%) in October 2022,
then another 25 basis point increase in March 2023. In mid-
February, market prices pointed to a faster pace of ECB tightening,
with more than 40bps of rate rises priced in for 2022. 
Financial summary
Use of alternative performance measures
Our reported results are prepared in accordance with International
Financial Reporting Standards ('IFRSs'), as detailed in the Financial
Statements starting on page 107. In measuring our performance,
the financial measures that we use include those derived from our
reported results in order to eliminate factors that distort year-on-
year comparisons. These are considered alternative performance
measures.
All alternative performance measures are described and reconciled
to the closest reported financial measure when used.
Adjusted performance
Adjusted performance is computed by adjusting reported results
for the year-on-year effects of significant items that distort year-
on-year comparisons.
We use ‘significant items’ to describe collectively the group of
individual adjustments excluded from reported results when
arriving at adjusted performance. These items are ones that
management and investors would ordinarily identify and consider
separately when assessing performance to understand better the
underlying trends in the business. We consider adjusted
performance provides useful information for investors by aligning
internal and external reporting, identifying and quantifying items
management believes to be significant and providing insight into
how management assesses year-on-year performance.
Summary consolidated income statement for the year ended
2021
2020
£m
£m
Net interest income
1,754
1,898
Net fee income
1,413
1,400
Net income from financial instruments measured at fair value
3,432
2,314
Gains less losses from financial investments
60
95
Net insurance premium income
1,906
1,559
Other operating income
594
417
Total operating income1
9,159
7,683
Net insurance claims, benefits paid and movement in liabilities to policyholders
(3,039)
(1,783)
Net operating income before change in expected credit losses and other credit impairment charges1
6,120
5,900
Change in expected credit losses and other credit impairment charges
174
(808)
Net operating income
6,294
5,092
Total operating expenses excluding impairment of goodwill and other intangible assets2
(5,416)
(5,903)
Impairment of goodwill and other intangible assets
(46)
(802)
Operating profit/(loss)
832
(1,613)
Share of profit/(loss) in associates and joint ventures
191
(1)
Profit/(loss) before tax
1,023
(1,614)
Tax credit
23
136
Profit/(loss) for the year
1,046
(1,478)
Profit/(loss) attributable to the parent company
1,041
(1,488)
Profit attributable to non-controlling interests
5
10
1Net operating income before change in expected credit losses and other credit impairment charges is also referred to as revenue.
2Total operating income and expense include significant items as detailed on pages 14 to 16.
HSBC Bank plc Annual Report and Accounts 2021
13
Reported performance
Performance in 2021 was stronger compared with 2020, which
was heavily impacted by the Covid-19 pandemic.
Reported profit before tax was £1,023m, compared with a loss
before tax in 2020 of £(1,614)m, an increase of £2,637m. This was
mainly due to a significant reduction in operating expenses, a net
release in ECL compared with charges in 2020, and stronger
revenue performance.
Reported revenue was £220m higher, largely driven by favourable
market impacts on the present value of in-force ('PVIF') long-term
insurance contracts in insurance manufacturing in WPB. Also,
2020 revenue included a significant negative impact from
valuation adjustments in MSS. This was partly offset in 2021 by
higher restructuring and other related costs comprising disposal
losses associated with RWA reductions, related to the
commitments at our February 2020 business update. ECL were
lower driven by a net release in 2021 compared with net charge in
2020 as a result of the deteriorating economic outlook during the
onset of the Covid-19 outbreak. Operating expenses were lower,
mainly driven by the non-recurrence of a impairment of goodwill
and other intangible assets and lower transformation costs, partly
offset by the UK bank levy incurred for the first time in 2021. In
addition, there was also a gain compared with a loss in 2020
recognised from our share of profit/(loss) from associates.
Net interest income (‘NII’) decreased by £144m or 8%
compared with the prior year. NII was lower mainly driven by the
impact of lower interest rate environment, notably in Retail
deposits in WPB and in GLCM (in Global Banking). Revenue was
also lower due to a reduction in balance sheet lending as a result
of the transformation programme to reduce RWAs. This was partly
offset by a reduction in the funding cost of trading assets, and
through initiatives to reduce the overall funding costs of the bank
through retiring more expensive wholesale funding.
Net fee income increased by £13m or 1% compared with the
prior year, primarily in WPB largely in Asset Management driven
by favourable market conditions and in Retail due to higher fees
commission driven by increased levels of customer activity
compared to 2020, which was impacted by the Covid-19
pandemic.
Net income from financial instruments measured at fair
value increased by £1,118m or 48% compared with the prior year.
In WPB, revenue increased primarily reflecting a stronger equity
market performance and higher interest rate yields in France
compared with 2020 when the value of equity and unit trust assets
supporting insurance contracts were heavily impacted by the
Covid-19 outbreak.
This favourable movement resulted in a corresponding movement
in liabilities to policyholders, reflecting the extent to which
policyholders participate in the investment performance of the
associated assets. The offsetting movements are recorded in net
insurance claims and benefits paid and movement in liabilities to
policyholders.
Revenue also increased in MSS largely driven by lower adverse
credit and funding valuation adjustments compared with 2020.
Excluding this, revenue was lower, as 2020 benefited from higher
market volatility supporting a particularly strong performance
within Global Foreign Exchange and Global Debt Markets, notably
in the UK.
By contrast, revenue decreased in GBM Other, mainly driven by
higher restructuring and other related costs comprising disposal
losses associated with RWA reductions, related to the
commitments at our February 2020 business update.
Gains less losses from financial investments decreased by
£35m, mainly driven by lower gains on the disposal of bonds held
at fair value through other comprehensive income ('FVOCI') in
Markets Treasury.
Net insurance premium income increased by £347m or 22%, in
WPB, from insurance manufacturing revenue in France driven by
higher new business volumes.
Net insurance claims, benefits paid and movement in
liabilities to policyholders increased by £1,256m or 70%,
primarily in the insurance business in WPB. The increase was
driven by higher returns on financial assets supporting contracts
where the policyholder is subject to part or all of the investment
risks. The gains recognised on the financial assets measured at fair
value through profit and loss that are held to support these
insurance contract liabilities are reported in 'Net income from
financial instruments designated at fair value'. This was partly
offset by a increase in premium income.
Other operating income increased by £177m or 42%, mainly
due to favourable market impacts, notably on PVIF, in insurance
manufacturing in WPB. This reflected a stronger equity market
performance and higher interest rate yields on the valuations of
the liabilities under insurance contracts. This was partly offset by
lower revenue in GBM Other due to lower intercompany recharge
recoveries from other entities in the Group, with an offsetting
decrease in operating expenses.
Changes in expected credit losses and other credit
impairment charges (‘ECL’) were a net release of £174m in
2021, compared with a net charge of £808m in 2020. The net
release in 2021 reflected an improvement in the economic outlook
and a stabilisation of credit risk. This compared with the
significant build-up of stage 1 and stage 2 allowances in 2020 due
to the worsening economic outlook at the onset of the Covid-19
outbreak. The reduction in ECL compared with 2020 also reflected
lower levels of stage 3 charges.
Total operating expenses excluding impairment of goodwill
and other intangible assets decreased by £487m or 8%, mainly
driven by a reduction in staff costs, lower contractor and
consultancy spend, and lower discretionary spend, in line with our
transformation plan. In addition, there was also lower expenses
related to severance costs arising from cost efficiency measures
across our global businesses and function. This reduction was
partly offset by the UK bank levy incurred in 2021, which was
previously paid by the Group.
Impairment of goodwill and other intangible assets was
£756m lower compared with the prior year. In 2020, operating
expenses included a £802m goodwill impairment which principally
comprised the write-off of capitalised software. This mainly related
to our businesses in the UK and France and reflected the
underperformance and deterioration in the future forecasts of
these businesses, substantially relating to prior periods.
Share of profit/(loss) in associates and joint ventures was a
profit of £191m compared with a loss of £(1)m in 2020. The profit
in 2021 included a £93m true-up of prior year valuations in the
underlying investments of an associate.
Tax credit was £113m lower compared with 2020. The effective
tax rate of 2.3% for 2021 included favourable non-recurring items
in respect of tax rate changes, prior period adjustments and the
recognition of previously unrecognised deferred tax assets in
France.
The effective tax rate of 8.4% for 2020, representing a tax credit
on loss before tax, was mainly due to the non-recognition of
deferred tax on the loss in France for the period.
Strategic Report | Financial summary
14
HSBC Bank plc Annual Report and Accounts 2021
Adjusted performance
Significant revenue items by business segment – (gains)/losses for the year ended
MSS
GB
GBM
Other
CMB
WPB
Corporate
Centre
Total
£m
£m
£m
£m
£m
£m
£m
31 Dec 2021
Reported revenue
2,043
1,367
310
1,096
1,276
28
6,120
Significant revenue items
12
—
269
(1)
(1)
(69)
210
–  fair value movements on financial instruments1
12
—
(5)
(1)
(1)
—
5
–  restructuring and other related costs2
—
—
274
—
—
(69)
205
Adjusted revenue
2,055
1,367
579
1,095
1,275
(41)
6,330
31 Dec 20203
Reported revenue
1,966
1,381
437
1,132
1,035
(51)
5,900
Significant revenue items
2
—
187
1
—
(93)
97
–  fair value movements on financial instruments1
2
—
2
1
—
(2)
3
–  restructuring and other related costs2
—
—
185
—
—
(91)
94
Adjusted revenue
1,968
1,381
624
1,133
1,035
(144)
5,997
1 Includes fair value movements on non-qualifying hedges and debt valuation adjustments on derivatives.
2Includes losses associated with the RWA reduction commitments.
3 A change in reportable segments was made in 2021. Comparatives data have been re-presented accordingly. For further guidance, refer to
Note 9: Segmental Analysis on page 138.
Significant cost items by business segment – (recoveries)/charges for the year ended
MSS
GB
GBM
Other
CMB
WPB
Corporate
Centre
Total
£m
£m
£m
£m
£m
£m
£m
31 Dec 2021
Reported operating expenses
(2,064)
(918)
(588)
(611)
(981)
(300)
(5,462)
Significant cost items
—
—
103
(1)
6
236
344
–  restructuring and other related costs
—
—
103
(1)
6
236
344
–  settlements and provisions in connection with legal and regulatory
matters
—
—
—
—
—
—
—
–  impairment of other intangible assets
—
—
—
—
—
—
—
Adjusted operating expenses
(2,064)
(918)
(485)
(612)
(975)
(64)
(5,118)
31 Dec 20202
Reported operating expenses
(1,950)
(878)
(1,351)
(773)
(1,169)
(584)
(6,705)
Significant cost items
1
—
679
114
41
498
1,333
–  restructuring and other related costs1
—
—
218
79
5
377
679
–  settlements and provisions in connection with legal and regulatory
matters
1
—
—
—
—
8
9
–  impairment of other intangible assets
—
—
461
35
36
113
645
Adjusted operating expenses
(1,949)
(878)
(672)
(659)
(1,128)
(86)
(5,372)
1Includes the write down of software £148m.
2A change in reportable segments was made in 2021. Comparatives data have been re-presented accordingly. For further guidance, refer to
Note 9: Segmental Analysis on page 138.
Net impact on profit/(loss) before tax by business segment
MSS
GB
GBM
Other
CMB
WPB
Corporate
Centre
Total
£m
£m
£m
£m
£m
£m
£m
31 Dec 2021
Reported profit/(loss) before tax
(20)
589
(273)
492
318
(83)
1,023
Net impact on reported profit and loss
12
—
372
(2)
5
167
554
–  Significant revenue items
12
—
269
(1)
(1)
(69)
210
–  Significant cost items
—
—
103
(1)
6
236
344
Adjusted profit/(loss) before tax
(8)
589
99
490
323
84
1,577
31 Dec 20201
Reported profit/(loss) before tax
17
55
(918)
37
(173)
(632)
(1,614)
Net impact on reported profit and loss
3
—
866
115
41
405
1,430
–  Significant revenue items
2
—
187
1
—
(93)
97
–  Significant cost items
1
—
679
114
41
498
1,333
Adjusted profit/(loss) before tax
20
55
(52)
152
(132)
(227)
(184)
1A change in reportable segments was made in 2021. Comparatives data have been re-presented accordingly. For further guidance, refer to
Note 9: Segmental Analysis on page 138.
HSBC Bank plc Annual Report and Accounts 2021
15
Adjusted performance
Adjusted profit before tax was £1,577m compared with a loss
before tax of £(184)m in 2020, up £1,761m. This reflected lower
ECL, a strong revenue performance and lower operating expenses.
There was also a gain in our share of profit in associates and joint
ventures compared with a loss in 2020. ECL were significantly
lower mainly reflecting an improvement in the economic outlook
from 2020. Adjusted revenue performance was stronger largely
driven by the impact of volatile items including favourable market
impacts on insurance manufacturing in WPB and favourable
valuation adjustments in MSS. Adjusted operating expenses were
lower as a result of our transformation plans and continued
prudent management of discretionary spend. This was partly
offset by the UK bank levy which incurred in 2021.
Adjusted revenue increased by £333m or 6%, partly offset by
unfavourable movements in foreign exchange. Excluding this,
revenue increased primarily in WPB, MSS and Corporate Centre.
The increase in WPB reflected favourable market impacts on
insurance manufacturing as equity markets performance remained
strong compared with 2020, which was heavily impacted by the 
Covid-19 pandemic. In MSS, adjusted revenue was higher driven
by lower adverse credit and funding valuations and continued
momentum in Equities performance, partly offset by lower
revenue in Global FX driven by lower market volatility. Revenue
also increased in Corporate Centre, primarily due to a fair value
gain from a long-standing investment in a Germany-based
company. There were also gains from disposals in Legacy Credit.
Adjusted ECL were £982m lower compared with 2020. There
was a net release of £174m compared with a net charge of £808m
in 2020. In 2021, there were releases of stage 1 and 2 provisions
reflecting an improvement in the economic outlook and a
stabilisation of credit risk, compared with a significant build-up of
allowances in the first half of 2020 at the onset of the Covid-19
outbreak. There were also lower charges against specific
wholesale customers during 2021 compared with 2020.
Adjusted operating expenses decreased by £254m or 5%, in
part due to favourable movements in foreign exchange. Excluding
this, operating expenses decreased as we reviewed and re-
prioritised spend aligning with our transformation plans and to
reflect the economic outlook. This resulted in a reduction in FTE,
tight control of contractor and consultancy spend as well as lower
discretionary spend. This decrease was partly offset by the UK
bank levy booked in 2021, which was previously paid by the
Group.
Share of profit/(loss) in associates and joint ventures was a
profit of £191m compared with a loss of £(1)m in 2020. Profit in
2021 included a £93m true-up of prior year valuations in the
underlying investments of an associate.
Markets and Securities Services
Adjusted loss before tax was £(8)m compared to a profit before
tax of £20m, down £28m compared with 2020. This was driven by
higher operating expenses, largely offset by higher revenue.
Revenue increased by £87m or 4%, mainly driven by lower
adverse credit and funding valuations compared with 2020 and a
stronger performance in Equities, notably in structured derivatives,
driven by higher market volatility. This was partly offset by lower
revenue in Global FX as, in 2020, there was an exceptional level of
volatility and client activity driven by the onset of the Covid-19
outbreak.
Operating expenses increased by £115m or 6%, largely driven
by an increase in performance-related pay reflecting higher
revenue and a higher Single Resolution Fund ('SRF') levy in France
and Germany. This was partly offset by a reduction in staff costs
resulting from our transformation cost-saving initiatives.
Global Banking
Adjusted profit before tax was £589m, an increase of £533m
compared with 2020, largely driven by lower ECL, partly offset by
higher operating expenses.
Revenue decreased by £14m or 1%, mainly driven by
unfavourable movements in foreign exchange. Excluding this,
revenue remained broadly stable compared with 2020. This was
despite a reduction in interest rates in the first half of 2020 and
lower customer balances in 2021, reflecting actions taken to
reduce RWAs as part of our transformation. Revenue in 2020
included mark-to-market losses which were not repeated in 2021.
ECL net credit of £139m compared to a net charge of £448m in
2020. The net credit in 2021 mainly reflected releases of stage 1
and stage 2 allowances as the economic outlook improved. This
compared with the significant build-up of charges in 2020
resulting from the deterioration in the economic situation due to
the Covid-19 outbreak.
Operating expenses were £40m or 5% higher compared with
2020, mainly driven by higher performance-related pay, partly
offset by a reduction in staff costs resulting from our
transformation cost-saving initiatives. 
Global Banking and Markets Other
Adjusted profit before tax was £99m, compared with a loss before
tax of £(52)m in 2020. This was largely driven by lower operating
expenses and gains from disposals in Principal Investments ('PI').
Revenue decreased by £45m or 7%, mainly driven by lower
intercompany cost recoveries which resulted from a change in
billing methodology of GBM costs, where recharges and
recoveries were moved to other entities in the Group (with an
offsetting reduction in operating expenses). This was partly offset
by higher revenue in PI driven by gains following disposals of a
number of funds in 2021 compared with losses in 2020.
Operating expenses decreased by £187m or 28% compared
with 2020, including the move of certain GBM costs from the bank
to other entities in the Group (offset by lower intercompany
recoveries in revenue). In addition, there was a reduction in staff
costs and performance-related pay resulting from our
transformation initiatives. This was partly offset by the UK bank
levy incurred in 2021.
Commercial Banking
CMB performed well in 2021 as we continued to implement our
strategy to focus on serving our international customers.
Adjusted profit before tax was £490m, up by £339m compared
with 2020. This was mainly driven by lower ECL and lower
operating expenses, partly offset by lower revenue.
Revenue decreased by £38m or 3% compared with 2020. This
was primarily in Credit and Lending due to lower customer
balances reflecting actions taken to reduce RWAs as part of
transformation. Revenue also decreased in GLCM driven by the
lower interest rate environment despite growth in average deposit
balances. This was partly offset by an increase in revenue
allocated from Markets Treasury. 
ECL net credit of £7m compared with a net charge of £322m in
2020. The net credit in 2021 largely reflected releases of stage 1
and stage 2 allowances reflecting the improved economic outlook.
In 2020, there was significant build-up of charges resulting from
the deterioration in the economic situation driven by the Covid-19
outbreak. In addition, stage 3 charges were lower compared with
2020.
Operating expenses decreased by £47m or 7%, mainly driven by
a reduction in staff costs resulting from transformation initiatives.
There were also lower corporate real estate costs due to lower
depreciation as certain assets have been fully written down.
Wealth and Personal Banking ('WPB')
Adjusted profit before tax of £323m, up £456m compared with
2020. This was primarily due to higher revenue, lower operating
expenses and lower ECL.
Revenue increased by £241m or 19%, mainly in insurance
manufacturing in France and in the UK, largely from positive
market impacts, notably on PVIF, driven by favourable equity
market performance and higher interest rate yields on insurance
contracts. This partly offset by lower revenue in Retail in France
Strategic Report | Financial summary
16
HSBC Bank plc Annual Report and Accounts 2021
and in the Channel Islands and Isle of Man, mainly from deposits
due to the low interest rate environment, despite growth in
average balances.
ECL net credit of £23m compared with a net charge of £39m in
2020. This mainly reflected an improvement in the economic
outlook from 2020.
Operating expenses decreased by £152m or 23%. This was
driven by the non-recurrence of an impairment of real estate
assets in France in 2020. In addition, there were lower technology
costs and lower corporate real estate costs due to lower
depreciation as certain assets have been fully written down.
Corporate Centre
Adjusted profit before tax of £96m compared with a loss before
tax of £227m in 2020. This was mainly driven by a profit in
associates and joint ventures compared with a loss in 2020, lower
operating expenses and higher revenue.
Revenue was higher by £104m, primarily driven by gains on
portfolio disposals in Legacy Credit compared with losses in 2020.
The increase was also driven by a fair-value gain from a long-
standing investment in a Germany-based brokerage company.
ECL net charge of £2m in 2021 compared with a net release of
£5m in 2020, mainly driven by losses in Legacy Credit following
disposals.
Operating expenses decreased by £22m or 26%, largely driven
by lower intercompany recharges from other entities in the Group,
with an offsetting decrease in revenue. 
Shares of profit/(loss) in associates and joint ventures was a
profit of £191m, of which £93m was due to a true-up of prior year
valuations in the underlying investments of an associate. This
compared with a loss of £(1)m in 2020.
Dividends
The consolidated reported profit for the year attributable to the
shareholders of the bank was £1,041m.
No dividend in respect of 2021 was declared on the ordinary share
capital during the year.
Further information about the results is given in the consolidated income
statement on page 108.
Review of business position
Summary consolidated balance sheet at 31 Dec
2021
2020
£m
£m
Total assets
596,611
681,150
–  cash and balances at central banks
108,482
85,092
–  trading assets
83,706
86,976
–  financial assets designated and otherwise mandatorily measured at fair value through profit or loss
18,649
16,220
–  derivatives
141,221
201,210
–  loans and advances to banks
10,784
12,646
–  loans and advances to customers
91,177
101,491
–  reverse repurchase agreements – non-trading
54,448
67,577
–  financial investments
41,300
51,826
–  other assets
46,844
58,112
Total liabilities
572,896
657,301
–  deposits by banks
32,188
34,305
–  customer accounts
205,241
195,184
–  repurchase agreements – non-trading
27,259
34,903
–  trading liabilities
46,433
44,229
–  financial liabilities designated at fair value
33,608
40,792
–  derivatives
139,368
199,232
–  debt securities in issue
9,428
17,371
–  liabilities under insurance contracts
22,264
22,816
–  other liabilities
57,107
68,469
Total equity
23,715
23,849
Total shareholders’ equity
23,584
23,666
Non-controlling interests
131
183
Total reported assets were 12.4% lower than at 31 December
2020. The group maintained a strong and liquid balance sheet with
the ratio of customer advances to customer accounts decreasing
to 44.4% from 52.0% as at 31 December 2020 driven by ongoing
loan book optimisation efforts.
Assets
Cash and balances at central banks increased by 27.5% as a result
of increased customer deposits and decreased reverse repurchase
agreements and advances to customers positions.
Trading assets and financial assets designated at fair value slightly
reduced due to changes in business and product mix during the
year.
Derivative assets decreased by 29.8% due to a combination of
market movement and trades compression and novation.
Non-trading reverse repurchase agreements decreased by 19.4%
primarily due to changes in market conditions.
Financial investments decreased by 20.3% as a result of
optimisation strategy.
Liabilities
Customer accounts increased by 5.2%, which is consistent with
our funding strategy to grow customer deposits and increase
stable funding.
Total of trading liabilities and financial liabilities designated at fair
value balances has decreased by 5.9%.
Debt securities in issue decreased by 45.7% in line with the
funding strategy.
Non-trading repurchase agreements decreased by 21.9% as a
result of market activities.
Derivative liabilities decreased by 30.0%. This is in line with
derivative assets as the underlying risk is broadly matched.
Equity
Total shareholder's equity remained broadly unchanged as
compared to 2020.
HSBC Bank plc Annual Report and Accounts 2021
17
Net interest margin
Net interest margin is calculated by dividing net interest income as
reported in the income statement by the average balance of
interest-earning assets. Average balances are based on daily
averages of the group’s activities.
Net interest income
2021
2020
£m
£m
Interest income
3,149
4,086
Interest expense
(1,395)
(2,188)
Net interest income
1,754
1,898
Average interest-earning assets
354,324
369,617
%
%
Gross interest yield1
0.51
0.74
Less: gross interest payable1
(0.01)
(0.27)
Net interest spread2
0.50
0.47
Net interest margin3
0.50
0.51
1Gross interest yield is the average annualised interest rate earned on average interest-earning assets (‘AIEA’). Gross interest payable is the average
annualised interest cost as a percentage of average interest-bearing liabilities.
2Net interest spread is the difference between the average annualised interest rate earned on AIEA, net of amortised premiums and loan fees, and
the average annualised interest rate payable on average interest-bearing liabilities.
3Net interest margin is net interest income expressed as an annualised percentage of AIEA.
Summary of interest income by asset type
2021
2020
Average
balance
Interest
income
Yield1
Average
balance
Interest
income
Yield1
£m
£m
%
£m
£m
%
Short term funds and loans and advances to banks
119,025
(221)
(0.19)
90,841
(113)
(0.12)
Loans and advances to customers
99,151
1,585
1.60
116,518
2,058
1.77
Reverse repurchase agreements – non-trading
57,630
(132)
(0.23)
68,573
22
0.03
Financial investments
45,142
497
1.10
51,335
652
1.27
Other interest-earning assets
33,376
67
0.20
42,350
118
0.28
Total interest-earning assets
354,324
1,796
0.51
369,617
2,737
0.74
1Interest yield calculations include negative interest on assets recognised as interest expense in the income statement.
Summary of interest expense by type of liability and equity
2021
2020
Average
balance
Interest
expense
Cost1
Average
balance
Interest
expense
Cost1
£m
£m
%
£m
£m
%
Deposits by banks
32,891
(186)
(0.57)
28,812
(60)
(0.21)
Customer accounts
150,048
95
0.06
143,807
321
0.22
Repurchase agreements – non-trading
32,916
(192)
(0.58)
38,829
(129)
(0.33)
Debt securities in issue – non-trading
38,727
258
0.67
52,781
546
1.03
Other interest-bearing liabilities
36,811
68
0.18
47,384
160
0.34
Total interest-bearing liabilities
291,393
43
0.01
311,613
838
0.27
1Interest payable calculations include negative interest on liabilities recognised as interest income in the income statement.
Strategic Report | Financial summary
18
HSBC Bank plc Annual Report and Accounts 2021
Risk overview
The group continuously identifies and monitors risks. This process,
which is informed by its risk factors and the results of its stress
testing programme, gives rise to the classification of certain
financial and non-financial risks. Changes in the assessment of
these risks may result in adjustments to the group’s business
strategy and, potentially, its risk appetite.
Our banking risks include credit risk, treasury risk, market risk,
resilience risk, regulatory compliance risk, financial crime and
fraud risk and model risk. We also incur insurance risk. In addition
to these banking risks, we have identified top and emerging risks
with the potential to have a material impact on our financial
results, or reputation and the sustainability of our long-term
business model.
The exposure to our risks and risk management of these are
explained in more detail in the Risk section of the Report of the
Directors on pages 21 to 87.
During 2021, a number of changes to our top and emerging risks
have been made, to reflect the revised assessment of their effect
on the group. Some risks were removed towards the end of 2021
as current concerns in these areas were considered as having
been absorbed effectively into business as usual risk management
practices. These risks were the UK’s exit from the EU, market
illiquidity and Covid-19. Covid-19 has been maintained as an Area
of Special Interest reflecting the continued impact of the pandemic
on our operations in 2021.
Environmental, social and governance also replaced Climate-
related risks to cover the wider scope of climate, nature and
human rights risks.
Risk
Mitigants
Externally driven
Geopolitical risk
p
We continually assess the impact of geopolitical events, including the ongoing impacts of the Covid-19 pandemic, on our
businesses and exposures across the group, and take steps to mitigate them, where required and possible, to help ensure we
remain within our risk appetite. The relationship between the UK and the EU may come under more severe strain in 2022 over
multiple disputes, most notably the Northern Ireland Protocol and possible triggering of Article 16 that could have potential
repercussions on the terms of trade between the UK and the EU. We will continue to work with regulators, governments and our
customers to manage the risks created by the UK's exit from the EU as they arise, particularly across those industry sectors most
impacted. In addition with tensions continuing to rise between Russia and Ukraine, we will continue to monitor the development of
this situation and any potential implications for the group.
Cyber threat
and
unauthorised
access to
systems
u
We protect the group and our customers by strengthening our cyber defences, helping us to execute our business priorities safely
and keep our customers’ information secure. We employ a defence in depth approach to cyber security and continue to focus on
controls to prevent, detect and mitigate the impacts of persistent and increasingly advanced cyber threats with a specific emphasis
on vulnerability management, malware defences, protections against unauthorised access and third-party risk. We closely monitor
the continued dependency on widespread remote working and online facilities.
Regulatory
focus on
conduct of
business
u
We proactively monitor for regulatory developments to ensure they are interpreted and implemented effectively and in a timely
way. We engage with regulators, policy makers and standard setters as appropriate, to help make a positive contribution to the
evolving regulatory landscape. We also track closely the key themes currently driving the regulatory compliance agenda, which
include: consumer protection and customer vulnerability; the impact of digital services and innovation; Ibor transition; regulatory
reporting obligations; mitigating the risk of inappropriate market conduct; and environmental, social and governance ('ESG')
matters, with a particular focus on climate change, diversity and inclusion considerations and enhancements to ESG disclosure
and reporting obligations.
Financial crime
and fraud risk
u
We continued to support our customers as the Bank’s financial crime landscape evolved due to the Covid-19 pandemic and as
broad geopolitical, socioeconomic and technological shifts happened across our markets. We continued to make improvements to
our financial crime controls as emerging risks were identified and to invest in advanced analytics and artificial intelligence as key
elements of our next generation of tools to fight financial crime.
Ibor transition
u
We remain focused on completing the system and product updates to support the transition of demising Libor benchmarks, in
particular US dollar Libor. We continue to support the transition of all legacy contracts referencing demised and demising Ibor
benchmarks, including from any sterling or Japanese yen contracts using ‘synthetic’ Libor. Throughout 2022 there will be an
increasing focus on customer engagement for US dollar Libor related transition activities.
Environmental,
social and
governance
p
We continue to develop our approach to managing ESG risk, noting that the risk has increased owing to the pace and volume of
regulatory developments globally, with the focus on formalising climate risk management, enhanced disclosures, and integration
of other ESG risks such as nature-related risks and human rights. Some stakeholders are also placing more emphasis on financial
institutions’ actions and investment decisions in respect of ESG.
Internally driven
People risk
p
We monitor workforce capacity and capability requirements in line with our published growth strategy. We have put in place
measures to support our people to work safely during the Covid-19 pandemic, and to integrate them back into the workplace as
government restrictions ease. We monitor people risks that may arise due to business transformation to help sensitively manage
redundancies and support impacted employees. People Risk is heightened as a result of the ongoing pandemic conditions,
including long periods of working from home, and impacts from our transformation programme. This has affected our staff's
resilience, wellbeing and level of engagement over time, with increased attrition seen in some areas of our business.
IT systems
infrastructure
and resilience
u
We continue to monitor and improve our IT systems and network resilience, both on our premises and on the Cloud to minimise
service disruption and improve customer experience. To support the business strategy, we strengthened our end to end
management, build and deployment controls and system monitoring capabilities. We continue to seek to reduce the complexity of
our technology estate and consolidate our core banking systems onto a single strategic platform.
HSBC Bank plc Annual Report and Accounts 2021
19
Risk
Mitigants
Internally driven
Execution risk
p
We monitored and managed our change execution risk, including capacity and resources to meet the increased delivery demand
across both strategic transformation projects, regulatory deliverables and remediation activities throughout 2021. Our
transformation programme continues to oversee all initiatives mobilised to deliver the commitments made to restructure the
business and reduce costs by the end of 2022. Execution risk is heightened by the inter-dependencies between projects within our
transformation programme, which are primarily centred on France and Germany. A number of these initiatives impact our
colleagues and are supported by increased levels of investment in technology. We are working to strengthen our change
management practices to deliver sustainable change efficiently and safely, aligned to a new Group change framework launched
during the first half of 2021.
Model risk
u
We continue to strengthen our oversight of models. Our model risk policy is fully embedded, including updated controls around
the monitoring and use of models. New model risk appetite measures have been rolled out which are more forward looking and
will help our businesses and functions manage model risk more effectively. Redevelopment of capital models to reflect the
evolving regulatory requirements are also either in progress or pending regulatory approval for implementation.
Data
management
u
We protect our customers and organisation by making focused investments in capabilities that manage data risk. We focus on
controls that manage data governance, usage, integrity, privacy and retention. During 2021, we refreshed our data strategy and
continued to improve our approach to data risk management and reporting.
Third party risk
management
u
We continually enhance our third-party risk management framework as our supply chain evolves, and to stay aligned to the latest
regulatory expectations. We closely monitor for Covid-19-related impacts on the delivery of services to the group, with businesses
and functions taking appropriate action where needed.
p
Risk has heightened during 2021
u
Risk remains at the same level as 2020
On behalf of the Board
Dave Watts, Director
21 February 2022
Registered number 00014259
Strategic Report | Risk overview
20
HSBC Bank plc Annual Report and Accounts 2021
Risk
Page
Our approach to risk
Our risk appetite
Risk management
Key developments and risk profile
Top and emerging risks
Externally driven
Internally driven
Areas of special interest
Risks related to Covid-19
Climate-related risks
Our material banking and insurance risks
Credit risk
Treasury risk
Capital risk in 2021
Market risk
Resilience risk
Regulatory compliance risk
Financial crime risk
Model risk
Insurance manufacturing operations risk
.
Our approach to risk
Our risk appetite
We recognise the importance of a strong culture, which refers to
our shared attitudes, values and standards that shape behaviours
related to risk awareness, risk taking and risk management. All our
people are responsible for the management of risk, with the
ultimate accountability residing with the Board.
We seek to build our business for the long term by balancing
social, environmental and economic considerations in the
decisions we make. Our strategic priorities are underpinned by our
endeavour to operate in a sustainable way. This helps us to carry
out our social responsibility and manage the risk profile of the
business. We are committed to managing and mitigating climate-
related risks, both physical and transition, and continue to
incorporate consideration of these into how we manage and
oversee risks internally and with our customers.
The following principles guide the group’s overarching appetite for
risk and determine how our businesses and risks are managed.
Financial position
•Strong capital position, defined by regulatory and internal
ratios.
•Liquidity and funding management for each entity on a stand-
alone basis.
Operating model
•Ambition to generate returns in line with our risk appetite and
strong risk management capability.
•Ambition to deliver sustainable earnings and appropriate
returns for shareholders.
Business practice
•Zero tolerance for knowingly engaging in any business, activity
or association where foreseeable reputational risk or damage
has not been considered and/or mitigated.
•No appetite for deliberately or knowingly causing detriment to
consumers arising from our products and services or incurring
a breach of the letter or spirit of regulatory requirements.
•No appetite for inappropriate market conduct by a member of
staff or by any group business.
Enterprise-wide application
Our risk appetite encapsulates consideration of financial and non-
financial risks and is expressed in both quantitative and qualitative
terms. It is applied at the global business level, at the group level
and to material European entities.
Our risk management framework
An established risk governance framework and ownership
structure ensures oversight of, and accountability for, the effective
management of risk within the group. HSBC's Risk Management
Framework ('RMF') fosters the continuous monitoring of the risk
environment and an integrated evaluation of risks and their
interactions. Integral to the RMF are risk appetite, stress testing
and the identification of emerging risks.
The bank’s Risk Committee focuses on risk governance and
provides a forward-looking view of risks and their mitigation. The
Risk Committee is a committee of the Board and has responsibility
for oversight and advice to the Board on, amongst other things,
the bank’s risk appetite, tolerance and strategy, systems of risk
management, internal control and compliance. Additionally,
members of the Risk Committee attend meetings of the
Chairman’s Nominations and Remuneration Committee at which
the alignment of the reward structures to risk appetite is
considered.
In carrying out its responsibilities, the Risk Committee is closely
supported by the Chief Risk Officer, the Chief Financial Officer, the
Head of Internal Audit and the Head of Compliance, together with
other business functions on risks within their respective areas of
responsibility.
Responsibility for managing both financial and non-financial risk
lies with our people. They are required to manage the risks of the
business and operational activities for which they are responsible.
We maintain oversight of our risks through our various specialist
Risk Stewards, as well as the accountability held by the Chief Risk
Officer. Non-financial risk includes some of the most material risks
HSBC faces, such as cyber-attacks, poor customer outcomes and
loss of data. Actively managing non-financial risks is crucial to
serving our customers effectively and having a positive impact on
society. During 2021 we continued to strengthen the control
environment and our approach to the management of non-
financial risks, as is broadly set out in our risk management
framework. The management of non-financial risk focuses on
governance and risk appetite, providing a single view of the non-
financial risks that matter most, and associated controls. It
incorporates a risk management system designed to enable the
active management of non-financial risk. Our ongoing focus is on
simplifying our approach to non-financial risk management, while
driving more effective oversight and better end-to-end
identification and management of non-financial risks. This is
overseen by the Operational and Resilience Risk function, headed
by the Group Head of Operational and Resilience Risk.
Three lines of defence
To create a robust control environment to manage risks, we use
an activity-based three lines of defence model, whereby the
activity a member of staff undertakes drives which line they reside
within. This model delineates management accountabilities and
responsibilities for risk management and the control environment.
The model underpins our approach to risk management by
clarifying responsibility, encouraging collaboration and enabling
efficient coordination of risk and control activities. The three lines
are summarised below:
•The first line of defence owns the risks and is responsible for
identifying, recording, reporting and managing them, and
ensuring that the right controls and assessments are in place to
mitigate them.
•The second line of defence challenges the first line of defence
on effective risk management, and provides advice and
guidance in relation to the risk.
HSBC Bank plc Annual Report and Accounts 2021
21
•The third line of defence is our Internal Audit function, which
provides independent assurance that the group’s risk
management approach and processes are designed and
operating effectively. 
Risk appetite
We formally articulate our risk appetite through our risk appetite
statement ('RAS'), which is approved by the Board on the
recommendation of the Risk Committee. Setting out our risk
appetite ensures that planned business activities provide an
appropriate balance of return for the risk we are taking, and that
we agree a suitable level of risk for our strategy. In this way, risk
appetite informs our financial planning process and helps senior
management to allocate capital to business activities, services and
products.
The RAS consists of qualitative statements and quantitative
metrics, covering financial and non-financial risks. It is
fundamental to the development of business line strategies,
strategic and business planning and senior management balanced
scorecards. Performance against the RAS is reported to the Risk
Management Meeting ('RMM') so that any actual performance
that falls outside the approved risk appetite is discussed and
appropriate mitigating actions are determined. This reporting
allows risks to be promptly identified and mitigated, and informs
risk-adjusted remuneration to drive a strong risk culture.
.
Risk management
As a provider of banking and financial services, the group actively
manages risk as a core part of its day-to-day activities. It continues
to maintain a strong liquidity position and is well positioned for the
evolving regulatory landscape.
Stress testing
Stress testing is an important tool that is used by banks, as part of
their internal risk management, and regulators to assess
vulnerabilities in individual banks and/or the financial banking
sector under hypothetical adverse scenarios. The results of stress
testing are used to assess banks’ resilience to a range of adverse
shocks and to assess their capital adequacy.
HSBC Bank plc is subject to regulatory stress testing in several
jurisdictions. These requirements are increasing in frequency and
granularity. They include the programmes of the Bank of England
(‘BoE’), Prudential Regulation Authority (‘PRA’) and the European
Banking Authority (‘EBA’). Assessment by regulators is on both a
quantitative and qualitative basis, the latter focusing on our
portfolio quality, data provision, stress testing capability and
capital planning processes.
A number of internal macroeconomic and event-driven scenarios
specific to the European region were considered and reported to
senior management during the course of the year. The selection of
stress scenarios is based upon the output of our top and emerging
risks identified and our risk appetite. The results help the Board
and senior management to set our risk appetite and confirm the
strength of our strategic and financial plans. Our risk appetite is
set at a level that enables the group to withstand future stress
impacts.
In 2021, the Group participated in the successful completion of the
BoE solvency stress testing exercise. The Solvency Stress Test
Scenario depicts a synchronised, global, double-dip recession in
2021, driven by a continuation and intensification of economic and
financial shocks experienced in 2020 as a result of the Covid-19
pandemic. Unemployment rises sharply in the stress, with certain
sectors such as hospitality, leisure, construction and transport
more affected than others.
Traded risk shocks are consistent with the macro-economic
scenario. The global stress causes financial market participants’
perceptions of risk to increase, and their risk appetite to diminish.
The traded risk shocks are lower than those included in the 2019
exercise. This is, in part, because of a smaller rise in risk premia in
the stress scenario given an expectation from market participants
that markets remain functional despite the broader
macroeconomic stress.
The BoE published the results of the 2021 Solvency Stress Test in
December 2021, confirming that these tests did not reveal any
capital inadequacies for the HSBC Group. In 2021, the Group
participated also in the Climate Biennial Exploratory Scenario
('CBES') exercise of BoE.
The CBES objective was to test the resilience of the UK financial
system to the physical and transition risks associated with
different climate pathways. The BoE has indicated that CBES was
a learning exercise for both participating banks and the BoE. CBES
will not be used to set capital requirements but to understand the
collective impact on the wider economy and also explore
vulnerabilities of current business models to future climate policy
pathways and how the Group is expected to adjust it's business
models in response to these climate change impacts.
Key developments and risk profile
Key developments in 2021
We continued to actively manage the risks resulting from the
Covid-19 pandemic and its impacts on our customers and
operations during 2021, as well as other key risks described in this
section. In addition, we enhanced our risk management in the
following areas:
•We streamlined the articulation of our risk appetite framework,
providing further clarity on how risk appetite interacts with
strategic planning and recovery planning processes.
•We continued to simplify our approach to non-financial risk
management, with the implementation of more effective
oversight tools and techniques to improve end-to-end
identification and management of these risks.
•We accelerated the transformation of our approach to
managing financial risks across the businesses and risk
functions, including initiatives to enhance portfolio monitoring
and analytics, credit risk, traded risk and treasury risk
management, as well as the models used to manage financial
risks.
•We are progressing with a comprehensive regulatory reporting
programme to strengthen our processes, improve consistency,
and enhance controls.
•We continued to enhance our approach to portfolio and
concentration risk management, through clearly defined roles
and responsibilities, and improving our data and management
information reporting capabilities.
•We continued the development of our climate risk
management capabilities. Our climate risk programme will
shape our approach to climate risk across four key pillars:
governance and risk appetite; risk management; stress testing;
and disclosures. We enhanced our risk appetite statement with
quantitative climate risk metrics.
•We continued to improve the effectiveness of our financial
crime controls with a targeted update of our fraud controls. We
refreshed our financial crime and fraud policies, ensuring they
remained up to date and addressed changing and emerging
risks, and we continued to meet our regulatory obligations.
•We introduced enhanced governance and oversight around
model adjustments and related processes for IFRS 9 models.
Top and emerging risks
Top and emerging risks are those that may impact on the financial
results, reputation or business model of the bank. If these risks
were to occur, they could have a material effect on the group. The
exposure to these risks and our risk management approach are
explained in more detail below.
Report of the Directors | Risk
22
HSBC Bank plc Annual Report and Accounts 2021
Externally driven
Geopolitical risk
Our operations and portfolios are exposed to risks associated with
political instability, civil unrest and military conflict, which could
lead to disruption of our operations, physical risk to our staff and/
or physical damage to our assets.
We will increasingly need to consider potential regulatory,
reputational and market risks arising from the evolving geopolitical
landscape.
The Covid-19 pandemic brought supply chain issues into focus
and has heightened geopolitical tensions, which could have
potential ramifications for the group and our customers.
Tensions between Russia and the US and a number of European
states have heightened significantly following the escalation of
hostilities between Russia and Ukraine. While negotiations are
ongoing to seek a resolution, a continuation of or any further
deterioration to the situation could have significant geopolitical
implications, including economic, social and political
repercussions on the group and its customers. In addition, the US,
the UK and the EU have threatened a significant expansion of
sanctions and trade restrictions against Russia in the event of a
Russian incursion into Ukraine, and Russian countermeasures are
also possible.
Political disagreements between the UK and the EU, notably over
the future operation of the Northern Ireland Protocol, has meant
work on the creation of a framework for voluntary regulatory
cooperation in financial services following the UK’s withdrawal
from the EU has stalled. While negotiations are continuing, it is
unclear whether or when an agreement will be reached, and this
has led to speculation that the UK may trigger Article 16 of the
Protocol, which could suspend the operation of the Protocol in
certain respects. Any decision to do so could be met with
retaliatory action by the EU, complicating the terms of trade
between the UK and the EU and potentially preventing progress in
other areas such as financial services. 
Mitigating actions
•We closely monitor geopolitical and economic developments in
key markets and sectors and undertake scenario analysis where
appropriate. This helps us to take portfolio actions where
necessary, including enhanced monitoring, amending our risk
appetite and/or reducing limits and exposures.
•We stress test portfolios of particular concern to identify
sensitivity to loss under a range of scenarios, with management
action being taken to rebalance exposures and manage risk
appetite where necessary.
•We regularly review key portfolios to help ensure that individual
customer or portfolio risks are understood and our ability to
manage the level of facilities offered through any downturn is
appropriate.
•We continue to monitor geopolitical tensions involving Russia
and Ukraine and any potential impacts on the group and our
customers.
•We continue to monitor the UK’s relationship with the EU, and
assess the potential impact on our people, operations and
portfolios.
•We have taken steps, where necessary, to enhance physical
security in those geographical areas deemed to be at high risk
from terrorism and military conflicts.
Cyber threat and unauthorised access to systems
We continue to operate in a challenging cyber threat environment,
which requires ongoing investment in business and technical
controls to defend against these threats. 
Key threats include unauthorised access to our data, advanced
malware attacks, attacks on third-party suppliers and security
vulnerabilities being exploited.
Mitigating actions
•We continually evaluate threat levels for the most prevalent
attack types and their potential outcomes. To further protect
our business and our customers we strengthened our controls
to reduce the likelihood and impact of advanced malware, data
leakage, exposure through third parties and security
vulnerabilities.
•We continue to enhance our cybersecurity capabilities,
including cloud security, identity and access management,
metrics and data analytics, and third-party security reviews. An
important part of our defence strategy is ensuring our people
remain aware of cybersecurity issues and know how to report
incidents.
•We report and review cyber risk and control effectiveness
regularly at executive and non-executive Board level. We also
report it across our businesses and functions, to help ensure
appropriate visibility and governance of the risk and mitigating
actions.
•We participate globally in several industry bodies and working
groups to share information about tactics employed by cyber-
crime groups and to collaborate in fighting, detecting and
preventing cyber-attacks on financial organisations.
Regulatory focus on conduct of business
We keep abreast of the emerging regulatory compliance and
conduct agenda, which currently includes, but is not limited to:
ESG matters; operational resilience; how digital and technology
changes, including payments, are impacting financial institutions;
how we are ensuring good customer outcomes, including
addressing customer vulnerabilities; regulatory reporting; and
employee compliance. We monitor regulatory developments
closely and engage with regulators, as appropriate, to help ensure
new regulatory requirements are implemented effectively and in a
timely way.
The competitive landscape in which we operate may be impacted
by future regulatory changes and government intervention. In the
UK, potential regulatory developments include any legislative
changes resulting from a statutory review for ring-fencing, which
has been undertaken by an independent panel appointed by HM
Treasury. The panel has recommended several adjustments to the
regime and HM Treasury is reviewing these recommendations.
Legislative amendments may be proposed in due course.
Mitigating actions
•We monitor for regulatory developments to understand the
evolving regulatory landscape and respond with changes in a
timely way.
•We engage, wherever possible, with governments and
regulators to make a positive contribution to regulations and
ensure that new requirements are considered properly and can
be implemented effectively. We hold regular meetings with
relevant authorities to discuss strategic contingency plans,
including those arising from geopolitical issues. 
•We launched our simplified conduct approach to align to our
new purpose and values, in particular the value ‘we take
responsibility’.
Financial crime and fraud risk
Financial institutions remain under considerable regulatory
scrutiny regarding their ability to prevent and detect financial
crime. The financial crime threats we face have continued to
evolve, often in tandem with broader geopolitical, socioeconomic
and technological shifts in our markets, leading to challenges such
as managing conflicting laws and approaches to legal and
regulatory regimes. Financial crime risk evolved during the
Covid-19 pandemic, notably with the manifestation of fraud risks
linked to the economic slowdown and resulting deployment of
government relief measures. The accelerated digitisation of
financial services has fostered significant changes to the payments
ecosystem, including a multiplicity of providers and new payment
mechanisms, not all of which are subject to the same level of
regulatory scrutiny or regulations as financial institutions.
HSBC Bank plc Annual Report and Accounts 2021
23
This is presenting increasing challenges to the industry in terms of
maintaining required levels of transparency, notably where
institutions serve as intermediaries. Developments around digital
assets and currencies, notably the role of stablecoins and central
bank digital currencies, have continued at pace, with an increasing
regulatory and enforcement focus on the financial crimes linked to
these types of assets.
Expectations with respect to the intersection of ESG issues and
financial crime as our organisation, customers and suppliers
transition to net zero, are increasing, not least with respect to
potential ‘greenwashing’. Companies also face a heightened
regulatory focus on both human rights issues and environmental
crimes, from a financial crime perspective. We also continue to
face increasing challenges presented by national data privacy
requirements, which may affect our ability to manage financial
crime risks holistically and effectively.
Mitigating actions
•We are strengthening our fraud and surveillance controls, and
investing in next generation capabilities to fight financial crime
through the application of advanced analytics and artificial
intelligence.
•We are looking at the impact of a rapidly changing payments
ecosystem to ensure our financial crime controls remain
appropriate for changes in customer behaviour and gaps in
regulatory coverage, including the development of procedures
and controls to manage the risks associated with direct and
indirect exposure to digital assets and currencies.
•We are assessing our existing policies and control framework
to ensure that developments in the ESG space are considered
and the risks mitigated.
•We work with jurisdictions and relevant international bodies to
address data privacy challenges through international
standards, guidance, and legislation to help enable effective
management of financial crime risk.
•We work closely with our regulators and engage in public-
private partnerships, playing an active role in shaping the
industry’s financial crime controls for the future, notably with
respect to the enhanced, and transparent, use of technology.
Ibor transition
Interbank offered rates (‘Ibors’) have historically been used
extensively to set interest rates on different types of financial
transactions and for valuation purposes, risk measurement and
performance benchmarking.
Following the UK’s Financial Conduct Authority (‘FCA’)
announcement in July 2017 that it would no longer continue to
persuade or require panel banks to submit rates for the London
interbank offered rate (‘Libor’) after 2021, we have been actively
working to transition legacy contracts from Ibors to products
linked to near risk-free replacement rates (‘RFRs’) or alternative
reference rates. In March 2021, in accordance with the 2017 FCA
announcement, ICE Benchmark Administration Limited (‘IBA’)
announced that it would cease publication of 24 of the 35 main
Libor currency interest rate benchmark settings from the end of
2021, and that the most widely used US dollar Libor settings
would cease from 30 June 2023. The FCA subsequently used its
regulatory powers to compel IBA to publish the remaining six
sterling and Japanese yen settings, from 1 January 2022, under an
amended methodology, commonly known as 'synthetic' Libor. As
a result, our focus during 2021 was on the transition of legacy
contracts referencing the Euro Overnight Index average (‘Eonia’)
and the Libor settings that demised from the end of 2021,
including those settings subsequently being published on a
'synthetic' basis.
During 2021, we continued the development of IT and RFR
product capabilities, implemented supporting operational
processes, and engaged with our clients to discuss options for the
transition of their legacy contracts. The successful implementation
of new processes and controls, as well as the transition of
contracts away from Ibors, reduced the heightened financial and
non-financial risks to which we were exposed. However, while all
but exceptional Libor contract issuance ceased in 2021, or from
the end of 2021 for US dollar Libor, we remain exposed to material
risks. These include, from so-called ‘tough legacy’ contracts, that
have not been able to be transition to a new rate and will use a
'synthetic' Libor or a contractual fallback rate, and from legacy
contracts that reference US dollar Libor, which are expected to
demise from June 2023.
Financial risks have been largely mitigated as a result of the
implementation of model and pricing changes. However,
differences in US dollar Libor and its replacement RFR, Secured
Overnight Funding Rate (‘SOFR’), create a basis risk in the trading
book and banking book due to the asymmetric adoption of SOFR
across assets, liabilities and products that we need to actively
manage through appropriate financial hedging. Additionally, the
comparatively limited use of SOFR for new RFR products to date
and lack of alignment around conventions could potentially delay
transition of some US dollar Libor contracts into 2023. This would
compress the amount of time to transition these contracts, which
could lead to heightened operational and conduct-related risk as a
result.
Additional non-financial risks, including regulatory compliance
risk, resilience risk, financial reporting risk, and legal risk also
remain for ‘tough legacy’ contracts, and the US dollar legacy
portfolio. These risks continue to be actively managed and
mitigated with a focus on ensuring that fair outcomes for our
clients are achieved.
These risks are present in different degrees across our product
offering.
Transition of Legacy contracts 
During 2021, we successfully transitioned over 90% of legacy Ibor
lending contracts in sterling, Swiss franc, euro and Japanese yen
Libor interest rates, as well as Eonia, directly or via appropriate
fallback mechanisms. The majority of the remaining contracts will
transition in advance of their next interest payment date, with only
a small proportion of ‘tough legacy’ contracts remaining. We
expect that out of approximately 1000 lending contracts there will
be less than 20 ‘tough legacy’ contracts, the majority of which will
be transitioned to alternative rates during 2022. Our approach to
transition ‘tough legacy’ and US dollar legacy Ibor contracts will
differ by product and business area, but will be based on the
lessons learned from the successful transition of contracts during
2021. We will continue to communicate with our clients and
investors in a structured manner and be client led in the timing
and nature of the transition.
For derivatives, approximately 99% of our sterling, Swiss franc,
euro and Japanese yen Libor interest rate exposures at the end of
2021 had successfully transitioned directly or via appropriate
fallback mechanisms, leaving a small number of ‘tough legacy’
contracts. There are expected to be less than 20 bilateral
derivatives trades that remain ‘tough legacy,’ the majority of
which are expected to mature or transition in 2022. We anticipate
our ‘tough legacy’ and US dollar exposure will continue to reduce
through 2022 as a result of contract maturities, and active
transition. We will continue to look to actively reduce our US dollar
exposure by transitioning trades ahead of the demise date of 30
June 2023, by working with our clients to determine their needs
and how we transition their contracts. Additionally, we are
working with market participants, including clearing houses, to
ensure we are able to transition our cleared derivative contracts as
the US dollar Libor benchmark demise date approaches.
For our loan book, approximately 85% of our reported exposure at
the end of 2021 linked to sterling, Swiss franc, euro and Japanese
yen Libor interest rate contracts that required no further client
negotiation but remained drawn on Libor as they have yet to reach
their next interest payment date. The majority of the remaining
exposure linked to benchmarks that demised from the end of 2021
relates to contracts where discussions with our clients and other
market participants, for syndicated transactions, have continued in
early 2022, in advance of their next scheduled interest payment
date, and this has led to further transitions being completed.
Report of the Directors | Risk
24
HSBC Bank plc Annual Report and Accounts 2021
A small number of 'tough legacy' contracts, less than 20, that
were unable to transition prior to their first interest payment date
in 2022, are expected to use legislative reliefs, such as ‘synthetic’
Libor, or an alternative rate determined by the contractual fallback
language and in the main will be transitioned during 2022. For the
remaining demising Ibors, notably US dollar Libor, we have
implemented new products and processes and updated our
systems in readiness for transition. Global Banking, Commercial
Banking and Global Private Banking have begun to engage with
clients who have upcoming contract maturities with a view to
refinancing using an appropriate replacement rate. Further
communications and outreach to customers with US dollar Libor
contracts with later maturities will occur in due course.
Where we hold bonds issued by other institutions, we have
remained dependent on the issuer’s agents to engage in the
transition process, although analysis will be undertaken of the
issuers in US dollar Libor bonds to reduce our exposure, as
occurred through 2021.
The completion of an orderly transition from the remaining Ibors,
notably US dollar Libor, continues to be our programme’s key
objective through 2022 and 2023, with the aim of putting systems
and processes in place to help achieve this.
Mitigating actions
•The global Ibor transition programme, which is overseen by the
Group Chief Risk and Compliance Officer, will continue to
deliver IT and operational processes to meet its objectives.
•We carry out extensive training, communication and client
engagement to facilitate appropriate selection of new rates and
products.
•We have dedicated teams in place to support the transition.
•We actively transitioned legacy contracts and ceased new
issuance of Libor-based contracts, other than those allowed
under regulatory exemptions, with associated monitoring and
controls.
•We assess, monitor and dynamically manage risks arising from
Ibor transition, and implement specific mitigating controls
when required.
•We continue to actively engage with regulatory and industry
bodies to mitigate risks relating to ‘tough legacy’ contracts.
Financial instruments impacted by IBOR reforms
Interest Rate Benchmark Reform Phase 2, the amendments to
IFRSs issued in August 2020, represents the second phase of the
IASB’s project on the effects of interest rate benchmark reform.
The amendments address issues affecting financial statements
when changes are made to contractual cash flows and hedging
relationships.
Under these amendments, changes made to a financial instrument
measured at other than fair value through profit or loss that are
economically equivalent and required by interest rate benchmark
reform, do not result in the derecognition or a change in the
carrying amount of the financial instrument. Instead they require
the effective interest rate to be updated to reflect the change in
the interest rate benchmark. In addition, hedge accounting will not
be discontinued solely because of the replacement of the interest
rate benchmark if the hedge meets other hedge accounting
criteria.
(audited)
Financial instruments yet to transition to alternative
benchmarks, by main benchmark
USD Libor
GBP Libor
EONIA
Others1
At 31 Dec 2021
£m
£m
£m
£m
Non-derivative financial assets2
Loans and advances to customers
5,999
2,562
—
26
Financial investments
1,171
140
—
—
Others
693
499
—
—
Total non-derivative financial assets
7,863
3,201
—
26
Non-derivative financial liabilities
Subordinated liabilities
1,145
—
—
—
Others
479
181
—
—
Total non-derivative financial liabilities
1,624
181
—
—
Derivative notional contract amount
Foreign exchange
8,288
1,568
—
1,080
Interest rate
1,567,577
215,377
1,679
76,059
Others
—
—
—
—
Total derivative notional contract amount
1,575,865
216,945
1,679
77,139
At 31 Dec 2020
Non-derivative financial assets2
Loans and advances to customers
7,782
4,323
1
183
Financial investments
1,187
406
—
—
Others
1,043
1,033
—
1
Total non-derivative financial assets
10,012
5,762
1
184
Non-derivative financial liabilities2
Subordinated liabilities
1,135
900
—
—
Others
798
510
3
1
Total non-derivative financial liabilities
1,933
1,410
3
1
Derivative notional contract amount
Foreign exchange
6,296
2,768
—
8,148
Interest rate
1,694,279
865,545
196,515
126,545
Others
7
—
—
—
Total derivative notional contract amount
1,700,582
868,313
196,515
134,693
1Comprises financial instruments referencing other significant demising benchmark rates (euro Libor, Swiss franc Libor, Japanese Yen Libor, SOR
and THBFIX Sibor).
2Gross carrying amount excluding allowances for expected credit losses.
3The amounts in the above table do not represent amounts at risk as the steps to transition for certain trades have been completed.
The amounts in the above table relate to the group's main
operating entities where we have material exposures impacted by
Ibor reform, including in the United Kingdom, France and
Germany. The amounts provide an indication of the extent of the
HSBC Bank plc Annual Report and Accounts 2021
25
group’s exposure to the Ibor benchmarks that are due to be
replaced. Amounts are in respect of financial instruments that:
•contractually reference an interest rate benchmark that is
planned to transition to an alternative benchmark;
•have a contractual maturity date beyond the date by which the
reference interest rate benchmark is expected to cease; and
•are recognised on the group’s consolidated balance sheet.
In March 2021, the administrator of Libor, IBA, announced that the
publication date of most US dollar Libor tenors has been extended
from 31 December 2021 to 30 June 2023. Publication of one-week
and two-month tenors ceased after 31 December 2021. This
change, together with the extended publication dates of Sibor,
SOR and THBFIX, reduce the amounts presented at 31 December
2021 in the above table as some financial instruments included at
31 December 2020 will reach their contractual maturity date prior
to the extended publication dates. Comparative data have not
been re-presented.
Environmental, social and governance risk
We are subject to financial and non-financial risks associated with
environmental, social and governance related matters ('ESG')
which can impact us both directly and indirectly through our
customers.
Climate-related risk increased over 2021, owing to the pace and
volume of policy and regulatory changes regionally, particularly on
climate risk management, stress testing and scenario analysis and
disclosures. If we fail to meet regulatory expectations or
requirements on climate risk management, this could have
regulatory compliance and reputational impacts.
We face increased reputational, legal and regulatory risks as we
make progress towards the HSBC Group’s net zero ambition, as
stakeholders are likely to place greater focus on our actions,
disclosures and financing decisions related to this. We will face
additional risks if we are perceived to mislead stakeholders
regarding our climate strategy, the climate impact of a product or
service, or regarding the commitments of our customers.
To track and report on our progress towards achieving our
ambition, we rely on internal and external data, guided by certain
industry standards. While emissions reporting has improved over
time, data remains of limited quality and consistency.
Methodologies we have used may evolve in line with market
practice and regulation as well as due to developments in climate
science. Any developments in data and methodologies could
result in revisions, meaning that reported figures may not be
reconcilable or comparable year-on-year.  We may also have to re-
evaluate our progress towards the HSBC Group’s climate-related
ambition in future and this could result in reputational, legal and
regulatory risks.
Climate risk will also have an impact on model risk, as models play
an important role in risk management and the financial reporting
of climate-related risks. The uncertain impacts of climate change
and data limitations, present challenges to creating reliable and
accurate model outputs.
We could also face increased resilience; retail credit; and
wholesale credit risks owing to the increase in frequency and
severity of weather events and chronic shifts in weather patterns.
These risks could impact our own critical operations, resulting in
customer detriment and operational losses for the group. Our
customers’ operations and assets could also be affected, reducing
their ability to afford mortgage or loan repayments, leading to
credit risk impacts for the firm.
There is increasing evidence that a number of nature-related risks
beyond climate change – which include risks that can be
represented more broadly by economic dependence on nature –
can and will have significant economic impact. These risks arise
when the provision of natural services – such as water availability,
air quality, and soil quality – is compromised by overpopulation,
urban development, natural habitat and ecosystem loss, and other
environmental stresses beyond climate change. They can show
themselves in various ways, including through macroeconomic,
market, credit, reputational, legal and regulatory risks, for both the
group and our customers.
Mitigating actions 
•We continue to deepen our understanding of the drivers of
climate risk and managing our exposure to climate risk is a
priority. Our dedicated Climate Risk Oversight Forums are
responsible for shaping and overseeing our approach and
providing support in managing climate risk in the region.
•Our climate risk programme continues to accelerate the
development of our climate risk management capabilities
across four key pillars – governance and risk appetite, risk
management, stress testing and scenario analysis and
disclosures. We are also enhancing our approach to
greenwashing risk.
•In December 2021, the HSBC Group published its thermal coal
phase-out policy committing to phase out the financing of coal-
fired power and thermal coal mining in EU/OECD markets by
the end of 2030, and globally by the end of 2040. The policy
helps us chart the path to net zero and is a component of our
approach towards managing the climate risk of our lending
portfolio and wider banking activities.
•We have started to incorporate the outcomes and insights from
the Bank of England’s Climate Biennial Exploratory Scenario
into climate risk management, and are currently engaged in the
2022 ECB Climate Risk Stress Test.
•We have delivered climate risk training to our legal entity board
and wider target audiences.
•In 2021, we joined several industry working groups dedicated
to helping us access and manage nature-related risks, such as
the Taskforce on Nature-Related Financial Disclosure (‘TNFD’).
Our asset management business also published its biodiversity
policy to publicly explain how our analysts address nature-
related issues.
•We continue to engage with our customers, investors and
regulators proactively on the management of climate risks. We
also engage with initiatives actively, including the EU
Taxonomy disclosures, Climate Financial Risk Forum, Equator
Principles, Taskforce on Climate-related Financial Disclosures
and CDP (formerly the Carbon Disclosure Project) to drive best
practice for climate risk management.
For further details on ESG, see our ESG review on page 8 and for
further details on our approach to climate risk management, see
‘Areas of special interest’ on page 28. For further details on ESG
risk management see ‘Financial crime and fraud risk on page 23.
Internally driven
People risk
Our success in delivering our strategic priorities and managing the
regulatory environment proactively depends on the development
and retention of our leadership and high-performing employees.
The ability to continue to attract, develop and retain competent
individuals in an employment market impacted by the Covid-19
pandemic is challenging particularly due to organisational
restructuring. Changed working arrangements, local Covid-19
restrictions and health concerns during the pandemic also impact
on employee mental health and well-being.
Mitigating actions
•We have put in place measures to help support our people so
they are able to work safely during the Covid-19 pandemic.
•We promote a diverse and inclusive workforce and provide
active support across a wide range of health and wellbeing
activities. We continue to build our speak up culture through
active campaigns.
•We monitor people risks that have arisen due to organisational
restructuring, helping to ensure we manage redundancies
sensitively and support impacted employees.
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HSBC Bank plc Annual Report and Accounts 2021
•Launch of the Future Skills Curriculum through HSBC
University to help provide the critical skills that will enable
employees and HSBC to be successful in the future.
•We continue to develop succession plans for key management
roles, with actions agreed and reviewed on a regular basis by
the group's Executive Committee.
•We have robust plans in place, driven by senior management,
to mitigate the effect of external factors that may impact our
employment practices. Political, legislative and regulatory
challenges are closely monitored to minimise the impact on the
attraction and retention of talent and key performers.
IT systems infrastructure and resilience
HSBC is committed to investing in the reliability and resilience of
its IT systems and critical services. HSBC does so in order to
protect its customers and ensure they do not receive disruption to
services, which could result in reputational and regulatory
damage.
The group's strategy includes simplification of our technology
estate to reduce complexity and costs; this includes consolidation
of our core banking systems onto a single strategic platform. The
target state will leverage existing and known technology, and will
be simpler and easier to maintain. However, as with any strategic
transformation programme risks associated with implementation
must be managed continuously.
Mitigating actions
•We continue to invest in transforming how software solutions
are developed, delivered and maintained, with a particular
focus on providing high-quality, stable and secure services. As
part of this, we are concentrating on improving system
resilience and service continuity testing. We have enhanced the
security features of our software development life cycle and
improved our testing processes and tools.
•During 2021, we have upgraded many of our IT systems,
simplified our service provision and replaced older IT
infrastructure and applications. These enhancements led to
continued global improvements in service availability during
2021 for both our customers and employees.
•We manage implementation risks arising from the
simplification of our technology estate continuously via
thorough oversight of these risks at all levels of the programme
and reporting up to our Risk Committee.
Execution risk
In order to deliver our strategic objectives and meet mandatory
regulatory requirements, it is important for the group to maintain a
strong focus on execution risk. This requires robust management
of significant resource-intensive and time-sensitive programmes. 
Risks arising from the magnitude and complexity of change may
include regulatory censure, reputational damage or financial
losses. Current major initiatives include managing the operational
implications of the disposal of our French retail business, large
transformation programmes including the simplification and
integration of our IT Systems and other restructuring programmes
across Europe.
Mitigating actions
•Our prioritisation and governance processes for significant
projects are monitored by the group‘s Executive Committee.
•We continue to work to strengthen our change management
practices to deliver sustainable change, increased adoption of
Agile ways of working, and a more consistent standard of
delivery. For HSBC Bank plc, this includes embedding of an
improved Group-wide change framework released in the first
half of 2021, which sets out the mandatory principles and
standards to be adhered to when leading and delivering
change.
Model risk
Model risk arises whenever business decision-making includes
reliance on models. We use models in both financial and
non-financial contexts and in a range of business applications
such as customer selection, product pricing, financial crime
transaction monitoring, creditworthiness evaluation and financial
reporting. Assessing model performance is a continuous
undertaking. Models can need redevelopment as market
conditions change. This was required following the outbreak of
Covid-19 as some models used for estimating credit losses needed
to be redeveloped due to the significant change to inputs including
GDP, unemployment rates and housing prices; and the varying
government support measures introduced.
Prior to the Covid-19 outbreak a key area of focus was improving
and enhancing our model risk governance, and this activity
continued throughout 2021. We prioritised the redevelopment and
validation of internal ratings-based (‘IRB’) and internal models
methods (‘IMM’) models, in relation to counterparty credit, as part
of the IRB repair and Basel III programmes with a key focus on
enhancing the quality of data used as model inputs.
Mitigating actions
•We appointed model risk stewards for our key entities to
support, oversee and guide the global businesses and functions
on model risk management. The risk stewards provide close
monitoring of changes in model behaviour, working closely
with business and function model owners and sponsors.
•We worked with the model owners of IRB models and traded
risk models to increase our engagement on management of
model risk with key regulators including the PRA and the ECB.
•We embedded the model risk policy and model risk standards
in all business and functions to enable a more risk-based
approach to model risk management.
•We made further enhancements to our control framework for
models used in financial reporting processes to address the
control weaknesses that emerged as a result of significant
increases in model adjustments and overlays that were applied
to compensate for the impact of Covid-19 on models and to
introduce a requirement for the second line of defence to
approve material models prior to use.
•The model inventory system was enhanced to support the
management of model risk for multiple applications of a single
model.
•We have submitted the first set of IRB models for regulatory
approval in 2021. The redevelopment and validation of
remaining IRB and IMM models for counterparty credit and our
internal models approach (‘IMA’) for traded risk models is in
progress. Models are expected to undergo PRA approval over
the next 12 months.
Data management
We use a large number of systems and growing quantities of data
to support our customers. Risk arises if data is incorrect,
unavailable, misused, or if the privacy of our customers and
colleagues is unprotected. Along with other banks and financial
institutions, we need to meet external regulatory obligations and
laws that cover data, such as the Basel Committee on Banking
Supervisions 239 guidelines and the General Data Protection
Regulation (‘GDPR’).
Mitigating actions
•Through our global data management framework, we monitor
proactively the quality, availability and security of data that
supports our customers and internal processes. We resolve any
identified data issues in a timely manner.
•We have made improvements to our data policies and are
implementing an updated control framework to enhance the
end-to-end management of data risk by our businesses and
functions.
•We protect customer data via our data privacy framework,
which establishes practices, design principles and guidelines
that enable us to demonstrate compliance with data privacy
laws and regulations.
HSBC Bank plc Annual Report and Accounts 2021
27
•We continue to modernise our data and analytics infrastructure
through investments in Cloud technology, data visualisation,
machine learning and artificial intelligence.
•We educate our employees on data risk and data management
and have delivered global mandatory training on the
importance of protecting data and managing data
appropriately.
Third Party Risk Management
We use third parties to provide a range of services, in common
with other financial service providers. Risks arising from the use of
third-party service providers and their supply chain may be less
transparent. It is critical that we ensure we have appropriate risk
management policies, processes and practices over the selection,
governance and oversight of third parties and their supply chain,
particularly for key activities that could affect our operational
resilience. Any deficiency in the management of risks associated
with our third parties could affect our ability to support our
strategic approach and meet our customer and regulatory
expectations.
Mitigating actions
•We have enhanced our control framework for external supplier
arrangements to ensure the risks associated with third-party
arrangements are understood and managed effectively by our 
businesses and functions across the group.
•We have applied the same control standards to intra-group
arrangements as we have for external third-party arrangements
to ensure we are managing them effectively.
•We are implementing the changes required by our new third-
party risk policy to comply with new regulations as defined by
our regulators.
Areas of special interest
Risks related to Covid-19
Despite the successful roll-out of vaccines across the world, the
Covid-19 pandemic and its effect on the global economy have
continued to impact our customers and organisation. The global
vaccination roll-out in 2021 helped reduce the social and economic
impact of the Covid-19 pandemic and high vaccination rates are
enabling many countries across Europe in 2022 to ease Covid-19-
related restrictions on activity and constraints on travel. However,
the emergence of the Omicron variant in late 2021, demonstrated
the continued risk new variants pose.
The pandemic necessitated governments to respond at
unprecedented levels to protect public health, and to support local
economies and livelihoods. The resulting government support
measures and restrictions have created additional challenges,
given the rapid pace of change and significant operational
demands. Renewed outbreaks, particularly those resulting from
the emergence of variants of the virus, emphasise the ongoing
threat of Covid-19 and could result in further tightening of
government restrictions. There remains a divergence in approach
taken by countries to the level of restrictions on activity and travel.
Such diverging approaches to future pandemic waves could
prolong or worsen supply chain and international travel
disruptions.
We continue to support our personal and business customers
through market-specific measures initiated during the Covid-19
pandemic, and by supporting government schemes that focus on
the parts of the economy most impacted by the pandemic. For
further details of our customer relief programmes, see page 60.
The rapid introduction and varying nature of the government
support schemes introduced throughout the Covid-19 pandemic
has led to increased operational risks, including complex conduct
considerations, increased reputational risk and increased risk of
fraud. These risks are likely to be heightened further as and when
those government support schemes are unwound. We are focused
upon avoiding and mitigating any conduct risks that may arise
from the implementation decisions we have had to make and also
those that may be created if our customers find themselves in
financial difficulties as a result of the impact of the Covid-19
pandemic.
The impact of the pandemic on the long-term prospects of
businesses in the most vulnerable sectors of the economy – such
as retail, hospitality and commercial real estate – remains
uncertain and may lead to significant credit losses on specific
exposures, which may not be fully captured in ECL estimates. In
addition, in times of stress, fraudulent activity is often more
prevalent, leading to potentially significant credit or operational
losses.
As economic conditions improve, and government support
measures come to an end, there is a risk that the outputs of IFRS 9
models may have a tendency to underestimate loan losses. To
help mitigate this risk, model outputs and management
adjustments are closely monitored and independently reviewed for
reliability and appropriateness prior to inclusion in the financial
results.
Despite the ongoing economic recovery, significant uncertainties
remain in assessing the duration and impact of the Covid-19
pandemic, including whether any subsequent outbreaks result in a
reimposition of government restrictions. There is a risk that
economic activity remains below pre-pandemic levels for a
prolonged period, increasing inequality across markets, and it will
likely be some time before societies return to pre-pandemic levels
of social interactions. As a result, there may still be a requirement
for additional mitigating actions including further use of
adjustments, overlays and model redevelopment.
Governments and central banks in major economies have
deployed extensive measures to support their local populations.
This is expected to reverse partially in 2022. Central banks in major
markets are expected to raise interest rates, but such increases are
expected to be gradual and monetary policy is expected to remain
accommodative overall. Governments are also expected to reduce
the level of fiscal support they offer households and businesses as
the appetite for broad lockdowns and public health restrictions
decreases. Government debt has risen in most advanced
economies, and is expected to remain high into the medium term.
High government debt burdens have raised fiscal vulnerabilities,
increasing the sensitivity of debt service costs to interest rate
increases and potentially reducing the fiscal space available to
address future economic downturns. HSBC's Central scenario
used to calculate impairment assumes that economic activity will
continue to recover through 2022, surpassing peak pre-pandemic
levels of GDP in our key markets. It is assumed that private sector
growth accelerates, ensuring a strong recovery is sustained even
as pandemic-related fiscal support is withdrawn. However, there is
a high degree of uncertainty associated with economic forecasts
in the current environment and there are significant risks to our
Central scenario. The degree of uncertainty varies by our key
markets, driven by country specific trends in the evolution of the
pandemic, associated policy responses and ongoing impacts felt
from the Trade and Cooperation Agreement in place between the
UK and the EU from 1 January 2021. For further details of our
Central and other scenarios, see ‘Measurement uncertainty and
sensitivity analysis of ECL estimates’ on page 41.
We continue to monitor the situation closely, and given the novel
and prolonged nature of the pandemic, additional mitigating
actions may be required.
Climate-related risks
Climate change can have an impact across HSBC’s risk taxonomy
through both transition and physical channels.
Transition risk can arise from the move to a low-carbon economy,
such as through policy, regulatory and technological changes.
Physical risk can arise through increasing frequency and severity
of weather or other climatic events, such as flooding, or chronic
changes in precipitation patterns, temperatures or sea levels.
These have the potential to cause both idiosyncratic and systemic
risks, resulting in potential financial and non-financial impacts for
the group. Financial impacts could materialise if transition and
physical risks impact the ability of our customers to repay their
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28
HSBC Bank plc Annual Report and Accounts 2021
loans. Non-financial impacts could materialise if our own assets or
operations are impacted by extreme weather or chronic changes
in weather patterns, or as a result of business decisions to achieve
our climate ambition.
How climate risk can impact our customers
Climate change could impact our customers in two main ways.
Firstly, customer business models may fail to align to a low-carbon
economy, which could mean that new climate-related regulation,
policy or technological changes would have a material impact on
their business. Secondly, extreme weather events or chronic
changes in weather patterns may damage our customers’ assets
and supply chain leaving them unable to operate their business or
perhaps even live in their home.
One of the most valuable ways we can help our customers
navigate the transition challenges and to become more resilient to
the physical impacts of climate change is through financing and
investment. To do this effectively, we must understand the risks
they are facing.
The table below summarises the key categories of transition and
physical risk, with examples of how our customers might be
affected financially by climate change and the shift to a low-
carbon economy.
Climate risk
Main causes of financial impact on customers
Transition
Policy and
legal
Mandates on, and regulation of, existing
products and services
Litigation from parties who have suffered
from the effects of climate change
Technology
Replacement of existing products with lower
emission options
End-demand
(market)
Changing consumer behaviour
Reputational
Increased scrutiny following a change in
stakeholder perceptions of climate-related
action or inaction
Physical
Acute
Increased frequency and severity of weather
events
Chronic
Changes in precipitation patterns
Rising temperatures
Integrating climate into enterprise-wide risk
management
Our approach to climate risk management is aligned to HSBC
Group’s risk management framework and three line of defence
model which sets out how we identify, assess and manage our
risks. This approach ensures the Board and senior management
have visibility and oversight of our key climate risks.
Climate Risk Appetite
Our developing climate risk appetite measures support the
oversight and management of the financial and non-financial risks
from climate change, meet regulatory expectations and support
the business to deliver our climate ambition in a safe and
sustainable way. Our initial measures are focused on the oversight
and management of our key climate risks: wholesale credit risk,
retail credit risk, reputational risk, resilience risk and regulatory
compliance.
Our future ambition for our climate risk appetite is to:
•Adapt the Risk Appetite Statement metrics to incorporate
forward looking transition plans and net zero commitments.
•Expand to consider other financial and non-financial risks.
•Use enhanced scenario analysis capabilities.
•Broaden the scope of risks to include climate considerations in
Market Risk, Liquidity Risk, Legal Risk and Environmental Risk
management.
      Climate Risk Policies, Processes and Controls
We are integrating climate risk into the supporting policies,
processes and controls for our key climate risks and we will
continue to update these as our climate risk management
capabilities mature over time. For example, we have updated our
policy on product management and developed the first version of
a climate risk scoring tool for our corporate portfolios. In addition,
HSBC Group has published the new Thermal Coal Phase-Out
Policy and we are implementing this in the region.
Climate Risk Governance and Reporting
Our key climate risks are reported and governed through our
climate risk governance structure. Our Climate Risk Oversight
Forums are responsible for the oversight, management and
escalation of all climate related matters in the region. The regional
Risk Management Meeting and the Risk Committee receive
scheduled updates on climate risk, and regular updates on our
climate risk appetite and top and emerging climate risks.
Our Chief Risk Officer is responsible for the manner by which
financial risks from climate change should be identified and
managed in line with the group's risk management framework. 
We have assessed the impact of climate risk on our balance sheet
and have concluded that there is no material impact on the
financial statements for the year ended 31 December 2021.
Climate Risk Programme
Our dedicated Climate Risk Programme continues to accelerate
the development of our climate risk management capabilities. The
key achievements in 2021 include:
•We delivered tailored training sessions on climate risk to our
legal entity board.
•We delivered training to colleagues across the three lines of
defence to increase their understanding of how climate risk can
impact their role, and we also included an introduction to our
climate ambition in our global mandatory training.
•We developed our climate risk scoring tool for corporate
customers for use in priority regions, which builds on our
corporate transition questionnaire.
•We have continued to develop our climate stress testing and
scenario analysis capabilities, including model development to
deliver on the ECB climate stress testing exercise.
We will continue to enhance our climate risk management
capabilities throughout 2022. This will include the further roll-out
of training, refinement of our risk appetite, enhancement of our
climate risk scoring tool and increasing the availability and quality
of data so that new metrics can be developed.
How climate risk can impact the group
Below, we provide detail on how climate risk impacts to our
customers might manifest across our key climate risks, and the
potential time frames involved using four main drivers under
transition risk; policy and legal, technology, end-demand (market)
and reputational; and two main drivers under physical risk; acute
and chronic.
HSBC Bank plc Annual Report and Accounts 2021
29
Risk management framework
Financial risks
Non-financial risk
Risk type
Wholesale
credit
Retail credit
Strategic risk
(reputational)
Resilience risk
Regulatory
compliance risk
Timescale1
Short–long
term
Medium–long
term
Short–long
term
Short–long
term
Short–medium
Transition risk drivers
– Policy and legal
l
l
l
– Technology
l
– End-demand (market)
l
l
– Reputational
l
l
l
Physical risk drivers
– Acute – increased frequency and severity of weather event
l
l
l
– Chronic – changes in weather pattern
l
l
l
1Short term: less than one year; medium term: period to 2030; long term: period to 2050.
Our material banking and insurance risks
The material risk types associated with our banking and insurance manufacturing operations are described in the following tables.
Credit risk (see page 32)
The risk of financial loss if a
customer or counterparty fails to
meet an obligation under a contract.
Credit risk arises principally from direct
lending, trade finance and leasing
business, but also from certain other
products such as guarantees and
derivatives.
Credit risk is:
•measured as the amount that could be lost if a customer or
counterparty fails to make repayments;
•monitored using various internal risk management measures and
within limits approved by individuals within a framework of
delegated authorities; and
•managed through a robust risk control framework that outlines
clear and consistent policies, principles and guidance for risk
managers.
Treasury risk (see page 70)
The risk of having insufficient
capital, liquidity or funding
resources to meet financial
obligations and satisfy regulatory
requirements, including the risk of
adverse impact on earnings or
capital due to structural foreign
exchange exposures and changes in
market interest rates, and including
the financial risks arising from
historic and current provision of
pensions and other post
employment benefits to staff and
their dependants.
Treasury risk arises from changes to the
respective resources and risk profiles
driven by customer behaviour,
management decisions or the external
environment. 
Treasury risk is:
•measured through appetites set as target and minimum ratios;
•monitored and projected against appetites and using stress and
scenario testing; and
•managed through control of resources in conjunction with risk
profiles and cashflows.
Market risk (see page 77)
The risk that movements in market
factors such as foreign exchange
rates, interest rates, credit spreads,
equity prices and commodity prices
will reduce our income or the value
of our portfolios.
Exposure to market risk is separated into
two portfolios:
•trading portfolios; and
•non-trading portfolios.
Market risk exposures arising from our
insurance operations are discussed on
page 84.
Market risk is:
•measured using sensitivities, value at risk (‘VaR’) and stress testing,
giving a detailed picture of potential gains and losses for a range of
market movements and scenarios, as well as tail risks over specified
time horizons;
•monitored using VaR, stress testing and other measures, including
the sensitivity of net interest income and the sensitivity of structural
foreign exchange; and
•managed using risk limits approved by the risk management
meeting (‘RMM’) and the RMM in various global businesses.
Resilience risk (see page 80)
Resilience risk is the risk that we are
unable to provide critical services to
our customers, affiliates, and
counterparties as a result of
sustained and significant operational
disruption.
