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Contents
NWM Group
Annual Report and Accounts 2023
1
Page
Strategic report
Performance highlights
2
Outlook
2
Chief Executive’s review
3
Our strategic framework
4
Our business model: how we create value
5
Strategic progress
7
Operating environment
8
Risk overview
10
Section 172 (1) statement
17
Our colleagues
19
Financial review
20
Risk and capital management
24
Report of the directors
74
Statement of directors’ responsibilities
78
Financial statements
79
Risk factors
165
Forward-looking statements
187
Approval of Strategic report
The Strategic report for the year ended 31 December 2023 set out on pages 2 to 19 was approved by the Board of Directors on 15
February 2024.
By order of the Board
Company Secretary
Sarah Beddows
15 February 2024
Chairman
Frank Dangeard
Executive Directors
Robert Begbie, CEO
Simon Lowe, CFO
Non-Executive Directors
Vivek Ahuja
Tamsin Rowe
Anne Simpson
Sabrina Wilson
Presentation of information
NatWest Markets Plc (‘NWM Plc’) is a wholly owned subsidiary of NatWest Group plc or ‘the ultimate holding company’.
The NatWest Markets Group (‘NWM Group’) or ‘we’ comprises NWM Plc and its subsidiary and associated undertakings.
The term ‘NatWest Group’ comprises NatWest Group plc and its subsidiaries.
The term ‘NatWest Markets’ refers to the primary business activities for NWM Group. These activities form part of the NatWest Group
Commercial & Institutional segment.
Performance highlights
NWM Group
Annual Report and Accounts 2023
2
Against a backdrop of economic volatility in 2023, we have continued to focus on our strengths in supporting our customers’ evolving
needs with financing and risk solutions. As part of the NatWest Group Commercial & Institutional segment, we are making progress by
unlocking further opportunities for growth and strengthening our relationships with NatWest Group customers. Our business
performance for the year has been broadly in line with management’s plan and we have maintained our robust capital and liquidity
position.
NWM Group reported an operating loss before tax for the year ended 31 December 2023 of £75 million, compared with a loss of £447
million for the year ended 31 December 2022. Higher income largely reflected stronger performance in the Fixed Income and Capital
Markets businesses, in addition to the impact of a new profit share arrangement with fellow NatWest Group subsidiaries in 2023. Other
operating expenses for the year under review were £1,082 million compared with £1,048 million for the year ended 31 December 2022,
largely due to lower technology investment costs recognised in the prior year and the impact of one-off items.
Refer to the Financial review section on page 20 for further details on the financial performance for the period.
Financial highlights
2023
2022
£m
£m
Total income
1,069
689
Other operating expenses
(1)
1,082
1,048
Income excluding own credit adjustments
1,072
647
Operating loss before tax
(75)
(447)
Capital and leverage highlights
(2)
2023
2022
CET1 ratio
(3)
17.1%
17.2%
MREL ratio
(3)
34.5%
40.4%
Leverage ratio
5.0%
5.4%
Liquidity coverage ratio
183%
253%
RWAs
£22.1bn
£21.4bn
ESG highlights
2023
2022
Climate and sustainable funding and financing
(4)
£14.8bn
£12.2bn
(1)
Excludes litigation and conduct costs.
(2)
These metrics are shown for NWM Plc. Capital, leverage and risk weighted assets (RWAs) are based on Prudential Regulation Authority (PRA) transitional arrangements for NWM Plc.
Regulatory capital is monitored and reported at NWM Plc level.
(3)
CET1 stands for Common Equity Tier 1 capital and MREL refers to the minimum requirement for own funds and eligible liabilities.
(4)
This comprises funding and financing for climate and sustainable finance to support transition towards a net-zero and climate-resilient economy. NatWest Group uses its climate and
sustainable funding and financing inclusion criteria (CSFFI criteria) to determine the assets, activities and companies that are eligible to be counted towards its climate and sustainable
funding and financing target.
Outlook
(1,2)
We aim to generate sustainable and attractive returns over the medium term, with efficient capital usage.
Medium-term outlook
Metric
(3)
Estimate
CET1 ratio
~14%
MREL ratio
(4)
>30%
Leverage ratio
>4%
(1)
This supersedes all prior guidance.
(2)
The guidance, targets, expectations and trends discussed in this section represent management’s current expectations and are subject to change, including as a result of the factors
described in the ‘Risk factors’ section in this document. These statements constitute forward-looking statements. Refer to ‘Forward-looking statements’ in this document.
(3)
All metrics presented relate to NWM Plc.
(4)
Includes total regulatory capital, non-eligible capital and down streamed internal MREL.
Chief Executive’s review
NWM Group
Annual Report and Accounts 2023
3
In 2023, we continued to support our customers as they
navigated macroeconomic uncertainty and geo-political
challenges – from inflation and changing interest rates to supply-
chain disruption.
Delivering on our strategy of sustainable
growth
Our total income was £1,069 million (55% increase year-on-year)
and the operating loss before tax for the year was £75 million.
This reflected a stronger current year performance compared to
2022, largely driven by Fixed Income and by growth in our Capital
Markets business, in addition to the impact of a new profit share
arrangement with NatWest Group fellow subsidiaries. The new
profit share arrangement was introduced during the year in
relation to NatWest Group Commercial & Institutional business
activity. We have also continued to make progress in closing
legacy matters during the year.
We maintained a robust capital position and reported a strong
CET1 ratio of 17.1% and leverage of 5.0%, with our risk-weighted
assets (RWAs) increasing slightly to £22.1 billion reflecting higher
levels of credit risk and counterparty credit risk, offset partially by
decreases in market and operational risk.
We issued £2.4 billion of public benchmark transactions during
2023 which is lower than guidance of £3 billion to £5 billion for the
year. This was mainly due to higher levels of customer deposits
and optimisation of funding requirements.
Being the best bank we can be for our
customers
I’m proud of the way that, as part of the NatWest Group
Commercial & Institutional (C&I) segment, we are bringing
together the best of our products and services to support
customers’ needs in a challenging market while keeping the bank
resilient, safe and secure.
Examples include a pan-segment approach to our customer
strategy in corporate rates sales and, in foreign exchange (FX),
we’ve onboarded over 500 new and existing Commercial
customers. We’ve continued to grow our Funds business,
providing financing to a range of customers and Fund strategies.
We have ambitious plans for further growth in 2024 and look
forward to further supporting our funds customers’ financing and
hedging needs.
Our Capital Markets business continued to deliver for our
customers, and we achieved year-on-year increases in revenue
(16%) as well as strong league table positions in our chosen debt
markets. We also made good progress in our Fixed Income
business with income increasing by £113 million during the year to
£153 million.
We’ve leveraged our global footprint by working closely with the
businesses in the Commercial & Institutional segment to connect
them to the important US market, as well as supporting US
customers to access financing in the UK and Europe. We’ve raised
funding and financing for our customers from investors in Asia
Pacific (APAC) and have continued to build and strengthen our
European customer business.
Supporting climate transition
We’ve continued to support our customers’ transition to a low
carbon economy as well as their ESG ambitions and targets. This
included supporting NatWest Group’s social bond issuance linked
to women-led enterprises and the Ørsted blue bond, which
represents the world’s first blue bond issued by an energy
company.
In 2023, we provided £14.8 billion of climate and sustainable
funding and financing (21% increase year-on-year), contributing a
cumulative £30.3 billion towards the NatWest Group target of
£100 billion aimed to be delivered between 1 July 2021 and the
end of 2025.
Our progress has also been recognised externally with lead
manager awards in three categories at the Environmental
Finance Bond Awards.
Developing a strong compliance culture
We’re now a year into our US Department of Justice-appointed
monitorship and are working together closely to ensure a strong
control environment for our business.
(1)
From 1 January 2024, NatWest Markets N.V. will be supervised by
the European Central Bank (ECB) in collaboration with De
Nederlandsche Bank (DNB). A robust programme of work has
supported this significant transition to ensure appropriate systems
and processes are in place.
Building our inclusive culture
We’ve continued to invest in our team and business capabilities
through structured development opportunities which support skills
and capability for the future. Our Diversity, Equity and Inclusion
Action Committee has made progress on the focus areas of how
we attract, develop and retain more diverse colleagues.
I believe that, in 2024, we will be in an even stronger position to
support the Commercial & Institutional segment by delivering our
products and capabilities and supporting global connectivity to
strengthen customer relationships. This will build long-term value,
support customers’ ambitions and drive sustainable returns for
shareholders.
Robert Begbie
Chief Executive Officer
(1)
You can find more information on this in the Litigation and regulatory matters section
on page 155.
Our strategic framework
NWM Group
Annual Report and Accounts 2023
4
We are focused on serving our customers
We aim to be the partner of choice to meet the financial markets
needs of NatWest Group’s customers. By providing the expertise,
global footprint and products that our customers require, it
enables us to drive sustainable long-term returns for our business.
Our strategy for growth provides sustainable returns to
shareholders through four strategic priorities:
–
Supporting customers.
–
Powered by people, technology, innovation and partnerships.
–
Simple to deal with.
–
Sharpened capital allocation.
Central to the delivery of our strategy are our values:
inclusive,
curious, robust, sustainable
and
ambitious
.
Read more about our progress against the strategic priorities on
page 7.
We are informed by the needs of our
stakeholders
We aim to balance the different interests of all our stakeholders –
including customers, colleagues, communities and shareholders –
in our decision-making, especially when there are difficult choices
to be made.
Read more on page 18
We aim to create a positive impact
We recognise the responsibilities that our role brings, and this
informs our considered approach. From supporting local housing
associations to funding global customer sustainability initiatives,
we aim to continue to have a positive influence on the
environment.
We focus on three areas where we believe we can make a
long-term, meaningful contribution to our customers,
colleagues and communities:
Climate
Supported by our dedicated Climate and ESG teams, we plan to
continue to grow our climate and ESG activities in our chosen
markets and geographies, including through our climate and
sustainable funding and financing.
We believe that building market momentum for sustainability, and
driving broader education of climate and ESG, is of paramount
importance. To support this, we are continually sharing ESG
thought leadership with our Commercial & Institutional customers
and the wider public. This is through events, webinars and
podcasts, as well as bespoke product solutions to further our
customers’ own ambitions or objectives.
Our resident climate and ESG specialists produce a breadth of
content and insights, with key updates on topics such as ESG
regulation, institutional developments, reporting and ratings.
Enterprise
We continue to serve more of NatWest Group customers,
removing barriers to enterprise and providing businesses in the
UK with the backing they need to grow.
The creation of the Commercial & Institutional business segment
in Q1 2022 has further enabled NatWest Markets to unlock
opportunities across the bank. An example of this has been
supporting Commercial & Institutional customers to access our
foreign exchange capabilities. By working closely with
relationship managers, over 500 new and existing NatWest
Group customers have been onboarded to NWM Group as at
end of 2023 and 1,590 since the initiative began in 2021.
Learning
We are creating the conditions that allow our colleagues to thrive
personally and professionally, while continuing to share our
industry insight with our customers. We continued to build
colleagues’ knowledge and behaviours in understanding their role
in helping to address the climate challenge. The Climate Change
Fundamentals programme in partnership with the University of
Edinburgh was successfully completed by more than 1,350
colleagues.
Colleagues in NWM Group have continued to support initiatives
with schools to support social mobility and educate the next
generation on working in the financial services industry. These
include:
–
At work experience programme, which gives students the
opportunity to learn about the roles and careers available to
them within an investment bank.
–
The ESG work placement programme focusing on climate and
ESG for A-Level students.
–
Participation in two NatWest Group Student Career Compass
hybrid events with participants from over 170 different
universities and schools from across the UK.
Our business model: how we create value
NWM Group
Annual Report and Accounts 2023
5
NWM Group aims to be the partner of choice to meet the financial markets needs of NatWest
Group customers.
1.
Our key
strengths and
resources
Digital First led Currencies and Fixed Income businesses that are connected across NatWest Group,
working seamlessly to deliver for customers.
Innovative Capital Markets platform with industry-leading structuring and distribution expertise.
Recognised Climate and ESG capabilities, providing innovation in Sustainable Finance, ESG advisory and
thought leadership.
Strong capital and liquidity positions.
A highly engaged, customer-focused, diverse workforce with significant expertise and experience.
2.
Our business
Our customers
As part of NatWest Group, we support our corporate and institutional customers.
We work in close collaboration with teams across NatWest Group to provide capital markets and risk
management solutions to its customers.