Resilience risk arises from failures or
inadequacies in processes, people, systems
or external events. These may be driven by
rapid technological innovation, changing
behaviours of our consumers, cyber-threats
and attacks, crossborder dependencies,
and third party relationships.
Resilience risk is:
•measured through a range of metrics with defined maximum
acceptable impact tolerances, and against our agreed risk appetite. 
•monitored through oversight of enterprise processes, risks, controls
and strategic change programmes; and
•managed by continuous monitoring and thematic reviews.
Description of risks – banking operations
Risks
Arising from
Measurement, monitoring and management of risk
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HSBC Bank plc Annual Report and Accounts 2021
Regulatory compliance risk (see page 81)
Regulatory compliance risk is the
risk associated with breaching our
duty to clients and other
counterparties, inappropriate market
conduct and breaching related
financial services regulatory
standards.
Regulatory compliance risk arises from the
failure to observe the letter and spirit of
relevant laws, codes, rules, regulations and
standards of good practice. This could
result in poor market or customer
outcomes leading to fines, penalties and
reputational damage to our business.
Regulatory compliance risk is:
•measured by reference to risk appetite, identified metrics, incident
assessments, regulatory feedback and the judgement and
assessment of our regulatory compliance teams;
•monitored against the first line of defence risk and control
assessments, the results of the monitoring and control assurance
activities of the second line of defence functions, and the results of
internal and external audits and regulatory inspections; and
•managed by establishing and communicating appropriate policies
and procedures, training employees in them and monitoring activity
to help ensure their observance. Proactive risk control and/or
remediation work is undertaken where required.
Financial crime risk (see page 81)
Financial crime risk is the risk of
knowingly or unknowingly helping
parties to commit or to further
potentially illegal activity through
HSBC, including money laundering,
fraud, bribery and corruption, tax
evasion, sanctions breaches, and
terrorist and proliferation financing.
Financial crime risk arises from day-to-day
banking operations involving customers,
third parties and employees.
Financial crime risk is:
•measured by reference to risk appetite, identified metrics, incident
assessments, regulatory feedback and the judgement of, and
assessment by, our regulatory compliance teams;
•monitored against the first line of defence risk and control
assessments, the results of the monitoring and control assurance
activities of the second line of defence functions, and the results of
internal and external audits and regulatory inspections; and
•managed by establishing and communicating appropriate policies
and procedures, training employees in them and monitoring activity
to help ensure their observance. Proactive risk control and/or
remediation work is undertaken where required.
Model risk (see page 83)
Model risk is the potential for
adverse consequences from
business decisions informed by
models, which can be exacerbated
by errors in methodology, design or
the way they are used. 
Model risk arises in both financial and non-
financial contexts whenever business
decision making includes reliance on
models. 
Model risk is:
•measured by reference to model performance tracking and the
output of detailed technical reviews, with key metrics including
model review statuses and findings;
•monitored against model risk appetite statements, insight from the
independent review function, feedback from internal and external
audits, and regulatory reviews; and
•managed by creating and communicating appropriate policies,
procedures and guidance, training colleagues in their application,
and supervising their adoption to ensure operational effectiveness.
Description of risks – banking operations (continued)
Risks
Arising from
Measurement, monitoring and management of risk
Our insurance manufacturing subsidiaries are regulated separately from our banking operations. Risks in our insurance entities are
managed using methodologies and processes that are subject to Group oversight. Our insurance operations are also subject to some of
the same risks as our banking operations, and these, are covered by the Group’s risk management processes. There are though specific
risks inherent to the insurance operations as noted below.
Description of risks – insurance manufacturing operations
Risks
Arising from
Measurement, monitoring and management of risk
Financial risk (see page 84)
For insurance entities,
Financial risk includes the
risk of not being able to
effectively match liabilities
arising under insurance
contracts with appropriate
investments and that the
expected sharing of
financial performance with
policyholders under certain
contracts is not possible.
Exposure to financial risks arises from:
•market risk affecting the fair values of
financial assets or their future cash flows;
•credit risk; and
•liquidity risk of entities not being able to
make payments to policyholders as they
fall due.
Financial risk is:
•measured (i) for credit risk, in terms of economic capital and the
amount that could be lost if a counterparty fails to make repayments;
(ii) for market risk, in terms of economic capital, internal metrics and
fluctuations in key financial variables; and (iii) for liquidity risk, in
terms of internal metrics, including stressed operational cash flow
projections;
•monitored through a framework of approved limits and delegated
authorities; and
•managed through a robust risk control framework that outlines clear
and consistent policies, principles and guidance. This includes using
product design and asset liability matching and bonus rates.
Insurance risk (see page 84)
The risk that, over time,
the cost of the contract,
including claims and
benefits may exceed the
total amount of premiums
and investment income
received.
The cost of claims and benefits can be influenced
by many factors, including mortality and
morbidity experience, as well as lapse and
surrender rates.
Insurance risk is:
•measured in terms of life insurance liabilities and economic capital
allocated to insurance underwriting risk;
•monitored though a framework of approved limits and delegated
authorities; and
•managed through a robust risk control framework that outlines clear
and consistent policies, principles and guidance. This includes using
product design, underwriting, reinsurance and claims-handling
procedures.
HSBC Bank plc Annual Report and Accounts 2021
31
Credit risk
Credit risk is the risk of financial loss if a customer or counterparty
fails to meet an obligation under a contract. Credit risk arises
principally from direct lending, trade finance and leasing business,
but also from certain other products, such as guarantees and
derivatives.
Credit risk management
Key developments in 2021
We continued to actively manage the risks resulting from the
Covid-19 outbreak and its impacts on our customers and
operations in 2021. For further details of market-specific measures
to support our personal and business customers, see page 28.
Outside these Covid-19 initiatives, there have been no material
changes to credit risk policy and we continue to apply the
requirements of IFRS 9 'Financial Instruments' within Credit risk.
Climate Risk
For our Global Banking and Commercial Banking wholesale clients
operating in high transition risk sectors, a detailed Transition Risk
Questionnaire is completed which assess both the climate risk the
client faces and their plans to adapt to a Net Zero world. This
information is taken into consideration as part of the broader client
credit assessment. During 2022, we will broaden our assessments
to include other high risk sectors which may be vulnerable to other
climate considerations, including physical risk. This will also be
embedded as part of the usual credit assessment process.
Governance and structure
We have established group-wide credit risk management and
related IFRS 9 processes. We continue to actively assess the
impact of economic developments in key markets on specific
customers, customer segments or portfolios. As credit conditions
change, we take mitigating action, including the revision of risk
appetites or limits and tenors, as appropriate. In addition, we
continue to evaluate the terms under which we provide credit
facilities within the context of individual customer requirements,
the quality of the relationship, local regulatory requirements,
market practices and our local market position.
Credit risk sub-function
(Audited)
Credit approval authorities are delegated by the Board to the Chief
Executive together with the authority to sub-delegate them. The
Credit risk sub-function in Risk is responsible for the key policies
and processes for managing credit risk, which include formulating
credit policies and risk rating frameworks, guiding the appetite for
credit risk exposures, undertaking independent reviews and
objective assessment of credit risk, and monitoring performance
and management of portfolios.
The principal objectives of our credit risk management are:
•to maintain across the group a strong culture of responsible
lending and a robust risk policy and control framework;
•to both partner and challenge global businesses in defining,
implementing and continually re-evaluating our risk appetite
under actual and scenario conditions; and
•to ensure there is independent, expert scrutiny of credit risks,
their costs and mitigation.
Key risk management process
IFRS 9 ‘Financial Instruments’ process
The IFRS 9 process comprises three main areas: modelling and
data; implementation; and governance.
Modelling and data
The Group has established IFRS 9 modelling and data processes in
various geographies, which are subject to internal model risk
governance including independent review of significant model
developments.
Implementation
A centralised impairment engine performs the ECL calculation
using data, which is subject to a number of validation checks and
enhancements, from a variety of client, finance and risk systems.
Where possible, these checks and processes are performed in a
globally consistent and centralised manner.
Governance
Management review forums are established in order to review and
approve the impairment results. Management review forums have
representatives from Credit Risk and Finance. Required members
of the committee are the heads of Wholesale Credit, Market Risk,
and Wealth and Personal Banking Risk, as well as the global
business Chief Financial Officers and the Chief Accounting Officer.
Concentration of exposure
(Audited)
Concentrations of credit risk arise when a number of
counterparties or exposures have comparable economic
characteristics, or are engaged in similar activities, or operate in
the same geographical areas/industry sectors, so that their
collective ability to meet contractual obligations is uniformly
affected by changes in economic, political or other conditions. The
group uses a number of controls and measures to minimise undue
concentration of exposure in the group’s portfolios across
industry, country and customer groups. These include portfolio
and counterparty limits, approval and review controls, and stress
testing.
Credit quality of financial instruments
(Audited)
Our risk rating system facilitates the internal ratings-based
approach under the Basel framework adopted by the Group to
support the calculation of our minimum credit regulatory capital
requirement. The five credit quality classifications each
encompass a range of granular internal credit rating grades
assigned to wholesale and retail lending businesses, and the
external ratings attributed by external agencies to debt securities.
For debt securities and certain other financial instruments, external
ratings have been aligned to the five quality classifications based
upon the mapping of related Customer Risk Rating (‘CRR’) to
external credit rating.
Wholesale lending
The CRR 10-grade scale summarises a more granular underlying
23-grade scale of obligor probability of default (‘PD’). All corporate
customers are rated using the 10- or 23-grade scale, depending on
the degree of sophistication of the Basel approach adopted for the
exposure.
Each CRR band is associated with an external rating grade by
reference to long-run default rates for that grade, represented by
the average of issuer-weighted historical default rates. This
mapping between internal and external ratings is indicative and
may vary over time.
Retail lending
Retail lending credit quality is based on a 12-month point-in-time
probability-weighted PD.
Report of the Directors | Risk
32
HSBC Bank plc Annual Report and Accounts 2021
Credit quality classification
Sovereign debt
securities and bills
Other debt
securities and bills
Wholesale lending and derivatives
Retail lending
External
credit rating
External
credit rating
Internal
credit rating
12-month
probability of
default %
Internal
credit rating
12 month
probability-
weighted PD %
Quality classification1,2
Strong
BBB and above
A- and above
CRR1 to CRR21
0 – 0.169
Band 1 and 2
0.000 – 0.500
Good
BBB- to BB
BBB+ to BBB-
CRR3
0.170 – 0.740
Band 3
0.501 – 1.500
Satisfactory
BB- to B and
unrated
BB+ to B and
unrated
CRR4 to CRR5
0.741 – 4.914
Band 4 and 5
1.501 – 20.000
Sub-standard
B- to C
B- to C
CRR6 to CRR8
4.915 – 99.999
Band 6
20.001 – 99.999
Credit impaired
Default
Default
CRR9 to CRR10
100
Band 7
100
1Customer risk rating (‘CRR’).
212-month point-in-time probability-weighted PD.
Quality classification definitions
•‘Strong’ exposures demonstrate a strong capacity to meet financial commitments, with negligible or low probability of default and/or low levels of
expected loss.
•‘Good’ exposures require closer monitoring and demonstrate a good capacity to meet financial commitments, with low default risk.
•‘Satisfactory’ exposures require closer monitoring and demonstrate an average to fair capacity to meet financial commitments, with moderate default
risk.
•‘Sub-standard’ exposures require varying degrees of special attention and default risk is of greater concern.
•‘Credit-impaired’ exposures have been assessed as described in Note 1.2(i) on the Financial Statements.
Renegotiated loans and forbearance
‘Forbearance’ describes concessions made on the contractual
terms of a loan in response to an obligor’s financial difficulties.
A loan is classed as ‘renegotiated’ when we modify the
contractual payment terms on concessionary terms because we
have significant concerns about the borrowers’ ability to meet
contractual payments when due. Non-payment-related
concessions (e.g. covenant waivers), while potential indicators of
impairment, do not trigger identification as renegotiated loans.
Loans that have been identified as renegotiated retain this
designation until maturity or derecognition.
For details of our policy on derecognised renegotiated loans, see
Note 1.2(i) on the financial statements.
Credit quality of renegotiated loans
On execution of a renegotiation, the loan will also be classified as
credit impaired if it is not already so classified. In wholesale
lending, all facilities with a customer, including loans that have not
been modified, are considered credit impaired following the
identification of a renegotiated loan.
Wholesale renegotiated loans are classified as credit impaired until
there is sufficient evidence to demonstrate a significant reduction
in the risk of non-payment of future cash flows, observed over a
minimum one-year period, and there are no other indicators of
impairment. Personal renegotiated loans generally remain credit
impaired until repayment, write-off or derecognition.
Renegotiated loans and recognition of expected credit losses
(Audited)
For retail lending, unsecured renegotiated loans are generally
segmented from other parts of the loan portfolio. Renegotiated
expected credit loss assessments reflect the higher rates of losses
typically encountered with renegotiated loans. For wholesale
lending, renegotiated loans are typically assessed individually.
Credit risk ratings are intrinsic to the impairment assessments. The
individual impairment assessment takes into account the higher
risk of the future non-payment inherent in renegotiated loans.
Impairment assessment
(Audited)
For details of our impairment policies on loans and advances and
financial investments see Note 1.2(i) on the financial statements.
Write-off of loans and advances
(Audited)
For details of our accounting policy on the write-off of loans and
advances, see Note 1.2(i) on the financial statements.
Unsecured personal facilities, including credit cards, are generally
written off at between 150 and 210 days past due. The standard
period runs until the end of the month in which the account
becomes 180 days contractually delinquent. Write-off periods may
be extended, generally to no more than 360 days past due.
However, in exceptional circumstances, they may be extended
further.
For secured facilities, write-off should occur upon repossession of
collateral, receipt of proceeds via settlement, or determination that
recovery of the collateral will not be pursued.
Any secured assets maintained on the balance sheet beyond 60
months of consecutive delinquency-driven default require
additional monitoring and review to assess the prospect of
recovery.
There are exceptions in a few countries where local regulation or
legislation constrain earlier write-off, or where the realisation of
collateral for secured real estate lending takes more time. In the
event of bankruptcy or analogous proceedings, write-off may
occur earlier than the maximum periods stated above. Collection
procedures may continue after write-off.
Credit risk in 2021
At 31 December 2021, gross loans and advances to customers
and banks of £103.1bn decreased by £12.5bn, compared with
31 December 2020. This included adverse foreign exchange
movements of £4.3bn. Excluding foreign exchange movements,
the decline was driven by a £7.1bn decrease in wholesale loans
and advances to customers and a £1.5bn decrease in loans and
advances to banks. This was partly offset by a £0.4bn increase in
personal loans and advances .
During the first half of 2021, the group experienced a release in
allowances for ECL, reflecting an improvement of the economic
outlook.  This trend continued during the second half of the year
following better than expected levels of credit performance and
lower levels of stage 3 charges. However, in the later part of the
year the trend slowed down due to the emergence of the new
Covid-19 Omicron variant. Excluding foreign exchange
movements, the allowance for ECL in relation to loans and
advances to customers decreased by £258m from 31 December
2020.
HSBC Bank plc Annual Report and Accounts 2021
33
This was attributable to:
•a £225m decrease in wholesale loans and advances to
customers, of which £156m was driven by stages 1 and 2; and
•a £33m increase in personal loans and advances to customers,
of which £14m was driven by stages 1 and 2.
During the first six months of the year, the group experienced
significant migrations from stage 2 to stage 1, reflecting an
improvement of  the economic outlook. This trend continued
during the second half of 2021 as forward economic guidance
('FEG') remained broadly stable in comparison with 30 June 2021.
Stage 3 balances at 31 December 2021 remained broadly stable 
compared with 31 December 2020.
The ECL release for 2021 was £174m, inclusive of recoveries,
Uncertainty remains as some countries emerge from the pandemic
at different speeds of recovery, government support measures
unwind and the emergence of new strains of the virus test the
efficacy of vaccination programmes.
During 2021, we continued to provide Covid-19-related support to
customers under the current policy framework. For further details
of market-specific measures to support our personal and business
customers, see page 60.
Summary of credit risk
The following disclosure presents the gross carrying/nominal
amount of financial instruments to which the impairment
requirements in IFRS9 are applied and the associated allowance
for ECL. The allowance for ECL decreased from £1,632m at
31 December 2020 to £1,240m at 31 December 2021.
The allowance for ECL at 31 December 2021 comprised of
£1,168m (2020: £1,497m) in respect of assets held at amortised
cost, £72m (2020: £135m) in respect of loans and other credit
related commitments, and financial guarantees, and £19m (2020:
£22m) in respect of debt instruments measured at FVOCI.
Summary of financial instruments to which the impairment requirements in IFRS 9 are applied
(Audited)
31 Dec 2021
31 Dec 2020
Gross carrying/
nominal amount
Allowance for ECL1
Gross carrying/
nominal amount
Allowance for ECL1
The group
£m
£m
£m
£m
Loans and advances to customers at amortised cost
92,331
(1,154)
102,960
(1,469)
–  personal
25,394
(163)
26,499
(208)
–  corporate and commercial
56,087
(964)
62,987
(1,168)
–  non-bank financial institutions
10,850
(27)
13,474
(93)
Loans and advances to banks at amortised cost
10,789
(5)
12,662
(16)
Other financial assets measured at amortised cost
202,137
(9)
202,763
(12)
–  cash and balances at central banks
108,482
—
85,093
(1)
–  items in the course of collection from other banks
346
—
243
—
–  reverse repurchase agreements – non trading
54,448
—
67,577
—
–  financial investments
10
—
15
—
–  prepayments, accrued income and other assets2
38,851
(9)
49,835
(11)
Total gross carrying amount on balance sheet
305,257
(1,168)
318,385
(1,497)
Loans and other credit related commitments
115,695
(55)
143,036
(112)
–  personal
2,269
(1)
2,211
(1)
–  corporate and commercial
63,352
(48)
75,863
(89)
–  financial
50,074
(6)
64,962
(22)
Financial guarantees3
11,054
(17)
3,969
(23)
–  personal
26
—
32
—
–  corporate and commercial
9,894
(16)
2,735
(19)
–  financial
1,134
(1)
1,202
(4)
Total nominal amount off balance sheet4
126,749
(72)
147,005
(135)
432,006
(1,240)
465,390
(1,632)
Fair value
Memorandum
allowance for ECL5
Fair value
Memorandum
allowance for ECL5
£m
£m
£m
£m
Debt instruments measured at fair value through other comprehensive
income ('FVOCI')
41,188
(19)
51,713
(22)
1The total ECL is recognised in the loss allowance for the financial asset unless the total ECL exceeds the gross carrying amount of the financial
asset, in which case the ECL is recognised as a provision.
2Includes only those financial instruments which are subject to the impairment requirements of IFRS 9. ‘Prepayments, accrued income and other
assets’ as presented within the consolidated balance sheet on page 110 includes both financial and non-financial assets.
3Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
4Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.
5Debt instruments measured at FVOCI continue to be measured at fair value with the allowance for ECL as a memorandum item. Change in ECL is
recognised in ‘Change in expected credit losses and other credit impairment charges’ in the income statement.
Report of the Directors | Risk
34
HSBC Bank plc Annual Report and Accounts 2021
Summary of financial instruments to which the impairment requirements in IFRS 9 are applied
(Audited)
31 Dec 2021
31 Dec 2020
Gross carrying/
nominal amount
Allowance for ECL1
Gross carrying/
nominal amount
Allowance for
ECL1
The bank
£m
£m
£m
£m
Loans and advances to customers at amortised cost
34,286
(350)
43,831
(590)
–  personal
3,680
(6)
3,582
(13)
–  corporate and commercial
21,182
(308)
26,014
(494)
–  non-bank financial institutions
9,424
(36)
14,235
(83)
Loans and advances to banks at amortised cost
6,782
(4)
8,078
(15)
Other financial assets measured at amortised cost
135,033
(1)
135,900
(1)
–  cash and balances at central banks
63,008
—
48,777
—
–  items in the course of collection from other banks
211
—
37
—
–  reverse repurchase agreements-non trading
39,708
—
50,137
—
–  financial investments
3,337
—
2,214
—
–  prepayments, accrued income and other assets2
28,769
(1)
34,735
(1)
Total gross carrying amount on balance sheet
176,101
(355)
187,809
(606)
Loans and other credit related commitments
31,255
(29)
45,308
(81)
–  personal
589
—
352
—
–  corporate and commercial
19,175
(26)
25,444
(66)
–  financial
11,491
(3)
19,512
(15)
Financial guarantees3
1,270
(7)
1,510
(13)
–  personal
3
—
3
—
–  corporate and commercial
527
(6)
457
(9)
–  financial
740
(1)
1,050
(4)
Total nominal amount off balance sheet4
32,525
(36)
46,818
(94)
208,626
(391)
234,627
(700)
Fair value
Memorandum
allowance for ECL5
Fair value
Memorandum
allowance for ECL5
£m
£m
£m
£m
Debt instruments measured at FVOCI
23,152
(4)
28,699
(9)
1The total ECL is recognised in the loss allowance for the financial asset unless the total ECL exceeds the gross carrying amount of the financial
asset, in which case the ECL is recognised as a provision.
2Includes only those financial instruments which are subject to the impairment requirements of IFRS 9. ‘Prepayments, accrued income and other
assets’ as presented within the consolidated balance sheet on page 110 includes both financial and non-financial assets.
3Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
4Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.
5Debt instruments measured at FVOCI continue to be measured at fair value with the allowance for ECL as a memorandum item. Change in ECL is
recognised in ‘Change in expected credit losses and other credit impairment charges’ in the income statement.
The following table provides an overview of the group’s and
bank's credit risk by stage and industry, and the associated ECL
coverage. The financial assets recorded in each stage have the
following characteristics:
•Stage 1: These financial assets are unimpaired and without
significant increase in credit risk on which a 12-month
allowance for ECL is recognised.
•Stage 2: A significant increase in credit risk has been
experienced since initial recognition on which a lifetime ECL is
recognised.
•Stage 3: There is objective evidence of impairment, and are
therefore considered to be in default or otherwise credit-
impaired on which a lifetime ECL is recognised.
•Purchased or originated credit-impaired ('POCI'): Financial
assets that are purchased or originated at a deep discount that
reflects the incurred credit losses on which a lifetime ECL is
recognised.
HSBC Bank plc Annual Report and Accounts 2021
35
Summary of credit risk (excluding debt instruments measured at FVOCI) by stage distribution and ECL coverage by industry sector at
31 December 2021
(Audited)
Gross carrying/nominal amount2
Allowance for ECL
ECL coverage %
Stage 1
Stage 2
Stage 3
POCI3
Total
Stage 1
Stage 2
Stage 3
POCI3
Total
Stage 1
Stage 2
Stage 3
POCI3
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
%
%
%
%
%
Loans and
advances to
customers at
amortised cost
80,730
9,121
2,478
2
92,331
(86)
(158)
(908)
(2)
(1,154)
0.1
1.7
36.6
100.0
1.2
–  personal
24,255
686
453
—
25,394
(22)
(16)
(125)
—
(163)
0.1
2.3
27.6
—
0.6
–  corporate and
commercial
46,237
8,066
1,782
2
56,087
(58)
(137)
(767)
(2)
(964)
0.1
1.7
43.0
100.0
1.7
–  non-bank
financial
institutions
10,238
369
243
—
10,850
(6)
(5)
(16)
—
(27)
0.1
1.4
6.6
—
0.2
Loans and
advances to banks
at amortised cost
10,750
39
—
—
10,789
(4)
(1)
—
—
(5)
—
2.6
—
—
—
Other financial
assets measured at
amortised cost
202,048
47
42
—
202,137
—
—
(9)
—
(9)
—
—
21.4
—
—
Loan and other
credit-related
commitments
107,922
7,571
202
—
115,695
(25)
(22)
(8)
—
(55)
—
0.3
4.0
—
—
–  personal
2,152
114
3
—
2,269
(1)
—
—
—
(1)
—
—
—
—
—
–  corporate and
commercial
56,325
6,829
198
—
63,352
(20)
(20)
(8)
—
(48)
—
0.3
4.0
—
0.1
–  financial
49,445
628
1
—
50,074
(4)
(2)
—
—
(6)
—
0.3
—
—
—
Financial
guarantees1
10,215
740
99
—
11,054
(3)
(7)
(7)
—
(17)
—
0.9
7.1
—
0.2
–  personal
23
2
1
—
26
—
—
—
—
—
—
—
—
—
—
–  corporate and
commercial
9,257
540
97
—
9,894
(2)
(7)
(7)
—
(16)
—
1.3
7.2
—
0.2
–  financial
935
198
1
—
1,134
(1)
—
—
—
(1)
0.1
—
—
—
0.1
At 31 Dec 2021
411,665
17,518
2,821
2
432,006
(118)
(188)
(932)
(2)
(1,240)
—
1.1
33.0
100.0
0.3
1Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
2Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.
3Purchased or originated credit-impaired (‘POCI’).
Unless identified at an earlier stage, all financial assets are
deemed to have suffered a significant increase in credit risk when
they are 30 days past due (‘DPD’) and are transferred from stage 1
to stage 2. The following disclosure presents the ageing of stage 2
financial assets by those less than 30 days and greater than 30
DPD and therefore presents those financial assets classified as
stage 2 due to ageing (30 DPD) and those identified at an earlier
stage (less than 30 DPD).
Stage 2 days past due analysis at 31 December 2021
(Audited)
Gross carrying amount
Allowance for ECL
ECL coverage %
Of which:
Of which:
Of which:
Of which:
Of which:
Of which:
Stage 2
1 to 29
DPD1,2
30 and >
DPD1,2
Stage 2
1 to 29
DPD1,2
30 and >
DPD1,2
Stage 2
1 to 29
DPD1,2
30 and >
DPD1,2
The group
£m
£m
£m
£m
£m
£m
%
%
%
Loans and advances to customers at
amortised cost:
9,121
56
237
(158)
(1)
(1)
1.7
1.8
0.4
–  personal
686
49
29
(16)
(1)
(1)
2.3
2.0
3.4
–  corporate and commercial
8,066
7
199
(137)
—
—
1.7
—
—
–  non-bank financial institutions
369
—
9
(5)
—
—
1.4
—
—
Loans and advances to banks at
amortised cost
39
—
—
(1)
—
—
2.6
—
—
Other financial assets measured at
amortised cost
47
—
—
—
—
—
—
—
—
1Days past due (‘DPD’). Up-to-date accounts in stage 2 are not shown in amounts presented above.
2The days past due amounts presented above are on a contractual basis and include the benefit of any customer relief payment holidays granted.
Report of the Directors | Risk
36
HSBC Bank plc Annual Report and Accounts 2021
Summary of credit risk (excluding debt instruments measured at FVOCI) by stage distribution and ECL coverage by industry sector at
31 December 2020 (continued)
(Audited)
Gross carrying/nominal amount2
Allowance for ECL
ECL coverage %
Stage 1
Stage 2
Stage 3
POCI3
Total
Stage 1
Stage 2
Stage 3
POCI3
Total
Stage 1
Stage 2
Stage 3
POCI3
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
%
%
%
%
%
Loans and advances to
customers at
amortised cost
83,179
16,774
2,966
41
102,960
(129)
(297)
(1,031)
(12)
(1,469)
0.2
1.8
34.8
29.3
1.4
–  personal
24,991
974
534
—
26,499
(18)
(37)
(153)
—
(208)
0.1
3.8
28.7
—
0.8
–  corporate and
commercial
46,773
14,052
2,121
41
62,987
(100)
(225)
(831)
(12)
(1,168)
0.2
1.6
39.2
29.3
1.9
–  non-bank financial
institutions
11,415
1,748
311
—
13,474
(11)
(35)
(47)
—
(93)
0.1
2.0
15.1
—
0.7
Loans and advances to
banks at amortised
cost
12,533
129
—
—
12,662
(13)
(3)
—
—
(16)
0.1
2.3
—
—
0.1
Other financial assets
measured at amortised
cost
202,659
65
39
—
202,763
(2)
—
(10)
—
(12)
—
—
25.6
—
—
Loan and other credit-
related commitments
128,956
13,814
266
—
143,036
(34)
(68)
(10)
—
(112)
—
0.5
3.8
—
0.1
–  personal
1,991
217
3
—
2,211
—
(1)
—
—
(1)
—
0.5
—
—
—
–  corporate and
commercial
65,199
10,404
260
—
75,863
(29)
(51)
(9)
—
(89)
—
0.5
3.5
—
0.1
–  financial
61,766
3,193
3
—
64,962
(5)
(16)
(1)
—
(22)
—
0.5
33.3
—
—
Financial guarantees1
2,839
1,008
121
1
3,969
(4)
(10)
(9)
—
(23)
0.1
1.0
7.4
—
0.6
–  personal
26
5
1
—
32
—
—
—
—
—
—
—
—
—
—
–  corporate and
commercial
1,878
737
119
1
2,735
(3)
(7)
(9)
—
(19)
0.2
0.9
7.6
—
0.7
–  financial
935
266
1
—
1,202
(1)
(3)
—
—
(4)
0.1
1.1
—
—
0.3
At 31 Dec 2020
430,166
31,790
3,392
42
465,390
(182)
(378)
(1,060)
(12)
(1,632)
—
1.2
31.3
28.6
0.4
1Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
2Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.
3Purchased or originated credit-impaired (‘POCI’).
Stage 2 days past due analysis at 31 December 2020 (continued)
(Audited)
Gross carrying amount
Allowance for ECL
ECL coverage %
Of which:
Of which:
Of which:
Of which:
Of which:
Of which:
Stage 2
1 to 29
DPD1,2
30 and >
DPD1,2
Stage 2
1 to 29
DPD1,2
30 and >
DPD1,2
Stage 2
1 to 29
DPD1,2
30 and >
DPD1,2
The group
£m
£m
£m
£m
£m
£m
%
%
%
Loans and advances to customers at
amortised cost
16,774
64
50
(297)
(3)
(2)
1.8
4.7
4.0
–  personal
974
54
39
(37)
(2)
(2)
3.8
3.7
5.1
–  corporate and commercial
14,052
9
11
(225)
(1)
—
1.6
11.1
—
–  non-bank financial institutions
1,748
1
—
(35)
—
—
2.0
—
—
Loans and advances to banks at amortised
cost
129
—
—
(3)
—
—
2.3
—
—
Other financial assets measured at
amortised cost
65
—
—
—
—
—
—
—
—
1Days past due (‘DPD’). Up-to-date accounts in stage 2 are not shown in amounts presented above.
2The days past due amounts presented above are on a contractual basis and include the benefit of any customer relief payment holidays granted.
HSBC Bank plc Annual Report and Accounts 2021
37
Summary of credit risk (excluding debt instruments measured at FVOCI) by stage distribution and ECL coverage by industry sector at
31 December 2021
(Audited)
Gross carrying/nominal amount2
Allowance for ECL
ECL coverage %
Stage 1
Stage 2
Stage 3
POCI3
Total
Stage 1
Stage 2
Stage 3
POCI3
Total
Stage 1
Stage 2
Stage 3
POCI3
Total
The bank
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
%
%
%
%
%
Loans and
advances to
customers at
amortised cost
30,105
3,197
984
—
34,286
(33)
(47)
(270)
—
(350)
0.1
1.5
27.4
—
1.0
–  personal
3,544
88
48
—
3,680
(1)
(2)
(3)
—
(6)
—
2.3
6.3
—
0.2
–  corporate and
commercial
17,608
2,893
681
—
21,182
(28)
(45)
(235)
—
(308)
0.2
1.6
34.5
—
1.5
–  non-bank
financial
institutions
8,953
216
255
—
9,424
(4)
—
(32)
—
(36)
—
—
12.5
—
0.4
Loans and
advances to
banks at
amortised cost
6,775
7
—
—
6,782
(3)
(1)
—
—
(4)
—
14.3
—
—
0.1
Other financial
assets measured
at amortised cost
134,984
21
28
—
135,033
—
—
(1)
—
(1)
—
—
3.6
—
—
Loan and other
credit-related
commitments
28,911
2,301
43
—
31,255
(15)
(11)
(3)
—
(29)
0.1
0.5
7.0
—
0.1
–  personal
585
2
2
—
589
—
—
—
—
—
—
—
—
—
—
–  corporate and
commercial
17,010
2,124
41
—
19,175
(12)
(11)
(3)
—
(26)
0.1
0.5
7.3
—
0.1
–  financial
11,316
175
—
—
11,491
(3)
—
—
—
(3)
—
—
—
—
—
Financial
guarantees1
1,060
150
60
—
1,270
(1)
—
(6)
—
(7)
0.1
—
10.0
—
0.6
–  personal
2
1
—
—
3
—
—
—
—
—
—
—
—
—
—
–  corporate and
commercial
437
31
59
—
527
—
—
(6)
—
(6)
—
—
10.2
—
1.1
–  financial
621
118
1
—
740
(1)
—
—
—
(1)
0.2
—
—
—
0.1
At 31 Dec 2021
201,835
5,676
1,115
—
208,626
(52)
(59)
(280)
—
(391)
—
1.0
25.1
—
0.2
1Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
2Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.
3Purchased or originated credit-impaired (‘POCI’).
Stage 2 days past due analysis at 31 December 2021
(Audited)
Gross carrying amount
Allowance for ECL
ECL coverage %
Of which:
Of which:
Of which:
Of which:
Of which:
Of which:
Stage 2
1 to 29
DPD1
30 and >
DPD1
Stage 2
1 to 29
DPD1
30 and >
DPD1
Stage 2
1 to 29
DPD1
30 and >
DPD1
The bank
£m
£m
£m
£m
£m
£m
%
%
%
Loans and advances to customers at
amortised cost:
3,197
19
6
(47)
(1)
—
1.5
5.3
—
–  personal
88
19
6
(2)
(1)
—
2.3
5.3
—
–  corporate and commercial
2,893
—
—
(45)
—
—
1.6
—
—
–  non-bank financial institutions
216
—
—
—
—
—
—
—
—
Loans and advances to banks at
amortised cost
7
—
—
(1)
—
—
14.3
—
—
Other financial assets measured at
amortised cost
21
—
—
—
—
—
—
—
—
1Days past due (‘DPD’). Up-to-date accounts in stage 2 are not shown in amounts presented above.
Report of the Directors | Risk
38
HSBC Bank plc Annual Report and Accounts 2021
Summary of credit risk (excluding debt instruments measured at FVOCI) by stage distribution and ECL coverage by industry sector at
31 December 2020 (continued)
(Audited)
Gross carrying/nominal amount2
Allowance for ECL
ECL coverage %
Stage 1
Stage 2
Stage 3
POCI3
Total
Stage 1
Stage 2
Stage 3
POCI3
Total
Stage 1
Stage 2
Stage 3
POCI3
Total
The bank
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
%
%
%
%
%
Loans and
advances to
customers at
amortised cost
34,629
7,921
1,279
2
43,831
(79)
(158)
(351)
(2)
(590)
0.2
2.0
27.4
100.0
1.3
–  personal
3,455
70
57
—
3,582
(1)
(8)
(4)
—
(13)
—
11.4
7.0
—
0.4
–  corporate and
commercial
18,670
6,424
918
2
26,014
(70)
(121)
(301)
(2)
(494)
0.4
1.9
32.8
100.0
1.9
–  non-bank
financial
institutions
12,504
1,427
304
—
14,235
(8)
(29)
(46)
—
(83)
0.1
2.0
15.1
—
0.6
Loans and
advances to banks
at amortised cost
7,995
83
—
—
8,078
(12)
(3)
—
—
(15)
0.2
3.6
—
—
0.2
Other financial
assets measured
at amortised cost
135,843
35
22
—
135,900
—
—
(1)
—
(1)
—
—
4.5
—
—
Loan and other
credit-related
commitments
39,343
5,905
60
—
45,308
(28)
(48)
(5)
—
(81)
0.1
0.8
8.3
—
0.2
–  personal
338
14
—
—
352
—
—
—
—
—
—
—
—
—
—
–  corporate and
commercial
21,895
3,492
57
—
25,444
(23)
(39)
(4)
—
(66)
0.1
1.1
7.0
—
0.3
–  financial
17,110
2,399
3
—
19,512
(5)
(9)
(1)
—
(15)
—
0.4
33.3
—
0.1
Financial
guarantees1
1,203
253
54
—
1,510
(2)
(4)
(7)
—
(13)
0.2
1.6
13.0
—
0.9
–  personal
2
1
—
—
3
—
—
—
—
—
—
—
—
—
—
–  corporate and
commercial
331
73
53
—
457
(1)
(1)
(7)
—
(9)
0.3
1.4
13.2
—
2.0
–  financial
870
179
1
—
1,050
(1)
(3)
—
—
(4)
0.1
1.7
—
—
0.4
At 31 Dec 2020
219,013
14,197
1,415
2
234,627
(121)
(213)
(364)
(2)
(700)
0.1
1.5
25.7
100.0
0.3
1Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
2Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.
3Purchased or originated credit-impaired (‘POCI’).
Stage 2 days past due analysis at 31 December 2020 (continued)
(Audited)
Gross carrying amount
Allowance for ECL
ECL coverage %
Of which:
Of which:
Of which:
Of which:
Of which:
Of which:
Stage 2
1 to 29
DPD1
30 and >
DPD1
Stage 2
1 to 29
DPD1
30 and >
DPD1
Stage 2
1 to 29
DPD1
30 and >
DPD1
The bank
£m
£m
£m
£m
£m
£m
%
%
%
Loans and advances to customers at
amortised cost:
7,921
16
8
(158)
(1)
(1)
2.0
6.3
12.5
–  Personal
70
15
8
(8)
(1)
(1)
11.4
6.7
12.5
–  Corporate and commercial
6,424
1
—
(121)
—
—
1.9
—
—
–  Non-bank financial institutions
1,427
—
—
(29)
—
—
2.0
—
—
Loans and advances to banks at
amortised cost
83
—
—
(3)
—
—
3.6
—
—
Other financial assets measured at
amortised cost
35
—
—
—
—
—
—
—
—
1Days past due (‘DPD’). Up-to-date accounts in stage 2 are not shown in amounts presented above.
Stage 2 decomposition as at 31 December 2021
The following disclosure presents the stage 2 decomposition of
gross carrying amount and allowances for ECL for loans and
advances to customers.
The table below discloses the reasons why an exposure moved
into stage 2 originally, and is therefore presented as a significant
increase in credit risk since origination.
The Quantitative classification is predominantly related to
exposures where the adjusted 12-month PD is greater than the
average 12-month PD; or accounts with a significant increase in
credit risk when the origination PD has doubled.
The Qualitative classification primarily accounts for management
judgemental adjustments, CRR deterioration, and other reasons.
For further details on our approach to the assessment of
significant increase in credit risk, see 'Summary of significant
accounting policies' on page 119.
.
HSBC Bank plc Annual Report and Accounts 2021
39
Loans and advances to customers1
Gross carrying amount
Allowance for ECL
ECL
Coverage
% Total
Personal
Corporate
and
commercial
Non-bank
financial
institutions
Total
Personal
Corporate
and
commercial
Non-bank
financial
institutions
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
%
Quantitative
561
3,611
162
4,334
(13)
(41)
(1)
(55)
1.3
Qualitative
102
4,260
198
4,560
(2)
(96)
(4)
(102)
2.2
30 DPD backstop2
23
195
9
227
(1)
—
—
(1)
0.4
Total Stage 2
686
8,066
369
9,121
(16)
(137)
(5)
(158)
1.7
The bank
Quantitative
26
1,731
95
1,852
(2)
(9)
—
(11)
0.6
Qualitative
62
1,162
121
1,345
—
(36)
—
(36)
2.7
30 DPD backstop2
—
—
—
—
—
—
—
—
—
Total Stage 2
88
2,893
216
3,197
(2)
(45)
—
(47)
1.5
1Where balances satisfy more than one of the above three criteria for determining a significant increase in credit risk, the corresponding gross
exposure and ECL have been assigned in order of categories presented.
2Days past due (‘DPD’).
Credit exposure
Maximum exposure to credit risk
(Audited)
This section provides information on balance sheet items and their
offsets as well as loan and other credit-related commitments. The
offset on derivatives remains in line with the movements
in maximum exposure amounts.
‘Maximum exposure to credit risk’ table
The following table presents our maximum exposure before taking
account of any collateral held or other credit enhancements (unless such
enhancements meet accounting offsetting requirements). The table
excludes financial instruments whose carrying amount best represents the
net exposure to credit risk and it excludes equity securities as they are not
subject to credit risk. For the financial assets recognised on the balance
sheet, the maximum exposure to credit risk equals their carrying amount;
for financial guarantees and other guarantees granted, it is the maximum
amount that we would have to pay if the guarantees were called upon. For
loan commitments and other credit-related commitments, it is generally
the full amount of the committed facilities.
The offset in the table relates to amounts where there is a legally
enforceable right of offset in the event of counterparty default and where,
as a result, there is a net exposure for credit risk purposes. However, as
there is no intention to settle these balances on a net basis under normal
circumstances, they do not qualify for net presentation for accounting
purposes. No offset has been applied to off-balance sheet collateral. In the
case of derivatives the offset column also includes collateral received in
cash and other financial assets.
Other credit risk mitigants
While not disclosed as an offset in the following ‘Maximum
exposure to credit risk’ table, other arrangements are in place
which reduce our maximum exposure to credit risk. These include
a charge over collateral on borrowers’ specific assets such as
residential properties, collateral held in the form of financial
instruments that are not held on balance sheet and short positions
in securities. In addition, for financial assets held as part of linked
insurance/investment contracts the risk is predominantly borne by
the policyholder. See Note 28 on the financial statements for
further details of collateral in respect of certain loans and
advances and derivatives.
Collateral available to mitigate credit risk is disclosed in the
Collateral section on page 64.
Maximum exposure to credit risk
(Audited)
2021
2020
Maximum
exposure
Offset
Net
Maximum
exposure
Offset
Net
The group
£m
£m
£m
£m
£m
£m
Loans and advances to customers held at amortised cost
91,177
(7,057)
84,120
101,491
(8,717)
92,774
–  personal
25,231
—
25,231
26,291
(3)
26,288
–  corporate and commercial
55,123
(6,228)
48,895
61,819
(7,662)
54,157
–  non-bank financial institutions
10,823
(829)
9,994
13,381
(1,052)
12,329
Loans and advances to banks at amortised cost
10,784
(88)
10,696
12,646
(137)
12,509
Other financial assets held at amortised cost
202,455
(10,239)
192,216
203,084
(10,604)
192,480
–  cash and balances at central banks
108,482
—
108,482
85,092
—
85,092
–  items in the course of collection from other banks
346
—
346
243
—
243
–  reverse repurchase agreements – non trading
54,448
(10,239)
44,209
67,577
(10,604)
56,973
–  financial investments
10
—
10
15
—
15
–  prepayments, accrued income and other assets
39,169
—
39,169
50,157
—
50,157
Derivatives
141,221
(139,668)
1,553
201,210
(200,137)
1,073
Total on balance sheet exposure to credit risk
445,637
(157,052)
288,585
518,431
(219,595)
298,836
Total off-balance sheet
146,261
—
146,261
165,368
—
165,368
–  financial and other guarantees1
26,840
—
26,840
18,177
—
18,177
–  loan and other credit-related commitments
119,421
—
119,421
147,191
—
147,191
At 31 Dec
591,898
(157,052)
434,846
683,799
(219,595)
464,204
1‘Financial and other guarantees’ represents 'Financial guarantees' and 'Performance and other guarantees' as disclosed in Note 30, net of ECL.
Report of the Directors | Risk
40
HSBC Bank plc Annual Report and Accounts 2021
2021
2020
Maximum
exposure
Offset
Net
Maximum
exposure
Offset
Net
The bank
£m
£m
£m
£m
£m
£m
Loans and advances to customers held at amortised cost
33,936
(7,047)
26,889
43,241
(8,711)
34,530
–  personal
3,674
—
3,674
3,569
—
3,569
–  corporate and commercial
20,874
(6,224)
14,650
25,520
(7,661)
17,859
–  non-bank financial institutions
9,388
(823)
8,565
14,152
(1,050)
13,102
Loans and advances to banks at amortised cost
6,778
—
6,778
8,063
—
8,063
Other financial assets held at amortised cost
135,109
(9,045)
126,064
135,948
(10,003)
125,945
–  cash and balances at central banks
63,008
—
63,008
48,777
—
48,777
–  items in the course of collection from other banks
211
—
211
37
—
37
–  reverse repurchase agreements – non trading
39,708
(9,045)
30,663
50,137
(10,003)
40,134
–  financial investments
3,337
—
3,337
2,214
—
2,214
–  prepayments, accrued income and other assets
28,845
—
28,845
34,783
—
34,783
Derivatives
125,787
(123,964)
1,823
182,066
(181,925)
141
Total on balance sheet exposure to credit risk
301,610
(140,056)
161,554
369,318
(200,639)
168,679
Total off-balance sheet
41,034
—
41,034
54,899
—
54,899
–  financial and other guarantees1
8,592
—
8,592
8,640
—
8,640
–  loan and other credit-related commitments
32,442
—
32,442
46,259
—
46,259
At 31 Dec
342,644
(140,056)
202,588
424,217
(200,639)
223,578
Maximum exposure to credit risk (continued)
1‘Financial and other guarantees’ represents 'Financial guarantees' and 'Performance and other guarantees' as disclosed in Note 30, net of ECL.
Concentration of exposure
We have a number of businesses with a broad range of products.
We operate in a number of markets with the majority of our
exposures in UK and France.
For an analysis of:
•financial investments, see Note 15 on the financial statements;
•trading assets, see Note 10 on the financial statements;
•derivatives, see page 67 and Note 14 on the financial
statements; and
•loans and advances by industry sector and by the location
of the principal operations of the lending subsidiary or by the
location of the lending branch, see page 62 for wholesale
lending and page 67 for personal lending.
Credit deterioration of financial instruments
(Audited)
A summary of our current policies and practices regarding the identification,
treatment and measurement of stage 1, stage 2 and stage 3 (credit impaired)
and POCI financial instruments can be found in Note 1.2 on the financial
statements.
Measurement uncertainty and sensitivity analysis
of ECL estimates
(Audited)
Despite a broad recovery in economic conditions during 2021, ECL
estimates continued to be subject to a high degree of uncertainty
and management judgements and estimates continue to reflect a
degree of caution, both in the selection of economic scenarios and
their weightings, and through management judgemental
adjustments. Releases of provisions were made progressively as
economic conditions recovered and by 31 December 2021 the
majority of the 2020 uplift in ECL provisions had been reversed.
The recognition and measurement of ECL involves the use of
significant judgement and estimation. We form multiple economic
scenarios based on economic forecasts, apply these assumptions
to credit risk models to estimate future credit losses, and
probability-weight the results to determine an unbiased ECL
estimate. Management judgemental adjustments are used to
address late-breaking events, data and model limitations, model
deficiencies and expert credit judgements. 
Methodology
Four economic scenarios are used to capture the current
economic environment and to articulate management’s view of
the range of potential outcomes. Scenarios produced to calculate
ECL are aligned to HSBC’s top and emerging risks.
In the second quarter of 2020, to ensure that the severe risks
associated with the pandemic were appropriately captured,
management added a fourth, more severe, scenario to use in the
measurement of ECL. Starting in the fourth quarter of 2021,
HSBC’s methodology has been adjusted so that the use of four
scenarios, of which two are Downside scenarios, is the standard
approach to ECL calculation.
Three of the scenarios are drawn from consensus forecasts and
distributional estimates. The Central scenario is deemed the ‘most
likely’ scenario, and usually attracts the largest probability
weighting, while the outer scenarios represent the tails of the
distribution, which are less likely to occur. The Central scenario is
created using the average of a panel of external forecasters.
Consensus Upside and Downside scenarios are created with
reference to distributions for select markets that capture
forecasters’ views of the entire range of outcomes. In the later
years of the scenarios, projections revert to long-term consensus
trend expectations. In the consensus outer scenarios, reversion to
trend expectations is done mechanically with reference to
historically observed quarterly changes in the values of
macroeconomic variables.
The fourth scenario, Downside 2, is designed to represent
management’s view of severe downside risks. It is a globally
consistent narrative-driven scenario that explores more extreme
economic outcomes than those captured by the consensus
scenarios. In this scenario, variables do not, by design, revert to
long-term trend expectations. They may instead explore alternative
states of equilibrium, where economic activity moves permanently
away from past trends.
Description of economic scenarios
The economic assumptions presented in this section have been
formed by HSBC with reference to external forecasts specifically
for the purpose of calculating ECL.
The global economy experienced a recovery in 2021, following an
unprecedented contraction in 2020. Restrictions to mobility and
travel eased across our key markets, aided by the successful roll-
out of vaccination programmes. The emergence of new variants
that potentially reduce the efficacy of vaccines remains a risk.
Economic forecasts remain subject to a high degree of
uncertainty. Risks to the economic outlook are dominated by the
progression of the pandemic, vaccine roll-out and the public policy
response. Geopolitical risks also remain significant and include
continued differences between the US and other countries with
China over a range of economic and strategic defence issues.
Continued uncertainty over the long-term economic relationship
between the UK and EU also present downside risks.
HSBC Bank plc Annual Report and Accounts 2021
41
The scenarios used to calculate ECL in the Annual Report and
Accounts 2021 are described below.
The consensus Central scenario
HSBC’s Central scenario features a continued recovery in
economic growth in 2022 as activity and employment gradually
return to the levels reached prior to the outbreak of Covid-19.
Our Central scenario assumes that the stringent restrictions on
activity, imposed across several countries and territories in 2020
and early 2021 are not repeated. The new viral strain that emerged
late in 2021, Omicron, has only a limited impact on the recovery,
according to this scenario. Consumer spending and business
investment, supported by elevated levels of private sector savings,
are expected to drive the economic recovery as fiscal and
monetary policy support recedes.
Regional differences in the speed of economic recovery in the
Central scenario reflect differences in the progression of the
pandemic, roll-out of vaccination programmes, national level
restrictions imposed and scale of support measures. Global GDP is
expected to grow by 4.2% in 2022 in the Central scenario and the
average rate of global GDP growth is 3.1% over the five-year
forecast period. This exceeds the average growth rate over the
five-year period prior to the onset of the pandemic.
The key features of our Central scenario are:
•Economic activity in our top markets continues to recover.
GDP grows at a moderate rate and exceeds pre-pandemic
levels across all our key markets in 2022.
•Unemployment declines to levels only slightly higher than
existed pre-pandemic, with the exception of France where the
downward trend in unemployment, related to structural
changes to the labour market, resumes.
•Covid-19-related fiscal spending recedes in 2022 as fewer
restrictions on activity allow fiscal support to be withdrawn.
Deficits remain high in several countries as they embark on
multi-year investment programmes to support recovery,
productivity growth and climate transition.
•Inflation across many of our key markets remains elevated
through 2022. Supply driven price pressures persist through
the first half of 2022 before gradually easing. In subsequent
years, inflation quickly converges back towards central bank
target rates.
•Policy interest rates in key markets rise gradually over our
projection period, in line with economic recovery.
•The West Texas Intermediate oil price is forecast to average
$62 per barrel over the projection period.
In the longer-term, growth reverts back towards similar rates that
existed prior to the pandemic, suggesting that the damage to long-
term economic prospects is expected to be minimal.
The Central scenario was first created with forecasts available in
November, and subsequently updated in December.
The following table describes key macroeconomic variables and
the probabilities assigned in the consensus Central scenario.
Central scenario 2022–2026
UK
France
%
%
GDP growth rate
2022: Annual average growth rate
5.0
3.9
2023: Annual average growth rate
2.1
2.1
2024: Annual average growth rate
1.9
1.6
5-year average
2.5
2.1
Unemployment rate
2022: Annual average rate
4.5
8.0
2023: Annual average rate
4.3
7.7
2024: Annual average rate
4.2
7.6
5-year average
4.3
7.7
House price growth
2022: Annual average growth rate
5.5
4.9
2023: Annual average growth rate
3.3
4.6
2024: Annual average growth rate
3.3
4.0
5-year average
3.5
3.9
Short-term interest rate
2022: Annual average rate
1.0
(0.5)
2023: Annual average rate
1.3
(0.3)
2024: Annual average rate
1.2
(0.1)
5-year average
1.2
(0.2)
Probability
60
60
The graphs comparing the respective Central scenarios in the
fourth quarters of 2020 and 2021 reveal the extent of economic
dislocation that occurred in 2020 and compare current economic
expectations with those held a year ago.
GDP growth: Comparison
UK
Note: Real GDP shown as year-on-year percentage change.
France
Note: Real GDP shown as year-on-year percentage change.
Report of the Directors | Risk
42
HSBC Bank plc Annual Report and Accounts 2021
The consensus Upside scenario
Compared with the Central scenario, the consensus Upside
scenario features a faster recovery in economic activity during the
first two years, before converging to long-run trend expectations.
The scenario is consistent with a number of key upside risk
themes. These include the orderly and rapid global abatement of
Covid-19 via successful containment and ongoing vaccine
efficacy; de-escalation of tensions between the US and China;
continued fiscal and monetary support; and smooth relations
between the UK and the EU.
The following table describes key macroeconomic variables and
the probabilities assigned in the consensus Upside scenario.
Consensus Upside scenario best outcome
UK
France
%
%
GDP growth rate
9.9
(1Q22)
7.0
(2Q22)
Unemployment rate
3.0
(4Q23)
6.6
(4Q23)
House price growth
7.4
(2Q23)
6.8
(2Q22)
Short term interest rate
0.7
(1Q22)
(0.5)
(1Q22)
Probability
10
10
Note: Extreme point in the consensus Upside is ‘best outcome’ in the
scenario, for example the highest GDP growth and the lowest
unemployment rate, in the first two years of the scenario.
Downside scenarios
The progress of the pandemic and the ongoing public policy
response continues to be a key source of risk. Downside scenarios
assume that new strains of the virus result in an acceleration in
infection rates and increased pressure on public health services,
necessitating restrictions on activity. The reimposition of such
restrictions could be assumed to have a damaging effect on
consumer and business confidence.
Government fiscal programmes in advanced economies in 2020
and 2021 were supported by accommodative actions taken by
central banks. These measures have provided households and
firms with significant support. An inability or unwillingness to
continue with such support or the untimely withdrawal of support
present a downside risk to growth.
While Covid-19 and related risks dominate the economic outlook,
geopolitical risks also present a threat. These risks include:
•continued differences between the US and other countries
with China, which could affect sentiment and restrict global
economic activity; and
•potential disagreements between the UK and the EU, which
may hinder the ability to reach a more comprehensive
agreement on trade and services, despite the Trade and
Cooperation Agreement averting a disorderly UK departure.
The consensus Downside scenario
In the consensus Downside scenario, economic recovery is
weaker compared with the Central scenario as key global risks,
including Covid-19, escalate. Compared to the Central scenario
GDP growth is expected to be lower, unemployment rates rise
moderately and asset and commodity prices fall, before gradually
recovering towards their long-run trend expectations.
The following table describes key macroeconomic variables and
the probabilities assigned in the consensus Downside scenario.
Consensus Downside scenario worst outcome
UK
France
%
%
GDP growth rate
(0.5)
(3Q23)
0.5
(4Q23)
Unemployment rate
5.6
(4Q22)
9.1
(3Q22)
House price growth
(4.2)
(1Q23)
2.0
(4Q22)
Short-term interest rate
0.2
(4Q23)
(0.5)
(1Q22)
Probability
15
15
Note: Extreme point in the consensus Downside is ‘worst outcome’ in
the scenario, for example lowest GDP growth and the highest
unemployment rate, in the first two years of the scenario.
Downside 2 scenario
The Downside 2 scenario features a deep global recession. In this
scenario, new Covid-19 variants emerge that cause infections to
rise sharply in 2022, resulting in setbacks to vaccination
programmes and the rapid imposition of restrictions on mobility
and travel across some countries. The scenario also assumes
governments and central banks are unable to significantly increase
fiscal and monetary support, which results in abrupt corrections in
labour and asset markets.
The following table describes key macroeconomic variables and
the probabilities assigned in the Downside 2 scenario.
Downside 2 scenario worst outcome
UK
France
%
%
GDP growth rate
(4.6)
(4Q22)
(4.6)
(4Q22)
Unemployment rate
7.5
(2Q23)
10.0
(4Q23)
House price growth
(14.2)
(2Q23)
(6.0)
(2Q23)
Short-term interest rate
1.6
(2Q22)
0.4
(2Q22)
Probability
15
15
Note: Extreme point in the Downside 2 is ‘worst outcome’ in the
scenario, for example lowest GDP growth and the highest
unemployment rate, in the first two years of the scenario.
Scenario weighting
In reviewing the economic conjuncture, the level of uncertainty
and risk, management has considered both global and country-
specific factors. This has led management to assign scenario
probabilities that are tailored to its view of uncertainty in individual
markets.
To inform its view, management has considered the progression
of the virus in individual countries, the speed of vaccine roll-outs,
the degree of current and expected future government support
and connectivity with other countries. Management has also been
guided by the policy response and economic performance through
the pandemic, as well as the evidence that economies have
adapted as the virus has progressed.
A key consideration in the fourth quarter was the emergence of
the new variant, Omicron. The virulence and severity of the new
strain, in addition to the continued efficacy of vaccines against it,
was unknown when the variant first emerged. Management
therefore determined that uncertainty attached to forecasts had
increased and sought to reflect this in scenario weightings.
The UK and France faced the greatest economic uncertainties of
our key markets. The emergence of Omicron exacerbated the rise
in case rates and hospitalisations in both countries, necessitating
the imposition of new restrictions. These increase uncertainties
around economic growth and employment. Accordingly, the
Central scenario was assigned a 60% weight in both countries.
The two Downside scenarios were given a combined probability
weighting of 30% for both the UK and France.
The following graphs show the historical and forecasted GDP
growth rate for the various economic scenarios in UK and France.
.
UK
HSBC Bank plc Annual Report and Accounts 2021
43
France
Critical accounting estimates and judgements
The calculation of ECL under IFRS 9 involves significant
judgements, assumptions and estimates. Despite a general
recovery in economic conditions during 2021, the level of
estimation uncertainty and judgement has remained high during
2021 as a result of the ongoing economic effects of the Covid-19
pandemic and other sources of economic instability, including
significant judgements relating to:
•the selection and weighting of economic scenarios, given
rapidly changing economic conditions in an unprecedented
manner, uncertainty as to the effect of government and central
bank support measures designed to alleviate adverse economic
impacts, and a wider distribution of economic forecasts than
before the pandemic. The key judgements are the length of
time over which the economic effects of the pandemic will
occur, and the speed and shape of recovery. The main factors
include the effectiveness of pandemic containment measures,
the pace of roll-out and effectiveness of vaccines, and the
emergence of new variants of the virus, plus a range of
geopolitical uncertainties, which together represent a high
degree of estimation uncertainty, particularly in assessing
Downside scenarios;
•estimating the economic effects of those scenarios on ECL,
where there is no observable historical trend that can be
reflected in the models that will accurately represent the effects
of the economic changes of the severity and speed brought
about by the Covid-19 pandemic and the recovery from those
conditions. Modelled assumptions and linkages between
economic factors and credit losses may underestimate or
overestimate ECL in these conditions, and there is significant
uncertainty in the estimation of parameters such as collateral
values and loss severity; and
•the identification of customers experiencing significant
increases in credit risk and credit impairment, particularly
where those customers have accepted payment deferrals and
other reliefs designed to address short-term liquidity issues
given muted default experience to date. The use of
segmentation techniques for indicators of significant increases
in credit risk involves significant estimation uncertainty.
How economic scenarios are reflected in ECL
calculations
Models are used to reflect economic scenarios on ECL estimates.
As described above, modelled assumptions and linkages based on
historical information could not alone produce relevant information
under the conditions experienced in 2021, and judgemental
adjustments were still required to support modelled outcomes. 
We have developed globally consistent methodologies for the
application of forward economic guidance into the calculation of
ECL for wholesale and retail credit risk. These standard
approaches are described below, followed by the management
judgemental adjustments made, including those to reflect the
circumstances experienced in 2021. 
For our wholesale portfolios, a global methodology is used for the
estimation of the term structure of probability of default (‘PD’) and
loss given default (‘LGD’). For PDs, we consider the correlation of
forward economic guidance to default rates for a particular
industry in a country. For LGD calculations, we consider the
correlation of forward economic guidance to collateral values and
realisation rates for a particular country and industry. PDs and
LGDs are estimated for the entire term structure of each
instrument.
For impaired loans, LGD estimates take into account independent
recovery valuations provided by external consultants where
available or internal forecasts corresponding to anticipated
economic conditions and individual company conditions. In
estimating the ECL on impaired loans that are individually
considered not to be significant, we incorporate forward economic
guidance proportionate to the probability-weighted outcome and
the Central scenario outcome for non-stage 3 populations.
For our retail portfolios, the impact of economic scenarios on PD is
modelled at a portfolio level. Historical relationships between
observed default rates and macroeconomic variables are
integrated into IFRS 9 ECL estimates by using economic response
models. The impact of these scenarios on PD is modelled over a
period equal to the remaining maturity of the underlying asset or
assets. The impact on LGD is modelled for mortgage portfolios by
forecasting future loan-to-value (‘LTV’) profiles for the remaining
maturity of the asset by using national level forecasts of the house
price index and applying the corresponding LGD expectation.
These models are based largely on historical observations and
correlations with default rates. Management judgemental
adjustments are described below.
Management judgemental adjustments
In the context of IFRS 9, management judgemental adjustments
are short-term increases or decreases to the ECL at either a
customer, segment or portfolio level to account for late-breaking
events, model and data limitations and deficiencies, and expert
credit judgement applied following management review and
challenge.
At 31 December 2021, management judgements were applied to
reflect credit risk dynamics not captured by our models. The
drivers of the management judgemental adjustments reflect the
changing economic outlook and evolving risks across our
geographies.
Where the macroeconomic and portfolio risk outlook continues to
improve, supported by low levels of observed defaults,
adjustments initially taken to reflect increased risk expectations
have been retired or reduced.
However, other adjustments have increased where modelled
outcomes are overly sensitive and not aligned to observed
changes in the risk of the underlying portfolios during the
pandemic, or where sector-specific risks are not adequately
captured.
The effect of management judgemental adjustments is considered
for balances and ECL when determining whether or not a
significant increase in credit risk has occurred and are attributed or
allocated to a stage as appropriate. This is in accordance with the
internal adjustments framework.
Management judgemental adjustments are reviewed under the
governance process for IFRS 9 (as detailed in the section ‘Credit
risk management’ on page 32). Review and challenge focuses on
the rationale and quantum of the adjustments with a further
review carried out by the second line of defence where significant.
For some management judgemental adjustments, internal
frameworks establish the conditions under which these
adjustments should no longer be required and as such are
considered as part of the governance process. This internal
governance process allows management judgemental
adjustments to be reviewed regularly and, where possible, to
reduce the reliance on these through model recalibration or
redevelopment, as appropriate.
Management judgemental adjustments made in estimating the
scenario-weighted reported ECL at 31 December 2021 are set out
in the following table.
Report of the Directors | Risk
44
HSBC Bank plc Annual Report and Accounts 2021
The table includes adjustments in relation to data and model
limitations, including those driven by late-breaking events and
sector-specific risks and as a result of the regular process of model
development and implementation.
Management judgemental adjustments to ECL at 31 December
20211
Retail
Wholesale
Total
£m
£m
£m
Low-risk counterparties (banks,
sovereigns and government entities)
—
(4)
(4)
Corporate lending adjustments
—
31
31
Retail lending probability of default
adjustments
—
—
—
Retail model default timing adjustments
—
—
—
Macroeconomic-related adjustments
17
—
17
Pandemic-related economic recovery
adjustments
3
—
3
Other retail lending adjustments
—
—
—
Total
20
27
47
Management judgemental adjustments to ECL at 31 December
20201
Retail
Wholesale
Total
£m
£m
£m
Low-risk counterparties (banks,
sovereigns and government entities)
(5)
8
3
Corporate lending adjustments
—
56
56
Retail lending probability of default
adjustments
(10)
—
(10)
Retail model default timing adjustments
3
—
3
Macroeconomic-related adjustments
11
—
11
Pandemic-related economic recovery
adjustments
—
—
—
Other retail lending adjustments
4
—
4
Total
3
64
67
1Management judgemental adjustments presented in the table reflect
increases or (decreases) to ECL, respectively.
Management judgemental adjustments at 31 December 2021
were an increase to ECL of £27m for the wholesale portfolio and
an increase to ECL of £20m for the retail portfolio.
During 2021, management judgemental adjustments reflected an
evolving macroeconomic outlook and the relationship of the
modelled ECL to this outlook and to late-breaking and sector-
specific risks.
At 31 December 2021, wholesale management judgemental
adjustments were an ECL increase of £27m (31 December 2020:
£64m increase).
•Adjustments relating to low credit-risk exposures decreased
ECL by £4m at 31 December 2021 (31 December 2020: £8m
increase). These were mainly to highly rated banks, sovereigns
and US government-sponsored entities, where modelled credit
factors did not fully reflect the underlying fundamentals of
these entities or the effect of government support and
economic programmes in the Covid-19 environment. The
decrease in adjustment impact relative to 31 December 2020
was mostly driven by increased alignment of modelled
outcomes to management expectations following changes in
systems and data.
•Adjustments to corporate exposures increased ECL by £31m at
31 December 2021 (31 December 2020: £56m increase). These
principally reflected the outcome of management judgements
for high-risk and vulnerable sectors in some of our key markets,
supported by credit experts’ input, portfolio risk metrics,
quantitative analyses and benchmarks. Considerations include
risk of individual exposures under different macroeconomic
scenarios and comparison of key risk metrics to pre-pandemic
levels, resulting in either releases or increases to ECL. The
decrease in adjustment impact relative to 31 December 2020
    was mostly driven by management judgements as a result of
the effect of further improvement of macroeconomic scenarios
on modelled outcomes and increased dislocation of modelled
outcomes to management expectations for high-risk sectors
and due to late-breaking events not fully reflected in the
underlying data.
At 31 December 2021, retail management judgemental
adjustments were an ECL increase of £20m (31 December 2020:
£3m increase).
•Pandemic-related economic recovery adjustments increased
ECL by £3m (31 December 2020: £0) to adjust for the effects of
the volatile pace of recovery from the pandemic. This is where
in management’s judgement, supported by quantitative
analyses of portfolio and economic metrics, modelled
outcomes are overly sensitive given the limited observed
deterioration in the underlying portfolio during the pandemic.
•Positive macroeconomic-related adjustments have remained
broadly stable in comparison to 31 December 2020.
Economic scenarios sensitivity analysis of ECL
estimates
Management considered the sensitivity of the ECL outcome
against the economic forecasts as part of the ECL governance
process by recalculating the ECL under each scenario described
above for selected portfolios, applying a 100% weighting to each
scenario in turn. The weighting is reflected in both the
determination of a significant increase in credit risk and the
measurement of the resulting ECL.
The ECL calculated for the Upside and Downside scenarios should
not be taken to represent the upper and lower limits of possible
ECL outcomes. The impact of defaults that might occur in the
future under different economic scenarios is captured by
recalculating ECL for loans at the balance sheet date.
There is a particularly high degree of estimation uncertainty in
numbers representing more severe risk scenarios when assigned a
100% weighting.
For wholesale credit risk exposures, the sensitivity analysis
excludes ECL and financial instruments related to defaulted (stage
3) obligors. It is generally impracticable to separate the effect of
macroeconomic factors in individual assessments of obligors in
default. The measurement of stage 3 ECL is relatively more
sensitive to credit factors specific to the obligor than future
economic scenarios, and loans to defaulted obligors are a small
portion of the overall wholesale lending exposure, even if
representing the majority of the allowance for ECL. Therefore, the
sensitivity analysis to macroeconomic scenarios does not capture
the residual estimation risk arising from wholesale stage 3
exposures.
For retail credit risk exposures, the sensitivity analysis includes
ECL for loans and advances to customers related to defaulted
obligors. This is because the retail ECL for secured mortgage
portfolios including loans in all stages is sensitive to
macroeconomic variables.
Wholesale and retail sensitivity
The wholesale and retail sensitivity analysis is stated inclusive of
management judgemental adjustments, as appropriate to each
scenario. The results tables exclude portfolios held by the
insurance business and small portfolios, and as such cannot be
directly compared to personal and wholesale lending presented in
other credit risk tables. Additionally, in both the wholesale and
retail analysis, the comparative period results for Downside 2
scenarios are also not directly comparable with the current period,
because they reflect different risk profiles relative to the consensus
scenarios for the period end.
HSBC Bank plc Annual Report and Accounts 2021
45
Wholesale analysis
IFRS 9 ECL sensitivity to future economic conditions1,2
UK
France
£m
£m
ECL of loans and advances to customers at
31 December 2021
Reported ECL
104
98
Consensus scenarios
Central scenario
90
89
Upside scenario
71
78
Downside scenario
109
120
Downside 2 scenario
189
138
Gross carrying amount2
142,450
120,955
ECL of loans and advances to customers at
31 December 2020
Reported ECL
317
88
Consensus scenarios
Central scenario
219
82
Upside scenario
156
73
Downside scenario
339
98
Additional Downside scenario
657
178
Gross carrying amount2
137,825
123,444
1ECL sensitivity includes off-balance sheet financial instruments that
are subject to significant measurement uncertainty.
2Includes low credit-risk financial instruments such as debt
instruments at FVOCI, which have high carrying amounts but low
ECL under all the above scenarios.
Retail analysis
IFRS 9 ECL sensitivity to future economic conditions1
UK
France
£m
£m
ECL of loans and advances to customers at
31 December 2021
Reported ECL
5
91
Consensus scenarios
Central scenario
4
91
Upside scenario
4
91
Downside scenario
5
92
Downside 2 scenario
10
93
Gross carrying amount
2,007
18,295
IFRS 9 ECL sensitivity to future economic conditions1
UK
France
ECL of loans and advances to customers at
31 December 2020
Reported ECL
12
114
Consensus scenarios
Central scenario
11
113
Upside scenario
8
111
Downside scenario
14
115
Additional Downside scenario
17
118
Gross carrying amount
1,980
19,254
1ECL sensitivities exclude portfolios utilising less complex modelling
approaches.
Reconciliation of changes in gross carrying/
nominal amount and allowances for loans and
advances to banks and customers including loan
commitments and financial guarantees
The following disclosure provides a reconciliation by stage of the
group’s gross carrying/nominal amount and allowances for loans
and advances to banks and customers, including loan
commitments and financial guarantees. Movements are calculated
on a quarterly basis and therefore fully capture stage movements
between quarters. If movements were calculated on a year-to-date
basis they would only reflect the opening and closing position of
the financial instrument. The transfers of financial instruments
represent the impact of stage transfers upon the gross carrying/
nominal amount and associated allowance for ECL.
The net remeasurement of ECL arising from stage transfers
represents the increase or decrease due to these transfers, for
example, moving from a 12-month (stage 1) to a lifetime (stage 2)
ECL measurement basis. Net remeasurement excludes the
underlying customer risk rating (‘CRR’)/probability of default (‘PD’)
movements of the financial instruments transferring stage. This is
captured, along with other credit quality movements in the
‘changes in risk parameters – credit quality’ line item.
Changes in ‘New financial assets originated or purchased’, ‘Assets
derecognised (including final repayments)’ and ‘Changes to risk
parameters – further lending/repayments’ represent the impact
from volume movements within the group’s lending portfolio.
Report of the Directors | Risk
46
HSBC Bank plc Annual Report and Accounts 2021
Reconciliation of changes in gross carrying/nominal amount and allowances for loans and advances to banks and customers including
loan commitments and financial guarantees1
(Audited)
Non credit – impaired
Credit – impaired
Stage 1
Stage 2
Stage 3
POCI
Total
Gross
carrying/
nominal
amount
Allowance
for ECL
Gross
carrying/
nominal
amount
Allowance
for ECL
Gross
carrying/
nominal
amount
Allowance
for ECL
Gross
carrying/
nominal
amount
Allowance
for ECL
Gross
carrying/
nominal
amount
Allowance
for ECL
The group
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
At 1 Jan 2021
184,715
(180)
31,726
(378)
3,352
(1,050)
40
(12)
219,833
(1,620)
Transfers of financial instruments
5,245
(66)
(5,617)
90
372
(24)
—
—
—
—
–  Transfers from Stage 1 to Stage 2
(8,431)
14
8,431
(14)
—
—
—
—
—
—
–  Transfers from Stage 2 to Stage 1
13,714
(78)
(13,714)
78
—
—
—
—
—
—
–  Transfers to Stage 3
(93)
—
(401)
28
494
(28)
—
—
—
—
–  Transfers from Stage 3
55
(2)
67
(2)
(122)
4
—
—
—
—
Net remeasurement of ECL arising from
transfer of stage
—
43
—
(22)
—
(5)
—
—
—
16
New financial assets originated or
purchased
72,348
(55)
—
—
—
—
—
—
72,348
(55)
Asset derecognised (including final
repayments)
(57,098)
6
(3,481)
32
(454)
95
(3)
2
(61,036)
135
Changes to risk parameters – further
lending/repayments
(16,766)
76
(3,927)
62
(213)
40
(29)
2
(20,935)
180
Changes to risk parameters – credit
quality
—
54
—
7
—
(176)
—
—
—
(115)
Changes to model used for ECL
calculation
—
2
—
9
—
—
—
—
—
11
Assets written off
—
—
—
—
(152)
152
(5)
5
(157)
157
Credit related modifications that resulted
in derecognition
—
—
—
—
—
—
—
—
—
—
Foreign exchange
(7,512)
2
(1,060)
10
(126)
46
(1)
1
(8,699)
59
Others2
(1,320)
—
(170)
2
—
(1)
—
—
(1,490)
1
At 31 Dec 2021
179,612
(118)
17,471
(188)
2,779
(923)
2
(2)
199,864
(1,231)
ECL income statement release/(charge)
for the period
126
88
(46)
4
172
Recoveries
3
Others
(23)
Total ECL income statement
release for the period
152
At 31 Dec 2021
12 months ended 31 Dec 2021
Gross carrying/nominal
amount
Allowance for ECL
ECL release/(charge)
 
£m
£m
£m
As above
199,864
(1,231)
152
Other financial assets measured at amortised cost
202,137
(9)
(1)
Non-trading reverse purchase agreement commitments
30,005
—
—
Performance and other guarantees not considered for IFRS 9
18
Summary of financial instruments to which the impairment requirements in
IFRS 9 are applied/Summary consolidated income statement
432,006
(1,240)
169
Debt instruments measured at FVOCI
41,188
(19)
5
Total allowance for ECL/total income statement ECL release for the period
n/a
(1,259)
174
1Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
2Includes the period on period movement in exposures relating to other HSBC Group companies. As at 31 December 2021, these amounted to
£(1)bn and were classified as Stage 1 with no ECL.
HSBC Bank plc Annual Report and Accounts 2021
47
Reconciliation of changes in gross carrying/nominal amount and allowances for loans and advances to banks and customers including
loan commitments and financial guarantees1 (continued)
(Audited)
Non credit – impaired
Credit – impaired
Stage 1
Stage 2
Stage 3
POCI
Total
Gross
carrying/
nominal
amount
Allowance
for ECL
Gross
carrying/
nominal
amount
Allowance
for ECL
Gross
carrying/
nominal
amount
Allowance
for ECL
Gross
carrying/
nominal
amount
Allowance
for ECL
Gross
carrying/
nominal
amount
Allowance
for ECL
The group
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
At 1 Jan 2020
195,249
(132)
11,103
(143)
2,235
(796)
78
(33)
208,665
(1,104)
Transfers of financial instruments:
(19,123)
(62)
16,792
93
2,331
(31)
—
—
—
—
–  Transfers from Stage 1 to Stage 2
(31,600)
54
31,600
(54)
—
—
—
—
—
—
–  Transfers from Stage 2 to Stage 1
12,821
(121)
(12,821)
121
—
—
—
—
—
—
–  Transfers to Stage 3
(351)
7
(2,147)
32
2,498
(39)
—
—
—
—
–  Transfers from Stage 3
7
(2)
160
(6)
(167)
8
—
—
—
—
Net remeasurement of ECL arising from
transfer of stage
—
60
—
(67)
—
(2)
—
—
—
(9)
New financial assets originated or
purchased
95,477
(62)
—
—
—
—
10
(1)
95,487
(63)
Asset derecognised (including final
repayments)
(72,860)
6
(2,553)
21
(998)
139
(16)
1
(76,427)
167
Changes to risk parameters –  further
lending/repayments
(21,912)
48
5,666
6
(41)
101
(11)
(2)
(16,298)
153
Changes to risk parameters – credit
quality
—
(53)
—
(248)
—
(687)
—
—
—
(988)
Changes to model used for ECL
calculation
—
10
—
(36)
—
—
—
—
—
(26)
Assets written off
—
—
—
—
(252)
252
(23)
23
(275)
275
Credit related modifications that resulted
in derecognition
—
—
—
—
(18)
5
—
—
(18)
5
Foreign exchange
6,058
5
498
(3)
95
(33)
2
—
6,653
(31)
Others2
1,826
—
220
(1)
—
2
—
—
2,046
1
At 31 Dec 2020
184,715
(180)
31,726
(378)
3,352
(1,050)
40
(12)
219,833
(1,620)
ECL Income statement charge for the
period
9
(324)
(449)
(2)
(766)
Recoveries
2
Others
(17)
Total ECL income statement charge for
the period
(781)
At 31 Dec 2020
12 months ended 31 Dec 2020
Gross carrying/nominal
amount
Allowance for ECL
ECL charge
 
£m
£m
£m
As above
219,833
(1,620)
(781)
Other financial assets measured at amortised cost
202,763
(12)
(2)
Non-trading reverse purchase agreement commitments
42,794
—
—
Performance and other guarantees not considered for IFRS 9
(17)
Summary of financial instruments to which the impairment requirements in IFRS 9
are applied/Summary consolidated income statement
465,390
(1,632)
(800)
Debt instruments measured at FVOCI
51,713
(22)
(8)
Total allowance for ECL/total income statement ECL charge for the period
n/a
(1,654)
(808)
1Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
2Includes the period on period movement in exposures relating to other HSBC Group companies. As at 31 December 2020, these amounted to
£2bn and were classified as Stage 1 with no ECL.
Report of the Directors | Risk
48
HSBC Bank plc Annual Report and Accounts 2021
Reconciliation of changes in gross carrying/nominal amount and allowances for loans and advances to banks and customers including
loan commitments and financial guarantees1
(Audited)
Non credit – impaired
Credit – impaired
Stage 1
Stage 2
Stage 3
POCI
Total
Gross
carrying/
nominal
amount
Allowance
for ECL
Gross
carrying/
nominal
amount
Allowance
for ECL
Gross
carrying/
nominal
amount
Allowance
for ECL
Gross
carrying/
nominal
amount
Allowance
for ECL
Gross
carrying/
nominal
amount
Allowance
for ECL
The bank
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
At 1 Jan 2021
78,422
(121)
14,161
(213)
1,395
(363)
2
(2)
93,980
(699)
Transfers of financial instruments
4,795
(27)
(4,840)
39
45
(12)
—
—
—
—
–  Transfers from Stage 1 to Stage 2
(2,261)
3
2,261
(3)
—
—
—
—
—
—
–  Transfers from Stage 2 to Stage 1
7,043
(29)
(7,043)
29
—
—
—
—
—
—
–  Transfers to Stage 3
—
—
(59)
13
59
(13)
—
—
—
—
–  Transfers from Stage 3
13
(1)
1
—
(14)
1
—
—
—
—
Net remeasurement of ECL arising from
transfer of stage
—
13
—
(1)
—
(1)
—
—
—
11
New financial assets originated or
purchased
11,532
(31)
—
—
—
—
—
—
11,532
(31)
Asset derecognised (including final
repayments)
(11,861)
2
(1,836)
17
(80)
4
(2)
1
(13,779)
24
Changes to risk parameters – further
lending/repayments
(13,051)
58
(1,813)
32
(190)
4
—
—
(15,054)
94
Changes to risk parameters – credit
quality
—
48
—
59
—
13
—
—
—
120
Changes to model used for ECL
calculation
—
2
—
9
—
—
—
—
—
11
Assets written off
—
—
—
—
(78)
78
(1)
1
(79)
79
Credit related modifications that resulted
in derecognition
—
—
—
—
—
—
—
—
—
—
Foreign exchange
(76)
—
(15)
—
(4)
1
—
—
(95)
1
Others2
(4,051)
—
—
—
—
—
—
—
(4,051)
—
At 31 Dec 2021
65,710
(56)
5,657
(58)
1,088
(276)
(1)
—
72,454
(390)
ECL income statement release for the
period
92
116
20
1
229
Recoveries
1
Others
(23)
Total ECL income release for the
period
207
At 31 Dec 2021
12 months ended 31 Dec 2021
Gross carrying/nominal
amount
Allowance for ECL
ECL release
 
£m
£m
£m
As above
72,454
(390)
207
Other financial assets measured at amortised cost
135,033
(1)
1
Non-trading reverse purchase agreement commitments
1,139
—
—
Performance and other guarantees not considered for IFRS 9
4
Summary of financial instruments to which the impairment requirements in
IFRS 9 are applied/Summary consolidated income statement
208,626
(391)
212
Debt instruments measured at FVOCI
23,152
(4)
5
Total allowance for ECL/total income statement ECL release for the period
n/a
(395)
217
1Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
2Includes the period on period movement in exposures relating to other HSBC Group companies. As at 31 December 2021, these amounted to
£(4)bn and were classified as Stage 1 with no ECL.
HSBC Bank plc Annual Report and Accounts 2021
49
Reconciliation of changes in gross carrying/nominal amount and allowances for loans and advances to banks and customers including
loan commitments and financial guarantees1 (continued)
(Audited)
Non-credit – impaired
Credit – impaired
Stage 1
Stage 2
Stage 3
POCI
Total
Gross
carrying/
nominal
amount
Allowance
for ECL
Gross
carrying/
nominal
amount
Allowance
for ECL
Gross
carrying/
nominal
amount
Allowance
for ECL
Gross
carrying/
nominal
amount
Allowance/
for ECL
Gross
carrying/
nominal
amount
Allowance/
for ECL
The bank
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
At 1 Jan 2020
94,937
(77)
4,582
(77)
753
(242)
38
(24)
100,310
(420)
Transfers of financial instruments:
(12,397)
(27)
11,422
47
975
(20)
—
—
—
—
–  Transfers from Stage 1 to Stage 2
(17,892)
36
17,892
(36)
—
—
—
—
—
—
–  Transfers from Stage 2 to Stage 1
5,676
(68)
(5,676)
68
—
—
—
—
—
—
–  Transfers to Stage 3
(183)
5
(845)
17
1,028
(22)
—
—
—
—
–  Transfers from Stage 3
2
—
51
(2)
(53)
2
—
—
—
—
Net remeasurement of ECL arising from
transfer of stage
—
26
—
(34)
—
—
—
—
—
(8)
New financial assets originated or
purchased
14,911
(43)
—
—
—
—
—
—
14,911
(43)
Asset derecognised (including final
repayments)
(7,687)
2
(666)
2
(167)
9
(15)
1
(8,535)
14
Changes to risk parameters – further
lending/repayments
(5,898)
35
(1,201)
13
(25)
(9)
2
(3)
(7,122)
36
Changes to risk parameters – credit
quality
—
(54)
—
(129)
—
(232)
—
1
—
(414)
Changes to model used for ECL
calculation
—
10
—
(36)
—
—
—
—
—
(26)
Assets written off
—
—
—
—
(118)
118
(23)
23
(141)
141
Credit related modifications that resulted
in derecognition
—
—
—
—
(16)
4
—
—
(16)
4
Foreign exchange
(60)
7
24
1
(2)
4
—
—
(38)
12
Others2
(5,384)
—
—
—
(5)
5
—
—
(5,389)
5
At 31 Dec 2020
78,422
(121)
14,161
(213)
1,395
(363)
2
(2)
93,980
(699)
ECL income statement charge for the
period
(24)
(184)
(232)
(1)
(441)
Recoveries
—
Others
(12)
Total ECL income statement charge for
the period
(453)
.
At 31 Dec 2020
12 months ended 31 Dec 2020
Gross carrying/nominal
amount
Allowance for ECL
ECL charge
 
£m
£m
£m
As above
93,980
(699)
(453)
Other financial assets measured at amortised cost
135,900
(1)
4
Non-trading reverse purchase agreement commitments
4,747
—
—
Performance and other guarantees not considered for IFRS 9
(3)
Summary of financial instruments to which the impairment requirements in IFRS 9
are applied/Summary consolidated income statement
234,627
(700)
(452)
Debt instruments measured at FVOCI
28,699
(9)
(5)
Total allowance for ECL/total income statement ECL charge for the period
n/a
(709)
(457)
1Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
2Includes the period on period movement in exposures relating to other HSBC Group companies. As at 31 December 2020, these amounted to
£(5)bn and were classified as Stage 1 with no ECL.
Credit quality
Credit quality of financial instruments
(Audited)
We assess the credit quality of all financial instruments that are
subject to credit risk. The credit quality of financial instruments is
a point-in-time assessment of the probability of default (‘PD’),
whereas stages 1 and 2 are determined based on relative
deterioration of credit quality since initial recognition.
Accordingly, for non-credit-impaired financial instruments, there is
no direct relationship between the credit quality assessment and
stages 1 and 2, though typically the lower credit quality bands
exhibit a higher proportion in stage 2.
The five credit quality classifications each encompass a range of
granular internal credit rating grades assigned to wholesale and
personal lending businesses and the external ratings attributed by
external agencies to debt securities, as shown in the table on page
33.
Report of the Directors | Risk
50
HSBC Bank plc Annual Report and Accounts 2021
Distribution of financial instruments by credit quality at 31 December 2021
(Audited)
Gross carrying/notional amount
Allowance
for ECL
Net
Strong
Good
Satisfactory
Sub-
standard
Credit
impaired
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
In-scope for IFRS 9
Loans and advances to customers held at
amortised cost
41,339
20,531
23,469
4,512
2,480
92,331
(1,154)
91,177
–  personal
18,956
4,136
1,793
56
453
25,394
(163)
25,231
–  corporate and commercial
16,533
13,867
19,597
4,305
1,785
56,087
(964)
55,123
–  non-bank financial institutions
5,850
2,528
2,079
151
242
10,850
(27)
10,823
Loans and advances to banks held at amortised
cost
8,649
320
1,815
5
—
10,789
(5)
10,784
Cash and balances at central banks
108,133
198
151
—
—
108,482
—
108,482
Items in the course of collection from other
banks
343
—
3
—
—
346
—
346
Reverse repurchase agreements – non-trading
47,071
6,355
1,022
—
—
54,448
—
54,448
Financial investments
2
—
8
—
—
10
—
10
Prepayments, accrued income and other assets
36,558
666
1,574
11
42
38,851
(9)
38,842
–  endorsements and acceptances
105
61
23
—
7
196
—
196
–  accrued income and other
36,453
605
1,551
11
35
38,655
(9)
38,646
Debt instruments measured at fair value
through other comprehensive income1
36,410
1,899
1,406
118
—
39,833
(19)
39,814
Out-of-scope for IFRS 9
Trading assets
28,110
5,331
8,985
350
—
42,776
—
42,776
Other financial assets designated and otherwise
mandatorily measured at fair value through
profit or loss
2,246
304
2,644
3
—
5,197
—
5,197
Derivatives
111,471
25,487
4,054
207
2
141,221
—
141,221
Total gross carrying amount on balance
sheet
420,332
61,091
45,131
5,206
2,524
534,284
(1,187)
533,097
Percentage of total credit quality
78.7%
11.4%
8.4%
1.0%
0.5%
100.0%
Loans and other credit-related commitments
71,741
21,860
20,018
1,874
202
115,695
(55)
115,640
Financial guarantees
8,412
1,088
1,245
210
99
11,054
(17)
11,037
In-scope: Irrevocable loan commitments
and financial guarantees
80,153
22,948
21,263
2,084
301
126,749
(72)
126,677
Loans and other credit-related commitments
2,134
1,114
432
94
7
3,781
—
3,781
Performance and other guarantees
7,738
4,359
3,130
490
116
15,833
(31)
15,802
Out-of-scope: Revocable loan
commitments and non-financial
guarantees
9,872
5,473
3,562
584
123
19,614
(31)
19,583
1For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss
allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes
fair value gains and losses.
HSBC Bank plc Annual Report and Accounts 2021
51
Distribution of financial instruments by credit quality at 31 December 2020 (continued)
(Audited)
Gross carrying/notional amount
Allowance for
ECL
Net
Strong
Good
Satisfactory
Sub- 
standard
Credit
impaired
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
In-scope for IFRS 9
Loans and advances to customers held at
amortised cost
43,077
24,780
26,477
5,619
3,007
102,960
(1,469)
101,491
–  personal
19,232
4,341
2,251
141
534
26,499
(208)
26,291
–  corporate and commercial
16,340
17,132
22,330
5,023
2,162
62,987
(1,168)
61,819
–  non-bank financial institutions
7,505
3,307
1,896
455
311
13,474
(93)
13,381
Loans and advances to banks held at amortised
cost
10,518
721
1,412
11
—
12,662
(16)
12,646
Cash and balances at central banks
84,964
—
129
—
—
85,093
(1)
85,092
Items in the course of collection from other
banks
240
—
3
—
—
243
—
243
Reverse repurchase agreements – non-trading
57,282
8,370
1,920
5
—
67,577
—
67,577
Financial investments
2
—
13
—
—
15
—
15
Prepayments, accrued income and other assets
47,928
566
1,285
17
39
49,835
(11)
49,824
–  endorsements and acceptances
62
2
31
2
2
99
(1)
98
–  accrued income and other
47,866
564
1,254
15
37
49,736
(10)
49,726
Debt instruments measured at fair value through
other comprehensive income1
46,029
2,487
405
153
—
49,074
(22)
49,052
Out-of-scope for IFRS 9
Trading assets
34,302
5,996
9,493
410
—
50,201
—
50,201
Other financial assets designated and otherwise
mandatorily measured at fair value through profit
or loss
2,460
1,152
587
4
—
4,203
—
4,203
Derivatives
165,868
30,113
4,299
890
40
201,210
—
201,210
Total gross carrying amount on balance sheet
492,670
74,185
46,023
7,109
3,086
623,073
(1,519)
621,554
Percentage of total credit quality
79%
12%
8%
1%
—
100%
Loans and other credit-related commitments
97,281
26,361
17,081
2,047
266
143,036
(112)
142,924
Financial guarantees
1,340
1,153
1,020
334
122
3,969
(23)
3,946
In-scope: Irrevocable loan commitments and
financial guarantees
98,621
27,514
18,101
2,381
388
147,005
(135)
146,870
Loans and other credit-related commitments
2,525
986
578
177
1
4,267
—
4,267
Performance and other guarantees
6,728
3,808
3,145
422
179
14,282
(51)
14,231
Out-of-scope: Revocable loan commitments and
non-financial guarantees
9,253
4,794
3,723
599
180
18,549
(51)
18,498
1For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss
allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes
fair value gains and losses.
Report of the Directors | Risk
52
HSBC Bank plc Annual Report and Accounts 2021
Distribution of financial instruments by credit quality at 31 December 2021
(Audited)
Gross carrying/notional amount
Allowance
for ECL
Net
Strong
Good
Satisfactory
Sub-
standard
Credit
impaired
Total
The bank
£m
£m
£m
£m
£m
£m
£m
£m
In-scope for IFRS 9
Loans and advances to customers held at
amortised cost
16,993
9,038
6,467
804
984
34,286
(350)
33,936
–  personal
1,909
850
860
13
48
3,680
(6)
3,674
–  corporate and commercial
8,120
6,649
5,003
729
681
21,182
(308)
20,874
–  non-bank financial institutions
6,964
1,539
604
62
255
9,424
(36)
9,388
Loans and advances to banks held  at amortised
cost
6,427
166
187
2
—
6,782
(4)
6,778
Cash and balances at central banks
63,008
—
—
—
—
63,008
—
63,008
Items in the course of collection from other
banks
211
—
—
—
—
211
—
211
Reverse repurchase agreements – non-trading
32,877
5,916
915
—
—
39,708
—
39,708
Financial investments
3,337
—
—
—
—
3,337
—
3,337
Prepayments, accrued income and other assets
28,524
121
94
2
28
28,769
(1)
28,768
–  endorsements and acceptances
90
61
13
—
7
171
—
171
–  accrued income and other
28,434
60
81
2
21
28,598
(1)
28,597
Debt instruments measured at fair value
through other comprehensive income1
21,748
64
1,039
—
—
22,851
(4)
22,847
Out-of-scope for IFRS 9
Trading assets
18,318
5,082
8,470
350
—
32,220
—
32,220
Other financial assets designated and otherwise
mandatorily measured at fair value through
profit or loss
138
—
2,504
2
—
2,644
—
2,644
Derivatives
98,698
24,160
2,854
75
—
125,787
—
125,787
Total gross carrying amount on balance
sheet
290,279
44,547
22,530
1,235
1,012
359,603
(359)
359,244
Percentage of total credit quality
80.7%
12.4%
6.3%
0.3%
0.3%
100.0%
Loans and other credit-related commitments
20,446
6,663
3,651
452
43
31,255
(29)
31,226
Financial guarantees
630
89
471
20
60
1,270
(7)
1,263
In-scope: Irrevocable loan commitments
and financial guarantees
21,076
6,752
4,122
472
103
32,525
(36)
32,489
Loans and other credit-related commitments
620
383
126
86
1
1,216
—
1,216
Performance and other guarantees
4,846
1,939
480
56
13
7,334
(7)
7,327
Out-of-scope: Revocable loan
commitments and non-financial
guarantees
5,466
2,322
606
142
14
8,550
(7)
8,543
1For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss
allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes
fair value gains and losses.
HSBC Bank plc Annual Report and Accounts 2021
53
Distribution of financial instruments by credit quality at 31 December 2020 (continued)
(Audited)
Gross carrying/notional amount
Allowance for
ECL
Net
Strong
Good
Satisfactory
Sub-
standard
Credit
impaired
Total
The bank
£m
£m
£m
£m
£m
£m
£m
£m
In-scope for IFRS 9
Loans and advances to customers held at
amortised cost
20,109
12,752
8,496
1,193
1,281
43,831
(590)
43,241
–  personal
1,804
816
880
25
57
3,582
(13)
3,569
–  corporate and commercial
7,870
9,401
6,785
1,038
920
26,014
(494)
25,520
–  non-bank financial institutions
10,435
2,535
831
130
304
14,235
(83)
14,152
Loans and advances to banks held at amortised
cost
7,256
412
410
—
—
8,078
(15)
8,063
Cash and balances at central banks
48,777
—
—
—
—
48,777
—
48,777
Items in the course of collection from other banks
37
—
—
—
—
37
—
37
Reverse repurchase agreements – non-trading
41,057
7,213
1,862
5
—
50,137
—
50,137
Financial investments
2,214
—
—
—
—
2,214
—
2,214
Prepayments, accrued income and other assets
34,495
94
120
4
22
34,735
(1)
34,734
–  endorsements and acceptances
44
2
22
—
2
70
(1)
69
–  accrued income and other
34,451
92
98
4
20
34,665
—
34,665
Debt instruments measured at fair value through
other comprehensive income1
27,762
62
3
—
—
27,827
(9)
27,818
Out-of-scope for IFRS 9
Trading assets
21,486
5,922
9,406
410
—
37,224
—
37,224
Other financial assets designated and otherwise
mandatorily measured at fair value through profit
or loss
94
788
382
4
—
1,268
—
1,268
Derivatives
150,837
26,966
3,625
638
—
182,066
—
182,066
Total gross carrying amount on balance sheet
354,124
54,209
24,304
2,254
1,303
436,194
(615)
435,579
Percentage of total credit quality
81%
13%
6%
—
—
100%
Loans and other credit-related commitments
29,939
10,375
4,422
512
60
45,308
(81)
45,227
Financial guarantees
913
134
376
33
54
1,510
(13)
1,497
In-scope: Irrevocable loan commitments and
financial guarantees
30,852
10,509
4,798
545
114
46,818
(94)
46,724
Loans and other credit-related commitments
475
235
148
173
1
1,032
—
1,032
Performance and other guarantees
4,670
1,701
623
127
35
7,156
(13)
7,143
Out-of-scope: Revocable loan commitments and
non-financial guarantees
5,145
1,936
771
300
36
8,188
(13)
8,175
1For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss
allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes
fair value gains and losses.
Report of the Directors | Risk
54
HSBC Bank plc Annual Report and Accounts 2021
Distribution of financial instruments to which the impairment requirements in IFRS 9 are applied, by credit quality and stage distribution
(Audited)
Gross carrying/notional amount
Allowance
for ECL
Net
Strong
Good
Satisfactory
Sub-
standard
Credit
impaired
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
Loans and advances to customers at amortised
cost
41,339
20,531
23,469
4,512
2,480
92,331
(1,154)
91,177
–  stage 1
40,831
19,376
19,077
1,446
—
80,730
(86)
80,644
–  stage 2
508
1,155
4,392
3,066
—
9,121
(158)
8,963
–  stage 3
—
—
—
—
2,478
2,478
(908)
1,570
–  POCI
—
—
—
—
2
2
(2)
—
Loans and advances to banks at amortised
cost
8,649
320
1,815
5
—
10,789
(5)
10,784
–  stage 1
8,620
311
1,814
5
—
10,750
(4)
10,746
–  stage 2
29
9
1
—
—
39
(1)
38
–  stage 3
—
—
—
—
—
—
—
—
–  POCI
—
—
—
—
—
—
—
—
Other financial assets measured at amortised
cost
192,107
7,219
2,758
11
42
202,137
(9)
202,128
–  stage 1
192,105
7,214
2,727
2
—
202,048
—
202,048
–  stage 2
2
5
31
9
—
47
—
47
–  stage 3
—
—
—
—
42
42
(9)
33
–  POCI
—
—
—
—
—
—
—
—
Loans and other credit-related commitments
71,741
21,860
20,018
1,874
202
115,695
(55)
115,640
–  stage 1
71,074
19,960
16,337
551
—
107,922
(25)
107,897
–  stage 2
667
1,900
3,681
1,323
—
7,571
(22)
7,549
–  stage 3
—
—
—
—
202
202
(8)
194
–  POCI
—
—
—
—
—
—
—
—
Financial guarantees
8,412
1,088
1,245
210
99
11,054
(17)
11,037
–  stage 1
8,340
951
849
75
—
10,215
(3)
10,212
–  stage 2
72
137
396
135
—
740
(7)
733
–  stage 3
—
—
—
—
99
99
(7)
92
–  POCI
—
—
—
—
—
—
—
—
At 31 Dec 2021
322,248
51,018
49,305
6,612
2,823
432,006
(1,240)
430,766
Debt instruments at FVOCI1
–  stage 1
36,005
1,825
1,292
—
—
39,122
(10)
39,112
–  stage 2
405
74
114
118
—
711
(9)
702
–  stage 3
—
—
—
—
—
—
—
—
–  POCI
—
—
—
—
—
—
—
—
At 31 Dec 2021
36,410
1,899
1,406
118
—
39,833
(19)
39,814
1 For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss
allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes
fair value gains and losses.
HSBC Bank plc Annual Report and Accounts 2021
55
Distribution of financial instruments to which the impairment requirements in IFRS 9 are applied, by credit quality and stage distribution
(continued)
(Audited)
Gross carrying/notional amount
Allowance
for ECL
Net
Strong
Good
Satisfactory
Sub-
standard
Credit
impaired
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
Loans and advances to customers at amortised cost
43,077
24,780
26,477
5,619
3,007
102,960
(1,469)
101,491
–  stage 1
42,579
21,351
17,556
1,693
—
83,179
(129)
83,050
–  stage 2
498
3,429
8,921
3,926
—
16,774
(297)
16,477
–  stage 3
—
—
—
—
2,966
2,966
(1,031)
1,935
–  POCI
—
—
—
—
41
41
(12)
29
Loans and advances to banks at amortised cost
10,518
721
1,412
11
—
12,662
(16)
12,646
–  stage 1
10,479
674
1,372
8
—
12,533
(13)
12,520
–  stage 2
39
47
40
3
—
129
(3)
126
–  stage 3
—
—
—
—
—
—
—
—
–  POCI
—
—
—
—
—
—
—
—
Other financial assets measured at amortised cost
190,416
8,936
3,350
22
39
202,763
(12)
202,751
–  stage 1
190,407
8,924
3,321
7
—
202,659
(2)
202,657
–  stage 2
9
12
29
15
—
65
—
65
–  stage 3
—
—
—
—
39
39
(10)
29
–  POCI
—
—
—
—
—
—
—
—
Loans and other credit-related commitments
97,281
26,361
17,081
2,047
266
143,036
(112)
142,924
–  stage 1
95,270
21,398
11,758
530
—
128,956
(34)
128,922
–  stage 2
2,011
4,963
5,323
1,517
—
13,814
(68)
13,746
–  stage 3
—
—
—
—
266
266
(10)
256
–  POCI
—
—
—
—
—
—
—
—
Financial guarantees
1,340
1,153
1,020
334
122
3,969
(23)
3,946
–  stage 1
1,337
883
496
123
—
2,839
(4)
2,835
–  stage 2
3
270
524
211
—
1,008
(10)
998
–  stage 3
—
—
—
—
121
121
(9)
112
–  POCI
—
—
—
—
1
1
—
1
At 31 Dec 2020
342,632
61,951
49,340
8,033
3,434
465,390
(1,632)
463,758
Debt instruments at FVOCI1
–  stage 1
45,958
2,424
233
—
—
48,615
(12)
48,603
–  stage 2
71
63
172
153
—
459
(10)
449
–  stage 3
—
—
—
—
—
—
—
—
–  POCI
—
—
—
—
—
—
—
—
At 31 Dec 2020
46,029
2,487
405
153
—
49,074
(22)
49,052
1For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss
allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes
fair value gains and losses.
Report of the Directors | Risk
56
HSBC Bank plc Annual Report and Accounts 2021
Distribution of financial instruments to which the impairment requirements in IFRS 9 are applied, by credit quality and stage distribution
(continued)
(Audited)
Gross carrying/notional amount
Allowance
for ECL
Net
Strong
Good
Satisfactory
Sub-
standard
Credit
impaired
Total
The bank
£m
£m
£m
£m
£m
£m
£m
£m
Loans and advances to customers at
amortised cost
16,993
9,038
6,467
804
984
34,286
(350)
33,936
–  stage 1
16,757
8,305
4,964
79
—
30,105
(33)
30,072
–  stage 2
236
733
1,503
725
—
3,197
(47)
3,150
–  stage 3
—
—
—
—
984
984
(270)
714
–  POCI
—
—
—
—
—
—
—
—
Loans and advances to banks at amortised
cost
6,427
166
187
2
—
6,782
(4)
6,778
–  stage 1
6,427
160
186
2
—
6,775
(3)
6,772
–  stage 2
—
6
1
—
—
7
(1)
6
–  stage 3
—
—
—
—
—
—
—
—
–  POCI
—
—
—
—
—
—
—
—
Other financial assets measured at amortised
cost
127,957
6,037
1,009
2
28
135,033
(1)
135,032
–  stage 1
127,956
6,037
991
—
—
134,984
—
134,984
–  stage 2
1
—
18
2
—
21
—
21
–  stage 3
—
—
—
—
28
28
(1)
27
–  POCI
—
—
—
—
—
—
—
—
Loans and other credit-related commitments
20,446
6,663
3,651
452
43
31,255
(29)
31,226
–  stage 1
20,307
6,469
2,135
—
—
28,911
(15)
28,896
–  stage 2
139
194
1,516
452
—
2,301
(11)
2,290
–  stage 3
—
—
—
—
43
43
(3)
40
–  POCI
—
—
—
—
—
—
—
—
Financial guarantees
630
89
471
20
60
1,270
(7)
1,263
–  stage 1
630
89
324
17
—
1,060
(1)
1,059
–  stage 2
—
—
147
3
—
150
—
150
–  stage 3
—
—
—
—
60
60
(6)
54
–  POCI
—
—
—
—
—
—
—
—
At 31 Dec 2021
172,453
21,993
11,785
1,280
1,115
208,626
(391)
208,235
Debt instruments at FVOCI1
–  stage 1
21,748
64
1,035
—
—
22,847
(2)
22,845
–  stage 2
—
—
4
—
—
4
(2)
2
–  stage 3
—
—
—
—
—
—
—
—
–  POCI
—
—
—
—
—
—
—
—
At 31 Dec 2021
21,748
64
1,039
—
—
22,851
(4)
22,847
1For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss
allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes
fair value gains and losses.
HSBC Bank plc Annual Report and Accounts 2021
57
Distribution of financial instruments to which the impairment requirements in IFRS 9 are applied, by credit quality and stage distribution
(continued)
(Audited)
Gross carrying/notional amount
Allowance
for ECL
Net
Strong
Good
Satisfactory
Sub-
standard
Credit
impaired
Total
The bank
£m
£m
£m
£m
£m
£m
£m
£m
Loans and advances to customers at amortised cost
20,109
12,752
8,496
1,193
1,281
43,831
(590)
43,241
–  stage 1
19,650
10,014
4,918
47
—
34,629
(79)
34,550
–  stage 2
459
2,738
3,578
1,146
—
7,921
(158)
7,763
–  stage 3
—
—
—
—
1,279
1,279
(351)
928
–  POCI
—
—
—
—
2
2
(2)
—
Loans and advances to banks at amortised cost
7,256
412
410
—
—
8,078
(15)
8,063
–  stage 1
7,254
366
375
—
—
7,995
(12)
7,983
–  stage 2
2
46
35
—
—
83
(3)
80
–  stage 3
—
—
—
—
—
—
—
—
–  POCI
—
—
—
—
—
—
—
—
Other financial assets measured at amortised cost
126,580
7,307
1,982
9
22
135,900
(1)
135,899
–  stage 1
126,579
7,306
1,953
5
—
135,843
—
135,843
–  stage 2
1
1
29
4
—
35
—
35
–  stage 3
—
—
—
—
22
22
(1)
21
–  POCI
—
—
—
—
—
—
—
—
Loans and other credit-related commitments
29,939
10,375
4,422
512
60
45,308
(81)
45,227
–  stage 1
28,569
8,176
2,453
145
—
39,343
(28)
39,315
–  stage 2
1,370
2,199
1,969
367
—
5,905
(48)
5,857
–  stage 3
—
—
—
—
60
60
(5)
55
–  POCI
—
—
—
—
—
—
—
—
Financial guarantees
913
134
376
33
54
1,510
(13)
1,497
–  stage 1
910
121
170
2
—
1,203
(2)
1,201
–  stage 2
3
13
206
31
—
253
(4)
249
–  stage 3
—
—
—
—
54
54
(7)
47
–  POCI
—
—
—
—
—
—
—
—
At 31 Dec 2020
184,797
30,980
15,686
1,747
1,417
234,627
(700)
233,927
Debt instruments at FVOCI1
–  stage 1
25,570
62
—
—
—
25,632
(7)
25,625
–  stage 2
—
—
3
—
—
3
(2)
1
–  stage 3
—
—
—
—
—
—
—
—
–  POCI
—
—
—
—
—
—
—
—
At 31 Dec 2020
25,570
62
3
—
—
25,635
(9)
25,626
1For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss
allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes
fair value gains and losses.
Credit‑impaired loans
(Audited)
The group determines that a financial instrument is credit impaired
and in stage 3 by considering relevant objective evidence,
primarily whether:
•contractual payments of either principal or interest are past due
for more than 90 days;
•there are other indications that the borrower is unlikely to pay
such as that a concession has been granted to the borrower for
economic or legal reasons relating to the borrower’s financial
condition; and
•the loan is otherwise considered to be in default. If such
unlikeliness to pay is not identified at an earlier stage, it is
deemed to occur when an exposure is 90 days past due, even
where regulatory rules permit default to be defined based on
180 days past due. Therefore, the definitions of credit-impaired
and default are aligned as far as possible so that stage 3
represents all loans which are considered defaulted or
otherwise credit-impaired.
Renegotiated loans and forbearance
The following table shows the gross carrying amounts of the
group’s holdings of renegotiated loans and advances to customers
by industry sector and by stages. Mandatory and general offer
loan modifications that are not borrower-specific, for example
market-wide customer relief programmes, have not been classified
as renegotiated loans. For details on customer relief schemes see
page 60.
A summary of our current policies and practices for renegotiated loans and
forbearance is set out in 'Credit risk management' on page 32.
Report of the Directors | Risk
58
HSBC Bank plc Annual Report and Accounts 2021
Renegotiated loans and advances to customers at amortised costs by stage allocation
Stage 1
Stage 2
Stage 3
POCI
Total
The group
£m
£m
£m
£m
£m
Gross carrying amount
Personal
—
—
132
—
132
–  first lien residential mortgages
—
—
96
—
96
–  other personal lending
—
—
36
—
36
Wholesale
49
192
706
2
949
–  corporate and commercial
49
192
702
2
945
–  non-bank financial institutions
—
—
4
—
4
At 31 Dec 2021
49
192
838
2
1,081
Allowance for ECL
Personal
—
—
(15)
—
(15)
–  first lien residential mortgages
—
—
(11)
—
(11)
–  other personal lending
—
—
(4)
—
(4)
Wholesale
(1)
(5)
(218)
(2)
(226)
–  corporate and commercial
(1)
(5)
(218)
(2)
(226)
–  non-bank financial institutions
—
—
—
—
—
At 31 Dec 2021
(1)
(5)
(233)
(2)
(241)
The group
Gross carrying amount
Personal
—
—
122
—
122
–  first lien residential mortgages
—
—
97
—
97
–  other personal lending
—
—
25
—
25
Wholesale
43
348
773
40
1,204
–  corporate and commercial
43
348
773
40
1,204
–  non-bank financial institutions
—
—
—
—
—
At 31 Dec 2020
43
348
895
40
1,326
Allowance for ECL
Personal
—
—
(18)
—
(18)
–  first lien residential mortgages
—
—
(14)
—
(14)
–  other personal lending
—
—
(4)
—
(4)
Wholesale
(1)
(9)
(211)
(12)
(233)
–  corporate and commercial
(1)
(9)
(211)
(12)
(233)
–  non-bank financial institutions
—
—
—
—
—
At 31 Dec 2020
(1)
(9)
(229)
(12)
(251)
Stage 1
Stage 2
Stage 3
POCI
Total
The bank
£m
£m
£m
£m
£m
Gross carrying amount
Personal
—
—
3
—
3
–  first lien residential mortgages
—
—
2
—
2
–  other personal lending
—
—
1
—
1
Wholesale
40
158
431
—
629
–  corporate and commercial
40
158
431
—
629
At 31 Dec 2021
40
158
434
—
632
Allowance for ECL
Personal
—
—
—
—
—
–  first lien residential mortgages
—
—
—
—
—
–  other personal lending
—
—
—
—
—
Wholesale
(1)
(2)
(124)
—
(127)
–  corporate and commercial
(1)
(2)
(124)
—
(127)
At 31 Dec 2021
(1)
(2)
(124)
—
(127)
HSBC Bank plc Annual Report and Accounts 2021
59
Renegotiated loans and advances to customers at amortised costs by stage allocation (continued)
Stage 1
Stage 2
Stage 3
POCI
Total
The bank
£m
£m
£m
£m
£m
Gross carrying amount
Personal
—
—
7
—
7
–  first lien residential mortgages
—
—
6
—
6
–  other personal lending
—
—
1
—
1
Wholesale
39
181
520
2
742
–  corporate and commercial
39
181
520
2
742
At 31 Dec 2020
39
181
527
2
749
Allowance for ECL
Personal
—
—
—
—
—
–  first lien residential mortgages
—
—
—
—
—
–  other personal lending
—
—
—
—
—
Wholesale
(1)
(4)
(124)
(2)
(131)
–  corporate and commercial
(1)
(4)
(124)
(2)
(131)
At 31 Dec 2020
(1)
(4)
(124)
(2)
(131)
Customer relief programmes
In response to the Covid-19 pandemic, governments and
regulators around the world introduced a number of support
measures for both personal and wholesale customers in market-
wide schemes. The following table presents the number of
personal accounts/wholesale customers and the associated drawn
loan values of customers under these schemes and HSBC-specific
measures for major markets at 31 December 2021. When
schemes expire, accounts and customers and their associated
drawn balances are no longer reported under relief regardless of
their repayment status. In relation to personal lending, the majority
of relief measures, including payment holidays, relate to existing
lending, while in wholesale lending the relief measures comprise
payment holidays, refinancing of existing facilities and new
lending under government-backed schemes. .
At 31 December 2021, the gross carrying value of loans to
personal customers under relief was £36m and wholesale
customers under relief was £3,428m. We continue to monitor the
recoverability of loans granted under customer relief programmes,
including loans to a small number of customers that were
subsequently found to be ineligible for such relief. The ongoing
performance of such loans remains an area of uncertainty at
31 December 2021.
Personal lending
Extant at 31 December 2021
UK
HSBC
Continental
Europe1
Germany
Other
markets2
Total
Market-wide schemes
Number of accounts granted mortgage customer relief
00s
—
—
—
—
—
Drawn loan value of accounts granted mortgage customer relief
£m
—
—
—
—
—
Number of accounts granted other personal lending customer relief
00s
—
5
—
—
5
Drawn loan value of accounts granted other personal lending customer relief
£m
—
32
—
—
32
HSBC-specific measures
Number of accounts granted mortgage customer relief
00s
—
—
—
—
—
Drawn loan value of accounts granted mortgage customer relief
£m
—
—
—
—
—
Number of accounts granted other personal lending customer relief
00s
—
<1
—
—
<1
Drawn loan value of accounts granted other personal lending customer relief
£m
—
4
—
—
4
Total personal lending to major markets under market-wide schemes and
HSBC-specific measures
Number of accounts granted mortgage customer relief
00s
—
—
—
—
—
Drawn loan value of accounts granted mortgage customer relief
£m
—
—
—
—
—
Number of accounts granted other personal lending customer relief
00s
—
5
—
—
5
Drawn loan value of accounts granted other personal lending customer relief
£m
—
36
—
—
36
Market-wide schemes and HSBC-specific measures – mortgage relief as a
proportion of total mortgages
%
—
—
—
—
—
Market-wide schemes and HSBC-specific measures – other personal
lending relief as a proportion of total other personal lending loans and
advances
%
—
0.2
—
—
0.2
Wholesale lending
Extant at 31 December 2021
UK
HSBC
Continental
Europe1
Germany
Other
markets2
Total
Market-wide schemes
Number of customers under market-wide schemes
00s
<1
49
<1
1
50
Drawn loan value of customers under market-wide schemes
£m
1
2,918
63
39
3,021
HSBC-specific measures
Number of customers under HSBC-specific measures
00s
—
<1
—
—
<1
Drawn loan value of customers under HSBC-specific measures
£m
—
407
—
—
407
Total wholesale lending to major markets under market-wide schemes
and HSBC-specific measures
Number of customers
00s
<1
49
<1
1
50
Drawn loan value
£m
1
3,325
63
39
3,428
Market-wide schemes and HSBC-specific measures as a proportion of
total wholesale lending loans and advances
%
—
12.3
1.1
4.0
5.9
1HSBC Continental Europe includes France and branches in Spain, Poland and Greece.
2Other markets include Malta and Armenia.
Report of the Directors | Risk
60
HSBC Bank plc Annual Report and Accounts 2021
Personal lending (continued)
Extant at 31 December 2020
UK
HSBC
Continental
Europe1
Germany
Other
markets2
Total
Market-wide schemes
Number of accounts granted mortgage customer relief
00s
1
—
—
—
1
Drawn loan value of accounts granted mortgage customer relief
£m
9
—
—
—
9
Number of accounts granted other personal lending customer relief
00s
<1
5
—
—
5
Drawn loan value of accounts granted other personal lending customer relief
£m
—
38
—
—
38
HSBC-specific measures
Number of accounts granted mortgage customer relief
00s
—
<1
—
3
3
Drawn loan value of accounts granted mortgage customer relief
£m
—
2
—
58
60
Number of accounts granted other personal lending customer relief
00s
—
3
—
2
5
Drawn loan value of accounts granted other personal lending customer relief
£m
—
85
—
5
90
Total personal lending to major markets under market-wide schemes and HSBC-
specific measures
Number of accounts granted mortgage customer relief
00s
1
<1
—
3
4
Drawn loan value of accounts granted mortgage customer relief
£m
9
2
—
58
69
Number of accounts granted other personal lending customer relief
00s
<1
8
—
2
10
Drawn loan value of accounts granted other personal lending customer relief
£m
—
123
—
5
128
Market-wide schemes and HSBC-specific measures – mortgage relief as a
proportion of total mortgages
%
0.5
0.1
—
2.2
0.9
Market-wide schemes and HSBC-specific measures – other personal lending relief
as a proportion of total other personal lending loans and advances
%
—
0.7
—
2.3
0.7
Wholesale lending (continued)
Extant at 31 December 2020
UK
HSBC
Continental
Europe1
Germany
Other
markets2
Total
Market-wide schemes
Number of customers under market-wide schemes
00s
<1
49
<1
1
50
Drawn loan value of customers under market-wide schemes
£m
1
3,997
47
24
4,069
HSBC-specific measures
Number of customers under HSBC-specific measures
00s
<1
3
—
<1
4
Drawn loan value of customers under HSBC-specific measures
£m
1
1,103
—
295
1,399
Total wholesale lending to major markets under market-wide schemes and HSBC-
specific measures
Number of customers
00s
<1
52
<1
1
54
Drawn loan value
£m
2
5,100
47
319
5,468
Market-wide schemes and HSBC-specific measures as a proportion of total
wholesale lending loans and advances
%
—
20.7
0.7
22.7
8.5
1HSBC Continental Europe includes France and branches in Spain, Poland and Greece.
2Other markets include Malta, Jersey, Armenia and Middle East leasing partnership.
The initial granting of customer relief does not automatically
trigger a migration to stage 2 or 3. However, information provided
by payment deferrals is considered in the context of other
reasonable and supportable information. This forms part of the
overall assessment for whether there has been a significant
increase in credit risk and credit impairment to identify loans for
which lifetime ECL is appropriate. An extension in payment
deferral does not automatically result in a migration to stage 2 or
stage 3. The key accounting and credit risk judgement to ascertain
whether a significant increase in credit risk has occurred is
whether the economic effects of the Covid-19 outbreak on the
customer are likely to be temporary over the lifetime of the loan,
and whether they indicate that a concession is being made in
respect of financial difficulty that would be consistent with   
stage 3.
Market-wide schemes The following narrative provides further
details on the major government and regulatory schemes offered
in France and Germany.
Personal lending
France – Other personal lending
The Prêt garanti par l'Etat (‘PGE’) government scheme provides
term lending to professionals, firms, business owners, craftsmen
and micro-entrepreneurs for a maximum duration of six years
including a first year deferral. The maximum relief value is at 25%
of baseline turnover with the maximum amount of €2.25m
granted. Borrowers need to confirm that Covid-19 has placed
them under temporary financial hardship and that they didn't
experience financial difficulties before the crisis.
Wholesale lending
France
The PGE government scheme provides term lending to all
registered French companies, excluding real estate special
purpose vehicles (‘SPVs’), banks, and companies subject to
insolvency proceedings, for a maximum duration of one year (with
the option to amortise up to five years). The maximum loan value
is linked to turnover.
Germany – wholesale lending
Kreditanstalt für Wiederaufbau ('KfW') Coronavirus Aid provides
lending to corporates for a maximum tenor of ten years.
HSBC-specific measures
France business banking lending
Payment holidays offered to professionals, firms, business owners,
craftsmen and micro-entrepreneurs.
France wholesale lending
Payment holidays offered to commercial banking customers
focused largely on business banking or lower end micro and
medium enterprises. The duration is between 3 and 18 months
and there is no specific maximum loan value.
HSBC Bank plc Annual Report and Accounts 2021
61
Wholesale lending
This section provides further details on the countries and
industries comprising wholesale loans and advances to customers
and banks. Industry granularity is also provided by stage with
geographical data presented for loans and advances to customers
and banks, loans and other credit-related commitments and
financial guarantees.
Total wholesale lending for loans and advances to banks and customers by stage distribution
Gross carrying amount
Allowance for ECL
Stage 1
Stage 2
Stage 3
POCI
Total
Stage 1
Stage 2
Stage 3
POCI
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Corporate and commercial
46,237
8,066
1,782
2
56,087
(58)
(137)
(767)
(2)
(964)
–  agriculture, forestry and fishing
157
7
7
—
171
—
—
(5)
—
(5)
–  mining and quarrying
1,207
86
58
—
1,351
(1)
(1)
(5)
—
(7)
–  manufacture
7,327
1,624
281
2
9,234
(8)
(14)
(72)
(2)
(96)
–  electricity, gas, steam and air-
conditioning supply
2,891
49
30
—
2,970
(3)
(1)
(4)
—
(8)
–  water supply, sewerage, waste
management and remediation
215
—
4
—
219
—
—
(4)
—
(4)
–  construction
641
116
97
—
854
(2)
(2)
(40)
—
(44)
–  wholesale and retail trade, repair of
motor vehicles and motorcycles
7,743
889
192
—
8,824
(4)
(8)
(132)
—
(144)
–  transportation and storage
3,254
1,570
205
—
5,029
(9)
(20)
(56)
—
(85)
–  accommodation and food
831
409
80
—
1,320
(4)
(10)
(20)
—
(34)
–  publishing, audiovisual and
broadcasting
2,390
81
50
—
2,521
(2)
(2)
(12)
—
(16)
–  real estate
4,849
891
280
—
6,020
(9)
(32)
(159)
—
(200)
–  professional, scientific and technical
activities
2,522
669
221
—
3,412
(3)
(8)
(60)
—
(71)
–  administrative and support services
8,765
1,204
178
—
10,147
(9)
(21)
(161)
—
(191)
–  public administration and defence,
compulsory social security
376
180
—
—
556
—
—
—
—
—
–  education
22
5
3
—
30
—
(1)
(1)
—
(2)
–  health and care
473
47
6
—
526
(1)
(4)
(5)
—
(10)
–  arts, entertainment and recreation
104
116
5
—
225
—
(3)
(3)
—
(6)
–  other services
1,427
66
85
—
1,578
(3)
(2)
(28)
—
(33)
–  activities of households
—
2
—
—
2
—
—
—
—
—
–  government
1,027
45
—
—
1,072
—
—
—
—
—
–  asset-backed securities
16
10
—
—
26
—
(8)
—
—
(8)
Non-bank financial institutions
10,238
369
243
—
10,850
(6)
(5)
(16)
—
(27)
Loans and advances to banks
10,750
39
—
—
10,789
(4)
(1)
—
—
(5)
At 31 Dec 2021
67,225
8,474
2,025
2
77,726
(68)
(143)
(783)
(2)
(996)
By country
UK
27,765
3,001
832
—
31,598
(34)
(43)
(233)
—
(310)
France
29,287
3,492
572
1
33,352
(27)
(62)
(396)
(1)
(486)
Germany
4,628
1,175
328
—
6,131
—
(17)
(73)
—
(90)
Other countries
5,545
806
293
1
6,645
(7)
(21)
(81)
(1)
(110)
At 31 Dec 2021
67,225
8,474
2,025
2
77,726
(68)
(143)
(783)
(2)
(996)
Total wholesale lending for loans and other credit-related commitments and financial guarantees1 by stage distribution
Nominal amount
Allowance for ECL
Stage 1
Stage 2
Stage 3
POCI
Total
Stage 1
Stage 2
Stage 3
POCI
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Corporate and commercial
65,582
7,369
295
—
73,246
(22)
(27)
(15)
—
(64)
Financial
50,380
826
2
—
51,208
(5)
(2)
—
—
(7)
At 31 Dec 2021
115,962
8,195
297
—
124,454
(27)
(29)
(15)
—
(71)
By geography
Europe
115,962
8,195
297
—
124,454
(27)
(29)
(15)
—
(71)
–  of which: UK
25,662
2,910
87
—
28,659
(16)
(11)
(3)
—
(30)
–  of which: France
77,664
1,273
37
—
78,974
(3)
(3)
(4)
—
(10)
–  of which: Germany
10,113
3,693
127
—
13,933
(4)
(8)
(1)
—
(13)
1Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
Report of the Directors | Risk
62
HSBC Bank plc Annual Report and Accounts 2021
Total wholesale lending for loans and advances to banks and customers by stage distribution (continued)
Gross carrying amount
Allowance for ECL
Stage 1
Stage 2
Stage 3
POCI
Total
Stage 1
Stage 2
Stage 3
POCI
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Corporate and commercial
46,773
14,052
2,121
41
62,987
(100)
(225)
(831)
(12)
(1,168)
–  agriculture, forestry and fishing
108
8
9
—
125
—
—
(5)
—
(5)
–  mining and quarrying
1,110
215
108
—
1,433
(1)
(3)
(2)
—
(6)
–  manufacture
8,598
2,900
286
13
11,797
(11)
(34)
(93)
(3)
(141)
–  electricity, gas, steam and air-
conditioning supply
2,532
299
29
—
2,860
(3)
(3)
(5)
—
(11)
–  water supply, sewerage, waste
management and remediation
260
44
4
—
308
—
(2)
(3)
—
(5)
–  construction
589
265
131
2
987
(7)
(17)
(46)
(2)
(72)
–  wholesale and retail trade, repair of
motor vehicles and motorcycles
7,074
1,779
283
1
9,137
(10)
(22)
(171)
(1)
(204)
–  transportation and storage
3,506
2,175
253
—
5,934
(31)
(30)
(81)
—
(142)
–  accommodation and food
964
408
23
—
1,395
(2)
(8)
(12)
—
(22)
–  publishing, audiovisual and
broadcasting
2,381
424
50
—
2,855
(2)
(16)
(11)
—
(29)
–  real estate
5,256
1,266
393
—
6,915
(17)
(28)
(194)
—
(239)
–  professional, scientific and technical
activities
3,219
1,409
179
25
4,832
(3)
(14)
(53)
(6)
(76)
–  administrative and support services
6,470
2,336
259
—
9,065
(8)
(19)
(125)
—
(152)
–  public administration and defence,
compulsory social security
449
147
—
—
596
(1)
(1)
—
—
(2)
–  education
26
76
1
—
103
—
(3)
(1)
—
(4)
–  health and care
490
127
9
—
626
(1)
(10)
(6)
—
(17)
–  arts, entertainment and recreation
127
85
4
—
216
—
(3)
(3)
—
(6)
–  other services
2,443
25
100
—
2,568
(2)
(2)
(20)
—
(24)
–  activities of households
2
—
—
—
2
—
—
—
—
—
–  government
1,153
53
—
—
1,206
(1)
—
—
—
(1)
–  asset-backed securities
16
11
—
—
27
—
(10)
—
—
(10)
Non-bank financial institutions
11,415
1,748
311
—
13,474
(11)
(35)
(47)
—
(93)
Loans and advances to banks
12,533
129
—
—
12,662
(13)
(3)
—
—
(16)
At 31 Dec 2020
70,721
15,929
2,432
41
89,123
(124)
(263)
(878)
(12)
(1,277)
By country
UK
32,869
7,695
1,097
2
41,663
(87)
(147)
(310)
(2)
(546)
France
25,378
4,514
739
2
30,633
(16)
(55)
(417)
(2)
(490)
Germany
5,460
1,692
334
—
7,486
(4)
(20)
(68)
—
(92)
Other countries
7,014
2,028
262
37
9,341
(17)
(41)
(83)
(8)
(149)
At 31 Dec 2020
70,721
15,929
2,432
41
89,123
(124)
(263)
(878)
(12)
(1,277)
.
Nominal amount
Allowance for ECL
Stage 1
Stage 2
Stage 3
POCI
Total
Stage 1
Stage 2
Stage 3
POCI
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Corporate and commercial
67,077
11,141
379
1
78,598
(32)
(58)
(18)
—
(108)
Financial
62,701
3,459
4
—
66,164
(6)
(19)
(1)
—
(26)
At 31 Dec 2020
129,778
14,600
383
1
144,762
(38)
(77)
(19)
—
(134)
By geography
Europe
129,778
14,600
383
1
144,762
(38)
(77)
(19)
—
(134)
–  of which: UK
34,908
6,066
109
—
41,083
(29)
(51)
(12)
—
(92)
–  of which: France
80,356
1,992
49
—
82,397
(3)
(9)
(3)
—
(15)
–  of which: Germany
11,208
5,711
193
—
17,112
(2)
(9)
(1)
—
(12)
Total wholesale lending for loans and other credit-related commitments and financial guarantees1 by stage distribution (continued)
1Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
HSBC Bank plc Annual Report and Accounts 2021
63
Collateral and other credit enhancement
(Audited)
Although collateral can be an important mitigant of credit risk, it is
the group’s practice to lend on the basis of the customer’s ability
to meet their obligations out of cash flow resources rather than
placing primary reliance on collateral and other credit risk
enhancements. Depending on the customer’s standing and the
type of product, facilities may be provided without any collateral
or other credit enhancements. For other lending, a charge over
collateral is obtained and considered in determining the credit
decision and pricing. In the event of default, the group may utilise
the collateral as a source of repayment.
Depending on its form, collateral can have a significant financial
effect in mitigating our exposure to credit risk. Where there is
sufficient collateral, an expected credit loss is not recognised. This
is the case for reverse repurchase agreements and for certain
loans and advances to customers where the loan to value (‘LTV’) is
very low.
Mitigants may include a charge on borrowers’ specific assets,
such as real estate or financial instruments. Other credit risk
mitigants include short positions in securities and financial assets
held as part of linked insurance/investment contracts where the
risk is predominantly borne by the policyholder. Additionally, risk
may be managed by employing other types of collateral and credit
risk enhancements, such as second charges, other liens and
unsupported guarantees. Guarantees are normally taken from
corporates and export credit agencies. Corporates would normally
provide guarantees as part of a parent/subsidiary relationship and
span a number of credit grades. The export credit agencies will
normally be investment grade.
Certain credit mitigants are used strategically in portfolio
management activities. While single name concentrations arise in
portfolios managed by Global Banking and Commercial Banking, it
is only in Global Banking that their size requires the use of
portfolio level credit mitigants. Across Global Banking, risk limits
and utilisations, maturity profiles and risk quality are monitored
and managed proactively. This process is key to the setting of risk
appetite for these larger, more complex, geographically distributed
customer groups. While the principal form of risk management
continues to be at the point of exposure origination, through the
lending decision-making process, Global Banking also utilises loan
sales and credit default swap (‘CDS’) hedges to manage
concentrations and reduce risk. These transactions are the
responsibility of a dedicated Global Banking portfolio management
team. Hedging activity is carried out within agreed credit
parameters, and is subject to market risk limits and a robust
governance structure. Where applicable, CDSs are entered into
directly with a central clearing house counterparty. Otherwise our
exposure to CDS protection providers is diversified among mainly
banking counterparties with strong credit ratings.
CDS mitigants are held at portfolio level and are not included in
the expected loss calculations. CDS mitigants are not reported in
the following tables.
Collateral on loans and advances
The following tables include off-balance sheet loan commitments,
primarily undrawn credit lines.
The collateral measured in the following tables consists of charges
over cash and marketable financial instruments. The values in the
tables represent the expected market value on an open market
basis. No adjustment has been made to the collateral for any
expected costs of recovery. Marketable securities are measured at
their fair value.
Other types of collateral such as unsupported guarantees and
floating charges over the assets of a customer’s business are not
measured in the following tables. While such mitigants have value,
often providing rights in insolvency, their assignable value is not
sufficiently certain and they are therefore assigned no value for
disclosure purposes.
The LTV ratios presented are calculated by directly associating
loans and advances with the collateral that individually and
uniquely supports each facility. When collateral assets are shared
by multiple loans and advances, whether specifically or, more
generally, by way of an all monies charge, the collateral value is
pro-rated across the loans and advances protected by the
collateral.
For credit-impaired loans, the collateral values cannot be directly
compared with impairment allowances recognised. The LTV
figures use open market values with no adjustments. Impairment
allowances are calculated on a different basis, by considering
other cash flows and adjusting collateral values for costs of
realising collateral as explained further on page 122.
Other corporate, commercial and financial (non-bank) loans
and advances
Other corporate, commercial and financial (non-bank) loans are
analysed separately in the following table, which focuses on the
countries containing the majority of our loans and advances
balances. For financing activities in other corporate and
commercial lending, collateral value is not strongly correlated
to principal repayment performance.
Collateral values are generally refreshed when an obligor’s general
credit performance deteriorates and we have to assess the likely
performance of secondary sources of repayment should it prove
necessary to rely on them.
Report of the Directors | Risk
64
HSBC Bank plc Annual Report and Accounts 2021
Wholesale lending – corporate, commercial and financial (non-bank) loans and advances including loan commitments by level of
collateral for key countries by stage (excluding commercial real estate)
(Audited)
Of which:
Total
UK
France
Germany
Gross
carrying/
nominal
amount
ECL
coverage
Gross
carrying/
nominal
amount
ECL
coverage
Gross
carrying/
nominal
amount
ECL
coverage
Gross
carrying/
nominal
amount
ECL
coverage
The group
£m
%
£m
%
£m
%
£m
%
Stage 1
Not collateralised
109,435
0.1
40,298
0.1
52,583
—
11,479
—
Fully collateralised
10,399
0.1
6,133
0.1
2,221
0.1
708
—
LTV ratio:
–  less than 50%
2,450
0.2
1,649
0.1
587
—
—
—
–  51% to 75%
3,543
0.1
2,124
—
989
0.1
—
—
–  76% to 90%
801
0.1
446
—
349
—
—
—
–  91% to 100%
3,605
—
1,914
—
296
—
708
—
Partially collateralised (A):
3,424
0.1
85
—
3,248
0.1
—
—
–  collateral value on A
2,661
51
2,555
—
Total Stage 1
123,258
0.1
46,516
0.1
58,052
—
12,187
—
Stage 2
Not collateralised
11,024
0.9
4,365
0.9
1,890
1.5
3,942
0.6
Fully collateralised
1,675
1.1
608
0.8
639
1.1
243
0.4
LTV ratio:
–  less than 50%
689
1.7
217
1.4
350
1.1
—
—
–  51% to 75%
253
0.8
217
0.9
34
2.9
—
—
–  76% to 90%
271
0.4
165
—
106
0.9
—
—
–  91% to 100%
462
0.9
9
—
149
1.3
243
0.4
Partially collateralised (B):
1,573
0.9
4
—
1,567
0.9
—
—
–  collateral value on B
1,408
3
1,404
—
Total Stage 2
14,272
0.9
4,977
0.9
4,096
1.2
4,185
0.5
Stage 3
Not collateralised
1,598
37.2
669
25.1
378
86.0
393
17.8
Fully collateralised
148
16.2
77
7.8
10
50.0
24
16.7
LTV ratio:
–  less than 50%
76
18.4
41
7.3
6
50.0
—
—
–  51% to 75%
22
13.6
19
10.5
2
50.0
—
—
–  76% to 90%
18
5.6
17
—
1
—
—
—
–  91% to 100%
32
15.6
—
—
1
100.0
24
16.7
Partially collateralised (C):
216
27.3
35
17.1
165
27.3
—
—
–  collateral value on C
152
22
123
—
Total Stage 3
1,962
34.6
781
23.0
553
67.8
417
17.7
POCI
Not collateralised
—
—
—
—
—
—
—
—
Fully collateralised
—
—
—
—
—
—
—
—
LTV ratio:
–  less than 50%
—
—
—
—
—
—
—
—
–  51% to 75%
—
—
—
—
—
—
—
—
–  76% to 90%
—
—
—
—
—
—
—
—
–  91% to 100%
—
—
—
—
—
—
—
—
Partially collateralised (D):
2
100.0
—
—
2
100.0
—
—
–  collateral value on D
2
—
2
—
Total POCI
2
100.0
—
—
2
100.0
—
—
At 31 Dec 2021
139,494
0.6
52,274
0.5
62,703
0.7
16,789
0.6
HSBC Bank plc Annual Report and Accounts 2021
65
Wholesale lending – corporate, commercial and financial (non-bank) loans and advances including loan commitments by level of
collateral for key countries by stage (excluding commercial real estate) (continued)
(Audited)
Of which:
Total
UK
France
Germany
Gross
carrying/
nominal
amount
ECL
coverage
Gross
carrying/
nominal
amount
ECL
coverage
Gross
carrying/
nominal
amount
ECL
coverage
Gross
carrying/
nominal
amount
ECL coverage
The group
£m
%
£m
%
£m
%
£m
%
Stage 1
Not collateralised
117,820
0.1
49,970
0.1
47,647
—
13,685
—
Fully collateralised
12,232
0.1
8,241
0.2
2,163
—
638
—
LTV ratio:
–  less than 50%
1,886
0.3
1,019
0.3
543
—
—
—
–  51% to 75%
4,403
0.2
3,489
0.2
901
—
—
—
–  76% to 90%
751
0.1
267
0.4
360
—
—
—
–  91% to 100%
5,192
—
3,466
—
359
—
638
—
Partially collateralised (A):
3,476
0.1
59
—
3,167
0.1
—
—
–  collateral value on A
2,855
32
2,621
—
Total Stage 1
133,528
0.1
58,270
0.1
52,977
—
14,323
—
Stage 2
Not collateralised
23,132
1.0
12,398
1.2
2,447
1.1
6,220
0.4
Fully collateralised
1,838
1.2
630
1.0
649
1.1
290
0.3
LTV ratio:
–  less than 50%
824
1.5
326
1.2
348
0.6
—
—
–  51% to 75%
334
1.2
269
0.4
45
2.2
—
—
–  76% to 90%
47
2.1
26
3.8
17
—
—
—
–  91% to 100%
633
0.8
9
—
239
1.3
290
0.3
Partially collateralised (B):
2,629
0.7
87
2.3
2,528
0.6
—
—
–  collateral value on B
2,223
14
2,200
—
Total Stage 2
27,599
1.0
13,115
1.2
5,624
0.9
6,510
0.4
Stage 3
Not collateralised
1,803
36.3
740
29.7
529
63.9
441
15.2
Fully collateralised
210
9.5
152
1.3
12
66.7
21
14.3
LTV ratio:
–  less than 50%
25
28.0
2
—
7
57.1
—
—
–  51% to 75%
27
29.6
17
5.9
3
66.7
—
—
–  76% to 90%
120
0.8
118
0.8
1
100.0
—
—
–  91% to 100%
38
10.5
15
—
1
100.0
21
14.3
Partially collateralised (C):
275
24.0
71
11.3
191
26.2
—
—
–  collateral value on C
182
40
136
—
Total Stage 3
2,288
32.4
963
23.9
732
54.1
462
15.2
POCI
Not collateralised
37
27.0
2
100.0
—
—
—
—
Fully collateralised
—
—
—
—
—
—
—
—
LTV ratio:
–  less than 50%
—
—
—
—
—
—
—
—
–  51% to 75%
—
—
—
—
—
—
—
—
–  76% to 90%
—
—
—
—
—
—
—
—
–  91% to 100%
—
—
—
—
—
—
—
—
Partially collateralised (D):
3
100.0
—
—
3
100.0
—
—
–  collateral value on D
3
—
3
—
Total POCI
40
32.5
2
100.0
3
100.0
—
—
At 31 Dec 2020
163,455
0.7
72,350
0.7
59,336
0.8
21,295
0.5
.
Other credit risk exposures
In addition to collateralised lending, other credit enhancements are
employed and methods used to mitigate credit risk arising from
financial assets. These are described in more detail below:
•Some securities issued by governments, banks and other
financial institutions benefit from additional credit
enhancement provided by government guarantees that cover
the assets;
•Debt securities issued by banks and financial institutions
include asset-backed securities ('ABSs') and similar instruments
which are supported by underlying pools of financial assets.
Credit risk associated with ABSs is reduced through the
purchase of credit default swap (‘CDS’) protection;
•Trading loan and advances mainly pledged against cash
collaterals are posted to satisfy margin requirements. There is
•limited credit risk on trading loans and advances since in the
event of default of the counterparty these would be set off
against the related liability. Reverse repos and stock
borrowings are by their nature collateralised.
Collateral accepted as security that the group is permitted to sell or repledge
under these arrangements is described on page 155 of the financial
statements.
•The group’s maximum exposure to credit risk includes financial
guarantees and similar contracts granted; as well as loan and
other credit-related commitments. Depending on the terms of
the arrangement, we may use additional credit mitigation if a
guarantee is called upon or a loan commitment is drawn and
subsequently defaults.
For further information on these arrangements, see Note 30 on the financial
statements.
Report of the Directors | Risk
66
HSBC Bank plc Annual Report and Accounts 2021
Derivatives
We participate in transactions exposing us to counterparty credit
risk. Counterparty credit risk is the risk of financial loss if the
counterparty to a transaction defaults before satisfactorily settling
it. It arises principally from over-the-counter (‘OTC’) derivatives
and securities financing transactions and is calculated in both the
trading and non-trading books. Transactions vary in value by
reference to market factors such as interest rates, exchange rates
or asset prices.
The counterparty risk from derivative transactions is taken into
account when reporting the fair value of derivative positions. The
adjustment to the fair value is known as the credit value
adjustment (‘CVA’).
The International Swaps and Derivatives Association (‘ISDA’)
master agreement is our preferred agreement for documenting
derivatives activity. It is common, and our preferred practice, for
the parties involved in a derivative transaction to execute a credit
support annex (‘CSA’) in conjunction with the ISDA master
agreement. Under a CSA, collateral is passed between the parties
to mitigate the counterparty risk inherent in outstanding positions.
The majority of our CSAs are with financial institutional clients. We
manage the counterparty exposure on our OTC derivative
contracts by using collateral agreements with counterparties and
netting agreements. Currently, we do not actively manage our
general OTC derivative counterparty exposure in the credit
markets, although we may manage individual exposures in certain
circumstances.
We place strict policy restrictions on collateral types and as a
consequence the types of collateral received and pledged are, by
value, highly liquid and of a strong quality, being predominantly
USD, EUR and GBP cash and G7 Government Bonds.
Where a collateral type is required to be approved outside the
collateral policy, approval is required from a committee of senior
representatives from Markets, Legal and Risk.
See Note 28 on the financial statements for details regarding legally
enforceable right of offset in the event of counterparty default and collateral
received in respect of derivatives
Personal lending
This section provides further details on the countries and products
comprising personal loans and advances to customers.
Further product granularity is also provided by stage, with
geographical data presented for loans and advances to customers,
loan and other credit-related commitments, and financial
guarantees.
Total personal lending for loans and advances to customers at amortised costs by stage distribution
Gross carrying amount
Allowance for ECL
Stage 1
Stage 2
Stage 3
Total
Stage 1
Stage 2
Stage 3
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
By portfolio
First lien residential mortgages
6,723
173
234
7,130
(11)
(5)
(65)
(81)
–  of which: interest only (including offset)
3,134
115
94
3,343
(1)
(2)
(27)
(30)
–  affordability including ARMs
451
2
6
459
(3)
—
(1)
(4)
Other personal lending
17,532
513
219
18,264
(11)
(11)
(60)
(82)
–  guaranteed loans in respect of residential property
14,387
332
38
14,757
(5)
(2)
(1)
(8)
–  Other personal lending which is secured
2,535
136
100
2,771
(3)
(4)
(24)
(31)
–  credit cards
318
22
11
351
(1)
(2)
(1)
(4)
–  Other personal lending which is unsecured
292
23
70
385
(2)
(3)
(34)
(39)
At 31 Dec 2021
24,255
686
453
25,394
(22)
(16)
(125)
(163)
By geography
UK1
3,543
88
49
3,680
(1)
(3)
(3)
(7)
France
18,500
497
239
19,236
(10)
(10)
(75)
(95)
Germany
161
47
—
208
—
—
—
—
Other countries
2,051
54
165
2,270
(11)
(3)
(47)
(61)
At 31 Dec 2021
24,255
686
453
25,394
(22)
(16)
(125)
(163)
Total personal lending for loans and other credit-related commitments and financial guarantees2 by stage distribution
Nominal amount
Allowance for ECL
Stage 1
Stage 2
Stage 3
Total
Stage 1
Stage 2
Stage 3
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
UK
586
3
2
591
—
—
—
—
France
1,076
20
2
1,098
—
—
—
—
Germany
136
85
—
221
—
—
—
—
Other countries
377
8
—
385
(1)
—
—
(1)
At 31 Dec 2021
2,175
116
4
2,295
(1)
—
—
(1)
1Includes primarily first lien residential mortgages in Channel Islands and Isle of Man.
2Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
HSBC Bank plc Annual Report and Accounts 2021
67
Total personal lending for loans and advances to customers at amortised costs by stage distribution (continued)
Gross carrying amount
Allowance for ECL
Stage 1
Stage 2
Stage 3
Total
Stage 1
Stage 2
Stage 3
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
By portfolio
First lien residential mortgages
7,087
211
265
7,563
(9)
(10)
(77)
(96)
–  of which: interest only (including offset)
3,454
151
115
3,720
(1)
(3)
(30)
(34)
–  affordability including ARMs
394
2
4
400
(2)
—
(1)
(3)
Other personal lending
17,904
763
269
18,936
(9)
(27)
(76)
(112)
–  guaranteed loans in respect of residential property
14,625
434
45
15,104
(2)
(4)
(3)
(9)
–  Other personal lending which is secured
2,521
94
141
2,756
(3)
(7)
(27)
(37)
–  credit cards
288
37
14
339
(2)
(6)
(1)
(9)
–  Other personal lending which is unsecured
470
198
68
736
(2)
(10)
(45)
(57)
At 31 Dec 2020
24,991
974
534
26,499
(18)
(37)
(153)
(208)
By geography
UK1
3,455
70
57
3,582
(2)
(9)
(5)
(16)
France
19,230
689
296
20,215
(7)
(20)
(92)
(119)
Germany
124
145
—
269
—
—
—
—
Other countries
2,182
70
181
2,433
(9)
(8)
(56)
(73)
At 31 Dec 2020
24,991
974
534
26,499
(18)
(37)
(153)
(208)
Total personal lending for loans and other credit-related commitments and financial guarantees2 by stage distribution (continued)
Nominal amount
Allowance for ECL
Stage 1
Stage 2
Stage 3
Total
Stage 1
Stage 2
Stage 3
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
UK
340
15
—
355
—
—
—
—
France
1,170
29
3
1,202
—
—
—
—
Germany
65
170
—
235
—
—
—
—
Other countries
442
8
1
451
—
(1)
—
(1)
At 31 Dec 2020
2,017
222
4
2,243
—
(1)
—
(1)
1Includes primarily first lien residential mortgages in Channel Islands and Isle of Man.
2Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
Collateral on loans and advances
The following table provides a quantification of the value of fixed
charges we hold over specific assets where we have a history of
enforcing, and are able to enforce, collateral in satisfying a debt in
the event of the borrower failing to meet its contractual
obligations, and where the collateral is cash or can be realised by
sale in an established market.
The collateral valuation excludes any adjustment for obtaining and
selling the collateral and in particular loans shown as collateralised
or partially collateralised may also benefit from other forms of
credit mitigants.
Report of the Directors | Risk
68
HSBC Bank plc Annual Report and Accounts 2021
Personal lending: residential mortgage loans including loan commitments by level of collateral for key countries
(Audited)
Of which:
Total
UK
France
Gross
exposure
ECL
coverage
Gross
exposure
ECL
coverage
Gross
exposure
ECL
coverage
The group
£m
%
£m
%
£m
%
Stage 1
Fully collateralised
6,915
0.2
2,789
—
2,088
—
LTV ratio:
–  less than 50%
3,400
0.1
1,308
—
1,110
0.1
–  51% to 60%
1,274
0.2
540
—
431
—
–  61% to 70%
1,074
0.2
452
—
296
—
–  71% to 80%
776
0.3
358
—
177
—
–  81% to 90%
345
0.3
113
—
48
—
–  91% to 100%
46
—
18
—
26
—
Partially collateralised (A):
90
—
11
—
50
—
LTV ratio:
–  101% to 110%
18
—
2
—
12
—
–  111% to 120%
9
—
1
—
5
—
–  greater than 120%
63
—
8
—
33
—
–  collateral value on A
63
4
50
Total
7,005
0.2
2,800
—
2,138
—
Stage 2
Fully collateralised
169
3.0
46
—
83
1.2
LTV ratio:
–  less than 50%
91
2.2
18
—
48
2.1
–  51% to 60%
25
4.0
6
—
13
—
–  61% to 70%
34
2.9
17
—
12
—
–  71% to 80%
15
6.7
5
—
7
—
–  81% to 90%
3
—
—
—
2
—
–  91% to 100%
1
—
—
—
1
—
Partially collateralised (B):
5
—
—
—
2
—
LTV ratio:
–  101% to 110%
1
—
—
—
—
—
–  111% to 120%
1
—
—
—
—
—
–  greater than 120%
3
—
—
—
2
—
–  collateral value on B
4
—
3
Total
174
2.9
46
—
85
1.2
Stage 3
Fully collateralised
204
24.5
9
11.1
62
21.0
LTV ratio:
–  less than 50%
94
12.8
6
16.7
24
20.8
–  51% to 60%
31
19.4
3
—
8
25.0
–  61% to 70%
34
23.5
—
—
19
10.5
–  71% to 80%
13
38.5
—
—
3
33.3
–  81% to 90%
14
42.9
—
—
4
25.0
–  91% to 100%
18
72.2
—
—
4
50.0
Partially collateralised (C):
30
53.3
—
—
24
58.3
LTV ratio:
–  101% to 110%
2
50.0
—
—
2
50.0
–  111% to 120%
2
50.0
—
—
2
50.0
–  greater than 120%
26
53.8
—
—
20
60.0
–  collateral value on C
6
—
6
Total
234
28.2
9
11.1
86
31.4
At 31 Dec 2021
7,413
1.1
2,855
—
2,309
1.3
HSBC Bank plc Annual Report and Accounts 2021
69
Personal lending: residential mortgage loans including loan commitments by level of collateral for key countries (continued)
(Audited)
Of which:
Total
UK
France
Gross
exposure
ECL
coverage
Gross
exposure
ECL
coverage
Gross
exposure
ECL
coverage
The group
£m
%
£m
%
£m
%
Stage 1
Fully collateralised
7,308
0.1
2,751
—
2,364
—
LTV ratio:
–  less than 50%
3,110
0.1
1,018
—
1,147
—
–  51% to 60%
1,074
0.1
293
—
513
—
–  61% to 70%
991
0.1
316
—
378
—
–  71% to 80%
789
0.3
214
—
225
—
–  81% to 90%
505
0.4
109
—
70
—
–  91% to 100%
839
0.1
801
—
31
—
Partially collateralised (A):
90
—
9
—
63
—
LTV ratio:
–  101% to 110%
21
—
—
—
13
—
–  111% to 120%
14
—
2
—
10
—
–  greater than 120%
55
—
7
—
40
—
–  collateral value on A
81
5
63
Total
7,398
0.1
2,760
—
2,427
—
Stage 2
Fully collateralised
202
4.0
34
2.9
116
0.9
LTV ratio:
–  less than 50%
114
1.8
17
—
64
1.6
–  51% to 60%
31
3.2
4
—
21
—
–  61% to 70%
22
4.5
—
—
17
—
–  71% to 80%
15
13.3
—
—
10
—
–  81% to 90%
6
16.7
—
—
3
—
–  91% to 100%
14
7.1
13
7.7
1
—
Partially collateralised (B):
10
20.0
—
—
5
—
LTV ratio:
–  101% to 110%
4
25.0
—
—
2
—
–  111% to 120%
2
50.0
—
—
—
—
–  greater than 120%
4
—
—
—
3
—
–  collateral value on B
10
—
5
Total
212
4.7
34
2.9
121
0.8
Stage 3
Fully collateralised
200
22.0
12
8.3
69
23.2
LTV ratio:
–  less than 50%
95
13.7
8
12.5
30
23.3
–  51% to 60%
34
23.5
3
—
10
30.0
–  61% to 70%
34
26.5
—
—
16
12.5
–  71% to 80%
23
34.8
1
—
7
28.6
–  81% to 90%
9
44.4
—
—
2
50.0
–  91% to 100%
5
40.0
—
—
4
25.0
Partially collateralised (C):
65
50.8
—
—
36
38.9
LTV ratio:
–  101% to 110%
10
60.0
—
—
3
33.3
–  111% to 120%
8
62.5
—
—
1
—
–  greater than 120%
47
46.8
—
—
32
40.6
–  collateral value on C
35
—
17
Total
265
29.1
12
8.3
105
28.6
At 31 Dec 2020
7,875
1.2
2,806
0.1
2,653
1.2
Treasury risk
Overview
Treasury risk is the risk of having insufficient capital, liquidity or
funding resources to meet financial obligations and satisfy
regulatory requirements, together with the financial risks arising
from the provision of pensions and other post-employment
benefits to staff and their dependants. Treasury risk also includes
the risk to our earnings or capital due to non-trading book foreign
exchange exposures and changes in market interest rates.
Treasury risk arises from changes to the respective resources and
risk profiles driven by customer behaviour, management decisions
or the external environment.
Approach and policy
(Audited)
Our objective in the management of treasury risk is to maintain
appropriate levels of capital, liquidity, funding, foreign exchange
and market risk to support our business strategy, and meet our
regulatory and stress testing-related requirements.
Our approach to treasury management is driven by our strategic
and organisational requirements, taking into account the
regulatory, economic and commercial environment. We aim to
maintain a strong capital and liquidity base to support the risks
inherent in our business and invest in accordance with our
strategy, meeting regulatory requirements at all times.
Our policy is underpinned by our risk management framework, our
internal capital adequacy assessment process (‘ICAAP’) and our
Report of the Directors | Risk
70
HSBC Bank plc Annual Report and Accounts 2021
internal liquidity adequacy assessment process (‘ILAAP’). The risk
framework incorporates a number of measures aligned to our
assessment of risks for both internal and regulatory purposes.
These risks include credit, market, operational, pensions, non-
trading book foreign exchange risk, and interest rate risk in the
banking book.
Treasury risk management
Key developments in 2021
•Global Treasury initiated a new flagship programme to deliver a
more resilient, effective and efficient Treasury function over the
next 3 years with a focus on optimising and safeguarding
financial resources. The programme will deliver modernised
infrastructure and upgraded modelling capabilities alongside a
broad re-organisation of the Treasury function.
•We continued to build our recovery and resolution capabilities,
including in relation to the Bank of England (‘BoE’) Resolvability
Assessment Framework, which had an overall compliance
deadline of 1 January 2022. The HSBC Group submitted a self-
assessment report on its resolvability to the Prudential
Regulation Authority (‘PRA’) and the BoE on 1 October 2021.
This included an assessment of how we addressed resolvability
outcomes that impact treasury risk, including valuations, and
capital, liquidity and funding capabilities in resolution. The
HSBC Group will publish a summary of its self-assessment
report in June 2022. The BoE will similarly publish a statement
relating to the resolvability of the HSBC Group at the same
time.
•The BoE’s Financial Policy Committee (‘FPC’) confirmed its
guidance on the path for the UK countercyclical capital buffer
rate. It has announced that it is increasing the rate from 0% to
1%, effective December 2022 in line with the usual 12‑month
implementation lag. Absent a material change in the outlook for
the UK’s financial stability, the FPC would expect to further
increase the rate to 2% in the second quarter of 2022, which
would take effect 12 months later. As part of our ongoing focus
on enhancing the quality of our regulatory reporting, we are
progressing with a comprehensive programme to strengthen
our global processes, improve consistency and enhance control
standards on various aspects of regulatory reporting. Further
details can be found in the subsequent sub-section ‘Regulatory
reporting processes and controls’.
•We worked with the fiduciaries of all our pension plans to
ensure the measures taken in response to the Covid-19
pandemic, including remote working for plan providers and
dealing appropriately with affected plan members, were
properly maintained and supported. Our de-risking
programmes continued to provide protection against the
volatility in financial markets that resulted from the pandemic’s
economic impact.
•A new team was created within the Global Treasury function to
be accountable for monitoring and managing the financial risk
and capital implications of the HSBC Group’s employee defined
benefit pension plans. This change creates clearer delineation
of the roles and responsibilities of the first and second lines of
defence.
The group’s CET1 ratio was 17.3% at 31 December 2021 and the
leverage ratio was 4.1%. The group continues to maintain and
plan for the appropriate resources required to manage its risk and
deliver its strategic objectives, including the sale of the retail
banking business in France.
Governance and structure
The Chief Risk Officer is the accountable risk steward for all
treasury risks. The Chief Financial Officer is the risk owner for
treasury risks with the exception of pension risk which is co-
owned together with the regional heads of Performance &
Reward.
Capital, liquidity, interest rate risk in the banking book and non-
trading book foreign exchange risk are the responsibility of the
Executive Committee and the Risk Committee. The Treasury
function actively manages these risks on an on-going basis,
supported by the Asset and Liability Management Committee
(‘ALCO’), overseen by Treasury Risk Management and the Risk
Management Meeting (‘RMM’).
Pension risk is overseen by the Pension Risk Management
Meeting.
Capital, liquidity and funding risk management
processes
Assessment and risk appetite
Our capital management policy is underpinned by a global capital
management framework and our ICAAP. The framework
incorporates key capital risk appetites for CET1, total capital,
minimum requirements for own funds and eligible liabilities
(‘MREL’), and leverage. The ICAAP is an assessment of the
Group’s capital position, outlining both regulatory and internal
capital resources and requirements resulting from our business
model, strategy, risk profile and management, performance and
planning, risks to capital, and the implications of stress testing.
Our assessment of capital adequacy is driven by an assessment of
risks. These risks include credit, market, operational, pensions,
insurance, structural foreign exchange, and interest rate risk in the
banking book. Climate risk is also considered as part of the ICAAP,
and we are continuing to develop our approach. The Group’s
ICAAP supports the determination of the capital risk appetite and
target ratios, as well as enables the assessment and determination
of capital requirements by regulators. Subsidiaries prepare ICAAPs
in line with global guidance, while considering their local
regulatory regimes to determine their own risk appetites and
ratios.
We aim to ensure that management have oversight of our liquidity
and funding risks by maintaining comprehensive policies, metrics
and controls. We manage liquidity and funding risk at an operating
entity level to make sure that obligations can be met in the
jurisdiction where they fall due, generally without reliance on other
parts of the Group. Operating entities are required to meet internal
minimum requirements and any applicable regulatory
requirements at all times. These requirements are assessed
through the ILAAP, which ensures that operating entities have
robust strategies, policies, processes and systems for the
identification, measurement, management and monitoring of
liquidity risk over an appropriate set of time horizons, including
intra-day. The ILAAP informs the validation of risk tolerance and
the setting of risk appetite. It also assesses the capability to
manage liquidity and funding effectively in each major entity.
These metrics are set and managed locally but are subject to
robust review and challenge by the HSBC Group to ensure
consistency of approach and application of the Group’s policies
and controls.
Planning and performance
Capital and risk-weighted asset (‘RWA’) plans form part of the
annual financial resource plan that is approved by the Board.
Capital and RWA forecasts are submitted to the ALCO on a
monthly basis, and capital and RWAs are monitored and managed
against the plan.
Through our internal governance processes, we seek to strengthen
discipline over our investment and capital allocation decisions, and
to ensure that returns on investment meet management’s
objectives. The Group’s strategy is to allocate capital to businesses
and entities to support growth objectives where returns above
internal hurdle levels have been identified and in order to meet
their regulatory and economic capital needs. We evaluate and
manage business returns by using a return on average tangible
equity measure.
Funding and liquidity plans form part of the financial resource plan
that is approved by the Board. The Board-level appetite measures
are the LCR and NSFR, together with an internal liquidity metric
which was introduced in January 2021 to supplement the LCR and
NSFR. In addition, we use a wider set of measures to manage an
appropriate funding and liquidity profile, including legal entity
depositor concentration limits, intra-day liquidity, forward-looking
funding assessments and other key measures.
HSBC Bank plc Annual Report and Accounts 2021
71
Risks to capital and liquidity
Outside the stress testing framework, other risks may be identified
that have the potential to affect our RWAs, capital and/or liquidity
position. We closely monitor future regulatory changes and
continue to evaluate the impact of these upon our capital and
liquidity requirements. These include the UK’s implementation of
amendments to the Capital Requirements Regulation, the Basel III
Reforms, and the regulatory impact from the UK’s withdrawal
from the EU, as well as other regulatory statements including
changes to IRB modelling requirements.
Regulatory developments
The PRA has confirmed that software assets will be deducted in
full from CET1 capital starting 1 January 2022. This will reverse the
beneficial changes to the treatment of software assets that were
implemented as part of the EU’s response to the Covid-19
pandemic. This will have an immaterial impact on our CET1 ratio.
Overall we expect RWAs to increase by up to 5% as a result of
new regulations during 2022. These include the changes to the
UK’s version of the Capital Requirements Regulation, as well as
other regulatory statements including changes to IRB modelling
requirements. Following the implementation of the UK’s
amendments to the Capital Requirements Regulation (‘CRR II’), we
have adopted the PRA’s new rules on net stable funding ratio
(‘NSFR’), counterparty risk, equity investment in funds, and
leverage ratio, which will be reflected in disclosures starting in the
first quarter of 2022.
Further changes will occur with the introduction of the remaining
Basel III reforms on which the PRA is expected to consult in the
second half of 2022.
Regulatory reporting processes and controls
The quality of regulatory reporting remains a key priority for
management and regulators. Notably, the PRA published a Dear
CEO letter addressed to UK regulated banks, which highlighted
areas of concern over the processes firms use to deliver regulatory
returns. Recent sanctions issued by the PRA demonstrate their
intent in this respect. We are progressing with a comprehensive
programme to strengthen our processes, improve consistency,
and enhance controls on various aspects of regulatory reporting.
We have commissioned a number of independent external
reviews, some at the request of our regulators, including one of
our credit risk RWA reporting process which is currently ongoing.
As a result of these initiatives, there may be an impact on some of
our regulatory ratios, such as the CET1 and LCR.
Stress testing and recovery planning
The Group uses stress testing to evaluate the robustness of plans
and risk portfolios, and to meet the stress testing requirements set
by supervisors. Stress testing also informs the ICAAP and ILAAP
and supports recovery planning. It is an important output used to
evaluate how much capital and liquidity the Group requires in
setting risk appetite for capital and liquidity risk. It is also used to
re-evaluate business plans where analysis shows capital, liquidity
and/or returns do not meet their target.
In addition to a range of internal stress tests, we are subject to
supervisory stress testing in many jurisdictions. These include the
programmes of the Bank of England, the European Banking
Authority, the European Central Bank, as well as stress tests
undertaken in other jurisdictions. The results of regulatory stress
testing and our internal stress tests are used when assessing our
internal capital requirements through the ICAAP. The outcomes of
stress testing exercises carried out by the PRA and other
regulators feed into the setting of regulatory minimum ratios and
buffers.
The Group and subsidiaries have established recovery plans,
which set out potential options management could take in a range
of stress scenarios that could result in a breach of capital or
liquidity buffers. All entities monitor internal and external triggers
that could threaten their capital, liquidity or funding positions.
Entities have established recovery plans providing detailed actions
that management would consider taking in a stress scenario
should their positions deteriorate and threaten to breach risk
appetite and regulatory minimum levels. This is to help ensure that
our capital and liquidity position can be recovered even in an
extreme stress event.
Overall, recovery and resolution plans form part of the framework
safeguarding the Group’s financial stability. The Group is
committed to developing its recovery and resolution capabilities
further, including in relation to the BoE’s Resolvability Assessment
Framework.
Structural foreign exchange exposures
Structural foreign exchange exposures represent net assets or
capital investments in subsidiaries, branches, joint arrangement or
associates, together with any associated hedges, the functional
currencies of which are currencies other than pound sterling. An
entity’s functional currency is that of the primary economic
environment in which the entity operates. We use the pound
sterling as our presentation currency in our consolidated financial
statements because sterling forms the major currency in which we
transact and fund our business. Exchange rate differences on
structural exposures are recognised in other comprehensive
income (‘OCI’).
The structural foreign exchange exposures are managed within
limits such that the capital ratios and the capital ratios of
individual banking subsidiaries are largely protected from the
effect of changes in exchange rates. We may hedge certain
structural foreign exchange positions, either at entity level, or by
relying on hedges held in other group entities, subject to approved
limits.
Measurement of interest rate risk in the banking book
The following measures are used by Treasury to monitor and
control interest rate risk in the banking book including:
•Net Interest Income ('NII') sensitivity; and
•Economic Value of Equity ('EVE').
Net interest income sensitivity
A principal part of our management of non-traded interest rate risk
is to monitor the sensitivity of expected NII under varying interest
rate scenarios (simulation modelling), where all other economic
variables are held constant. This monitoring is undertaken by
ALCO.
The group applies a combination of scenarios and assumptions
relevant to the businesses as well as applying standard scenarios
that are required throughout HSBC Group.
NII sensitivity reflects the group’s sensitivity of earnings to
changes in market interest rates. We forecast both one year and
five year NII sensitivities across a range of interest rate scenarios
based on a static balance sheet assumption. Forecasts include
business line rate pass-on assumptions, re-investment of maturing
assets and liabilities at market rates per shock scenario and
prepayment risk. NII is modelled based on no management
actions i.e. the risk profile at the month end is assumed to remain
constant throughout the forecast horizon.
Economic value of equity
EVE represents the present value of the future banking book cash
flows that could be distributed to equity providers under a
managed run-off scenario, i.e. the current book value of equity
plus the present value of future net interest income in this
scenario. EVE sensitivity is the extent to which the EVE value will
change due to a pre-specified movement in interest rates, where
all other economic variables are held constant.
Report of the Directors | Risk
72
HSBC Bank plc Annual Report and Accounts 2021
Pension risk management processes
HSBC provides future pension benefits on a defined contribution
basis from many of its European operations. However, there
remain future defined benefit pensions provided in the region.
Pension plans are run by local fiduciaries in line with local
legislative requirements. The largest pension plan is the HSBC
Trinkaus & Burkhardt Pension Scheme which is regulated by the
German Company Benefits Act (Gesetz zur Verbesserung der
betrieblichen Altersversorgung – Betriebsrentengesetz –BetrAVG).
In defined contribution pension plans, the contributions that HSBC
is required to make are known, while the ultimate pension benefit
will vary, typically with investment returns achieved by investment
choices made by the employee. While the market risk to HSBC of
defined contribution plans is low, it is still exposed to operational
and reputational risk.