Our operations
We think and act as one bank for our customers, leveraging NatWest Group’s expertise and shared
services. NWM Group is headquartered in the UK with trading hubs in Asia, Europe and the US.
Financial markets access is offered by NWM Group across NatWest Markets Plc (NWM Plc) and its
subsidiaries, including NatWest Markets Securities Inc. and NatWest Markets N.V. (NWM N.V.).
Our products and solutions
We provide liquidity and risk management in our Currencies and Fixed Income businesses through a
combination of voice and electronic distribution channels. Through our Capital Markets business, we
provide an integrated proposition across financing, solutions and advisory services.
We understand the power of building deep and enduring relationships. One of the ways we do this is by
providing relevant market analysis to customers. Our strategists and content experts across
Currencies, Fixed Income and Capital Markets offer industry and economic insights in the key
economies where our customers do business.
We have a sharp focus on digitisation and automation and we offer a range of digital FX, fixed income,
risk management and international payments options which use our applications or APIs (application
programme interfaces), including Agile Markets, FXmicropay and Rate Manager.
Fixed Income
We have long-standing expertise in the fixed income markets and offer cash bond, repo and interest
rate derivatives, with a focus on sterling, euros and US dollars, that supports our customers’ financing
and hedging needs. In addition, we provide liquidity and credit for investment-grade and high-yield
bonds and loans for both financial institutions and corporate issuers.
Currencies
We are an award-winning foreign exchange service provider offering FX spot, forwards, cross-currency
swaps and options, as well as an FX prime service and FX digital solutions.
Capital Markets
We help customers to access global debt capital markets across a wide variety of products and target
markets, including bonds, loans, commercial paper, medium-term notes (MTNs), private placements, as
well as via bespoke financing solutions and primary lending products. We also provide customers with
thought leadership, advice and innovative solutions to support their climate and ESG strategies through
our Climate and ESG capital markets platform
.
Our business model: how we create value continued
NWM Group
Annual Report and Accounts 2023
6
3.
Value created
for our
stakeholders
Also refer to Board
engagement with key
stakeholders on page 17.
NatWest Group
–
We provide access to financial markets for NatWest Group customers, through an integrated
proposition and expertise.
–
Throughout 2023, NWM Group continued to support NatWest Group’s climate ambition – to be
a leading bank in the UK helping address the climate challenge.
Customers
Our commitment and focus continues to be on anticipating our customers’ needs and providing
excellent customer service and execution. Our support with financing and risk solutions has been
recognised by a number of industry awards
(1)
:
–
At the Environmental Finance’s Bond Awards 2023; NatWest was named ‘Lead manager of
the year, social bonds – financial institution’; ‘Lead manager of the year, social bonds –
supranational, sub-sovereign and agency’; ‘Lead manager of the year, sustainability bonds –
corporate’.
–
NatWest was named ‘Best FX Bank for Corporates’ at the Euromoney Foreign Exchange
Awards 2023 and ‘Best Prime Broker’ 2023 in the eFX Awards.
–
NatWest was named ‘Best Bank for Sustainable Finance in the UK’ at the Global Finance
Sustainable Finance 2023 awards.
–
NatWest was named the ‘Best Sterling Lead Manager’ at the Global Capital Covered Bond
Awards 2023 and won ‘Best Sterling Deal - Santander’ and ‘Best Dollar Deal - National Australia
Bank ’ at the Global Capital Covered Bond Awards 2023.
Colleagues
–
We are committed to investing in our workforce to champion their potential.
–
We are focused on developing our talent and people proposition with greater franchise
mobility and encouraging a culture of innovation.
–
Our integrated wellbeing strategy allows us to support colleagues, customers and
communities.
NatWest Markets investors
–
We maintain a resilient capital base and liquidity, providing confidence to existing and future
investors on the stability of NWM Group as a business.
Regulators and industry bodies
–
We provide insights via our active participation in trade associations and industry-wide
forums on key topics such as the EMIR REFIT (Regulatory Fitness and Performance Program)
and sustainable funding and financing.
–
We actively participate in industry-wide climate-related and ESG forums focused on climate
data collection (Global Financial Markets Association), transition finance (Glasgow Financial
Alliance for Net Zero), product governance (Financial Markets Standards Board), transition
finance and sustainability-linked bonds (The International Capital Market Association) and
facilitated emissions (Partnership for Carbon Accounting Financials).
Community and environment
–
We completed £14.8 billion of climate and sustainable funding and financing in 2023,
contributing a cumulative £30.3 billion towards the NatWest Group target to provide £100 billion
between 1 July 2021 and the end of 2025.
–
We published the NatWest global fixed income investor survey ‘Climate Risks and Opportunities:
What debt investors expect from issuers’, which surveyed 225 asset managers in North America,
APAC, the UK and Europe to see where they stand on climate transition and physical risk, and
the impact on investment strategies. This engagement with investors provides an industry-wide
overview of what action is being undertaken, encourages dialogue between issuers and
investors, and is useful to understand which climate standards and data matter to investors.
(1)
Award entry is at NatWest Group parent level containing NWM Plc content.
Strategic progress
NWM Group
Annual Report and Accounts 2023
7
A strategy to drive sustainable returns for our shareholders.
Strategic priorities
Progress in 2023
Our priorities
Supporting our
customers
Support the
Commercial &
Institutional segment to
invest in growth areas
that matter the most
to our customers.
We delivered growth through our corporate FX and Rates
business, building on our existing commercial relationship.
We deepened capital markets relationships in areas of
specialism.
We continued to advance and demonstrate leadership across
climate and ESG solutions:
–
Sole arranger on Ørsted’s €100 million privately placed
blue bond issuance, focusing on the sustainable use of
ocean resources while preserving marine ecosystems.
This represents the world's first blue bond issued by an
energy company.
–
Joint Sustainability Coordinator on Capital Dynamics
Clean Energy UK’s GBP and EUR green use-of-proceeds
facility. This represents NWM Group’s inaugural-green-
labelled facility provided to a funds client.
Continue to deliver FX and
Rates risk solutions growth
across NatWest Group
customers.
Continued growth in our
Financial Institutions business,
particularly in funds financing.
Drive revenue generation by
further leveraging our
international footprint.
Build on our momentum in
addressing the climate challenge
and ESG themes, supporting the
transition agenda for our
Corporate & Institutional
customers.
Powered by people,
technology,
innovation and
partnerships
Use technology,
leverage our digital
expertise and partner
with leading external
organisations to deliver
excellent customer
experience.
–
Following a successful pilot in 2022 of our cash and liquidity
management tool, Auto FX, we scaled the service to over 240
customers – automatically sweeping elected customer funds
across their NatWest bank accounts using cutting edge
technology and Open Banking, reducing FX risk and the risk
of manual errors.
–
We supported Retail Banking to bring currency conversion to
the entire NatWest ATM cash machine estate across the UK.
–
NWM Group extended our award-winning Agile Markets
platform for Money Market deposits as an integrated part of
our proposition for non-retail customers across NatWest
Group.
–
We continued to develop our digital asset issuance capability,
including progressing on the development of a platform and
the legal framework to issue under English law.
–
We developed an internal model with our settlement systems
to manage and oversee the on/off ramp for fiat/digital
currency.
–
NWM Group became the first bank to be completely
onboarded onto the voluntary carbon credit platform,
Carbonplace. We continue to work with Carbonplace to
enhance platform functionality ahead of participating in our
first trades on this venue.
–
Continue to support customers
by investing in core customer
journeys and simplifying
customer workflows,
automating where needed to
enhance outcomes for our
customers.
–
Leverage our 2023 investment
deliveries to execute
transactions in support of our
customers.
–
Drive innovation in climate and
ESG to incorporate nature and
biodiversity into the product
offering.
–
Development of digital climate
and ESG platforms for our
customers to ensure scalability
across the financial ecosystem.
Simple to deal with
Transform our
business to be simple,
safe and secure –
enabling us to deliver
efficiently and safely
for our customers.
–
We continued to simplify our trade lifecycle management
capability, with continuous linked FX now on the Murex
platform for confirmations and settlements.
–
We continued to simplify our data capability, rationalising and
modernising our data stores.
–
We continued to build cloud capability, enabling on-demand
ability to increase and decrease computer processing,
memory and storage to meet changing demands and to
support risk calculations.
–
Simplify our technology estate
and optimise our processes.
–
Safe and secure technology and
modernisation of key capability.
Sharpened
capital
allocation
Demonstrate effective
capital management
by optimising RWAs
and redeploying capital
to our growth areas.
–
Our Capital Management unit carefully managed capital
allocation and prioritisation, to support the growth of our
segment customer businesses.
–
We provided £14.8 billion of climate and sustainable funding
and financing, contributing a cumulative £30.3 billion towards
the NatWest Group £100 billion target.
–
Further leverage our risk
management and distribution
expertise, both for our
customers and for the bank to
actively manage the use of our
balance sheet and resources.
Operating environment
NWM Group
Annual Report and Accounts 2023
8
NWM Group continues to adapt to evolving market trends.
The environment we operate in is constantly changing. Understanding the multiple influences on our business
enables us to be prepared for change, to respond quickly and to create value for the long term.
Competitive landscape
Overview
NWM Group offers risk management, trading solutions and debt
financing to both financial institutions and UK, European, and US
corporate customers. It competes with large domestic banks, major
international banks and a number of investment banks.
During 2023, corporate and investment banks continued to navigate
elevated geopolitical risks and a shifting macroeconomic
environment underpinned by rising interest rates and inflation. Peers
continued to focus on expanding ESG and sustainable financing
solutions, as well as exploring the application of new technologies
(including artificial intelligence (AI)). Competition also continues from
non-bank liquidity providers using low-latency and algorithmic
trading to participate in high-volume flow markets.
During 2023, Fixed income, Currencies and Commodities (FICC)
divisions in the industry delivered a softer performance reflecting a
low volatility market. The market experienced weaker performance
in fixed income and currencies against a strong 2022, which
particularly benefitted from heightened FX volatility driven by
geopolitical events. Debt capital markets (DCM) saw reduced global
issuance volumes during a risk-off period following collapse of Silicon
Valley Bank and Credit Suisse in 2023, but remained resilient against
higher interest rates.
Our response
NWM Group continued to refine and innovate its products and
services to support the needs of Corporate & Institutional
customers, additionally providing climate and ESG insights and
solutions. By doing so, we also looked to preserve strong market
positions in FX and capital markets in our areas of focus, while also
evolving our rates risk solutions offering to align with the needs of
our customers.
Economy
Overview
NWM Group’s activities primarily relate to the UK, EU and US, with
the majority of its income from operations in the UK. All these
regions displayed growth in 2023, outperforming expectations of
recession at the start of the year. Inflation generally fell throughout
2023, with central banks having repeatedly raised interest rates,
before pausing in the second half of the year.
Our response
NWM Group's business and financial position is intrinsically linked to
changes in market conditions, geopolitical upheaval and broader
economic changes that impact on liquidity, trading, risk and pricing.
Despite an uncertain economic outlook, NWM Group remained
focused on meeting the diverse changing needs of customers in
the UK and internationally.
Regulation
Overview
NWM Group operates in highly-regulated markets which continue
to evolve in scope. It is primarily regulated by:
The Financial Conduct Authority and Prudential Regulation
Authority in the UK;
De Nederlandsche Bank (DNB) which is the Dutch Central
Bank and will be supervised by the European Central Bank
(ECB) effective from 1 January 2024, and the Autoriteit
Financiële Markten (the Dutch Authority for the Financial
Markets) in the Netherlands, the host state regulators of the
jurisdictions in which NWM NV has a branch office and the
Commission de Surveillance du Secteur Financier (CSSF) in
Luxembourg in respect of RBSI Depositary Services S.A.;
The Federal Financial Supervisory Authority (‘BaFin’) in
Germany;
The Securities and Exchange Commission, Commodity
Futures Trading Commission, Federal Reserve Bank of New
York, Financial Industry Regulatory Authority, and National
Futures Association in the US; and
The Monetary Authority of Singapore and the Japan Financial
Services Agency in Asia.
Our response
NWM Group has a global framework to identify, capture and
implement new and changing regulations across its international
footprint. This includes an established prudential programme which
coordinates the regulatory changes encompassed by the finalised
Basel III framework. The programme oversees required capital model
changes, Internal Models Approach (IMA) eligibility and business
readiness for the new and revised regulations, as well as required
changes across trading, risk, finance and technology, and simulates
the capital impact of the revised regulations.