In defined benefit pension plans, the level of pension benefit is
known. Therefore, the level of contributions required by HSBC will
vary due to a number of risks, including:
•investments delivering a return below that required to provide
the projected plan benefits;
•the prevailing economic environment leading to corporate
failures, thus triggering write-downs in asset values (both
equity and debt);
•a change in either interest rates or inflation, causing an
increase in the value of the plan liabilities; and
•plan members living longer than expected (known as
longevity risk).
Pension risk is assessed using an economic capital model that
takes into account potential variations in these factors. The impact
of these variations on both pension assets and pension liabilities is
assessed using a one-in-200-year stress test. Scenario analysis
and other stress tests are also used to support pension risk
management.
To fund the benefits associated with defined benefit plans,
sponsoring group companies, and in some instances employees,
make regular contributions in accordance with advice from
actuaries and in consultation with the plan’s fiduciaries where
relevant. These contributions are normally set to ensure that there
are sufficient funds to meet the cost of the accruing benefits for
the future service of active members. However, higher
contributions are required when plan assets are considered
insufficient to cover the existing pension liabilities. Contribution
rates are typically revised annually or once every three years,
depending on the plan.
The defined benefit plans invest contributions in a range of
investments designed to limit the risk of assets failing to meet a
plan’s liabilities. Any changes in expected returns from the
investments may also change future contribution requirements. In
pursuit of these long-term objectives, an overall target allocation
of the defined benefit plan assets between asset classes is
established. In addition, each permitted asset class has its own
benchmarks, such as stock market or property valuation indices or
liability characteristics. The benchmarks are reviewed at least once
every three to five years and more frequently if required by local
legislation or circumstances. The process generally involves an
extensive asset and liability review.
Capital risk in 2021
Capital overview
Capital adequacy metrics
At
31 Dec
31 Dec
2021
2020
Risk-weighted assets ('RWAs') (£m)
Credit risk
67,540
77,214
Counterparty credit risk
16,434
19,344
Market risk
9,828
14,589
Operational risk
10,512
11,245
Total RWAs
104,314
122,392
Capital on a transitional basis (£m)
Common equity tier 1 ('CET1') capital
18,007
18,042
Tier 1 capital
21,869
22,165
Total  capital
33,036
33,438
Capital ratios on a transitional basis (%)
Common equity tier 1
17.3
14.7
Total tier 1
21.0
18.1
Total capital ratio
31.7
27.3
Leverage ratio (transitional)
Tier 1 capital (£m)
21,869
22,165
Total leverage ratio exposure measure (£m)
535,562
565,049
Leverage ratio (%)
4.1
3.9
Leverage ratio (fully phased-in)
Tier 1 capital (£m)
21,696
21,732
Total leverage ratio exposure measure (£m)
535,562
565,049
Leverage ratio (%)
4.1
3.8
References to EU regulations and directives (including technical
standards) should, as applicable, be read as references to the UK's
version of such regulation and/or directive, as onshored into UK
law under the European Union (Withdrawal) Act 2018, and as may
be subsequently amended under UK law.
Capital figures and ratios in the table above are calculated in
accordance with the revised Capital Requirements Regulation and
Directive, as implemented (‘CRR II’). Leverage ratios are calculated
using the end point definition of capital and the IFRS 9 regulatory
transitional arrangements.
Regulatory transitional arrangements for IFRS 9
‘Financial Instruments’
We have adopted the regulatory transitional arrangements in
CRR II for IFRS 9, including paragraph four of article 473a. Our
capital and ratios are presented under these arrangements
throughout the table above. Without their application, our CET1
ratio would be 17.2%.
The IFRS 9 regulatory transitional arrangements allow banks to
add back to their capital base a proportion of the impact that IFRS
9 has upon their loan loss allowances during the first five years of
use. The impact is defined as:
•the increase in loan loss allowances on day one of IFRS 9
adoption; and
•any subsequent increase in expected credit losses (‘ECL’) in the
non-credit-impaired book thereafter.
Any add-back must be tax-effected and accompanied by a
recalculation of exposure and RWAs. The impact is calculated
separately for portfolios using the standardised (‘STD’) and internal
ratings based (‘IRB’) approaches. For IRB portfolios, there is no
add-back to capital unless loan loss allowances exceed regulatory
12-month expected losses.
In the current period, the add-back to the capital base amounted
to £48m under the STD approach with a tax impact of £12m which
resulted in a net add-back of £36m.
HSBC Bank plc Annual Report and Accounts 2021
73
Own funds
2021
2020
Ref*
£m
£m
Common equity tier 1 (‘CET1’) capital: instruments and reserves
1
Capital instruments and the related share premium accounts
797
797
–  ordinary shares
797
797
2
Retained earnings1
15,511
17,229
3
Accumulated other comprehensive income (and other reserves)
1,975
2,888
5
Minority interests (amount allowed in consolidated CET1)
57
66
5a
Independently reviewed interim net profits net of any foreseeable charge or dividend2
625
(1,755)
6
Common equity tier 1 capital before regulatory adjustments
18,965
19,225
28
Total regulatory adjustments to common equity tier 11
(958)
(1,183)
29
Common equity tier 1 capital
18,007
18,042
36
Additional tier 1 capital before regulatory adjustments
3,906
4,167
43
Total regulatory adjustments to additional tier 1 capital
(44)
(44)
44
Additional tier 1 capital
3,862
4,123
45
Tier 1 capital
21,869
22,165
51
Tier 2 capital before regulatory adjustments
11,591
11,724
57
Total regulatory adjustments to tier 2 capital
(424)
(451)
58
Tier 2 capital
11,167
11,273
59
Total capital
33,036
33,438
Own funds disclosure
(Audited)
At
31 Dec
31 Dec
*The references identify the lines prescribed in the European Banking Authority template, which are applicable and where there is a value.
1From 1H21, the new deduction for insufficient coverage for non-performing exposures has been combined with IFRS 9 transitional adjustments.
Comparatives have been restated.
2This row includes losses that have been recognised and deducted as they arose and were therefore not subject to an independent review.
At 31 December 2021, our CET1 capital ratio increased to 17.3%
from 14.7% at 31 December 2020. This was mainly due to a fall in
RWAs.
Throughout 2021, we complied with the PRA's regulatory capital
adequacy requirements, including those relating to stress testing.
Risk-weighted assets
RWA movement by key driver
Total
RWAs
£m
RWAs at 1 Jan 2021
122,392
Asset size
(13,682)
Asset quality
2,612
Model updates
(694)
Methodology and policy
(4,071)
Foreign exchange movement
(2,243)
Total RWA movement
(18,078)
RWAs at 31 Dec 2021
104,314
Risk-weighted assets ('RWAs') decreased by £18.1bn during the
year, including a decrease of £2.2bn due to foreign currency
translation differences. The £15.9bn decrease (excluding foreign
currency translation differences) comprised the movements
described by the following comments.
Asset size
Credit risk RWAs fell by £9.1bn due to management actions, lower
lending and a fall in securitisation related RWAs, and a reduction
in counterparty credit risk RWAs due to management actions and
mark-to-market movements.
Market risk RWAs decreased by £4.1bn largely due to the effects
of risk mitigation actions, a reduction in the equity and emerging
markets bond portfolios and a decrease in stressed value at risk.
The annual calculation of operational risk RWAs led to a £0.5bn
fall in RWAs due to lower average revenue and expenses.
Asset quality
The £2.6bn increase in RWAs was mainly due to portfolio changes
and credit migration.
Model updates
The £0.7bn decrease in RWAs was mainly due to a fall in market
risk RWAs largely from the implementation of an options risk
model.
Methodology and policy
The £4.1bn decrease in RWAs was primarily due to risk parameter
refinements. This included a £0.2bn increase arising from the
adoption of a Pillar 1 approach to the capitalisation of structural
foreign exchange risk.
Leverage ratio
Our leverage ratio calculated in accordance with the Capital
Requirements Regulation was 4.1% at 31 December 2021, up
from 3.8% at 31 December 2020. This was mainly due to a
decrease in the leverage exposure measure, primarily driven by a
reduction in security finance transactions and on balance sheet
exposures.
Pillar 3 disclosure requirements
Pillar 3 of the Basel regulatory framework is related to market
discipline and aims to make financial services firms more
transparent by requiring publication of wide-ranging information
on their risks, capital and management. Our Pillar 3 Disclosures at
31 December 2021 is published on our website, www.hsbc.com/
investors
Structural foreign exchange exposures
The group’s structural foreign currency exposure is represented by
the net assets or capital investments in subsidiaries, branches,
joint arrangements or associates, the functional currencies of
which are currencies other than the sterling.
For our policies and procedures for managing structural foreign exchange
exposures, see page 72 of the ‘Risk management’ section.
.
Report of the Directors | Risk
74
HSBC Bank plc Annual Report and Accounts 2021
Net structural foreign exchange exposures
2021
2020
£m
£m
Currency of structural exposure
Euro
8,068
8,511
US Dollars
1,470
1,081
South African rand
285
277
Israeli new shekel
169
159
Others, each less than £150m
319
446
At 31 Dec
10,311
10,474
Liquidity and funding risk in 2021
Liquidity coverage ratio
The LCR aims to ensure that a bank has sufficient unencumbered
high-quality liquid assets (‘HQLA’) to meet its liquidity needs in a
30-calendar-day liquidity stress scenario. HQLA consist of cash or
assets that can be converted into cash at little or no loss of value
in markets.
At 31 December 2021, all the group’s principal operating entities
were within the LCR risk tolerance level established by the Board
and applicable under the LFRF.
The following table displays the individual LCR levels for HSBC
Bank plc's principal operating entities on the European
Commission Delegated Regulation basis.
Operating entities’ LCRs
At
31 Dec
31 Dec
2021
2020
%
%
HSBC Bank plc
150
136
HSBC Continental Europe
145
143
HSBC Germany
170
144
HSBC Bank plc LCR increased mainly due to loan book
optimisation resulting in lower loan and committed facilities
positions.
The LCR increase for HSBC Germany is mainly driven by increased
customer deposits and additional TLTRO III funding being raised in
June 2021.
In addition to the regulatory metric, the group enhanced its
liquidity framework in 2021 to include as 'internal liquidity metric',
which is being used to monitor and manage liquidity risk via a low-
point measure across a 270-day horizon, taking into account
recovery capacity.
Net stable funding ratio
The Net Stable Funding Ratio (‘NSFR’) requires institutions to
maintain sufficient stable funding relative to required stable
funding, and reflects a bank’s long-term funding profile (funding
with a term of more than a year).
At 31 December 2021, all the group’s principal operating entities
were within the NSFR risk tolerance level established by the Board
and applicable under the LFRF.
Operating entities’ NSFRs
At
31 Dec
31 Dec
2021
2020
%
%
HSBC Bank plc1
124
133
HSBC Continental Europe2
130
130
HSBC Germany
163
138
1HSBC Bank plc uses an adjusted NSFR as a basis for establishing
stable funding. The adjusted NSFR requires HSBC Bank plc to
maintain sufficient stable funding and reflects its long term funding
profile commensurate with the risk profile of the balance sheet.
2HBCE abide by the CRR II NSFR definition since JUN21.
Depositor concentration and term funding maturity
concentration
The LCR and NSFR metrics assume a stressed outflow based on a
portfolio of depositors within each depositor segment. To ensure
the validity of these assumptions in the sense that the deposit
base is sufficient diversified, the depositor concentration is
monitored on an ongoing basis.
In addition to this, operating entities monitor the term funding
maturity concentration metric to ensure they are not overly
exposed to term funding concentration of wholesale market
counterparts by the current maturity profile in any defined period.
Liquid assets of the group’s principal operating entities
The table below shows the unweighted liquidity value of assets
categorised as liquid, which is used for the purposes of calculating
the LCR metric. This reflects the stock of unencumbered liquid
assets at the reporting date, using the regulatory definition of
liquid assets.
Operating entities' liquid assets
At Estimated
liquidity value
At Estimated
liquidity value
31 Dec 2021
31 Dec 2020
£m
£m
HSBC Bank plc
Level 1
89,805
88,942
Level 2a
6,320
8,260
Level 2b
3,550
3,888
HSBC Continental Europe
Level 1
39,159
34,981
Level 2a
450
267
Level 2b
142
—
HSBC Germany
Level 1
13,072
11,044
Level 2a
33
8
Level 2b
327
315
Sources of funding
Our primary sources of funding are customer current accounts,
repo and wholesale securities.
The following ‘Funding sources and uses’ table provides a
consolidated view of how our balance sheet is funded, and should
be read in light of the LFRF, which requires operating entities to
manage liquidity and funding risk on a stand-alone basis.
The table analyses our consolidated balance sheet according to
the assets that primarily arise from operating activities and the
sources of funding primarily supporting these activities. Assets
and liabilities that do not arise from operating activities are
presented at other balance sheet lines. In 2021, the level of
customer accounts continued to exceed the level of loans and
advances to customers. The positive funding gap was
predominantly deployed in liquid assets, cash and balances with
central banks and financial investments, as required by the LFRF.
HSBC Bank plc Annual Report and Accounts 2021
75
Funding sources and uses for the group
2021
2020
2021
2020
£m
£m
£m
£m
Sources
Uses
Customer accounts
205,241
195,184
Loans and advances to customers
91,177
101,491
Deposits by banks
32,188
34,305
Loans and advances to banks
10,784
12,646
Repurchase agreements – non-trading
27,259
34,903
Reverse repurchase agreements – non-trading
54,448
67,577
Debt securities in issue
9,428
17,371
Cash collateral, margin and settlement accounts
34,907
46,840
Cash collateral, margin and settlement accounts
37,076
47,173
Assets held for sale
9
90
Subordinated liabilities
12,488
13,764
Trading assets
83,706
86,976
Financial liabilities designated at fair value
33,608
40,792
–  reverse repos
8,626
8,182
Liabilities under insurance contracts
22,264
22,816
–  stock borrowing
3,218
4,137
Trading liabilities
46,433
44,229
–  other trading assets
71,862
74,657
–  repos
7,663
8,441
Financial investments
41,300
51,826
–  stock lending
1,637
3,356
Cash and balances with central banks
108,482
85,092
–  other trading liabilities
37,133
32,432
Other balance sheet assets
171,798
228,612
Total equity
23,715
23,849
At 31 Dec
596,611
681,150
Other balance sheet liabilities
146,911
206,764
At 31 Dec
596,611
681,150
Contingent liquidity risk arising from committed lending
facilities
The group provides customers with committed facilities such as
standby facilities to corporate customers and committed backstop
lines to conduits sponsored by the group. All of the undrawn
commitments provided to conduits or external customers are
accounted for in the LCR and NSFR in line with the applicable
regulations. This ensures that under a stress scenario any
additional outflow generated by increased utilisation of these
committed facilities by either customers or the group’s sponsored
conduits is appropriately reflected in our liquidity and funding
position.
In relation to commitments to customers, the table below shows
the level of undrawn commitments outstanding in terms of the five
largest single facilities and the largest market sector.
The group’s contractual exposures at 31 December monitored under the contingent liquidity risk limit structure
2021
2020
£bn
£bn
Commitments to conduits
Multi-seller conduits1
–  total lines
4.2
5.8
–  largest individual lines
0.2
0.4
Securities investment conduits – total lines
1.3
1.6
Commitments to customers
–  five largest 2
10.4
6.6
–  largest market sector3
7.7
8.0
1Exposures relate to the Regency multi-seller conduit. This vehicle provides funding to group customers by issuing debt secured by a diversified
pool of customer-originated assets.
2Represents the undrawn balance for the five largest committed liquidity facilities provided to customers, other than those facilities to conduits.
3Represents the undrawn balance for the total of all committed liquidity facilities provided to the largest market sector, other than those facilities to
conduits.
Asset encumbrance and collateral management
An asset is defined as encumbered if it has been pledged as
collateral against an existing liability and, as a result, is no longer
available to the group to secure funding, satisfy collateral needs or
be sold to reduce the funding requirement. Collateral is managed
on an operating entity basis consistent with the approach to
managing liquidity and funding. Available collateral held in an
operating entity is managed as a single consistent collateral pool
from which each operating entity will seek to optimise the use of
the available collateral. The objective of this disclosure is to
facilitate an understanding of available and unrestricted assets
that could be used to support potential future funding and
collateral needs. The disclosure is not designed to identify assets
which would be available to meet the claims of creditors or to
predict assets that would be available to creditors in the event of a
resolution or bankruptcy.
Summary of assets available to support potential future funding and collateral needs (on- and off-balance sheet)
2021
2020
£m
£m
Total on-balance sheet assets at 31 Dec
596,611
681,150
Less:
–  reverse repo/stock borrowing receivables and derivative assets
(207,513)
(281,125)
–  other assets that cannot be pledged as collateral
(48,350)
(51,068)
Total on-balance sheet assets that can support funding and collateral needs at 31 Dec
340,748
348,957
Add: off-balance sheet assets
–  fair value of collateral received in relation to reverse repo/stock borrowing/derivatives that is available to sell or repledge
202,794
213,690
Total assets that can support future funding and collateral needs
543,542
562,647
Less:
–  on-balance sheet assets pledged
(93,513)
(107,671)
–  re-pledging of off-balance sheet collateral received in relation to reverse repo/stock borrowing/derivatives
(151,378)
(154,486)
Assets available to support funding and collateral needs at 31 Dec
298,651
300,490
Report of the Directors | Risk
76
HSBC Bank plc Annual Report and Accounts 2021
Market risk
Overview
Market risk is the risk that movements in market factors, including
foreign exchange rates and commodity prices, interest rates,
credit spreads and equity prices will reduce the group’s income or
the value of its portfolios.
Exposure to market risk is separated into two portfolios.
Trading portfolios comprise positions arising from market-making
and warehousing of customer-derived positions.
Non-trading portfolios including Markets Treasury comprise
positions that primarily arise from the interest rate management of
the group’s retail and commercial banking assets and liabilities,
financial investments designated as held-to-collect-and-sale
(‘HTCS’), and exposures arising from the group’s insurance
operations.
Key developments in 2021
There were no material changes to our policies and practices for
the management of market risk in 2021.
Market risk governance
(Audited)
The following diagram summarises the main business areas where
trading and non-trading market risks reside, and the market risk
measures used to monitor and limit exposures.
Risk types
Trading risk
Non-trading risk
•Foreign exchange and
commodities
•Interest rates
•Credit spreads
•Equities
•Interest rates
•Credit spreads
•Foreign exchange
Risk measure
Value at risk | Sensitivity
| Stress testing
Value at risk | Sensitivity |
Stress testing
Where appropriate, we apply similar risk management policies and
measurement techniques to both trading and non-trading
portfolios. Our objective is to manage and control market risk
exposures to optimise return on risk while maintaining a market
profile consistent with our established risk appetite.
Market risk is managed and controlled through limits approved by
the group Chief Risk Officer. These limits are allocated across
business lines and to the group and its subsidiaries. The majority
of HSBC’s total VaR and almost all trading VaR reside in GBM.
Each major operating entity has an independent market risk
management and control sub-function, which is responsible for
measuring, monitoring and reporting market risk exposures
against limits on a daily basis. Each operating entity is required to
assess the market risks arising in its business and to transfer them
either to its local Markets & Securities Services or Markets
Treasury unit for management, or to separate books managed
under the supervision of the local ALCO. The Traded Risk function
enforces the controls around trading in permissible instruments
approved for each site as well as following completion of the new
product approval process. Traded Risk also restricts trading in the
more complex derivative products to offices with appropriate
levels of product expertise and robust control systems.
Market risk measures
Monitoring and limiting market risk exposures
Our objective is to manage and control market risk exposures
while maintaining a market profile consistent with the group’s risk
appetite.
We use a range of tools to monitor and limit market risk exposures
including sensitivity analysis, VaR, and stress testing
Sensitivity analysis
Sensitivity analysis measures the impact of individual market
factor movements on specific instruments or portfolios, including
interest rates, foreign exchange rates, credit spreads and equity
prices, such as the effect of a one basis point change in yield. We
use sensitivity measures to monitor the market risk positions
within each risk type. Sensitivity limits are set for portfolios,
products and risk types, with the depth of the market being one of
the principal factors in determining the level of limits set.
Value at risk
VaR is a technique that estimates the potential losses on risk
positions as a result of movements in market rates and prices over
a specified time horizon and to a given level of confidence. The
use of VaR is integrated into market risk management and is
calculated for all trading positions regardless of how the group
capitalises those exposures. Where there is not an approved
internal model, the group uses the appropriate local rules to
capitalise exposures.
In addition, the group calculates VaR for non-trading portfolios in
order to have a complete picture of risk. The models are
predominantly based on historical simulation. VaR is calculated at
a 99% confidence level for a one-day holding period. Where we do
not calculate VaR explicitly, we use alternative tools like Stress
Testing.
The VaR models used by us are based predominantly on historical
simulation. These models derive plausible future scenarios from
past series of recorded market rates and prices, taking into
account inter-relationships between different markets and rates
such as interest rates and foreign exchange rates. The models also
incorporate the effect of option features on the underlying
exposures.
The historical simulation models used incorporates the following
features:
•historical market rates and prices are calculated with reference
to foreign exchange rates and commodity prices, interest rates,
equity prices and the associated volatilities;
•potential market movements utilised for VaR are calculated
with reference to data from the past two years; and
•VaR measures are calculated to a 99% confidence level and use
a one-day holding period.
The nature of the VaR models means that an increase in observed
market volatility will most likely lead to an increase in VaR without
any changes in the underlying positions.
VaR model limitations
Although a valuable guide to risk, VaR should always be viewed in
the context of its limitations. For example:
•the use of historical data as a proxy for estimating future events
may not encompass all potential events, particularly those
which are extreme in nature;
•the use of a holding period assumes that all positions can be
liquidated or the risks offset during that period. This may not
fully reflect the market risk arising at times of severe illiquidity,
when the holding period may be insufficient to liquidate or
hedge all positions fully;
•the use of a 99% confidence level by definition does not take
into account losses that might occur beyond this level of
confidence; and
•VaR is calculated on the basis of exposures outstanding at the
close of business and therefore does not necessarily reflect
intra-day exposures.
Risk not in VaR framework
Other basis risks which are not completely covered in VaR are
complemented by our risk not in VaR (‘RNIV’) calculations, and are
integrated into our capital framework.
Risk factors are reviewed on a regular basis and either
incorporated directly in the VaR models, where possible, or
quantified through the VaR-based RNIV approach or a stress test
approach within the RNIV framework. The outcome of the VaR-
based RNIV is included in the VaR calculation; a stressed VaR
RNIV is also computed for the risk factors considered in the VaR-
based RNIV approach.
HSBC Bank plc Annual Report and Accounts 2021
77
Stress-type RNIVs include a deal contingent derivatives capital
charge to capture risk for these transactions and a de-peg risk
measure to capture risk to pegged and heavily managed
currencies
Stress testing
Stress testing is an important procedure that is integrated into our
market risk management tool to evaluate the potential impact on
portfolio values of more extreme, although plausible, events or
movements in a set of financial variables. In such scenarios, losses
can be much greater than those predicted by VaR modelling.
Stress testing is implemented at legal entity, regional and overall
Group levels. A standard set of scenarios is utilised consistently
across all regions within the HSBC Group. Scenarios are tailored to
capture the relevant events or market movements at each level.
The risk appetite around potential stress losses for the group is set
and monitored against referral limits.
Market risk reverse stress tests are undertaken on the premise that
there is a fixed loss. The stress testing process identifies which
scenarios lead to this loss. The rationale behind the reverse stress
test is to understand scenarios which are beyond normal business
settings that could have contagion and systemic implications.
Stressed VaR and stress testing, together with reverse stress
testing and the management of gap risk, provide management
with insights regarding the ‘tail risk’ beyond VaR for which the
group's appetite is limited.
Trading portfolios
Back-testing
We routinely validate the accuracy of our VaR models by back-
testing the VaR metric against both actual and hypothetical profit
and loss. Hypothetical profit and loss excludes non-modelled items
such as fees, commissions and revenue of intra-day transactions.
The hypothetical profit and loss reflects the profit and loss that
would be realised if positions were held constant from the end of
one trading day to the end of the next. This measure of profit and
loss does not align with how risk is dynamically hedged, and is not
therefore necessarily indicative of the actual performance of the
business.
The number of back-testing exceptions is used to gauge how well
the models are performing. We consider enhanced internal
monitoring of a VaR model if more than five profit exceptions or
more than five loss exceptions occur in a 250-day period.
We back-test our VaR at set levels of our group entity hierarchy.
Non-trading portfolios
Non-trading VaR of HSBC Bank plc includes the interest rate risk
of non-trading financial instruments held by the global businesses
and transferred into portfolios managed by Markets Treasury or
Asset, Liability and Capital Management ('ALCM') functions. In
measuring, monitoring and managing risk in our non-trading
portfolios, VaR is just one of the tools used. The management of
interest rate risk in the banking book is described further in ‘Non-
trading interest rate risk’ below, including the role of Markets
Treasury. The Group’s and HSBC Bank plc’s control of market risk
in the non-trading portfolios is based on transferring the assessed
market risk of non-trading assets and liabilities created outside
Markets Treasury or Markets, to the books managed by Markets
Treasury, provided the market risk can be neutralised. The net
exposure is typically managed by Markets Treasury through the
use of fixed rate government bonds (liquid asset held in held-to-
collect-and-sale ('HTCS' books)) and interest rate swaps. The
interest rate risk arising from fixed rate government bonds held
within HTCS portfolios is reflected within the group’s non-trading
VaR. Interest rate swaps used by Markets Treasury are typically
classified as either a fair value hedge or a cash flow hedge and
included within the group’s non-trading VaR. Any market risk that
cannot be neutralised in the market is managed by HSBC Bank plc
ALCM in segregated ALCO books.
Defined benefit pension plans
Market risk also arises within the Bank’s defined benefit pension
plans to the extent that the obligations of the plans are not fully
matched by assets with determinable cash flows. Refer to the
Pension risk management processes section on page 73 for
additional information.
Market risk in 2021
Financial markets performed well in 2021. During the first half of
the year, the rollout of COVID vaccination programmes, loose
financial conditions and continued fiscal support contributed to a
gradual reopening of major economies. Concerns of rising
inflationary pressures were mainly interpreted as transitory. Whilst
the path of monetary policies remained uncertain, central banks
continued to provide liquidity. This supported risk assets
valuations, while volatility in most asset classes was subdued. In
the second half of 2021, amid the emergence of new COVID
variants, global equities reached further record highs, as investors
focused on global economic resilience and corporate earnings.
Yields followed a downward trend for most of 3Q-21, before
reversing in the final weeks of the year, when markets began
pricing a faster pace of interest rate rises in some of the major
economies, due to persistently elevated inflation and the
expectation of tighter monetary policies. Credit markets remained
strong, with credit benchmark indices for investment-grade and
high-yield debt close to pre-pandemic levels.
We continued to manage market risk prudently during 2021.
Sensitivity exposures and VaR remained within appetite as the
business pursued its core market-making activity in support of our
customers. Market risk was managed using a complementary set
of risk measures and limits, including stress and scenario analysis.
Trading portfolios
Value at risk of the trading portfolios
(Audited)
Trading VaR predominantly resides within Market Securities
Services where it was £19m at 31 December 2021 compared with
£27.5m at 31 December 2020. The Total Trading VaR peaked at
£31.9m early January owing to some negative convexity positions
in the FX options portfolio and then rapidly decreased and
remained fairly stable during the year, ranging between £15m and
£25m. We saw it spike to £29.8m end of March, owing to an
unusually large increase of the TRY Rates and the sensitivity of the
FX cash desk to that risk factor.
Report of the Directors | Risk
78
HSBC Bank plc Annual Report and Accounts 2021
Daily VaR (trading portfolios), 99% 1 day (£m)
.
The group’s trading VaR for the year is shown in the table below.
Trading VaR, 99% 1 day
(Audited)
Foreign
exchange ('FX')
and commodity
Interest
rate ('IR')
Equity ('EQ')
Credit
Spread ('CS')
Portfolio
Diversification1
Total2
£m
£m
£m
£m
£m
£m
Balance at 31 Dec 2021
4.5
10.0
10.5
14.9
(20.9)
19.0
Average
7.1
12.8
10.2
12.6
(20.4)
22.3
Maximum
19.3
26.7
14.9
16.7
—
31.9
Minimum
3.7
9.3
6.3
9.2
—
17.3
Balance at 31 Dec 2020
7.6
11.0
13.9
14.1
(19.2)
27.5
Average
6.5
13.5
18.7
14.1
(20.8)
32.1
Maximum
14.2
21.2
33.2
29.2
—
47.7
Minimum
2.0
9.2
8.1
9.6
—
20.9
1Portfolio diversification is the market risk dispersion effect of holding a portfolio containing different risk types. It represents the reduction in
unsystematic market risk that occurs when combining a number of different risk types, for example, interest rate, equity and foreign exchange,
together in one portfolio. It is measured as the difference between the sum of the VaR by individual risk type and the combined total VaR. A
negative number represents the benefit of portfolio diversification. As the maximum occurs on different days for different risk types, it is not
meaningful to calculate a portfolio diversification benefit for this measure.
2The total VaR is non-additive across risk types due to diversification effect and it includes VaR RNIV.
Back-testing
In 2021, HSBC Bank plc experienced 5 back testing exceptions in
total, 2 of which against the Hypothetical P&L and 3 of which
against the Actual P&L.
The first exception against hypothetical P&L occurred in March
and was mostly due to a rates sell-off and a decrease of the Equity
volatilities.
The second exception against hypothetical P&L occurred at the
end of December and was mostly due to a decrease of the Equity
volatilities, which had a negative impact on the Equity Derivative
desk.
Two of the three exceptions against the Actual P&L were due to
the novation of trades from the RWA optimization unit in HBCE.
The last exception against the Actual P&L was mostly due to the
February month end Independent Price verification and Bid-Offer
reserve across HSBC Bank plc and HSBC France.
Non-trading portfolios
Value at risk of the non-trading portfolios
(Audited)
The non-trading VaR in 2021 was driven by interest rate risk in the
banking book. During the first half of the year, the non-trading VaR
trended upwards into the month of May as the Markets Treasury
business took advantage of higher yield environment and
increased USD and GBP sovereign bond holdings in their book,
with non-trading VaR reaching a high of £37.8m. Bond positions
receded during Q2 before increasing again at the tail end of Q3 as
rates sold off and inflation pressures grew. Markets Treasury
business re-deployed cash within the Liquid Asset Buffer (LAB)
into local government securities as opportunities arose. The
positions and non-trading VaR then declined in December to end
the year at £29.4m. The daily levels of total non-trading VaR over
the last year are set out in the graph below.
HSBC Bank plc Annual Report and Accounts 2021
79
Daily VaR (non-trading portfolios), 99% 1 day (£m)
The group’s non-trading VaR for the year is shown in the table below.
Non-trading VaR, 99% 1 day
(Audited)
Interest
rate ('IR')
Credit
spread ('CS')
Portfolio
diversification1
Total2
£m
£m
£m
£m
Balance at Balance at 31 Dec 2021
28.7
9.0
(8.4)
29.4
Average
26.6
10.0
(5.6)
31.0
Maximum
34.6
12.7
—
37.8
Minimum
18.0
7.2
—
22.5
Balance at 31 Dec 2020
25.1
11.6
(3.4)
33.3
Average
21.9
12.3
(6.3)
27.9
Maximum
28.8
16.6
—
35.0
Minimum
14.3
5.5
—
15.0
1Portfolio diversification is the market risk dispersion effect of holding a portfolio containing different risk types. It represents the reduction in
unsystematic market risk that occurs when combining a number of different risk types, for example, interest rate, equity and foreign exchange,
together in one portfolio. It is measured as the difference between the sum of the VaR by individual risk type and the combined total VaR. A
negative number represents the benefit of portfolio diversification. As the maximum occurs on different days for different risk types, it is not
meaningful to calculate a portfolio diversification benefit for this measure.
2The total VaR is non-additive across risk types due to diversification effect.
Resilience Risk
Overview
Resilience risk is the risk that we are unable to provide critical
services to our customers, affiliates and counterparties, as a result
of sustained and significant operational disruption. Resilience risk
arises from failures or inadequacies in processes, people, systems
or external events.
Resilience Risk management
Key developments in 2021
Our Operational and Resilience Risk function provides robust non-
financial risk steward oversight of the management of risk within
the group's businesses, functions and legal entities. It also
provides effective and timely independent challenge. During the
year we carried out a number of initiatives to strengthen the
management of non-financial risks:
•We developed a more robust understanding of our risk and
control environment, by updating our material risk taxonomy
and control libraries, and refreshing material risk and control
assessments.
•We further strengthened our non-financial risk governance and
senior leadership.
•We created a consolidated view of risk issues enabling better
senior management focus on non-financial risk, and the ability
to identify material control issues and intervention as required.
•We improved how we provide analysis and reporting of non-
financial risks, with more risk practitioners having access to a
wider range of management information on their risks and
controls.
•We increased the capability of risk stewards to allow for
effective stewardship to be in place in HSBC Bank plc.
•We strengthened our approach in the comparison of issues and
near misses by implementing a group approach that considers
all events across the global businesses, functions and regions.
•We enhanced risk management oversight across our most
material change initiatives to support growth in our strategic
transformation.
We prioritise our efforts on material risks and areas undergoing
strategic growth, aligning our location strategy to this need.
Governance and structure
The Operational and Resilience Risk target operating model
provides a consistent view across resilience risks, strengthening
our risk management oversight while operating effectively as part
of a simplified non-financial risk structure. We view resilience risk
across seven risk types related to: third parties and supply chains;
information, technology and cybersecurity; payments and manual
processing; physical security; business interruption and
contingency risk; building unavailability; and workplace safety.
Operational and Resilience Risk is governed in the group through
the RMM and our Risk Committee with clear global escalation
Report of the Directors | Risk
80
HSBC Bank plc Annual Report and Accounts 2021
routes through to the Non-Financial Risk Management Board
('NFRMB'), chaired by the Group Chief Risk and Compliance
Officer, and the Group Risk Management Meeting (‘GRMM’).
Key risk management process
Operational resilience is our ability to anticipate, prevent, adapt,
respond to, recover and learn from internal or external disruption,
protecting customers, the markets we operate in and economic
stability. Resilience is determined by assessing whether we are
able to continue to provide our most important services, within an
agreed level. We accept we will not be able to prevent all
disruption, we prioritise investment to continually improve the
response and recovery strategies for our most important business
services.
Business operations continuity
Business Continuity, in response to the Covid-19 pandemic,
remains in place across a number of locations where we operate,
allowing the majority of service level agreements to be
maintained. There were no significant impacts to service delivery
in locations where we operate.
Regulatory compliance risk
Overview
Regulatory compliance risk is the risk that we fail to observe the
letter and spirit of all relevant laws, codes, rules, regulations and
standards of good market practice, which as a consequence incur
fines and penalties and suffer damage to our business.
Regulatory compliance risk arises from the risks associated with
breaching our duty to our customers and inappropriate market
conduct, as well as breaching regulatory licensing, permissions
and rules.
Key developments in 2021
In 2021, we continued to embed the structural changes made in
the prior year to our wider approach to Compliance Risk
Management. Further, the integration of the Risk and Compliance
Functions in May 2021 has brought together two complimentary
functions which will strengthen the Regulatory Conduct mandate
and our capability to drive ever greater standards in regard to
conduct of our business.
In June 2021, we also announced HSBC’s new purpose-led
approach to conduct. As part of this, we have taken the
opportunity to simplify our approach, making Conduct easier to
understand and showing how it fulfils our value: ‘we take
responsibility’.
Governance and structure
We have evolved our structure in response to ever-changing
business and industry needs. We reviewed the effectiveness of our
governance framework to manage regulatory compliance risk,
such as to enable compliance with the letter and the spirit of all
applicable laws and regulations, as well as our own standards,
values and policies.
In 2021, the key governance meeting was the HBEU Risk
Management Meeting ('RMM'). The RMM acts as the sole
governance for risk management across all risk types. The Chief
Risk Officer ('CRO'), currently chairs the RMM, attended by the
CEO, Business Heads and Risk Stewards. To attend to all
compliance related discussions and matters in the RMM, the Chief
Compliance Officer is a key member of the RMM.
The Europe Regulatory Conduct capability continues to work
closely with the Country Chief Compliance Officers and their
respective teams to help them identify and manage regulatory
compliance risks across the region. They also work together to
ensure good conduct outcomes and provide enterprise-wide
support on the regulatory agenda.
Key risk management processes
The Europe Regulatory Conduct function is responsible for setting
policies, standards and risk appetite to guide the management of
regulatory compliance. It also devises clear frameworks and
support processes to mitigate regulatory compliance risks. The
capability provides oversight, review and challenge to the Country
Chief Compliance Officers and their teams to help them identify,
assess and mitigate regulatory compliance risks, where required.
The regulatory compliance risk policies are regularly reviewed.
Policies and procedures require the prompt identification and
escalation of any actual or potential regulatory breach. Relevant
reportable events are escalated to the HBEU RMM and to the
Group Risk Committee, as appropriate.
Conduct of business
Our new simplified Conduct Approach, which was launched in
2021, guides us to do the right thing and to recognise the real
impact we have for our customers and the financial markets in
which we operate. It complements our Purpose and Values,
setting the right outcomes to be achieved for our customers and
markets. It recognises cultural and behavioural drivers of good
Conduct Outcomes and applies across all risk disciplines,
operational processes and technologies. During 2021:
a.We understood and serviced our customer’s ongoing needs
and continued to champion a strong conduct and customer-
focused culture.
b.We demonstrated this through providing support to our
customers facing financial difficulties as a result of the
prolonged impacts of the pandemic and the resulting
uncertainty in trading conditions.
c.We acted with integrity through areas such as commencing the
integration of Climate Risk into the Risk Management approach
to recognise the importance of strengthened controls and
oversight for our related activities.
d.We operated resiliently and securely to avoid harm to our
customers and markets by continuing to embed conduct within
our business line processes and through our Non- Financial and
Financial Risk Steward activities.
e.We continued our focus on culture and behaviours as a driver
of good conduct outcomes.
f.We placed a particular focus on the importance of well-being
and collaborative working as we continued to adapt to
changing working practices as the pace of change resulting
from the pandemic varied across our markets.
g.We continued to emphasise – and worked to create – an
environment in which employees are encouraged and feel safe
to speak up.
h.We delivered our annual global mandatory training course on
conduct to reinforce the important role we all play in adhering
to good conduct and values.
Regulators and governments
We seek strong, open and transparent engagement with all our
regulators and have extensive interaction with them as they
pursue their regulatory objectives. We engage with governments
and policymakers at a regional and national level to make a
positive contribution to the evolving regulatory landscape. We also
actively monitor changes in the laws and regulations that apply to
our activities, and respond to various formal consultations
published by governments, regulatory agencies and standard
setting bodies, either directly or through input to trade body
responses.
Financial crime risk
Overview
Financial crime risk is the risk of knowingly or unknowingly
helping parties to commit or to further illegal activity through
HSBC, including money laundering, terrorist and proliferation
financing, tax evasion, bribery and corruption, sanctions, fraud
and market abuse. Financial crime risk arises from day-to-day
HSBC Bank plc Annual Report and Accounts 2021
81
banking operations involving customers, third parties and
employees.
Key developments in 2021
We consistently review the effectiveness of our financial crime risk
management framework, which includes consideration of
geopolitical and wider economic factors, and 2021 was no
exception. We continued to support the business in navigating the
complex and dynamic nature of geopolitics as it relates to
sanctions and export control risk, notably with respect to the array
of new regulations and designations in 2021 and in alignment with
our policy, which is to comply with all applicable sanctions
regulations in the jurisdictions in which we operate.
We also continued to progress several key financial crime risk
management initiatives based on an increased use of technology
to enhance our processes, while minimising the impact to the
customer, including:
•Deployment of a key component of our intelligence-led,
dynamic risk assessment capabilities for customer account
monitoring in one of our home markets, as well as undertaking
key enhancements to our traditional transaction monitoring
systems
•Strengthening our anti-fraud capabilities, notably with respect
to the early identification of first party lending fraud and the
identification of new strategic detection tools
•Ongoing developments in leading-edge surveillance technology
and capabilities to identify potential market abuse, including
testing Machine Learning within Unauthorised Trading
•Investing in the use of artificial intelligence (‘AI’) and advanced
analytics techniques to manage financial crime risk, notably
new automated capabilities in name and transaction screening
•Implementing a market leading gifts and entertainment ('G&E')
recording and approval system, which, in combination with an
expenses reconciliation tool, allows HSBC to manage its G&E
risk consistently and effectively.
Governance and Structure
Since establishing a global framework of financial crime risk
management committees, we have continued to review the
effectiveness of our governance framework to manage financial
crime risk, such as to enable compliance with the letter and the
spirit of all applicable financial crime laws and regulations, as well
as our own standards, values and policies relating to financial
crime risks.
In 2021, the key financial crime governance meeting, HBEU
Financial Crime Risk Management Committee ('FCRMC'),
established in June 2017, merged into the HBEU Risk
Management Meeting ('RMM'), to support the strategic objectives
of reducing bureaucracy and increasing efficiency in decision
making. This ensures a more efficient approach to the
management of financial crime risk, by streamlining the body for
executive governance. This is also due to the success of the
FCRMC framework, which helped successfully embed the
management of financial crime risk under the three lines of
defence model. The RMM now acts as the sole governance for risk
management across all risk types. This does not reduce the
importance which HSBC places on the management of financial
crime risk, nor does it reduce any of the underlying activities or
commitments. The Chief Risk Officer ('CRO'), currently chairs the
RMM, attended by the CEO and Business Heads. To attend to all
financial crime risk related discussions and matters in the RMM,
the Chief Compliance Officer and Money Laundering Reporting
Officer are key members of the RMM.
Key risk management processes
We assess the effectiveness of our financial crime risk
management framework on an ongoing basis and invest in
enhancing our operational control capabilities and technology
solutions to deter and detect criminal activity. We have continued
to simplify our end to end financial crime risk management
framework, streamlining and de-duplicating policy requirements,
while also strengthening our financial crime risk taxonomy and
control libraries, our investigative and monitoring capabilities
through technology deployments, as well as developing more
targeted metrics. We have also enhanced governance and
reporting. 
We are committed to working in partnership with the wider
industry and the public sector in managing financial crime risk,
protecting the integrity of the financial system and the
communities we serve. We participate in numerous public-private
partnerships and information-sharing initiatives, also supporting
national governments and international standard setters’ reform
activity. In 2021, there was a particular focus on reform activity in
the EU and the UK, where we were front and centre of industry
responses to a number of consultation papers focused on the
overall effectiveness of the anti-money laundering framework. We
also took part in a number of round-tables organised by the
Financial Action Task Force, supporting their strategic review, as
well as their work on digitisation and beneficial ownership
registers. These align with our objectives of promoting a public
policy and regulatory environment that embraces the use of
technology in building the future financial crime framework to
ensure our bank is more resilient and secure, while enabling
benefits for customers.
ESG disclosures
We have continued our efforts to combat financial crime risks and
reduce their impact on our organisation, our customers and the
communities that we serve. These financial crime risks include
money laundering, terrorist and proliferation financing, tax
evasion, bribery and corruption, sanctions, fraud and market
abuse. As part of this work, we have made progress on several
key initiatives, enabling us to manage and mitigate these risks
more effectively, and further our pioneering work in financial crime
risk management across the financial services industry.
HSBC operates a zero tolerance approach to bribery and
corruption, and considers such activity to be unethical and
contrary to good environmental, social and corporate governance.
HSBC, its staff and third parties are prohibited from engaging in or
facilitating bribery or corruption. HSBC has a global anti-bribery
and corruption policy ('AB&C Policy'), which sets out the key
principles and minimum control requirements that enable HSBC to
mitigate bribery and corruption risk and comply with all laws and
regulations in the countries where we operate, including the UK
Bribery Act and France’s Loi Sapin II. In order to prevent bribery
and corruption, the AB&C Policy requires that all activity: 
•must be conducted without intent to bribe or corrupt;
•must be reasonable and transparent;
•must not be considered lavish or disproportionate to the
professional relationship;
•must be appropriately documented with business rationale; and
•must be authorised at an appropriate level of seniority.
HSBC requires all staff, board of directors and associated persons
comply with the principles in the AB&C Policy. Annual mandatory
AB&C training is provided to all staff (including temporary workers
and contractors), with additional targeted training tailored to the
roles and risk rating of individuals. HSBC carries out regular risk
assessments, monitoring and testing of its AB&C programme,
with any applicable findings included within the annual AB&C
Policy refresh. HSBC also maintains clear whistleblowing policies
and processes, to ensure that individuals can confidentially report
concerns.
There are currently no concluded legal cases regarding bribery or
corruption brought against the issuer or its employees during the
reporting period.
We continue to invest in new technology to enable us to make an
impact in the fight against financial crime, including the use of
contextual monitoring in our trade finance business, the
enhancement of our fraud monitoring and market surveillance
capabilities and the application of machine learning techniques to
improve the accuracy and timeliness of our financial crime
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82
HSBC Bank plc Annual Report and Accounts 2021
detection capabilities, with due care and attention paid to the
ethical questions arising with the use of AI in particular.
We are confident our adoption of these new technologies will
continue to enhance our ability to respond quickly to suspicious
activity and be more granular in our risk assessments, helping to
protect our customers and the integrity of the financial system.
Skilled Person & Independent Consultant
In December 2012, HSBC Holdings entered into a number of
agreements, including an undertaking with the UK Financial
Services Authority (replaced with a Direction issued by the UK
Financial Conduct Authority (‘FCA’) in 2013 and again in 2020), as
well as a cease-and-desist order with the US Federal Reserve
Board (‘FRB’), both of which contained certain forward-looking
anti-money laundering (‘AML’) and sanctions-related obligations.
HSBC also agreed to retain an independent compliance monitor
(who was, for FCA purposes, a ‘Skilled Person’ under section 166
of the Financial Services and Markets Act and, for FRB purposes,
an ‘Independent Consultant’) to produce periodic assessments of
the Group’s AML and sanctions compliance programme.
In 2020, HSBC’s engagement with the independent compliance
monitor, acting in his roles as both Skilled Person and Independent
Consultant, concluded. The role of FCA Skilled Person was
assigned to a new individual in the second quarter of 2020. 
Separately, a new FRB Independent Consultant was appointed in
the second quarter of 2021 pursuant to the cease-and-desist order.
The new Skilled Person issued a final report in June 2021,
concluding its review. The 2021 FCA Firm Evaluation Letter
confirmed that there is no requirement for a further Skilled Person
review, finding that "HSBC had delivered its plans and developed
an automated transaction monitoring capability that is effective
overall".  The new Independent Consultant carried out the eighth
annual review for the FRB and issued its report in November 2021.
Overall, the Independent Consultant assessed that HSBC’s OFAC
compliance programme is substantially compliant with regulatory
expectations and is “well-performing, relative to its purpose and
design”. For the second year running the Independent Consultant
also found HSBC in compliance with each sub-paragraph of the
December 2012 FRB Cease and Desist Consent Order (the
'Consent Order').
Model risk
Overview
Model risk is the potential for adverse consequences from
business decisions informed by models, which can be exacerbated
by errors in methodology, design or the way they are used. Model
risk arises in both financial and non-financial contexts whenever
business decision making includes reliance on models.
Key developments in 2021
In 2021, we continued to make improvements in our model risk
management processes, amid regulatory changes in model
requirements.
Initiatives during the year included:
•We redeveloped, validated and submitted critical Internal
Ratings Based ('IRB') Approach models for credit risk, Internal
Model Method ('IMM') for counterparty credit risk and Internal
Model Approach ('IMA') models for market risk to the PRA in
response to regulatory capital changes. These new models
have been built to enhanced standards using improved data as
a result of investment in processes and systems.
•We redeveloped and validated models impacted by changes to
alternative rate setting mechanisms due to the IBOR transition.
•We made further enhancements to our control framework for
models used in financial reporting processes to address the
control weaknesses that emerged as a result of significant
increases in model adjustments and overlays that were applied
to compensate for the impact of Covid-19 on models and to
introduce a requirement for second line of defence to approve
material models prior to use.
•Our businesses and functions were more involved in the
development and management of models, hiring colleagues
who had strong model risk skills. They also put an enhanced
focus on key model risk drivers such as data quality and model
methodology.
•Our model owners in businesses and functions fully embedded
the requirements included in the model risk policy and
standards introduced in 2020.
•We delivered a suite of training on model risk to front line
teams to improve their awareness of model risk and their
adherence to the governance framework.
•We rolled out new model risk appetite measures, which are
more forward looking and will help our businesses and
functions manage model risk more effectively.
•We continued the transformation of the Model Risk
Management team, with changes to the model validation
processes, including new systems and processes. Key senior
hires were made during the year to lead the business areas and
regions to strengthen oversight and expertise within the
function. We also made changes to the model inventory system
to provide businesses and functions with improved
functionality and more detailed information related to model
risk.
•We initiated a programme of development related to climate
risk and models using advanced analytics and machine
learning, which have become critical areas of focus that will
grow in importance in 2022 and beyond. We also added
qualified specialist skills to the model risk teams to manage the
increased model risk.
Governance and structure
The group's Model Risk Committee is chaired by our Chief Risk
Officer and provides oversight of model risk. The committee
includes senior leaders and risk owners across the Lines of
Business and Risk and focuses on model-related concerns and key
model risk metrics.
Key risk management processes
We use a variety of modelling approaches, including regression,
simulation, sampling, machine learning and judgemental
scorecards for a range of business applications. These activities
include customer selection, product pricing, financial crime
transaction monitoring, creditworthiness evaluation and financial
reporting. Global responsibility for managing model risk is
delegated from the RMM to the Group Model Risk Committee,
which is chaired by the Group Chief Risk and Compliance Officer.
This committee regularly reviews our model risk management
policies and procedures, and requires the first line of defence to
demonstrate comprehensive and effective controls based on a
library of model risk controls provided by Model Risk
Management.
Model Risk Management also reports on model risk to senior
management on a regular basis through the use of the risk map,
risk appetite metrics and top and emerging risks.
We regularly review the effectiveness of these processes,
including the model oversight committee structure, to help ensure
appropriate understanding and ownership of model risk is
embedded in the businesses and functions.
Insurance manufacturing operations risk
Overview
The key risks for our insurance manufacturing operations are
market risks, in particular interest rate and equity, credit risks and
insurance underwriting and operational risks. These have a direct
impact on the financial results and capital positions of the
insurance operations. Liquidity risk, whilst significant in other
parts of the bank, is relatively minor for our insurance operations.
HSBC Bank plc Annual Report and Accounts 2021
83
HSBC’s insurance business
We sell insurance products worldwide through a range of
channels including our branches, direct channels and third-party
distributors. The majority of sales are through an integrated
bancassurance model that provides insurance products principally
for customers with whom we have a banking relationship.
The insurance contracts we sell relate to the underlying needs of
our customers, which we can identify from our point-of-sale
contacts and customer knowledge. For the products we
manufacture, the majority of sales are of savings, universal life and
protection contracts.
We choose to manufacture these insurance products in HSBC
subsidiaries based on an assessment of operational scale and risk
appetite. Manufacturing insurance allows us to retain the risks and
rewards associated with writing insurance contracts by keeping
part of the underwriting profit and investment income within the
Group.
Where we do not have the risk appetite or operational scale to be
an effective insurance manufacturer, we engage with a small
number of leading external insurance companies in order to
provide insurance products to our customers through our banking
network and direct channels. These arrangements are generally
structured with our exclusive strategic partners and earn the group
a combination of commissions, fees and a share of profits. We
distribute insurance products in all of our geographical regions.
Insurance products are sold through all global businesses, but
predominantly by WPB and CMB through our branches and direct
channels
Insurance manufacturing operations risk
management
Key developments in 2021
The insurance manufacturing subsidiaries follow the group’s risk
management framework. In addition, there are specific policies
and practices relating to the risk management of insurance
contracts. There were no material changes to the policies and
practices over 2021, although enhancements were made to the
product pricing and profitability framework to allow for the
transition to IFRS17.
Governance
Insurance manufacturing risks are managed to a defined risk
appetite, which is aligned to the bank’s risk appetite and risk
management framework, including the three lines of defence
model. For details on the governance framework, see page 21. The
Group Insurance Risk Management Meeting oversees the control
framework globally and is accountable to the WPB Risk
Management Meeting on risk matters relating to the insurance
business.
The monitoring of the risks within the insurance operations is
carried out by Insurance Risk teams. The Bank’s risk stewardship
functions support the Insurance Risk teams in their respective
areas of expertise.
Stress and scenario testing
Stress testing forms a key part of the risk management framework
for the insurance business. We participate in local and Group-wide
regulatory stress tests, including the Bank of England stress test of
the banking system, the European Insurance and Occupational
Pensions Authority stress test, and individual country insurance
regulatory stress tests.
The results of these stress tests and the adequacy of management
action plans to mitigate these risks are considered in the HBEU
ICAAP and the entities’ regulatory Own Risk and Solvency
Assessments (ORSAs).
Management and mitigation of key risk types
Market risk
All our insurance manufacturing subsidiaries have market risk
mandates and limits that specify the investment instruments in
which they are permitted to invest and the maximum quantum of
market risk that they may retain. They manage market risk by
using, among others, some or all of the techniques listed below,
depending on the nature of the contracts written:
•We are able to adjust bonus rates to manage the liabilities to
policyholders for products with discretionary participating
features (‘DPF’). The effect is that a significant portion of the
market risk is borne by the policyholder.
•We use asset and liability matching where asset portfolios are
structured to support projected liability cash flows. The Group
manages its assets using an approach that considers asset
quality, diversification, cash flow matching, liquidity, volatility
and target investment return. We use models to assess the
effect of a range of future scenarios on the values of financial
assets and associated liabilities, and ALCOs employ the
outcomes in determining how best to structure asset holdings
to support liabilities.
•We use derivatives to protect against adverse market
movements.
•We design new products to mitigate market risk, such as
changing the investment return sharing portion between
policyholders and the shareholder.
•We exit, to the extent possible, investment portfolios whose
risk is considered unacceptable.
Credit risk
Our insurance manufacturing subsidiaries also have credit risk
mandates and limits within which they are permitted to operate,
which consider the credit risk exposure, quality and performance
of their investment portfolios. Our assessment of the
creditworthiness of issuers and counterparties is based primarily
upon internationally recognised credit ratings and other publicly
available information.
Stress testing is performed on investment credit exposures using
credit spread sensitivities and default probabilities.
We use a number of tools to manage and monitor credit risk.
These include a credit report containing a watch-list of
investments with current credit concerns, primarily investments
that may be at risk of future impairment or where high
concentrations to counterparties are present in the investment
portfolio. Sensitivities to credit spread risk are assessed and
monitored regularly.
Capital and liquidity risk
Capital risk for our insurance manufacturing subsidiaries is
assessed in the group’s ICAAP based on their financial capacity to
support the risks to which they are exposed. Capital adequacy is
assessed on both the group’s economic capital basis, and the
relevant local insurance regulatory basis. The group’s economic
capital basis is largely aligned to European Solvency II regulations.
Risk appetite buffers are set to ensure that the operations are able
to remain solvent on both bases, allowing for business-as-usual
volatility and extreme but plausible stress events.
Liquidity risk is managed by cash flow matching and maintaining
sufficient cash resources, investing in high credit-quality
investments with deep and liquid markets, monitoring investment
concentrations and restricting them where appropriate, and
establishing committed contingency borrowing facilities.
Insurance manufacturing subsidiaries complete quarterly liquidity
risk reports and an annual review of the liquidity risks to which
they are exposed.
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84
HSBC Bank plc Annual Report and Accounts 2021
Insurance underwriting risk
Our insurance manufacturing subsidiaries primarily use the
following frameworks and processes to manage and mitigate
insurance underwriting risks:
•a formal approval process for launching new products or
making changes to products;
•a product pricing and profitability framework which requires
initial and ongoing assessment of the adequacy of premiums
charged on new insurance contracts to meet the risks
associated with them;
•a framework for customer underwriting;
•reinsurance which cedes risks above our appetite thresholds to
third party reinsurer thereby limiting our exposure; and
•oversight of expense and reserving risks by entity Actuarial
Control Committees.
Insurance manufacturing operations risk in 2021
Measurement
The following table shows the composition of assets and liabilities
by contract type.
Balance sheet of insurance manufacturing subsidiaries by type of contract
(Audited)
With DPF
Unit- linked
Other
contracts1
Shareholder
assets and
liabilities
Total
£m
£m
£m
£m
£m
Financial assets
19,384
2,924
254
2,704
25,266
–  financial assets designated and otherwise mandatorily measured at fair value through
profit or loss
9,876
2,859
89
1,236
14,060
–  derivatives
47
—
—
1
48
–  financial investments – at amortised cost
815
—
—
42
857
–  financial investments – at fair value through other comprehensive income
7,490
—
104
1,327
8,921
–  other financial assets2
1,156
65
61
98
1,380
Reinsurance assets
—
53
104
—
157
PVIF3
—
—
—
811
811
Other assets and investment properties
748
1
—
59
808
Total assets at 31 Dec 2021
20,132
2,978
358
3,574
27,042
Liabilities under investment contracts designated at fair value
—
1,031
—
—
1,031
Liabilities under insurance contracts
19,998
1,938
328
—
22,264
Deferred tax4
133
6
—
46
185
Other liabilities
—
—
—
2,003
2,003
Total liabilities at 31 Dec 2021
20,131
2,975
328
2,049
25,483
Total equity at 31 Dec 2021
—
—
—
1,559
1,559
Total liabilities and equity at 31 Dec 2021
20,131
2,975
328
3,608
27,042
Financial assets
20,261
2,412
249
2,490
25,412
–  financial assets designated and otherwise mandatorily measured at fair value through
profit or loss
9,148
2,352
92
991
12,583
–  derivatives
76
—
—
2
78
–  financial investments – at amortised cost
372
1
—
17
390
–  financial investments – at fair value through other comprehensive income
8,724
—
112
1,341
10,177
–  other financial assets2
1,941
59
45
139
2,184
Reinsurance assets
—
47
134
—
181
PVIF3
—
—
—
647
647
Other assets and investment properties
809
1
—
60
870
Total assets at 31 Dec 2020
21,070
2,460
383
3,197
27,110
Liabilities under investment contracts designated at fair value
—
944
—
—
944
Liabilities under insurance contracts
20,962
1,512
342
—
22,816
Deferred tax4
107
3
—
39
149
Other liabilities
—
—
—
1,776
1,776
Total liabilities at 31 Dec 2020
21,069
2,459
342
1,815
25,685
Total equity at 31 Dec 2020
—
—
—
1,425
1,425
Total liabilities and equity at 31 Dec 2020
21,069
2,459
342
3,240
27,110
1‘Other contracts’ includes term assurance and credit life insurance.
2Comprise mainly loans and advances to banks, cash and intercompany balances with other non-insurance legal entities.
3Present value of in-force long-term insurance business.
4  'Deferred tax’ includes the deferred tax liabilities arising on recognition of PVIF.
HSBC Bank plc Annual Report and Accounts 2021
85
Key risk types
Market risk
(Audited)
Description and exposure
Market risk is the risk of changes in market factors affecting the
bank’s capital or profit. Market factors include interest rates,
equity and growth assets and foreign exchange rates.
Our exposure varies depending on the type of contract issued. Our
most significant life insurance products are investment contracts
with discretionary participating features (‘DPF’) issued in France.
These products typically include some form of capital guarantee or
guaranteed return on the sums invested by the policyholders, to
which discretionary bonuses are added if allowed by the overall
performance of the funds. These funds are primarily invested in
fixed interest assets with a proportion allocated to other asset
classes, to provide customers with the potential for enhanced
returns. DPF products expose the bank to the risk of variation in
asset returns, which will impact our participation in the investment
performance. In addition, in some scenarios the asset returns can
become insufficient to cover the policyholders’ financial
guarantees, in which case the shortfall has to be met by the bank.
Amounts are held against the cost of such guarantees. The cost of
such guarantees is accounted for as a deduction from the present
value of in-force 'PVIF' asset, unless the cost of such guarantees is
already explicitly allowed for within the insurance contracts
liabilities. The table below shows the total reserve held for the cost
of guarantees, the range of investment returns on assets
supporting these products and the implied investment return that
would enable the business to meet the guarantees. The cost of
guarantees decreased to £299m (2020: £347m) primarily due to
increases in interest rates and favourable equity performances in
France. For unit-linked contracts, market risk is substantially borne
by the policyholder, but some market risk exposure typically
remains as fees earned are related to the market value of the
linked assets.
Financial return guarantees
(Audited)
2021
2020
Investment
returns
implied by
guarantee
Long-term
investment
returns on
relevant
portfolios
Cost of 
guarantees
Investment
returns
implied by
guarantee
Long-term
investment
returns on
relevant
portfolios
Cost of
guarantees
%
%
£m
%
%
£m
Capital
—
0.8 - 2.0
127
—
0.7 - 2.0
162
Nominal annual return
2.6
2.2
92
2.6
2.0
96
Nominal annual return
4.5
2.2
80
4.5
2.0
89
At 31 Dec
299
347
Sensitivities
The following table illustrates the effects of selected interest rate
and equity price scenarios on our profit for the year and the total
equity of our insurance manufacturing subsidiaries.
Where appropriate, the effects of the sensitivity tests on profit
after tax and equity incorporate the impact of the stress on the
PVIF. Due in part to the impact of the cost of guarantees and
hedging strategies which may be in place, the relationship
between the profit and total equity and the risk factors is non-
linear. Therefore, the results disclosed should not be extrapolated
to measure sensitivities to different levels of stress. For the same
reason, the impact of the stress is not necessarily symmetrical on
the upside and downside. The sensitivities are stated before
allowance for management actions which may mitigate the effect
of changes in the market environment. The sensitivities presented
allow for adverse changes in policyholder behaviour that may arise
in response to changes in market rates. The differences between
the impacts on profit after tax and equity are driven by the
changes in value of the bonds measured at fair value through
other comprehensive income, which are only accounted for in
equity.
Sensitivity of the group’s insurance manufacturing subsidiaries to market risk factors
(Audited)
2021
2020
Effect on
profit after tax
Effect on
total equity
Effect on profit
after tax
Effect on
total equity
£m
£m
£m
£m
+100 basis point parallel shift in yield curves
119
96
110
89
-100 basis point parallel shift in yield curves
(229)
(203)
(203)
(179)
10% increase in equity prices
46
46
39
39
10% decrease in equity prices
(49)
(49)
(42)
(42)
.
Credit risk
(Audited)
Description and exposure
Credit risk is the risk of financial loss if a customer or counterparty
fails to meet their obligation under a contract. It arises in two main
areas for our insurance manufacturers:
•risk associated with credit spread volatility and default by debt
security counterparties after investing premiums to generate a
return for policyholders and shareholders; and
•risk of default by reinsurance counterparties and non-
reimbursement for claims made after ceding insurance risk.
The amounts outstanding at the balance sheet date in respect of
these items are shown in the table on page 85. The credit quality
of the reinsurers’ share of liabilities under insurance contracts is
assessed as ‘satisfactory’ or higher as defined on page 33, with
100% of the exposure being neither past due nor impaired. Credit
risk on assets supporting unit-linked liabilities is predominantly
borne by the policyholder; therefore our exposure is primarily
related to liabilities under non-linked insurance and investment
contracts and shareholders’ funds. The credit quality of these
financial assets is included in the table on page 50.
Report of the Directors | Risk
86
HSBC Bank plc Annual Report and Accounts 2021
Liquidity risk
(Audited)
Description and exposure
Liquidity risk is the risk that an insurance operation, though
solvent, either does not have sufficient financial resources
available to meet its obligations when they fall due, or can secure
them only at excessive cost.
The following table shows the expected undiscounted cash flows
for insurance contract liabilities at 31 December 2021. The liquidity
risk exposure is wholly borne by the policyholder in the case of
unit-linked business and is shared with the policyholder for non-
linked insurance.
The profile of the expected maturity of insurance contracts at
31 December 2021 remained comparable with 2020.
The remaining contractual maturity of investment contract
liabilities is included within ‘Financial liabilities designated at fair
value’ in Note 27.
Expected maturity of insurance contract liabilities
(Audited)
Expected cash flows (undiscounted)
Within 1 year
1-5 years
5-15 years
Over 15 years
Total
£m
£m
£m
£m
£m
Unit-linked
230
565
927
926
2,648
With DPF and Other contracts
1,341
5,102
7,318
6,415
20,176
At 31 Dec 2021
1,571
5,667
8,245
7,341
22,824
Unit-linked
222
539
790
672
2,223
With DPF and Other contracts
1,565
5,765
7,735
6,077
21,142
At 31 Dec 2020
1,787
6,304
8,525
6,749
23,365
.
Insurance underwriting risk
Description and exposure
Insurance underwriting risk is the risk of loss through adverse
experience, in either timing or amount, of insurance underwriting
parameters (non-economic assumptions). These parameters
include mortality, morbidity, longevity, lapse and expense rates.
The principal risk we face is that, over time, the cost of
the contract, including claims and benefits, may exceed the total
amount of premiums and investment income received.
The table on page 85 analyses our insurance manufacturing
exposures by type of contract.
The insurance risk profile and related exposures remain largely
consistent with those observed at 31 December 2020.
Sensitivities
The table below shows the sensitivity of profit and total equity to
reasonably possible changes in non-economic assumptions across
all our insurance manufacturing subsidiaries.
Mortality and morbidity risk is typically associated with
life insurance contracts. The effect on profit of an increase in
mortality or morbidity depends on the type of business being
written.
Sensitivity to lapse rates depends on the type of contracts being
written. For a portfolio of term assurance, an increase in lapse
rates typically has a negative effect on profit due
to the loss of future income on the lapsed policies. However, some
contract lapses have a positive effect on profit due to the
existence of policy surrender charges. We are most sensitive to a
change in lapse rates in France.
Expense rate risk is the exposure to a change in the allocated cost
of administering insurance contracts. To the extent that increased
expenses cannot be passed on to policyholders, an increase in
expense rates will have a negative effect on our profits. This risk is
generally greatest for smaller entities.
Sensitivity analysis
(Audited)
2021
2020
£m
£m
Effect on profit after tax and total equity at 31
Dec
10% increase in mortality and/or morbidity rates
(20)
(15)
10% decrease in mortality and/or morbidity rates
19
15
10% increase in lapse rates
(19)
(19)
10% decrease in lapse rates
20
21
10% increase in expense rates
(40)
(46)
10% decrease in expense rates
40
43
HSBC Bank plc Annual Report and Accounts 2021
87
Corporate Governance Report
The statement of corporate governance practices set out on pages
88 to 96, together with the information incorporated by reference,
constitutes the Corporate Governance Report of the bank. The
following disclosures, read together with those in the Strategic
Report, including the section 172 statement on pages 9 and 10
and reporting on employee engagement on pages 7 to 10 describe
how the Board has discharged its duty under section 172 of the
Companies Act 2006 (the 'Act'), as well as the requirements under
the Companies (Miscellaneous Reporting) Regulations 2018 (the
'Reporting Regulations').
Engagement with employees, suppliers, customers and other key
stakeholders:
Stakeholder
Page
Section
Customers
Page 9
How we do business
Page 9
section 172 statement
Employees
Page 9
How we do business
Pages 9 and 10
section 172 statement
Pages 94 to 95
Corporate Governance
statement
Communities / the
environment
Pages 8 and 9
How we do business
Regulators
Page 10
How we do business
Page 9
section 172 statement
Suppliers
Page 10
How we do business
Page 9
section 172 statement
The bank, together with the wider Group, is committed to high
standards of corporate governance. The Group has a
comprehensive range of principles, policies and procedures
influenced by the UK Corporate Governance Code with
requirements in respect of Board independence, composition and
effectiveness to ensure that the Group is well managed, with
appropriate oversight and control. During the year, the bank
adhered to these corporate governance principles, policies and
procedures, as applicable.
Board of Directors
As at 31 December 2021, the Board comprised 10 Directors
including the Chair, eight non-executive Directors, and two
executive Directors, being the Chief Executive Officer and the
Chief Financial Officer. All Directors are subject to election or re-
election at the bank’s Annual General Meeting ('AGM'). The
Directors serving at 31 December 2021 are set out below.
Directors
Stephen O'Connor
Chairman
Chairman of the Nomination, Remuneration & Governance
Committee
Appointed to the Board: May 2018. Chairman since August
2018.
Stephen is a non-executive Director and Vice Chairman of HSBC
Continental Europe, Chairman of Quantile Group Limited and its
subsidiary Quantile Technologies Limited, and a Director of the
London Stock Exchange plc. He is also a non-executive Director of
the FICC Markets Standards Board. He has more than 25 years’
investment banking experience in London and New York.
Former appointments include: Senior Independent Director,
Chairman of the Risk Committee and member of both the Audit
and Nomination Committees of the London Stock Exchange Group
plc and Chairman of the International Swaps and Derivatives
Association, prior to which he was Managing Director and a
member of the Fixed Income Management Committee at Morgan
Stanley.
Colin Bell
Executive Director and Chief Executive Officer
Chairman of the Executive Committee and Executive Director of the
Board
Appointed to the Board and as Chief Executive Officer: February
2021.
Colin Bell is Chief Executive Officer, HSBC Bank plc and HSBC
Europe. He joined HSBC in July 2016 and most recently held the
role of Group Chief Compliance Officer until February 2021. He is a
member of the Supervisory Board, Remuneration, Nomination and
Mediation Committees of HSBC Trinkaus & Burkhardt AG and is
an Executive Director of HSBC Bank plc.
Before HSBC, Colin worked at UBS, where he was Head of
Compliance and Operational Risk Control. He has more than 10
years of experience in managing risk and financial crime, following
16 years in the British Army.
During his time in the Army, he held a variety of command and
staff appointments, including operational tours of Iraq and
Northern Ireland, time in the Ministry of Defence, a NATO
appointment and completion of the Advanced Command and Staff
Course.
David Watts
Executive Director and Chief Financial Officer
Member of the Executive Committee and Executive Director of the
Board
Appointed to the Board and as Chief Finance Officer: December
2021.
Dave joined the HSBC Group in 1994 and was previously a
Director and Chief Financial Officer of HSBC UK Bank plc.
Former HSBC Group roles include: Chief Financial Officer for
HSBC Bank plc, Global Commercial Banking, the Middle East and
North Africa, Group HSBC Technology and Operations, Global
Banking, and HSBC Securities (USA) Inc; Head of Group Cost and
Investment Reporting & Analysis; and Manager Treasury Services,
France.
Norma Dove-Edwin
Independent non-executive Director
Appointed to the Board: October 2021.
Norma serves as Chief Information Officer of ESO at National Grid
Plc. She is also a non-executive Director of Pod Point Group
Holdings plc.
Former appointments include: Group Chief Data and Information
Officer at Places for People and held a number of positions at
British American Tobacco Plc including as Head of Global Data
Services.
Dame Mary Marsh
Non-executive Director
Member of the Transformation, Operational Resilience and
Technology Committee
Appointed to the Board: January 2009.
Mary is a Director of the London Symphony Orchestra, a member
of the Governing Body and the Audit and Risk Committee of the
London Business School, a Trustee and Deputy Chair of the British
Spanish Society and a Trustee of Teach First.
Former appointments include: Non-executive Chair of the Trustees
of the Royal College of Paediatrics and Child Health, founding
Director of the Clore Social Leadership Programme and Chief
Executive of the National Society for the Prevention of Cruelty to
Children.
Report of the Directors | Corporate Governance
88
HSBC Bank plc Annual Report and Accounts 2021
Yukiko Omura
Independent non-executive Director
Member of the Audit Committee
Appointed to the Board: May 2018.
Yukiko is a senior independent non-executive Director of The
Private Infrastructure Development Group Limited (‘PIDG’). She
also serves as a non-executive Director of Assured Guaranty Ltd,
and a member of the Supervisory Board of Nishimoto HD Co. Ltd.
She has more than 35 years’ international professional experience
in both the public and private financial sector, performing senior
roles for JP Morgan, Lehman Brothers, UBS and Dresdner Bank.
Former appointments include: Chair of GuarantCo Limited, a
subsidiary of PIDG, Under-Secretary General and COO/Vice
President of the International Fund for Agricultural Development
and Executive Vice President and CEO of the Multilateral
Investment Guarantee Agency of the World Bank Group.
Juliet Robinson
Independent non-executive Director
Chair of the Transformation, Operational Resilience and Technology
Committee and member of the Risk Committee
Appointed to the Board: February 2021.
Former appointments include: Dual role as European Head of
Operations and Global Head of Shared Services and Banking
Operations and other senior management positions at Morgan
Stanley. Prior to 2007 she performed senior roles within Goldman
Sachs International.
Dr Eric Strutz
Independent non-executive Director
Chairman of the Risk Committee and member of the Nomination,
Remuneration & Governance Committee and Transformation,
Operational Resilience and Technology Committee
Appointed to the Board: October 2016.
Eric is a member of the Supervisory Board and Risk Committee
and Chairman of the Audit Committee of HSBC Trinkaus &
Burkhardt AG, a member of the Board of Directors and the
Remuneration Committee and Chairman of the Audit Committee
of Global Blue Group Holding AG, and a member of the Advisory
Board and Chairman of the Audit & Risk Committee of
Luxembourg Investment Company 261 Sarl.
Former appointments include: Vice Chairman and Lead
Independent Director of Partners Group Holding AG, where he also
Chaired the Risk and Audit Committee, Chief Financial Officer of
Commerzbank Group, Partner and Director of the Boston
Consulting Group, as well as non-executive Director of
Mediobanca Banca di Credito Finanziario SpA.
John Trueman
Deputy Chairman and non-executive Director
Member of the Audit Committee, the Risk Committee and the
Nomination, Remuneration & Governance Committee
Appointed to the Board: September 2004. Deputy Chairman
since December 2013.
Former appointments include: Chairman and member of the Risk
Committee of HSBC Global Asset Management Limited and
Deputy Chairman of S.G. Warburg & Co Ltd.
Andrew Wright
Independent non-executive Director
Chairman of the Audit Committee and member of the Risk
Committee and the Nomination, Remuneration & Governance
Committee
Appointed to the Board: May 2018.
Andrew is a member of the Supervisory Board and chairs the Risk
Committee of HSBC Trinkaus & Burkhardt AG. 
Former appointments include: Treasurer to the Prince of Wales
and the Duchess of Cornwall, a role he held from May 2012 until
June 2019, Global Chief Financial Officer for the Investment Bank
at UBS AG, Chief Financial Officer, Europe and the Middle East at
Lehman Brothers and Chief Financial Officer for the Private Client
and Asset Management Division at Deutsche Bank.
Board Changes during 2021 and following the
year-end
Nuno Matos stepped down from the Board and Colin Bell
succeeded him as a Director and Chief Executive Officer of the
bank and Europe with effect from 22 February 2021.
Stephen Moss stepped down from the Board on 23 February 2021
to take up the position of Chief Executive Officer, Middle East,
North Africa and Turkey (MENAT) in April 2021.
Jacques Fleurant stepped down from the Board on 30 September
2021 and Dave Watts succeeded him as a Director and Chief
Financial Officer of the bank with effect from 15 December 2021.
Juliet Robinson joined the Board as an independent non-executive
Director and member of the Risk Committee with effect from
1 February 2021. In 1 January 2021 she was appointed as Chair of
the Transformation, Operational Resilience and Technology
Committee.
Norma Dove-Edwin joined the Board as an independent non-
executive Director with effect from 28 October 2021.
Company Secretary
The responsibilities of the Company Secretary include ensuring
good governance practices at Board level and effective
information flows within the Board and its committees and
between senior management and the non-executive Directors.
Philip Jockelson acted as Company Secretary of the bank until
28 February 2021 and  Alison Campbell was appointed as
Company Secretary from 1 March 2021.
Board of Directors
Key responsibilities
The Board, led by the Chair, is responsible amongst other matters
for:
(i) promoting the long-term success of the bank and delivering
sustainable value to shareholders and other stakeholders;
(ii) entrepreneurial leadership of the bank within a framework of
prudent and effective controls which enables risks to be assessed
and managed;
(iii) setting the bank's strategy and risk appetite statement
including monitoring the bank's risk profile;
(iv) establishing and monitoring the effectiveness of procedures for
maintenance of a sound system of control and risk management,
and compliance with statutory and regulatory obligations; and
(v) approving the capital and operating plans and material
transactions on the recommendation of management.
The role of the non-executive Directors is to support the
development of proposals on strategy, hold management to
account and ensure the executive Directors are discharging their
responsibilities properly by promoting a culture that encourages
constructive challenge. Non-executive Directors also review the
performance of management in meeting agreed goals and
objectives. The Chair regularly meets with the non-executive
Directors without executive Directors in attendance after Board
meetings, and otherwise, as necessary.
Operation of the Board
During 2021, the Board was required to meet at least six times a
year; six additional meetings were scheduled to help facilitate,
amongst other things, the execution of the bank’s transformation
strategy. The Board agenda is agreed with the Chair, working
closely with the Company Secretary, in advance of scheduled
HSBC Bank plc Annual Report and Accounts 2021
89
meetings. The agenda is informed by forward-looking planning
and additional emerging matters that require Board oversight or
approval.
The Chief Risk Officer, General Counsel, and Company Secretary
are regular attendees at Board meetings, and other senior
executives attend to contribute their subject matter expertise and
insight, as required.
Board activities during 2021
During 2021, the Board focused on the implementation of
approved strategy and execution of the bank’s transformation
programme across the region, supporting senior management and
overseeing performance, risk and capital. The Board considered
performance against financial and other strategic objectives, key
business challenges, emerging risks, business development and
relationships with the bank’s key stakeholders.
Deep dives on key aspects of the bank's business were also
conducted to consider the performance and strategy of targeted
businesses and countries. Throughout the year, the Board received
regular updates from management including the implementation
of regulatory programmes, technology, operations and resilience,
as well as people, culture and talent.
During the year the Board also approved the financial, capital,
liquidity and funding plans put forward by management and
monitored the implementation of plans. Further information on the
principal decisions made by the Board during 2021, including in
respect of the strategic reset and capital plans is located in the
section 172 statement on pages 9 to 11.
Directors’ emoluments
Details of the emoluments of the Directors of the bank for 2021,
disclosed in accordance with the Act, are shown in Note 5
‘Employee compensation and benefits’.
Non-executive Directors do not have service contracts, but are
engaged through letters of appointment. There are no obligations
in the non-executive Directors’ letters of appointment that could
give rise to payments other than fees due or payments for loss of
office.
Board committees
The Board delegates oversight of certain audit, risk, remuneration,
nomination and governance matters to its committees. Each
standing Board committee is chaired by a non-executive Board
member and has a remit to cover specific topics in accordance
with their respective terms of reference. Only non-executive
Directors are members of Board committees. The Chairman of
each non-executive Board Committee reports to the Board on the
activities of the Committee since the previous Board meeting.
Board and Committee effectiveness and
performance
The Board understands the importance of, and benefits that derive
from regular reviews of the effectiveness of the Board and its
committees.  In 2020, the bank was subject to an internally
facilitated subsidiary governance review of the Group's main
subsidiary Boards and Committees. The review focused on (i) the
composition, skill-set, time commitment and fees for Boards and
Committees; (ii) service quality and scope of governance and
secretarial support; and (iii) the effectiveness of the bank's
relationship with the Group. The results of the subsidiary
governance review of the bank have been considered by the Board
and work was progressed during 2021 to address
recommendations. An annual review of the terms of reference for
the Board and its committees was facilitated by the Corporate
Governance and Secretariat function which assessed that the
Board and its committees had materially complied with their
respective terms of reference during 2021. Executive Directors are
also subject to performance evaluation which helps to determine
the level of variable pay they receive each year.
At the date of this report, the following are the principal
Committees of the Board:
Audit Committee
Key Responsibilities
The Audit Committee is accountable to the Board and has non-
executive responsibility for oversight of financial reporting related
matters, internal controls over financial reporting and
implementation of the group policies and procedures for capturing
and responding to whistleblower concerns.
The Committee's key responsibilities include:
(i) monitoring and assessing the integrity of the financial
statements, formal announcements and supplementary regulatory
information in relation to the bank's financial performance;
(ii) reviewing, as applicable, compliance with accounting
standards, listing rules, and other requirements in relation to
financial reporting;
(iii) reviewing and monitoring the relationship with the external
auditor; and
(iv) overseeing the work of Internal Audit and monitoring and
assessing the effectiveness, performance, resourcing,
independence and standing of the function.
The committee has responsibility for the oversight of the bank’s
whistleblowing arrangements, and receives regular updates on
matters relating to the whistleblowing arrangements that are in
place.
Committee activities during 2021
In addition to significant accounting judgements, key matters
considered by the Committee during the year were regulatory
reporting and control enhancements, interbank offered rates
(IBOR) transition, IFRS 17 implementation, the development of
climate-related disclosure, pension risk, the bank’s financial
resources and capital, transformation of the Finance function, the
independence, fees and performance of the external auditor, PwC,
and updates on key issues identified by Internal Audit related to
the bank and its subsidiaries.
The committee also received updates from the Chairs of the Audit
committees of key subsidiaries of the Bank, updates from the
external auditor on the progress and findings of their audit, and bi
annual updates on the tax position of the bank and its subsidiaries.
Operation of the Committee
The committee held seven scheduled meetings during the year
and held separate meetings with each of the Chief Finance Officer,
the Chief Risk Officer, the Head of Internal Audit and
representatives of the external auditor without management
present.
The committee meets regularly with the bank’s senior financial
and Internal Audit management and the external auditors to
consider, among other matters, the bank’s financial reporting, the
nature and scope of audit reviews, the effectiveness of the
systems of internal control relating to financial reporting and the
monitoring of the Finance function transformation programme.
The Chief Financial Officer, Financial Controller, Chief Risk Officer,
Head of Internal Audit, and Company Secretary are standing
attendees and regularly attend Committee meetings to contribute
their subject matter expertise and insight. Other members of
senior management routinely attended meetings of the
Committee. The external auditor attended all meetings.
During 2021 the committee continued to actively engage with the
bank’s key subsidiaries and key subsidiary audit committees, with
regular reporting throughout the year. The Chair of the committee
regularly meets with the Chair of the Group Audit Committee
(GAC) to help maintain connectivity with the group and develop
deeper understanding on judgements around key matters. Further,
from time to time the Chair is invited to attend meetings of the
GAC on relevant topics. The committee comprises a majority of
independent non-executive Directors. The current members are
Andrew Wright (Chair), Yukiko Omura and John Trueman.
Report of the Directors | Corporate Governance
90
HSBC Bank plc Annual Report and Accounts 2021
Significant accounting judgements and related matters considered by the Audit Committee ('AC') for the year ended 2021 included:
Key area
Action taken
Interim and annual reporting
The AC considered key matters in relation to interim and annual reporting, including changes to
segmental reporting.
Expected credit loss ('ECL')
The AC considered key judgements in relation to ECL, in particular post-model adjustments in
certain sectors due to economic uncertainty.
Valuation of financial instruments
The AC considered key valuation metrics and judgements involved in the determination of the fair
value of financial instruments. The AC also considered management’s analysis of exit losses upon
the novation of certain derivative portfolios and the determination that there was insufficient
evidence to support the introduction of fair value adjustments in respect of these.