We have direct engagement with regulatory bodies as and when
required to keep them informed of ongoing compliance with
regulations and market standards, as well as indirect contact
through trade associations to help shape future regulatory
requirements.
Cyber threats
Overview
Cyberattacks pose a constant risk to our operations, both in
relation to our own digital estate and indirectly with regards to our
supply chain, reinforcing the importance of due diligence with the
third parties on whom we rely.
Our response
We continue to invest significant resources in the development
and evolution of cybersecurity controls. We perform rigorous due
diligence and governance in relation to our third parties to ensure
they are aligned to our security controls and practices.
Operating environment continued
NWM Group
Annual Report and Accounts 2023
9
Climate change
Overview
NWM Group recognises that climate change is a global issue which
has significant implications and inherent risks for our customers,
colleagues, suppliers, partners and the economy, as well as for NWM
Group itself.
Climate change and environmental degradation are inextricably
linked, and each require immediate and significant action to avert
potentially irreversible impacts.
Climate and nature-related risks have the potential to affect asset
values, operational costs and business models not only through
increasing frequency and severity of extreme weather events and
biodiversity loss, but also as the transition to a net-zero economy
accelerates.
These risks, transmitted through the economy to NWM Group,
continue to evolve reflecting increasing regulatory, legislative, political
and societal change. Likewise, our response continues to develop.
Our response
Throughout 2023, NWM Group continued to play a key role in
delivering NatWest Group’s climate ambition and climate-related
targets. This has included supporting NatWest Group to continue to
implement and refine the Climate transition plan, focusing on
prioritising climate-related opportunities based on their relative
commercial and decarbonisation potential to support our customers
and the wider economy transition to net zero. We also recognise the
power of partnerships and collaborations to overcome critical
challenges to support customers in their sustainability transitions.
The achievement of NatWest Group’s Climate transition plan has a
significant dependency on factors and uncertainties beyond its direct
control, including timely and appropriate UK Government policies.
However, delays to a range of net-zero related UK Government
policies indicate the pace of implementation is slower than required
for the net-zero transition as outlined in the UK CCC’s sixth carbon
budget issued in 2021.
Technology
Overview
The market continues to explore innovative ways to leverage the
power of technology to build and implement new solutions that
optimise business processes and models. As AI, cloud and
blockchain technologies increasingly gain traction and impact,
demand rises for simplification and modernisation of underlying
infrastructure, applications and data to reduce the barriers to
adoption. While technologies like generative AI have the potential to
deliver greater customer personalisation and competitor
differentiation, there are growing concerns around the safeguarding
of data. As such, there is an increasing need for safe and secure
technology solutions to manage and protect customers and their
data.
Our response
For customers, we’re creating enhanced experiences through the
digitalisation of our customer propositions and services, as well as
by strengthening the connection of our capabilities to the broader
Commercial & Institutional segment. For colleagues, we’re creating
the tools, analytics and insights that our people need to effectively
deliver for customers. For capability, the focus on engineering
excellence, protecting our customers, and the digitalisation of
operations with our technology function NatWest Digital X, we are
supporting our efforts towards delivering improvements in speed
and efficiency, while maintaining a safe and secure environment.
Human rights and modern slavery
Overview
At NWM Group, we understand that businesses have an
important role to play in promoting respect for human rights. We
seek to promote and respect human rights through implementing
policies and practices covering our colleagues, customers and
suppliers.
Our response
Our approach to promoting respect for human rights takes into
account a range of international standards and principles,
including the UN Guiding Principles on Business and Human Rights
(UNGPs). In 2023, the NatWest Group Human Rights Action Group
prioritised progress on paying above the minimum and living wage
rates for NatWest Group’s major hubs outside of the UK and in
November extended this commitment to its global operations by
achieving accreditation as a Regional Living Wage Employer from
the Fair Wage Network and is now recognised as a Global Living
Wage Employer.
During 2023, NatWest Group developed a standalone ESE Human
Rights RAC, which broadens the existing ESE approach to
additional high-risk sectors and in December NatWest Group
published detail on its salient human rights issues.
Tackling modern slavery forms an integral part of our approach to
human rights. For the fifth year, our NWM Group colleagues
supported the TRIBE Freedom Foundation and raised over
£17,100 to assist its anti-slavery projects, enabling long-term
support for survivors and helping to raise awareness of modern
slavery.
NatWest Group published its seventh Modern Slavery and Human
Trafficking statement in June 2023. Further information on
NatWest Group’s approach to human rights, including its annual
Modern Slavery and Human Trafficking Statement, Salient Human
Rights Issues and Human Rights Position Statement can be found
at natwestgroup.com.
Risk overview
NWM Group
Annual Report and Accounts 2023
10
Our approach to risk management
NWM Group operates within NatWest Group’s enterprise-wide risk
management framework (EWRMF), which provides a common risk
language to facilitate effective risk management. The framework
applies to all subsidiary legal entities to help deliver NWM Group’s
strategy in a safe and sustainable way.
Risk culture
NatWest Group’s multi-year programme to enhance risk
management capability at different levels of the organisation
continued in 2023, with an ongoing emphasis on risk culture. The
approach to risk culture, under the banner of intelligent risk-taking,
ensures a focus on robust risk management behaviours and
practices.
The approach to our risk culture, in line with our strategy and our
values across all three lines of defence, enables us to support
better customer outcomes, develop a stronger and more
sustainable business and deliver an improved cost base. During
2023, we continued to evolve the five key outcomes to deliver on
the intelligent risk-taking approach. These outcomes focused on
behaviours, leadership, risk practices, decision-making and roles
and responsibilities.
Risk governance
NWM Group’s governance structure facilitates sound risk
management decision-making, in line with standards of good
corporate governance. The Board ensures there is a framework of
prudent and effective controls which enables risks to be assessed
and managed. It reviews the EWRMF, monitors performance
against risk appetite, considers material risks and reviews the
effectiveness of risk management and internal control systems. In
addition, the principal risk committees have the following roles and
responsibilities:
The Board Risk Committee (BRC) is responsible for:
–
Providing oversight and advice to the Board on current and
potential future risk exposures and future risk profile.
including risk appetite and the approval and effectiveness of
internal controls required to manage risk.
–
Reviewing the performance of NWM Group relative to risk
appetite.
–
Reviewing all material risk exposures and management’s
recommendations to monitor, control and mitigate such
exposures, including all principal risks.
–
Approving the Key Risk Policies.
–
Providing input to remuneration decisions from a risk
management perspective.
–
Reviewing and recommending to the Board the
assumptions, scenarios and metrics used for stress tests.
The Executive Risk Committee (ERC), chaired by the Chief Risk
Officer is responsible for:
–
Supporting the CRO and other accountable individuals in
discharging their risk management accountabilities.
–
Reviewing performance relative to risk appetite.
–
Reviewing and debating all material risk exposures across
NWM Group and management’s recommendations to
monitor and control such exposures.
–
Reviewing the EWRMF, supporting its recommendation to
BRC and overseeing its implementation across NWM
Group.
–
Reviewing the Key Risk Policies and supporting their
recommendation to BRC.
Three lines of defence
In line with industry best practice and sound risk governance
principles, NWM Group adopts a three lines of defence model of
risk governance. Everyone has a responsibility for the intelligent
management of risk in day-to-day activities. This includes actively
demonstrating risk practices and behaviours that are consistent
with NWM Group’s desired risk culture.
As the second line of defence, the Risk function has a clear
mandate to undertake proactive risk oversight and monitoring of
all risk management activities including maintaining a robust
control environment. The Risk function designs and maintains the
EWRMF. The Chief Risk Officer leads the Risk function and plays
an integral role in advising the Board on NWM Group’s risk profile.
This includes continuous monitoring activities to confirm that NWM
Group engages in sustainable risk-taking activities in pursuit of
strategic objectives.
Risk appetite
The risk appetite framework is a component of the EWRMF and
establishes the extent of permissible risk-taking to support
business outcomes and delivery of the strategy. The EWRMF sets
out the requirements regarding how risk appetite is implemented
through risk policies and standards and translated into operational
procedures. This consistent approach is followed for all principal
risks, frameworks, tools and techniques. Risk appetite statements
and associated measures are approved at least annually by the
Board on the Board Risk Committee’s recommendation to ensure
they remain appropriate and aligned to strategy.
Risk profile – key developments
NWM Group maintained a stable risk profile in 2023 despite
persistent inflation, higher interest rates and geopolitical tensions
creating a challenging risk environment. Our approach to intelligent
risk-taking helped us support businesses facing these and other
challenges.
The overall financial risk profile remained within risk appetite
despite challenging economic conditions and continuing losses. Key
developments in 2023 included:
NWM Group retained robust capital, liquidity and funding
positions.
The CET1 ratio of 17.1% remained within appetite despite RWA
inflation. RWAs increased in 2023 from £21.4 billion to £22.1
billion, reflecting increased credit and counterparty credit risk,
partially offset by decreases in market risk and operational risk.
Overall credit risk performance remained stable with limited
signs of deterioration despite economic headwinds.
Areas of management focus in the non-financial risk profile in 2023
included:
Ensuring models used by NWM Group are designed effectively –
and that model assumptions and techniques remain fit for
purpose. This included a programme of ongoing work to upgrade
several models to improve performance and compliance with
new regulatory requirements.
Significant investment continued to be made to support the
delivery of the multi-year transformation plan across financial
crime risk management. Enhancements were made to
technology, data quality, and data analytics to improve the
effectiveness of systems used to monitor customers and
transactions.
Risk overview continued
NWM Group
Annual Report and Accounts 2023
11
Enterprise-wide risk management framework
Enterprise-wide risk management framework
01
The enterprise-wide risk management framework (EWRMF) sets out our approach to managing risk across NWM Group and provides a
common risk language and framework to facilitate effective risk management
02
The building blocks of the EWRMF are: risk appetite, risk governance, three lines of defence and risk culture.
Risk appetite
Risk appetite is defined as
the type and aggregate
level of risk NWM Group is
willing to accept in pursuit
of its strategic objectives
and business plans.
Risk governance
NWM Group's governance
structure facilitates sound risk
management decision-making,
in line with standards of good
corporate governance.
Three lines of defence
NWM Group adopts a three
lines of defence model of risk
governance. Everyone has a
responsibility for intelligent risk
taking
.
Risk culture
The EWRMF is centred on
the embedding of a strong
risk culture that encompasses
both prudential and conduct
risk outcomes and prescribed
behaviours.
03
The EWRMF sets out a common risk language and standard definitions to ensure consistency in the application of risk
management terminology
.
Common risk language, architecture and approach
Risk directory and principal
risks
The risk directory
provides a common
language to ensure that
consistent terminology is
used across NWM Group
to describe the principal
risks.
Principal risk policies
Risk policies are in place for
each principal risk and define,
at a high level, the cascade of
qualitative expectations,
guidance and standards for
risk.
Risk standards
Risk standards provide a more
granular expression of the risk
policies and provide the detail
for the first line of defence to
develop operational
policies/procedures.
Risk toolkits
Risk toolkits define the
approaches, tools and
techniques for managing risk
(split by all principal risks,
financial and non-financial
risks).
04
The risk toolkit cycle outlines the NWM Group-
wide approach to identify, assess, mitigate,
monitor and report risks.
05
Principal risks are used as the basis for setting risk
appetite and risk identification.
Principal risks
Report
Identify and assess
Financial risks
Non-financial risks
Capital risk
Financial crime risk
Liquidity and funding risk
Model risk
Reporting of the risk profile,
emerging themes, current
issues and other key
information.
Effective risk identification and
assessment to understand the
risk profile.
Credit risk
Operational risk
Traded market risk
Reputational risk
Monitor
Mitigate
Non-traded market risk
Regulatory compliance risk
Pension risk
Climate risk
Monitoring of the risk profile
through principal risk
indicators or other key
metrics.
Determination of the
appropriate action for
how risks are managed or
mitigated.
Risk overview continued
NWM Group
Annual Report and Accounts 2023
12
Risk directory and principal risks
To ensure common language and a consistent approach across NWM Group, the risk directory defines and documents all principal risks
that NWM Group may face, categorised into financial and non-financial risks. The risk directory is an important component of the
EWRMF, underpinning the linkage between strategy, risk appetite, risk reporting and governance. Principal risks are the Board-approved
EWRMF categories that describe the highest-level financial and non-financial risks in the risk directory.
Principal risks - financial
Key developments
Mitigants
Capital risk
The risk that there is or will be insufficient
capital and other loss-absorbing debt
instruments to operate effectively, including
meeting minimum regulatory requirements,
operating within Board-approved risk
appetite and supporting its strategic goals.
A strong capital position was
maintained in 2023, with the CET1
ratio decreasing by 10 basis points to
17.1%, largely driven by the increase in
RWAs and other movements in
reserves and regulatory adjustments.
Capital planning is integrated into NWM
Group’s wider annual budgeting process
with capital plans produced over a five-
year planning horizon under expected
and stress conditions.
Stress testing is a principal risk
management tool and is used to quantify
and evaluate the potential impact of
risks on the financial strength and capital
position.
Liquidity and funding risk
The risk that NWM Group cannot meet its
actual or potential financial obligations, in a
timely manner, as they fall due. Funding risk
is the risk that NWM Group cannot maintain
a diversified and stable funding base.
A robust liquidity and funding risk
profile was maintained throughout
2023, with a liquidity coverage ratio of
183%, compared to 253% in 2022.
A suite of tools is used to monitor, limit
and stress test the liquidity and funding
risks on the balance sheet. Limit
frameworks are in place to control the
level of liquidity risk, asset and liability
mismatches and funding concentrations.
Liquidity condition indicators are
monitored daily.
Performance is reported to the Assets &
Liabilities Committee on a regular basis.
Credit risk
The risk that customers, counterparties or
issuers fail to meet their contractual
obligation to settle outstanding amounts.
Despite a challenging outlook driven by
persistent inflation and higher interest
rates, the credit risk profile remained
stable throughout 2023.
Extensive and thorough credit processes,
strategies and controls to ensure effective risk
identification, management and oversight.
Sector appetite continues to be reviewed
regularly, with particular focus on sector
clusters and sub-sectors that are deemed to
represent a heightened risk.
Traded market risk
The risk to the value of assets and liabilities
inside the trading book, or the risk to
income which arises from changes in
market prices.
2023 was marked by periods of
increased market volatility. The
significant volatility in gilts, sterling
swaps and inflation entered the rolling
window for value-at-risk (VaR)
calculation during 2023. However,
traded VaR and stressed value-at-risk
(SVaR) remained within appetite and,
on an average basis, at similar levels
compared with 2022.
VaR, SVaR and the incremental risk charge
are used to measure traded market risk.
Traded market risk exposures are monitored
against limits and analysed daily. Limit
reporting is supplemented with regulatory
capital and stress testing.
Non-traded market risk
The risk to the value of assets and liabilities
outside the trading book
or the risk to
income which arises from changes in
market prices.
Overall, non-traded VaR rose in 2023,
on both an average and period end
basis, reflecting time series impacts and
the growth in the banking book. This
was driven by an increasing trend in
credit spread VaR – reflecting
increased holdings of bonds in the
liquidity portfolio – and in interest rate
VaR. Interest rate VaR fell slightly in the
second half of the year.
Non-traded market risk appetite is measured
via VaR, SVaR, sensitivity and stress limits,
and earnings-at-risk limits.
Limits are reviewed to reflect changes in risk
appetite, business plans, portfolio
composition and the market and economic
environments.
Non-traded market risk stress results are
combined with those for other risks into
capital planning.
Risk overview continued
NWM Group
Annual Report and Accounts 2023
13
Risk directory and principal risks continued
Principal risks – financial (continued)
Key developments
Mitigants
Pension risk
The inability to meet contractual obligations
and other liabilities to the established
employee or related company pension
scheme.
NWM Group has exposure to pension risk
through its defined benefit schemes
worldwide.
During 2023, the Trustee of NWM
Group’s largest scheme (the AA Section
of the NatWest Group Pension Fund)
invested in a full scheme buy-in policy
and as a result the scheme is protected
against investment and demographic
risks.
The Pension Committee reviews and
monitors risk management, asset and
liability strategy and financing issues
on behalf of NWM Group.
The pension risk appetite statement
incorporating defined metrics against
which risk is measured is annually
reviewed.
Annual stress tests are undertaken on
the material defined benefit pension
schemes. These tests are also used to
satisfy the requests of regulatory
bodies, such as the Bank of England.
Climate risk
Financial loss or adverse non-financial
impacts associated with climate change
and political, economic and environmental
responses to it.
In 2023, as part of NatWest Group, NWM
Group contributed to a range of scenario
analysis exercises conducted to test the
resilience of its strategy against the
impacts of climate change under different
climate scenarios. NWM Group continued
to enhance its in-house climate risk
modelling capabilities.
There was a focus on developing the
capabilities to use scenario analysis to
identify the most material climate
risks and opportunities for its
customers. While this is a maturing
discipline (with recognised limitations
around data, scenario and
methodologies), progress continues to
be made to leverage the insights to
inform risk management practices,
maximise the opportunities arising
from a transition to a low-carbon
economy and support decision-
making.
Risk overview continued
NWM Group
Annual Report and Accounts 2023
14
Risk directory and principal risks continued
Principal risks – non-financial
Key developments
Mitigants
Financial crime risk
The risk that NWM Group’s products,
services, employees and/or third parties are
intentionally or unintentionally used to
facilitate criminal activities in the form of
money laundering, terrorist financing,
bribery and corruption, sanctions and tax
evasion, as well as external or internal fraud.
Significant investment continued to be
made to support the delivery of the
multi-year transformation plan across
financial crime risk management.
Enhancements were made to
technology, data quality and data
analytics to improve the effectiveness of
systems used to monitor customers and
transactions.
The financial crime framework,
relevant policies, systems, processes
and controls are used to mitigate and
manage financial crime risk. This
includes the use of dedicated
screening and monitoring systems and
controls to identify people,
organisations, transactions and
behaviours that may require further
investigation or other actions.
Model risk
The potential for adverse consequences
from model errors or the inappropriate use
of modelled outputs to inform business
decisions.
NWM Group’s model risk management
practices continued to evolve,
supported by a dedicated model risk
management enhancement
programme, set up in response to the
PRA’s Supervisory Statement 1/23.
Model risk appetite is set to limit the
level of model risk that NWM Group is
willing to accept in the course of its
business activities. Policies, toolkits and
model standards related to the
development, validation, approval,
implementation, use and ongoing
monitoring of models are in place to
ensure adequate control across the
lifecycle of an individual model. This
includes refining, redeveloping or
restricting use of models where
appropriate.
Operational risk
The risk of loss resulting from inadequate or
failed internal processes, people and
systems, or external events. It arises from
day-to-day operations and is relevant to
every aspect of the business.
The enhanced risk and control self-
assessment approach continued to be
developed and embedded with a focus
on material operational risks across key
end-to-end processes.
NWM Group recognised the risk
associated with the processing of
payments, and as such, a NWM Group-
wide programme on the movement of
funds was mobilised, which focused on
enhancing payment related controls.
Operational risk appetite supports
effective management of all
operational risks. It expresses the level
and types of operational risk that
NWM Group is willing to accept to
achieve its strategic objectives and
business plans.
Operational risks are mitigated by
applying key preventative and
detective controls. The half-yearly
control environment certification
process is an effective means to
provide a consistent and comparable
view of the adequacy and
effectiveness of the internal control
environment.
Reputational risk
The risk of damage to stakeholder trust due
to negative consequences arising from
internal actions or external events.
Reputational risk registers were
implemented into relevant business
areas. A new environmental, social and
ethical (ESE) risk acceptance criteria
was implemented to manage human
rights risks.
Relevant internal and external factors
are monitored through regular
reporting via reputational risk
registers. They are escalated, where
appropriate, to the relevant business
risk committee.
ESE risk framework guides decision-
making in areas of elevated
reputational risk. ESE risk acceptance
criteria are regularly reviewed and
updated.
Regulatory compliance risk
The risk that NWM Group fails to observe
the letter and spirit of all relevant laws,
codes, rules, regulations and standards of
good market practice.
Further progress was made on the
compliance agenda during 2023.
Significant enhancements were made to
the compliance and conduct framework
with the introduction of numerous new
tools to manage the risk profile. These
include a compliance and conduct risk
directory and new risk standards and
toolkits which support NWM Group to
measure and manage compliance
accurately and efficiently.
Risk appetite for compliance and
conduct risks is set at Board level. Risk
appetite statements articulate the
levels of risk that businesses and
functions work within when pursuing
their strategic objectives and business
plans.
A range of controls are operated to
ensure the business delivers good
customer outcomes and are
conducted in accordance with legal
and regulatory requirements.
Risk overview continued
NWM Group
Annual Report and Accounts 2023
15
Top and emerging risks
Top and emerging risks are scenarios that could have a significant negative impact on our ability to operate or deliver our strategy and
are managed through the EWRMF toolkit. They usually combine elements of several principal risks and require a coordinated
management response. Top risks could occur or require management action within 1-2 years while emerging risks are evolving and/or
could occur over a longer time horizon but have the potential to become a top risk. Both are subject to review by senior governance
forums including ERC and BRC. Horizon scanning is an important element of the toolkit, enabling NWM Group to identify, assess and
mitigate both top and emerging risks. A range of methods are used including scenario exercises, analysis, planning, monitoring, review of
industry/institutional insights and discussion with external experts. In 2023, there was continued focus on assessing and managing
interconnected risks assessing preparedness for correlated risk scenarios. This approach helps to integrate strategic risk considerations
into business processes, as well as planning and strategy.
Top risk
scenarios in
focus in 2023
Description
Mitigants
Increased
competition
Competitive pressures could intensify, impeding NWM
Group’s ability to grow or retain market share,
impacting revenues and profitability. Drivers of
competition mainly relate to developments in
technology, evolving incumbents, challengers (including
shadow banks and alternative lenders) and new
entrants to the market, shifts in customer behaviour and
changes in regulation. For example, increased
competition from technology conglomerates, who may
have competitive advantages in scale, technology and
customer engagement (including brand recognition).
NWM Group closely monitors the competitive
environment and adapts strategy as appropriate.
This includes utilising scenario analysis and
assessing how mega-trends will impact industry
competitive dynamics. Strategic responses are
focused on investing to deliver innovative and
compelling propositions for customers.
Cyberattack
There is a constantly evolving threat from cyberattacks
that are increasing in terms of frequency, sophistication,
impact and severity. This includes hostile attempts to
gain access to and exploit potential vulnerabilities of IT
systems including via malware. Any failure in NWM
Group’s cybersecurity policies, procedures or controls
may result in significant financial losses, major business
disruption, inability to deliver customer services, loss of
data, and may cause associated reputational damage.
NWM Group continues to invest in additional
capability to defend against threats including
developing and evolving cybersecurity policies,
procedures and controls that are designed to
minimise the potential effect of such attacks. The
focus is to manage the impact of the attacks and
maintain services for NWM Group’s customers.
This includes testing and proving cyber resilience
capabilities via stress testing of NWM Group’s
important business services.
Economic and
rate volatility
Volatile economic conditions created a challenging
operating environment in 2023 and the outlook remains
uncertain. Areas of focus in 2023 included GDP growth,
inflation and interest rates, changing asset prices
(including residential and commercial property), energy
prices, supply-chain disruption, changes to monetary
and fiscal policy, and the impact of armed conflict. Any
of the above may have a material adverse effect on
NWM Group’s future financial prospects.
A range of complementary approaches is used to
mitigate the risks, such as targeted scenario
analysis, stress tests, targeted customer reviews
and reviews of risk appetite. Stress tests included
completion of regulatory stress tests including the
Bank of England 2022/23 Annual Cyclical Scenario
and the 2023/24 System Wide Exploratory
Scenario as well as a range of internal scenarios.
Climate change
Climate-related risks represent a source of systemic risk
in the global financial system. The financial impacts of
climate-related risks, both physical and transition risk,
are expected to be widespread and may disrupt the
proper functioning of financial markets and institutions,
including NWM Group.
NatWest Group’s climate-related strategy, targets
and transition plan support the identification and
management of climate-related risks. However,
they also entail significant execution and
reputational risk and are unlikely to be achieved
without significant and timely government policy,
technology and customer behavioural changes.
Operational risk
scenarios
Operational risks are inherent in NWM Group’s
businesses and a broad range of scenarios are
considered. NWM Group could be adversely impacted by
a broad range of operational risk scenarios including a
failure to have or be able to access current, complete,
and accurate data or disruption to services should a
third-party service provider experience any
interruptions. These scenarios could result in business
and customer interruption and related reputational
damage, significant compensation costs, regulatory
sanctions and/or a breach of applicable regulations.