Going concern
The AC considered a wide range of information relating to present and potential conditions,
including projections for profitability, cash flows, liquidity and capital.
Impairment of investment in subsidiaries
The AC reviewed management's periodic assessment of impairment of investments in subsidiaries
and paid particular attention to the reliability of cash flow projections and long-term growth rate
and discount rate assumptions. Management assessed that there had been no impairment of the
bank's investment in HSBC Continental Europe for the year ended 2021 with due regard to the
sensitivity of this judgement to changes in assumptions, in particular those relating to the sale of
retail banking activities in Continental Europe.
Appropriateness of provisioning for legal proceedings
and regulatory matters
The AC received reports from management on the recognition and measurement of provisions and
contingent liabilities for legal proceedings and regulatory matters, including investigations by
regulators and competition and law-enforcement authorities.
Regulatory reporting
The AC reviewed management’s efforts to strengthen and simplify the end-to-end operating and
control model, including independent external reviews of key aspects of regulatory reporting.
IBOR transition
The AC considered the implications of benchmark interest rate reform, including the recognition
and measurement of financial instruments and related disclosures.
Controls
The AC considered the financial control environment on an ongoing basis through the year,
reviewing and challenging remediation actions undertaken and enhancements made. This
included confirmation of mitigating controls where programmes of work had not fully completed
by the year end. Areas of particular focus in 2021 have been Model Risk Governance, controls
over use of external market data, accounting and tax implications of Merger and Acquisition
('M&A') transactions, general ledger substantiation and Financial Statement Disclosures.
Tax
The AC reviewed management’s judgements on the recognition and measurement of deferred tax
assets and liabilities, in particular those arising from the sale of retail banking activities in
Continental Europe, and the accounting and disclosure of retrospective VAT assessments issued
by HMRC.
Environmental, Social and Governance (‘ESG’)
Reporting
The AC considered regulatory developments in ESG Reporting, in particular at 31 December 2021
for bank subsidiaries in the European Union.
Restructuring provisions
The AC considered key judgements in relation to restructuring provisions, mainly relating to
transformation in Continental Europe and Germany.
Risk Committee
Key Responsibilities
The Risk Committee is accountable to the Board and has overall
non-executive responsibility for oversight of risk-related matters
and the risks impacting the bank.
The committee's key responsibilities include:
(i) advising the Board on risk appetite-related matters, and key
regulatory submissions;
(ii) overseeing and advising the Board on all risk-related matters,
including financial risks, non-financial risks and the effectiveness
of the bank's conduct framework;
(iii) reviewing, challenging and satisfying itself that the bank's
stress testing framework, governance and internal controls are
robust; and
(iv) to review the effectiveness of the bank's risk management
framework and internal control systems (other than internal
financial controls overseen by the Audit Committee).
Committee activities during 2021
Key matters considered by the committee during the year included
the bank’s approach to the financial and non-financial risks in the
context of evolving Covid-19 infections and strict lockdown
measures across the region, wholesale credit and market risks
including, interbank offered rates ('IBOR') transition, geopolitical,
operational and climate-related risks.
The committee also reviewed and challenged management on key
regulatory processes, including the bank’s internal capital
adequacy assessment process ('ICAAP') and the internal liquidity
adequacy assessment process ('ILAAP'); recovery and resolution
plans (including the bank's response to the Bank of England's
Resolvability Assessment Framework requirements); the outcome
of stress tests undertaken during the year; and the bank’s capital
liquidity and funding plans.
Operation of the Committee
The committee held 11 scheduled meetings during the year. The
Chief Risk Officer, Chief Financial Officer, Head of Internal Audit,
and Head of Risk Strategy are standing attendees and regularly
attend committee meetings to contribute their subject matter
expertise and insight.
The committee reviews and challenges current and forward-
looking risk issues, and the regional senior business leaders are
regularly invited to participate at committee meetings, working
together with functional and regional leaders across all three lines
of defence.
The Chair and members of the committee meet regularly with the
bank’s senior financial, risk, internal audit and compliance
management and the external auditors to consider, among other
matters, risk reports and internal audit reports and the
effectiveness of compliance activities.
During 2021 the committee continued to actively engage with the
bank’s key subsidiaries and key subsidiary risk committees, with
regular reporting from the respective Chairs throughout the year.
The Chair of the committee attended several Group-led meetings
to help promote connectivity, escalation and cascade of important
topics. The committee comprises a majority of independent non-
executive Directors. The current members are: Eric Strutz (Chair),
Juliet Robinson, John Trueman and Andrew Wright.
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91
Transformation, Operational Resilience and
Technology Committee
Key Responsibilities
The Transformation, Operational Resilience and Technology
Committee ('TRT') was established during the year to assist the
Board and Risk Committee with their respective responsibilities in
relation to the bank's transformation strategy, operational
resilience, as well as the governance and oversight of technology.
The Committee's key responsibilities include:
(i) reviewing progress of the transformation strategy and the steps
management have taken to manage risk, and to monitor progress
against set objectives;
(ii) reviewing the effectiveness of governance frameworks to set
and oversee the internal control environment in relation to
technology;
(iii) reviewing regional technology strategy, ensuring it is aligned
with the adopted business strategies of the bank; and
(iv) overseeing and challenging management on execution of
operational resilience objectives and deliverables.
Committee activities during 2021
Key matters considered by the Committee during the year
included a review of IT and Cloud strategies, oversight of the
bank’s operating systems, operational resilience and technology
infrastructure, including operational resilience of critical IT and
other business services, information and cyber security risks, and
major IT change programmes.
The Committee also reviewed and challenged management on the
progress and associated risks with respect the transformation
strategy, including transformation governance, cost complexity
and key change programmes underway.
Operation of the Committee
The Committee has been established for an initial 12-month period
from March 2021. The Board has recommended the continuation
of the Committee for the duration of 2022.
The Committee held eight scheduled meetings during 2021.
The Chief Operating Officer, Chief Information Officer, Chief Risk
Officer, Head of Internal Audit, and Head of Transformation are
standing attendees and regularly attend Committee meetings to
contribute their subject matter expertise and insight.
The current members are: Juliet Robinson (Chair), Mary Marsh,
and Eric Strutz.
Nomination, Remuneration & Governance
Committee
Key Responsibilities
The Nomination, Remuneration & Governance Committee has
responsibility for:
(i) leading the process for Board appointments and for identifying
and nominating, for the approval of the Board, candidates for
appointment to the Board;
(ii) the endorsement of the appointment of individuals to certain
Board and management positions at the bank's subsidiaries;
including proposed fees payable to non-executive Directors on
subsidiary boards;
(iii) reviewing the implementation and appropriateness of the
Group’s Director remuneration policy and the remuneration of the
bank’s senior executives, including the identification of the
Material Risk Taker population for the purposes of the Capital
Requirements Directive;
(iv) reviewing and developing the corporate governance
framework on behalf of the Board and ensuring it is consistent
with best corporate governance standards and practices while
remaining appropriate to the size, complexity and strategy of the
bank; and
(v) overseeing the implementation and compliance with the HSBC
Group Subsidiary Accountability Framework ('SAF').
Further information in relation to the HSBC’s approach to
remuneration for group employees is available in the Director’s
remuneration report on pages 276 - 278 of HSBC’s Annual Report
and Accounts available on https://www.hsbc.com/investors/
results-and-announcements/annual-report.
Committee activities during 2021
Key matters considered by the Committee during the year
included the appointment to the Board of new Directors, including
an additional independent non-executive Director, as well as a
number of senior positions within the bank's executive team,
including the Chief Financial Officer.
The Committee undertook a full review of Board composition,
succession planning for all material subsidiaries under SAF,
approval of a revised Board Diversity Policy. The Committee
applies the principles in the policy when considering the
composition of the Board, including in relation to gender, ethnicity
and age.
Other activities during the year included, the review of key
remuneration matters for the bank and its subsidiaries in the
context of the HSBC’s remuneration framework, including variable
and fixed pay allocations, aligned with the bank's risk appetite,
and in keeping with the bank's strategy, culture and values, and
long-term interests of the bank. The Committee reviewed the
annual pay review outcomes across the region.
Operation of the Committee
The Committee held eight scheduled meetings during 2021, with
additional meetings arranged to consider specific matters.
The Head of HR and Head of Performance & Reward attend
Committee meetings on a regular basis to contribute their subject
matter expertise and insight. Other senior executives attend
periodically for specific items considered by the Committee. 
The Committee comprises a majority of non-executive Directors.
The current members are: Stephen O'Connor (Chair), Eric Strutz,
Andrew Wright, and John Trueman (for Nomination and
Governance matters only).
Executive Committee
The Executive Committee is a committee of the Board and has
overall executive responsibility, under formal delegation, for the
management and day-to-day running of the bank. The committee
is accountable to the Board for overseeing the execution of the
bank’s strategy. 
The purpose of the committee is to support the Chief Executive
Officer of the bank in the performance of their duties and exercise
of their powers, authorities and discretions in relation to the
management of the bank and its subsidiaries. The committee
meets on a regular basis and is chaired by the Chief Executive
Officer.
During 2021, in addition to its day-to-day oversight of the bank's
operations, the committee's principal areas of focus included
managing the bank's response to the evolving nature of the
Covid-19 pandemic across the region, oversight of the bank's
transformation strategy, including the sale of the French retail
banking operations, oversight of the performance across the
bank's lines of business, review of the bank’s financial
performance. cost management, and preparing the bank’s forward
looking Financial Resource Plan. The committee also received
updates on regulatory remediation programmes, regulatory
engagement themes across the region and the transition to IBOR.
Dividends
Information about dividends paid during the year is provided on
page 17 of the Strategic Report and in Note 8 to the financial
statements.
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92
HSBC Bank plc Annual Report and Accounts 2021
Internal control
The Board is responsible for maintaining and reviewing the
effectiveness of risk management and internal control systems
and for determining the aggregate level and types of risks the
bank is willing to take in achieving its strategic objectives.
To meet this requirement and to discharge its obligations under
the FCA Handbook and the PRA Handbook, procedures have been
designed for safeguarding assets against unauthorised use or
disposal; for maintaining proper accounting records; and for
ensuring the reliability and usefulness of financial information used
within the business or for publication.
These procedures provide reasonable assurance against material
misstatement, errors, losses or fraud. They are designed to provide
effective internal control within the group and accord with the
Financial Reporting Council's guidance for Directors issued in
2014, internal control and related financial and business reporting.
The procedures have been in place throughout the year and up to
21 February 2022, the date of approval of this Annual Report and
Accounts 2021.
The key risk management and internal control procedures include
the following:
•Global principles: The HSBC Group's Global Principles set an
overarching standard for all other policies and procedures and
are fundamental to the Group’s risk management structure.
They inform and connect our purpose, values, strategy and risk
management principles, guiding us to do the right thing and
treat our customers and our colleagues fairly at all times.
•Risk management framework ('RMF'): The risk management
framework supports our Global Principles. It outlines the key
principles and practices that we employ in managing material
risks. It applies to all categories of risk and supports a
consistent approach in identifying, assessing, managing and
reporting the risks we accept and incur in our activities.
•Delegation of authority within limits set by the Board: Subject
to certain matters reserved for the Board, the Chief Executive
Officer has been delegated authority limits and powers within
which to manage the day-to-day affairs of the group, including
the right to sub-delegate those limits and powers. Each relevant
executive has authority within which to manage the day-to-day
affairs of the business or function for which he or she is
accountable. Those individuals are required to maintain a clear
and appropriate apportionment of significant responsibilities
and to oversee the establishment and maintenance of systems
of control that are appropriate to their business or function.
Authorities to enter into credit and market risk exposures are
delegated with limits to line management of group companies.
However, credit proposals with specified higher-risk
characteristics require the concurrence of the appropriate
global function. Credit and market risks are measured and
reported at subsidiary company level and aggregated for risk
concentration analysis on a group-wide basis.
•Risk identification and monitoring: Systems and procedures are
in place to identify, assess, control and monitor  the material
risk types facing the group as set out in the RMF.The group‘s
risk measurement and reporting systems are designed to help
ensure that material risks are captured with all the attributes
necessary to support well-founded decisions, that those
attributes are accurately assessed and that information is
delivered in a timely manner for those risks to be successfully
managed and mitigated.
•Changes in market conditions/practices: Processes are in place
to identify new risks arising from changes in market conditions/
practices or customer behaviours, which could expose the
group to heightened risk of loss or reputational damage. The
group employs a top and emerging risks framework, which
contains an aggregate of all current and forward-looking risks
and enables it to take action that either prevents them
materialising or limits their impact.
•During 2021, due to the prolonged impact of the Covid-19
pandemic on the global economy, banks continued to play an
expanded role to support society and customers. The pandemic
and its impact on the global economy have impacted many of
our customers’ business models and income, requiring
significant levels of support from both governments and banks.
To meet the additional challenges, we supplemented our
existing approach to risk management with additional tools and
practices and these continue to be in place. We continue our
focus on the quality and timeliness of the data used to inform
management decisions, through measures such as early
warning indicators, prudent active risk management of our risk
appetite, and ensuring regular communication with our Board
and other key stakeholders
•Responsibility for risk management: All employees are
responsible for identifying and managing risk within the scope
of their role as part of the three lines of defence model. This is
an activity-based model to delineate management
accountabilities and responsibilities for risk management and
the control environment. The second line of defence sets the
policy and guidelines for managing specific areas, provides
advice and guidance in relation to the risk, and challenges the
first line of defence (the risk owners) on effective risk
management.
•The Board has delegated to the Audit Committee oversight for
the implementation of the group’s policies and procedures for 
capturing and responding to whistleblower concerns, ensuring 
confidentiality, protection and fair treatment of whistleblowers,
and receiving reports arising from the operation of those
policies as well as ensuring arrangements are in place for
independent investigation.
•Strategic plans: Strategic plans are prepared for global
businesses, global functions and geographical regions within
the framework of the HSBC Group’s overall strategy. The bank
also prepares and adopts a Financial Resourcing Plan, which is
informed by detailed analysis of risk appetite, describing the
types and quantum of risk that the bank is prepared to take in
executing its strategy and sets out the key business initiatives
and the likely financial effects of those initiatives.
•The effectiveness of the group’s system of risk management
and internal control is reviewed regularly by the Board, the Risk
Committee and the Audit Committee.
•During 2021, the group continued to focus on operational
resilience and invest in the non-financial risk infrastructure.
There was a particular focus on material and emerging risks
with significant progress made enhancing the end-to-end risk
and control assessment process. The Risk Committee,
supported by the TRT, and the Audit Committee received
confirmation that executive management has taken or is taking
the necessary actions to remedy any failings or weaknesses
identified through the operation of the group's framework of
controls. In response to the prolonged Covid-19 pandemic, our
business continuity responses have been successfully
implemented and the majority of service level agreements
continue to be maintained.
Internal control over financial reporting
The key risk management and internal control procedures over
financial reporting include the following:
•Entity level controls: The primary mechanism through which
comfort over risk management and internal control systems is
achieved, is through assessments of the effectiveness of entity
level controls (‘ELCs’), and the reporting of risk and control
issues on a regular basis through the various risk management
and risk governance forums. ELCs are internal controls that
have a pervasive influence over the entity as a whole. They
include controls related to the control environment, for example
the bank's values and ethics, the promotion of effective risk
management and the overarching governance exercised by the
Board and its non-executive committees. The design and
operational effectiveness of ELCs are assessed annually as part
HSBC Bank plc Annual Report and Accounts 2021
93
of the assessment of the effectiveness of internal controls over
financial reporting. 
•Process level transactional controls: Key process level
controls that mitigate risk of financial mis-statement are
identified, recorded and monitored in accordance with the risk
framework. This includes the identification and assessment of
relevant control issues against which action plans are tracked
through to remediation. Further details on the group’s approach
to risk management can be found on page 21. The Audit
Committee has continued to receive regular updates on HSBC’s
ongoing activities for improving the effective oversight of end-
to-end business processes and management continues to
identify opportunities for enhancing key controls, such as
through the use of automation technologies.
•External Reporting Forum: The External Reporting Forum
reviews financial reporting disclosures made by the bank for
any material errors, mis-statements or omissions. The integrity
of disclosures is underpinned by structures and processes
within the group's Finance and Risk functions that support
rigorous analytical review of financial reporting and the
maintenance of proper accounting records.
•Disclosure Committee: The Disclosure Committee considers
the external reporting obligations of the bank to ensure
compliance with reporting obligations under the EU Market
Abuse Regulations.
•Financial reporting: The group’s financial reporting process is
controlled using documented accounting policies and reporting
formats, supported by detailed instructions and guidance on
reporting requirements, issued to all reporting entities within
the group in advance of each reporting period end. The
submission of financial information from each reporting entity
is supported by a certification by the responsible financial
officer and analytical review procedures at subsidiary and
group levels.
•Subsidiary certifications: Certifications are provided to the
Audit Committee and the Risk Committees (full and half yearly)
and to the Nomination, Remuneration and Governance
Committee (annually) from the audit, risk and remuneration
committees of key material subsidiary companies confirming
amongst other things that:
–Audit – the financial statements of the subsidiary have been
prepared in accordance with group policies, present fairly
the state of affairs of the subsidiary and are prepared on a
going concern basis;
–Risk – the Risk Committee of the subsidiary has carried out
its oversight activities consistent with and in alignment to
the RMF; and
–Remuneration – the Remuneration Committee of the
subsidiary has discharged its obligations in overseeing the
implementation and operation of HSBC’s Group
Remuneration Policy.
Employees
Health and safety
We are committed to providing a safe and healthy working
environment for everyone.  We have adopted global policies,
mandatory procedures, and incident and information reporting
systems across the organisation that reflect our core values and
are aligned to international standards. Our global health and safety
performance is subject to ongoing monitoring and assurance.
Our Chief Operating Officers have overall responsibility for
engendering a positive health and safety culture and ensuring that
global policies, procedures and systems are put into practice
locally. They also have responsibility for ensuring all local legal
requirements are met.
We delivered a range of programmes in 2021 to help us
understand and manage our health and safety risks:
•We continued to provide enhancements to our workplaces
globally to minimise the risks of Covid-19, including enhancing
cleaning, improved ventilation and social distancing measures
•We updated our advice and risk assessment methodology on
working from home, providing more awareness and best
practices on good ergonomics and wellbeing to be adopted as
we transitioned to new ways of working 
•We delivered health and safety training and awareness to
49,000 employees and contractors ensuring roles and
responsibilities were clear and understood
•We completed the annual safety inspection on all of our
buildings globally, subject to local Covid-19 restrictions, to
ensure we were meeting our standards and continuously 
improving our safety performance
•We continued to focus on enhancing the safety culture in our
supply chain through our SAFER Together programme,
covering the five key elements of best practice safety culture,
including speaking up about safety, and recognising excellence
•Our 2021 safety climate survey results showed a continued
high level of positive safety culture, significantly above the
industry average
•Our Eat Well Live Well programme continued educating and
informing our colleagues on how to make healthy food and
drink choices. We enhanced the programme to provide digital
educational and information resources, including a suite of
videos and recipe ideas. The programme was a key component
of HSBC's winning entry in the 2021 Global Healthy Workplace
Awards
Employee health and safety
2021
2020
2019
Number of workplace fatalities
—
—
—
Number of major injuries to employees1
2
2
3
All injury rate per 100,000 employees
14
35
130
1Fractures, dislocation, concussion, hospitalisation, unconsciousness.
Diversity and Inclusion
Our employees and the societies they represent and serve span
many cultures, communities and continents. We believe this
diversity makes us stronger, and we are dedicated to building a
diverse and connected workforce where everyone feels a sense of
belonging. In Europe, we have carried out actions to drive
improvements in representation and sentiment across multiple
diversity strands, strengthen our employee networks, and improve
our diversity data.
We set up a HBEU Diversity and Inclusion Council, including
several members from the European Executive Committee in order
to reinforce our commitments, engage more closely with our
Employee Resources Groups and track our progress.
Throughout the year, more than thirty events and conferences
were organised across several European countries on topics such
as inclusive leadership, disability, parenthood, resilience, mental
health, hypersensitivity, women in leadership, cross-generation,
multicultural working environment.
Exchange meetings to discuss key diversity topics including
ethnicity and multiculturalism took place in several countries e.g.
Germany, Malta, Italy and France.
We actively participated in the #24 hours of Pride through virtual
events and building lightening in the UK, Poland, Malta,
Luxembourg, France, Channel Islands, Ireland and Italy 
We continued to increase Employee Resources Groups (ERG)
representation across Europe. In 2021, we launched a new Pan-
European ERG called 'Inclusive Europe' aiming to create an
inclusive culture, reinforce collaboration between existing ERGs.
Our Pride ERGs in countries have gathered to create a European
structure. A new 'EmbRace' ERG has been launched in Ireland to
promote ethnic diversity and an ERG to support people with
disabilities has also been set up in France.
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HSBC Bank plc Annual Report and Accounts 2021
All our ERGs are actively involved in supporting employees locally.
Balance, our ERG dedicated to gender diversity, have run a
programme (e-Taste of the Top) to give exposure to 27 female
talent allowing them to cover a week of leave for very senior
positions. A new initiative, Coaching Circles, has been launched to
create a peer to peer coaching culture. This is available to all
employees.
In 2021, we updated our recruitment training to emphasise the
need for inclusivity, and made this mandatory for all hiring
managers. We also ran sessions for leadership teams on
'Unconcious Bias' to raise awareness of affinity bias amongst
others. In the UK, acknowledging the previous under
representation of Black and Ethnic Minority talent on our
development programmes and introducing leadership
development specifically for talented individuals in this group. In
2021, 189 colleagues at GCB 4 (mid manager) took part in our
ethnic minority Accelerate into Leadership programme and, to
date, 15% of participants have progressed in their career.
In France, HSBC has signed a charter along with other large
financial companies in order to significantly improve female
representation.
Gender diversity statistics HSBC Bank plc's overall female
representation is improving and we are committed to building a
strong pipeline of female talent to improve gender balance in
senior leadership across Europe. Our target was 24.3% of women
in senior leadership (Global Career Band 0-3) roles by the end of
2021. The outcome for 2021 was 24% of women in senior
leadership roles.
Female representation by management level:
All grades – 52.2%
GCB 6-8  Clerical grades – 65.8%
GCB 4-5  Management – 43.6%
GCB 0-3  Senior management – 24%
HBEU Executive Committee – 29.4%
Employment of people with a disability
We strongly believe in providing equal opportunities for all
employees. The employment of people with a disability is included
in this commitment. The recruitment, training, development and
promotion of people with a disability are based on the aptitudes
and abilities of the individual. Should employees become disabled
during their employments with us, efforts are made to continue
their employment. Where necessary, we will provide appropriate
training, facilities and reasonable equipment. A number of
countries have dedicated teams to ensure that barriers to work are
removed for colleagues.
Continuous work is done to ensure individual support is provided
to make home office adjustments.
Learning and talent development
The development of our people continues to be of critical
importance to our organisations success as we develop and
implement practices that identifies talent, and builds broad
employee capability, together with the right values, skills and
experience to meet the future needs of our business. This applies
across all levels of our business including the launch of our new
General Manager Curriculum in 2021 which will be followed with
the launch of a new learning curriculum for our Managing
Directors in 2022.
With the launch of our new Learning Experience Platform –
Degreed, we continue to make progress in the move to a modern
learning culture where, ‘on demand’ resources are available for
our learners to access as the need arises, driving a departure from
‘done to’, mandatory learning and moving to a self-driven learner-
led culture. We commit to continually providing opportunities for
our colleagues to develop skills and capability that empower them
to realise their potential for the future.
HSBC University remains the hub for dedicated HSBC learning and
during the year the offering was extended to provided targeted
guidance and development to help colleagues navigate through
hybrid working patterns and broader Future of Work topics. This
sits within the broader offering of HSBC Leadership, risk
management, strategy and performance, as well as business-
specific technical training all with virtual online formats.
Employee relations
We consult with and, where appropriate, negotiate with employee
representative bodies where we have them. We also aim to
maintain well-developed communications and consultation
programmes with all employee representative bodies and there
have been no material disruptions to our operations from labour
disputes during the past five years.
Disclosure of information to auditors
The directors are not aware that there is any relevant audit
information (as defined in the Companies Act 2006) of which the
bank’s auditors are unaware and processes are in place to ensure
that the bank’s auditors are aware of any relevant audit
information.
Auditors
PricewaterhouseCoopers LLP (‘PwC’) are the external auditors to
the bank. PwC has expressed its willingness to continue in office
and the Board recommends that PwC be re-appointed as the
bank’s auditors. A resolution proposing the re-appointment of
PwC as the bank’s auditors, and giving authority to the Audit
Committee to determine its remuneration, will be submitted to the
forthcoming AGM.
Branches
HSBC Bank plc provides a wide range of banking and financial
services through 20 markets. HSBC Bank plc is simplifying its
operating model to one integrated business supporting a
wholesale banking hub for the European Union ('EU') in Paris and
a wholesale banking hub for western markets in London. Further
information on the bank’s branches are located in ‘HSBC in
Europe’ on page 4.
HSBC Bank plc Annual Report and Accounts 2021
95
Disclosures required pursuant to the Large and
Medium-sized Companies and Groups (Accounts
and Reports) Regulations 2008 as updated by
Companies (Miscellaneous Reporting) Regulations
2018 can be found on the following pages:
Engagement with employees (Sch.7 Para 11 and 11A
2008/2018 Regs), s172 Statement)
Pages 9 and 10
Engagement with suppliers, customers and others in a
business relationship with the bank  (Sch.7 Para 11B
2008 Regs)
Page  9
Policy concerning the employment of disabled persons
(Sch.7 Para 10 2008 Regs)
Page 95
Financial Instruments (Sch.7 Para 6 2008 Regs)
Pages 32 to 70
Hedge accounting policy (Sch.7 Para 6 2008 Regs)
Note 14, Pages
150 to 154
Articles of Association, Conflicts of interest
and indemnification of Directors
The bank's Articles of Association gives the Board authority to
approve Directors’ conflicts and potential conflicts of interest. The
Board has adopted policies and procedures for the approval of
Directors’ conflicts or potential conflicts of interest. On
appointment, new Directors are advised of the process for dealing
with conflicts and a review of those conflicts that have been
authorised, and the terms of those authorisations, is routinely
undertaken by the Board.
The Articles of Association of the bank contain a qualifying third-
party indemnity provision, which entitles Directors and other
officers to be indemnified out of the assets of the bank against
claims from third parties in respect of certain liabilities. HSBC
Group has granted, by way of deed poll, indemnities to the
Directors, including former Directors who retired during the year,
against certain liabilities arising in connection with their position
as a Director of or of any Group company, including the bank and
its subsidiaries. Directors are indemnified to the maximum extent
permitted by law.
The indemnities that constitute a 'qualifying third-party indemnity
provision', as defined by section 234 of the Companies Act 2006,
remained in force for the whole of the financial year (or, in the
case of Directors appointed during 2020, from the date of their
appointment). The deed poll is available for inspection at the
registered office of HSBC Holdings.
Additionally, Directors have the benefit of Directors’ and Officers’
liability insurance. Qualifying pension scheme indemnities have
also been granted to the Trustees of the Group's pension schemes,
which were in force for the whole of the financial year and remain
in force as at the date of this report.
Research and Development
In the ordinary course, the lines of business develop new products
and services.
Events after the Balance Sheet Date
In its assessment of events after the balance sheet date, the group
has considered and concluded that there are no events requiring
adjustment or disclosures in the financial statements.
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96
HSBC Bank plc Annual Report and Accounts 2021
Statement on going concern
The Directors consider it appropriate to prepare the financial statements on the going concern basis. In making their going concern
assessment, the Directors have considered a wide range of detailed information relating to present and potential conditions, including
profitability, cash flows, capital requirements and capital resources.
Further information relevant to the assessment is provided in the Strategic Report and the Report of the Directors, in particular:
•a description of the group’s strategic direction;
•a summary of the group's financial performance and a review of performance by business;
•the group’s approach to capital management and its capital position; and
•the top and emerging risks facing the group, as appraised by the Directors, along with details of the group's approach to mitigating
those risks and its approach to risk management in general.
In addition, the objectives, policies and processes for managing credit, liquidity and market risk are set out in the ‘Report of the Directors:
Risk’.
The Report of the Directors comprising pages 21 to 98 was approved by the Board on 21 February 2022 and is signed on its behalf by.
By order of the Board
Dave Watts
Director
HSBC Bank plc
21 February 2022
Registered number 00014259
HSBC Bank plc Annual Report and Accounts 2021
97
Statement of directors' responsibilities in respect of the financial statements
The directors are responsible for preparing the Annual Report and the financial statements in accordance with applicable law and
regulation.
Company law requires the directors to prepare financial statements for each financial year. Under that law the directors have prepared
the group and the company financial statements in accordance with UK-adopted accounting standards, and have also applied
international financial reporting standards ('IFRSs') adopted pursuant to Regulation (EC) No 1606/2002 as it applies in the European
Union. These financial statements are also prepared in accordance with IFRSs as issued by the International Accounting Standards Board
(IASB), including interpretations issued by the IFRS Interpretations Committee, as there are no applicable differences from IFRSs as
issued by the IASB for the periods presented.
Under company law, directors must not approve the financial statements unless they are satisfied that they give a true and fair view of
the state of affairs of the group and company and of the profit or loss of the group for that period. In preparing the financial statements,
the directors are required to:
•select suitable accounting policies and then apply them consistently;
•state whether UK-adopted accounting standards, IFRSs adopted pursuant to Regulation (EC) No 1606/2002 as it applies in the
European Union and IFRSs as issued by the International Accounting Standards Board (‘IASB’), including interpretations issued by the
IFRS Interpretations Committee, have been followed, subject to any material departures disclosed and explained in the financial
statements;
•make judgements and accounting estimates that are reasonable and prudent; and
•prepare the financial statements on the going concern basis unless it is inappropriate to presume that the group and company will
continue in business.
The directors are responsible for safeguarding the assets of the group and company and hence for taking reasonable steps for the
prevention and detection of fraud and other irregularities.
The directors are also responsible for keeping adequate accounting records that are sufficient to show and explain the group’s and
company’s transactions and disclose with reasonable accuracy at any time the financial position of the group and company and enable
them to ensure that the financial statements comply with the Companies Act 2006.
The directors are responsible for the maintenance and integrity of the company’s website. Legislation in the United Kingdom governing
the preparation and dissemination of financial statements may differ from legislation in other jurisdictions.
Directors’ confirmations
The directors consider that the Annual Report and accounts, taken as a whole, is fair, balanced and understandable and provides the
information necessary for shareholders to assess the group’s and company’s position and performance, business model and strategy.
Each of the directors, whose names and functions are listed in the Corporate Governance Report confirm that, to the best of their
knowledge:
•the group and company financial statements, which have been prepared in accordance with UK-adopted accounting standards, IFRSs
adopted pursuant to Regulation (EC) No 1606/2002 as it applies in the European Union and IFRSs as issued by the International
Accounting Standards Board (‘IASB’), including interpretations issued by the IFRS Interpretations Committee, give a true and fair view
of the assets, liabilities and financial position of the group and company, and of the profit of the group; and
•the Strategic Report includes a fair review of the development and performance of the business and the position of the group and
company, together with a description of the principal risks and uncertainties that it faces.
On behalf of the Board
Dave Watts
Director
HSBC Bank plc
21 February 2022
Registered number 00014259
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HSBC Bank plc Annual Report and Accounts 2021
Independent auditors’ report to the members of HSBC Bank plc
Report on the audit of the financial statements
Opinion
In our opinion, HSBC Bank plc’s group financial statements and company financial statements (the 'financial statements'):
•give a true and fair view of the state of the group’s and of the company’s affairs as at 31 December 2021 and of the group’s profit and
the group’s and company’s cash flows for the year then ended;
•have been properly prepared in accordance with UK-adopted international accounting standards; and
•have been prepared in accordance with the requirements of the Companies Act 2006.
We have audited the financial statements, included within the HSBC Bank plc Annual Report and Accounts 2021 (the 'Annual Report'),
which comprise:
•the consolidated balance sheet as at 31 December 2021;
•the consolidated income statement and consolidated statement of comprehensive income for the year then ended;
•the consolidated statement of cash flows for the year then ended;
•the consolidated statement of changes in equity for the year then ended;
•the HSBC Bank plc balance sheet as at 31 December 2021;
•the HSBC Bank plc statement of cash flows for the year then ended;
•the HSBC Bank plc statement of changes in equity for the year then ended; and
•the notes on the financial statements, which include a description of the significant accounting policies.
Our opinion is consistent with our reporting to the Audit Committee.
Separate opinion in relation to international financial reporting standards adopted pursuant to
Regulation (EC) No 1606/2002 as it applies in the European Union
As explained in note 1.1(a) to the financial statements, the group, in addition to applying UK-adopted international accounting standards,
has also applied international financial reporting standards adopted pursuant to Regulation (EC) No 1606/2002 as it applies in the
European Union.
In our opinion, the group financial statements have been properly prepared in accordance with international financial reporting standards
adopted pursuant to Regulation (EC) No 1606/2002 as it applies in the European Union.
Separate opinion in relation to IFRSs as issued by the IASB
As explained in note 1.1(a) to the financial statements, the group, in addition to applying UK-adopted international accounting standards,
has also applied international financial reporting standards ('IFRSs') as issued by the International Accounting Standards Board ('IASB').
In our opinion, the group financial statements have been properly prepared in accordance with IFRSs as issued by the IASB.
Basis for opinion
We conducted our audit in accordance with International Standards on Auditing (UK) ('ISAs (UK)') and applicable law. Our responsibilities
under ISAs (UK) are further described in the Auditors’ responsibilities for the audit of the financial statements section of our report. We
believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
Independence
We remained independent of the group in accordance with the ethical requirements that are relevant to our audit of the financial
statements in the UK, which includes the FRC’s Ethical Standard, as applicable to listed public interest entities, and we have fulfilled our
other ethical responsibilities in accordance with these requirements.
To the best of our knowledge and belief, we declare that non-audit services prohibited by the FRC’s Ethical Standard were not provided.
Other than those disclosed in note 6, we have provided no non-audit services to the company or its controlled undertakings in the period
under audit.
Our audit approach
Overview
Audit scope
We performed audits of the complete financial information of two components, namely the UK non-ring-fenced bank and HSBC
Continental Europe (HBCE).
For five further components, specific audit procedures were performed over selected significant account balances and financial
statement note disclosures.
Key audit matters
•Expected credit losses (‘ECL’) impairment of loans and advances (group and company)
•Valuation of financial instruments (group and company)
•Recognition of deferred tax assets (group); and
•Impairment of investment in subsidiaries (company).
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Materiality
•Overall group materiality: £218 million (2020: £222 million) based on 1% of Tier 1 capital.
•Overall company materiality: £140 million (2020: £142 million) based on 1% of Tier 1 capital.
•Performance materiality: £164 million (2020: £166 million) (group) and £105 million (2020: £106 million) (company).
The scope of our audit
As part of designing our audit, we determined materiality and assessed the risks of material misstatement in the financial statements. In
particular, we looked at where the directors made subjective judgements, for example in respect of significant accounting estimates that
involved making assumptions and considering future events that are inherently uncertain.
Key audit matters
Key audit matters are those matters that, in the auditors’ professional judgement, were of most significance in the audit of the financial
statements of the current period and include the most significant assessed risks of material misstatement (whether or not due to fraud)
identified by the auditors, including those which had the greatest effect on: the overall audit strategy; the allocation of resources in the
audit; and directing the efforts of the engagement team. These matters, and any comments we make on the results of our procedures
thereon, were addressed in the context of our audit of the financial statements as a whole, and in forming our opinion thereon, and we
do not provide a separate opinion on these matters. This is not a complete list of all risks identified by our audit. Compared to last year
the number of key audit matters has reduced from six to four. The following are no longer considered to be key audit matters.
•Impact of Covid-19 (group and company) – Given the impact of Covid-19 on working practices and international travel, the majority of
our interactions continued to be undertaken virtually, including those with the partners and teams for component audit teams, and
with Board members and management. Similarly, a substantial part of our audit testing was performed remotely. We have established
practices throughout 2021 for interacting and undertaking our audit testing virtually, consistent with the hybrid working models at
both PwC and HSBC.
•The present value of in-force long-term insurance contracts ('PVIF') asset (group) – The risk is reduced due to a reduction in the
materiality of changes to judgemental assumptions resulting in lower estimation uncertainty.
•Information Technology (‘IT’) Access Management (group and company) – Management has remediated a number of the control
deficiencies in relation to IT access management.
Recognition of deferred tax assets (group) is a new key audit matter this year. The remaining three key audit matters are consistent with
last year.
Expected credit losses – Impairment of loans and advances (group and company)
Nature of the key audit matter
Determining expected credit losses (‘ECL’) involves management judgement and is subject to a high degree of estimation uncertainty. Management makes
various assumptions when estimating ECL. The significant assumptions that we focus on in our audit included those with greater levels of management
judgement and for which variations had the most significant impact on ECL. These included assumptions made in determining the following:
•forward looking economic scenarios and their probability weightings for the wholesale portfolios;
•material management judgemental adjustments;
•wholesale customer risk ratings ('CRRs'); and
•estimating expected cash flows and collateral valuations for credit impaired wholesale exposures.
The impact of Covid-19, including the nature and extent of government support, and more recent factors, including supply chain constraints and increasing
energy prices, have resulted in unprecedented economic conditions that vary between territories and industries, leading to uncertainty around judgements
made in determining the severity and probability weighting of macroeconomic variable (‘MEV’) forecasts across the different economic scenarios used in
ECL models.
The modelling methodologies used to estimate ECL are developed using historical experience. The impact of the unprecedented economic conditions has
resulted in certain limitations in the reliability of these methodologies to forecast the extent and timing of future customer defaults and therefore estimate
ECL. In addition, modelling methodologies do not incorporate all factors that are relevant to estimating ECL, such as differentiating the impact on industry
sectors of economic conditions. These limitations are addressed with management adjustments, the measurement of which is inherently judgemental and
subject to a high level of estimation uncertainty. Management makes other assumptions which are less judgemental or for which variations have a less
significant impact on ECL. These assumptions include:
•Model methodologies themselves; and
•Quantitative and qualitative criteria used to assess significant increases in credit risk.
Matters discussed with the Audit Committee
We held discussions with the Audit Committee covering governance and controls over ECL, with a significant focus on judgemental adjustments. We also
discussed a number of other areas, including:
•the severity of MEV forecasts in economics scenarios and their related probability weightings;
•management judgemental adjustments and the nature and extent of analysis used to support those adjustments;
•the criteria and conditions used to assess to what extent management judgemental adjustments continue to be needed; and
•management’s policies, governance and controls over model validation and monitoring.
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HSBC Bank plc Annual Report and Accounts 2021
How our audit addressed the Key Audit Matter
We assessed the design and effectiveness of governance and controls over the estimation of ECLs. We observed management’s review and challenge
governance forums for (1) the determination of MEV forecasts and their probability weightings for different economic scenarios, and (2) the assessment of
ECL for Wholesale portfolios, including the assessment of model limitations and approval of any resulting adjustments to modelled outcomes.
We also tested controls over:
•model validation and monitoring;
•credit reviews that determine CRRs for wholesale customers;
•the identification of credit impaired events;
•the input of critical data into source systems and the flow and transformation of critical data from source systems to the impairment models; and
•the calculation and approval of management judgemental adjustments to modelled outcomes.
We involved our economic experts to assist in assessing the reasonableness of the severity and probability weighting of MEV forecasts. These assessments
considered the sensitivity of ECLs to variations in the severity and probability weighting of MEVs for different economic scenarios. We involved our
modelling experts in assessing the appropriateness of the significant assumptions and methodologies used for models and management judgemental
adjustments. We independently reperformed the calculations for a sample of those models and management judgemental adjustments. We further
considered whether the judgements made in selecting the significant assumptions would give rise to indicators of possible management bias.
In addition, we performed substantive testing over:
•the compliance of ECL methodologies and assumptions with the requirements of IFRS 9;
•the appropriateness and application of the quantitative and qualitative criteria used to assess significant increases in credit risk;
•a sample of critical data used in the year end ECL calculation and to estimate management judgemental adjustments as at 31 December 2021;
•assumptions and critical data for a sample of credit impaired wholesale exposures; and
•a sample of CRRs applied to wholesale exposures.
We evaluated and tested the Credit Risk disclosures made in the financial statements.
Relevant references in the Annual Report and Accounts 2021
•Credit risk, page 32.
•Audit Committee, page 90.
•Note 1.2(i) Impairment of amortised cost and FVOCI financial assets, page 122
Valuation of financial instruments (group and company)
Nature of the key audit matter
The financial instruments held by the group range from those that are traded daily on active markets with quoted prices, to more complex and bespoke
positions. The valuation of these financial instruments can require the use of complex valuation models and/or prices or inputs which are not readily
observable in the market.
Where significant pricing inputs are unobservable, the financial instruments are classified as Level 3 (L3), per the IFRS 13 fair value hierarchy. Determining
unobservable inputs in fair value measurement involves management judgement and is subject to a high degree of estimation uncertainty. There is also a
risk that certain L3 portfolios are not valued appropriately due to the complexity of the trades, specifically where valuation modelling techniques result in
significant limitations or where there is greater uncertainty around the choice of an appropriate pricing methodology. 
Valuation of the L3 asset backed securities held by the Markets & Securities Services business have a significant risk attached to the valuation
methodology due to the complexity of the valuation models and lack of observable pricing inputs.
The own credit spread (OCS) adjustment for issued debt instruments held at fair value also forms part of our significant risk due to its underlying modelling
complexity as well as unobservability of the inputs.
Matters discussed with the Audit Committee
We discussed with the Audit Committee the results of our review of fair valuation adjustment methodology and the results of our substantive testing which
included independent revaluation of a range of financial instruments, including a sample of Level 3 positions.
How our audit addressed the Key Audit Matter
For fair values based on complex valuation models and significant unobservable inputs, specifically asset backed securities and issued debt instruments
held at fair value, we performed the following:
•Tested the design and operating effectiveness of key controls supporting the identification and measurement of the valuation of financial instruments,
including the independent price verification process.
•Engaged our valuation experts to perform independent revaluation of a sample of trades to determine if management’s estimates fell within a
reasonable range.
For OCS, we engaged our valuation experts to assess the methodology and underlying assumptions and compare with our knowledge of current industry
practice. Controls over the calculation of these adjustments were also tested.
We also evaluated the adequacy and extent of disclosures made in the financial statements in relation to valuation of L3 financial instruments.
Relevant references in the Annual Report and Accounts 2021
•Audit Committee, page 90.
•Note 1.2(c) Valuation of financial instruments, page 120
•Note 11: Fair values of financial instruments carried at fair value, page 140
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101
Recognition of deferred tax assets (group)
Nature of the key audit matter
Recognition of deferred tax assets ('DTAs') relies on an assessment of the availability of future taxable profits against which to recognise accumulated tax
losses.
An assessment of the recoverability of deferred tax assets was performed and deferred tax assets of £555m have been recorded in HSBC Continental
Europe ('HBCE') of which £261m relates to deductible temporary differences and £294m relates to brought forward tax losses.
As at 31 December 2021, HBCE had accumulated tax losses of £496m, of which £380m arose during 2021. Losses generated in 2019 and 2020 had not
previously been recognised on the balance sheet as DTAs given the history of HBCE taxable losses in those years. Management judgement is required
when assessing whether there is convincing other evidence of future taxable profits, including over assumptions regarding the forecast cash flows and
determination of risk adjustments to such cash flows and with regard to the timing of the reversal of temporary differences.
Management’s assessment required consideration of the impact of the disposal of the French retail business, including the impact that business, and other
one off restructuring costs, have had on historical taxable profitability as well as the impact on future taxable profits across a number of scenarios.
Significant management  judgements and assumptions have been required in determining the quantum and probability of future taxable profits.
Matters discussed with the Audit Committee
We discussed with the Audit Committee our risk assessment with respect to DTA recognition. We held discussions with the Audit Committee covering
controls over DTA and we also discussed  the results of our challenge of the key judgements and estimates being made with regard to deferred tax.
How our audit addressed the Key Audit Matter
•We tested the design and operating effectiveness of controls over deferred tax asset recognition.
•With the support of our tax specialists we assessed the viability of management’s strategy to recover deferred tax assets.
•We tested key inputs into the deferred tax recognition model, including forecast cash flows to approved plans and consistency with other judgements.
•We challenged management on their methodology and underlying assumptions in arriving at their judgements, including in relation to availability of
convincing other evidence of future taxable profits and determination of risk adjustments applied to those forecast taxable profits.
•In assessing these judgements we considered the historic taxable profits and losses and the evidence provided to support the judgement that the
criteria for recognition had been reached. We challenged the achievability of management's forecast taxable profits and assumptions made over the
future reversal of deferred tax assets and liabilities and reviewed management’s stress and scenario analyses over the likelihood of future taxable
profits.
We evaluated and tested the disclosures made in the financial statements in relation to deferred tax.
Relevant references in the Annual Report and Accounts 2021
•Audit Committee Report, page 90.
•Note 1.2(l) Tax, page 126
•Note 7: Tax, page 135
Impairment of investment in subsidiaries (company)
Nature of the key audit matter
An annual impairment indicators assessment is performed for each of the company’s investments in subsidiaries. The sale of the retail banking business in
France, for which a framework agreement was signed in November 2021, and the ongoing restructuring within the company's largest subsidiary, HSBC
Continental Europe (‘HBCE’), is considered by management to be an indicator of impairment.
An impairment test was performed for the company’s investment in HBCE using a value in use (‘VIU’) model to estimate the recoverable amount. The
recoverable amount was higher than the carrying value for this investment and therefore no impairment was recorded. The investment in HBCE amounts to
£4.3bn as at 31 December 2021.
The methodology in the VIU model is dependent on various assumptions, both short term and long term in nature. These assumptions, which are subject
to estimation uncertainty, are derived from a combination of management’s judgement, experts engaged by management and market data. The significant
assumptions that we focused our audit on were those with greater levels of management judgement and for which variations had the most significant
impact on the recoverable amount. Specifically, these included forecast cash flows for 2022 to 2026, capital requirements, long term growth rates and
discount rates.
Matters discussed with the Audit Committee
We discussed the appropriateness of methodologies used and significant assumptions with the Audit Committee, giving consideration to the group’s
strategy. We discussed the sensitivity of the impairment assessment to the key assumptions, in particular the forecast cash flows and the discount rate.
We also discussed the disclosures made in relation to investment in subsidiaries, including the use of sensitivity analysis to explain estimation uncertainty
and the conditions that would result in an impairment being recognised.
How our audit addressed the Key Audit Matter
We tested the control in place over the forecasted cash flow assumptions used to determine the recoverable amounts. We assessed the appropriateness of
the methodology used, and the mathematical accuracy of the calculations, to estimate the recoverable amounts. In respect of the significant assumptions,
our testing included the following:
•Challenging the achievability of management’s forecast cash flows;
•Obtaining and evaluating evidence where available for critical data relating to significant assumptions, from a combination of historic experience and
external market and other group financial information;
•Assessing whether the cash flows included in the model were in accordance with the relevant accounting standard;
•Assessing the sensitivity of the VIU to reasonable variations in significant assumptions, both individually and in aggregate; and
•Determining a reasonable range for the discount rate used within the model, with the assistance of our valuation experts, and comparing it to the
discount rate used by management.
We evaluated and tested the disclosures made in the financial statements in relation to investment in subsidiaries.
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HSBC Bank plc Annual Report and Accounts 2021
Relevant references in the Annual Report and Accounts 2021
•Audit Committee Report, page 90.
•Note 1.2(a) Consolidation and related policies, page 119
•Note 18: Investment in subsidiaries, page 156
How we tailored the audit scope
We performed a risk assessment, giving consideration to relevant external and internal factors, including Covid-19, climate change,
geopolitical and economic risks, relevant accounting and regulatory developments, the group’s strategy and the changes taking place
across the group.  We also considered our knowledge and experience obtained in prior year audits. As part of considering the impact of
climate change in our risk assessment, we evaluated management's assessment of the impact of climate risk including their conclusion
that there is no material impact on the financial statements. In particular, we considered management’s assessment of the impact on ECL
on loans and advances, the financial statement line item we determined to be most likely to be impacted by climate risk. Management’s
assessment gave consideration to a number of matters, including the HSBC Holdings plc climate stress testing performed in 2021.
Using our risk assessment, we tailored the scope of our audit to ensure that we performed enough work to be able to give an opinion on
the financial statements as a whole, taking into account the structure of the group and the company, the accounting processes and
controls, and the industry in which they operate.
HSBC Bank plc is structured into five divisions being Markets & Securities Services, Global Banking, GBM Other, Commercial Banking
and Wealth and Personal Banking, which are supported by a Corporate Centre. The divisions operate across a number of operations,
subsidiary entities and branches (‘components’) throughout Europe. Within the group’s main consolidation and financial reporting
system, the consolidated financial statements are an aggregation of the components. Each component submits their financial
information to the group in the form of a consolidation pack.
In establishing the overall approach to the group and company audit, we scoped using the balances included in the consolidation pack.
We determined the type of work that needed to be performed over the components by us, as the group engagement team, or auditors
within PwC UK and from other PwC network firms operating under our instruction (‘component auditors’).
As a result of our scoping, for the group we determined that audits of the complete financial information of the UK non-ring-fenced bank
('UK NRFB') and HSBC Continental Europe (HBCE) were necessary, owing to their financial significance. We instructed component
auditors, PwC UK and PwC France to perform the audits of these components. Our interactions with component auditors included
regular communication throughout the audit, including the issuance of instructions, a review of working papers relating to the key audit
matters and formal clearance meetings. The group audit engagement partner was also the partner on the audit of the UK NRFB
significant component.
We then considered the significance of other components in relation to primary statement account balances and note disclosures. In
doing this we also considered the presence of any significant audit risks and other qualitative factors (including history of misstatements
through fraud or error). For five components, specific audit procedures were performed over selected significant account balances. For
the remainder, the risk of material misstatement was mitigated through group audit procedures including testing of entity level controls
and group and company level analytical review procedures.
Certain group-level account balances were audited by the group engagement team.
Materiality
The scope of our audit was influenced by our application of materiality. We set certain quantitative thresholds for materiality. These,
together with qualitative considerations, helped us to determine the scope of our audit and the nature, timing and extent of our audit
procedures on the individual financial statement line items and disclosures and in evaluating the effect of misstatements, both
individually and in aggregate on the financial statements as a whole.
Based on our professional judgement, we determined materiality for the financial statements as a whole as follows:
 
Financial statements - group
Financial statements - company
Overall materiality
£218 million (2020: £222 million).
£140 million (2020: £142 million).
How we determined it
1% of Tier 1 capital.
1% of Tier 1 capital.
Rationale for benchmark applied
Tier 1 capital is used as a benchmark as it is considered to be a
key driver of HSBC Bank plc's decision making process and
has been a primary focus for regulators.
Tier 1 capital is used as a benchmark as it is considered to be a
key driver of HSBC Bank plc's decision making process and
has been a primary focus for regulators.
Tier 1 capital was also used as the benchmark in the prior year. The basis for determining materiality was re-evaluated and we considered
other benchmarks, such as profit before tax. Tier 1 capital is a common benchmark for wholly owned banking subsidiaries, because of
the focus on financial stability. Tier 1 capital was determined to continue to be an appropriate benchmark given the importance of this
metric to the HSBC Bank plc decision making process and to principal users of the financial statements, including the ultimate holding
company HSBC Holdings plc.
For each component in the scope of our group audit, we allocated a materiality that is less than our overall group materiality. The range
of materiality allocated across components was £9 million to £130 million. Certain components were audited to a local statutory audit
materiality that was also less than our overall group materiality.
We use performance materiality to reduce to an appropriately low level the probability that the aggregate of uncorrected and undetected
misstatements exceeds overall materiality. Specifically, we use performance materiality in determining the scope of our audit and the
nature and extent of our testing of account balances, classes of transactions and disclosures, for example in determining sample sizes.
Our performance materiality was 75% (2020: 75%) of overall materiality, amounting to £164 million (2020: £166 million) for the group
financial statements and £105 million (2020: £106 million) for the company financial statements. In determining the performance
materiality, we considered a number of factors - the history of misstatements, risk assessment and aggregation risk and the effectiveness
of controls - and concluded that an amount at the upper end of our normal range was appropriate.
We agreed with the Audit Committee that we would report to them misstatements identified during our audit above £11 million (group
audit) (2020: £7 million) and £7 million (company audit) (2020: £7 million) as well as misstatements below those amounts that, in our
view, warranted reporting for qualitative reasons.
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103
Conclusions relating to going concern
Our evaluation of the directors’ assessment of the group's and the company’s ability to continue to adopt the going concern basis of
accounting included:
•Performing a risk assessment to identify factors that could impact the going concern basis of accounting, including the impact of
external risks including Covid-19 and climate change risks.
•Understanding and evaluating the group and company’s financial forecasts and stress testing of liquidity and regulatory capital,
including the severity of the stress scenarios that were used.
•Reading and evaluating the adequacy of the disclosures made in the financial statements in relation to going concern.
Based on the work we have performed, we have not identified any material uncertainties relating to events or conditions that, individually
or collectively, may cast significant doubt on the group's and the company’s ability to continue as a going concern for a period of at least
twelve months from when the financial statements are authorised for issue.
In auditing the financial statements, we have concluded that the directors’ use of the going concern basis of accounting in the
preparation of the financial statements is appropriate.
However, because not all future events or conditions can be predicted, this conclusion is not a guarantee as to the group's and the
company's ability to continue as a going concern.
Our responsibilities and the responsibilities of the directors with respect to going concern are described in the relevant sections of this
report.
Reporting on other information
The other information comprises all of the information in the Annual Report other than the financial statements and our auditors’ report
thereon. The directors are responsible for the other information. Our opinion on the financial statements does not cover the other
information and, accordingly, we do not express an audit opinion or, except to the extent otherwise explicitly stated in this report, any
form of assurance thereon.
In connection with our audit of the financial statements, our responsibility is to read the other information and, in doing so, consider
whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the audit, or
otherwise appears to be materially misstated. If we identify an apparent material inconsistency or material misstatement, we are required
to perform procedures to conclude whether there is a material misstatement of the financial statements or a material misstatement of the
other information. If, based on the work we have performed, we conclude that there is a material misstatement of this other information,
we are required to report that fact. We have nothing to report based on these responsibilities.
With respect to the Strategic Report and Report of the Directors, we also considered whether the disclosures required by the UK
Companies Act 2006 have been included.
Based on our work undertaken in the course of the audit, the Companies Act 2006 requires us also to report certain opinions and matters
as described below.
Strategic Report and Report of the Directors
In our opinion, based on the work undertaken in the course of the audit, the information given in the Strategic Report and Report of the
Directors for the year ended 31 December 2021 is consistent with the financial statements and has been prepared in accordance with
applicable legal requirements.
In light of the knowledge and understanding of the group and company and their environment obtained in the course of the audit, we did
not identify any material misstatements in the Strategic Report and Report of the Directors.
Responsibilities for the financial statements and the audit
Responsibilities of the directors for the financial statements
As explained more fully in the Statement of directors' responsibilities in respect of the financial statements, the directors are responsible
for the preparation of the financial statements in accordance with the applicable framework and for being satisfied that they give a true
and fair view. The directors are also responsible for such internal control as they determine is necessary to enable the preparation of
financial statements that are free from material misstatement, whether due to fraud or error.
In preparing the financial statements, the directors are responsible for assessing the group’s and the company’s ability to continue as a
going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless the
directors either intend to liquidate the group or the company or to cease operations, or have no realistic alternative but to do so.
Auditors’ responsibilities for the audit of the financial statements
Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material
misstatement, whether due to fraud or error, and to issue an auditors’ report that includes our opinion. Reasonable assurance is a high
level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material
misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate,
they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.
Irregularities, including fraud, are instances of non-compliance with laws and regulations. We design procedures in line with our
responsibilities, outlined above, to detect material misstatements in respect of irregularities, including fraud. The extent to which our
procedures are capable of detecting irregularities, including fraud, is detailed below.
Based on our understanding of the group and industry, we identified that the principal risks of non-compliance with laws and regulations
related to the Financial Conduct Authority's ('FCA') regulations, the Prudential Regulation Authority's ('PRA') regulations, UK Listing
Rules, Pensions legislation, Anti-Bribery and Corruption legislation, Anti-Money Laundering legislation and UK tax legislation, and we
considered the extent to which non-compliance might have a material effect on the financial statements. We also considered those laws
and regulations that have a direct impact on the financial statements such as the Companies Act 2006. We evaluated management’s
incentives and opportunities for fraudulent manipulation of the financial statements (including the risk of override of controls), and
determined that the principal risks were related to posting inappropriate journal entries to increase revenue or reduce costs, creation of
fictitious transactions to hide losses or to improve financial performance, and management bias in accounting estimates. The group
Independent Auditors’ Report
104
HSBC Bank plc Annual Report and Accounts 2021
engagement team shared this risk assessment with the component auditors so that they could include appropriate audit procedures in
response to such risks in their work. Audit procedures performed by the group engagement team and/or component auditors included:
•Review of correspondence with and reports to the regulators, including the PRA and FCA;
•Review of reporting to the Audit Committee and Risk Committee in respect of compliance and legal matters;
•Review of a sample of legal correspondence with legal advisors;
•Enquiries of management and review of internal audit reports in so far as they related to the financial statements;
•Obtaining legal confirmations from legal advisors relating to material litigation and compliance matters;
•Challenging assumptions and judgements made by management in their significant accounting estimates, in particular in relation to
the determination of fair value for certain financial instruments, the determination of expected credit losses, impairment assessments
of investments in subsidiaries and recognition of deferred tax assets (see related key audit matters above);
•Obtaining confirmations from third parties to confirm the existence of a sample of transactions and balances; and
•Identifying and testing journal entries meeting specific fraud criteria, including those posted with certain descriptions, posted and
approved by the same individual, backdated journals or posted by infrequent and unexpected users.
There are inherent limitations in the audit procedures described above. We are less likely to become aware of instances of non-
compliance with laws and regulations that are not closely related to events and transactions reflected in the financial statements. Also,
the risk of not detecting a material misstatement due to fraud is higher than the risk of not detecting one resulting from error, as fraud
may involve deliberate concealment by, for example, forgery or intentional misrepresentations, or through collusion.
Our audit testing might include testing complete populations of certain transactions and balances, possibly using data auditing
techniques. However, it typically involves selecting a limited number of items for testing, rather than testing complete populations. We
will often seek to target particular items for testing based on their size or risk characteristics. In other cases, we will use audit sampling to
enable us to draw a conclusion about the population from which the sample is selected.
A further description of our responsibilities for the audit of the financial statements is located on the FRC’s website at: www.frc.org.uk/
auditorsresponsibilities. This description forms part of our auditors’ report.
Use of this report
This report, including the opinions, has been prepared for and only for the company’s members as a body in accordance with Chapter 3
of Part 16 of the Companies Act 2006 and for no other purpose. We do not, in giving these opinions, accept or assume responsibility for
any other purpose or to any other person to whom this report is shown or into whose hands it may come save where expressly agreed by
our prior consent in writing.
HSBC Bank plc Annual Report and Accounts 2021
105
Other required reporting
Companies Act 2006 exception reporting
Under the Companies Act 2006 we are required to report to you if, in our opinion:
•we have not obtained all the information and explanations we require for our audit; or
•adequate accounting records have not been kept by the company, or returns adequate for our audit have not been received from
branches not visited by us; or
•certain disclosures of directors’ remuneration specified by law are not made; or
•the company financial statements are not in agreement with the accounting records and returns.
We have no exceptions to report arising from this responsibility.
Appointment
Following the recommendation of the Audit Committee, we were appointed by the directors on 31 March 2015 to audit the financial
statements for the year ended 31 December 2015 and subsequent financial periods. The period of total uninterrupted engagement is
seven years, covering the years ended 31 December 2015 to 31 December 2021.
Other matter
In due course, as required by the Financial Conduct Authority Disclosure Guidance and Transparency Rule 4.1.14R, these financial
statements will form part of the ESEF-prepared annual financial report filed on the National Storage Mechanism of the Financial Conduct
Authority in accordance with the ESEF Regulatory Technical Standard (‘ESEF RTS’). This auditors’ report provides no assurance over
whether the annual financial report will be prepared using the single electronic format specified in the ESEF RTS.
Claire Sandford
(Senior Statutory Auditor)
for and on behalf of PricewaterhouseCoopers LLP
Chartered Accountants and Statutory Auditors
London
21 February 2022
Independent Auditors’ Report
106
HSBC Bank plc Annual Report and Accounts 2021
Financial statements
Page
Consolidated income statement
Consolidated statement of comprehensive income
Consolidated balance sheet
Consolidated statement of cash flows
Consolidated statement of changes in equity
HSBC Bank plc balance sheet
HSBC Bank plc statement of cash flows
HSBC Bank plc statement of changes in equity
Notes on the financial
statements
1
Basis of preparation and significant accounting policies
2
Net fee income
3
Net income from financial instruments measured at fair value
through profit or loss
4
Insurance business
5
Employee compensation and benefits
6
Auditors’ remuneration
7
Tax
8
Dividends
9
Segmental analysis
10
Trading assets
11
Fair values of financial instruments carried at fair value
12
Fair values of financial instruments not carried at fair value
13
Financial assets designated and otherwise mandatorily
measured at fair value through profit or loss
14
Derivatives
15
Financial investments
16
Assets pledged, collateral received and assets transferred
17
Interests in associates and joint ventures
18
Investments in subsidiaries
19
Structured entities
20
Goodwill and intangible assets
21
Prepayments, accrued income and other assets
22
Trading liabilities
23
Financial liabilities designated at fair value
24
Accruals, deferred income and other liabilities
25
Provisions
26
Subordinated liabilities
27
Maturity analysis of assets, liabilities and off-balance sheet
commitments
28
Offsetting of financial assets and financial liabilities
29
Called up share capital and other equity instruments
30
Contingent liabilities, contractual commitments, guarantees
and contingent assets
31
Finance lease receivables
32
Legal proceedings and regulatory matters
33
Related party transactions
34
Business disposals
35
Events after the balance sheet date
36
HSBC Bank plc’s subsidiaries, joint ventures and associates
HSBC Bank plc Annual Report and Accounts 2021
107
Consolidated income statement
for the year ended 31 December
2021
2020
Notes*
£m
£m
Net interest income
1,754
1,898
–  interest income1,2
3,149
4,086
–  interest expense3
(1,395)
(2,188)
Net fee income
2
1,413
1,400
–  fee income
2,706
2,674
–  fee expense
(1,293)
(1,274)
Net income from financial instruments held for trading or managed on a fair value basis
3
1,733
1,758
Net income from assets and liabilities of insurance businesses, including related derivatives, measured at fair value
through profit or loss
3
1,214
254
Changes in fair value of long-term debt and related derivatives
3
(8)
17
Changes in fair value of other financial instruments mandatorily measured at fair value through profit or loss
3
493
285
Gains less losses from financial investments
60
95
Net insurance premium income
4
1,906
1,559
Other operating income4
594
417
Total operating income
9,159
7,683
Net insurance claims, benefits paid and movement in liabilities to policyholders
4
(3,039)
(1,783)
Net operating income before change in expected credit losses and other credit impairment charges5
6,120
5,900
Change in expected credit losses and other credit impairment charges
174
(808)
Net operating income
6,294
5,092
Total operating expenses
(5,462)
(6,705)
–  employee compensation and benefits
5
(2,023)
(2,340)
–  general and administrative expenses
(3,265)
(3,092)
–  –  depreciation and impairment of property, plant and equipment and right of use assets
(110)
(372)
–  amortisation and impairment of intangible assets
20
(64)
(901)
Operating profit/(loss)
832
(1,613)
Share of profit/(loss) in associates and joint ventures
17
191
(1)
Profit/(loss) before tax
1,023
(1,614)
Tax credit
7
23
136
Profit/(loss) for the period
1,046
(1,478)
Profit/(loss) attributable to  the parent company
1,041
(1,488)
Profit attributable to non-controlling interests
5
10
*For Notes on the financial statements, see page 118.
1Interest income includes £1,986m (2020: £2,773m) of interest recognised on financial assets measured at amortised cost; £659m (2020: £656m)
of negative interest recognised on financial liabilities and £504m (2020: £657m) of interest recognised on financial assets measured at fair value
through other comprehensive income. Include within this is £61m (2020: £57m) interest recognised on impaired financial assets.
2Interest revenue calculated using the effective interest method comprises interest recognised on financial assets measured at either amortised
cost or fair value through other comprehensive income.
3Interest expense includes £616m (2020: £1,299m) of interest on financial liabilities, excluding interest on financial liabilities held for trading or
designated or otherwise mandatorily measured at fair value.
42021 balances include £65m gain recognised from sale of HSBC Trinkaus & Burkhardt AG’s one property which was classified as held for sale.
5Net operating income before change in expected credit losses and other credit impairment charges is also referred to as 'revenue'.
Financial statements
108
HSBC Bank plc Annual Report and Accounts 2021
Consolidated statement of comprehensive income
for the year ended 31 December
2021
2020
£m
£m
Profit/(loss) for the year
1,046
(1,478)
Other comprehensive (expense)/income
Items that will be reclassified subsequently to profit or loss when specific conditions are met:
Debt instruments at fair value through other comprehensive income
(237)
213
–  fair value (losses)/gains
(247)
366
–  fair value gains transferred to the income statement on disposal
(63)
(90)
–  expected credit (recoveries)/losses recognised in the income statement
(5)
8
–  income taxes
78
(71)
Cash flow hedges
(165)
118
–  fair value (losses)/gains
(40)
86
–  fair value (gains)/losses reclassified to the income statement
(202)
72
–  income taxes
77
(40)
Exchange differences
(603)
467
Items that will not be reclassified subsequently to profit or loss:
Remeasurement of defined benefit asset/liability
44
(8)
–  before income taxes
61
(18)
–  income taxes
(17)
10
Equity instruments designated at fair value through other comprehensive income
2
2
–  fair value gains
2
2
–  income taxes
—
—
Changes in fair value of financial liabilities designated at fair value upon initial recognition arising from changes in own credit risk
2
67
–  fair value gains
3
93
–  income taxes
(1)
(26)
Other comprehensive (expense)/income for the year, net of tax
(957)
859
Total comprehensive income/(expense) for the year
89
(619)
Attributable to:
–  shareholders of the parent company
93
(653)
–  non-controlling interests
(4)
34
Total comprehensive income/(expense) for the year
89
(619)
HSBC Bank plc Annual Report and Accounts 2021
109
Consolidated balance sheet
at 31 December
2021
2020
Notes*
£m
£m
Assets
Cash and balances at central banks
108,482
85,092
Items in the course of collection from other banks
346
243
Trading assets
10
83,706
86,976
Financial assets designated and otherwise mandatorily measured at fair value through profit or loss
13
18,649
16,220
Derivatives
14
141,221
201,210
Loans and advances to banks
10,784
12,646
Loans and advances to customers
91,177
101,491
Reverse repurchase agreements – non-trading
54,448
67,577
Financial investments
15
41,300
51,826
Prepayments, accrued income and other assets
21
43,127
55,565
Current tax assets
1,135
444
Interests in associates and joint ventures
17
743
497
Goodwill and intangible assets
20
894
766
Deferred tax assets
7
599
597
Total assets
596,611
681,150
Liabilities and equity
Liabilities
Deposits by banks
32,188
34,305
Customer accounts
205,241
195,184
Repurchase agreements – non-trading
27,259
34,903
Items in the course of transmission to other banks
489
290
Trading liabilities
22
46,433
44,229
Financial liabilities designated at fair value
23
33,608
40,792
Derivatives
14
139,368
199,232
Debt securities in issue
9,428
17,371
Accruals, deferred income and other liabilities
24
43,456
53,395
Current tax liabilities
97
139
Liabilities under insurance contracts
4
22,264
22,816
Provisions
25
562
861
Deferred tax liabilities
7
15
20
Subordinated liabilities
26
12,488
13,764
Total liabilities
572,896
657,301
Equity
Total shareholders’ equity
23,584
23,666
–  called up share capital
29
797
797
–  other equity instruments
29
3,722
3,722
–  other reserves
(5,670)
(4,682)
–  retained earnings
24,735
23,829
Non-controlling interests
131
183
Total equity
23,715
23,849
Total liabilities and equity
596,611
681,150
*    For Notes on the financial statements, see page 118.
The accompanying notes on pages 118 to 178, and the audited sections of the 'Report of the Directors' on pages 21 to 96 form an
integral part of these financial statements.
The financial statements were approved by the Board of Directors on 21 February 2022 and signed on its behalf by:
Dave Watts
Director
Financial statements
110
HSBC Bank plc Annual Report and Accounts 2021
Consolidated statement of cash flows
for the year ended 31 December
2021
2020
£m
£m
Profit/(loss) before tax
1,023
(1,614)
Adjustments for non-cash items
Depreciation, amortisation and impairment1
174
1,273
Net gain from investing activities
(62)
(99)
Share of (profit)/losses in associates and joint ventures
(191)
1
Change in expected credit losses gross of recoveries and other credit impairment charges
(171)
810
Provisions including pensions
104
424
Share-based payment expense
96
78
Other non-cash items included in profit/loss before tax
(198)
135
Elimination of exchange differences2
4,926
(2,527)
Changes in operating assets and liabilities
9,602
35,418
–  change in net trading securities and derivatives
8,157
8,070
–  change in loans and advances to banks and customers
11,149
6,780
–  change in reverse repurchase agreements – non-trading
9,538
16,084
–  change in financial assets designated and otherwise mandatorily measured at fair value
(2,429)
735
–  change in other assets
10,924
(7,513)
–  change in deposits by banks and customer accounts
7,940
28,262
–  change in repurchase agreements – non-trading
(7,643)
(14,482)
–  change in debt securities in issue
(7,943)
(7,668)
–  change in financial liabilities designated at fair value
(7,191)
(402)
–  change in other liabilities
(12,295)
5,432
–  contributions paid to defined benefit plans
(24)
(22)
–  tax paid
(581)
142
Net cash from operating activities
15,303
33,899
–  purchase of financial investments
(18,890)
(21,037)
–  proceeds from the sale and maturity of financial investments
25,027
17,417
–  net cash flows from the purchase and sale of property, plant and equipment
52
(70)
–  net investment in intangible assets
(45)
(150)
–  net cash outflow from investment in associates and acquisition of businesses and subsidiaries
(85)
(371)
–  net cash flow on disposal of subsidiaries, businesses, associates and joint ventures
—
57
Net cash from investing activities
6,059
(4,154)
–  redemption of preference shares and other equity instruments
—
(318)
–  subordinated loan capital issued
10,466
—
–  subordinated loan capital repaid3
(10,902)
(18)
–  dividends to the parent company
(194)
(263)
–  funds received from the parent company
—
1,000
–  dividends paid to non-controlling interests
(1)
—
Net cash from financing activities
(631)
401
Net increase/(decrease) in cash and cash equivalents
20,731
30,146
Cash and cash equivalents at 1 Jan
125,304
92,338
Exchange difference in respect of cash and cash equivalents
(5,112)
2,820
Cash and cash equivalents at 31 Dec4
140,923
125,304
Cash and cash equivalents comprise of
–  cash and balances at central banks
108,482
85,092
–  items in the course of collection from other banks
346
243
–  loans and advances to banks of one month or less
7,516
8,676
–  reverse repurchase agreement with banks of one month or less
17,430
21,020
–  treasury bills, other bills and certificates of deposit less than three months
235
685
–  cash collateral and net settlement accounts
7,403
9,878
–  less: items in the course of transmission to other banks
(489)
(290)
Cash and cash equivalents at 31 Dec4
140,923
125,304
1Included within 2020 are the impact of impairment and write-offs related principally to our businesses in the UK and HSBC Continental Europe
(£994m).
2Adjustment to bring changes between opening and closing balance sheet amounts to average rates. This is not done on a line-by-line basis, as
details cannot be determined without unreasonable expense.
3Subordinated liabilities changes during the year are attributable to cash flows from issuance £10,466m (2020: Nil)) and repayment of £(10,902)m
(2020: £(18)m) of securities as presented in the Consolidated statement of cash flows. Non-cash changes during the year included foreign
exchanges gains/(losses) £(512)m (2020: £351m) and fair value gains/(losses) £(82)m (2020: £69m).
4At 31 December 2021, £9,410m (2020: £11,828m) was not available for use by the group, of which £1,393m (2020: £2,460m) related to
mandatory deposits at central banks.
Interest received was £4,285m (2020: £5,424m), interest paid was £2,919m (2020: £3,725m) and dividends received were £704m (2020:
£423m).
HSBC Bank plc Annual Report and Accounts 2021
111
Consolidated statement of changes in equity
for the year ended 31 December
Other reserves
Called up
share
capital
Other
equity
instruments
Retained
earnings
Financial
assets at
FVOCI
reserve
Cash
flow
hedging
reserve
Foreign
exchange
reserve
Group
reorganisa-
tion
reserve
('GRR')4
Total
share-
holders’
equity
Non-
controlling
interests
Total
equity
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
At 1 Jan 2021
797
3,722
23,829
1,309
158
1,543
(7,692)
23,666
183
23,849
Profit for the year
—
—
1,041
—
—
—
—
1,041
5
1,046
Other comprehensive (expense)/income
(net of tax)
—
—
46
(234)
(165)
(595)
—
(948)
(9)
(957)
–  debt instruments at fair value through
other comprehensive income
—
—
—
(236)
—
—
—
(236)
(1)
(237)
–  equity instruments designated at fair 
value through other comprehensive
income
—
—
—
2
—
—
—
2
—
2
–  cash flow hedges
—
—
—
—
(165)
—
—
(165)
—
(165)
–  changes in fair value of financial
liabilities designated at fair value due to
movement in own credit risk1
—
—
2
—
—
—
—
2
—
2
–  remeasurement of defined benefit
asset/liability
—
—
44
—
—
—
—
44
—
44
–  exchange differences
—
—
—
—
—
(595)
—
(595)
(8)
(603)
Total comprehensive income/
(expense) for the year
—
—
1,087
(234)
(165)
(595)
—
93
(4)
89
Dividends to the parent company2
—
—
(194)
—
—
—
—
(194)
(1)
(195)
Net impact of equity-settled share-based
payments
—
—
(10)
—
—
—
—
(10)
—
(10)
Change in business combinations and
other movements3
—
—
23
6
—
—
—
29
(47)
(18)
At 31 Dec 2021
797
3,722
24,735
1,081
(7)
948
(7,692)
23,584
131
23,715
1At 31 December 2021, the cumulative amount of change in fair value attributable to changes in own credit risk of financial liabilities designated at
fair value was a loss of £165m. The cumulative change on 31 December 2020 was a loss of £189m.
2The dividends to the parent company are the coupons payment on additional tier 1 instruments.
3Additional shares were acquired in HSBC Trinkaus & Burkhardt AG and HSBC Bank Armenia cjsc, increasing the group’s interest to 100%.
4The Group reorganisation reserve ('GRR') is an accounting reserve resulting from the ring-fencing implementation. The GRR does not form part of
regulatory capital.
Financial statements
112
HSBC Bank plc Annual Report and Accounts 2021
Consolidated statement of changes in equity (continued)
for the year ended 31 December
Other reserves
Called up
share
capital
Other
equity
instruments
Retained
earnings
Financial
assets at
FVOCI
reserve
Cash flow
hedging
reserve
Foreign
exchange
reserve
Group
reorganisa-
tion
reserve
('GRR')
Total
share-
holders’
equity
Non-
controlling
interests
Total
equity
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
At 1 Jan 2020
797
3,722
24,449
1,089
40
1,098
(7,692)
23,503
509
24,012
Loss for the year
—
—
(1,488)
—
—
—
—
(1,488)
10
(1,478)
Other comprehensive income (net of tax)
—
—
56
216
118
445
—
835
24
859
–  debt instruments at fair value through
other comprehensive income
—
—
—
214
—
—
—
214
(1)
213
–  equity instruments designated at fair value
through other comprehensive income
—
—
—
2
—
—
—
2
—
2
–  cash flow hedges
—
—
—
—
118
—
—
118
—
118
–  changes in fair value of financial liabilities
designated at fair value due to movement
in own credit risk1
—
—
67
—
—
—
—
67
—
67
–  remeasurement of defined benefit asset/
liability
—
—
(11)
—
—
—
—
(11)
3
(8)
–  exchange differences
—
—
—
—
—
445
—
445
22
467
Total comprehensive (expense)/income for
the year
—
—
(1,432)
216
118
445
—
(653)
34
(619)
Capital securities issued during the period
—
—
—
—
—
—
—
—
—
—
Dividends to the parent company2
—
—
(263)
—
—
—
—
(263)
—
(263)
Net impact of equity-settled share-based
payments
—
—
11
—
—
—
—
11
—
11
Capital contribution3
—
—
1,000
—
—
—
—
1,000
—
1,000
Change in business combinations and other
movements4
—
—
64
4
—
—
—
68
(360)
(292)
At 31 Dec 2020
797
3,722
23,829
1,309
158
1,543
(7,692)
23,666
183
23,849
1At 31 December 2020, the cumulative amount of change in fair value attributable to changes in own credit risk of financial liabilities designated at
fair value was a loss of £189m.
2The dividends to the parent company includes, £51m on preference shares and £212m paid as coupons on additional tier 1 instruments.
3HSBC UK Holdings Limited injected £1bn of CET1 capital into HSBC Bank plc during March 2020 to improve the capital base of the group,
impacted by Covid-19. There was no new issuance of share capital.
4Additional shares were acquired in HSBC Trinkaus & Burkhardt AG in May 2020, increasing the group’s interest from 80.67% to 99.33%.
.
HSBC Bank plc Annual Report and Accounts 2021
113
HSBC Bank plc balance sheet
at 31 December
2021
2020
Notes*
£m
£m
Assets
Cash and balances at central banks
63,008
48,777
Items in the course of collection from other banks
211
37
Trading assets
10
70,790
73,035
Financial assets designated and otherwise mandatorily measured at fair value through profit or loss
13
3,215
1,865
Derivatives
14
125,787
182,066
Loans and advances to banks
6,778
8,063
Loans and advances to customers
33,936
43,241
Reverse repurchase agreements – non-trading
39,708
50,137
Financial investments
15
26,542
30,969
Prepayments, accrued income and other assets
21
31,490
38,775
Current tax assets
1,071
388
Investments in subsidiary undertakings
18
6,479
6,458
Goodwill and intangible assets
20
34
31
Deferred tax assets
7
509
549
Total assets
409,558
484,391
Liabilities and equity
Liabilities
Deposits by banks
14,655
17,484
Customer accounts
124,706
119,974
Repurchase agreements – non-trading
22,344
26,996
Items in the course of transmission to other banks
172
14
Trading liabilities
22
31,161
26,673
Financial liabilities designated at fair value
23
20,869
24,687
Derivatives
14
127,651
181,032
Debt securities in issue
5,658
15,356
Accruals, deferred income and other liabilities
24
30,170
38,571
Current tax liabilities
5
9
Provisions
25
250
413
Deferred tax liabilities
7
—
3
Subordinated liabilities
26
12,218
13,360
Total liabilities
389,859
464,572
Equity
Called up share capital
29
797
797
Other equity instruments
29
3,722
3,722
Other reserves
(5,173)
(4,799)
Retained earnings
20,353
20,099
Total equity
19,699
19,819
Total liabilities and equity
409,558
484,391
*    For Notes on the financial statements, see page 118.
Profit after tax for the year was £455m (2020: loss after tax £(644)m).
The accompanying notes on pages 118 to 178, and the audited sections of the 'Report of the Directors' on pages 21 to 96 form an
integral part of these financial statements.
The financial statements were approved by the Board of Directors on 21 February 2022 and signed on its behalf by:
Dave Watts
Director
Financial statements
114
HSBC Bank plc Annual Report and Accounts 2021
HSBC Bank plc statement of cash flows
for the year ended 31 December
2021
2020
£m
£m
Profit/(loss) before tax
273
(936)
Adjustments for non-cash items
Depreciation, amortisation and impairment1
18
635
Net (gain)/loss from investing activities
(34)
(67)
Change in expected credit losses gross of recoveries and other credit impairment charges
(216)
457
Provisions including pensions
42
154
Share-based payment expense
71
56
Other non-cash items included in profit/loss before tax
(7)
8
Elimination of exchange differences2
1,073
108
Changes in operating assets and liabilities
4,150
27,197
–  change in net trading securities and derivatives
11,761
11,580
–  change in loans and advances to banks and customers
9,712
8,568
–  change in reverse repurchase agreements – non-trading
5,651
5,890
–  change in financial assets designated and otherwise mandatorily measured at fair value
(1,350)
1,264
–  change in other assets3
4,383
(3,771)
–  change in deposits by banks and customer accounts
1,903
12,062
–  change in repurchase agreements – non-trading
(4,652)
(9,331)
–  change in debt securities in issue
(9,698)
318
–  change in financial liabilities designated at fair value
(3,831)
500
–  change in other liabilities
(9,357)
(71)
–  contributions paid to defined benefit plans
(21)
(22)
–  tax paid
(351)
210
Net cash from operating activities
5,370
27,612
–  purchase of financial investments
(15,185)
(13,882)
–  proceeds from the sale and maturity of financial investments
18,285
11,791
–  net cash flows from the purchase and sale of property, plant and equipment
(4)
(9)
–  net investment in intangible assets
(8)
(98)
Net cash from investing activities
3,088
(2,198)
–  subordinated loan capital issued
10,466
—
–  subordinated loan capital repaid4
(10,791)
(313)
–  funds received from the parent company
—
1,000
–  dividends to the parent company
(194)
(263)
Net cash from financing activities
(519)
424
Net increase/(decrease) in cash and cash equivalents
7,939
25,838
Cash and cash equivalents at 1 Jan
77,605
51,235
Exchange difference in respect of cash and cash equivalents
(1,730)
532
Cash and cash equivalents at 31 Dec
83,814
77,605
Cash and cash equivalents comprise of:
–  cash and balances at central banks
63,008
48,777
–  items in the course of collection from other banks
211
37
–  loans and advances to banks of one month or less
4,323
5,338
–  reverse repurchase agreement with banks of one month or less
9,779
14,558
–  treasury bills, other bills and certificates of deposit less than three months
175
279
–  cash collateral and net settlement accounts
6,490
8,630
–  less: items in the course of transmission to other banks
(172)
(14)
Cash and cash equivalents at 31 Dec
83,814
77,605
1Included within 2020 is the impact of impairment related to our business in the UK (£531m).
2Adjustment to bring changes between opening and closing balance sheet amounts to average rates. This is not done on a line-by-line basis, as
details cannot be determined without unreasonable expense.
3Includes additional investment in subsidiaries £17m (2020: £443m).
4Subordinated liabilities changes during the year are attributable to cash flows from issuance £10,466m (2020: Nil) and repayment of £(10,791)m
(2020: £(313)m) of securities as presented in the HSBC Bank plc statement of cash flows. Non-cash changes during the year included foreign
exchanges gains(losses) £(489)m (2020: £329m) and fair value gains £(82)m (2020: £69m).
Interest received was £2,321m (2020: £3,211m), interest paid was £1,827m (2020: £2,539m) and dividends received was £902m (2020:
£555m).
HSBC Bank plc Annual Report and Accounts 2021
115
HSBC Bank plc statement of changes in equity
for the year ended 31 December
Other reserves
Called up
share
capital
Other
equity
instruments
Retained
earnings
Financial
assets at
FVOCI
reserve
Cash flow
hedging
reserve
Foreign
exchange
reserve
Group
reorganisation
reserve
(‘GRR’)4
Total
shareholders’
equity
£m
£m
£m
£m
£m
£m
£m
£m
At 1 Jan 2021
797
3,722
20,099
351
55
43
(5,248)
19,819
Profit for the year
—
—
455
—
—
—
—
455
Other comprehensive (expense)/income (net
of tax)
—
—
14
(216)
(137)
(21)
—
(360)
–  debt instruments at fair value through other
comprehensive income
—
—
—
(215)
—
—
—
(215)
–  equity instruments designated at fair value
through other comprehensive income
—
—
—
(1)
—
—
—
(1)
–  cash flow hedges
—
—
—
—
(137)
—
—
(137)
–  changes in fair value of financial liabilities
designated at fair value due to movement
in own credit risk1
—
—
—
—
—
—
—
—
–  remeasurement of defined benefit asset/
liability
—
—
14
—
—
—
—
14
–  exchange differences
—
—
—
—
—
(21)
—
(21)
Total comprehensive income/(expense)
for the period
—
—
469
(216)
(137)
(21)
—
95
Dividends to the parent company2
—
—
(194)
—
—
—
—
(194)
Net impact of equity-settled share-based
—
—
(10)
—
—
—
—
(10)
Change in business combinations and other
movements3
—
—
(11)
—
—
—
—
(11)
At 31 Dec 2021
797
3,722
20,353
135
(82)
22
(5,248)
19,699
1At 31 December 2021, the cumulative amount of change in fair value attributable to changes in own credit risk of financial liabilities designated at
fair value was a loss of £72m. The cumulative change on 31 December 2020 was a loss of £76m.
2  The dividends to the parent company are the coupons payment on additional tier 1 instruments.
3Additional shares were acquired in HSBC Trinkaus & Burkhardt AG in Feb 2021, increasing the group’s interest from 99.33% to 100.00%.
4The Group reorganisation reserve ('GRR') is an accounting reserve resulting from the ring-fencing implementation. The GRR does not form part of
regulatory capital.
Financial statements
116
HSBC Bank plc Annual Report and Accounts 2021
HSBC Bank plc statement of changes in equity (continued)
for the year ended 31 December
Other reserves
Called up
share capital
Other equity
instruments
Retained
earnings
Financial
assets at
FVOCI
reserve
Cash flow
hedging
reserve
Foreign
exchange
reserve
Group
reorganisation
reserve
(‘GRR’)
Total
shareholders'
equity
£m
£m
£m
£m
£m
£m
£m
£m
1 January 2020
797
3,722
19,876
182
(32)
77
(5,248)
19,374
Loss for the year
—
—
(644)
—
—
—
—
(644)
Other comprehensive income/(expense) (net of
tax)
—
—
107
170
87
(28)
—
336
–  debt instruments at fair value through other
comprehensive income
—
—
—
168
—
—
—
168
–  equity instruments designated at fair value
through other comprehensive income
—
—
—
2
—
—
—
2
–  cash flow hedges
—
—
—
—
87
—
—
87
–  changes in fair value of financial liabilities
designated at fair value due to movement in
own credit risk1
—
—
92
—
—
—
—
92
–  remeasurement of defined benefit asset/
liability
—
—
15
—
—
—
—
15
–  exchange differences
—
—
—
—
—
(28)
—
(28)
Total comprehensive (expense)/income for the
period
—
—
(537)
170
87
(28)
—
(308)
Capital securities issued during the period
—
—
—
—
—
—
—
—
Dividends to the parent company2
—
—
(263)
—
—
—
—
(263)
Net impact of equity-settled share-based
payments
—
—
11
—
—
—
—
11
Capital contribution3
—
—
1,000
—
—
—
—
1,000
Change in business combinations and other
movements4
—
—
12
(1)
—
(6)
—
5
At 31 Dec 2020
797
3,722
20,099
351
55
43
(5,248)
19,819
1At 31 December 2020, the cumulative amount of change in fair value attributable to changes in own credit risk of financial liabilities designated at
fair value was a loss of £76m.
2The dividends to the parent company includes £51m on preference shares and £212m paid as coupons on additional tier 1 instruments.
3HSBC UK Holdings Limited injected £1bn of CET1 capital into HSBC Bank plc during March 2020 to improve the capital base of the group,
impacted by Covid-19. There was no new issuance of share capital.
4Additional shares were acquired in HSBC Trinkaus & Burkhardt AG in May 2020, increasing the group’s interest from 80.67% to 99.33%.
HSBC Bank plc Annual Report and Accounts 2021
117
Notes on the Financial Statements
1
Basis of preparation and significant accounting policies
1.1Basis of preparation
(a)Compliance with International Financial Reporting Standards
The consolidated financial statements of the group and the separate financial statements of HSBC Bank plc comply with UK-adopted
international accounting standards and with the requirements of the Companies Act 2006, and have also applied international financial
reporting standards adopted pursuant to Regulation (EC) No 1606/2002 as it applies in the European Union. These financial statements
are also prepared in accordance with International Financial Reporting Standards ('IFRSs') as issued by the International Accounting
Standards Board (‘IASB’), including interpretations issued by the IFRS Interpretations Committee, as there are no applicable differences
from IFRSs as issued by the IASB for the periods presented. There were no unendorsed standards effective for the year ended
31 December 2021 affecting these consolidated and separate financial statements.
Standards adopted during the year ended 31 December 2021
There were no new accounting standards or interpretations that had a significant effect on the group in 2021. Accounting policies have
been consistently applied.
(b)Future accounting developments
Minor amendments to IFRSs
The IASB has not published any minor amendments effective from 1 January 2021 that are applicable to the group. However, the IASB
has published a number of minor amendments to IFRSs that are effective from 1 January 2022 and 1 January 2023. The group expects
they will have an insignificant effect, when adopted, on the consolidated financial statements of the group and the separate financial
statements of HSBC Bank plc.
New IFRSs
IFRS 17 ‘Insurance Contracts’
IFRS 17 ‘Insurance Contracts’ was issued in May 2017, with amendments to the standard issued in June 2020. The standard sets out the
requirements that an entity should apply in accounting for insurance contracts it issues and reinsurance contracts it holds. Following the
amendments, IFRS 17 is effective from 1 January 2023. The standard has been endorsed for use in the EU but has not yet been
endorsed for use in the UK. The group is in the process of implementing IFRS 17. Industry practice and interpretation of the standard are
still developing. Therefore, the likely financial impact of its implementation remains uncertain. However, we have the following
expectations as to the impact compared with our current accounting policy for insurance contracts, which is set out in policy 1.2(j)
below:
•Under IFRS 17, there will be no present value of in-force business ('PVIF') asset recognised. Instead the estimated future profit will be
included in the measurement of the insurance contract liability as the contractual service margin ('CSM'), representing unearned
profit, and this will be gradually recognised in revenue as services are provided over the duration of the insurance contract. While the
profit over the life of an individual contract will be unchanged, its emergence will be later under IFRS 17. The removal of the PVIF
asset and the recognition of CSM, which is a liability, will reduce equity. The PVIF asset will be eliminated to equity on transition,
together with other adjustments to assets and liabilities to reflect IFRS 17 measurement requirements and any consequential
amendments to financial assets in the scope of IFRS 9.
•IFRS 17 requires increased use of current market values in the measurement of insurance liabilities. Changes in market conditions for
certain products measured under the general measurement approach are immediately recognised in profit or loss, while changes in
market conditions for other products measured under the variable fee approach are included in the measurement of CSM.
•In accordance with IFRS 17, directly attributable costs will be incorporated in the CSM and recognised in the results of insurance
services as a reduction in reported revenue, as profit is recognised over the duration of insurance contracts. Costs that are not directly
attributable remain in operating expenses. This will result in a reduction in reported operating expenses compared with the current
accounting policy.
•We intend to provide an update on the likely financial impacts in later 2022 financial reports, when we expect that this will be
reasonably estimable.
(c)Foreign currencies
The functional currency of the bank is sterling, which is also the presentational currency of the consolidated financial statements of the
group.
Transactions in foreign currencies are recorded at the rate of exchange on the date of the transaction. Assets and liabilities denominated
in foreign currencies are translated at the rate of exchange at the balance sheet date except non-monetary assets and liabilities
measured at historical cost, which are translated using the rate of exchange at the initial transaction date. Exchange differences are
included in other comprehensive income or in the income statement depending on where the gain or loss on the underlying item is
recognised.
In the consolidated financial statements, the assets and liabilities of branches, subsidiaries, joint ventures and associates whose
functional currency is not sterling are translated into the group’s presentation currency at the rate of exchange at the balance sheet date,
while their results are translated into sterling at the average rates of exchange for the reporting period. Exchange differences arising are
recognised in other comprehensive income. On disposal of a foreign operation, exchange differences previously recognised in other
comprehensive income are reclassified to the income statement.
(d)    Presentation of information
Certain disclosures required by IFRSs have been included in the audited sections of this Annual Report and Accounts 2021 as follows:
•disclosures concerning the nature and extent of risks relating to financial instruments and insurance contracts are included in the
'Report of the Directors: Risk’ on pages 21 to 87;
Notes on the Financial Statements
118
HSBC Bank plc Annual Report and Accounts 2021
•the 'Own funds' disclosure is included in the ‘Report of the Directors: Capital Risk in 2021’ on page 73; and
•in publishing the parent company financial statements together with the group financial statements, the bank has taken advantage of
the exemption in section 408(3) of the Companies Act 2006 not to present its individual income statement and related notes.
(e)Critical accounting estimates and judgements
The preparation of financial information requires the use of estimates and judgements about future conditions. In view of the inherent
uncertainties and the high level of subjectivity involved in the recognition or measurement of items highlighted, as the 'critical
accounting estimates and judgements' in section 1.2 below, it is possible that the outcomes in the next financial year could differ from
those on which management’s estimates are based. This could result in materially different estimates and judgements from those
reached by management for the purposes of these financial statements. Management’s selection of the group’s accounting policies that
contain critical estimates and judgements reflects the materiality of the items to which the policies are applied and the high degree of
judgement and estimation uncertainty involved.
(f)Segmental analysis
HSBC Bank plc's chief operating decision maker is the group Chief Executive, supported by the group Executive Committee, and
operating segments are reported in a manner consistent with the internal reporting provided to the group Chief Executive and the group
Executive Committee.
Measurement of segmental assets, liabilities, income and expenses is in accordance with the bank’s accounting policies. Segmental
income and expenses include transfers between segments and these transfers are conducted at arm’s length. Shared costs are
included in segments on the basis of the actual recharges made.
The types of products and services from which each reportable segment derives its revenue are discussed in the ‘Strategic Report –
Our global businesses’ on page 6.
(g)Going concern
The financial statements are prepared on a going concern basis, as the Directors are satisfied that the group and the company have the
resources to continue in business for the foreseeable future. In making this assessment, the Directors have considered a wide range of
information relating to present and future conditions, including future projections of profitability, cash flows, capital requirements and
capital resources. These considerations include stressed scenarios that reflect the uncertainty that the global Covid-19 pandemic has
had on the group’s operations, as well as considering potential impacts from other top and emerging risks, and the related impact on
profitability, capital and liquidity.
1.2Summary of significant accounting policies
(a)Consolidation and related policies
Investments in subsidiaries
Where an entity is governed by voting rights, the group consolidates when it holds – directly or indirectly – the necessary voting rights to
pass resolutions by the governing body. In all other cases, the assessment of control is more complex and requires judgement of other
factors, including having exposure to variability of returns, power to direct relevant activities and whether power is held as agent or
principal.
Business combinations are accounted for using the acquisition method. The amount of non-controlling interest is measured either at fair
value or at the non-controlling interest’s proportionate share of the acquiree’s identifiable net assets.
The bank's investments in subsidiaries are stated at cost less impairment losses.
Critical accounting estimates and judgements
Investments in subsidiaries are tested for impairment when there is an indication that the investment may be impaired, which involves estimations of value
in use reflecting management’s best estimate of the future cash flows of the investment and the rates used to discount these cash flows, both of which are
subject to uncertain factors as follows:
Judgements
Estimates
•The accuracy of forecast cash flows is subject to a
high degree of uncertainty in volatile market
conditions. Where such circumstances are
determined to exist, management re-tests for
impairment more frequently than once a year when
indicators of impairment exist. This ensures that the
assumptions on which the cash flow forecasts are
based continue to reflect current market conditions
and management's best estimate of future business
prospects
•The future cash flows of each investment are sensitive to the cash flows projected for the
periods for which detailed forecasts are available and to assumptions regarding the long-term
pattern of sustainable cash flows thereafter. Forecasts are compared with actual performance
and verifiable economic data, but they reflect management’s view of future business prospects
at the time of the assessment
•The rates used to discount future expected cash flows can have a significant effect on their
valuation, and are based on the costs of equity assigned to the investment. The cost of equity
percentage is generally derived from a capital asset pricing model and the market implied cost
of equity, which incorporates inputs reflecting a number of financial and economic variables,
including the risk-free interest rate in the country concerned and a premium for the risk of the
business being evaluated. These variables are subject to fluctuations in external market rates
and economic conditions beyond management’s control
•Key assumptions used in estimating impairment in subsidiaries are described in Note 18
Group sponsored structured entities
The group is considered to sponsor another entity if, in addition to ongoing involvement with the entity, it had a key role in establishing
that entity or in bringing together relevant counterparties so the transaction that is the purpose of the entity could occur. The group is
generally not considered a sponsor if the only involvement with the entity is merely administrative.
Interests in associates and joint arrangements
Joint arrangements are investments in which the group, together with one or more parties, has joint control. Depending on the group’s
rights and obligations, the joint arrangement is classified as either a joint operation or a joint venture. The group classifies investments in
entities over which it has significant influence, and those that are neither subsidiaries nor joint arrangements, as associates.
HSBC Bank plc Annual Report and Accounts 2021
119
The group recognises its share of the assets, liabilities and results in a joint operation. Investments in associates and interests in joint
ventures are recognised using the equity method. The attributable share of the results and reserves of joint ventures and associates are
included in the consolidated financial statements of the group based on either financial statements made up to 31 December or pro-
rated amounts adjusted for any material transactions or events occurring between the date the financial statements are available and
31 December.
Investments in associates and joint ventures are assessed at each reporting date and tested for impairment when there is an indication
that the investment may be impaired. Goodwill on acquisition of interests in joint ventures and associates is not tested separately for
impairment, but is assessed as part of the carrying amount of the investment.
(b)Income and expense
Operating income
Interest income and expense
Interest income and expense for all financial instruments, excluding those classified as held for trading or designated at fair value, are
recognised in ‘Interest income’ and ‘Interest expense’ in the income statement using the effective interest method. However, as an
exception to this, interest on debt instruments issued by the group for funding purposes that are designated under the fair value option
to reduce an accounting mismatch and on derivatives managed in conjunction with those debt instruments is included in interest
expense.
Interest on credit-impaired financial assets is recognised using the rate of interest used to discount the future cash flows for the purpose
of measuring the impairment loss.
Non-interest income and expense
The group generates fee income from services provided at a fixed price over time, such as account service and card fees, or when the
group delivers a specific transaction at a point in time, such as broking services and import/export services. With the exception of certain
fund management and performance fees, all other fees are generated at a fixed price. Fund management and performance fees can be
variable depending on the size of the customer portfolio and HSBC’s performance as fund manager. Variable fees are recognised when
all uncertainties are resolved. Fee income is generally earned from short-term contracts with payment terms that do not include a
significant financing component.
The group acts as principal in the majority of contracts with customers, with the exception of broking services. For most brokerage
trades, the group acts as agent in the transaction and recognises broking income net of fees payable to other parties in the arrangement.
The group recognises fees earned on transaction-based arrangements at a point in time when it has fully provided the service to the
customer. Where the contract requires services to be provided over time, income is recognised on a systematic basis over the life of the
agreement. Where the group offers a package of services that contains multiple non-distinct performance obligations, such as those
included in account service packages, the promised services are treated as a single performance obligation. If a package of services
contains distinct performance obligations, such as those including both account and insurance services, the corresponding transaction
price is allocated to each performance obligation based on the estimated stand-alone selling prices.
Dividend income is recognised when the right to receive payment is established. This is the ex-dividend date for listed equity securities,
and usually the date when shareholders approve the dividend for unlisted equity securities.
Net income/(expense) from financial instruments measured at fair value through profit or loss includes the following:
•‘Net income from financial instruments held for trading or managed on a fair value basis’: This comprises net trading income, which
includes all gains and losses from changes in the fair value of financial assets and financial liabilities held for trading and other
financial instruments managed on a fair value basis, together with the related interest income, expense and dividends, excluding the
effect of changes in the credit risk of liabilities managed on a fair value basis. It also includes all gains and losses from changes in the
fair value of derivatives that are managed in conjunction with financial assets and liabilities measured at fair value through profit or
loss.
•‘Net income/(expense) from assets and liabilities of insurance businesses, including related derivatives, measured at fair value
through profit or loss’: This includes interest income, interest expense and dividend income in respect of financial assets and liabilities
measured at fair value through profit or loss; and those derivatives managed in conjunction with the above that can be separately
identifiable from other trading derivatives.
•‘Changes in fair value of designated debt instruments and related derivatives’: Interest paid on the debt instruments and interest cash
flows on related derivatives is presented in interest expense where doing so reduces and accounting mismatch.
•‘Changes in fair value of other financial instruments mandatorily measured at fair value through profit or loss’: This includes interest
on instruments that fail the solely payments of principal and interest (‘SPPI’) test, see (d) below.
The accounting policies for insurance premium income are disclosed in Note 1.2(j).
(c)Valuation of financial instruments
All financial instruments are initially recognised 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. The fair value of a financial instrument
on initial recognition is generally its transaction price (that is, the fair value of the consideration given or received). However, if there is a
difference between the transaction price and the fair value of financial instruments whose fair value is based on a quoted price in an
active market or a valuation technique that uses only data from observable markets, the group recognises the difference as a trading
gain or loss at inception (a ‘day 1 gain or loss’). In all other cases, the entire day 1 gain or loss is deferred and recognised in the income
statement over the life of the transaction either until the transaction matures or is closed out or the valuation inputs become observable.
The fair value of financial instruments is generally measured on an individual basis. However, in cases where the group manages a
group of financial assets and liabilities according to its net market or credit risk exposure, the fair value of the group of financial
instruments is measured on a net basis but the underlying financial assets and liabilities are presented separately in the financial
statements, unless they satisfy the IFRS offsetting criteria. Financial instruments are classified into one of three fair value hierarchy
levels, described in Note 11, ‘Fair values of financial instruments carried at fair value'.
Notes on the Financial Statements
120
HSBC Bank plc Annual Report and Accounts 2021
Critical accounting estimates and judgements
The majority of valuation techniques employ only observable market data. However, certain financial instruments are classified on the basis of valuation
techniques that feature one or more significant market inputs that are unobservable, and for them, the measurement of fair value is more judgemental:
Judgements
Estimates
•An instrument in its entirety is classified as valued using significant unobservable inputs
if, in the opinion of management, a significant proportion of the instrument’s inception
profit or greater than 5% of the instrument’s valuation is driven by unobservable inputs
•‘Unobservable’ in this context means that there is little or no current market data
available from which to determine the price at which an arm’s length transaction would
be likely to occur. It generally does not mean that there is no data available at all upon
which to base a determination of fair value (consensus pricing data may, for example,
be used)
•Details on the group’s level 3 financial instruments and the
sensitivity of their valuation to the effect of applying
reasonable possible alternative assumptions in
determining their fair value are set out in Note 11
(d)Financial instruments measured at amortised cost
Financial assets that are held to collect the contractual cash flows and which contain contractual terms that give rise on specified dates
to cash flows that are solely payments of principal and interest are measured at amortised cost. Such financial assets include most loans
and advances to banks and customers and some debt securities. In addition, most financial liabilities are measured at amortised cost.
The group accounts for regular way amortised cost financial instruments using trade date accounting. The carrying value of these
financial assets at initial recognition includes any directly attributable transactions costs.
The group may commit to underwriting loans on fixed contractual terms for specified periods of time. When the loan arising from the
lending commitment is expected to be held for trading, the commitment to lend is recorded as a derivative. When the group intends
to hold the loan, the loan commitment is included in the impairment calculations set out below.
Non-trading reverse repurchase, repurchase and similar agreements
When debt securities are sold subject to a commitment to repurchase them at a predetermined price (‘repos’), they remain on the
balance sheet and a liability is recorded in respect of the consideration received. Securities purchased under commitments to resell
(‘reverse repos’) are not recognised on the balance sheet and an asset is recorded in respect of the initial consideration paid. Non-trading
repos and reverse repos are measured at amortised cost. The difference between the sale and repurchase price or between the purchase
and resale price is treated as interest and recognised in net interest income over the life of the agreement.
Contracts that are economically equivalent to reverse repo or repo agreements (such as sales or purchases of debt securities entered
into together with total return swaps with the same counterparty) are accounted for similarly to, and presented together with, reverse
repo or repo agreements.
(e)Financial assets measured at fair value through other comprehensive income
Financial assets held for a business model that is achieved by both collecting contractual cash flows and selling and which contain
contractual terms that give rise on specified dates to cash flows that are solely payments of principal and interest are measured at fair
value through other comprehensive income (‘FVOCI’). These comprise primarily debt securities. They are recognised on the trade date
when HSBC enters into contractual arrangements to purchase and are normally derecognised when they are either sold or redeemed.
They are subsequently remeasured at fair value and changes therein (except for those relating to impairment, interest income and
foreign currency exchange gains and losses) are recognised in other comprehensive income until the assets are sold. Upon disposal, the
cumulative gains or losses in other comprehensive income are recognised in the income statement as ‘Gains less losses from financial
instruments’. Financial assets measured at FVOCI are included in the impairment calculations set out below and impairment is
recognised in profit or loss.
(f)Equity securities measured at fair value with fair value movements presented in other comprehensive income
The equity securities for which fair value movements are shown in other comprehensive income are business facilitation and other
similar investments where HSBC holds the investments other than to generate a capital return. Gains or losses on the derecognition of
these equity securities are not transferred to profit or loss. Otherwise, equity securities are measured at fair value through profit or loss
(except for dividend income, which is recognised in profit or loss).
(g)Financial instruments designated at fair value through profit or loss
Financial instruments, other than those held for trading, are classified in this category if they meet one or more of the criteria set out
below and are so designated irrevocably at inception:
•the use of the designation removes or significantly reduces an accounting mismatch;
•a group of financial assets and liabilities or a group of financial liabilities is managed and its performance is evaluated on a fair value
basis, in accordance with a documented risk management or investment strategy; and
•the financial liability contains one or more non-closely related embedded derivatives.
Designated financial assets are recognised when HSBC enters into contracts with counterparties, which is generally on trade date, and
are normally derecognised when the rights to the cash flows expire or are transferred. Designated financial liabilities are recognised
when HSBC enters into contracts with counterparties, which is generally on settlement date, and are normally derecognised when
extinguished. Subsequent changes in fair values are recognised in the income statement in ‘Net income from financial instruments held
for trading or managed on a fair value basis’ or ‘Net income/(expense) from assets and liabilities of insurance businesses, including
related derivatives, measured at fair value through profit or loss’ except for the effect of changes in the liabilities' credit risk, which is
presented in 'Other comprehensive income', unless that treatment would create or enlarge an accounting mismatch in profit or loss.
Under the above criterion, the main classes of financial instruments designated by HSBC are:
•Debt instruments for funding purposes that are designated to reduce an accounting mismatch: The interest and/or foreign exchange
exposure on certain fixed-rate debt securities issued has been matched with the interest and/or foreign exchange exposure on certain
swaps as part of a documented risk management strategy.
•Financial assets and financial liabilities under unit-linked and non-linked investment contracts: A contract under which HSBC does not
accept significant insurance risk from another party is not classified as an insurance contract, other than investment contracts with
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discretionary participation features (‘DPF’), but is accounted for as a financial liability. Customer liabilities under linked and certain
non-linked investment contracts issued by insurance subsidiaries are determined based on the fair value of the assets held in the
linked funds. If no fair value designation was made for the related assets, at least some of the assets would otherwise be measured at
either fair value through other comprehensive income or amortised cost. The related financial assets and liabilities are managed and
reported to management on a fair value basis. Designation at fair value of the financial assets and related liabilities allows changes in
fair values to be recorded in the income statement and presented in the same line.
•Financial liabilities that contain both deposit and derivative components: These financial liabilities are managed and their performance
evaluated on a fair value basis.
(h)Derivatives
Derivatives are financial instruments that derive their value from the price of underlying items such as equities, interest rates or other
indices. Derivatives are recognised initially and are subsequently measured at fair value through profit or loss, with changes in fair value
generally recorded in the income statement. Derivatives are classified as assets when their fair value is positive or as liabilities when
their fair value is negative. This includes embedded derivatives in financial liabilities, which are bifurcated from the host contract when
they meet the definition of a derivative on a stand-alone basis. Where the derivatives are managed with debt securities issued by HSBC
that are designated at fair value, the contractual interest is shown in ‘Interest expense’ together with the interest payable on the issued
debt.
Hedge accounting
When derivatives are not part of fair value designated relationships, if held for risk management purposes they are designated in hedge
accounting relationships where the required criteria for documentation and hedge effectiveness are met. The group uses these
derivatives or, where allowed, other non-derivative hedging instruments in fair value hedges, cash flow hedges or hedges of net
investments in foreign operations as appropriate to the risk being hedged.
Fair value hedge
Fair value hedge accounting does not change the recording of gains and losses on derivatives and other hedging instruments, but
results in recognising changes in the fair value of the hedged assets or liabilities attributable to the hedged risk that would not otherwise
be recognised in the income statement. If a hedge relationship no longer meets the criteria for hedge accounting, hedge accounting is
discontinued and the cumulative adjustment to the carrying amount of the hedged item is amortised to the income statement on a
recalculated effective interest rate, unless the hedged item has been derecognised, in which case it is recognised in the income
statement immediately.
Cash flow hedge
The effective portion of gains and losses on hedging instruments is recognised in other comprehensive income and the ineffective
portion of the change in fair value of derivative hedging instruments that are part of a cash flow hedge relationship is recognised
immediately in the income statement within ‘Net trading income’. The accumulated gains and losses recognised in other comprehensive
income are reclassified to the income statement in the same periods in which the hedged item affects profit or loss. When a hedge
relationship is discontinued, or partially discontinued, any cumulative gain or loss recognised in other comprehensive income remains in
equity until the forecast transaction is recognised in the income statement. When a forecast transaction is no longer expected to occur,
the cumulative gain or loss previously recognised in other comprehensive income is immediately reclassified to the income statement.
Derivatives that do not qualify for hedge accounting
Non-qualifying hedges are derivatives entered into as economic hedges of assets and liabilities for which hedge accounting was not
applied.
(i)Impairment of amortised cost and FVOCI financial assets
Expected credit losses are recognised for loans and advances to banks and customers, non-trading reverse repurchase agreements,
other financial assets held at amortised cost, debt instruments measured at FVOCI, and certain loan commitments and financial
guarantee contracts. At initial recognition, allowance (or provision in the case of some loan commitments and financial guarantees) is
required for ECL resulting from default events that are possible within the next 12 months, or less, where the remaining life is less than
12 months, (’12-month ECL’). In the event of a significant increase in credit risk, allowance (or provision) is required for ECL resulting
from all possible default events over the expected life of the financial instrument (‘lifetime ECL’). Financial assets where 12-month ECL is
recognised are considered to be ‘stage 1’; financial assets which are considered to have experienced a significant increase in credit risk
are in ‘stage 2’; and financial assets for which there is objective evidence of impairment so are considered to be in default or otherwise
credit impaired are in ‘stage 3’. Purchased or originated credit-impaired financial assets ('POCI') are treated differently as set out below.
Credit impaired (stage 3)
The group determines that a financial instrument is credit impaired and in stage 3 by considering relevant objective evidence, primarily
whether:
•contractual payments of either principal or interest are past due for more than 90 days;
•there are other indications that the borrower is unlikely to pay, such as when a concession has been granted to the borrower for
economic or legal reasons relating to the borrower’s financial condition; and
•the loan is otherwise considered to be in default.
If such unlikeliness to pay is not identified at an earlier stage, it is deemed to occur when an exposure is 90 days past due, even where
regulatory rules permit default to be defined based on 180 days past due. Therefore, the definitions of credit impaired and default are
aligned as far as possible so that stage 3 represents all loans that are considered defaulted or otherwise credit impaired.
Interest income is recognised by applying the effective interest rate to the amortised cost amount, i.e. gross carrying amount less
ECL allowance.
Write-off
Financial assets (and the related impairment allowances) are normally written off, either partially or in full, when there is no realistic
prospect of recovery. Where loans are secured, this is generally after receipt of any proceeds from the realisation of security. In
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HSBC Bank plc Annual Report and Accounts 2021
circumstances where the net realisable value of any collateral has been determined and there is no reasonable expectation of further
recovery, write-off may be earlier.
Renegotiation
Loans are identified as renegotiated and classified as credit impaired when we modify the contractual payment terms due to significant
credit distress of the borrower. Renegotiated loans remain classified as credit impaired until there is sufficient evidence to demonstrate a
significant reduction in the risk of non-payment of future cash flows and retain the designation of renegotiated until maturity or
derecognition.
A loan that is renegotiated is derecognised if the existing agreement is cancelled and a new agreement is made on substantially different
terms or if the terms of an existing agreement are modified such that the renegotiated loan is a substantially different financial
instrument. Any new loans that arise following derecognition events in these circumstances are considered to be POCI and will continue
to be disclosed as renegotiated loans.
Other than originated credit-impaired loans, all other modified loans could be transferred out of stage 3 if they no longer exhibit any
evidence of being credit impaired and, in the case of renegotiated loans, there is sufficient evidence to demonstrate a significant
reduction in the risk of non-payment of future cash flows, over the minimum observation period, and there are no other indicators of
impairment. These loans could be transferred to stage 1 or 2 based on the mechanism as described below by comparing the risk of a
default occurring at the reporting date (based on the modified contractual terms) and the risk of a default occurring at initial recognition
(based on the original, unmodified contractual terms). Any amount written off as a result of the modification of contractual terms would
not be reversed.
Loan modifications other than renegotiated loans
Loan modifications that are not identified as renegotiated are considered to be commercial restructuring. Where a commercial
restructuring results in a modification (whether legalised through an amendment to the existing terms or the issuance of a new loan
contract) such that HSBC’s rights to the cash flows under the original contract have expired, the old loan is derecognised and the new
loan is recognised at fair value. The rights to cash flows are generally considered to have expired if the commercial restructure is at
market rates and no payment-related concession has been provided. Mandatory and general offer loan modifications that are not
borrower-specific, for example market-wide customer relief programmes, have not been classified as renegotiated loans and generally
have not resulted in derecognition, but their stage allocation is determined considering all available and supportable information under
our ECL impairment policy. Changes made to these financial instruments that are economically equivalent and required by interest rate
benchmark reform do not result in the derecognition or a change in the carrying amount of the financial instrument, but instead require
the effective interest rate to be updated to reflect the change of the interest rate benchmark.
Significant increase in credit risk (stage 2)
An assessment of whether credit risk has increased significantly since initial recognition is performed at each reporting period by
considering the change in the risk of default occurring over the remaining life of the financial instrument. The assessment explicitly or
implicitly compares the risk of default occurring at the reporting date compared with that at initial recognition, taking into account
reasonable and supportable information, including information about past events, current conditions and future economic conditions.
The assessment is unbiased, probability-weighted, and to the extent relevant, uses forward-looking information consistent with that
used in the measurement of ECL. The analysis of credit risk is multifactor. The determination of whether a specific factor is relevant and
its weight compared with other factors depends on the type of product, the characteristics of the financial instrument and the borrower,
and the geographical region. Therefore, it is not possible to provide a single set of criteria that will determine what is considered to be a
significant increase in credit risk and these criteria will differ for different types of lending, particularly between retail and wholesale.
However, unless identified at an earlier stage, all financial assets are deemed to have suffered a significant increase in credit risk when
30 days past due. In addition, wholesale loans that are individually assessed, which are typically corporate and commercial customers,
and included on a watch or worry list, are included in stage 2.
For wholesale portfolios, the quantitative comparison assesses default risk using a lifetime probability of default ('PD'), which
encompasses a wide range of information including the obligor’s customer risk rating (‘CRR’), macroeconomic condition forecasts and
credit transition probabilities. For origination CRRs up to 3.3, significant increase in credit risk is measured by comparing the average PD
for the remaining term estimated at origination with the equivalent estimation at reporting date. The quantitative measure of significance
varies depending on the credit quality at origination as follows:
Origination CRR
Significance trigger – PD to increase by
0.1-1.2
15bps
2.1-3.3
30bps
For CRRs greater than 3.3 that are not impaired, a significant increase in credit risk is considered to have occurred when the origination
PD has doubled. The significance of changes in PD was informed by expert credit risk judgement, referenced to historical credit
migrations and to relative changes in external market rates.
For loans originated prior to the implementation of IFRS 9, the origination PD does not include adjustments to reflect expectations of
future macroeconomic conditions since these are not available without the use of hindsight. In the absence of this data, origination PD
must be approximated assuming through-the-cycle PDs and through-the-cycle migration probabilities, consistent with the instrument’s
underlying modelling approach and the CRR at origination. For these loans, the quantitative comparison is supplemented with additional
CRR deterioration-based thresholds, as set out in the table below:
Origination CRR
Additional significance criteria – Number of CRR grade notches deterioration
required to identify as significant credit deterioration (stage 2) (> or equal to)
0.1
5 notches
1.1–4.2
4 notches
4.3–5.1
3 notches
5.2–7.1
2 notches
7.2–8.2
1 notch
8.3
0 notch
Further information about the 23-grade scale used for CRR can be found on page 32.
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For certain portfolios of debt securities where external market ratings are available and credit ratings are not used in credit risk
management, the debt securities will be in stage 2 if their credit risk increases to the extent they are no longer considered investment
grade. Investment grade is where the financial instrument has a low risk of incurring losses, the structure has a strong capacity to meet
its contractual cash flow obligations in the near term and adverse changes in economic and business conditions in the longer term may,
but will not necessarily, reduce the ability of the borrower to fulfil their contractual cash flow obligations.
For retail portfolios, default risk is assessed using a reporting date 12-month PD derived from credit scores, which incorporates all
available information about the customer. This PD is adjusted for the effect of macroeconomic forecasts for periods longer than
12 months and is considered to be a reasonable approximation of a lifetime PD measure. Retail exposures are first segmented into
homogeneous portfolios, generally by country, product and brand. Within each portfolio, the stage 2 accounts are defined as accounts
with an adjusted 12-month PD greater than the average 12-month PD of loans in that portfolio 12 months before they become 30 days
past due. The expert credit risk judgement is that no prior increase in credit risk is significant. This portfolio-specific threshold identifies
loans with a PD higher than would be expected from loans that are performing as originally expected, and higher than what would have
been acceptable at origination. It therefore approximates a comparison of origination to reporting date PDs.
Unimpaired and without significant increase in credit risk (stage 1)
ECL resulting from default events that are possible within the next 12 months (’12-month ECL’) are recognised for financial instruments
that remain in stage 1.
Purchased or originated credit impaired
Financial assets that are purchased or originated at a deep discount that reflects the incurred credit losses are considered to be POCI.
This population includes the recognition of a new financial instrument following a renegotiation where concessions have been granted
for economic or contractual reasons relating to the borrower’s financial difficulty that otherwise would not have been considered. The
amount of change-in-lifetime ECL is recognised in profit or loss until the POCI is derecognised, even if the lifetime ECL are less than the
amount of ECL included in the estimated cash flows on initial recognition.
Movement between stages
Financial assets can be transferred between the different categories (other than POCI) depending on their relative increase in credit risk
since initial recognition. Financial instruments are transferred out of stage 2 if their credit risk is no longer considered to be significantly
increased since initial recognition based on the assessments described above. Except for renegotiated loans, financial instruments are
transferred out of stage 3 when they no longer exhibit any evidence of credit impairment as described above. Renegotiated loans that
are not POCI will continue to be in stage 3 until there is sufficient evidence to demonstrate a significant reduction in the risk of non-
payment of future cash flows, observed over a minimum one-year period and there are no other indicators of impairment. For loans that
are assessed for impairment on a portfolio basis, the evidence typically comprises a history of payment performance against the original
or revised terms, as appropriate to the circumstances. For loans that are assessed for impairment on an individual basis, all available
evidence is assessed on a case-by-case basis.
Measurement of ECL
The assessment of credit risk and the estimation of ECL are unbiased and probability-weighted, and incorporate all available information
that is relevant to the assessment including information about past events, current conditions and reasonable and supportable forecasts
of future events and economic conditions at the reporting date. In addition, the estimation of ECL should take into account the time
value of money.
In general, HSBC calculates ECL using three main components, a probability of default, a loss given default ('LGD') and the exposure at
default (‘EAD’).
The 12-month ECL is calculated by multiplying the 12-month PD, LGD and EAD. Lifetime ECL is calculated using the lifetime PD instead.
The 12-month and lifetime PDs represent the probability of default occurring over the next 12 months and the remaining maturity of the
instrument respectively.
The EAD represents the expected balance at default, taking into account the repayment of principal and interest from the balance sheet
date to the default event together with any expected drawdowns of committed facilities. The LGD represents expected losses on the
EAD given the event of default, taking into account, among other attributes, the mitigating effect of collateral value at the time it is
expected to be realised and the time value of money.
HSBC makes use of the Basel II IRB framework where possible, with recalibration to meet the differing IFRS 9 requirements as set out in
the following table:
Model
Regulatory capital
IFRS 9
PD
•Through the cycle (represents long-run average PD throughout a
full economic cycle)
•The definition of default includes a backstop of 90+ days past due,
although this has been modified to 180+ days past due for some
portfolios, particularly UK and US mortgages
•Point in time (based on current conditions, adjusted to take
into account estimates of future conditions that will impact
PD)
•Default backstop of 90+ days past due for all portfolios
EAD
•Cannot be lower than current balance
•Amortisation captured for term products
LGD
•Downturn LGD (consistent losses expected to be suffered during a
severe but plausible economic downturn)
•Regulatory floors may apply to mitigate risk of underestimating
downturn LGD due to lack of historical data
•Discounted using cost of capital
•All collection costs included
•Expected LGD (based on estimate of loss given default
including the expected impact of future economic conditions
such as changes in value of collateral)
•No floors
•Discounted using the original effective interest rate of the loan
•Only costs associated with obtaining/selling collateral included
Other
•Discounted back from point of default to balance sheet date
While 12-month PDs are recalibrated from Basel II models where possible, the lifetime PDs are determined by projecting the 12-month
PD using a term structure. For the wholesale methodology, the lifetime PD also takes into account credit migration, i.e. a customer
migrating through the CRR bands over its life.
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HSBC Bank plc Annual Report and Accounts 2021
The ECL for wholesale stage 3 is determined on an individual basis using a discounted cash flow (‘DCF’) methodology. The expected
future cash flows are based on the credit risk officer’s estimates as at the reporting date, reflecting reasonable and supportable
assumptions and projections of future recoveries and expected future receipts of interest. Collateral is taken into account if it is likely
that the recovery of the outstanding amount will include realisation of collateral based on its estimated fair value of collateral at the time
of expected realisation, less costs for obtaining and selling the collateral. The cash flows are discounted at a reasonable approximation
of the original effective interest rate. For significant cases, cash flows under four different scenarios are probability-weighted by
reference to the economic scenarios applied more generally by HSBC Group and the judgement of the credit risk officer in relation to the
likelihood of the workout strategy succeeding or receivership being required. For less significant cases, the effect of different economic
scenarios and work-out strategies is approximated and applied as an adjustment to the most likely outcome.
Period over which ECL is measured
Expected credit loss is measured from the initial recognition of the financial asset. The maximum period considered when measuring
ECL (be it 12-month or lifetime ECL) is the maximum contractual period over which HSBC is exposed to credit risk. For wholesale
overdrafts, credit risk management actions are taken no less frequently than on an annual basis and therefore this period is to the
expected date of the next substantive credit review. The date of the substantive credit review also represents the initial recognition of
the new facility.
However, where the financial instrument includes both a drawn and undrawn commitment and the contractual ability to demand
repayment and cancel the undrawn commitment does not serve to limit HSBC’s exposure to credit risk to the contractual notice period,
the contractual period does not determine the maximum period considered. Instead, ECL is measured over the period HSBC remains
exposed to credit risk that is not mitigated by credit risk management actions. This applies to retail overdrafts and credit cards, where
the period is the average time taken for stage 2 exposures to default or close as performing accounts, determined on a portfolio basis
and ranging from between two and six years. In addition, for these facilities it is not possible to identify the ECL on the loan commitment
component separately from the financial asset component. As a result, the total ECL is recognised in the loss allowance for the financial
asset unless the total ECL exceeds the gross carrying amount of the financial asset, in which case the ECL is recognised as a provision.
Forward-looking economic inputs
HSBC applies multiple forward-looking global economic scenarios determined with reference to external forecast distributions
representative of its view of forecast economic conditions. This approach is considered sufficient to calculate unbiased expected loss in
most economic environments. In certain economic environments, additional analysis may be necessary and may result in additional
scenarios or adjustments, to reflect a range of possible economic outcomes sufficient for an unbiased estimate. The detailed
methodology is disclosed in 'Measurement uncertainty and sensitivity analysis of ECL estimates' on page 41.
Critical accounting estimates and judgements
The calculation of the group’s ECL under IFRS 9 requires the group to make a number of judgements, assumptions and estimates. The most significant are
set out below:
Judgements
Estimates
•Defining what is considered to be a significant increase in credit risk
•Selecting and calibrating the PD, LGD and EAD models, which support the calculations,
including making reasonable and supportable judgements about how models react to current
and future economic conditions
•Selecting model inputs and economic forecasts, including determining whether sufficient and
appropriately weighted economic forecasts are incorporated to calculate unbiased expected
loss
•Making management judgemental adjustments to account for late breaking events, model and
data limitations and deficiencies, and expert credit judgements
•The section ‘Measurement uncertainty and
sensitivity analysis of ECL estimates’, marked as
audited from page 41 sets out the assumptions used
in determining ECL, and provides an indication of
the sensitivity of the result to the application of
different weightings being applied to different
economic assumptions
(j)    Insurance contracts
A contract is classified as an insurance contract where the group accepts significant insurance risk from another party by agreeing to
compensate that party on the occurrence of a specified uncertain future event. An insurance contract may also transfer financial risk, but
is accounted for as an insurance contract if the insurance risk is significant. In addition, the group issues investment contracts with
discretionary participation features ('DPF') which are also accounted for as insurance contracts as required by IFRS 4 ‘Insurance
Contracts’.
Net insurance premium income
Premiums for life insurance contracts are accounted for when receivable, except in unit-linked insurance contracts where premiums are
accounted for when liabilities are established.
Reinsurance premiums are accounted for in the same accounting period as the premiums for the direct insurance contracts to which
they relate.
Net insurance claims and benefits paid and movements in liabilities to policyholders
Gross insurance claims for life insurance contracts reflect the total cost of claims arising during the year, including claim handling costs
and any policyholder bonuses allocated in anticipation of a bonus declaration.
Maturity claims are recognised when due for payment. Surrenders are recognised when paid or at an earlier date on which, following
notification, the policy ceases to be included within the calculation of the related insurance liabilities. Death claims are recognised when
notified.
Reinsurance recoveries are accounted for in the same period as the related claim.
Liabilities under insurance contracts
Liabilities under non-linked life insurance contracts are calculated by each life insurance operation based on local actuarial principles.
Liabilities under unit-linked life insurance contracts are at least equivalent to the surrender or transfer value, which is calculated by
reference to the value of the relevant underlying funds or indices.
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125
Future profit participation on insurance contracts with DPF
Where contracts provide discretionary profit participation benefits to policyholders, liabilities for these contracts include provisions for
the future discretionary benefits to policyholders. These provisions reflect the actual performance of the investment portfolio to date and
management’s expectation of the future performance of the assets backing the contracts, as well as other experience factors such as
mortality, lapses and operational efficiency, where appropriate. The benefits to policyholders may be determined by the contractual
terms, regulation or past distribution policy.
Investment contracts with DPF
While investment contracts with DPF are financial instruments, they continue to be treated as insurance contracts as required by IFRS 4.
The group therefore recognises the premiums for these contracts as revenue and recognises as an expense the resulting increase in the
carrying amount of the liability.
In the case of net unrealised investment gains on these contracts, whose discretionary benefits principally reflect the actual performance
of the investment portfolio, the corresponding increase in the liabilities is recognised in either the income statement or other
comprehensive income, following the treatment of the unrealised gains on the relevant assets. In the case of net unrealised losses, a
deferred participating asset is recognised only to the extent that its recoverability is highly probable. Movements in the liabilities arising
from realised gains and losses on relevant assets are recognised in the income statement.
Present value of in-force long-term insurance business
The group recognises the value placed on insurance contracts, and investment contracts with DPF, that are classified as long-term and
in-force at the balance sheet date, as an asset. The asset represents the present value of the equity holders’ interest in the issuing
insurance companies’ profits expected to emerge from these contracts written at the balance sheet date. The present value of
in-force long-term insurance business (‘PVIF’) is determined by discounting those expected future profits using appropriate assumptions
in assessing factors such as future mortality, lapse rates and levels of expenses, and a risk discount rate that reflects the risk premium
attributable to the respective contracts. The PVIF incorporates allowances for both non-market risk and the value of financial options and
guarantees. The PVIF asset is presented gross of attributable tax in the balance sheet and movements in the PVIF asset are included in
‘Other operating income’ on a gross of tax basis.
(k)Employee compensation and benefits
Share-based payments
The group enters into both equity-settled and cash-settled share-based payment arrangements with its employees as compensation for
the provision of their services. The vesting period for these schemes may commence before the legal grant date if the employees have
started to render services in respect of the award before the legal grant date, where there is a shared understanding of the terms and
conditions of the arrangement. Expenses are recognised when the employee starts to render service to which the award relates.
Cancellations result from the failure to meet a non-vesting condition during the vesting period, and are treated as an acceleration of
vesting recognised immediately in the income statement. Failure to meet a vesting condition by the employee is not treated as a
cancellation, and the amount of expense recognised for the award is adjusted to reflect the number of awards expected to vest.
Post-employment benefit plans
The group operates a number of pension schemes including defined benefit, defined contribution and post-employment benefit
schemes.
Payments to defined contribution schemes are charged as an expense as the employees render service.
Defined benefit pension obligations are calculated using the projected unit credit method. The net charge to the income statement
mainly comprises the service cost and the net interest on the net defined benefit asset or liability, and is presented in operating
expenses.
Remeasurements of the net defined benefit asset or liability, which comprise actuarial gains and losses, return on plan assets (excluding
interest) and the effect of the asset ceiling (if any, excluding interest), are recognised immediately in other comprehensive income. The
net defined benefit asset or liability represents the present value of defined benefit obligations reduced by the fair value of plan assets,
after applying the asset ceiling test, where the net defined benefit surplus is limited to the present value of available refunds and
reductions in future contributions to the plan.
The cost of obligations arising from other post-employment plans are accounted for on the same basis as defined benefit pension plans.
(l)    Tax
Income tax comprises current tax and deferred tax. Income tax is recognised in the income statement except to the extent that it relates
to items recognised in other comprehensive income or directly in equity, in which case the tax is recognised in the same statement in
which the related item appears.
Current tax is the tax expected to be payable on the taxable profit for the year and on any adjustment to tax payable in respect of
previous years. The group provides for potential current tax liabilities that may arise on the basis of the amounts expected to be paid to
the tax authorities. Payments associated with any incremental base erosion and anti-abuse tax are reflected in tax expense in the period
incurred.
Deferred tax is recognised on temporary differences between the carrying amounts of assets and liabilities in the balance sheet, and the
amounts attributed to such assets and liabilities for tax purposes. Deferred tax is calculated using the tax rates expected to apply in the
periods as the assets will be realised or the liabilities settled.
Current and deferred tax are calculated based on tax rates and laws enacted, or substantively enacted, by the balance sheet date.
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HSBC Bank plc Annual Report and Accounts 2021
Critical accounting judgements
The recognition of deferred tax assets depends on judgements
Judgements
•In assessing the probability and sufficiency of future taxable profit, we consider the availability of evidence to support the recognition of deferred tax
assets. taking into account the inherent risk in long term forecasting and drivers of recent history of tax losses where applicable, taking into account the
future reversal of existing taxable temporary differences and tax planning strategies including corporate reorganisations. Specific judgements
supporting deferred tax assets are described in Note 7.
(m)Provisions, contingent liabilities and guarantees
Provisions
Provisions are recognised when it is probable that an outflow of economic benefits will be required to settle a present legal or
constructive obligation that has arisen as a result of past events and for which a reliable estimate can be made.
Critical accounting estimates and judgements
The recognition and measurement of provisions requires the group to make a number of judgements, assumptions and estimates. The most significant are
set out below:
Judgements
Estimates
•Determining whether a present obligation exists. Professional advice is
taken on the assessment of litigation and similar obligations
•Provisions for legal proceedings and regulatory matters typically require
a higher degree of judgement than other types of provisions. When
matters are at an early stage, accounting judgements can be difficult
because of the high degree of uncertainty associated with determining
whether a present obligation exists, and estimating the probability and
amount of any outflows that may arise. As matters progress,
management and legal advisers evaluate on an ongoing basis whether
provisions should be recognised, revising previous estimates as
appropriate. At more advanced stages, it is typically easier to make
estimates around a better defined set of possible outcomes
•Provisions for legal proceedings and regulatory matters remain very
sensitive to the assumptions used in the estimate. There could be a wider
range of possible outcomes for any pending legal proceedings,
investigations or inquiries. As a result, it is often not practicable to
quantify a range of possible outcomes for individual matters. It is also not
practicable to meaningfully quantify ranges of potential outcomes in
aggregate for these types of provisions because of the diverse nature and
circumstances of such matters and the wide range of uncertainties
involved
Contingent liabilities, contractual commitments and guarantees
Contingent liabilities
Contingent liabilities, which include certain guarantees and letters of credit pledged as collateral security, and contingent liabilities
related to legal proceedings or regulatory matters, are not recognised in the financial statements but are disclosed unless the probability
of settlement is remote.
Financial guarantee contracts
Liabilities under financial guarantee contracts that are not classified as insurance contracts are recorded initially at their fair value, which
is generally the fee received or present value of the fee receivable.
The bank has issued financial guarantees and similar contracts to other group entities. The group elects to account for certain
guarantees as insurance contracts in the bank’s financial statements, in which case they are measured and recognised as insurance
liabilities. This election is made on a contract by contract basis, and is irrevocable.
(n)Impairment of non-financial assets
Software under development is tested for impairment at least annually. Other non-financial assets are property, plant and equipment,
intangible assets (excluding goodwill) and right-of-use assets. They are tested for impairment at the individual asset level when there is
indication of impairment at that level, or at the CGU level for assets that do not have a recoverable amount at the individual asset level.
In addition, impairment is also tested at the CGU level when there is indication of impairment at that level. For this purpose, CGUs are
considered to be the principal operating legal entities divided by global business.
Impairment testing compares the carrying amount of the non-financial asset or CGU with its recoverable amount, which is the higher of
the fair value less costs of disposal or the value in use. The carrying amount of a CGU comprises the carrying value of its assets and
liabilities, including non-financial assets that are directly attributable to it and non-financial assets that can be allocated to it on a
reasonable and consistent basis. Non-financial assets that cannot be allocated to an individual CGU are tested for impairment at an
appropriate grouping of CGUs. The recoverable amount of the CGU is the higher of the fair value less costs of disposal of the CGU,
which is determined by independent and qualified valuers where relevant, and the value in use, which is calculated based on appropriate
inputs. When the recoverable amount of a CGU is less than its carrying amount, an impairment loss is recognised in the income
statement to the extent that the impairment can be allocated on a pro-rata basis to the non-financial assets by reducing their carrying
amounts to the higher of their respective individual recoverable amount or nil. Impairment is not allocated to the financial assets in a
CGU.
Impairment loss recognised in prior periods for non-financial assets is reversed when there has been a change in the estimate used to
determine the recoverable amount. The impairment loss is reversed to the extent that the carrying amount of the non-financial assets
would not exceed the amount that would have been determined (net of amortisation or depreciation) had no impairment loss been
recognised in prior periods.
HSBC Bank plc Annual Report and Accounts 2021
127
2
Net fee income
Net fee income by product type
2021
2020
£m
£m
Account services
271
239
Funds under management
465
424
Cards
44
44
Credit facilities
246
250
Broking income
368
369
Unit trusts
5
3
Imports/exports
40
41
Remittances
84
62
Underwriting
286
360
Global custody
200
220
Insurance agency commission
17
19
Other
680
643
Fee income
2,706
2,674
Less: fee expense
(1,293)
(1,274)
Net fee income
1,413
1,400
Net fee income by global business
MSS
GB
GBM
Other
CMB
WPB
Corporate
Centre
Total
£m
£m
£m
£m
£m
£m
£m
Year ended 31 Dec 2021
Fee income
1,251
861
89
415
633
(543)
2,706
Less: fee expense
(1,245)
(188)
(83)
(54)
(255)
532
(1,293)
Net fee income
6
673
6
361
378
(11)
1,413
Year ended 31 Dec 20201
Fee income
1,243
857
94
407
603
(530)
2,674
Less: fee expense
(1,209)
(172)
(123)
(51)
(245)
526
(1,274)
Net fee income
34
685
(29)
356
358
(4)
1,400
1    A change in reportable segments was made in 2021. Comparatives data have been re-presented accordingly. For further guidance, refer to   
Note 9: Segmental Analysis on page 138
Net fee income includes £935m of fees earned on financial assets that are not at fair value through profit or loss (other than amounts
included in determining the effective interest rate) (2020: £883m), £221m of fees payable on financial liabilities that are not at fair value
through profit of loss (other than amounts included in determining the effective interest rate) (2020: £176m), £709m of fees earned on
trust and other fiduciary activities (2020: £688m), and £61m of fees payable relating to trust and other fiduciary activities (2020: £68m).
3
Net income from financial instruments measured at fair value through profit or
loss
2021
2020
£m
£m
Net income arising on:
Net Trading activities
3
1,948
Other instruments managed on a fair value basis
1,730
(190)
Net income from financial instruments held for trading or managed on a fair value basis
1,733
1,758
Financial assets held to meet liabilities under insurance and investment contracts
1,305
290
Liabilities to customers under investment contracts
(91)
(36)
Net income from assets and liabilities of insurance businesses, including related derivatives, measured at fair
value through profit or loss
1,214
254
Derivatives managed in conjunction with the group's issued debt securities
(337)
112
Other changes in fair value
329
(95)
Changes in fair value of designated debt and related derivatives
(8)
17
Changes in fair value of other financial instruments mandatorily measured at fair value through profit or loss
493
285
Year ended 31 Dec
3,432
2,314
Notes on the Financial Statements
128
HSBC Bank plc Annual Report and Accounts 2021
4
Insurance business
.
Net insurance premium income
Non-linked
insurance
Linked life
insurance
Investment contracts
with DPF1
Total
£m
£m
£m
£m
Gross insurance premium income
218
429
1,360
2,007
Reinsurers’ share of gross insurance premium income
(100)
(1)
—
(101)
Year ended 31 Dec 2021
118
428
1,360
1,906
Gross insurance premium income
205
274
1,185
1,664
Reinsurers’ share of gross insurance premium income
(100)
(5)
—
(105)
Year ended 31 Dec 2020
105
269
1,185
1,559
1Discretionary participation features.
Net insurance claims and benefits paid and movement in liabilities to policyholders
Non-linked
insurance
Linked life
insurance
Investment contracts
with DPF1
Total
£m
£m
£m
£m
Gross claims and benefits paid and movement in liabilities
120
550
2,420
3,090
–  claims, benefits and surrenders paid
126
106
1,554
1,786
–  movement in liabilities
(6)
444
866
1,304
Reinsurers’ share of claims and benefits paid and movement in liabilities
(45)
(6)
—
(51)
–  claims, benefits and surrenders paid
(68)
(1)
—
(69)
–  movement in liabilities
23
(5)
—
18
Year ended 31 Dec 2021
75
544
2,420
3,039
Gross claims and benefits paid and movement in liabilities
143
300
1,404
1,847
–  claims, benefits and surrenders paid
102
93
1,578
1,773
–  movement in liabilities
41
207
(174)
74
Reinsurers’ share of claims and benefits paid and movement in liabilities
(64)
—
—
(64)
–  claims, benefits and surrenders paid
(62)
(3)
—
(65)
–  movement in liabilities
(2)
3
—
1
Year ended 31 Dec 2020
79
300
1,404
1,783
1Discretionary participation features.
Liabilities under insurance contracts
Non-linked
insurance
Linked life
insurance
Investment contracts
with DPF1
Total
£m
£m
£m
£m
Gross liabilities under insurance contracts at 1 Jan 2021
594
1,512
20,710
22,816
Claims and benefits paid
(126)
(106)
(1,554)
(1,786)
Increase in liabilities to policyholders
120
550
2,420
3,090
Exchange differences and other movements2
(32)
(18)
(1,806)
(1,856)
Gross liabilities under insurance contracts at 31 Dec 2021
556
1,938
19,770
22,264
Reinsurers’ share of liabilities under insurance contracts
(93)
(53)
—
(146)
Net liabilities under insurance contracts at 31 Dec 2021
463
1,885
19,770
22,118
Gross liabilities under insurance contracts at 1 Jan 2020
576
1,295
19,638
21,509
Claims and benefits paid
(102)
(93)
(1,578)
(1,773)
Increase in liabilities to policyholders
143
300
1,404
1,847
Exchange differences and other movements2
(23)
10
1,246
1,233
Gross liabilities under insurance contracts at 31 Dec 2020
594
1,512
20,710
22,816
Reinsurers‘ share of liabilities under insurance contracts
(118)
(47)
—
(165)
Net liabilities under insurance contracts at 31 Dec 2020
476
1,465
20,710
22,651
1 Discretionary participation features.
2'Exchange differences and other movements’ includes movements in liabilities arising from net unrealised investment gains recognised in other
comprehensive income.
The key factors contributing to the movement in liabilities to policyholders included movement in the market value of assets supporting
policyholder liabilities, death claims, surrenders, lapses, new business, the declaration of bonuses and other amounts attributable to
policyholders.
HSBC Bank plc Annual Report and Accounts 2021
129
5
Employee compensation and benefits
2021
2020
£m
£m
Wages and salaries
1,609
1,917
Social security costs
341
367
Post-employment benefits1
73
56
Year ended 31 Dec
2,023
2,340
1Includes £37m (2020: £36m) in employer contributions to the defined contribution pension plans.
Average number of persons employed by the group during the year
2021
2020
£m
£m
MSS
4,322
4,590
GB
2,458
2,857
GBM Other
140
158
CMB
3,023
3,396
WPB
6,709
6,807
Corporate Centre
171
58
Year ended 31 Dec1,2
16,823
17,866
1A change in reportable segments was made in 2021. Comparatives have been re-presented accordingly. For further guidance, refer to Note 9:
Segmental Analysis on page 138.
2  Average numbers of headcount in corporate centre are allocated in respective businesses on the basis of amounts charged to the respective
global businesses.
Share-based payments
'Wages and salaries’ includes the effect of share-based payments arrangements, of which £96m were equity settled (2020: £76m), as
follows:
2021
2020
£m
£m
Restricted share awards
96
77
Savings-related and other share award option plans
1
2
Year ended 31 Dec
97
79
HSBC share awards
Award
Policy
Deferred share awards
(including annual incentive
awards, LTI awards
delivered shares) and
Group Performance Share
Plan ('GPSP')
•An assessment of performance over the relevant period ending on 31 December is used to determine the amount of the
award to be granted.
•Deferred awards generally require employees to remain in employment over the vesting period and are generally not
subject to performance conditions after the grant date. An exception to these are the LTI awards, which are subject to
performance conditions.
•Deferred share awards generally vest over a period of three, five or seven years.
•Vested shares may be subject to a retention requirement post-vesting.
•Awards are subject to malus and clawback.
International Employee
Share Purchase Plan
(‘ShareMatch’)
•The plan was first introduced in Hong Kong in 2013 and now includes employees based in 28 jurisdictions.
•Shares are purchased in the market each quarter up to a maximum value of £750, or the equivalent in local currency.
•Matching awards are added at a ratio of one free share for every three purchased.
•Matching awards vest subject to continued employment and the retention of the purchased shares for a maximum
period of two years and nine months.
Movement on HSBC share awards
2021
2020
Number
Number
(000s)
(000s)
Restricted share awards outstanding at 1 Jan
24,367
24,578
Additions during the year1
15,479
16,823
Released in the year1
(16,690)
(16,024)
Forfeited in the year
(1,328)
(1,010)
Restricted share awards outstanding at 31 Dec
21,828
24,367
Weighted average fair value of awards granted (£)
4.49
5.58
1Includes a number of share option plans transferred from or to other subsidiaries of HSBC Holdings plc.
Notes on the Financial Statements
130
HSBC Bank plc Annual Report and Accounts 2021
HSBC share option plans
Main plans
Policy
Savings-related share
option plans (‘Sharesave’)
•From 2014, eligible employees for the UK plan can save up to £500 per month with the option to use the savings to
acquire shares.
•These are generally exercisable within six months following either the third or fifth anniversary of the commencement of
a three-year or five-year contract, respectively.
•The exercise price is set at a 20% (2020: 20%) discount to the market value immediately preceding the date of invitation.
Calculation of fair values
The fair values of share options are calculated using a Black-Scholes model. The fair value of a share award is based on the share price
at the date of the grant.
Movement on HSBC share option plans
Savings-related
share option plans
Number
WAEP1
(000s)
£
Outstanding at 1 Jan 2021
7,206
2.96
Granted during the year2
984
3.25
Exercised during the year
(227)
3.97
Expired during the year
(99)
4.70
Forfeited during the year
(928)
3.68
Outstanding at 31 Dec 2021
6,936
2.87
Weighted average remaining contractual life (years)
2.98
Outstanding at 1 Jan 2020
4,245
4.78
Granted during the year2
5,909
2.56
Exercised during the year
(107)
4.43
Expired during the year
(78)
4.64
Forfeited during the year
(2,763)
4.79
Outstanding at 31 Dec 2020
7,206
2.96
Weighted average remaining contractual life (years)
3.64
1Weighted average exercise price.
2Includes a number of share option plans transferred from or to other subsidiaries of HSBC Holdings plc.
Post-employment benefit plans
We operate a number of pension plans throughout Europe for our employees. Some are defined benefit plans, of which HSBC Trinkaus
& Burkhardt Pension Plan is the most prominent within the group. The pension risk section on page 73 contains details about policies
and practices associated with the pensions plans.
The group’s balance sheet includes the net surplus or deficit, being the difference between the fair value of plan assets and the
discounted value of scheme liabilities at the balance sheet date for each plan. Surpluses are only recognised to the extent that they are
recoverable through reduced contributions in the future, or through potential future refunds from the schemes. In assessing whether a
surplus is recoverable, the group has considered its current right to obtain a future refund or a reduction in future contributions together
with the rights of third parties such as trustees.
HSBC Trinkaus & Burkhardt Pension Plan
The plan is a final salary scheme and is calculated based on the employee length of service multiplied by a predefined benefit accrual
and earnings. The pension is paid when the benefit falls due and is a specified pension payment, lump-sum or combination thereof. The
plan is overseen by an independent corporate trustee, who has a fiduciary responsibility for the operation of the plan. Its assets are held
separately from the assets of the group.
The strategic aim of the investment is to achieve, as continuously as possible, an increase in value over time. For this purpose, the fund
invests mainly in government bonds, corporate bonds, investment funds and equities. It invests predominantly in developed regions.
Overall, emphasis is placed on having a high degree of diversification.
The latest measurement of the defined benefit obligation of the plan at 31 December 2021 was carried out by Tim Voetmann and Hans-
Peter Kieselmann, at Willis Towers Watson GmbH, who are Fellows of the German Association of Actuaries ('DAV'), using the projected
unit credit method. The next measurement will have an effective date of 31 December 2022.
HSBC Bank plc Annual Report and Accounts 2021
131
Net assets/(liabilities) recognised on the balance sheet in respect of defined benefit plans
Fair value of
plan assets
Present value
of defined
benefit
obligations
Total
£m
£m
£m
Defined benefit pension plans
668
(742)
(74)
Defined benefit healthcare plans
—
(68)
(68)
At 31 Dec 2021
668
(810)
(142)
Total employee benefit liabilities (within ‘Accruals, deferred income and other liabilities’)
(196)
Total employee benefit assets (within ‘Prepayments, accrued income and other assets’)
54
Defined benefit pension plans
693
(876)
(183)
Defined benefit healthcare plans
—
(75)
(75)
At 31 Dec 2020
693
(951)
(258)
Total employee benefit liabilities (within ‘Accruals, deferred income and other liabilities’)
(288)
Total employee benefit assets (within ‘Prepayments, accrued income and other assets’)
30
Defined benefit pension plans
Net asset/(liability) under defined benefit pension plans
Fair value of plan assets
Present value of defined benefit
obligations
Net defined benefit asset/(liability)
HSBC Trinkaus &
Burkhardt
Pension Plan2
Other
plans
HSBC Trinkaus &
Burkhardt
Pension Plan2
Other
plans
HSBC Trinkaus &
Burkhardt
Pension Plan2
Other
plans
£m
£m
£m
£m
£m
£m
At 1 Jan 2021
435
258
(489)
(387)
(54)
(129)
Service cost
—
—
(7)
(27)
(7)
(27)
–  current service cost
—
—
(8)
(11)
(8)
(11)
–  past service cost and gains from settlements
—
—
1
(16)
1
(16)
Net interest income/(cost) on the net defined
benefit asset/(liability)
3
4
(3)
(3)
—
1
Remeasurement effects recognised in other
comprehensive income
17
(2)
26
16
43
14
–  return on plan assets (excluding interest
income)
17
(2)
—
—
17
(2)
–  actuarial gains/(losses)
—
—
26
16
26
16
–  other changes
—
—
—
—
—
—
Exchange differences
(28)
(1)
29
9
1
8
Benefits paid
—
(15)
10
19
10
4
Other movements1
7
(10)
(4)
69
3
59
At 31 Dec 2021
434
234
(438)
(304)
(4)
(70)
At 1 Jan 2020
405
175
(434)
(325)
(29)
(150)
Service cost
—
—
(12)
(1)
(12)
(1)
–  current service cost
—
—
(14)
(10)
(14)
(10)
–  past service cost and gains from settlements
—
—
2
9
2
9
Net interest income/(cost) on the net defined
benefit asset/(liability)
3
16
(4)
(16)
(1)
—
Remeasurement effects recognised in other
comprehensive income
(3)
84
(20)
(79)
(23)
5
–  return on plan assets (excluding interest
income)
(3)
26
—
—
(3)
26
–  actuarial gains/(losses)
—
—
(21)
(27)
(21)
(27)
–  other changes
—
58
1
(52)
1
6
Exchange differences
23
—
(24)
(9)
(1)
(9)
Benefits paid
—
(39)
10
46
10
7
Other movements1
7
22
(5)
(3)
2
19
At 31 Dec 2020
435
258
(489)
(387)
(54)
(129)
1Other movements include contributions by the group, contributions by employees, administrative costs and tax paid by plan.
2The HSBC Trinkaus & Burkhardt Pension Plan and its comparatives have been disclosed as it is considered to be a prominent plan within the
group. Figures disclosed comprise this prominent plan and other plans in Germany.
HSBC Trinkaus & Burkhardt AG does not expect to make contributions to the HSBC Trinkaus & Burkhardt Pension Plan during 2022.
Benefits expected to be paid from the HSBC Trinkaus & Burkhardt Pension Plan to retirees over each of the next five years, and in
aggregate for the five years thereafter, are as follows:
Notes on the Financial Statements
132
HSBC Bank plc Annual Report and Accounts 2021
Benefits expected to be paid from plans
2022
2023
2024
2025
2026
2027-2031
£m
£m
£m
£m
£m
£m
HSBC Trinkaus & Burkhardt Pension Plan1
10
9
9
11
10
59
1The duration of the defined benefit obligation is 17.1 years for the HSBC Trinkaus & Burkhardt Pension Plan under the disclosure assumptions 
adopted (2020: 18.2 years).
Fair value of plan assets by asset classes
31 Dec 2021
31 Dec 2020
Value
Quoted
market price
in active
market
No quoted
market price
in active
market
Thereof HSBC
Value
Quoted
market price
in active
market
No quoted
market price
in active
market
Thereof HSBC
£m
£m
£m
£m
£m
£m
£m
£m
HSBC Trinkaus & Burkhardt Pension Plan
Fair value of plan assets
434
377
57
—
435
418
17
—
–  equities
11
11
—
—
19
19
—
—
–  bonds
112
112
—
—
109
109
—
—
–  other
311
254
57
—
307
290
17
—
Post-employment defined benefit plans’ principal actuarial financial assumptions
The group determines the discount rates to be applied to its obligations in consultation with the plans’ local actuaries, on the basis of
current average yields of high quality (AA-rated or equivalent) debt instruments with maturities consistent with those of the defined
benefit obligations.
Key actuarial assumptions
Discount rate
Inflation rate
Rate of
increase for
pensions
Rate of pay
increase
%
%
%
%
HSBC Trinkaus & Burkhardt Pension Plan
At 31 Dec 2021
1.14
1.75
1.75
1.75
At 31 Dec 2020
0.70
1.75
1.50
2.50
Mortality tables and average life expectancy at age 65
Mortality
table
Life expectancy at age 65 for
a male member currently:
Life expectancy at age 65 for
a female member currently:
Aged 65
Aged 45
Aged 65
Aged 45
HSBC Trinkaus & Burkhardt Pension Plan
At 31 Dec 2021
RT 2018G1
20.6
23.4
24.0
26.3
At 31 Dec 2020
RT 2018G
20.3
23.1
23.8
26.0
1Heubeck tables: RT 2018G. It is generally accepted and used mortality tables for occupational pension plans in Germany taking into account
future mortality improvements and lighter mortality for higher-paid pensioners.
The effect of changes in key assumptions
HSBC Trinkaus & Burkhardt Pension Plan Obligation
Financial impact of increase
Financial impact of decrease
2021
2020
2021
2020
£m
£m
£m
£m
Discount rate – increase/decrease of 0.25%
(13)
(15)
13
16
Inflation rate – increase/decrease of 0.25%
11
16
(9)
(12)
Pension payments and deferred pensions – increase/decrease of 0.25%
9
10
(8)
(10)
Pay – increase/decrease of 0.25%
2
4
(2)
(4)
Change in mortality – increase of 1 year
16
19
N/A
N/A
The above sensitivity analyses are based on a change in an assumption while holding all other assumptions constant. In practice, this in
unlikely to occur, and changes in some of the assumptions may be correlated. When calculating the sensitivity of the defined benefit
obligation to significant actuarial assumptions the same method (present value of the defined benefit obligation calculated with the
projected unit credit method at the end of the reporting period) has been applied as when calculating the defined benefit asset
recognised in the balance sheet. The methods and types of assumptions used in preparing the sensitivity analysis did not change
compared to the prior period.
HSBC Bank plc Annual Report and Accounts 2021
133
Directors’ emoluments
The aggregate emoluments of the Directors of the bank, computed in accordance with the Companies Act 2006 as amended by
statutory instrument 2008 No.410, were:
2021
2020
£000
£000
Fees1
1,525
1,256
Salaries and other emoluments2, 5
3,569
2,321
Annual incentives3
694
576
Long-term incentives4
511
727
Year ended 31 Dec
6,299
4,880
1Fees paid to non-executive Directors.
2Salaries and other emoluments include Fixed Pay Allowances.
3Discretionary annual incentives for executive Directors are based on a combination of individual and corporate performance, and are determined
by the Remuneration Committee of the bank’s parent company, HSBC Holdings plc. Incentive awards made to executive directors are delivered
in the form of cash and HSBC Holdings plc shares. The total amount shown is comprised of £346,959 (2020: £288,050) in cash and £346,959
(2020: £288,050) in Restricted Shares, which is the upfront portion of the annual incentive granted in respect of performance year 2021.
4The amount shown is comprised of £274,177 (2020: £428,822) in deferred cash, £237,259 (2020: £289,261) in deferred Restricted Shares, and
£0 (2020: £8,826) in shares under the Group Performance Share Plan (‘GPSP’). These amounts relate to the portion of the awards that will vest
following the substantial completion of the vesting condition attached to these awards in 2021. The total vesting period of deferred cash and
share awards is no less than three years, with 33% of the award vesting on each of the first and second anniversaries of the date of the award,
and the balance vesting on the third anniversary of the date of the award. The deferred share awards are subject to at least a six-month retention
period upon vesting. Details of the Plans are contained within the Directors’ Remuneration Report of HSBC Holdings plc. The cost of any awards
subject to service conditions under the HSBC Share Plan 2011 are recognised through an annual charge based on the fair value of the awards,
apportioned over the period of service to which the award relates.
5Includes a payment of £1,380,193 (2020: £93,097) made to a Director as compensation for loss of employment.
No Director exercised share options over HSBC Holdings plc ordinary shares during the year.
Retirement benefits accruing to one Director under a money purchase scheme in respect of Directors’ qualifying services (2020: one
Director).
In addition, there were payments during 2021 under unfunded retirement benefit agreements to former Directors of £396,363 (2020:
£785,548). The provision at 31 December 2021 in respect of unfunded pension obligations to former Directors amounted to £5,387,505
(2020: £10,245,741).
Of these aggregate figures, the following amounts are attributable to the highest paid Director:
2021
2020
£000
£000
Salaries and other emoluments
1,399
1,392
Annual incentives1
558
417
Long-term incentives2
390
677
Year ended 31 Dec
2,347
2,486
1Awards made to the highest paid Director are delivered in the form of cash and HSBC Holdings plc shares. The amount shown comprises
£279,225 (2020: £208,736) in cash and £279,225 (2020: £208,736) in Restricted Shares.
2The amount shown comprises £209,492 (2020: £402,567) in deferred cash, £180,147 (2020: £274,104) in deferred Restricted Shares. These
amounts relate to a portion of the awards that will vest following the substantial completion of the vesting condition attached to these awards in
2021. The total vesting period of deferred cash and share awards is no less than three years, with 33% of the award vesting on each of the first
and second anniversaries of the date of the award, and the balance vesting on the third anniversary of the date of the award. The share awards
are subject to a six-month retention period upon vesting.
No pension contributions were made by the bank in respect of services by the highest paid Director during the year (2020: £19,298).
6
Auditors’ remuneration
2021
2020
£m
£m
Audit fees payable to PwC
10.4
11.3
Other audit fees payable
0.4
0.4
Year ended 31 Dec
10.8
11.7
Notes on the Financial Statements
134
HSBC Bank plc Annual Report and Accounts 2021
Fees payable by the group to PwC
2021
2020
£m
£m
Fees for HSBC Bank plc‘s statutory audit1
4.8
5.3
Fees for other services provided to the group
14.3
13.1
–  audit of the group‘s subsidiaries2
5.6
6.0
–  audit-related assurance services3
5.7
4.2
–  other assurance services4
3.0
2.9
Year ended 31 Dec
19.1
18.4
1Fees payable to PwC for the statutory audit of the consolidated financial statements of the group and the separate financial statements of HSBC
Bank plc. They exclude amounts payable for the statutory audit of the bank’s subsidiaries which have been included in ‘Fees for other services
provided to the group’.
2Including fees payable to PwC for the statutory audit of the bank’s subsidiaries.
3Including services for assurance and other services that relate to statutory and regulatory filings, including interim reviews.
4Including permitted services relating to attestation reports on internal controls of a service organisation primarily prepared for and used by third-
party end user, including comfort letters.
Fees payable for non-audit services for HSBC Bank plc are not disclosed separately because such fees are disclosed on a consolidated
basis for the group.
7
Tax
Tax expense
2021
2020
£m
£m
Current tax
(187)
195
–  for this year
(245)
186
–  adjustments in respect of prior years
58
9
Deferred tax
164
(331)
–  origination and reversal of temporary differences
248
(339)
–  effect of changes in tax rates
(56)
(26)
–  adjustments in respect of prior years
(28)
34
Year ended 31 Dec1
(23)
(136)
1In addition to amounts recorded in the income statement, a tax credit of £135m (2020: charge of £135m) was recorded directly to equity.
The group’s profits are taxed at different rates depending on the country in which the profits arise. The key applicable corporate tax rates
in 2021 included the UK and France. The UK tax rate applying to HSBC Bank plc and its banking subsidiaries was 27% (2020: 27%),
comprising 19% corporation tax plus 8% surcharge on UK banking profits. The applicable tax rate in France was 28% (2020: 32%) and
will reduce to 26% from 1 January 2022. Other overseas subsidiaries and overseas branches provided for taxation at the appropriate
rates in the countries in which they operate.
During 2021, legislation was enacted to increase the main rate of UK corporation tax from 19% to 25% from 1 April 2023, increasing the
tax credit for 2021 by £56m due to the remeasurement of deferred tax balances. In the UK Budget on 27 October 2021, HM Treasury
announced that the UK banking surcharge rate will reduce from 8% to 3% with effect from 1 April 2023. The reduction in the UK
banking surcharge rate has not been reflected for accounting purposes as the legislation to effect this change had not been
substantively enacted at the balance sheet date.
In December 2021, the OECD published model rules that provided a template for countries to implement a new global minimum tax rate
of 15% from 2023. In January 2022, the UK government opened a consultation on how the UK implements the rules. The impact on
HSBC will depend on exactly how the UK implements the model rules, as well as the profitability and local tax liabilities of HSBC’s
operations in each tax jurisdiction from 2023. Separately, potential changes to tax legislation and tax rates in the countries in which we
operate could increase our effective tax rate in future as governments seek revenue to pay for Covid-19 support packages.
HSBC Bank plc Annual Report and Accounts 2021
135
Tax reconciliation
The tax charged to the income statement differs from the tax expense that would apply if all profits had been taxed at the UK
corporation tax rate as follows:
2021
2020
£m
%
£m
%
Profit/(loss) before tax
1,023
(1,614)
Tax expense
Taxation at UK corporation tax rate
194
19.0
(307)
19.0
Impact of taxing overseas profits at different rates
7
0.7
(75)
4.6
UK banking surcharge
(2)
(0.2)
(100)
6.2
Items increasing the tax charge in 2021:
- impact of temporary differences between French tax returns and IFRS
324
31.7
—
—
- bank levy
72
7.0
31
(1.9)
- adjustments in respect of prior periods
30
2.9
45
(2.8)
Items reducing the tax charge in 2021:
- tax impact of planned sale of French retail banking business
(324)
(31.7)
—
—
- non-taxable income and gains
(92)
(9.0)
(55)
3.4
- impact of changes in tax rates
(56)
(5.5)
(26)
1.6
- deductions for AT1 coupon payments
(53)
(5.2)
(51)
3.2
- movements in unrecognised deferred tax
(47)
(4.6)
321
(19.9)
- effect of profits in associates and joint ventures
(43)
(4.2)
(3)
0.2
- other permanent differences
(26)
(2.5)
24
(1.5)
- local taxes and overseas withholding taxes
(4)
(0.4)
49
(3.0)
- other
(3)
(0.3)
11
(0.7)
Year ended 31 Dec
(23)
(2.3)
(136)
8.4
The effective tax rate for the year was (2.3)% (2020: 8.4%), reflecting a tax credit arising on a profit before tax. The tax credit for 2021
included favourable non-recurring items in respect of tax rate changes, prior period adjustments and the recognition of previously
unrecognised deferred tax assets in France. The effective tax rate for 2020 was reduced by 19.9% by the non-recognition of deferred tax
on losses arising in France.
The signing of a framework agreement for the planned sale of the French retail banking business resulted in a tax deduction (tax value of
£324m) for a provision for loss on disposal which was recorded in the French tax return. A deferred tax liability of the same amount
arises as a consequence of the temporary difference between the French tax basis and IFRS in respect of this provision.
Accounting for taxes involves some estimation because the tax law is uncertain and the application requires a degree of judgement,
which authorities may dispute. Liabilities are recognised based on best estimates of the probable outcome, taking into account external
advice where appropriate. We do not expect significant liabilities to arise in excess of the amounts provided. The current tax asset
includes an estimate of tax recoverable from HMRC with regards to past dividends received from EU resident companies. The ultimate
resolution of this matter involves litigation for which the outcome is uncertain.
Movement of deferred tax assets and liabilities
Retirement
benefits
Loan
impairment
provisions
Property,
plant and
equipment
FVOCI
investments
Goodwill and
intangibles
Relief for tax
losses 2
Other1
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
Assets
63
66
171
—
157
418
—
875
Liabilities
—
(9)
(6)
(166)
—
—
(117)
(298)
At 1 Jan 2021
63
57
165
(166)
157
418
(117)
577
Income statement
28
(10)
51
3
55
(37)
(254)
(164)
Other comprehensive income
(17)
2
(1)
105
—
—
82
171
At 31 Dec 2021
74
49
215
(58)
212
381
(289)
584
Assets3
74
53
215
—
212
381
—
935
Liabilities3
—
(4)
—
(58)
—
—
(289)
(351)
Assets
82
41
172
—
142
82
2
521
Liabilities
—
(6)
(6)
(123)
—
—
—
(135)
At 1 Jan 2020
82
35
166
(123)
142
82
2
386
Income statement
(37)
22
(1)
(3)
15
351
(16)
331
Other comprehensive income
18
—
—
(40)
—
(15)
(103)
(140)
At 31 Dec 2020
63
57
165
(166)
157
418
(117)
577
Assets3
63
66
171
—
157
418
—
875
Liabilities3
—
(9)
(6)
(166)
—
—
(117)
(298)
1Other deferred tax assets and liabilities relate to share-based payments, cash flow hedges and temporary differences arising between IFRS and
French tax returns.
2The deferred tax asset recognised in respect of tax losses mainly relates to France (£294m), the UK (£40m) and US State tax losses of the New
York branch of HSBC Bank plc (£28m), all of which are supported by future profit forecasts.
3After netting off balances within countries, the balances as disclosed in the financial statements are as follows: deferred tax assets £599m (2020:
£597m); and deferred tax liabilities £15m (2020: £20m).
Notes on the Financial Statements
136
HSBC Bank plc Annual Report and Accounts 2021
Management has assessed the likely availability of future taxable profits against which to recover the deferred tax assets of the
Company and the Group, taking into consideration the reversal of existing taxable temporary differences, past business performance and
forecasts of future business performance.
The group’s net deferred tax asset of £584m (2020: £577m) included a net UK deferred tax asset of £448m (2020: £507m), of which
£103m related to UK banking tax losses which are expected to be substantially recovered within one year, and a net deferred asset of
£7m (2020: £nil) in France, of which £294m (2020: £nil) related to tax losses which are expected to be substantially recovered within 10
years.