NWM Group devotes significant resources to
third-party risk management. Focus areas include
identification of critical service suppliers,
developing robust exit and contingency plans in
the event of supply-chain disruption, and ensuring
appropriate monitoring and oversight of third-
party performance.
Effective and ethical use of data is critical to NWM
Group’s goals, with continued focus on delivering
a long-term data strategy alongside enhancing
control and policy frameworks governing data
usage.
Evolving
regulation
NWM Group’s businesses are subject to substantial
regulation and oversight, which are constantly evolving
and may have an adverse impact on NWM Group.
Areas of focus include Basel 3.1 standards
implementation, including the resulting effect on RWAs
and models.
NWM Group constantly monitor regulatory change
and work with the regulators to help shape those
developments that materially impact NWM Group,
responding when necessary either bilaterally or in
partnership with one of the affiliated industry
bodies. We implement new regulatory
requirements where applicable and use our
frequent engagement meetings with regulators to
discuss key regulatory priorities.
Risk overview continued
NWM Group
Annual Report and Accounts 2023
16
Top and emerging risks continued
Emerging risk
scenarios in
focus in 2023
Description
Mitigants
Artificial
intelligence
Innovations in artificial intelligence (AI), including
generative AI, may rapidly transform and disrupt
customers, industry and the economy. NWM Group’s
ability to continue to deploy AI solutions and integrate
AI in systems and controls will become increasingly
important to retain and grow business. There can be
no certainty that NWM Group’s innovation strategy
will be successful, and competitors may be more
successful in implementing AI technologies, in turn,
affecting industry competitive dynamics.
Developments in AI may also result in increased model
risk and rising levels of fraud.
NWM Group closely monitors developments in
disruptive technologies including AI and adapts
strategy as appropriate. The focus is on how we
use AI and machine-learning technologies safely
and ethically to improve the support we can
offer to our customers and ensure that our use
of data continues to be secure, accountable, fair
and ethical.
Biodiversity and
nature loss
NWM Group and its customers, suppliers and
counterparties face uncertainty in terms of risks
relating to the degradation of the environment, such
as air, water and land pollution, biodiversity loss and
deforestation. There is also increasing investor,
regulatory and stakeholder scrutiny regarding how
businesses address these changes and related climate
change, biodiversity and other sustainability issues.
NWM Group, as part of NatWest Group,
participates in developing an approach to
assess, manage and mitigate nature-related
risks. Using emerging industry guidance such as
the Task Force on Nature Related Financial
Disclosure framework, NatWest Group, including
NWM Group, is seeking to further its
understanding of nature-related risks. This
includes how its business activities impact
nature, the dependencies NatWest Group and
its counterparties (including its suppliers) and
customers have on nature, and the risks and
opportunities nature can generate.
Central bank
digital
currency
NWM Group operates in markets which would be
exposed to any developments in digital money,
including a UK central bank digital currency (CBDC).
The Bank of England and HMT are exploring the case
and design for a retail CBDC that could be used by
the public and businesses, the digital pound. The
future introduction of retail CBDCs, including a digital
pound, could result in deposit outflows, higher funding
costs, and/or other implications for UK banks including
NWM Group.
NatWest Group engages with the UK
Government and regulators on digital currency
developments.
This includes engagement with
policymakers on a bilateral and industry level.
For example, NatWest Group is represented on
the Bank of England’s CBDC Engagement
Forum, and responds to relevant consultations,
discussion papers and other publications. In
addition, NatWest Group has established an
Executive Steering Group on digital assets
including overseeing developments and
engagement on digital currencies, such as
CBDCs.
NatWest Group has also reviewed the potential
impact of a UK central bank digital currency
including on deposits, funding costs and broader
implications for the business model.
Geopolitical
risk
NWM Group is exposed to risks arising from
geopolitical events or political developments.
Geopolitical tensions remain elevated and a range of
potential scenarios and impacts were considered. This
includes the potential impact of armed conflict, global
trade and supply-chain disruption, volatility in
commodity prices, concerns regarding sovereign debt
or sovereign credit ratings, changing demographics,
protectionist policies or trade barriers and state
sponsored cyberattacks.
NWM Group closely monitors the geopolitical
risk outlook and undertakes regular scenario
analysis to understand the potential impacts and
takes mitigating actions as required. This
includes second and third order analysis of
impacts, for example, through customers’
supply-chain disruption or disruption to third-
party providers.
Section 172 (1) statement
NWM Group
Annual Report and Accounts 2023
17
Board engagement with key stakeholders
Here we highlight who our key stakeholders are, what matters to them, and how the NWM Plc Board engages with them to create
value.
What matters to them
How we engaged
Outcome of engagement
Customers
The NWM Plc Board is mindful of
the significance of providing a
reliable service to our customers
and supporting them to manage
their financial risks and achieve
their short- and long-term
financial goals.
The NWM Plc Board received regular
updates on customer issues via reports
from the NWM Plc CEO and business
heads, as well as briefings in relation to
the operation of the Commercial &
Institutional segment.
The NWM Plc Board was updated on the
nature and extent of financing activity
provided to customers throughout the
reporting period, during which there
continued to be significant changes in
macroeconomic conditions. The NWM Plc
Board was also regularly updated on
resource allocation between different
customer products and segments.
The NWM Plc CEO continued
to meet with customers
throughout 2023 to understand
their needs and how they can
be best supported by NWM Plc
as part of the Commercial &
Institutional segment.
Colleagues
The NWM Plc Board appreciates
the importance of a wide range
of topics which impact the
workforce, including diversity,
equity and inclusion.
The NWM Plc Board asked colleagues to
share thoughts on what it’s like to work
for NatWest Group, including in NWM Plc,
by completing colleague opinion surveys.
The NatWest Group-level Colleague
Advisory Panel provided a mechanism for
directors to engage directly with
colleagues on topics of strategic interest.
Colleagues were encouraged to report
any concerns relating to wrongdoing or
misconduct using NatWest Group’s
whistleblowing service, Speak Up.
The NatWest Markets
Diversity, Equity and Inclusion
(DE&I) Action Committee feeds
into the One Bank DE&I Action
Committee, which was
established to share best
practice, agree and drive a
focused, action-orientated and
impactful approach to
diversity, equity and inclusion.
Community and environment
The NWM Plc Board recognises
the growing importance of
climate change and its potential
impact on our society.
The NWM Plc Board received regular
updates on the progress made on green
finance along with dedicated sessions held
in relation to: climate strategy; climate
taxonomy and regulation; the impact of
climate on other risks; climate-related
disclosures; product labelling and
reporting; and nature and biodiversity.
The NWM Plc CEO and Deputy CEO
continued to lead a forum which oversees
NWM Group’s response to the risks posed
by climate change and explores the
opportunities for growth in the ESG
market.
The NWM Plc Board is committed to
managing the wider social,
environmental and economic
impacts of NWM Plc’s operations.
Regulators
The focus of regulatory
engagement in 2023 was on the
impact of the macroeconomic
conditions on the market, the
operation of the Commercial &
Institutional segment and
trading, including rates and FX.
The NWM Plc Board recognised the
importance of open and continuous
dialogue with regulators. As such, the
NWM Plc Chairman, executive directors
and non-executive directors had regular
meetings with the PRA and FCA during
2023.
The NWM Plc Board received
regular reports on regulatory
matters and outcomes of
engagement from the
Corporate Governance and
Regulatory Officer.
The NWM Plc Board also plays
an active role in monitoring the
delivery of important regulatory
priorities.
Suppliers
The NWM Plc Board is mindful of
the role suppliers play in
ensuring that a reliable service is
delivered to customers and of
the importance of our
relationships with key suppliers.
The NWM Plc Board regularly received
analytics including updates on the support
functions transferred to NatWest Group
and the operation of the Commercial &
Institutional segment. This allowed NWM
Plc to be aware of and isolate any issues
for remediation.
The NWM Plc Board received
regular updates on the
monitoring of the performance
of critical internal service
management services provided
under the now-embedded
functionalised operating model
and reviewed and approved
risk standards for outsourcing.
Section 172 (1) statement continued
NWM Group
Annual Report and Accounts 2023
18
In this statement we describe how our directors have had regard to the matters set out in section 172(1) (a) to (f) of the Companies
Act 2006 (‘section 172’) when performing their duty to promote the success of the company.
Board engagement with stakeholders
The NWM Plc Board reviews and confirms its key stakeholder
groups for the purposes of section 172 annually. For 2023, these
remained: customers; colleagues; community and environment;
regulators; and suppliers. Examples of how the NWM Plc Board
has engaged with key stakeholders, including the impact of
principal decisions, can be found in this statement and on page 17.
Supporting effective NWM Plc Board
discussions and decision-making
Our NWM Plc Board and committee paper template includes a
section for authors to explain how their paper aligns with our
strategy, and a separate section for them to include an
assessment of the relevant stakeholder impacts for the directors
to consider.
Our directors are mindful that it is not always possible to achieve
an outcome which meets the requirements, needs and/or
expectations of all stakeholders who are, or may be, impacted.
For decisions which are particularly challenging or complex, our
paper template provides directors with further information to
support decision-making. This page uses the ‘Blueprint for Better
Business’ framework as a base and is aligned to our broader
strategic framework.
Principal decisions
Principal decisions are those decisions taken by the NWM Plc
Board that are material, or of strategic importance, to the
company or are significant to NWM Plc’s key stakeholders. Set out
below is an example of the principal decisions taken by the NWM
Plc Board during 2023.
The factors considered were:
likely long-term consequences
employee interests
relationships with customers, suppliers and others
the impact on community and environment
maintaining a reputation for high standards of business
conduct
acting accordingly.
Case study: approval of the earnings stability
risk appetite measure
What was the decision-making process?
Risk appetite, including risk appetite measures, are reviewed and
approved annually for all principal risks in line with the risk
appetite framework.
In June 2023, the NWM Plc Board approved
a revised earnings stability risk appetite measure (RAM).
To support the NWM Plc Board in its decision-making, directors
received comprehensive papers prepared by management which
provided detailed rationale and supporting data for the revised
approach, as well as alternative options which had been explored.
The NWM Plc Board considered the proposals and provided
comprehensive feedback which helped shape the final RAM
approved by the NWM Plc Board.
The NWM Plc Executive and Board Risk Committees also
reviewed the proposals for the revised earnings stability RAM in
advance of the NWM Plc Board and ultimately recommended
them to NWM Plc Board for approval.
How did the directors fulfil their duties under section
172? How were stakeholder interests considered?
In approving the earnings stability RAM, directors were mindful of
their duties under section 172 including the likely long-term
consequences of the decision and whether changes proposed to
the RAM would support the long-term sustainable success of the
company.
Substantial analysis was completed to evaluate options and
assess the long-term impacts of changing the earnings stability
RAM on key stakeholder groups (including employees, customers,
investors, suppliers, the community and the environment), what
their concerns were likely to be, and the key messages that would
support engagement.
There was also extensive engagement with representatives of
NatWest Group to ensure that the approved earnings stability
RAM would support NatWest Group to operate within its
overarching risk appetite. This engagement ensured that the
NWM Plc Board understood the views of NatWest Group and
could balance these with the interests of other stakeholders in
making its decision to approve the NWM Plc earnings stability
RAM.
The revised RAM helps ensure the safety and soundness of NWM
Plc, as it provides the optimum assessment of business activity
against the agreed level of earnings stability risk that NWM Plc is
willing to accept. Accurate tracking of risk through use of the
revised RAM ensures that profits remain sustainable in times of
stress and that we consciously seek earnings stability, ensuring
profits are sufficiently robust to withstand a moderate stress.
Actions and outcomes
The NWM Plc Board approved the earnings stability RAM at its
meeting on 13 June 2023. The NWM Plc Board continues to
monitor performance of the business against the RAM on an
ongoing basis. It will also review the RAM on an annual basis in
line with the requirements of the risk appetite framework.
Our colleagues
NWM Group
Annual Report and Accounts 2023
19
By supporting our colleagues in what they do, and by making sure NWM Group is a great
place to work with a healthy culture, we can champion their potential and collectively deliver
our strategy and purpose.
Our People policies and procedures are, wherever possible, aligned
to NatWest Group. Information on NatWest Group-wide progress
can be found in the ‘Colleagues’ section in the NatWest Group 2023
Annual Report and Accounts.