Management is satisfied that although the Company recorded a UK tax loss in the year, the aforementioned evidence is sufficient to
support recognition of all UK deferred tax assets. These deferred tax assets are supported by future profit forecasts for the whole of
HSBC's UK tax group. This includes a number of companies which are not part of the HSBC Bank plc group, in particular HSBC UK Bank
plc and its subsidiaries.
Following the signing of a framework agreement in 2021 for the planned sale of the French retail banking business, that business is now
excluded from our deferred tax analysis as its sale is considered probable. Although the French consolidated tax group recorded a tax
loss in both 2020 and 2021, this would have been taxable profit if the effects of the retail banking business and other non-recurring
items, mainly related to the restructuring of the European business, were excluded. The French net deferred tax asset is supported by
forecasts of taxable profit, also taking into consideration the history of profitability in the remaining businesses. No net deferred tax asset
was recognised as at 31 December 2020 as management did not consider there to be convincing evidence of sufficient future taxable
profits to support recognition.
Movement of deferred tax assets and liabilities
Retirement
benefits
Property, plant
and equipment
Goodwill and
intangibles
Relief for tax
losses2
Other1
Total
The bank
£m
£m
£m
£m
£m
£m
Assets2
16
162
156
416
—
750
Lliabilities2
—
—
—
—
(204)
(204)
At 1 Jan 2021
16
162
156
416
(204)
546
Income statement
2
45
35
(347)
73
(192)
Other comprehensive income
(1)
—
—
—
154
153
Foreign exchange and other adjustments
—
—
—
—
2
2
At 31 Dec 2021
17
207
191
69
25
509
Assets3
17
207
191
69
25
509
Liabilities3
—
—
—
—
—
—
Assets
23
151
145
53
—
372
Liabilities
—
—
—
—
(47)
(47)
At 1 Jan 2020
23
151
145
53
(47)
325
Income statement
(10)
11
11
377
(41)
348
Other comprehensive income
3
—
—
(14)
(116)
(127)
At 31 Dec 2020
16
162
156
416
(204)
546
Assets3
16
162
156
416
—
750
Liabilities3
—
—
—
—
(204)
(204)
1Other deferred tax assets and liabilities relate to fair value of own debt, loan impairment allowances, share-based payments and cash flow
hedges.
2The deferred tax asset recognised in respect of losses mainly relates to US State tax losses of the New York branch of HSBC Bank plc and losses
in the UK; both are supported by future profit forecasts.
3After netting off balances within countries, the balances as disclosed in the accounts are as follows: deferred tax assets £510m (2020: £549m)
and deferred tax liabilities nil (2020: £3m).
Unrecognised deferred tax
The group
The amount of temporary differences, unused tax losses and tax credits for which no deferred tax asset is recognised in the balance
sheet was £1,944m (2020: £2,081m). These amounts consist of unused tax losses, tax credits and temporary differences of £1,141m
(2020: £925m) arising in the New York branch of HSBC Bank plc and of £782m (2020: £1,137m) arising in France. Of the unrecognised
losses, £394m expire within 10 years (2020: £88m), and the remainder expire after 10 years or do not expire. The value of the French
losses which are recognised is based on analysis of the probability of recovery, taking into account forecasting uncertainty.
The bank
The amount of temporary differences, unused tax losses and tax credits for which no deferred tax asset is recognised in the balance
sheet was £1,141m (2020: £925m). These amounts include unused tax losses, tax credits and temporary differences arising in the New
York branch of HSBC Bank plc of £1,141m (2020: £925m). Of the unrecognised losses, £394m expire within 10 years (2020: £88m), and
the remainder expire after 10 years.
There are no unrecognised deferred tax liabilities arising from the group’s investments in subsidiaries and branches.
HSBC Bank plc Annual Report and Accounts 2021
137
8
Dividends
Dividends to the parent company
2021
2020
£ per share
£m
£ per share
£m
Dividends on preference shares classified as equity
Dividend on HSBC Bank plc non-cumulative third dollar preference shares1
0.001
—
1.47
51
Total
0.001
—
1.47
51
Total coupons on capital securities classified as equity
194
212
Dividends to parent
194
263
1  In 2021,the liquidation value of USD third dollar preference shares reduced to $0.01 per share.
.
No dividend was declared on ordinary share capital in respect of 2021 and 2020.
Total coupons on capital securities classified as equity
2021
2020
First call date
£m
£m
Undated Subordinated additional Tier 1 instruments
–  €1,900m Undated Subordinated Resettable Additional Tier 1 instrument 2015
Dec 2020
84
103
–  €235m Undated Subordinated Resettable Additional Tier 1 instrument  2016
Jan 2022
12
11
–  €300m Undated Subordinated Resettable Additional Tier 1 instrument 2018
Mar 2023
10
10
–  £555m Undated Subordinated Resettable Additional Tier 1 instrument 2018
Mar 2023
28
28
–  £500m Undated Subordinated Resettable Additional Tier 1 instrument 2019
Nov 2024
24
24
–  €250m Undated Subordinated Resettable Additional Tier 1 instrument 2019
Nov 2024
7
8
–  £431m Undated Subordinated Resettable Additional Tier 1 instrument 2019
Dec 2024
20
20
–  €200m Undated Subordinated Resettable Additional Tier 1 instrument 2019
Jan 2025
9
8
Total
194
212
9
Segmental analysis
Basis of preparation
The Chief Executive, supported by the rest of the Executive Committee, is considered the Chief Operating Decision Maker (‘CODM’) for
the purposes of identifying the group’s reportable segments. Business results are assessed by the CODM on the basis of adjusted
performance that removes the effects of significant items from reported results. We therefore present a reconciliation between reported
and adjusted results as required by IFRSs.
Our operations are closely integrated and, accordingly, the presentation of data includes internal allocations of certain items of income
and expense. These allocations include the costs of certain support services and functions to the extent that they can be meaningfully
attributed to businesses and countries. While such allocations have been made on a systematic and consistent basis, they necessarily
involve a degree of subjectivity. Costs that are not allocated to businesses are included in Corporate Centre.
Where relevant, income and expense amounts presented include the results of inter-segment funding along with inter-company and
inter-business line transactions. All such transactions are undertaken on arm’s length terms. The intra-group elimination items for the
businesses are presented in Corporate Centre.
Change in reportable segments
During the year, Global Banking and Markets (‘GBM’) in Europe has been re-segmented into Market & Securities Services (‘MSS’),
Global Banking (‘GB’) and GBM Other to align with the reorganised GBM management structure and internal reporting to the Executive
Committee and CODM. This does not change the Group's management of its global GBM strategy.
Comparative data have been re-presented accordingly.
Our businesses
HSBC provides a comprehensive range of banking and related financial services to its customers through its global businesses. The
products and services offered to customers are organised by these global businesses.
Our operating model has the following material segments: WPB; CMB; a GBM business which is further split into 3 reportable segments
MSS, GB and GBM Other reflecting the reorganisation of the GBM management structure during the year and a Corporate Centre. These
segments are supported by Digital Business Services and 11 global functions, including Risk, Finance, Compliance, Legal, Marketing and
Human Resources. These business segment are our reportable segments under IFRS 8 'Operating Segments'.
Notes on the Financial Statements
138
HSBC Bank plc Annual Report and Accounts 2021
By operating segment:
Adjusted profit/(loss) before tax
2021
MSS
GB
GBM
Other
CMB
WPB
Corporate
Centre
Total
£m
£m
£m
£m
£m
£m
£m
Net operating income/(expense) before change in
expected credit losses and other credit
impairment charges1
          2,055
          1,367
              579
          1,095
          1,275
(41)
          6,330
–  of which: net interest income/(expense)
            (232)
              568
              224
              649
              567
(22)
          1,754
Change in expected credit losses and other credit
impairment charges
                  1
              140
                  5
                  7
                23
(2)
              174
Net operating income/(expense)
          2,056
          1,507
              584
          1,102
          1,298
(43)
          6,504
Total operating expenses
          (2,064)
            (918)
            (485)
            (612)
            (975)
(64)
          (5,118)
Operating profit/(loss)
                (8)
              589
                99
              490
              323
(107)
          1,386
Share of loss in associates and joint ventures
                —
                —
                —
                —
                —
191
              191
Adjusted profit/(loss) before tax
                (8)
              589
                99
              490
              323
  84
          1,577
%
%
%
%
%
%
Adjusted cost efficiency ratio
          100.4
            67.2
            83.9
            55.9
            76.5
            80.9
2020
Net operating income/(expense) before change in
expected credit losses and other credit impairment
charges1
            1,968
              1,381
                624
            1,133
            1,035
                (144)
              5,997
–  of which: net interest income/(expense)
                  (96)
                651
                  46
                686
                664
                  (53)
            1,898
Change in expected credit losses and other credit
impairment charges
                    1
              (448)
                  (4)
              (322)
                (39)
                    4
              (808)
Net operating income/(expense)
            1,969
                933
                620
                811
                996
              (140)
            5,189
Total operating expenses
            (1,949)
              (878)
              (672)
              (659)
            (1,128)
(86)
            (5,372)
Operating profit/(loss)
                  20
                  55
                (52)
              152
              (132)
              (226)
              (183)
Share of profit in associates and joint ventures
                  —
                  —
                  —
                    —
                  —
                  (1)
                  (1)
Adjusted profit/(loss) before tax
                  20
                  55
                (52)
                152
              (132)
              (227)
              (184)
%
%
%
%
%
%
Adjusted cost efficiency ratio
99.0
63.6
107.7
58.2
109.0
89.6
1  Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue. It includes inter-
segment revenue which is eliminated in Corporate centre, amounting to £124m (2020: £167m).
Reported external net operating income is attributed to countries on the basis of the location of the branch responsible for reporting the
results or advancing the funds:
2021
2020
£m
£m
Reported external net operating income by country1
6,120
5,900
–  United Kingdom
2,937
2,914
–  France
1,677
1,528
–  Germany
887
814
–  Other countries
619
644
Adjusted results reconciliation
2021
2020
Adjusted
Significant
items
Reported
Adjusted
Significant
items
Reported
£m
£m
£m
£m
£m
£m
Revenue1
6,330
(210)
6,120
5,997
(97)
5,900
ECL
174
—
174
(808)
—
(808)
Operating expenses
(5,118)
(344)
(5,462)
(5,372)
(1,333)
(6,705)
Share of profit/(loss) in associates and joint ventures
191
—
191
(1)
—
(1)
Profit/(loss) before tax
1,577
(554)
1,023
(184)
(1,430)
(1,614)
1Net operating income before change in expected credit losses and other credit impairment charges, also referred to as revenue.
Adjusted profit/(loss) reconciliation
2021
2020
£m
£m
Year ended 31 Dec
Adjusted profit/(loss) before tax
1,577
(184)
Significant items
(554)
(1,430)
–  fair value movements on financial instruments1
(5)
(3)
–  restructuring and other related costs
(549)
(773)
–  settlements and provisions in connection with legal and regulatory matters
—
(9)
–  impairment of other intangible assets
—
(645)
Reported profit/(loss) before tax
1,023
(1,614)
1 Includes fair value movements on non-qualifying hedges and debt valuation adjustments on derivatives.
HSBC Bank plc Annual Report and Accounts 2021
139
Balance sheet by business
MSS
GB
GBM
Other
CMB
WPB
Corporate
Centre
Total
£m
£m
£m
£m
£m
£m
£m
31 Dec 2021
Loans and advances to customers
2,016
37,685
197
23,529
27,574
176
91,177
Customer accounts
34,243
74,179
4,355
50,297
41,939
228
205,241
31 Dec 2020
Loans and advances to customers
3,451
42,810
606
25,809
28,638
177
101,491
Customer accounts
23,780
77,393
4,173
48,368
41,258
212
195,184
10
Trading assets
The group
The bank
2021
2020
2021
2020
£m
£m
£m
£m
Treasury and other eligible bills
2,451
3,273
1,872
2,507
Debt securities
27,004
31,399
17,794
20,035
Equity securities
40,930
36,775
38,570
35,810
Trading securities
70,385
71,447
58,236
58,352
Loans and advances to banks1
4,142
5,058
3,559
4,207
Loans and advances to customers1
9,179
10,471
8,995
10,476
At 31 Dec
83,706
86,976
70,790
73,035
1Loans and advances to banks and customers include reverse repos, stock borrowing and other amounts.
11
Fair values of financial instruments carried at fair value
Control framework
Fair values are subject to a control framework designed to ensure that they are either determined or validated by a function independent
of the risk taker.
For all financial instruments where fair values are determined by reference to externally quoted prices or observable pricing inputs to
models, independent price determination or validation is utilised. In inactive markets, the group will source alternative market
information to validate the financial instrument’s fair value, with greater weight given to information that is considered to be more
relevant and reliable. The factors that are considered in this regard are, inter alia:
•the extent to which prices may be expected to represent genuine traded or tradable prices;
•the degree of similarity between financial instruments;
•the degree of consistency between different sources;
•the process followed by the pricing provider to derive the data;
•the elapsed time between the date to which the market data relates and the balance sheet date; and
•the manner in which the data was sourced.
For fair values determined using valuation models, the control framework may include, as applicable, development or validation by
independent support functions of: (i) the logic within valuation models; (ii) the inputs to these models; (iii) any adjustments required
outside the valuation models; and (iv) where possible, model outputs. Valuation models are subject to a process of due diligence and
calibration before becoming operational and are calibrated against external market data on an ongoing basis.
Financial liabilities measured at fair value
In certain circumstances, the group records its own debt in issue at fair value, based on quoted prices in an active market for the specific
instrument. When quoted market prices are unavailable, the own debt in issue is valued using valuation techniques, the inputs for which
are based either on quoted prices in an inactive market for the instrument or are estimated by comparison with quoted prices in an
active market for similar instruments. In both cases, the fair value includes the effect of applying the credit spread that is appropriate to
the group’s liabilities.
Structured notes issued and certain other hybrid instruments are included within trading liabilities and are measured at fair value.
The spread applied to these instruments is derived from the spreads at which the group issues structured notes.
Fair value hierarchy
Fair values of financial assets and liabilities are determined according to the following hierarchy:
•Level 1 – valuation technique using quoted market price: financial instruments with quoted prices for identical instruments in active
markets that HSBC can access at the measurement date.
•Level 2 – valuation technique using observable inputs: financial instruments with quoted prices for similar instruments in active
markets or quoted prices for identical or similar instruments in inactive markets and financial instruments valued using models where
all significant inputs are observable.
•Level 3 – valuation technique with significant unobservable inputs: financial instruments valued using valuation techniques where one
or more significant inputs are unobservable.
Notes on the Financial Statements
140
HSBC Bank plc Annual Report and Accounts 2021
Financial instruments carried at fair value and bases of valuation
2021
2020
Level 1
Level 2
Level 3
Total
Level 1
Level 2
Level 3
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
Recurring fair value measurements at 31 Dec
Assets
Trading assets
59,813
22,549
1,344
83,706
60,890
24,475
1,611
86,976
Financial assets designated and otherwise mandatorily
measured at fair value through profit or loss
6,332
9,146
3,171
18,649
5,658
7,095
3,467
16,220
Derivatives
1,987
137,418
1,816
141,221
1,668
197,568
1,974
201,210
Financial investments
29,669
10,235
1,387
41,291
38,347
11,829
1,635
51,811
Liabilities
Trading liabilities
32,886
12,967
580
46,433
29,847
14,264
118
44,229
Financial liabilities designated at fair value
1,020
30,467
2,121
33,608
928
38,714
1,150
40,792
Derivatives
1,105
135,809
2,454
139,368
1,058
195,078
3,096
199,232
The bank
Recurring fair value measurements at 31 Dec
Assets
Trading assets
49,435
20,021
1,334
70,790
49,650
21,802
1,583
73,035
Financial assets designated and otherwise mandatorily
measured at fair value through profit or loss
298
2,556
361
3,215
327
1,227
311
1,865
Derivatives
1,413
122,422
1,952
125,787
1,168
178,866
2,032
182,066
Financial investments
21,806
1,346
53
23,205
27,011
1,603
141
28,755
Liabilities
Trading liabilities
19,367
11,240
554
31,161
13,681
12,889
103
26,673
Financial liabilities designated at fair value
—
19,306
1,563
20,869
—
24,036
651
24,687
Derivatives
1,066
123,863
2,722
127,651
960
176,785
3,287
181,032
Transfers between Level 1 and Level 2 fair values
Assets
Liabilities
Financial
investments
Trading assets
Designated and
otherwise mandatorily
measured at fair value
through profit or loss
Derivatives
Trading
liabilities
Designated
at fair value
Derivatives
£m
£m
£m
£m
£m
£m
£m
Year ended 31 Dec 2021
Transfers from Level 1 to Level 2
366
1,731
757
—
27
—
—
Transfers from Level 2 to Level 1
244
990
399
—
91
—
—
Year ended 31 Dec 2020
Transfers from Level 1 to Level 2
200
915
—
—
77
6,013
—
Transfers from Level 2 to Level 1
1,557
1,557
71
—
304
—
—
Transfers between levels of the fair value hierarchy are deemed to occur at the end of each quarterly reporting period. Transfers into and
out of levels of the fair value hierarchy are normally attributable to observability of valuation inputs and price transparency.
Fair value adjustments
Fair value adjustments are adopted when the group determines there are additional factors considered by market participants that are
not incorporated within the valuation model. Movements in the level of fair value adjustments do not necessarily result in the recognition
of profits or losses within the income statement, such as when models are enhanced and fair value adjustments may no longer be
required.
Fair value adjustments
2021
20201
MSS
Corporate Centre
MSS
Corporate Centre
£m
£m
£m
£m
Type of adjustment
Risk-related
505
31
647
16
–  bid-offer
190
—
252
—
–  uncertainty
37
1
60
1
–  credit valuation adjustment
99
26
211
15
–  debt valuation adjustment
(27)
—
(40)
—
–  funding fair value adjustment
206
4
151
—
–  other
—
—
13
—
Model-related
19
—
47
—
–  model limitation
19
—
44
—
–  other
—
—
3
—
Inception profit (Day 1 P&L reserves)
65
—
60
—
At 31 Dec
589
31
754
16
1A change in reportable segments was made in 2021. Comparatives data have been re-presented accordingly. For further guidance, refer to Note
9: Segmental Analysis on page 138.
HSBC Bank plc Annual Report and Accounts 2021
141
Bid-offer
IFRS 13 ‘Fair value measurement’ requires use of the price within the bid-offer spread that is most representative of fair value. Valuation
models will typically generate mid-market values. The bid-offer adjustment reflects the extent to which bid-offer costs would be incurred
if substantially all residual net portfolio market risks were closed using available hedging instruments or by disposing of or unwinding
the position.
Uncertainty
Certain model inputs may be less readily determinable from market data, and/or the choice of model itself may be more subjective. In
these circumstances, an adjustment may be necessary to reflect the likelihood that market participants would adopt more conservative
values for uncertain parameters and/or model assumptions than those used in the valuation model.
Credit and debit valuation adjustments
The CVA is an adjustment to the valuation of over-the-counter (‘OTC’) derivative contracts to reflect the possibility that the counterparty
may default, and that the group may not receive the full market value of the transactions.
The DVA is an adjustment to the valuation of OTC derivative contracts to reflect the possibility that HSBC may default, and that it may
not pay the full market value of the transactions.
HSBC calculates a separate CVA and DVA for each legal entity, and for each counterparty to which the entity has exposure. With the
exception of central clearing parties, all third-party counterparties are included in the CVA and DVA calculations, and these adjustments
are not netted across Group's entities.
HSBC calculates the CVA by applying the probability of default (‘PD’) of the counterparty, conditional on the non-default of HSBC, to
HSBC’s expected positive exposure to the counterparty and multiplying the result by the loss expected in the event of default.
Conversely, HSBC calculates the DVA by applying the PD of HSBC, conditional on the non-default of the counterparty, to the expected
positive exposure of the counterparty to HSBC and multiplying the result by the proportional loss expected in the event of default. Both
calculations are performed over the life of the potential exposure.
For most products, HSBC uses a simulation methodology, which incorporates a range of potential exposures over the life of the
portfolio, to calculate the expected positive exposure to a counterparty. The simulation methodology includes credit mitigants, such as
counterparty netting agreements and collateral agreements with the counterparty. The methodologies do not, in general, account for
‘wrong-way risk’, which arises when the underlying value of the derivative prior to any CVA is positively correlated to the PD of the
counterparty. When there is significant wrong-way risk, a trade-specific approach is applied to reflect this risk in the valuation.
Funding fair value adjustment
The FFVA is calculated by applying future market funding spreads to the expected future funding exposure of any uncollateralised
component of the OTC derivative portfolio. The expected future funding exposure is calculated by a simulation methodology, where
available, and is adjusted for events that may terminate the exposure, such as the default of HSBC or the counterparty. The FFVA and
DVA are calculated independently.
Model limitation
Models used for portfolio valuation purposes may be based upon a simplified set of assumptions that do not capture all current and
future material market characteristics. In these circumstances, model limitation adjustments are adopted.
Inception profit (Day 1 P&L reserves)
Inception profit adjustments are adopted when the fair value estimated by a valuation model is based on one or more significant
unobservable inputs. The accounting for inception profit adjustments is discussed in Note 1.
Fair value valuation bases
Financial instruments measured at fair value using a valuation technique with significant unobservable inputs – Level 3
Assets
Liabilities
Financial
Investments
Held for
trading
Designated and
otherwise
mandatorily
measured at fair
value through
profit or loss
Derivatives
Total
Held for
trading
Designated at
fair value
Derivatives
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
£m
Private equity including
strategic investments
79
1
2,898
—
2,978
7
—
—
7
Asset-backed securities
495
97
—
—
592
—
—
—
—
Structured notes
—
—
—
—
—
—
2,120
—
2,120
Derivatives
—
—
—
1,816
1,816
—
—
2,454
2,454
Other portfolios
813
1,246
273
—
2,332
573
1
—
574
At 31 Dec 2021
1,387
1,344
3,171
1,816
7,718
580
2,121
2,454
5,155
Private equity including
strategic investments
75
3
3,153
—
3,231
3
—
—
3
Asset-backed securities
847
372
18
—
1,237
—
—
—
—
Structured notes
—
—
—
—
—
21
1,147
—
1,168
Derivatives
—
—
—
1,974
1,974
—
—
3,095
3,095
Other portfolios
713
1,236
296
—
2,245
94
3
1
98
At 31 Dec 2020
1,635
1,611
3,467
1,974
8,687
118
1,150
3,096
4,364
Notes on the Financial Statements
142
HSBC Bank plc Annual Report and Accounts 2021
Financial instruments measured at fair value using a valuation technique with significant unobservable inputs – Level 3
Assets
Liabilities
Financial
Investments
Held for
trading
Designated and
otherwise
mandatorily
measured at fair
value through
profit or loss
Derivatives
Total
Held for
trading
Designated at
fair value
Derivatives
Total
The bank
Private equity including
strategic investments
53
—
353
—
406
6
—
—
6
Asset-backed securities
—
97
—
—
97
—
—
—
—
Structured notes
—
—
—
—
—
—
1,563
—
1,563
Derivatives
—
—
—
1,952
1,952
—
—
2,722
2,722
Other portfolios
—
1,237
8
—
1,245
548
—
—
548
At 31 Dec 2021
53
1,334
361
1,952
3,700
554
1,563
2,722
4,839
Private equity including
strategic investments
56
—
300
—
356
—
—
—
—
Asset-backed securities
85
372
—
—
457
—
—
—
—
Structured notes
—
—
—
—
—
9
651
—
660
Derivatives
—
—
—
2,032
2,032
—
—
3,286
3,286
Other portfolios
—
1,211
11
—
1,222
94
—
1
95
At 31 Dec 2020
141
1,583
311
2,032
4,067
103
651
3,287
4,041
.
Level 3 instruments are present in both ongoing and legacy businesses. Loans held for securitisation, certain derivatives and
predominantly all Level 3 Asset-backed securities are legacy positions. HSBC has the capability to hold these positions.
Private equity including strategic investments
The investment’s fair value is estimated: on the basis of an analysis of the investee’s financial position and results, risk profile, prospects
and other factors; by reference to market valuations for similar entities quoted in an active market; the price at which similar companies
have changed ownership; or from published net asset values (‘NAVs’) received. If necessary, adjustments are made to the NAV of funds
to obtain the best estimate of fair value.
Asset-backed securities
While quoted market prices are generally used to determine the fair value of these securities, valuation models are used to substantiate
the reliability of the limited market data available and to identify whether any adjustments to quoted market prices are required. For
certain ABSs, such as residential mortgage-backed securities, the valuation uses an industry standard model with assumptions relating
to prepayment speeds, default rates and loss severity based on collateral type, and performance, as appropriate. The valuations output is
benchmarked for consistency against observable data for securities of a similar nature.
Structured notes
The fair value of Level 3 structured notes is derived from the fair value of the underlying debt security, and the fair value of the
embedded derivative is determined as described in the paragraph below on derivatives. These structured notes comprise principally
equity-linked notes, issued by HSBC, which provide the counterparty with a return linked to the performance of equity securities and
other portfolios. Examples of the unobservable parameters include long-dated equity volatilities and correlations between equity prices,
and interest and foreign exchange rates.
Derivatives
OTC derivative valuation models calculate the present value of expected future cash flows, based upon ‘no-arbitrage’ principles. For
many vanilla derivative products, the modelling approaches used are standard across the industry. For more complex derivative
products, there may be some differences in market practice. Inputs to valuation models are determined from observable market data,
wherever possible, including prices available from exchanges, dealers, brokers or providers of consensus pricing. Certain inputs may not
be observable in the market directly, but can be determined from observable prices through model calibration procedures or estimated
from historical data or other sources.
HSBC Bank plc Annual Report and Accounts 2021
143
Reconciliation of fair value measurements in Level 3 of the fair value hierarchy
Movement in Level 3 financial instruments
Assets
Liabilities
Financial
Investments
Trading assets
Designated and
otherwise
mandatorily
measured at fair
value through
profit or loss
Derivatives
Trading
liabilities
Designated
at fair value
Derivatives
The group
£m
£m
£m
£m
£m
£m
£m
At 1 Jan 2021
1,635
1,611
3,467
1,974
118
1,150
3,096
Total gains/(losses) recognised in profit or loss
15
(77)
148
1,608
11
(316)
1,362
–  net income from financial instruments held for
trading or managed on a fair value basis
—
(77)
—
1,608
11
—
1,362
–  changes in fair value of other financial
instruments mandatorily measured at fair value
through profit or loss
—
—
148
—
—
(316)
—
–  gains less losses from financial investments at fair
value through other comprehensive income
15
—
—
—
—
—
—
Total gains/(losses) recognised in other
comprehensive income (‘OCI’)
(75)
(4)
(152)
(6)
(1)
(32)
(8)
–  financial investments: fair value gains/(losses)
(27)
—
—
—
—
—
—
–  exchange differences
(48)
(4)
(152)
(6)
(1)
(32)
(8)
Purchases
555
686
543
—
742
1
—
New issuances
—
—
—
—
25
2,213
—
Sales
(417)
(209)
(813)
—
(3)
(20)
—
Settlements
(109)
(506)
(5)
(1,722)
(504)
(1,053)
(2,343)
Transfers out
(218)
(668)
(41)
(368)
(5)
(137)
(465)
Transfers in
1
511
24
330
197
315
812
At 31 Dec 2021
1,387
1,344
3,171
1,816
580
2,121
2,454
Unrealised gains/(losses) recognised in profit or loss
relating to assets and liabilities held at 31 Dec 2021
—
(11)
51
846
—
102
(721)
–  trading income/(expense) excluding net interest
income
—
(11)
—
846
—
—
(721)
–  net income/(expense) from other financial
instruments designated at fair value
—
—
51
—
—
102
—
At 1 Jan 2020
1,554
3,203
3,737
1,637
40
943
1,681
Total gains/(losses) recognised in profit or loss
14
3
95
1,582
237
87
2,644
–  net income from financial instruments held for
trading or managed on a fair value basis
—
3
—
1,582
237
—
2,644
–  changes in fair value of other financial
instruments mandatorily measured at fair value
through profit or loss
—
—
95
—
—
87
—
–  gains less losses from financial investments at fair
value through other comprehensive income
14
—
—
—
—
—
—
Total gains/(losses) recognised in other
comprehensive income (‘OCI’)
21
56
(12)
33
1
23
7
–  financial investments: fair value gains/(losses)
58
–
2
—
—
—
—
–  exchange differences
(37)
56
(14)
33
1
23
7
Purchases
294
442
1,061
—
53
—
—
New issuances
—
—
—
—
5
575
—
Sales
(525)
(791)
(1,435)
—
(198)
—
—
Settlements
(116)
(868)
(79)
(1,138)
(20)
(525)
(1,080)
Transfers out
(61)
(1,336)
(61)
(358)
(7)
(265)
(437)
Transfers in
454
902
161
218
7
312
281
At 31 Dec 2020
1,635
1,611
3,467
1,974
118
1,150
3,096
Unrealised gains/(losses) recognised in profit or loss
relating to assets and liabilities held at 31 Dec 2020
—
(24)
43
505
(1)
(73)
1,171
–  trading income/(expense) excluding net interest
income
—
(24)
—
505
(1)
—
1,171
–  net income from other financial instruments
designated at fair value
—
—
43
—
—
(73)
—
Transfers between levels of the fair value hierarchy are deemed to occur at the end of each quarterly reporting period. Transfers into and
out of levels of the fair value hierarchy are primarily attributable to observability of valuation inputs and price transparency.
Notes on the Financial Statements
144
HSBC Bank plc Annual Report and Accounts 2021
Movement in Level 3 financial instruments (continued)
Assets
Liabilities
Financial
Investments
Trading Assets
Designated and
otherwise
mandatorily
measured at fair
value through
profit or loss
Derivatives
Trading
Liabilities
Designated
at fair value
Derivatives
The bank
£m
£m
£m
£m
£m
£m
£m
At 1 Jan 2021
141
1,583
311
2,032
103
651
3,287
Total gains/(losses) recognised in profit or loss
1
(76)
77
1,730
12
(246)
1,443
–  net income from financial instruments held for
trading or managed on a fair value basis
—
(76)
—
1,730
12
—
1,443
–  changes in fair value of other financial
instruments mandatorily measured at fair
value through profit or loss
—
—
77
—
—
(246)
—
–  gains less losses from financial investments at
fair value through other comprehensive
income
1
—
—
—
—
—
—
Total gains/(losses) recognised in other
comprehensive income (‘OCI’)1
(1)
(3)
(11)
—
—
—
—
–  financial investments: fair value gains/(losses)
(1)
—
—
—
—
—
—
–  exchange differences
—
(3)
(11)
—
—
—
—
Purchases
—
683
2
—
741
—
—
New issuances
—
—
—
—
—
2,128
—
Sales
(2)
(186)
(13)
—
—
—
—
Settlements
(3)
(505)
(5)
(1,778)
(494)
(950)
(2,297)
Transfers out
(83)
(668)
—
(375)
(5)
(153)
(511)
Transfers in
—
506
—
343
197
133
800
At 31 Dec 2021
53
1,334
361
1,952
554
1,563
2,722
Unrealised gains/(losses) recognised in profit or
loss relating to assets and liabilities held at
31 Dec 2021
—
(11)
1
973
—
46
(949)
–  trading income/(expense) excluding net
interest income
—
(11)
—
973
—
—
(949)
–  net income/(expense) from other financial
instruments designated at fair value
—
—
1
—
—
46
—
At 1 Jan 2020
58
3,198
524
1,659
27
683
1,929
Total gains/(losses) recognised in profit or loss
2
5
44
2,076
235
(22)
2,749
–  net income from financial instruments held for
trading or managed on a fair value basis
—
5
—
2,076
235
—
2,749
–  changes in fair value of other financial
instruments mandatorily measured at fair
value through profit or loss
—
—
44
—
—
(22)
—
–  gains less losses from financial investments at
fair value through other comprehensive
income
2
—
—
—
—
—
—
Total gains/(losses) recognised in other
comprehensive income (‘OCI’)1
(4)
55
5
2
—
—
—
–  exchange differences
(4)
55
5
2
—
—
—
Purchases
—
403
282
—
52
—
—
New issuances
—
–
—
—
—
558
—
Sales
—
(749)
(542)
—
(198)
—
—
Settlements
(6)
(849)
—
(1,551)
(13)
(536)
(1,254)
Transfers out
—
(1,336)
(2)
(385)
(7)
(167)
(524)
Transfers in
91
856
—
231
7
135
387
At 31 Dec 2020
141
1,583
311
2,032
103
651
3,287
Unrealised gains/(losses) recognised in profit or
loss relating to assets and liabilities held at
31 Dec 2020
—
(24)
10
523
(1)
(10)
1,287
–  trading income/(expense) excluding net
interest income
—
(24)
—
523
(1)
—
1,287
–  net income from other financial instruments
designated at fair value
—
—
10
—
—
(10)
—
1Included in ‘financial investments: fair value gains/(losses)’ in the current year and ‘exchange differences’ in the consolidated statement of
comprehensive income.
Transfers between levels of the fair value hierarchy are deemed to occur at the end of each quarterly reporting period. Transfers into and
out of levels of the fair value hierarchy are primarily attributable to observability of valuation inputs and price transparency.
HSBC Bank plc Annual Report and Accounts 2021
145
Effect of changes in significant unobservable assumptions to reasonably possible alternatives
Sensitivity of Level 3 fair values to reasonably possible alternative assumptions
2021
2020
Reflected in
profit or loss
Reflected in OCI
Reflected in
profit or loss
Reflected in OCI
Favourable
changes
Un-
favourable
changes
Favourable
changes
Un-
favourable
changes
Favourable
changes
Un-
favourable
changes
Favourable
changes
Un-
favourable
changes
The group
£m
£m
£m
£m
£m
£m
£m
£m
Derivatives, trading assets and trading liabilities1
92
(70)
—
—
161
(145)
—
—
Designated and otherwise mandatorily measured at fair value
through profit or loss
247
(247)
—
—
226
(226)
—
—
Financial investments
15
(15)
51
(50)
26
(26)
49
(49)
Year ended 31 Dec
354
(332)
51
(50)
413
(397)
49
(49)
The bank
Derivatives, trading assets and trading liabilities1
93
(72)
—
—
170
(154)
—
—
Designated and otherwise mandatorily measured at fair value
through profit or loss
64
(64)
—
—
54
(54)
—
—
Financial investments
—
—
6
(5)
—
—
10
(10)
Year ended 31 Dec
157
(136)
6
(5)
224
(208)
10
(10)
1Derivatives, trading assets and trading liabilities are presented as one category to reflect the manner in which these instruments are
risk managed.
Sensitivity of Level 3 fair values to reasonably possible alternative assumptions by instrument type
2021
2020
Reflected in
profit or loss
Reflected in OCI
Reflected in
profit or loss
Reflected in OCI
Favourable
changes
Un-
favourable
changes
Favourable
changes
Un-
favourable
changes
Favourable
changes
Un-
favourable
changes
Favourable
changes
Un-
favourable
changes
£m
£m
£m
£m
£m
£m
£m
£m
Private equity including strategic investments
232
(234)
7
(7)
193
(195)
7
(7)
Asset-backed securities
39
(20)
1
—
64
(40)
5
(4)
Structured notes
6
(6)
—
—
23
(23)
—
—
Derivatives
29
(34)
—
—
73
(70)
—
—
Other portfolios
48
(38)
43
(43)
60
(69)
37
(38)
Year ended 31 Dec
354
(332)
51
(50)
413
(397)
49
(49)
The sensitivity analysis aims to measure a range of fair values consistent with the application of a 95% confidence interval.
Methodologies take account of the nature of the valuation technique employed, as well as the availability and reliability of observable
proxy and historical data.
When the fair value of a financial instrument is affected by more than one unobservable assumption, the above table reflects the most
favourable or the most unfavourable change from varying the assumptions individually.
Notes on the Financial Statements
146
HSBC Bank plc Annual Report and Accounts 2021
Key unobservable inputs to Level 3 financial instruments
Quantitative information about significant unobservable inputs in Level 3 valuations
Fair value
2021
2020
Assets
Liabilities
Valuation
techniques
Key
unobservable
inputs
Full range of inputs
Full range of inputs
£m
£m
Lower
Higher
Lower
Higher
Private equity including strategic investments
2,978
7
See below
See below
N/A
N/A
N/A
N/A
Asset-backed securities
592
—
–  CLO/CDO1
14
—
Market
proxy
Bid quotes
—
100
—
100
–  Other ABSs
578
—
Market
proxy
Bid quotes
—
100
—
100
Structured notes
—
2,120
–  equity-linked notes
—
1,856
Model –
Option
model
Equity
Volatility
6%
124%
0%
115%
Equity
Correlation
34%
99%
(4)%
79%
–  fund-linked notes
—
—
Model –
Option
model
Fund
Volatility
0%
21%
–  FX-linked notes
—
14
Model –
Option
model
FX Volatility
3%
99%
0%
23%
–  other
—
250
Derivatives
1,816
2,454
–  Interest rate derivatives:
594
749
securitisation swaps
211
439
Model –
Discounted
cash flow
Constant
Prepayment
Rate
5%
50%
6%
6%
long-dated swaptions
27
54
Model –
Option
model
IR Volatility
15%
35%
6%
28%
other
356
256
–  FX derivatives:
384
418
FX options
116
107
Model –
Option
model
FX Volatility
2%
99%
3%
40%
other
268
311
0%
70%
–  Equity derivatives:
706
1,140
long-dated single stock options
425
586
Model –
Option
model
Equity
Volatility
4%
138%
7%
70%
other2
281
554
–  Credit derivatives:
132
147
other
132
147
Other portfolios
2,332
574
–  repurchase agreements
329
—
Model –
Discounted
cash flow
IR Curve
1%
5%
—%
5%
–  other3
2,003
574
At 31 Dec
7,718
5,155
1Collateralised loan obligation/collateralised debt obligation.
2Other Equity Derivatives consists mainly of Swaps and OTC Options.
3Other consists of various instruments including investment in funds, repurchase agreement and bonds.
Private equity including strategic investments
Given the bespoke nature of the analysis in respect of each holding, it is not practical to quote a range of key unobservable inputs. The
key unobservable inputs would be price and correlation. The valuation approach includes using a range of inputs that include company
specific financials, traded comparable companies multiples, published net asset values and qualitative assumptions, which are not
directly comparable or quantifiable.
Prepayment rates
Prepayment rates are a measure of the anticipated future speed at which a loan portfolio will be repaid in advance of the due date. They
vary according to the nature of the loan portfolio and expectations of future market conditions, and may be estimated using a variety of
evidence, such as prepayment rates implied from proxy observable security prices, current or historical prepayment rates and
macroeconomic modelling.
Market proxy
Market proxy pricing may be used for an instrument when specific market pricing is not available, but there is evidence from
instruments with common characteristics. In some cases, it might be possible to identify a specific proxy, but more generally evidence
across a wider range of instruments will be used to understand the factors that influence current market pricing and the manner of that
influence.
HSBC Bank plc Annual Report and Accounts 2021
147
Volatility
Volatility is a measure of the anticipated future variability of a market price. It varies by underlying reference market price, and by strike
and maturity of the option.
Certain volatilities, typically those of a longer-dated nature, are unobservable and estimated from observable data. The range of
unobservable volatilities reflects the wide variation in volatility inputs by reference market price. The core range is significantly narrower
than the full range because these examples with extreme volatilities occur relatively rarely within the HSBC portfolio.
Correlation
Correlation is a measure of the inter-relationship between two market prices, and is expressed as a number between minus one and one.
It is used to value more complex instruments where the payout is dependent upon more than one market price. There is a wide range of
instruments for which correlation is an input, and consequently a wide range of both same-asset correlations and cross-asset
correlations is used. In general, the range of same-asset correlations will be narrower than the range of cross-asset correlations.
Unobservable correlations may be estimated based upon a range of evidence, including consensus pricing services, HSBC trade prices,
proxy correlations and examination of historical price relationships. The range of unobservable correlations quoted in the table reflects
the wide variation in correlation inputs by market price pair.
Credit spread
Credit spread is the premium over a benchmark interest rate required by the market to accept lower credit quality. In a discounted cash
flow model, the credit spread increases the discount factors applied to future cash flows, thereby reducing the value of an asset. Credit
spreads may be implied from market prices and may not be observable in more illiquid markets.
Inter-relationships between key unobservable inputs
Key unobservable inputs to Level 3 financial instruments may not be independent of each other. As described above, market variables
may be correlated. This correlation typically reflects the manner in which different markets tend to react to macroeconomic or other
events. Furthermore, the effect of changing market variables on the HSBC portfolio will depend on HSBC’s net risk position in respect of
each variable.
12
Fair values of financial instruments not carried at fair value
Fair values of financial instruments not carried at fair value and bases of valuation
Fair value
Carrying amount
Quoted market
price
Level 1
Observable
inputs
Level 2
Significant
unobservable inputs
Level 3
Total
The group
£m
£m
£m
£m
£m
At 31 Dec 2021
Assets
Loans and advances to banks
10,784
—
10,786
—
10,786
Loans and advances to customers
91,177
—
—
91,276
91,276
Reverse repurchase agreements – non-trading
54,448
—
54,448
—
54,448
Financial investments – at amortised cost
10
2
—
8
10
Liabilities
Deposits by banks
32,188
—
32,102
—
32,102
Customer accounts
205,241
—
205,236
—
205,236
Repurchase agreements – non-trading
27,259
—
27,259
—
27,259
Debt securities in issue
9,428
—
9,286
144
9,430
Subordinated liabilities
12,488
—
13,118
—
13,118
At 31 Dec 2020
Assets
Loans and advances to banks
12,646
—
12,649
—
12,649
Loans and advances to customers
101,491
—
—
101,584
101,584
Reverse repurchase agreements – non-trading
67,577
—
67,577
—
67,577
Financial investments – at amortised cost
15
—
7
7
14
Liabilities
Deposits by banks
34,305
—
34,249
—
34,249
Customer accounts
195,184
—
195,076
104
195,180
Repurchase agreements – non-trading
34,903
—
34,903
—
34,903
Debt securities in issue
17,371
—
17,094
273
17,367
Subordinated liabilities
13,764
—
14,638
—
14,638
Notes on the Financial Statements
148
HSBC Bank plc Annual Report and Accounts 2021
Fair values of financial instruments not carried at fair value and bases of valuation
Fair value
Carrying
amount
Quoted market
price
Level 1
Observable
inputs
Level 2
Significant
unobservable inputs
Level 3
Total
The bank
£m
£m
£m
£m
£m
At 31 Dec 2021
Assets
Loans and advances to banks
6,778
—
6,881
—
6,881
Loans and advances to customers
33,936
—
—
33,921
33,921
Reverse repurchase agreements – non-trading
39,708
—
39,708
—
39,708
Financial investments – at amortised cost
3,337
—
—
—
—
Liabilities
Deposits by banks
14,655
—
14,655
—
14,655
Customer accounts
124,706
—
124,706
—
124,706
Repurchase agreements – non-trading
22,344
—
22,344
—
22,344
Debt securities in issue
5,658
—
5,658
—
5,658
Subordinated liabilities
12,218
—
12,851
—
12,851
At 31 Dec 2020
Assets
Loans and advances to banks
8,063
—
8,064
—
8,064
Loans and advances to customers
43,241
—
—
43,222
43,222
Reverse repurchase agreements – non-trading
50,137
—
50,137
—
50,137
Financial investments – at amortised cost
2,214
—
2,246
—
2,246
Liabilities
Deposits by banks
17,484
—
17,483
—
17,483
Customer accounts
119,974
—
119,974
—
119,974
Repurchase agreements – non-trading
26,996
—
26,996
—
26,996
Debt securities in issue
15,356
—
15,356
—
15,356
Subordinated liabilities
13,360
—
14,160
—
14,160
Other financial instruments not carried at fair value are typically short-term in nature and reprice to current market rates frequently.
Accordingly, their carrying amount is a reasonable approximation of fair value. They include cash and balances at central banks and
items in the course of collection from and transmission to other banks, all of which are measured at amortised cost.
Valuation
Fair value is an estimate of 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. It does not reflect the economic benefits and costs that HSBC expects to flow
from an instrument’s cash flow over its expected future life. Our valuation methodologies and assumptions in determining fair values for
which no observable market prices are available may differ from those of other companies.
Loans and advances to banks and customers
To determine the fair value of loans and advances to banks and customers, loans are segregated, as far as possible, into portfolios of
similar characteristics. Fair values are based on observable market transactions, when available. When they are unavailable, fair values
are estimated using valuation models incorporating a range of input assumptions. These assumptions may include: value estimates from
third-party brokers reflecting over-the-counter trading activity; forward-looking discounted cash flow models, taking account of expected
customer prepayment rates, using assumptions that HSBC believes are consistent with those that would be used by market participants
in valuing such loans; new business rates estimates for similar loans; and trading inputs from other market participants including
observed primary and secondary trades. From time to time, we may engage a third-party valuation specialist to measure the fair value of
a pool of loans.
The fair value of loans reflects expected credit losses at the balance sheet date and estimates of market participants’ expectations of
credit losses over the life of the loans, and the fair value effect of repricing between origination and the balance sheet date. For credit
impaired loans, fair value is estimated by discounting the future cash flows over the time period they are expected to be recovered.
Financial investments
The fair values of listed financial investments are determined using bid market prices. The fair values of unlisted financial investments
are determined using valuation techniques that incorporate the prices and future earnings streams of equivalent quoted securities.
Deposits by banks and customer accounts
The fair values of on-demand deposits are approximated by their carrying value. For deposits with longer-term maturities, fair values are
estimated using discounted cash flows, applying current rates offered for deposits of similar remaining maturities.
Debt securities in issue and subordinated liabilities
Fair values are determined using quoted market prices at the balance sheet date where available, or by reference to quoted market
prices for similar instruments. When quoted market prices are unavailable, these instruments are valued using valuation techniques, the
inputs for which are derived from observable market data and, where relevant, from assumptions in respect of unobservable inputs.
Repurchase and reverse repurchase agreements – non-trading
Fair values approximate carrying amounts as balances are generally short dated.
HSBC Bank plc Annual Report and Accounts 2021
149
13
Financial assets designated and otherwise mandatorily measured at fair value through profit
or loss
The group
The bank
2021
2020
2021
2020
Designated at fair
value and otherwise
mandatorily measured
at fair value
Designated at fair
value and otherwise
mandatorily measured
at fair value
Designated at fair
value and otherwise
mandatorily measured
at fair value
Designated at fair value
and otherwise
mandatorily measured
at fair value
£m
£m
£m
£m
Securities
15,738
14,620
418
398
–  debt securities
2,584
2,918
146
116
–  equity securities
13,154
11,702
272
282
Loans and advances to banks and customers
2,613
1,285
2,498
1,152
Other
298
315
299
315
At 31 Dec
18,649
16,220
3,215
1,865
14
Derivatives
Notional contract amounts and fair values of derivatives by product contract type
Notional contract amount
Fair value – Assets
Fair value – Liabilities
Trading
Hedging
Trading
Hedging
Total
Trading
Hedging
Total
The group
£m
£m
£m
£m
£m
£m
£m
£m
Foreign exchange
4,737,254
4,045
49,775
266
50,041
(48,613)
(67)
(48,680)
Interest rate
8,727,934
39,553
99,744
144
99,888
(96,297)
(270)
(96,567)
Equities
498,980
—
9,718
—
9,718
(11,881)
—
(11,881)
Credit
134,440
—
1,582
—
1,582
(2,159)
—
(2,159)
Commodity and other
42,677
—
681
—
681
(770)
—
(770)
Offset (Note 28)
(20,689)
20,689
At 31 Dec 2021
14,141,285
43,598
161,500
410
141,221
(159,720)
(337)
(139,368)
Foreign exchange
4,378,792
5,297
60,341
191
60,532
(59,990)
(41)
(60,031)
Interest rate
8,922,892
40,258
155,752
619
156,371
(151,623)
(488)
(152,111)
Equities
481,638
—
10,857
—
10,857
(12,598)
—
(12,598)
Credit
198,306
—
1,874
—
1,874
(2,672)
—
(2,672)
Commodity and other
82,130
—
1,572
—
1,572
(1,816)
—
(1,816)
Offset (Note 28)
(29,996)
29,996
At 31 Dec 2020
14,063,758
45,555
230,396
810
201,210
(228,699)
(529)
(199,232)
The notional contract amounts of derivatives held for trading purposes and derivatives designated in hedge accounting relationships
indicate the nominal value of transactions outstanding at the balance sheet date; they do not represent amounts at risk.
Derivative asset and liability fair values decreased during 2021, driven by yield curve movements and changes in foreign exchange rates.
Notional contract amount
Fair value – Assets
Fair value – Liabilities
Trading
Hedging
Trading
Hedging
Total
Trading
Hedging
Total
The bank
£m
£m
£m
£m
£m
£m
£m
£m
Foreign exchange
4,713,729
3,829
48,651
247
48,898
(47,771)
(67)
(47,838)
Interest rate
6,846,965
27,206
80,798
193
80,991
(80,281)
(240)
(80,521)
Equities
478,832
—
9,153
—
9,153
(11,896)
—
(11,896)
Credit
132,582
—
1,558
—
1,558
(2,121)
—
(2,121)
Commodity and other
41,308
—
677
—
677
(765)
—
(765)
Offset
(15,490)
15,490
At 31 Dec 2021
12,213,416
31,035
140,837
440
125,787
(142,834)
(307)
(127,651)
Foreign exchange
4,329,503
5,059
58,925
178
59,103
(58,831)
(41)
(58,872)
Interest rate
7,019,211
25,135
132,021
691
132,712
(128,249)
(388)
(128,637)
Equities
467,114
—
10,441
—
10,441
(12,697)
—
(12,697)
Credit
195,578
—
1,849
—
1,849
(2,621)
—
(2,621)
Commodity and other
81,513
—
1,561
—
1,561
(1,805)
—
(1,805)
Offset
(23,600)
23,600
At 31 Dec 2020
12,092,919
30,194
204,797
869
182,066
(204,203)
(429)
(181,032)
Use of derivatives
We undertake derivatives activity for three primary purposes: to create risk management solutions for clients, to manage the portfolio
risks arising from client business, and to manage and hedge our own risks. 
Trading derivatives
Most of the group's derivative transactions relate to sales and trading activities. Sales activities include the structuring and marketing of
derivative products to customers to enable them to take, transfer, modify or reduce current or expected risks. Trading activities include
market-making and risk management. Market-making entails quoting bid and offer prices to other market participants for the purpose of
generating revenues based on spread and volume. Risk management activity is undertaken to manage the risk arising from client
transactions, with the principal purpose of retaining client margin. Other derivatives classified as held for trading include non-qualifying
hedging derivatives.
Notes on the Financial Statements
150
HSBC Bank plc Annual Report and Accounts 2021
Substantially all of the group's derivatives entered into with subsidiaries are managed in conjunction with financial liabilities designated
at fair value.
Derivatives valued using models with unobservable inputs
The difference between the fair value at initial recognition (the transaction price) and the value that would have been derived had the
valuation techniques used for subsequent measurement been applied at initial recognition, less subsequent releases, is in the following
table:
Unamortised balance of derivatives valued using models with significant unobservable inputs
The group
The bank
2021
2020
2021
2020
£m
£m
£m
£m
Unamortised balance at 1 Jan
60
42
56
40
Deferral on new transactions
156
105
155
103
Recognised in the income statement during the year:
(152)
(88)
(147)
(87)
–  amortisation
(88)
(57)
(88)
(57)
–  subsequent to unobservable inputs becoming observable
(2)
(2)
(2)
(2)
–  maturity, termination or offsetting derivative
(60)
(28)
(57)
(28)
–  risk hedged
(2)
(1)
—
—
Exchange differences and other
—
1
—
—
Unamortised balance at 31 Dec1
64
60
64
56
1This amount is yet to be recognised in the consolidated income statement.
Hedge accounting derivatives
The group applies hedge accounting to manage the following risks: interest rate and foreign exchange. The Report of the Directors –
Risk presents more details on how these risks arise and how they are managed by the group.
Fair value hedges
The group enters into fixed-for-floating-interest-rate swaps to manage the exposure to changes in fair value due to movements in market
interest rates on certain fixed rate financial instruments which are not measured at fair value through profit or loss, including debt
securities held and issued.
Hedging instrument by hedged risk
Hedging instrument
Carrying amount
The group
Notional amount1
Assets
Liabilities
Balance sheet presentation
Change in fair value2
Hedged risk
£m
£m
£m
£m
Interest rate3
24,486
139
(270)
Derivatives
159
At 31 Dec 2021
24,486
139
(270)
159
Interest rate3
29,737
617
(488)
Derivatives
(364)
At 31 Dec 2020
29,737
617
(488)
(364)
1The notional contract amounts of derivatives designated in qualifying hedge accounting relationships indicate the nominal value of transactions
outstanding at the balance sheet date; they do not represent amounts at risk.
2Used in effectiveness testing; comprising the full fair value change of the hedging instrument not excluding any component.
3The hedged risk ‘interest rate’ includes inflation risk.
Hedged item by hedged risk
Hedged item
Ineffectiveness
Carrying amount
Accumulated fair value
hedge adjustments included
in carrying amount2
Balance sheet presentation
Change in fair
value1
Recognised in
profit and loss
Profit and loss
presentation
The group
Assets
Liabilities
Assets
Liabilities
Hedged risk
£m
£m
£m
£m
£m
£m
Interest rate3
14,099
—
167
—
Financial assets at fair
value through other
comprehensive income
(278)
(9)
Net income
from financial
instruments
held for
trading or
managed on a
fair value
basis
1
—
(2)
—
Loans and advances to
banks
(2)
997
—
7
—
Loans and advances to
customers
(16)
—
2,844
—
71
Debt securities in issue
24
—
5,841
—
(77)
Subordinated liabilities and
deposits by banks4
104
At 31 Dec 2021
15,097
8,685
172
(6)
(168)
(9)
HSBC Bank plc Annual Report and Accounts 2021
151
Hedged item by hedged risk (continued)
Hedged item
Ineffectiveness
Carrying amount
Accumulated fair value hedge
adjustments included in
carrying amount2
Balance sheet presentation
Change in fair
value1
Recognised in
profit and loss
Profit and loss
presentation
The group
Assets
Liabilities
Assets
Liabilities
Hedged risk
£m
£m
£m
£m
£m
£m
Interest rate3
20,295
—
588
—
Financial assets at fair value
through other comprehensive
income
409
(14)
Net income
from financial
instruments
held for trading
or managed on
a fair value
basis
4
—
2
—
Loans and advances to banks
2
1,327
—
23
—
Loans and advances to
customers
15
—
576
—
108
Debt securities in issue
4
—
6,483
—
248
Subordinated liabilities and
deposits by banks4
(80)
At 31 Dec 2020
21,626
7,059
613
356
350
(14)
1Used in effectiveness assessment; comprising amount attributable to the designated hedged risk that can be a risk component.
2The accumulated amounts of fair value adjustments remaining in the statement of financial position for hedged items that have ceased to be
adjusted for hedging gains and losses were £21m (2020: £(29)m) for 'Financial assets at fair value through other comprehensive income', is £nil
(2020: £Nil) for 'Deposits by banks' and £19m (2020: £24m) for 'Debt securities in issue'.
3The hedged risk ‘interest rate’ includes inflation risk.
4The notional amount of non-dynamic fair value hedges was £5,886m (2020: £6,178m) of which the weighted-average maturity is March 2026
and the weighted average swap rate is (0.06)% (2020: 0.82%). £5,886m (2020: £6,178m) of these hedges are internal to HSBC Group and
composed by internal funding between HSBC Holdings and the group.
Hedging instrument by hedged risk
Hedging instrument
Carrying amount
Balance sheet
presentation
Change in fair value2
The bank
Notional amount1
Assets
Liabilities
Hedged risk
£m
£m
£m
£m
Interest rate3
18,016
188
(234)
Derivatives
27
At 31 Dec 2021
18,016
188
(234)
27
Hedged risk
£m
£m
£m
£m
Interest rate3
20,725
689
(387)
Derivatives
(280)
At 31 Dec 2020
20,725
689
(387)
(280)
1  The notional contract amounts of derivatives designated in qualifying hedge accounting relationships indicate the nominal value of transactions
outstanding at the balance sheet date; they do not represent amounts at risk.
2Used in effectiveness testing; comprising the full fair value change of the hedging instrument not excluding any component.
3The hedged risk ‘interest rate’ includes inflation risk.
Hedged item by hedged risk
Hedged item
Ineffectiveness
Carrying amount
Accumulated fair value
hedge adjustments included
in carrying amount2
Change in fair
value1
Recognised in
profit and loss
The bank
Assets
Liabilities
Assets
Liabilities
Balance sheet presentation
Profit and loss
presentation
Hedged risk
£m
£m
£m
£m
£m
£m
Interest rate3
9,232
—
159
—
Financial assets at fair
value through other
comprehensive income
(163)
(8)
Net income
from financial
instruments
held for
trading or
managed on a
fair value
basis
6
—
—
—
Loans and advances to
customers
—
—
2,844
—
71
Debt securities in issue
24
—
5,810
—
(77)
Subordinated liabilities
and deposits by banks4
104
At 31 Dec 2021
9,238
8,654
159
(6)
(35)
(8)
Notes on the Financial Statements
152
HSBC Bank plc Annual Report and Accounts 2021
Hedged item by hedged risk (continued)
Hedged item
Ineffectiveness
Carrying amount
Accumulated fair value hedge
adjustments included in carrying
amount2
Change in fair
value1
Recognised in
profit and loss
The bank
Assets
Liabilities
Assets
Liabilities
Balance sheet presentation
Profit and loss
presentation
Hedged risk
£m
£m
£m
£m
£m
£m
Interest rate3
13,711
—
438
—
Financial assets at fair value
through other
comprehensive income
344
(17)
Net income
from financial
instruments
held for trading
or managed on
a fair value basis
37
—
—
—
Loans and advances to
customers
—
—
576
—
108
Debt securities in issue
4
—
6,449
—
248
Subordinated liabilities and
deposits by banks4
(85)
At 31 Dec 2020
13,748
7,025
438
356
263
(17)
1Used in effectiveness assessment; comprising amount attributable to the designated hedged risk that can be a risk component.
2The accumulated amounts of fair value adjustments remaining in the statement of financial position for hedged items that have ceased to be
adjusted for hedging gains and losses were £21m (2020: £(29)m) for 'Financial assets at fair value through other comprehensive income', £nil
(2020: £Nil ) for 'Deposits by banks' and £19m (2020: £24m) for 'Debt securities in issue'.
3The hedged risk ‘interest rate’ includes inflation risk.
4The notional amount of non-dynamic fair value hedges was £5,886m (2020: £6,178m), of which the weighted-average maturity is March 2026
and the weighted average swap rate is (0.06)% (2020: 0.82%) .Those hedges are internal to HSBC Group and composed by internal funding
between HSBC Holdings and the group.
Cash flow hedges
The group's cash flow hedging instruments consist principally of interest rate swaps and cross-currency swaps that are used to manage
the variability in future interest cash flows of non-trading financial assets and liabilities, arising due to changes in market interest rates
and foreign-currency basis.
The group applies macro cash flow hedging for interest-rate risk exposures on portfolios of replenishing current and forecasted
issuances of non-trading assets and liabilities that bear interest at variable rates, including rolling such instruments. The amounts and
timing of future cash flows, representing both principal and interest flows, are projected for each portfolio of financial assets and
liabilities on the basis of their contractual terms and other relevant factors, including estimates of prepayments and defaults. The
aggregate cash flows representing both principal balances and interest cash flows across all portfolios are used to determine the
effectiveness and ineffectiveness. Macro cash flow hedges are considered to be dynamic hedges.
The group also hedges the variability in future cash-flows on foreign-denominated financial assets and liabilities arising due to changes
in foreign exchange market rates with cross-currency swaps; these are considered dynamic hedges.
Hedging instrument by hedged risk4
Hedging instrument
Hedged item
Ineffectiveness
Carrying amount
Balance sheet
presentation
Change in fair
value2
Change in fair
value3
Recognised in
profit and loss
Profit and loss
presentation
Notional
amount1
Assets
Liabilities
Hedged risk
£m
£m
£m
£m
£m
£m
Foreign exchange
4,042
266
(67)
Derivatives
127
127
—
Net income
from financial
instruments
held for
trading or
managed on a
fair value basis
Interest rate
15,067
5
(2)
(178)
(167)
(11)
At 31 Dec 2021
19,109
271
(69)
(51)
(40)
(11)
Foreign exchange
5,286
191
(41)
Derivatives
(30)
(30)
—
Net income from
financial
instruments held
for trading or
managed on a
fair value basis
Interest rate
10,521
2
—
117
115
2
At 31 Dec 2020
15,807
193
(41)
87
85
2
1The notional contract amounts of derivatives designated in qualifying hedge accounting relationships indicate the nominal value of transactions
outstanding at the balance sheet date; they do not represent amounts at risk.
2Used in effectiveness testing; comprising the full fair value change of the hedging instrument not excluding any component.
3Used in effectiveness assessment; comprising amount attributable to the designated hedged risk that can be a risk component.
4The amounts in the above table predominantly represent the bank's exposure.
Sources of hedge ineffectiveness may arise from basis risk including, but not limited to timing differences between the hedged items
and hedging instruments, and hedges using instruments with a non-zero fair value.
HSBC Bank plc Annual Report and Accounts 2021
153
Reconciliation of equity and analysis of other comprehensive income by risk type
Interest rate
Foreign exchange
£m
£m
Cash flow hedging reserve at 1 Jan 2021
147
11
Fair value (losses)/gains
(167)
127
Fair value (gains) reclassified from cash flow hedge reserve to income statement in respect of:
–  hedged items that have affected profit or loss
(25)
(177)
Income taxes
77
—
Cash flow hedging reserve at 31 Dec 2021
32
(39)
Cash flow hedging reserve at 1 Jan 2020
76
(36)
Fair value gains/(losses)
115
(29)
Fair value (gains)/losses reclassified from cash flow hedge reserve to income statement in respect of:
–  hedged items that have affected profit or loss
(4)
76
Income taxes
(40)
—
Cash flow hedging reserve at 31 Dec 2020
147
11
Interest rate benchmark reform: amendments to IFRS 9 and IAS 39 ‘Financial Instruments’
HSBC has applied both the first set of amendments (‘Phase 1’) and the second set of amendments (‘Phase 2’) to IFRS 9 and IAS 39
applicable to hedge accounting. The hedge accounting relationships that are affected by Phase 1 and Phase 2 amendments are
presented in the balance sheet as ‘Financial assets designated and otherwise mandatorily measured at fair value through other
comprehensive income’, ‘Loans and advances to customers’, ‘Debt securities in issue’ and ‘Deposits by banks’. The notional value of the
derivatives impacted by the Ibors reform, including those designated in hedge accounting relationships, is disclosed on page 25 in the
section ‘Financial instruments impacted by the Ibor reform’. For further details of Ibor transition, see ‘Top and emerging risks’ on page
22.
During 2021 the group transitioned all of its hedging instruments referencing sterling Libor, European Overnight Index Average rate
(‘Eonia’) and Japanese yen Libor. The group also transitioned some of the hedging instruments referencing US dollar Libor. There is no
significant judgment applied for these benchmarks to determine whether and when the transition uncertainty has been resolved.
The most significant Ibor benchmark in which the group continues to have hedging instruments is US dollar Libor. It is expected that the
transition out of US dollar Libor hedging derivatives will be largely completed by the end of 2022. These transitions do not necessitate
new approaches compared with any of the mechanisms used so far for transition and it will not be necessary to change the transition
risk management strategy.
For some of the Ibors included under the 'Other' header, in the table below, judgment has been needed to establish whether a transition
is required, since there are Ibor benchmarks which are subject to computation methodology improvements and insertion of fallback
provisions without full clarity being provided by their administrators on whether these Ibor benchmarks will be demised.
The notional amounts of Interest Rate derivatives designated in hedge accounting relationships do not represent the extent of the risk
exposure managed by the group but they are expected to be directly affected by market-wide Ibor reform and in scope of Phase 1
amendments and are shown in the table below. The cross-currency swaps designated in hedge accounting relationships and affected by
Ibor reform are not significant and have not been presented below.
Hedging instrument impacted by Ibor Reform
Hedging instrument
Impacted by Ibor Reform
NOT Impacted
by Ibor Reform
Notional
Amount1
EUR2
GBP
USD
Other3
Total
The group
£m
£m
£m
£m
£m
£m
£m
Fair Value Hedges
6,407
—
336
124
6,867
17,619
24,486
Cash Flow Hedges
5,877
—
—
—
5,877
9,190
15,067
At 31 Dec 2021
12,284
—
336
124
12,744
26,809
39,553
The bank
Fair Value Hedges
4,920
—
6
124
5,050
12,966
18,016
Cash Flow Hedges
—
—
—
—
—
9,190
9,190
At 31 Dec 2021
4,920
—
6
124
5,050
22,156
27,206
The group
£m
£m
£m
£m
£m
£m
£m
Fair Value Hedges
12,822
1,855
1,908
60
16,645
13,092
29,737
Cash Flow Hedges
6,111
1,552
183
—
7,846
2,675
10,521
At 31 Dec 2020
18,933
3,407
2,091
60
24,491
15,767
40,258
The bank
Fair Value Hedges
6,275
1,833
1,556
61
9,725
11,000
20,725
Cash Flow Hedges
—
1,552
183
—
1,735
2,675
4,410
At 31 Dec 2020
6,275
3,385
1,739
61
11,460
13,675
25,135
1The notional contract amounts of derivatives designated in qualifying hedge accounting relationships indicate the nominal value of transactions
outstanding at the balance sheet date; they do not represent amounts at risk.
2  The notional contract amounts of euro interest rate derivatives impacted by Ibor reform mainly comprise hedges with a Euribor benchmark,
which are Fair value hedges of £6,407m (31 December 2020: £7,606m) and Cash flow hedges £5,877m (31 December 2020: £6,111m).
3  Other benchmarks impacted by Ibor reform comprise derivatives that are expected to transition, but do not have a published cessation date.
Notes on the Financial Statements
154
HSBC Bank plc Annual Report and Accounts 2021
15
Financial investments
Carrying amount of financial investments
The group
The bank
2021
2020
2021
2020
£m
£m
£m
£m
Financial investments measured at fair value through other
comprehensive income
41,290
51,811
23,205
28,755
–  treasury and other eligible bills
2,229
3,286
1,441
2,194
–  debt securities
38,924
48,363
21,711
26,505
–  equity securities
103
98
53
56
–  other instruments1
34
64
—
—
Debt instruments measured at amortised cost
10
15
3,337
2,214
–  treasury and other eligible bills
2
5
—
—
–  debt securities2
8
10
3,337
2,214
At 31 Dec
41,300
51,826
26,542
30,969
1'Other instruments’ are comprised of loans and advances.
2    The £3.3bn (2020: £2.2bn) of debt securities in the bank relates to Senior Non-Preferred debt issued by HSBC Continental Europe to comply with
Single Resolution Board requirements on Minimum Required Eligible Liabilities.
Equity instruments measured at fair value through other comprehensive income
Instruments held at year end
Fair value
Dividends
recognised
Type of equity instruments
£m
£m
Business facilitation
76
—
Investments required by central institutions
26
—
Others
1
—
At 31 Dec 2021
103
—
Business facilitation
79
1
Investments required by central institutions
18
—
Others
1
—
At 31 Dec 2020
98
1
16
Assets pledged, collateral received and assets transferred
Assets pledged
Financial assets pledged as collateral
The group
The bank
2021
2020
2021
2020
£m
£m
£m
£m
Treasury bills and other eligible securities
990
2,382
990
1,543
Loans and advances to customers
18,403
20,597
—
—
Debt securities
20,247
24,069
11,415
14,432
Equity securities
23,612
21,304
25,452
21,604
Other
30,261
39,319
23,259
28,142
Assets pledged at 31 Dec
93,513
107,671
61,116
65,721
Financial assets pledged as collateral which the counterparty has the right to sell or repledge
The group
The bank
2021
2020
2021
2020
£m
£m
£m
£m
Trading assets
39,594
40,000
35,311
32,409
Financial investments
1,436
3,009
542
2,684
At 31 Dec
41,030
43,009
35,853
35,093
Assets pledged as collateral includes all assets categorised as encumbered in the disclosure on page 76.
The amount of assets pledged to secure liabilities may be greater than the book value of assets utilised as collateral. For example, in the
case of securitisations and covered bonds, the amount of liabilities issued, plus mandatory over-collateralisation, is less than the book
value of the pool of assets available for use as collateral. This is also the case where assets are placed with a custodian or a settlement
agent that has a floating charge over all the assets placed to secure any liabilities under settlement accounts.
These transactions are conducted under terms that are usual and customary to collateralised transactions including, where relevant,
standard securities lending and borrowing, repurchase agreements and derivative margining. The group places both cash and non-cash
collateral in relation to derivative transactions.
HSBC Bank plc Annual Report and Accounts 2021
155
Collateral received
The fair value of assets accepted as collateral, relating primarily to standard securities lending, reverse repurchase agreements and
derivative margining, that the group is permitted to sell or repledge in the absence of default was £202,794m (2020: £213,690m)
(the bank: 2021: £167,737m; 2020: £169,797m). The fair value of any such collateral sold or repledged was £151,378m (2020:
£154,486m) (the bank: 2021: £120,436m; 2020: £117,505m).
The group is obliged to return equivalent securities. These transactions are conducted under terms that are usual and customary to
standard securities lending, reverse repurchase agreements and derivative margining.
Assets transferred
The assets pledged include transfers to third parties that do not qualify for derecognition, notably secured borrowings such as debt
securities held by counterparties as collateral under repurchase agreements and equity securities lent under securities lending
agreements, as well as swaps of equity and debt securities. For secured borrowings, the transferred asset collateral continues to be
recognised in full and a related liability, reflecting the group’s obligation to repurchase the assets for a fixed price at a future date is also
recognised on the balance sheet. Where securities are swapped, the transferred asset continues to be recognised in full. There is no
associated liability as the non-cash collateral received is not recognised on the balance sheet. The group is unable to use, sell or pledge
the transferred assets for the duration of these transactions, and remains exposed to interest rate risk and credit risk on these pledged
assets. The counterparty’s recourse is not limited to the transferred assets.
Transferred financial assets not qualifying for full derecognition and associated financial liabilities
Carrying amount of:
Transferred assets
Associated liabilities
The group
£m
£m
At 31 Dec 2021
Repurchase agreements
11,710
11,732
Securities lending agreements
29,321
2,129
At 31 Dec 2020
Repurchase agreements
14,232
14,264
Securities lending agreements
28,777
87
Transferred financial assets not qualifying for full derecognition and associated financial liabilities
Carrying amount of:
Transferred assets
Associated liabilities
The bank
£m
£m
At 31 Dec 2021
Repurchase agreements
4,489
4,488
Securities lending agreements
31,365
2,132
At 31 Dec 2020
Repurchase agreements
5,315
5,315
Securities lending agreements
29,778
82
17
Interests in associates and joint ventures
Principal associates of the group and the bank
Business Growth Fund Group plc (‘BGF’) is a principal associate of the group. BGF is an independent company, established in 2011 to
provide investment to growing small to medium-sized British businesses. BGF is backed by five of the UK’s main banking groups:
Barclays, HSBC, Lloyds, RBS and Standard Chartered. At 31 December 2021, the group had a 24.62% interest in the equity capital of
BGF. Share of profit in BGF is £192m (2020: £5m) and carrying amount of interest in BGF is £702m (2020: £471m).
Interests in joint ventures
A list of all associates is set out on page 177.
18
Investments in subsidiaries
Main subsidiaries of HSBC Bank plc
At 31 Dec 2021
Country of incorporation
or registration
HSBC Bank plc’s interest
in equity capital
Share class
%
HSBC Investment Bank Holdings Limited
England and Wales
100.00
£1 Ordinary
HSBC Asset Finance (UK) Limited
England and Wales
100.00
£1 Ordinary
HSBC Life (UK) Limited
England and Wales
100.00
£1 Ordinary
HSBC Trinkaus & Burkhardt AG
Germany
100.00
Stückaktien no par value
HSBC Continental Europe
France
99.99
€5 Actions
HSBC Bank Malta p.l.c
Malta
70.03
€0.30 Ordinary
All the above prepare their financial statements up to 31 December. Details of all group subsidiaries, as required under Section 409 of
the Companies Act 2006, are set out in Note 36. The principal countries of operation are the same as the countries of incorporation.
Notes on the Financial Statements
156
HSBC Bank plc Annual Report and Accounts 2021
Impairment testing of investments in subsidiaries
At each reporting period end, HSBC Bank plc reviews investments in subsidiaries for indicators of impairment. An impairment is
recognised when the carrying amount exceeds the recoverable amount for that investment.
The recoverable amount is the higher of the investment’s fair value less costs of disposal and its value in use. The value in use is
calculated by discounting management’s cash flow projections for the investment.
The cash flows represent the Free Cash Flows ('FCF') based on the subsidiary’s binding capital requirements.
•The cash flow projections for each investment are based on the latest approved plans, which includes forecast capital available for
distribution based on the capital requirements of the subsidiary taking into account minimum and core capital requirements. A long
term growth rate is used to extrapolate the free cash flows in perpetuity.
•The growth rate reflects inflation for the country within which the investment operates and is based on the long-term average growth
rates.
•The rate used to discount the cash flows is based on the cost of capital assigned to each investment, which is derived using a capital
asset pricing model (‘CAPM’). CAPM depends on a number of inputs reflecting financial and economic variables, including the risk-
free rate and a premium to reflect the inherent risk of the business being evaluated. These variables are based on the market’s
assessment of the economic variables and management’s judgement. The discount rates for each investment are refined to reflect
the rates of inflation for the countries within which the investment operates. In addition, for the purposes of testing investments for
impairment, management supplements this process by comparing the discount rates derived using the internally generated CAPM,
with cost of capital rates produced by external sources for businesses operating in similar markets.
Similar to 2020, an impairment test was performed in 2021 and it is concluded that no impairment is required to our investment in HSBC
Continental Europe.
Impairment test results
Investments
Carrying amount
Value in use
Discount rate
Long-term growth rate
Headroom
HSBC Continental Europe
£m
£m
%
%
£m
At 31 Dec 2021
4,331
4,429
8.34
1.53
98
At 31 Dec 2020
4,331
4,649
9.65
1.51
318
Sensitivities of key assumptions in calculating VIU
At 31 December 2021, the investment in HSBC Continental Europe was sensitive to reasonably possible changes in the key assumptions
supporting the recoverable amount.
In making an estimate of reasonably possible changes to assumptions, management considers the available evidence in respect of each
input to the model. These include the external range of observable discount rates, historical performance against forecast, and risks
attaching to the key assumptions underlying cash flow projections.
The following table presents a summary of the key assumptions underlying the most sensitive inputs to the model for HSBC Continental
Europe, the key risks attaching to each, and details of a reasonably possible change to assumptions where, in the opinion of
management, these could result in an impairment.
Reasonably possible changes in key assumptions
Input
Key assumptions
Associated risks
Reasonably possible change
Investment
HSBC Continental
Europe
Free Cash
Flows
projections
•Level of interest rates and yield
curves.
•Competitors’ positions within
the market.
•Level and change in unemployment
rates.
•Customer remediation and
regulatory actions.
•Achievement of strategic actions
relating to revenue and costs.
•FCF projections decrease
by 10%.
•Achievement of revenue and cost
targets
Discount
rate
•Discount rate used is a reasonable
estimate of a suitable market rate
for the profile of the business.
•External evidence arises to
suggest that the rate used is not
appropriate to the business.
•Discount rate increases by 1%.
Long-term
growth rates
•Business growth will reflect
inflation rates of the country the
subsidiary conducts business in the
long term.
•Growth does not match inflation 
or there is a fall in inflation 
forecasts.
•Real inflation does not occur or is
not reflected in performance.
Sensitivity of VIU to reasonably possible changes in key assumptions and changes to current assumptions to reduce headroom to nil
Increase/(decrease)
Investments
Carrying amount
Value in use
Discount rate
Free Cash flows
Long-term growth rate
At 31 Dec 2021
£m
£m
bps
%
bps
HSBC Continental Europe
4,331
4,429
16
(2.3)
(22)
HSBC Bank plc Annual Report and Accounts 2021
157
19
Structured entities
The group is mainly involved with both consolidated and unconsolidated structured entities through the securitisation of financial assets,
conduits and investment funds, established either by the group or a third party.
Consolidated structured entities
Total assets of the group’s consolidated structured entities, split by entity type
Conduits
Securitisations
HSBC managed
funds 1
Other1
Total
£m
£m
£m
£m
£m
At 31 Dec 2021
3,233
287
4,653
568
8,741
At 31 Dec 2020
5,023
423
3,885
1,079
10,410
1Balances from 2020 have been re-presented to disclose a consistent application of the 'HSBC and third-party managed funds categories.
Conduits
The group has established and manages two types of conduits: securities investment conduits (‘SICs’) and multi-seller conduits.
Securities investment conduits
The SICs purchase highly rated ABSs to facilitate tailored investment opportunities.
At 31 December 2021, Solitaire, the group's principal SIC held £1.2bn of ABSs (2020: £1.4bn). It is currently funded entirely by
commercial paper (‘CP’) issued to the group. At 31 December 2021, the group held £1.3bn of CP (2020: £1.6bn).
Multi-seller conduits
The group's multi-seller conduit was established to provide access to flexible market-based sources of finance for its clients. Currently,
the group bears risk equal to transaction-specific facility offered to the multi-seller conduits, amounting to £4.6bn at 31 December 2021
(2020: £6.5bn). First loss protection is provided by the originator of the assets, and not by the group, through transaction-specific credit
enhancements. A layer of secondary loss protection is provided by the group in the form of programme-wide enhancement facilities.
Securitisations
The group uses structured entities to securitise customer loans and advances it originates in order to diversify the sources of funding for
asset origination and capital efficiency purposes. The loans and advances are transferred by the group to the structured entities for cash
or synthetically through credit default swaps, and the structured entities issue debt securities to investors.
HSBC managed funds
The group together with other HSBC entities has established a number of money market and non-money market funds. Where it is
deemed to be acting as principal rather than agent in its role as investment manager, the group controls these funds.
Other
The group has entered into a number of transactions in the normal course of business, which include asset and structured finance
transactions where it has control of the structured entity. In addition, the group is deemed to control a number of third-party managed
funds through its involvement as a principal in the funds.
Unconsolidated structured entities
The term ‘unconsolidated structured entities’ refers to all structured entities not controlled by the group. The group enters into
transactions with unconsolidated structured entities in the normal course of business to facilitate customer transactions and for specific
investment opportunities.
Notes on the Financial Statements
158
HSBC Bank plc Annual Report and Accounts 2021
Nature and risks associated with the group’s interests in unconsolidated structured entities
Securitisa-
tions
HSBC managed
funds1
Non-HSBC
managed funds1
Other
Total
Total asset values of the entities (£m)
0 – 400
2
157
1,194
14
1,367
400 – 1,500
—
81
774
—
855
1,500 – 4,000
—
16
354
—
370
4,000 – 20,000
—
12
149
—
161
20,000+
—
2
9
—
11
Number of entities at 31 Dec 2021
2
268
2,480
14
2,764
£m
£m
£m
£m
£m
Total assets in relation to the group's interests in the unconsolidated structured entities
193
4,414
5,225
631
10,463
–  trading assets
—
1
1,807
—
1,808
–  financial assets designated and otherwise mandatorily measured at fair value
—
4,409
3,273
—
7,682
–  loans and advances to customers
193
—
49
631
873
–  financial investments
—
4
96
—
100
Total liabilities in relation to the group’s interests in the unconsolidated structured entities
—
—
2
—
2
Other off-balance sheet commitments
20
4
916
38
978
The group's maximum exposure at 31 Dec 2021
213
4,418
6,139
669
11,439
Total asset values of the entities (£m)
0 – 400
5
176
1,228
16
1,425
400 – 1,500
—
60
645
—
705
1,500 – 4,000
—
28
351
—
379
4,000 – 20,000
—
22
271
—
293
20,000+
—
4
39
—
43
Number of entities at 31 Dec 2020
5
290
2,534
16
2,845
£m
£m
£m
£m
£m
Total assets in relation to the group’s interests in the unconsolidated structured entities
686
3,884
5,985
346
10,901
–  trading assets
—
3
2,365
—
2,368
–  financial assets designated at fair value
—
3,849
3,247
—
7,096
–  loans and advances to customers
686
—
—
346
1,032
–  financial investments
—
32
373
—
405
Total liabilities in relation to group‘s interests in the unconsolidated structured entities
—
—
1
—
1
Other off-balance sheet commitments
40
1
1,450
—
1,491
The group's maximum exposure at 31 Dec 2020
726
3,885
7,434
346
12,391
1Balances from 2020 have been re-presented to disclose a consistent application of the HSBC and third-party managed funds categories.
The maximum exposure to loss from the group’s interests in unconsolidated structured entities represents the maximum loss it could
incur as a result of its involvement with these entities regardless of the probability of the loss being incurred.
•For commitments, guarantees and written credit default swaps, the maximum exposure to loss is the notional amount of potential
future losses.
•For retained and purchased investments and loans to unconsolidated structured entities, the maximum exposure to loss is the
carrying value of these interests at the balance sheet reporting date.
The maximum exposure to loss is stated gross of the effects of hedging and collateral arrangements entered into to mitigate the group‘s
exposure to loss.
Securitisations
The group has interests in unconsolidated securitisation vehicles through holding notes issued by these entities. In addition, the group
has investments in ABSs issued by third-party structured entities.
HSBC managed funds
The group together with other HSBC entities establishes and manages money market funds and non-money market investment funds to
provide customers with investment opportunities. The group, as fund manager, may be entitled to receive management and
performance fees based on the assets under management. The group may also retain units in these funds.
Non-HSBC managed funds
The group purchases and holds units of third-party managed funds in order to facilitate business and meet customer needs.
Other
The group has established structured entities in the normal course of business, such as structured credit transactions for customers, to
provide finance to public and private sector infrastructure projects, and for asset and structured finance transactions.
In addition to the interests disclosed above, the group enters into derivative contracts, reverse repos and stock borrowing transactions
with structured entities. These interests arise in the normal course of business for the facilitation of third-party transactions and risk
management solutions.
Group sponsored structured entities
The amount of assets transferred to and income received from such sponsored entities during 2021 and 2020 was not significant.
HSBC Bank plc Annual Report and Accounts 2021
159
20
Goodwill and intangible assets
The group
The bank
2021
2020
2021
2020
£m
£m
£m
£m
Goodwill
—
—
19
19
Present value of in-force long-term insurance business
811
647
—
—
Other intangible assets1
83
119
15
12
At 31 Dec
894
766
34
31
1Included within the group's other intangible assets is internally generated software with a net carrying value of £77m (2020: £115m). During
2021, capitalisation of internally generated software was £46m (2020: £150m), impairment was £(45)m (2020: £(790)m) and amortisation was
£15m (2020: £94m).