Supporting our colleagues’ wellbeing
During 2023, we have once again focused on supporting and
championing development opportunities for all colleagues and
people managers, including:
A monthly email tailored to NWM Group colleagues summarising
upcoming events and spotlighting a wide range of personal
development, extra-curricular and wellbeing initiatives happening
across NWM Group and NatWest Group.
A monthly email to all Commercial & Institutional segment
colleagues highlighting NatWest Group-wide and segment-
specific learning and development initiatives, as well as targeted
learning for NWM Group colleagues.
The NatWest Markets Wellbeing Network’s continued work to
make activities and resources available to colleagues, leveraging
the bank-wide wellbeing strategy. The monthly ‘Wellbeing Coffee
Connect’ initiative, when colleagues can take a break and learn
more about the wellbeing resources available, has become well
established, while monthly pilates classes continue.
A new sponsorship initiative to help us identify, engage and
develop a diverse and talented workforce in NWM Group. This
programme will work alongside any existing senior sponsorship
initiatives already in place.
Simplifying and enhancing the efficiency of learning activity,
making best use of our investment in learning, technology and
data. We’ve appointed aligned Capability Partners to help
increase the level of professional learning capability, the impact
of learning solutions, and to share expertise and leverage
coaching partnerships.
Diversity, equity and inclusion (DE&I)
Creating a diverse, equitable and inclusive workplace is integral to
fulfilling our purpose. We want to give everyone who works here,
and every customer who comes into contact with us, the chance
to succeed and the support to thrive.
Using an action-orientated and impactful approach, NatWest
Group’s DE&I strategy focuses on four pillars: recruiting, retaining
and advancing diverse colleagues; embedding an inclusive culture;
developing inclusive and accessible practices and processes; and
supporting a diverse range of customers and communities. The
strategy is governed through a One Bank DE&I Action
Committee, which NWM Group is part of. NatWest Group
initiatives in 2023 included: embedding our enhanced policies for
Partner Leave; targeted development initiatives to accelerate the
advancement of underrepresented colleagues; and enhanced
mandatory interview training to make sure DE&I is front of mind
at every stage of the recruitment process.
NWM Group aligns with NatWest Group’s DE&I strategy and
promotes NatWest Group-wide initiatives. The NWM Group DE&I
Action Committee members represent different areas and levels
of seniority, as well as the NWM Group employee-led networks.
The committee is data-led in its approach and is structured
around three workstreams: attract, retain and develop.
Achievements in these workstreams in 2023 included:
Attract
-
Collaborating with financial services executive
search and advisory firm The Return Hub to support senior
women returning to the workplace; a proactive focus on
attracting diverse talent including collaborations with schools
and universities; supporting the 10,000 Black Interns
scheme; and hosting female insight events. As part of an
ongoing initiative to promote and encourage women in
trading, a group of colleagues hosted the first ‘NatWest
Markets Female Trading Insight Day’ in August 2023, for 10
students aged 15 to 18 years old. The students enjoyed a
tour of the trading floor, interactive trading simulations, and
a variety of sessions on topics such as the different types of
trading roles. Feedback was positive, with all students noting
they would recommend the day to peers, and 80%
interested in trading specifically as a career.
Retain
-
Using bi-annual talent forums to spotlight
underrepresented colleagues and make sure robust development
plans are in place; using ‘advisory chairs’ at senior-level meetings
to support diversity of thought and increase visibility of
underrepresented colleagues across the business; encouraging
colleagues’ voluntary disclosure in our HR database to further
inform our plans. We promoted Inclusion Week in intranet articles,
emails and events; featured DE&I at a global ‘townhall event’; and
dedicated half of the franchise-wide leadership event to how we
embed DE&I.
Develop
-
Launching a targeted sponsorship initiative with an initial
focus on gender and ethnicity to aid career advancement of
diverse talent; embedding team-based active bystander learning,
Choose to Challenge, which educates and upskills participants on
the importance of challenging non-inclusive behaviours – at the
end of 2023, 94% of NWM Group colleagues have taken part in
the Choose to Challenge learning; Broader DE&I learning has also
seen 91% of colleagues enrolling in LGBT+ Awareness learning
and 91% enrolling in our Disability Smart learning, helping us build
a more informed and inclusive workplace.
In 2023, NatWest Group introduced diversity reviews – a
supportive intervention held quarterly with each CEO, including
the NWM Group CEO. The reviews help address any barriers and
ensure that NatWest Group-wide interventions are used.
Targets
-
We align to the NatWest Group target to have full gender
balance in our CEO-3 and above roles globally by 2030. Our NWM
Group target for 2023 was 29%, and as at 31 December 2023, we
had 28% women in our top three layers. The reported mean gender
pay gap is 38.6% (median: 31.0%) and the mean gender bonus gap
is 59.4% (median: 52.9%).
We continue to work towards and support the NatWest Group
target to have 14% of colleagues from ethnic minority groups in
CEO-4 and above positions in the UK by end of 2025. As at 31
December 2023, of 67% of colleagues who disclosed their ethnicity,
we have 22% of colleagues from ethnic minority backgrounds in our
CEO-4 and above positions.
According to our September 2023 NatWest Group engagement
survey, 89% of our colleagues believe they work in an environment
where they can be themselves*, and 90% of colleagues agree that
NatWest Group supports diversity and inclusion in the workplace.
This is 5 points above the average for the Global Financial Services
sector and 2 points above the norm for global high-performing
companies.
*Question is – “I can be myself at work without worrying about how I will be accepted”.
Financial review
NWM Group
Annual Report and Accounts 2023
20
Presentation of information
NatWest Markets Plc (‘NWM Plc’) is a wholly owned subsidiary of
NatWest Group plc or ‘the ultimate holding company’. The term
‘NWM Group’ or ‘we’ refers to NWM Plc and its subsidiary and
associated undertakings.
The term ‘NatWest Group’ refers to NatWest Group plc and its
subsidiary and associated undertakings. The term ‘NWH Group’
refers to NatWest Holdings Limited (‘NWH’) and its subsidiary and
associated undertakings.
The term ‘NatWest Bank Plc’ or ‘NWB
Plc’ refers to National Westminster Bank Plc.
NWM Group publishes its financial statements in pounds sterling
(‘£’ or ‘sterling’). The abbreviations ‘£m’ and ‘£bn’ represent
millions and thousands of millions of pounds sterling, respectively,
and references to ‘pence’ represent pence where amounts are
denominated in pound sterling (‘GBP’). Reference to ‘dollars’ or
‘$’ are to United States of America (‘US’) dollars. The
abbreviations ‘$m’ and ‘$bn’ represent millions and thousands of
millions of dollars, respectively. The abbreviation ‘€’ represents
the ‘euro’, and the abbreviations ‘€m’ and ‘€bn’ represent
millions and thousands of millions of euros, respectively.
Intermediate EU parent undertaking
NatWest Group, as a third-country group with two or more
subsidiary banking institutions in the European Union (‘EU’), was
approved by the European Central Bank (‘ECB’) to establish a
dual Intermediate EU Parent Undertaking (‘IPU’) structure on
behalf of its European subsidiaries. As a result, RBS Holdings N.V.
(‘RBSH N.V.’), a wholly-owned subsidiary of NatWest Markets Plc
(‘NWM Plc’), will act as the non-ring-fenced IPU and be subject to
ECB supervision from 1 January 2024. On 1 December 2023,
RBS International Depositary Services S.A.’s (‘RBSI DS’)
immediate parent company changed from Royal Bank of
Scotland International (Holdings) Limited (‘RBSIH’) to RBSH N.V.
following supervisory approval.
Non-IFRS financial measures
NWM Group prepares its financial statements in accordance with
generally accepted accounting principles (GAAP). This document
contains a number of adjusted or alternative performance
measures, also known as non-GAAP or non-IFRS performance
measures. These measures are adjusted for certain items which
management believe are not representative of the underlying
performance of the business and which distort period-on-period
comparison. These non-IFRS measures provide users of the
financial statements with a consistent basis for comparing
business performance between financial periods and information
on elements of performance that are one-off in nature. The non-
IFRS measures also include the calculation of metrics that are
used throughout the banking industry. These non-IFRS measures
are not measures within the scope of IFRS and are not a
substitute for IFRS measures. Refer to the section, ‘non-IFRS
financial measures’, on page 165 for further information and
calculations of non-IFRS financial measures included throughout
this document, and, where relevant, the most directly
comparable IFRS financial measures.
Performance overview
NWM Group reported a loss for the year ended 31 December
2023 of £98 million compared with a loss of £264 million for the
year ended 31 December 2022. Higher income largely reflected
stronger performances in Fixed Income and Capital Markets and
the impact of a new profit share arrangement with fellow
NatWest Group subsidiaries. Operating expenses for the current
year were slightly higher than in 2022, as a decrease in litigation
and conduct costs was offset by an increase in other operating
expenses.
Financial performance
Income of £1,069 million in 2023 was up by £380 million
compared with £689 million in 2022. The increase was largely
driven by stronger performances in Fixed Income and Capital
Markets, the impact of a new profit share arrangement with
fellow NatWest Group subsidiaries and higher income levels in
Capital Management Unit & other; partially offset by weaker
performance in Currencies, which was impacted by lower FX
volatility levels in the current year, and lower own credit
adjustments.
Operating expenses of £1,142 million increased by £14 million
compared with £1,128 million in 2022. Litigation and conduct
costs of £60 million reflected ongoing progress in closing
legacy matters and were down by £20 million compared with
£80 million in 2022. Other operating expenses of £1,082
million were £34 million higher than £1,048 million in 2022,
largely due to lower technology investment costs recognised
in the prior year and the impact of one-off items.
Total assets and liabilities decreased by £11.9 billion and £11.7
billion to £177.9 billion and £171.5 billion respectively at 31
December 2023, compared with the prior year. The
decreases were mainly driven by lower derivative fair values,
largely reflecting market volatility across major currencies
including the weakening of USD and an overall reduction in
interest rates during the year, following contrasting trends
from the previous year. This was partially offset by higher
funded assets, driven by increases in settlement balances,
loans to customers and other financial assets.
Capital and leverage
Total NWM Plc RWAs were £22.1 billion at 31 December
2023, compared with £21.4 billion at 31 December 2022. The
increase in the year reflected higher levels of credit risk and
counterparty credit risk, partially offset by decreases in
market risk and operational risk.
NWM Plc’s Common Equity Tier 1 (CET1) ratio was 17.1% at
31 December 2023, compared with 17.2% at 31 December
2022. The decrease in the year was largely driven by the
increase in RWAs, in addition to reserve movements.
Total MREL for NWM Plc at 31 December 2023 was £7.6
billion, or 34.5% of RWAs, compared with £8.7 billion or 40.4%
of RWAs at 31 December 2022. The decrease in total MREL
in the current year was largely due to the redemption of a
$0.6 billion internal Tier 2 instrument, decrease in senior
unsecured debt driven by a $0.6 billion instrument now
classified as ineligible, and other reserve movements.
NWM Plc’s leverage ratio was 5.0% at 31 December 2023,
compared with 5.4% at 31 December 2022. The decrease in
2023 was mainly due to higher leverage exposure, driven by
increases in off-balance sheet exposures, loans to customers
and other financial assets.
Liquidity and funding
NWM Plc’s liquidity portfolio at 31 December 2023 was £14.7
billion with an LCR of 183%, compared with £19.1 billion and
an LCR of 253% at 31 December 2022. Stressed coverage
ratio was 162% at 31 December 2023, compared with 199%
at 31 December 2022.
NWM Plc issued £2.4 billion of public benchmark transactions
during 2023, comprised of three issuances under the EMTN
programme being €1.5 billion, CHF0.25 billion and £0.5 billion
of notes respectively, and an issuance under the AUD debt
issuance programme of AUD0.6 billion of notes. NWM Plc also
raised funding in other formats throughout the year including,
but not limited to, structured note issuance. Issuance was
lower than guidance of £3 billion to £5 billion of public
benchmark issuance for the year, mainly due to higher levels
of customer deposits and optimisation of funding
requirements.
NWM Plc 2024 funding plan currently anticipates £3–5 billion
of public benchmark issuance. On 9 January 2024, NWM Plc
issued a total of €2.5 billion of notes under the EMTN
programme in benchmark transactions.
Financial review continued
NWM Group
Annual Report and Accounts 2023
21
NWM Group business review
The table below presents a segmental analysis of key lines of NWM Group’s income statement. Commentary refers to the table below
as well as the statutory income statement presented on page 90.
2023
2022
Variance
Income statement
(1)
£m
£m
£m
%
Net interest income
355
91
264
290
Non-interest income
714
598
116
19
Total income
1,069
689
380
55
Litigation and conduct costs
(60)
(80)
20
(25)
Other operating expenses
(1,082)
(1,048)
(34)
3
Operating expenses
(1,142)
(1,128)
(14)
1
Operating loss before impairment losses
(73)
(439)
366
(83)
Impairment losses
(2)
(8)
6
(75)
Operating loss before tax
(75)
(447)
372
(83)
Tax (charge)/credit
(23)
183
(206)
(113)
Loss for the year
(98)
(264)
166
(63)
Income
(2)
Fixed Income
153
40
113
283
Currencies
496
513
(17)
(3)
Capital Markets
463
398
65
16
Capital Management Unit and other
(3)
(7)
(113)
106
(94)
Income including shared revenue before OCA
1,105
838
267
32
Transfer pricing arrangements with fellow NatWest Group subsidiaries
(4)
(33)
(191)
158
(83)
Income excluding OCA
1,072
647
425
66
Own credit adjustments (OCA)
(3)
42
(45)
(107)
Total income
1,069
689
380
55
(1)
A presentational change was made in Q1 2023 whereby NWM Group no longer separately reports the performance of the NatWest Markets operating segment and Central items &
other.
(2)
Product performance includes gross income earned on a NatWest Group-wide basis, including amounts contributed to other NatWest Group subsidiaries. Income including shared
revenue before OCA includes revenue share from other NatWest Group subsidiaries but before revenue share is paid to or contributed to those subsidiaries.
(3)
Capital Management Unit was set up in Q3 2020 to manage the capital usage and optimisation across all parts of NatWest Markets, with the income materially relating to legacy
positions. Other mainly related to asset disposal/strategic risk reduction costs that were separately disclosed prior to Q1 2023.
(4)
Transfer pricing arrangements with fellow NatWest Group subsidiaries includes shared revenue paid to or contributed to those subsidiaries and a new profit share arrangement with
fellow NatWest Group subsidiaries. The profit share arrangement was introduced during the year to reward NWM Group on an arm’s length basis for its contribution to the performance
of the NatWest Group Commercial & Institutional business segment, 2023 being the first full year with the Commercial & Institutional segment in place. The profit share is not allocated to
individual NatWest Markets product areas.
Net interest income
was £355 million for 2023 compared with £91 million in 2022. Net interest income largely represents interest
income from lending activity and capital hedges, offset by interest expense from the funding costs of the business. The movement
compared with the prior year largely reflects growth in lending activity, interest rate movements and other one-off items.
Non-interest income
of £714 million in 2023 increased by £116 million compared with £598 million in 2022. This was largely driven
by the new profit share arrangement with fellow NatWest Group subsidiaries of £177 million, in addition to higher income levels in
Capital Management Unit & other which reflected lower strategic exit activity in 2023 and fair value movements with regard to
legacy and funding positions. This was partially offset by the impact of one-off items, a weaker performance in Currencies as FX
volatility levels reduced in the current year, and lower own credit adjustments reflecting the widening of spreads in the prior year.
Operating expenses
were £1,142 million in 2023, up by £14 million compared with £1,128 million in 2022. Litigation and conduct
costs of £60 million in 2023 reflected ongoing progress in closing legacy matters and were down by £20 million compared with £80
million in 2022. Other operating expenses of £1,082 million increased by £34 million compared with £1,048 million in 2022, largely
due to lower technology investment costs recognised in the prior year and the impact of one-off items.
Impairment losses
of £2 million in 2023 were down by £6 million compared with £8 million in 2022.
The tax charge
of £23 million on operating loss before tax of £75 million is higher than the expected UK corporation tax rate of
23.5%, primarily due to adjustments in respect of prior periods. Refer to Note 7 Tax for further information.
Financial review continued
NWM Group
Annual Report and Accounts 2023
22
NWM Group business review continued
Balance sheet profile as at 31 December 2023
NWM Group’s balance sheet profile is summarised below. Commentary refers to the tables below as well as the consolidated balance
sheet on page 91.
Assets
Liabilities
2023
2022
2023
2022
£bn
£bn
£bn
£bn
Cash and balances at central banks
13.8
17.0
Securities
12.0
9.9
9.8
9.5
Short positions
Reverse repos
(1)
23.7
21.5
26.9
23.7
Repos
(2)
Derivative cash collateral posted
(3)
8.9
12.7
15.1
17.7
Derivative cash collateral received
(4)
Other trading assets
0.7
1.2
1.8
1.9
Other trading liabilities
Total trading assets
45.3
45.3
53.6
52.8
Total trading liabilities
Loans - amortised cost
14.2
11.3
9.3
6.7
Deposits - amortised cost
Settlement balances
7.2
2.6
6.6
2.0
Settlement balances
Amounts due from holding company
Amounts due to holding company
and fellow subsidiaries
1.7
0.7
5.8
6.2
and fellow subsidiaries
Other financial assets
15.7
11.9
23.6
21.1
Other financial liabilities
Other assets
0.7
0.8
0.6
0.8
Other liabilities
Funded assets
98.6
89.6
99.5
89.6
Liabilities excluding derivatives
Derivative assets
79.3
100.2
72.0
93.6
Derivative liabilities
Total assets
177.9
189.8
171.5
183.2
Total liabilities
of which:
25.1
23.5
wholesale funding
(5)
9.9
7.7
short-term wholesale funding
(5)
Net derivative assets
(6)
2.9
3.5
3.6
5.6
Net derivative liabilities
(6)
(1)
Comprises bank reverse repos of £6.3 billion (2022 - £4.6 billion) and customer reverse repos of £17.4 billion (2022 - £16.9 billion).
(2)
Comprises bank repos of £4.0 billion (2022 - £1.6 billion) and customer repos of £22.9 billion (2022 - £22.1 billion).
(3)
Comprises derivative cash collateral posted relating to banks of £4.3 billion (2022 - £4.6 billion) and customers of £4.6 billion (2022 - £8.1 billion).
(4)
Comprises derivative cash collateral received relating to banks of £6.8 billion (2022 - £7.5 billion) and customers of £8.3 billion (2022 - £10.2 billion).
(5)
Predominantly comprises bank deposits (excluding repos), debt securities in issue and third-party subordinated liabilities.
(6)
Refer to page 56 for further details.
Total assets and liabilities
decreased by £11.9 billion and £11.7 billion to £177.9 billion and £171.5 billion respectively at 31
December 2023, compared with £189.8 billion and £183.2 billion at 31 December 2022. The decreases were mainly driven by
lower derivative fair values, largely reflecting market volatility across major currencies and movements in interest rates. Funded
assets, which exclude derivatives, increased by £9.0 billion to £98.6 billion, largely driven by higher settlement balances, loans to
customers and other financial assets.
Cash and balances at central banks
decreased by £3.2 billion to £13.8 billion at 31 December 2023 compared with £17.0 billion at
31 December 2022, largely driven by a reduction in excess liquidity and liquidity buffer optimisation offset by an increase in
customer deposits.
Trading assets
which primarily relate to client-led activity as well as derivative cash collateral posted, were £45.3 billion at 31
December 2023, consistent with 31 December 2022, as increases in securities and reverse repos were offset by a decrease in
derivative cash collateral posted.
Trading liabilities
increased by £0.8 billion to £53.6 billion at 31 December 2023 from £52.8 billion
at 31 December 2022, largely driven by an increase in repos, partially offset by a decrease in derivatives cash collateral received.
Loans to customers
increased by £2.8 billion to £13.0 billion at 31 December 2023 compared with £10.2 billion at 31 December
2022, largely driven by growth in private financing.
Derivative assets and derivative liabilities
were down by £20.9 billion to £79.3 billion and by £21.6 billion to £72.0 billion respectively
compared with year end 2022. The decreases in mark-to-market values largely reflected market volatility across major currencies
including the weakening of USD and an overall reduction in interest rates during the year, following contrasting trends from the
previous year.
Other financial assets
increased by £3.8 billion to £15.7 billion at 31 December 2023, mainly driven by an increase in held-to-collect
securities purchased to support customer primary issuance.
Customer deposits
increased by £3.4 billion to £7.0 billion at 31 December 2023, in line with our strategy to increase customer
deposits to match planned banking book activity.
Other financial liabilities
of £23.6 billion were up by £2.5 billion from £21.1 billion at 31 December 2022, driven by new issuance
partially offset by maturities. The balance at 31 December 2023 includes £17.6 billion of medium-term notes issued.
Board of directors and secretary
NWM Group
Annual Report and Accounts 2023
23
Board and committees
Chairman
Frank Dangeard
Chairman of the Board and Chairman of the Nominations and
Governance Committee
Executive directors
Robert Begbie
Chief Executive Officer
Simon Lowe
Chief Financial Officer
Independent non-executive directors
Vivek Ahuja
Chairman of Board Risk Committee
Anne Simpson
Chairman of Audit Committee
Tamsin Rowe
Chairman of the Performance and Remuneration Committee
Board changes in 2023
Sabrina Wilson (non-executive director) appointed on 4
September 2023
Auditors
Ernst & Young LLP,
Chartered Accountants and Statutory Auditor
25 Churchill Place
London E14 5EY
Registered
office
NatWest Markets Plc
36 St Andrew Square
Edinburgh
EH2 2YB
Registered in Scotland No. SC090312
Principal
office
NatWest Markets Plc
250 Bishopsgate
London EC2M 4AA
NatWest Markets N.V.
Claude Debussylaan 94
1082 MD Amsterdam, The Netherlands
NatWest Markets Securities Inc.
600 Washington Boulevard, Stamford
06901, CT, USA
Risk and capital management
NWM Group
Annual Report and Accounts 2023
24
Presentation of information
Where marked as audited in the section header, certain
information in the Risk and capital management section (pages
24 to 73) is within the scope of the independent auditor’s report.
Risk and capital management is generally conducted on an
overall basis within NatWest Group such that common policies,
procedures, frameworks and models apply across NatWest
Group. Therefore, for the most part, discussion on these
qualitative aspects reflects those in NatWest Group as relevant
for the businesses and operations in NWM Group.
Risk management framework
Introduction
NWM Group operates under NatWest Group’s enterprise-wide
risk management framework, which is centred on the embedding
of a strong risk culture. The framework ensures the governance,
capabilities and methods are in place to facilitate risk
management and decision-making across the organisation.
The framework ensures that NWM Group’s principal risks –
which are detailed in this section – are appropriately controlled
and managed. It sets out the standards and objectives for risk
management as well as defining the division of roles and
responsibilities.
This seeks to ensure a consistent approach to risk management
across NWM Group. It aligns risk management with NWM
Group’s overall strategic objectives.
The framework, which is designed and maintained by NatWest
Group’s independent Risk function, is owned by the NatWest
Group Chief Risk Officer. It is reviewed and approved annually by
the Board. The framework incorporates risk governance, the
three lines of defence operating model and the Risk function’s
mandate.
Risk appetite, supported by a robust set of principles, policies and
practices, defines the levels of tolerance for a variety of risks and
provides a structured approach to risk-taking within agreed
boundaries.
While all NWM Group colleagues are responsible for managing
risk, the Risk function provides oversight and monitoring of risk
management activities, including the implementation of the
framework and adherence to its supporting policies, standards
and operational procedures. The Chief Risk Officer plays an
integral role in providing the Board with advice on NWM Group’s
risk profile, the performance of its controls and in providing
challenge where a proposed business strategy may exceed risk
tolerance.
In addition, there is a process to identify and manage top and
emerging threats, which are those that could have a significant
negative impact on NWM Group’s ability to meet its strategic
objectives. Both top and emerging risks may incorporate aspects
of – or correlate to – a number of principal risks and are reported
alongside them to the Board on a regular basis.