Present value of in-force long-term insurance business
When calculating the present value of in-force long-term (‘PVIF’) insurance business, expected cash flows are projected after adjusting
for a variety of assumptions made by each insurance operation to reflect local market conditions and management’s judgement of future
trends and uncertainty in the underlying assumptions is reflected by applying margins (as opposed to a cost of capital methodology)
including valuing the cost of policyholder options and guarantees using stochastic techniques.
Actuarial Control Committees of each key insurance entity meet on a quarterly basis to review and approve PVIF assumptions. All
changes to non-economic assumptions, economic assumptions that are not observable and model methodology must be approved by
the Actuarial Control Committee.
Movements in PVIF
2021
2020
£m
£m
PVIF at 1 Jan
647
715
Change in PVIF of long-term insurance business
200
(95)
–  value of new business written during the year
67
43
–  expected return1
(70)
(74)
–  assumption changes and experience variances2 (see below)
202
(73)
–  other adjustments
1
9
Exchange differences
(36)
27
PVIF at 31 Dec
811
647
1‘Expected return’ represents the unwinding of the discount rate and reversal of expected cash flows for the period.
2Represents the effect of changes in assumptions on expected future profits and the difference between assumptions used in the previous PVIF
calculation and actual experience observed during the year to the extent that this affects future profits. The gain of £202m (2020: loss of £73m)
was driven mainly by an increase in yields and improved equity market performances during 2021.
Key assumptions used in the computation of PVIF for main life insurance operations
Economic assumptions are set in a way that is consistent with observable market values. The valuation of PVIF is sensitive to observed
market movements and the impact of such changes is included in the sensitivities presented below.
2021
2020
UK
France1
UK
France1
%
%
%
%
Weighted average risk-free rate
0.95
0.69
0.29
0.34
Weighted average risk discount rate
0.95
1.55
0.29
1.34
Expense inflation
3.80
1.80
2.80
1.60
1For 2021, the calculation of France’s PVIF assumes a risk discount rate of 1.55% (2020: 1.34%) plus a risk margin of £156m (2020: £159m).
Sensitivity to changes in economic assumptions
The group sets the risk discount rate applied to the PVIF calculation by starting from a risk-free rate curve and adding explicit allowances
for risks not reflected in the best estimate cash flow modelling. Where the insurance operations provide options and guarantees to
policyholders, the cost of these options and guarantees is accounted for as a deduction from the present value of in-force 'PVIF' asset,
unless the cost of such guarantees is already allowed for as an explicit addition to liabilities under insurance contracts. See page 86 for
further details of these guarantees and the impact of changes in economic assumptions on our insurance manufacturing subsidiaries.
Sensitivity to changes in non-economic assumptions
Policyholder liabilities and PVIF are determined by reference to non-economic assumptions including mortality and/or morbidity, lapse
rates and expense rates. See page 87 for further details on the impact of changes in non-economic assumptions on our insurance
manufacturing operations.
Notes on the Financial Statements
160
HSBC Bank plc Annual Report and Accounts 2021
21
Prepayments, accrued income and other assets
The group
The bank
2021
2020
2021
2020
£m
£m
£m
£m
Cash collateral and margin receivables
29,947
39,702
22,961
28,142
Settlement accounts
4,960
7,138
4,604
5,153
Bullion
2,253
3,597
2,253
3,593
Prepayments and accrued income
1,365
1,308
531
537
Property, plant and equipment
846
899
10
12
Right-of-use assets
251
390
37
59
Reinsurers’ share of liabilities under insurance contracts (Note 4)
146
165
—
—
Employee benefit assets (Note 5)
54
30
43
29
Endorsements and acceptances
196
97
172
69
Assets held for sale
9
90
—
—
Other accounts
3,100
2,149
879
1,181
At 31 Dec
43,127
55,565
31,490
38,775
Prepayments, accrued income and other assets include £39,064m (2020: £50,027m) of financial assets, the majority of which are
measured at amortised cost.
Impairment testing
Impairment of other intangible assets is assessed in accordance with our policy explained in Note 1.2(n) by comparing the net carrying
amount of CGUs containing intangible assets with their recoverable amounts. No significant impairment was recognised during the year.
In 2020, having considered the pervasive macroeconomic deterioration caused by the outbreak of Covid-19, along with the impact of
forecast profitability, £193m of tangible asset were impaired, primarily Right of Use ('ROU') assets for leased office, commercial and
retail branches and fixtures and fittings. This impairment reflected underperformance and deterioration in the future forecasts,
substantially relating to prior periods.
Assets held for sale
The group
2021
2020
£m
£m
Property, plant and equipment1
6
86
Assets of disposal groups held for sale
3
4
Assets classified as held for sale at 31 Dec
9
90
12020 includes HSBC Trinkaus & Burkhardt AG’s one property as held for sale.
22
Trading liabilities
The group
The bank
2021
2020
2021
2020
£m
£m
£m
£m
Deposits by banks1
3,122
4,324
3,141
4,303
Customer accounts1
6,386
7,744
6,216
7,528
Other debt securities in issue
1,324
1,156
30
21
Other liabilities – net short positions in securities
35,601
31,005
21,774
14,821
At 31 Dec
46,433
44,229
31,161
26,673
1'Deposits by banks' and 'Customer accounts' include repos, stock lending and other amounts.
23
Financial liabilities designated at fair value
The group
The bank
2021
2020
2021
2020
£m
£m
£m
£m
Deposits by banks and customer accounts
4,302
3,273
4,245
3,204
Liabilities to customers under investment contracts
1,032
944
—
—
Debt securities in issue
26,049
34,228
14,399
19,136
Subordinated liabilities (Note 26)
2,225
2,347
2,225
2,347
At 31 Dec
33,608
40,792
20,869
24,687
The group
The carrying amount of financial liabilities designated at fair value was £(1,568)m lower than the contractual amount at maturity
(2020: £3,351m higher). The cumulative amount of change in fair value attributable to changes in credit risk was a loss of £165m (2020:
loss of £189m).
HSBC Bank plc Annual Report and Accounts 2021
161
The bank
The carrying amount of financial liabilities designated at fair value was £(2,146)m lower than the contractual amount at maturity
(2020: £2,525m higher). The cumulative amount of change in fair value attributable to changes in credit risk was a loss of £72m (2020:
loss of £76m).
24
Accruals, deferred income and other liabilities
The group
The bank
2021
2020
2021
2020
£m
£m
£m
£m
Cash collateral and margin payables
32,309
42,273
24,204
31,810
Settlement accounts
4,767
4,900
3,996
4,451
Accruals and deferred income
1,507
1,566
859
826
Amount due to investors in funds consolidated by the group
1,315
1,051
—
—
Lease liabilities
386
558
55
82
Employee benefit liabilities (Note 5)
196
288
74
75
Share-based payment liability to HSBC Holdings
129
104
102
76
Endorsements and acceptances
189
89
172
70
Other liabilities
2,658
2,566
708
1,181
At 31 Dec
43,456
53,395
30,170
38,571
For the group, accruals, deferred income and other liabilities include £42,887m (2020: £52,754m), and for the bank £29,913m
(2020: £38,291m) of financial liabilities, the majority of which are measured at amortised cost.
25
Provisions
Restructuring
costs
Legal
proceedings and
regulatory
matters
Customer
remediation
Other provisions
Total
The group
£m
£m
£m
£m
£m
Provisions (excluding contractual commitments)
At 1 Jan 2021
309
237
25
103
674
Additions
91
32
11
86
220
Amounts utilised
(170)
(63)
(10)
(32)
(275)
Unused amounts reversed
(63)
(25)
(6)
(58)
(152)
Exchange and other movements
(3)
(6)
1
—
(8)
At 31 Dec 2021
164
175
21
99
459
Contractual commitments1
At 1 Jan 2021
187
Net change in expected credit loss provision and other movements
(84)
At 31 Dec 2021
103
Total Provisions
At 31 Dec 2020
861
At 31 Dec 2021
562
Provisions (excluding contractual commitments)
At 1 Jan 2020
94
211
29
104
438
Additions
315
68
5
66
454
Amounts utilised
(80)
(51)
(4)
(39)
(174)
Unused amounts reversed
(18)
(2)
(4)
(28)
(52)
Exchange and other movements
(2)
11
(1)
—
8
At 31 Dec 2020
309
237
25
103
674
Contractual commitments1
At 1 Jan 2020
102
Net change in expected credit loss provision and other movements
85
At 31 Dec 2020
187
Total Provisions
At 31 Dec 2019
540
At 31 Dec 2020
861
1The contractual commitments include provision for off-balance sheet loan commitments and guarantees, for which expected credit losses are
provided under IFRS 9. Further analysis of the movement in the expected credit loss is disclosed within the 'Reconciliation of changes in gross
carrying/nominal amount and allowances for loans and advances to banks and customers including loan commitments and financial guarantees'
table on page 46.
Notes on the Financial Statements
162
HSBC Bank plc Annual Report and Accounts 2021
Restructuring
costs
Legal
proceedings and
regulatory
matters
Customer
remediation
Other provisions
Total
The bank
£m
£m
£m
£m
£m
Provisions (excluding contractual commitments)
At 1 Jan 2021
39
198
17
52
306
Additions
54
23
7
30
114
Amounts utilised
(54)
(32)
(8)
(15)
(109)
Unused amounts reversed
(26)
(24)
(4)
(40)
(94)
Unwinding of discounts
—
—
—
—
—
Exchange and other movements
(1)
(10)
1
—
(10)
At 31 Dec 2021
12
155
13
27
207
Contractual commitments1
At 1 Jan 2021
107
Net change in expected credit loss provision and other
movements
(64)
At 31 Dec 2021
43
Total Provisions
At 31 Dec 2020
413
At 31 Dec 2021
250
Provisions (excluding contractual commitments)
At 1 Jan 2020
41
173
20
36
270
Additions
56
63
2
39
160
Amounts utilised
(45)
(47)
(3)
(8)
(103)
Unused amounts reversed
(6)
—
(1)
(15)
(22)
Exchange and other movements
(7)
9
(1)
—
1
At 31 Dec 2020
39
198
17
52
306
Contractual commitments1
At 1 Jan 2020
38
Net change in expected credit loss provision and other
movements
69
At 31 Dec 2020
107
Total Provisions
At 31 Dec 2019
308
At 31 Dec 2020
413
1The contractual commitments provision includes off-balance sheet loan commitments and guarantees, for which expected credit losses are
provided under IFRS 9. Further analysis of the movement in the expected credit loss is disclosed within the 'Reconciliation of changes in gross
carrying/nominal amount and allowances for loans and advances to banks and customers including loan commitments and financial guarantees'
table on page 46.
Restructuring costs
These provisions comprise the estimated cost of restructuring, including redundancy costs where an obligation exists. Additions made
during the year relate to formal restructuring plans made within the group. The majority of the restructuring costs recognised for 2021
relate to the transformation programme initiated by HSBC Continental Europe.
Legal proceedings and regulatory matters
Further details of legal proceedings and regulatory matters are set out in Note 32. Legal proceedings include civil court, arbitration or
tribunal proceedings brought against HSBC companies (whether by way of claim or counterclaim), or civil disputes that may, if not
settled, result in court, arbitration or tribunal proceedings. Regulatory matters refer to investigations, reviews and other actions carried
out by, or in response to the actions of, regulatory or law enforcement agencies in connection with alleged wrongdoing.
26
Subordinated liabilities
Subordinated liabilities
The group
The bank
2021
2020
2021
2020
£m
£m
£m
£m
At amortised cost
12,488
13,764
12,218
13,360
–  subordinated liabilities
11,788
13,064
12,218
13,360
–  preferred securities
700
700
—
—
Designated at fair value (Note 23)
2,225
2,347
2,225
2,347
–  subordinated liabilities
2,225
2,347
2,225
2,347
At 31 Dec
14,713
16,111
14,443
15,707
Subordinated liabilities rank behind senior obligations and consist of capital instruments and other instruments. Capital instruments
generally count towards the capital base of the group and may be called and redeemed by the group subject to prior notification to the
PRA and, where relevant, the consent of the local banking regulator. If not redeemed at the first call date, coupons payable may step up
or become floating rate based on interbank rates. On capital instruments other than floating rate notes, interest is payable at fixed rates
of up to 7.65%.
HSBC Bank plc Annual Report and Accounts 2021
163
The balance sheet amounts disclosed below are presented on an IFRS basis and do not reflect the amount that the instruments
contribute to regulatory capital due to the inclusion of issuance costs, regulatory amortisation and regulatory eligibility limits prescribed
in the grandfathering provisions under CRD IV.
Subordinated liabilities of the group
Carrying amount
2021
2020
£m
£m
Capital instruments
Additional tier 1 instruments guaranteed by the bank
£700m
5.844% Non-cumulative Step-up Perpetual Preferred Securities1
700
700
Tier 2 instruments
$450m
Subordinated Floating Rate Notes 20212
—
330
$750m
3.43% Subordinated Loan 2022
558
569
$2,000m
3.5404% Subordinated Loan 20233
—
1,534
£300m
6.5% Subordinated Notes 2023 
300
300
€1,500m
Floating Rate Subordinated Loan 2023
1,260
1,347
€2,000m
1.125% Subordinated Loan 20243
—
1,856
€1,500m
Floating Rate Subordinated Loan 2024
1,260
1,347
€2,000m
1.728% Subordinated Loan 20243
—
1,836
$300m
7.65% Subordinated Notes 2025 
222
220
$750m
HSBC Bank plc 4.186% Subordinated Loan 2027
604
633
€1,250m
1.4648% Subordinated Loan 20273
—
1,200
€300m
Floating Rate Subordinated Loan 2027
252
269
£200m
Floating Rate Subordinated Loan 2028
200
200
€300m
Floating Rate Subordinated Loan 2028
252
269
€260m
Floating Rate Subordinated Loan 2029
218
233
£350m
5.375% Callable Subordinated Step-up Notes 20304
398
427
$2,000m
HSBC Bank plc 1.625% Subordinated Loan 20313
1,457
—
€2,000m
HSBC Bank plc 0.375% Subordinated Loan 20313
1,658
—
€2,000m
HSBC Bank plc 0.375% Subordinated Loan 20313
1,658
—
€1,250m
HSBC Bank plc 0.25% Subordinated Loan 20313
1,036
—
£500m
5.375% Subordinated Notes 2033 
665
719
£225m
6.25% Subordinated Notes 2041 
224
224
£600m
4.75% Subordinated Notes 2046 
595
594
$750m
Undated Floating Rate Primary Capital Notes 
554
549
$500m
Undated Floating Rate Primary Capital Notes 
369
366
$300m
Undated Floating Rate Primary Capital Notes (Series 3) 
222
220
Other Tier 2 instruments each less than £100m 
51
169
At 31 Dec
14,713
16,111
1The interest rate payable after November 2031 is the sum of the compounded daily Sonia rate plus 2.0366%.
2In February 2021, HSBC Bank Plc redeemed the USD450m Subordinated Floating Rate note 2021.
3In March 2021, HSBC Bank plc redeemed its fixed rate subordinated loan and simultaneously drew in full a new fixed rate subordinated loan
from HSBC Holdings plc.
4The interest rate payable after November 2025 is the sum of the compounded daily Sonia rate plus 1.6193%.
Footnotes 1 and 4 both relate to instruments that are redeemable at the option of the issuer on the date of the change in the distribution or interest
rate, and on subsequent rate reset and payment dates in some cases, subject to prior notification to the PRA.
27
Maturity analysis of assets, liabilities and off-balance sheet commitments
Contractual maturity of financial liabilities
The balances in the table below do not agree directly with those in our consolidated balance sheet as the table incorporates, on an
undiscounted basis, all cash flows relating to principal and future coupon payments (except for trading liabilities and derivatives not
treated as hedging derivatives).
Undiscounted cash flows payable in relation to hedging derivative liabilities are classified according to their contractual maturities.
Trading liabilities and derivatives not treated as hedging derivatives are included in the ‘Due not more than 1 month’ time bucket and not
by contractual maturity.
In addition, loans and other credit-related commitments, and financial guarantees are generally not recognised on our balance sheet. The
undiscounted cash flows potentially payable under loan and other credit-related commitments and financial guarantees are classified on
the basis of the earliest date they can be called.
Notes on the Financial Statements
164
HSBC Bank plc Annual Report and Accounts 2021
Cash flows payable under financial liabilities by remaining contractual maturities
Due not more
than 1 month
Due over 1
month but not
more than 3
months
Due between
3 and 12 months
Due between
1 and 5 years
Due after
5 years
Total
The group
£m
£m
£m
£m
£m
£m
Deposits by banks
16,783
1,555
1,106
12,277
401
32,122
Customer accounts
196,609
5,599
2,770
199
101
205,278
Repurchase agreements – non-trading
24,273
1,924
1,061
7
—
27,265
Trading liabilities
46,433
—
—
—
—
46,433
Financial liabilities designated at fair value
9,358
2,790
4,310
8,269
11,873
36,600
Derivatives
139,040
46
104
406
581
140,177
Debt securities in issue
2,755
2,952
2,145
1,328
335
9,515
Subordinated liabilities
14
62
123
3,969
10,734
14,902
Other financial liabilities
40,292
423
442
234
1,417
42,808
475,557
15,351
12,061
26,689
25,442
555,100
Loan and other credit-related commitments
119,476
—
—
—
—
119,476
Financial guarantees1
11,054
—
—
—
—
11,054
At 31 Dec 2021
606,087
15,351
12,061
26,689
25,442
685,630
Deposits by banks
20,627
732
299
12,101
463
34,222
Customer accounts
186,178
5,769
2,936
231
109
195,223
Repurchase agreements – non-trading
31,635
1,772
1,504
12
—
34,923
Trading liabilities
44,229
—
—
—
—
44,229
Financial liabilities designated at fair value
9,602
1,051
4,989
12,914
11,740
40,296
Derivatives
198,758
54
125
483
408
199,828
Debt securities in issue
1,862
3,244
10,554
1,280
588
17,528
Subordinated liabilities
94
397
231
9,357
5,503
15,582
Other financial liabilities
50,107
349
444
384
1,178
52,462
543,092
13,368
21,082
36,762
19,989
634,293
Loan and other credit-related commitments
147,303
—
—
—
—
147,303
Financial guarantees1
3,969
—
—
—
—
3,969
At 31 Dec 2020
694,364
13,368
21,082
36,762
19,989
785,565
The bank
Deposits by banks
18,053
4,781
1,516
1,453
—
25,803
Customer accounts
119,749
3,504
1,453
2
—
124,708
Repurchase agreements – non-trading
19,707
1,575
1,061
7
—
22,350
Trading liabilities
31,161
—
—
—
—
31,161
Financial liabilities designated at fair value
9,241
1,597
3,723
2,360
7,055
23,976
Derivatives
127,352
46
104
379
574
128,455
Debt securities in issue
1,480
1,915
845
1,118
327
5,685
Subordinated liabilities
14
62
111
3,700
11,202
15,089
Other financial liabilities
29,248
320
148
28
22
29,766
356,005
13,800
8,961
9,047
19,180
406,993
Loan and other credit-related commitments
32,471
—
—
—
—
32,471
Financial guarantees1
1,270
—
—
—
—
1,270
At 31 Dec 2021
389,746
13,800
8,961
9,047
19,180
440,734
Deposits by banks
16,376
707
205
204
—
17,492
Customer accounts
115,204
3,485
1,287
3
—
119,979
Repurchase agreements – non-trading
24,398
1,105
1,500
12
—
27,015
Trading liabilities
26,673
—
—
—
—
26,673
Financial liabilities designated at fair value
9,414
1,007
2,962
4,497
5,515
23,395
Derivatives
180,608
52
125
444
391
181,620
Debt securities in issue
1,060
3,238
9,629
1,046
417
15,390
Subordinated liabilities
14
397
191
9,086
5,478
15,166
Other financial liabilities
37,510
248
146
53
14
37,971
411,257
10,239
16,045
15,345
11,815
464,701
Loan and other credit-related commitments
46,340
—
—
—
—
46,340
Financial guarantees1
1,510
—
—
—
—
1,510
At 31 Dec 2020
459,107
10,239
16,045
15,345
11,815
512,551
1Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
Maturity analysis of financial assets and financial liabilities
The following table provides an analysis of financial assets and liabilities by residual contractual maturity at the balance sheet date.
These balances are included in the maturity analysis as follows:
•Financial assets and liabilities with no contractual maturity (such as equity securities) are included in the ‘Due after more than 1 year’
time bucket. Undated or perpetual instruments are classified based on the contractual notice period, which the counterparty of the
instrument is entitled to give. Where there is no contractual notice period, undated or perpetual contracts are included in the ‘Due
after more than 1 year’ time bucket.
HSBC Bank plc Annual Report and Accounts 2021
165
•Financial instruments included within assets and liabilities of disposal groups held for sale are classified on the basis of the
contractual maturity of the underlying instruments and not on the basis of the disposal transaction.
•Liabilities under investment contracts are classified in accordance with their contractual maturity. Undated investment contracts are
included in the ‘Due after more than 1 year’ time bucket, however, such contracts are subject to surrender and transfer options by the
policyholders.
Maturity analysis of financial assets and financial liabilities
2021
2020
Due within
1 year
Due after more
than 1 year
Total
Due within
1 year
Due after more
than 1 year
Total
The group
£m
£m
£m
£m
£m
£m
Assets
Financial assets designated or otherwise
mandatorily measured at fair value
3,225
15,424
18,649
1,631
14,589
16,220
Loans and advances to banks
8,841
1,943
10,784
10,186
2,460
12,646
Loans and advances to customers
40,837
50,340
91,177
47,863
53,628
101,491
Reverse repurchase agreement – non-trading
53,079
1,369
54,448
65,157
2,420
67,577
Financial investments
6,748
34,552
41,300
8,984
42,842
51,826
Other financial assets
38,851
203
39,054
49,744
274
50,018
At 31 Dec
151,581
103,831
255,412
183,565
116,213
299,778
Liabilities
Deposits by banks
19,439
12,749
32,188
21,627
12,678
34,305
Customer accounts
204,973
268
205,241
194,872
312
195,184
Repurchase agreements – non-trading
27,252
7
27,259
34,891
12
34,903
Financial liabilities designated at fair value
16,329
17,279
33,608
17,109
23,683
40,792
Debt securities in issue
7,840
1,588
9,428
15,620
1,751
17,371
Other financial liabilities
41,131
1,754
42,885
50,955
1,704
52,659
Subordinated liabilities
8
12,480
12,488
445
13,319
13,764
At 31 Dec
316,972
46,125
363,097
335,519
53,459
388,978
The bank
Assets
Financial assets designated or otherwise
mandatorily measured at fair value
2,796
419
3,215
1,455
410
1,865
Loans and advances to banks
5,267
1,511
6,778
6,081
1,982
8,063
Loans and advances to customers
23,609
10,327
33,936
31,051
12,190
43,241
Reverse repurchase agreement – non-trading
38,759
949
39,708
48,175
1,962
50,137
Financial investments
4,580
21,962
26,542
5,617
25,352
30,969
Other financial assets
28,812
—
28,812
34,753
1
34,754
At 31 Dec
103,823
35,168
138,991
127,132
41,897
169,029
Liabilities
Deposits by banks
14,655
—
14,655
17,284
200
17,484
Customer accounts
124,704
2
124,706
119,971
3
119,974
Repurchase agreements – non-trading
22,337
7
22,344
26,984
12
26,996
Financial liabilities designated at fair value
14,425
6,444
20,869
14,859
9,828
24,687
Debt securities in issue
4,240
1,418
5,658
13,912
1,444
15,356
Other financial liabilities
29,868
44
29,912
38,167
56
38,223
Subordinated liabilities
—
12,218
12,218
330
13,030
13,360
At 31 Dec
210,229
20,133
230,362
231,507
24,573
256,080
28
Offsetting of financial assets and financial liabilities
The ‘Amounts not set off in the balance sheet’ include transactions where:
•The counterparty has an offsetting exposure with the group and a master netting or similar arrangement is in place with a right of set
off only in the event of default, insolvency or bankruptcy, or the offset criteria are not otherwise satisfied.
•In the case of derivatives and reverse repurchase/repurchase, stock borrowing/lending and similar agreements, cash and non-cash
collateral has been received/pledged.
For risk management purposes, the net amounts of loans and advances to customers are subject to limits, which are monitored and the
relevant customer agreements are subject to review and updated, as necessary, to ensure that the legal right of offset remains
appropriate.
Notes on the Financial Statements
166
HSBC Bank plc Annual Report and Accounts 2021
Amounts subject to enforceable netting arrangements
Amounts not
subject to
enforceable
netting
arrangements5
Total
Amounts not set off in the balance
sheet
Gross
amounts
Amounts
offset
Net amounts
in the
balance
sheet
Financial
instruments
Non-cash
collateral
Cash
collateral
Net
amount
£m
£m
£m
£m
£m
£m
£m
£m
£m
Financial assets
Derivatives (Note 14)1
160,801
(20,689)
140,112
(107,879)
(7,106)
(24,277)
850
1,109
141,221
Reverse repos, stock borrowing and similar
agreements classified as2:
–  trading assets
11,960
(156)
11,804
(265)
(11,539)
—
—
40
11,844
–  non-trading assets
125,935
(72,788)
53,147
(10,235)
(42,809)
(103)
—
1,301
54,448
Loans and advances to customers3
14,741
(6,091)
8,650
(7,053)
—
—
1,597
5
8,655
At 31 Dec 2021
313,437
(99,724)
213,713
(125,432)
(61,454)
(24,380)
2,447
2,455
216,168
Derivatives (Note 14)1
229,891
(29,996)
199,895
(160,907)
(8,837)
(29,834)
317
1,315
201,210
Reverse repos, stock borrowing and similar
agreements classified as2:
–  trading assets
12,430
(531)
11,899
(519)
(11,380)
—
—
419
12,318
–  non-trading assets
128,246
(64,386)
63,860
(10,604)
(53,218)
(38)
—
3,735
67,595
Loans and advances to customers3
17,312
(6,990)
10,322
(8,713)
—
—
1,609
1
10,323
At 31 Dec 2020
387,879
(101,903)
285,976
(180,743)
(73,435)
(29,872)
1,926
5,470
291,446
Financial liabilities
Derivatives (Note 14)1
159,169
(20,689)
138,480
(107,879)
(16,866)
(13,273)
462
888
139,368
Repos, stock lending and similar
agreements classified as2:
–  trading liabilities
9,444
(156)
9,288
(265)
(9,023)
—
—
13
9,301
–  non-trading liabilities
100,031
(72,788)
27,243
(10,235)
(16,855)
(153)
—
16
27,259
Customer accounts4
21,846
(6,091)
15,755
(7,053)
—
—
8,702
11
15,766
At 31 Dec 2021
290,490
(99,724)
190,766
(125,432)
(42,744)
(13,426)
9,164
928
191,694
Derivatives (Note 14)1
228,372
(29,996)
198,376
(160,907)
(14,652)
(22,521)
296
856
199,232
Repos, stock lending and similar
agreements classified as2:
–  trading liabilities
12,323
(531)
11,792
(519)
(11,273)
—
—
5
11,797
–  non-trading liabilities
99,289
(64,386)
34,903
(10,604)
(24,143)
(156)
—
—
34,903
Customer accounts4
21,847
(6,990)
14,857
(8,713)
—
—
6,144
8
14,865
At 31 Dec 2020
361,831
(101,903)
259,928
(180,743)
(50,068)
(22,677)
6,440
869
260,797
1At 31 December 2021, the amount of cash margin received that had been offset against the gross derivatives assets was £2,590m (2020:
£4,866m). The amount of cash margin paid that had been offset against the gross derivatives liabilities was £6,180m (2020: £10,622 m).
2For the amount of repos, reverse repos, stock lending, stock borrowing and similar agreements recognised on the balance sheet within 'Trading
assets' and 'Trading liabilities', see the 'Funding sources and uses' table on page 76.
3At 31 December 2021, the total amount of 'Loans and advances to customers' recognised on the balance sheet was £91,177m (2020:
£101,491m) of which £8,650m (2020: £10,322m) was subject to offsetting.
4At 31 December 2021, the total amount of 'Customer accounts' recognised on the balance sheet was £205,241m (2020: £195,184m) of which
£15,755m (2020: £14,857m) was subject to offsetting.
5These exposures continue to be secured by financial collateral, but we may not have sought or been able to obtain a legal opinion evidencing
enforceability of the right of offset.
29
Called up share capital and other equity instruments
Issued and fully paid
HSBC Bank plc £1.00 ordinary shares
2021
2020
Number
£m
Number
£m
At 1 Jan
796,969,111
797
796,969,111
797
At 31 Dec
796,969,111
797
796,969,111
797
HSBC Bank plc $0.01 non-cumulative third dollar preference shares
2021
2020
Number
£000
Number
£000
At 1 Jan and 31 Dec
35,000,000
172
35,000,000
172
The bank has no obligation to redeem the preference shares but may redeem them in part or in whole at any time, subject to prior
notification to the Prudential Regulation Authority ('PRA'). Dividends on the preference shares in issue are paid annually at the sole and
absolute discretion of the Board of Directors. The Board of Directors will not declare a dividend on the preference shares in issue if (i)
payment of the dividend would cause a breach of the capital adequacy requirements of the bank (or its subsidiary undertakings) under
applicable laws or regulations or (ii) the distributable profits of the bank are insufficient to enable the payment in full or in part (as
applicable) of the dividends on the preference shares in issue. If either the solo or consolidated Common Equity Tier 1 Capital Ratio of
the bank as of any date falls below 7.00% (a so-called 'right conversion event'), the rights attaching to the preference shares shall be
altered irrevocably and permanently such that they have the same rights attaching to them as ordinary shares. Holders of the preference
HSBC Bank plc Annual Report and Accounts 2021
167
shares in issue will be able to attend any general meetings of shareholders of the bank and to vote on any resolution proposed to vary or
abrogate any of the rights attaching to the preference shares or any resolution proposed to reduce the paid up capital of the preference
shares. If the dividend payable on the preference shares in issue has not been paid in full for the most recent dividend period, if a rights
conversion event has occurred or if any resolution is proposed for the winding-up of the bank or the sale of its entire business then, in
such circumstances, holders of preference shares will be entitled to vote on all matters put to general meetings. In the case of unpaid
dividends the holders of preference shares in issue will be entitled to attend and vote at any general meetings until such time as
dividends on the preference shares for the most recent dividend period have been paid in full, or a sum set aside for such payment in
full, in respect of one dividend period. All shares in issue are fully paid.
Other equity instruments
HSBC Bank plc additional tier 1 instruments
2021
2020
£m
£m
€1,900m
Undated Subordinated Resettable Additional Tier 1 instrument issued 2015 (Callable December 2020 onwards)
1,388
1,388
€235m
Undated Subordinated Resettable Additional Tier 1 instrument issued 2016 (Callable January 2022 onwards)
197
197
€300m
Undated Subordinated Resettable Additional Tier 1 instrument 2018 (Callable March 2023 onwards)
263
263
£555m
Undated Subordinated Resettable Additional Tier 1 instrument 2018 (Callable March 2023 onwards)
555
555
£500m
Undated Subordinated Resettable Additional Tier 1 instrument 2019 (Callable November 2024 onwards)
500
500
€250m
Undated Subordinated Resettable Additional Tier 1 instrument 2019 (Callable November 2024 onwards)
213
213
£431m
Undated Subordinated Resettable Additional Tier 1 instrument 2019 (Callable December 2024 onwards)
431
431
€200m
Undated Subordinated Resettable Additional Tier 1 instrument 2019 (Callable January 2025 onwards)
175
175
At 31 Dec
3,722
3,722
These instruments are held by HSBC Holdings plc. The bank has issued capital instruments that are included in the group’s capital base
as fully CRD IV compliant additional tier 1 capital.
Interest on these instruments will be due and payable only at the sole discretion of the bank, and the bank has sole and absolute
discretion at all times and for any reason to cancel (in whole or in part) any interest payment that would otherwise be payable on any
date. There are limitations on the payment of principal, interest or other amounts if such payments are prohibited under UK banking
regulations, or other requirements, if the bank has insufficient distributable items reserves or if the bank fails to satisfy the solvency
condition as defined in the instruments terms.
The instruments are undated and are repayable, at the option of the bank, in whole at the initial call date, or on any Interest Payment
Date after the initial call date. In addition, the instruments are repayable at the option of the bank in whole for certain regulatory or tax
reasons. Any repayments require the prior consent of the Prudential Regulation Authority. These instruments rank pari passu with the
bank’s most senior class or classes of issued preference shares and therefore ahead of ordinary shares. These instruments will be
written down in whole, together with any accrued but unpaid interest if either the group’s solo or consolidated Common Equity Tier 1
Capital Ratio falls below 7.00%.
30
Contingent liabilities, contractual commitments, guarantees and contingent assets
The group
The bank
2021
2020
2021
2020
£m
£m
£m
£m
Guarantees and other contingent liabilities:
–  financial guarantees
11,054
3,969
1,270
1,510
–  performance and other guarantees
15,833
14,282
7,334
7,156
–  other contingent liabilities
367
458
364
376
At 31 Dec
27,254
18,709
8,968
9,042
Commitments:1
–  documentary credits and short-term trade-related transactions
1,928
1,366
778
534
–  forward asset purchases and forward deposits placed
30,005
42,793
1,138
4,747
–  standby facilities, credit lines and other commitments to lend
87,543
103,144
30,555
41,059
At 31 Dec
119,476
147,303
32,471
46,340
1Includes £115,695m of commitments (2020: £143,036m), to which the impairment requirements in IFRS 9 are applied where the group has
become party to an irrevocable commitment.
The above table discloses the nominal principal amounts, which represent the maximum amounts at risk should the contracts be fully
drawn upon and clients default. As a significant portion of guarantees and commitments is expected to expire without being drawn
upon, the total of the nominal principal amounts is not indicative of future liquidity requirements.
UK branches of HSBC overseas entities
In December 2017, HM Revenue & Customs (‘HMRC’) challenged the VAT status of certain UK branches of HSBC overseas entities.
HMRC has also issued notices of assessment covering the period from 1 October 2013 to 31 December 2017 totalling £262m, with
interest to be determined. No provision has been recognised in respect of these notices. In Q1 2019, HMRC reaffirmed its assessment
that the UK branches are ineligible to be members of the UK VAT group and, consequently, HSBC paid HMRC the sum of £262m and
filed appeals. In February 2022, the Upper Tribunal issued a judgement addressing several preliminary legal issues, which was partially
in favour of HMRC and partially in favour of HSBC. Further proceedings remain pending. The payment of £262m is recorded as an asset
on HSBC’s balance sheet at 31 December 2021. Since January 2018, HSBC’s returns have been prepared on the basis that the UK
branches are not in the UK VAT group. In the event that HSBC’s appeals are successful, HSBC will seek a refund of this VAT, of which
£135m is estimated to be attributable to HSBC Bank plc.
Contingent liabilities arising from legal proceedings, regulatory and other matters against group companies are disclosed in Note 32.
Notes on the Financial Statements
168
HSBC Bank plc Annual Report and Accounts 2021
Financial Services Compensation Scheme
The Financial Services Compensation Scheme (‘FSCS’) provides compensation, up to certain limits, to eligible customers of financial
services firms that are unable, or likely to be unable, to pay claims against them. The FSCS may impose a further levy on the group to
the extent the industry levies imposed to date are not sufficient to cover the compensation due to customers in any future possible
collapse. The ultimate FSCS levy to the industry as a result of collapse cannot be estimated reliably. It is dependent on various uncertain
factors including the potential recovery of assets by the FSCS, changes in the level of protected products (including deposits and
investments) and the population of FSCS members at the time.
Guarantees
The group
The bank
2021
2020
2021
2020
In favour of
third parties
By the group in
favour of other
HSBC Group
entities
In favour of third
parties
By the group in
favour of other
HSBC Group
entities
In favour of
third parties
By the bank in
favour of other
HSBC Group
entities
In favour of
third parties
By the bank in
favour of other
HSBC Group
entities
£m
£m
£m
£m
£m
£m
£m
£m
Financial guarantees1
10,635
419
3,541
428
824
446
895
615
Performance and other
guarantees
14,433
1,400
13,091
1,191
6,119
1,215
6,088
1,068
Total
25,068
1,819
16,632
1,619
6,943
1,661
6,983
1,683
1Financial guarantees contracts are contracts that require the issuer to make specified payments to reimburse the holder for a loss incurred
because a specified debtor fails to make payment when due, in accordance with the original or modified terms of a debt instrument. The amounts
in the above table are nominal principal amounts. ‘Financial guarantees’ to which the impairment requirements in IFRS 9 are applied have been
presented separately from other guarantees to align with credit risk disclosures. 
The group provides guarantees and similar undertakings on behalf of both third-party customers and other entities within HSBC Group.
These guarantees are generally provided in the normal course of the group‘s banking businesses. Guarantees with terms of more than
one year are subject to the group’s annual credit review process.
31
Finance lease receivables
The group leases a variety of assets to third parties under finance leases, including transport assets (such as aircraft), property and
general plant and machinery. At the end of lease terms, assets may be sold to third parties or leased for further terms. Rentals are
calculated to recover the cost of assets less their residual value, and earn finance income.
2021
2020
Total future
minimum
payments
Unearned
finance income
Present
value
Total future
minimum
payments
Unearned
finance
income
Present
Value
£m
£m
£m
£m
£m
£m
Lease receivables:
No later than one year
409
(20)
389
270
(16)
254
One to two years
251
(19)
232
253
(17)
236
Two to three years
187
(17)
170
424
(15)
409
Three to four years
177
(13)
164
305
(15)
290
Four to five years
90
(9)
81
152
(9)
143
Later than one year and no later than five years
705
(58)
647
1,134
(56)
1,078
Later than five years
556
(33)
523
770
(31)
739
At 31 Dec
1,670
(111)
1,559
2,174
(103)
2,071
32
Legal proceedings and regulatory matters
The group is party to legal proceedings and regulatory matters in a number of jurisdictions arising out of its normal business operations.
Apart from the matters described below, the group considers that none of these matters are material. The recognition of provisions is
determined in accordance with the accounting policies set out in Note 1. While the outcomes of legal proceedings and regulatory
matters are inherently uncertain, management believes that, based on the information available to it, appropriate provisions have been
made in respect of these matters as at 31 December 2021 (see Note 25). Where an individual provision is material, the fact that a
provision has been made is stated and quantified, except to the extent that doing so would be seriously prejudicial. Any provision
recognised does not constitute an admission of wrongdoing or legal liability. 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.
Bernard L. Madoff Investment Securities LLC
Various non-US HSBC companies provided custodial, administration and similar services to a number of funds incorporated outside the
US whose assets were invested with Bernard L. Madoff Investment Securities LLC ('Madoff Securities'). Based on information provided
by Madoff Securities as at 30 November 2008, the purported aggregate value of these funds was $8.4bn, including fictitious profits
reported by Madoff. Based on information available to HSBC, the funds’ actual transfers to Madoff Securities minus their actual
withdrawals from Madoff Securities during the time HSBC serviced the funds are estimated to have totalled approximately $4bn. Various
HSBC companies have been named as defendants in lawsuits arising out of Madoff Securities’ fraud.
US litigation: The Madoff Securities Trustee has brought lawsuits against various HSBC companies and others in the US Bankruptcy
Court for the Southern District of New York (the ‘US Bankruptcy Court’), seeking recovery of transfers from Madoff Securities to HSBC in
an amount not yet pleaded or determined. Following an initial dismissal of certain claims, which was later reversed on appeal, the cases
were remanded to the US Bankruptcy Court, where they are now pending.
HSBC Bank plc Annual Report and Accounts 2021
169
Fairfield Sentry Limited, Fairfield Sigma Limited and Fairfield Lambda Limited (together, ‘Fairfield’) (in liquidation since July 2009) have
brought a lawsuit in the US against fund shareholders, including HSBC companies that acted as nominees for clients, seeking restitution
of redemption payments. In December 2018, the US Bankruptcy Court dismissed certain claims by the Fairfield liquidators and granted a
motion by the liquidators to file amended complaints. In May 2019, the liquidators appealed certain issues from the US Bankruptcy
Court to the US District Court for the Southern District of New York (the ’New York District Court’), and these appeals remain pending.
In January 2020, the Fairfield liquidators filed amended complaints on the claims remaining in the US Bankruptcy Court. In December
2020, the US Bankruptcy Court dismissed the majority of those claims. In March 2021, the liquidators and defendants appealed the US
Bankruptcy Court’s decision to the New York District Court, and these appeals are currently pending. Meanwhile, proceedings before the
US Bankruptcy Court with respect to the remaining claims that were not dismissed are ongoing.
UK litigation: The Madoff Securities Trustee has filed a claim against various HSBC companies in the High Court of England and Wales,
seeking recovery of transfers from Madoff Securities to HSBC in an amount not yet pleaded or determined. The deadline for service of
the claim has been extended to September 2022 for UK-based defendants and November 2022 for all other defendants.
Cayman Islands litigation: In February 2013, Primeo Fund (‘Primeo’) (in liquidation since April 2009) brought an action against HSBC
Securities Services Luxembourg (‘HSSL’) and Bank of Bermuda (Cayman) Limited (now known as HSBC Cayman Limited), alleging
breach of contract and breach of fiduciary duty and claiming damages and equitable compensation. The trial concluded in February
2017 and, in August 2017, the court dismissed all claims against the defendants. In September 2017, Primeo appealed to the Court of
Appeal of the Cayman Islands and, in June 2019, the Court of Appeal of the Cayman Islands dismissed Primeo’s appeal. In August 2019,
Primeo filed a notice of appeal to the UK Privy Council. Two hearings before the UK Privy Council took place during 2021. Judgment was
given against HSBC in respect of the first hearing and judgment is pending in respect of the second hearing.
Luxembourg litigation: In April 2009, Herald Fund SPC (‘Herald’) (in liquidation since July 2013) brought an action against HSSL
before the Luxembourg District Court, seeking restitution of cash and securities that Herald purportedly lost because of Madoff
Securities’ fraud, or money damages. The Luxembourg District Court dismissed Herald’s securities restitution claim, but reserved
Herald’s cash restitution and money damages claims. Herald has appealed this judgment to the Luxembourg Court of Appeal, where the
matter is pending. In late 2018, Herald brought additional claims against HSSL and HSBC Bank plc before the Luxembourg District
Court, seeking further restitution and damages.
In October 2009, Alpha Prime Fund Limited ('Alpha Prime') brought an action against HSSL before the Luxembourg District Court,
seeking the restitution of securities, or the cash equivalent, or money damages. In December 2018, Alpha Prime brought additional
claims before the Luxembourg District Court seeking damages against various HSBC companies. These matters are currently pending
before the Luxembourg District Court.
In December 2014, Senator Fund SPC (‘Senator’) brought an action against HSSL before the Luxembourg District Court, seeking
restitution of securities, or the cash equivalent, or money damages. In April 2015, Senator commenced a separate action against the
Luxembourg branch of HSBC Bank plc asserting identical claims before the Luxembourg District Court. In December 2018, Senator
brought additional claims against HSSL and HSBC Bank plc Luxembourg branch before the Luxembourg District Court, seeking
restitution of Senator’s securities or money damages. These matters are currently pending before the Luxembourg District Court.
There are many factors that may affect the range of possible outcomes, and any resulting financial impact, of the various Madoff-related
proceedings described above, including but not limited to the multiple jurisdictions in which the proceedings have been brought. Based
upon the information currently available, management’s estimate of the possible aggregate damages that might arise as a result of all
claims in the various Madoff-related proceedings is around $600m, excluding costs and interest. Due to uncertainties and limitations of
this estimate, any possible damages that might ultimately arise could differ significantly from this amount.
Anti-money laundering and sanctions-related matters
In December 2012, HSBC Holdings plc (’HSBC Holdings’) entered into a number of agreements, including an undertaking with the UK
Financial Services Authority (replaced with a Direction issued by the UK Financial Conduct Authority ('FCA') in 2013 and again in 2020)
as well as a cease-and-desist order with the US Federal Reserve Board ('FRB'), both of which contained certain forward-looking anti-
money laundering (‘AML’) and sanctions-related obligations. Over the past several years, HSBC has retained a Skilled Person under
section 166 of the Financial Services and Markets Act and an Independent Consultant under the FRB cease-and-desist order to produce
periodic assessments of the Group’s AML and sanctions compliance programme. The Skilled Person completed its engagement in the
second quarter of 2021, and the FCA has determined that no further Skilled Person work is required. Separately, the Independent
Consultant continues to work pursuant to the FRB cease-and-desist order. The roles of each of the FCA Skilled Person and the FRB
Independent Consultant are discussed on page 83.
In December 2021, the FCA concluded its investigation into HSBC's compliance with UK money laundering regulations and financial
crime systems and control requirements. The FCA imposed a fine on HSBC Bank plc, which has been paid.
Since November 2014, a number of lawsuits have been filed in federal courts in the US against various HSBC companies and others on
behalf of plaintiffs who are, or are related to, victims of terrorist attacks in the Middle East. In each case, it is alleged that the defendants
aided and abetted the unlawful conduct of various sanctioned parties in violation of the US Anti-Terrorism Act. Currently, nine actions
against HSBC Bank plc remain pending in federal courts in New York or the District of Columbia. The courts have granted HSBC Bank
plc’s motions to dismiss in five of these cases; appeals remain pending in two cases, and the remaining three dismissals are also subject
to appeal. The four remaining actions are at an early stage.
Based on the facts currently known, it is not practicable to predict the resolution of these matters, including the timing or any possible
impact on HSBC, which could be significant.
London interbank offered rates, European interbank offered rates and other benchmark interest rate
investigations and litigation
Euro interest rate derivatives: In December 2016, the European Commission (‘EC’) issued a decision finding that HSBC, among other
banks, engaged in anti-competitive practices in connection with the pricing of euro interest rate derivatives in early 2007. The EC
imposed a fine on HSBC based on a one-month infringement. In September 2019, the General Court of the European Union (the 'General
Court') issued a decision largely upholding the EC's findings on liability but annulling the fine. HSBC and the EC both appealed the
General Court’s decision to the European Court of Justice (the ‘Court of Justice’). In June 2021, the EC adopted a new fining decision for
an amount that was 5% less than the previously annulled fine, and it subsequently withdrew its appeal to the Court of Justice. HSBC has
appealed the EC’s June 2021 fining decision to the General Court, and its appeal to the Court of Justice on liability also remains pending.
Notes on the Financial Statements
170
HSBC Bank plc Annual Report and Accounts 2021
US dollar Libor: Beginning in 2011, HSBC and other panel banks have been named as defendants in a number of private lawsuits filed
in the US with respect to the setting of US dollar Libor. The complaints assert claims under various US laws, including US antitrust and
racketeering laws, the US Commodity Exchange Act (‘US CEA’) and state law. The lawsuits include individual and putative class actions,
most of which have been transferred and/or consolidated for pre-trial purposes before the New York District Court. HSBC has reached
class settlements with five groups of plaintiffs, and the court has approved these settlements. HSBC has also resolved several of the
individual actions, although a number of other US dollar Libor-related actions remain pending against HSBC in the New York District
Court.
Intercontinental Exchange (‘ICE’) Libor: Between January and March 2019, HSBC and other panel banks were named as defendants
in three putative class actions filed in the New York District Court on behalf of persons and entities who purchased instruments paying
interest indexed to US dollar ICE Libor from a panel bank. The complaints allege, among other things, misconduct related to the
suppression of this benchmark rate in violation of US antitrust and state law. In July 2019, the three putative class actions were
consolidated, and the plaintiffs filed a consolidated amended complaint. In March 2020, the court granted the defendants’ motion to
dismiss in its entirety and, in February 2022, the US Court of Appeals for the Second Circuit dismissed the plaintiffs' appeal.
Based on the facts currently known, it is not practicable to predict the resolution of these matters, including the timing or any possible
impact on HSBC, which could be significant.
Foreign exchange-related investigations and litigation
In December 2021, the EC issued a settlement decision finding that a number of banks, including HSBC, had engaged in anti-
competitive practices in an online chatroom between 2011 and 2012 in the foreign exchange spot market. The EC imposed a €174.3m
fine on HSBC in connection with this matter, which is fully provisioned.
In January 2018, following the conclusion of the US Department of Justice’s (‘DoJ’) investigation into HSBC’s historical foreign
exchange activities, HSBC Holdings entered into a three-year deferred prosecution agreement with the Criminal Division of the DoJ (the
‘FX DPA’), regarding fraudulent conduct in connection with two particular transactions in 2010 and 2011. In January 2021, the FX DPA
expired and, in August 2021, the charges deferred by the FX DPA were dismissed.
In June 2020, the Competition Commission of South Africa, having initially referred a complaint for proceedings before the South African
Competition Tribunal in February 2017, filed a revised complaint against 28 financial institutions, including HSBC Bank plc, for alleged
anti-competitive behaviour in the South African foreign exchange market. In December 2021, a hearing on HSBC Bank plc's application
to dismiss the revised complaint took place before the South African Competition Tribunal, where a decision remains pending.
Beginning in 2013, various HSBC companies and other banks have been named as defendants in a number of putative class actions filed
in, or transferred to, the New York District Court arising from allegations that the defendants conspired to manipulate foreign exchange
rates. HSBC has reached class settlements with two groups of plaintiffs, including direct and indirect purchasers of foreign exchange
products, and the court has granted final approval of these settlements.
In November and December 2018, complaints alleging foreign exchange-related misconduct were filed in the New York District Court
and the High Court of England and Wales against HSBC and other defendants by certain plaintiffs that opted out of the direct purchaser
class action settlement in the US. These matters remain pending. Additionally, lawsuits alleging foreign exchange-related misconduct
remain pending against HSBC and other banks in courts in Brazil and Israel.
In February 2019, various HSBC companies were named as defendants in a claim issued in the High Court of England and Wales that
alleged foreign exchange-related misconduct. In November 2021, the court dismissed all claims against HSBC and this matter is now
concluded.
It is possible that additional civil actions will be initiated against HSBC in relation to its historical foreign exchange activities.
There are many factors that may affect the range of outcomes, and the resulting financial impact, of these matters, which could be
significant.
Precious metals fix-related litigation
Gold: Beginning in March 2014, numerous putative class actions were filed in the New York District Court and the US District Courts for
the District of New Jersey and the Northern District of California, naming HSBC and other members of The London Gold Market Fixing
Limited as defendants. The complaints, which were consolidated in the New York District Court, allege that, from January 2004 to June
2013, the defendants conspired to manipulate the price of gold and gold derivatives for their collective benefit in violation of US antitrust
laws, the US CEA and New York state law. In October 2020, HSBC reached a settlement in principle with the plaintiffs to resolve the
consolidated action. The settlement remains subject to court approval.
Beginning in December 2015, numerous putative class actions under Canadian law were filed in the Ontario and Quebec Superior Courts
of Justice against various HSBC companies and other financial institutions. The plaintiffs allege that, among other things, from January
2004 to March 2014, the defendants conspired to manipulate the price of gold and gold derivatives in violation of the Canadian
Competition Act and common law. These actions are ongoing.
Silver: Beginning in July 2014, numerous putative class actions were filed in federal district courts in New York, naming HSBC and
other members of The London Silver Market Fixing Limited as defendants. The complaints allege that, from January 2007 to December
2013, the defendants conspired to manipulate the price of silver and silver derivatives for their collective benefit in violation of US
antitrust laws, the US CEA and New York state law. The actions were consolidated in the New York District Court and remain pending,
following the conclusion of pre-class certification discovery.
In April 2016, two putative class actions under Canadian law were filed in the Ontario and Quebec Superior Courts of Justice against
various HSBC companies and other financial institutions. The plaintiffs in both actions allege that, from January 1999 to August 2014,
the defendants conspired to manipulate the price of silver and silver derivatives in violation of the Canadian Competition Act and
common law. These actions are ongoing.
Platinum and palladium: Between late 2014 and early 2015, numerous putative class actions were filed in the New York District Court,
naming HSBC and other members of The London Platinum and Palladium Fixing Company Limited as defendants. The complaints allege
that, from January 2008 to November 2014, the defendants conspired to manipulate the price of platinum group metals (‘PGM’) and
PGM-based financial products for their collective benefit in violation of US antitrust laws and the US CEA. In March 2020, the court
granted the defendants' motion to dismiss the plaintiffs’ third amended complaint but granted the plaintiffs leave to re-plead certain
claims. The plaintiffs have filed an appeal.
HSBC Bank plc Annual Report and Accounts 2021
171
Based on the facts currently known, it is not practicable at this time for HSBC to predict the resolution of these matters, including the
timing or any possible impact on HSBC, which could be significant.
Other regulatory investigations, reviews and litigation
HSBC Bank plc and/or certain of its affiliates are subject to a number of other investigations and reviews by various regulators and
competition and law enforcement authorities, as well as litigation, in connection with various matters relating to the firm’s businesses
and operations, including:
•an investigation by the PRA in connection with depositor protection arrangements in the UK;
•an investigation by the FCA in connection with collections and recoveries operations in the UK;
•an investigation by the UK Competition and Markets Authority concerning the financial services sector; and
•two group actions pending in the US courts and a claim issued in the High Court of England and Wales in connection with HSBC
Bank plc’s role as a correspondent bank to Stanford International Bank Ltd from 2003 to 2009.
There are many factors that may affect the range of outcomes, and the resulting financial impact, of these matters, which could be
significant.
33
Related party transactions
On 21 June 2021, the immediate parent company of HSBC Bank plc changed from HSBC UK Holdings Limited to HSBC Holdings plc,
which is the ultimate parent company of the group and is incorporated in England.
Copies of the Group financial statements may be obtained from the below address.
HSBC Holdings plc
8 Canada Square
London E14 5HQ
IAS 24 ‘Related party disclosures’ defines related parties as including the parent, fellow subsidiaries, associates, joint ventures, post-
employment benefit plans for HSBC employees, Key Management Personnel (‘KMP’) of the group and its ultimate parent company,
close family members of the KMP and entities which are controlled, jointly controlled or significantly influenced by the KMP or their
close family members.
Particulars of transactions between the group and the related parties are tabulated below. The disclosure of the year-end balance and
the highest amounts outstanding during the year are considered to be the most meaningful information to represent the amount of the
transactions and outstanding balances during the year.
Key Management Personnel
The KMP of the bank are defined as those persons having authority and responsibility for planning, directing and controlling the
activities of the bank. They include the Directors and certain senior executives of the bank, directors and certain members of the Group
Executive Committee of HSBC Holdings plc, to the extent they have a role in directing the affairs of the bank.
The emoluments of those KMP who are not Directors or senior executives of the bank are paid by other Group companies who make no
recharge to the bank. Accordingly, no emoluments in respect of these KMP are included in the following disclosure.
The tables below represent the compensation for KMP (directors and certain senior executives) of the bank in exchange for services
rendered to the bank for the period they served during the year.
Compensation of Key Management Personnel
2021
20201
£000
£000
Short-term employee benefits2,3
13,678
3,865
Post-employment benefits
46
19
Other long-term employee benefits
1,378
429
Share-based payments
4,331
586
Year ended 31 Dec
19,433
4,899
1  In 2021 the scope of KMP was extended to include certain senior executives of the bank that were not included in 2020. The 2020 comparatives
have not been updated to include certain senior executives of the bank.
2  Includes fees paid to non-executive Directors.
3  Includes two payments totalling £2,091,617 relating to compensation for loss of employment.
Advances and credits, guarantees and deposit balances during the year with Key Management Personnel
2021
2020 3
Balance at
31 Dec
Highest amounts
outstanding
during year2
Balance at   
31 Dec
Highest amounts
outstanding
during year
£m
£m
£m
£m
Key Management Personnel1
Advances and credits
0.03
0.08
0.03
1.5
Deposits
11
18
13
39
1  Includes close family members and entities which are controlled or jointly controlled by KMP of the bank or their close family members.
2  Exchange rate applied for non-GBP amounts is the average for the year.
3  In 2021 the scope of KMP was extended to include certain senior executives of the bank that were not included in 2020. The 2020 comparatives
have not been updated to include certain senior executives of the bank.
Notes on the Financial Statements
172
HSBC Bank plc Annual Report and Accounts 2021
The above transactions were made in the ordinary course of business and on substantially the same terms, including interest rates and
security, as for comparable transactions with persons of a similar standing or, where applicable, with other employees. The transactions
did not involve more than the normal risk of repayment or present other unfavourable features.
In addition to the requirements of IAS 24, particulars of advances (loans and quasi-loans), credits and guarantees entered into by the
group with Directors of HSBC Bank plc are required to be disclosed pursuant to section 413 of the Companies Act 2006. Under the
Companies Act, there is no requirement to disclose transactions with KMP of the bank’s ultimate parent company, HSBC Holdings plc.
During the course of 2021, there were no advances, credits and guarantees entered into by the group with Directors of HSBC Bank plc.
Other related parties
Transactions and balances during the year with KMP of the bank’s ultimate parent company
During the course of 2021, there were no transactions and balances between KMP of the bank’s ultimate parent company, who were
not considered KMP of the bank, in respect of advances and credits, guarantees and deposits.
Transactions and balances during the year with associates and joint ventures
During the course of 2021, there were no transactions and balances with associates and joint ventures, in respect of loans, deposits,
guarantees and commitments.
The group’s transactions and balances during the year with HSBC Holdings plc and subsidiaries of HSBC Holdings plc
2021
2020
Due to/from
HSBC Holdings plc
Due to/from subsidiaries of
HSBC Holdings plc
Due to/from
HSBC Holdings plc
Due to/from subsidiaries of
HSBC Holdings plc
Highest
balance
during the
year
Balance at
31 Dec
Highest
balance
during the
year
Balance at
31 Dec
Highest
balance
during the
year
Balance at 31
Dec
Highest
balance
during the
year
Balance at
31 Dec
£m
£m
£m
£m
£m
£m
£m
£m
Assets
Trading assets
108
19
4,702
1,360
170
108
1,664
1,154
Derivatives
2,002
787
25,566
21,862
2,261
2,002
33,785
20,980
Financial assets designated and otherwise
mandatorily measured at fair value through
profit or loss
7
6
29
27
7
7
29
28
Loans and advances to banks
—
—
4,890
3,173
—
—
6,222
4,048
Loans and advances to customers
—
—
490
329
—
—
505
435
Financial investments
172
154
—
—
172
172
—
—
Reverse repurchase agreements – non-trading
—
—
2,332
1,690
—
—
4,638
1,137
Prepayments,accrued income and other assets
1,540
1,262
9,853
4,784
2,228
1,431
10,821
4,250
Total related party assets at 31 Dec
3,829
2,228
47,862
33,225
4,838
3,720
57,664
32,032
Liabilities
Trading liabilities
158
23
116
82
406
151
742
51
Financial liabilities designated at fair value
1,181
1,162
1,201
—
—
—
1,307
1,201
Deposits by banks
—
—
6,659
2,261
—
—
4,961
2,534
Customer accounts
2,364
1,875
3,428
3,149
4,200
2,080
2,565
2,234
Derivatives
3,443
2,074
26,152
22,133
4,649
3,443
30,283
20,878
Subordinated liabilities
9,485
9,251
10,421
—
—
—
10,756
10,421
Repurchase agreements – non-trading
—
—
6,162
1,841
—
—
8,738
1,028
Provisions, accruals, deferred income and other
liabilities
189
179
8,057
3,826
103
74
10,719
3,097
Total related party liabilities at 31 Dec
16,820
14,564
62,196
33,292
9,358
5,748
70,071
41,444
Guarantees and commitments
—
—
2,622
2,061
—
—
2,438
1,762
Due to/from
HSBC Holdings plc
Due to/from subsidiaries of
HSBC Holdings plc
2021
2020
2021
2020
£m
£m
£m
£m
Income statement
Interest income
4
5
32
55
Interest expense1
50
(55)
58
256
Fee income
8
13
61
55
Fee expense
—
—
357
389
Trading income
—
—
2
2
Trading expense
—
—
—
2
Other operating income
7
30
236
365
General and administrative expenses
143
126
2,110
2,077
12020 negative balance relates to net impact of fixed-for-floating-interest-rate swaps which the group has entered into to manage the movements
in market interest rates on certain fixed rate financial liabilities.
The above outstanding balances arose in the ordinary course of business and on substantially the same terms, including interest rates
and security, as for comparable transactions with third-party counterparties.
HSBC Bank plc Annual Report and Accounts 2021
173
The bank's transactions and balances during the year with HSBC Bank plc subsidiaries, HSBC Holdings plc and subsidiaries of HSBC
Holdings plc
2021
2020
Due to/from
subsidiaries of
HSBC Bank plc
subsidiaries
Due to/from HSBC
Holdings plc
Due to/from
subsidiaries of
HSBC Holdings plc
Due to/from
subsidiaries of HSBC
Bank plc subsidiaries
Due to/from HSBC
Holdings plc
Due to/from
subsidiaries of HSBC
Holdings plc
Highest
balance
during
the year
Balance
at 31 Dec
Highest
balance
during
the year
Balance
at 31 Dec
Highest
balance
during
the year
Balance
at 31 Dec
Highest
balance
during the
year
Balance
at 31 Dec
Highest
balance
during the
year
Balance
at 31 Dec
Highest
balance
during the
year
Balance
at 31 Dec
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
Assets
Trading assets
603
264
108
19
4,695
1,360
907
234
169
108
1,664
1,154
Derivatives
15,309
9,025
2,002
787
22,953
19,755
19,139
15,309
2,261
2,002
31,986
19,829
Financial assets designated and
otherwise mandatorily measured
at fair value through profit or loss
—
—
—
—
—
—
—
—
—
—
—
—
Loans and advances to banks
3,172
2,259
—
—
3,561
2,100
5,263
2,123
—
—
4,794
3,083
Loans and advances to
customers
6,446
3,850
—
—
416
242
8,198
6,446
—
—
395
322
Financial investments
3,337
3,337
—
—
—
—
2,214
2,214
—
—
—
—
Reverse repurchase agreements –
non-trading
2,313
2,313
—
—
2,058
1,428
3,070
965
—
—
1,942
775
Prepayments, accrued income
and other assets
5,921
1,685
1,537
1,261
9,327
4,557
4,769
2,986
2,228
1,430
10,063
4,136
Investments in subsidiary
undertakings
6,479
6,479
—
—
—
—
6,458
6,458
—
—
—
—
Total related party assets at
31 Dec
43,580
29,212
3,647
2,067
43,010
29,442
50,018
36,735
4,658
3,540
50,844
29,299
Liabilities
Trading liabilities
112
49
158
21
116
82
10
1
406
151
742
51
Financial liabilities designated at
fair value
—
—
1,181
1,162
1,201
—
318
—
—
—
1,307
1,201
Deposits by banks
1,808
1,229
—
—
3,245
965
1,956
1,096
—
—
3,089
1,471
Customer accounts
1,287
696
2,364
1,875
3,321
3,013
1,287
1,287
4,200
2,080
2,509
2,178
Derivatives
17,378
10,190
3,443
2,074
23,787
20,182
18,174
17,378
4,649
3,443
29,159
20,161
Subordinated liabilities
700
700
9,262
9,033
10,187
—
700
700
—
—
10,519
10,187
Repurchase agreements – non-
trading
988
431
—
—
5,670
1,645
2,349
988
—
—
8,468
1,028
Provisions, accruals, deferred
income and other liabilities
6,166
1,127
174
166
6,423
3,302
7,716
1,563
63
45
9,578
2,510
Total related party liabilities
at 31 Dec
28,439
14,422
16,582
14,331
53,950
29,189
32,510
23,013
9,318
5,719
65,371
38,787
Guarantees and commitments
5,338
2,676
—
—
1,686
1,130
11,011
4,974
—
—
1,427
893
The above outstanding balances arose in the ordinary course of business and on substantially the same terms, including interest rates
and security, as for comparable transactions with third-party counterparties.
Post-employment benefit plans
The HSBC Bank (UK) Pension Scheme (the ‘Scheme’) entered into swap transactions with the bank to manage the inflation and interest
rate sensitivity of the liabilities. At 31 December 2021, the gross notional value of the swaps was £5,490m (2020: £5,645m), the swaps
had a positive fair value of £766m to the bank (2020: positive fair value of £713m) and the bank had delivered collateral of £775m (2020:
£711m) to the Scheme in respect of these swaps. All swaps were executed at prevailing market rates and within standard market bid/
offer spreads.
34
Business disposals
In 2021, we accelerated the pace of execution on our strategic ambition to be the preferred international financial partner for our clients
with the announcement of the potential sale of our retail banking businesses in France.
Planned sale of the retail banking business in France
Further to the strategic review, HSBC Continental Europe signed on 25 November 2021 a Framework Agreement with Promontoria
MMB SAS (‘My Money Group’) and its subsidiary Banque des Caraïbes SA, regarding the planned sale of HSBC Continental Europe’s
retail banking business in France. This followed the signing of a Memorandum of Understanding on 18 June 2021 and the conclusion of
the information and consultation processes of the parties with their respective works councils. 
In parallel, several other agreements have been entered into aiming to ensure continuity of service for HSBC Continental Europe's retail
banking customers who hold asset management products with HSBC Global Asset Management (France) and HSBC REIM (France), and
protection and/or life-wrapped insurance products with HSBC Assurances Vie (France). 
The sale, which is subject to regulatory approvals and the satisfaction of other relevant conditions, includes: HSBC Continental Europe’s
French retail banking business; the Crédit Commercial de France (‘CCF’) brand; and HSBC Continental Europe’s 100 per cent ownership
interest in HSBC SFH (France) and its 3% ownership interest in Crédit Logement. The sale would generate an estimated pre-tax loss
including related transaction costs for HSBC Continental Europe of €2 billion. The signing of the framework agreement for the planned
sale of the French retail banking business resulted in a tax deduction (tax value of €382m) for a provision for loss on disposal which was
recorded in the French tax return. A deferred tax liability of the same amount arises as a consequence of the temporary difference
Notes on the Financial Statements
174
HSBC Bank plc Annual Report and Accounts 2021
between the French tax return and IFRS in respect of this provision. The vast majority of the estimated loss for the write down of the
disposal group to fair value less costs to sell will be recognised when it is classified as held for sale in accordance with IFRS 5, which is
currently anticipated to be in 2022. Subsequently, the disposal group classified as held for sale will be re-measured at the lower of
carrying amount and fair value less costs to sell at each reporting period. Any remaining gain or loss not previously recognised shall be
recognised at the date of derecognition which is currently anticipated to be in 2023.
At 31 December 2021, the value of the total assets of the business to be sold was €24.1bn, including €21.9bn of loans and advances to
customers, and the value of customer accounts was €19.9bn. For further information on tax, see page 135 ‘Note 7 - Tax’.
35
Events after the balance sheet date
In its assessment of events after the balance sheet date, the group has considered and concluded that there are no events requiring
adjustment or disclosures in the financial statements.
36
HSBC Bank plc’s subsidiaries, joint ventures and associates
In accordance with section 409 of the Companies Act 2006 a list of HSBC Bank plc subsidiaries, joint ventures and associates, the
registered office address and the effective percentage of equity owned at 31 December 2021 is disclosed below.
Unless otherwise stated, the share capital comprises ordinary or common shares which are held by HSBC Bank plc subsidiaries. The
ownership percentage is provided for each undertaking. The undertakings below are consolidated by HSBC Bank plc unless otherwise
indicated.
HSBC Bank plc's registered office address is:
HSBC Bank plc
8 Canada Square
London E14 5HQ
HSBC Bank plc Annual Report and Accounts 2021
175
Subsidiaries
The undertakings below are consolidated by the group.
Subsidiaries
% of share class
held by immediate
parent company
(or by HSBC Bank
plc where this
varies)
Footnotes
Assetfinance December (H) Limited
100.00
15
Assetfinance December (P) Limited
100.00
2,15
Assetfinance December (R) Limited
100.00
15
Assetfinance June (A) Limited
100.00
15
Assetfinance Limited
100.00
15
Assetfinance March (B) Limited
100.00
16
Assetfinance March (F) Limited
100.00
15
Assetfinance September (F) Limited
100.00
15
Banco Nominees (Guernsey) Limited
100.00
17
Banco Nominees 2 (Guernsey) Limited
100.00
17
Beau Soleil Limited Partnership
n/a
0,18
BentallGreenOak China Real Estate
n/a
0,19
Billingsgate Nominees Limited (In Liquidation)
100.00
2,20
Canada Crescent Nominees (UK) Limited
100.00
2,15
CCF & Partners Asset Management Limited
100.00
(99.99)
15
CCF Holding (LIBAN) S.A.L. (In Liquidation)
74.99
21
Charterhouse Administrators (D.T.) Limited
100.00
(99.99)
15
Charterhouse Management Services Limited
100.00
(99.99)
15
Charterhouse Pensions Limited
100.00
2,15
COIF Nominees Limited
n/a
0,2,15
Corsair IV Financial Services Capital Partners -
B L.P
n/a
0,22
Dem 9
100.00
(99.99)
4,23
Dempar 1
100.00
(99.99)
4,23
Eton Corporate Services Limited
100.00
17
Flandres Contentieux S.A.
100.00
(99.99)
23
Foncière Elysées
100.00
(99.99)
23
Griffin International Limited
100.00
15
Grundstuecksgesellschaft Trinkausstrasse
Kommanditgesellschaft
n/a
0,24
HSBC (BGF) Investments Limited
100.00
2,15
HSBC Asset Finance (UK) Limited
100.00
2,15
HSBC Asset Finance M.O.G. Holdings (UK)
Limited
100.00
2,15
HSBC Assurances Vie (France)
100.00
(99.99)
25
HSBC Bank (General Partner) Limited
100.00
2,26
HSBC Bank (RR) (Limited Liability Company)
n/a
0,7,27
HSBC Bank Armenia cjsc
100.00
28
HSBC Bank Capital Funding (Sterling 1) LP
n/a
0,26
HSBC Bank Capital Funding (Sterling 2) LP
n/a
0,26
HSBC Bank Malta p.l.c.
70.03
29
HSBC City Funding Holdings
100.00
15
HSBC Client Holdings Nominee (UK) Limited
100.00
2,15
HSBC Client Nominee (Jersey) Limited
100.00
2,30
HSBC Continental Europe
99.99
23
HSBC Corporate Trustee Company (UK)
Limited
100.00
2,15
HSBC Custody Services (Guernsey) Limited
100.00
17
HSBC Epargne Entreprise (France)
100.00
(99.99)
25
HSBC Equity (UK) Limited
100.00
2,15
HSBC Europe B.V.
100.00
15
HSBC Factoring (France)
100.00
(99.99)
23
HSBC Germany Holdings GmbH
100.00
2,24
HSBC Global Asset Management (Deutschland)
GmbH
100.00
24
HSBC Global Asset Management (France)
100.00
(99.99)
25
HSBC Global Asset Management (International)
Limited (In Liquidation)
100.00
2,31
HSBC Global Asset Management (Malta)
Limited
100.00
(70.03)
32
HSBC Global Asset Management (Oesterreich)
GmbH (In Liquidation)
100.00
6,33
HSBC Global Asset Management (Switzerland)
AG
100.00
(99.99)
4,34
HSBC Global Custody Nominee (UK) Limited
100.00
2,15
Subsidiaries
% of share class
held by immediate
parent company
(or by HSBC Bank
plc where this
varies)
Footnotes
HSBC Global Custody Proprietary Nominee
(UK) Limited
100.00
1,2,15
HSBC Global Shared Services (India) Private
Limited (In Liquidation)
99.99
1,35
HSBC Infrastructure Limited
100.00
15
HSBC INKA Investment-AG TGV
100.00
8,24
HSBC Insurance Services Holdings Limited
100.00
2,15
HSBC Investment Bank Holdings Limited
100.00
2,15
HSBC Issuer Services Common Depositary
100.00
2,15
HSBC Issuer Services Depositary Nominee
(UK) Limited
100.00
2,15
HSBC Leasing (France)
100.00
(99.99)
23
HSBC Life (UK) Limited
100.00
2,15
HSBC Life Assurance (Malta) Limited
100.00
(70.03)
32
HSBC LU Nominees Limited
100.00
2,15
HSBC Marking Name Nominee (UK) Limited
100.00
2,15
HSBC Middle East Leasing Partnership
n/a
0,36
HSBC Operational Services GmbH
80.00
24
HSBC Overseas Nominee (UK) Limited
100.00
2,15
HSBC PB Corporate Services 1 Limited
100.00
37
HSBC Pension Trust (Ireland) DAC
100.00
2,38
HSBC PI Holdings (Mauritius) Limited
100.00
39
HSBC Preferential LP (UK)
100.00
2,15
HSBC Private Banking Nominee 3 (Jersey)
100.00
40
HSBC Private Equity Investments (UK) Limited
100.00
15
HSBC Private Markets Management SARL
100.00
41
HSBC Property Funds (Holding) Limited
100.00
15
HSBC Real Estate Leasing (France)
100.00
(99.99)
23
HSBC REIM (France)
100.00
(99.99)
25
HSBC Securities (Egypt) S.A.E. (In Liquidation)
100.00
(0.8)
42
HSBC Securities (South Africa) (Pty) Limited
100.00
2,43
HSBC Securities Services (Guernsey) Limited
100.00
(99.99)
17
HSBC Securities Services (Ireland) DAC
100.00
38
HSBC Securities Services (Luxembourg) S.A.
100.00
2,44
HSBC Securities Services Holdings (Ireland)
DAC
100.00
38
HSBC Service Company Germany GmbH
100.00
24
HSBC Services (France)
100.00
(99.99)
23
HSBC SFH (France)
100.00
(99.99)
4,25
HSBC SFT (C.I.) Limited
100.00
2,17
HSBC Specialist Investments Limited
100.00
15
HSBC Transaction Services GmbH
100.00
6,24
HSBC Trinkaus & Burkhardt (International)
100.00
44
HSBC Trinkaus & Burkhardt AG
100.00
24
HSBC Trinkaus & Burkhardt Gesellschaft fur
Bankbeteiligungen mbH
100.00
24
HSBC Trinkaus Europa Immobilien-Fonds Nr. 5
GmbH
100.00
24
HSBC Trinkaus Family Office GmbH
100.00
6,24
HSBC Trinkaus Real Estate GmbH
100.00
6,24
HSBC Trustee (C.I.) Limited
100.00
2,40
HSBC Trustee (Guernsey) Limited
100.00
2,17
HSIL Investments Limited
100.00
15
INKA Internationale Kapitalanlagegesellschaft
mbH
100.00
24
James Capel & Co. Limited (In Liquidation)
100.00
2,45
James Capel (Nominees) Limited
100.00
2,15
James Capel (Taiwan) Nominees Limited
100.00
2,15
Keyser Ullmann Limited
100.00
(99.99)
15
Midcorp Limited
100.00
2,15
Prudential Client HSBC GIS Nominee (UK)
Limited
100.00
2,15
Republic Nominees Limited
100.00
2,17
RLUKREF Nominees (UK) One Limited
100.00
1,2,15
RLUKREF Nominees (UK) Two Limited
100.00
1,2,15
Notes on the Financial Statements
176
HSBC Bank plc Annual Report and Accounts 2021
S.A.P.C. - Ufipro Recouvrement
99.99
23
Saf Baiyun
100.00
(99.99)
4,23
Saf Guangzhou
100.00
(99.99)
4,23
SCI HSBC Assurances Immo
100.00
(99.99)
25
SFM
100.00
(99.99)
23
SFSS Nominees (Pty) Limited
100.00
43
SNC Dorique
99.99
1,5,46
SNC Les Oliviers D'Antibes
60.00
(59.99)
25
SNCB/M6 - 2008 A
100.00
(99.99)
23
SNCB/M6-2007 A
100.00
(99.99)
4,23
SNCB/M6-2007 B
100.00
(99.99)
4,23
Société Française et Suisse
100.00
(99.99)
23
Somers Dublin DAC
100.00
(99.99)
38
Sopingest
100.00
(99.99)
23
South Yorkshire Light Rail Limited
100.00
15
Swan National Limited
100.00
15
The Venture Catalysts Limited
100.00
2,15
Trinkaus Australien Immobilien Fonds Nr. 1
Brisbane GmbH & Co. KG
100.00
24
Trinkaus Australien Immobilien-Fonds Nr. 1
Treuhand-GmbH
100.00
6,24
Trinkaus Europa Immobilien-Fonds Nr.3 Objekt
Utrecht Verwaltungs-GmbH
100.00
24
Trinkaus Immobilien-Fonds
Geschaeftsfuehrungs-GmbH
100.00
6,24
Trinkaus Immobilien-Fonds Verwaltungs-
GmbH
100.00
6,24
Trinkaus Private Equity Management GmbH
100.00
24
Trinkaus Private Equity Verwaltungs GmbH
100.00
6,24
Valeurs Mobilières Elysées
100.00
(99.99)
23
Joint ventures
The undertakings below are joint ventures and equity accounted.
Joint Ventures
% of share class
held by immediate
parent company
(or by HSBC Bank
plc where this
varies)
Footnotes
HCM Holdings Limited (In Liquidation)
50.99
20
The London Silver Market Fixing Limited
n/a
0,1,2,47
Associates
The undertakings below are associates and equity accounted.
Associates
% of share class
held by immediate
parent company
(or by HSBC Bank
plc where this
varies)
Footnotes
BGF Group PLC
24.62
48
Bud Financial Limited
10.89
1,3,49
CFAC Payment Scheme Limited (In Liquidation)
33.33
2,3,50
Contour Pte Ltd
11.76
51
Divido Financial Services Limited
5.60
52
Episode Six Limited
8.09
53
Euro Secured Notes Issuer
16.66
54
LiquidityMatch LLC
n/a
0,55
London Precious Metals Clearing Limited
25.00
2,56
Quantexa Ltd
10.10
57
Services Epargne Enterprise
14.18
58
Simon Group LLC
n/a
0,12
sino AG
24.94
11
Threadneedle Software Holdings Limited
6.60
13
Trade Information Network Limited
16.66
10
Trinkaus Europa Immobilien-Fonds Nr. 7
n/a
0,24
Vizolution Limited
17.95
1,9
We Trade Innovation Designated Activity
9.88
1,14
Footnotes
0
Where an entity is governed by voting rights, HSBC consolidates
when it holds - directly or indirectly - the necessary voting rights
to pass resolutions by the governing body. In all other cases, the
assessment of control is more complex and requires judgement
of other factors, including having exposure to variability of
returns, power to direct relevant activities, and whether power is
held as an agent or principal. HSBC's consolidation policy is
described in Note 1.2(a).
1
Management has determined that these undertakings are
excluded from consolidation in the Group accounts as these
entities do not meet the definition of subsidiaries in accordance
with IFRSs. HSBC’s consolidation policy is described in Note
1.2(a).
2
Directly held by HSBC Bank plc
Description of shares
3
Preference Shares
4
Actions
5
Parts
6
GmbH Anteil
7
Russian Limited Liability Company Shares
8
Stückaktien
Registered offices
9
Office Block A, Bay Studios Business Park, Fabian Way,
Swansea, Wales, United Kingdom, SA1 8QB
10
3 More London Riverside, London, United Kingdom, SE1 2AQ
11
Ernst-Schneider-Platz 1, Duesseldorf, Germany, 40212
12
125 W 25th St. New York, New York, United States of America,
10001
13
34 Copse Wood Way, Northwood, Middlesex, United Kingdom,
HA6 2UA
14
10 Earlsfort Terrace, Dublin, Ireland, D02 T380
15
8 Canada Square , London, United Kingdom, E14 5HQ
16
5 Donegal Square South, Northern Ireland, Belfast, United
Kingdom, BT1 5JP
17
Arnold House, St Julians Avenue, St Peter Port, Guernsey, GY1
3NF
18
HSBC Main Building, 1 Queen's Road Central, Hong Kong
19
Oak House, Hirzel Street, St Peter Port, Guernsey, GY1 2NP
20
156 Great Charles Street, Queensway, Birmingham, West
Midlands, United Kingdom, B3 3HN
21
Solidere - Rue Saad Zaghloul Immeuble - 170 Marfaa, P.O. Box
17 5476 Mar Michael, Beyrouth, Lebanon, 11042040
22
c/o Walkers Corporate Services Limited, Walker House, 87 Mary
Street, George Town, Grand Cayman, Cayman Islands, KY1-9005
23
38 avenue Kléber, Paris, France, 75116
24
Hansaallee 3, Düsseldorf, Germany, 40549
25
Immeuble Cœur Défense, 110 esplanade du Général de Gaulle,
Courbevoie, France, 92400
26
HSBC House Esplanade, St. Helier, Jersey, JE4 8UB
27
2 Paveletskaya Square Building 2, Moscow, Russian Federation,
115054
28
66 Teryan Street, Yerevan, Armenia, 0009
29
116 Archbishop Street, Valletta, Malta
30
HSBC House Esplanade, St. Helier, Jersey, JE1 1HS
31
HSBC House Esplanade, St. Helier, Jersey, JE4 8WP
32
80 Mill Street, Qormi, Malta, QRM 3101
33
Herrengasse 1-3, Wien, Austria, 1010
34
26 Gartenstrasse, Zurich, Switzerland, 8002
35
52/60 M G Road Fort, Mumbai, India, 400 001
36
Unit 101 Level 1, Gate Village Building No. 8 Dubai International
Financial Centre (DIFC), Dubai, United Arab Emirates, P.O. Box
506553
37
HSBC House Esplanade, St. Helier, Jersey, JE1 1GT
38
1 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland,
D02 P820
HSBC Bank plc Annual Report and Accounts 2021
177
39
6th floor HSBC Centre 18, Cybercity, Ebene, Mauritius, 72201
40
HSBC House Esplanade, St Helier, Jersey, JE1 1GT
41
5 rue Heienhaff, Senningerberg, Luxembourg, 1736
42
306 Corniche El Nil, Maadi, Egypt, 11728
43
1 Mutual Place, 107 Rivonia Road, Sandton, Gauteng, South
Africa, 2196
44
16 Boulevard d'Avranches, Luxembourg, L-1160
45
Teneo Restructuring Limited, 156 Great Charles Street,
Queensway, West Midlands, Birmingham, United Kingdom, B3
3HN
46
43 rue de Paris, Saint Denis, France, 97400
47
c/o Hackwood Secretaries Limited One Silk Street, London,
United Kingdom, EC2Y 8HQ
48
13-15 York Buildings, London, United Kingdom, WC2N 6JU
49
Ground Floor, 25b Vyner Street, London, United Kingdom, E2
9DG
50
65 Gresham Street 6th Floor, London, United Kingdom, EC2V
7NQ
51
50 Raffles Place, #32-01 Singapore Land Tower, Singapore,
048623
52
Office 7, 35-37 Ludgate Hill, London, United Kingdom, EC4M
7JN
53
9/F Amtel Bldg, 148 des Voeux Rd Central, Central, Hong Kong
54
3 avenue de l'Opera, Paris, France, 75001
55
100 Town Square Place, Suite 201 | Jersey City, NJ, United
States of America, 07310
56
1-2 Royal Exchange Buildings Royal Exchange, London, United
Kingdom, EC3V 3LF
57
75 Park Lane, Croydon, Surrey, United Kingdom, CR9 1XS
58
32 rue du Champ de Tir, Nantes, France, 44300
Notes on the Financial Statements
178
HSBC Bank plc Annual Report and Accounts 2021
HSBC Bank plc
8 Canada Square
London E14 5HQ
United Kingdom
Telephone: 44 020 7991 8888 www.hsbc.co.uk
Registered number 00014259