Page
Risk management framework
Introduction
24
Culture
25
Governance
26
Risk appetite
28
Identification and measurement
29
Mitigation
29
Stress testing
29
Market risk
Traded market risk
33
Non-traded market risk
36
Capital, liquidity and funding risk
Definitions and sources
39
Key developments in 2023
40
Capital management
40
Liquidity and funding management
40
Minimum requirements
40
Measurement
41
Credit risk
Key developments
45
Impairment, provisioning and write-offs
47
Economic loss drivers and ECL sensitivity
48
Trading activities and banking activities
55
Pension risk
65
Compliance & conduct risk
66
Financial crime risk
67
Climate risk
67
Operational risk
71
Model risk
72
Reputational risk
73
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
25
Risk management framework continued
Culture
NWM Group supports NatWest Group’s multi-year programme to
enhance risk management capability at different levels of the
organisation which has an ongoing emphasis on risk culture. The
approach to risk culture, under the banner of intelligent risk-
taking, ensures a focus on robust risk management behaviours
and practices. This underpins the strategy and values across all
three lines of defence, enables NWM Group to support better
customer outcomes, develop a stronger and more sustainable
business and deliver an improved cost base.
NWM Group expects leaders to act as role models for strong risk
behaviours and practices building clarity, developing capability
and motivating employees to reach the required standards set
out in the intelligent risk-taking approach. Colleagues are
expected to:
Consistently role-model the values and behaviours in Our
Code, based on strong ethical standards.
Empower others to take risks aligned to NWM Group’s
strategy, explore issues from a fresh perspective, and tackle
challenges in new and better ways across organisational
boundaries.
Manage risk in line with appropriate risk appetite.
Ensure each decision made keeps NWM Group, colleagues,
customers, communities and shareholders safe and secure.
Understand their role in managing risk, remaining clear and
capable, grounded in knowledge of regulatory obligations.
Consider risk in all actions and decisions.
Escalate risks and issues early; taking action to mitigate risks
and learning from mistakes and near-misses, reporting and
communicating these transparently.
Challenge others’ attitudes, ideas and actions.
The target intelligent risk-taking behaviours are embedded in
NatWest Group’s Critical People Capabilities and are clearly
aligned to the core values of inclusive, curious, robust,
sustainable and ambitious. These aim to act as an effective basis
for a strong risk culture because the Critical People Capabilities
form the basis of all recruitment and selection processes.
Training
Enabling employees to have the capabilities and confidence to
manage risk is core to NWM Group’s learning strategy. NWM
Group offers a wide range of learning, both technical and
behavioural, across the risk disciplines. This training may be
mandatory, role-specific or for personal development. Mandatory
learning for all staff is focused on keeping employees, customers
and NWM Group safe. This is easily accessed online and is
assigned to each person according to their role and business
area. The system allows monitoring at all levels to ensure
completion.
Our Code
NWM Group operates under NatWest Group’s conduct guidance,
Our Code, which provides direction on expected behaviour and
sets out the standards of conduct that support the values. The
code explains the effect of decisions that are taken and describes
the principles that must be followed.
These principles cover conduct-related issues as well as wider
business activities. They focus on desired outcomes, with
practical guidelines to align the values with commercial strategy
and actions. The embedding of these principles facilitates sound
decision-making and a clear focus on good customer outcomes.
Where appropriate, if conduct falls short of NWM Group’s
required standards, the accountability review process is used to
assess how this should be reflected in pay outcomes for the
individuals concerned. The NatWest Group remuneration policy
ensures that the remuneration arrangements for all employees
reflect the principles and standards prescribed by the PRA
rulebook and the FCA handbook. Any employee falling short of
the expected standards would also be subject to internal
disciplinary policies and procedures. If appropriate, the relevant
authority would be notified.
Risk and capital management continued
Risk management framework continued
Governance
Committee structure
The diagram shows NWM Plc’s governance structure in 2023 and the main purposes of each committee.
(1)
The NWM Chief Executive Officer has established the Executive Committee to support him in discharging his individual responsibilities in managing the day to day activities of
NWM.
(2)
The Executive Risk Committee is chaired by the NWM Chief Risk Officer and supports him in discharging his risk management accountabilities.
(3)
The Operating Committee is chaired by the NWM Chief Operating Officer and supports him in discharging his individual accountabilities in accordance with the authority
delegated to him by the NWM Chief Executive Officer.
(4)
The Climate & Sustainability Committee is chaired by the NWM Deputy Chief Executive Officer and supports the NWM CEO in discharging his climate risk accountabilities.
(5)
The Assets & Liabilities Committee is chaired by the NWM Chief Financial Officer and supports him in discharging his individual accountabilities relating to treasury and balance
sheet management.
(6)
The Pension Committee is chaired by the NWM Chief Financial Officer and supports him in discharging his individual accountabilities relating to the management of NatWest
Markets’ pension schemes.
(7)
The Financial Crime Risk Committee, the E-Trading Oversight Committee, the Reputational Risk Committee, the Valuations Committee, the Enterprise-Wide Risk Committee, the
Policy Approval Committee, the Model Risk Committee, the Provisions Committee and the Credit Risk Committee are not shown here. They support the Executive Risk
Committee in discharging its risk management responsibilities.
Risk and capital management continued
Risk management framework continued
Governance
Risk management structure
The diagram shows NWM Group’s risk management structure in 2023.
(1)
The NWM Chief Risk Officer reports directly to the NWM Chief Executive Officer and the NatWest Group Chief Risk Officer. The NWM Chief Risk Officer also has an additional reporting
line to the chair of the NWM Board Risk Committee, and a right of access to the committee.
(2)
The NWM Group Risk function is independent and provides oversight of risk management activities to ensure risks are adequately monitored and controlled. The heads of risk work
closely with the NWM N.V. Chief Risk Officer, the US Head of Risk and the Chief Risk Officer Asia Pacific to ensure consistency across the international businesses.
(3)
The NWH Group Risk function provides services across NatWest Group, including – where agreed – to the NWM Chief Risk Officer. These services are managed, as applicable, through
service level agreements and resource augmentation agreements.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
28
Risk management framework continued
Three lines of defence
NWM Group uses the industry-standard three lines of defence
model to articulate accountabilities and responsibilities for
managing risk. This supports the embedding of effective risk
management throughout the organisation.
First line of defence
The first line of defence incorporates most roles in NWM Group,
including those in the customer-facing businesses, Technology
and Services as well as support functions such as People and
Transformation, Legal and Finance.
The first line of defence is empowered to take risks within the
constraints of the risk management framework, policies, risk
appetite statements set by NatWest Group and measures set by
the NWM Group Board.
The first line of defence is responsible for managing its direct
risks, and with the support of specialist functions, it is also
responsible for managing its consequential risks, by identifying,
assessing, mitigating, monitoring and reporting risks.
Second line of defence
The second line of defence comprises the Risk function and is
independent of the first line.
The second line of defence is empowered to design and maintain
the risk management framework and its components. It
undertakes proactive risk oversight and continuous monitoring
activities to confirm that NWM Group engages in permissible and
sustainable risk-taking activities.
The second line of defence advises on, monitors, challenges,
approves and escalates where required and reports on the risk-
taking activities of the first line, ensuring that these are within the
constraints of the risk management framework, policies, risk
appetite statements set by NatWest Group and measures set by
the NWM Group Board.
Third line of defence
The third line of defence is the Internal Audit function and is
independent of the first and second lines.
The third line of defence is responsible for providing independent
assurance to the Board, its subsidiary legal entity boards and
executive management on the overall design and operating
effectiveness of the risk management framework and its
components. This includes the adequacy and effectiveness of key
internal controls, governance and the risk management in place
to monitor, manage and mitigate the principal risks to NWM
Group and its subsidiary companies achieving their objectives.
The third line of defence executes its duties freely and objectively
in accordance with the Chartered Institute of Internal Auditors’
Code of Ethics and International Standards on independence and
objectivity.
Risk appetite
Risk appetite defines the type and aggregate level of risk NWM
Group is willing to accept in pursuit of its strategic objectives and
business plans. Risk appetite supports sound risk-taking, the
promotion of robust risk practices and risk behaviours, and is
calibrated annually.
For certain principal risks, risk capacity defines the maximum
level of risk NWM Group can assume before breaching
constraints determined by regulatory capital and liquidity
requirements, the operational environment, and from a conduct
perspective. Establishing risk capacity helps determine where risk
appetite should be set, ensuring there is a buffer between
internal risk appetite and NWM Group’s ultimate capacity to
absorb losses.
Risk appetite framework
The risk appetite framework supports effective risk management
by promoting sound risk-taking through a structured approach,
within agreed boundaries. It also ensures emerging threats and
risk-taking activities that might be out of appetite are identified,
assessed, escalated and addressed in a timely manner.
To facilitate this, a detailed review of the framework is carried
out annually. The review includes:
Assessing the adequacy of the framework compared to
internal and external expectations.
Ensuring the framework remains effective and acts as a
strong control environment for risk appetite.
Assessing the level of embedding of risk appetite across the
organisation.
Establishing risk appetite
In line with the risk appetite framework, risk appetite is
maintained across NWM Group through risk appetite statements.
These are in place for all principal risks and describe the extent
and type of activities that can be undertaken.
Risk appetite statements consist of qualitative statements of
appetite supported by risk limits and triggers that operate as a
defence against excessive risk-taking. Risk measures and their
associated limits are an integral part of the risk appetite
approach and a key part of embedding risk appetite in day-to-
day risk management decisions. A clear tolerance for each
principal risk is set in alignment with business activities.
The process of reviewing and updating risk appetite statements
is completed alongside the business and financial planning
process. This ensures that plans and risk appetite are
appropriately aligned.
The Board sets risk appetite for all principal risks to help ensure
NWM Group is well placed to meet its priorities and long-term
targets, even in challenging economic environments. This
supports NWM Group in remaining resilient and secure as it
pursues its strategic business objectives.
Risk appetite statements and associated measures are reviewed
at least annually by the Board on the Board Risk Committee’s
recommendation to ensure they remain appropriate and aligned
to strategy.
NWM Group’s risk profile is continually monitored and frequently
reviewed. Management focus is concentrated on all principal
risks as well as the top and emerging threats that may correlate
to them. Risk profile relative to risk appetite is reported regularly
to senior management and the Board.
NWM Group policies directly support the qualitative aspects of
risk appetite. They define the qualitative expectations, guidance
and standards that stipulate the nature and extent of permissible
risk-taking and are consistently applied across NWM Group and
its subsidiaries.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
29
Risk management framework continued
Identification and measurement
Identification and measurement within the risk management
process comprises:
Regular assessment of the overall risk profile, incorporating
market developments and trends, as well as external and
internal factors.
Monitoring of the risks associated with lending and credit
exposures.
Assessment of trading and non-trading portfolios.
Review of potential risks in new business activities and
processes.
Analysis of potential risks in any complex and unusual
business transactions.
The financial and non-financial risks that NWM Group faces are
detailed in the NatWest Group Risk Directory. This provides a
common risk language to ensure consistent terminology is used
across NWM Group. The NatWest Group Risk Directory is subject
to annual review to ensure it continues to fully reflect the risks
that NWM Group faces.
Mitigation
Mitigation is a critical aspect of ensuring that risk profile remains
within risk appetite. Risk mitigation strategies are discussed and
agreed within NWM Group.
When evaluating possible strategies, costs and benefits, residual
risks (risks that are retained) and secondary risks (those that
arise from risk mitigation actions themselves) are also considered.
Monitoring and review processes are in place to evaluate results.
Early identification, and effective management of changes in
legislation and regulation are critical to the successful mitigation
of compliance and conduct risk. The effects of all changes are
managed to ensure the timely achievement of compliance. Those
changes assessed as having a high or medium-high impact are
managed more closely. Emerging threats that could affect future
results and performance are also closely monitored. Action is
taken to mitigate potential risks as and when required. Further
in-depth analysis, including the stress testing of exposures, is also
carried out.
Stress testing
Stress testing – capital management
Stress testing is a key risk management tool and a fundamental
component of NWM Group’s approach to capital management. It
is used to quantify and evaluate the potential impact of specified
changes to risk factors on the financial strength of NWM Group,
including its capital position.
Stress testing includes:
Scenario testing, which examines the impact of a
hypothetical future state to define changes in risk factors.
Sensitivity testing, which examines the impact of an
incremental change to one or more risk factors.
The process for stress testing consists of four broad stages:
Define
scenarios
Identify macro and NWM Group
specific vulnerabilities and risks.
Define and calibrate scenarios to
examine risks and vulnerabilities.
Formal governance process to agree
scenarios.
Assess
impact
Translate scenarios into risk drivers.
Assess impact to current and
projected P&L and balance sheet
across NWM Group.
Calculate
results and
assess
implications
Aggregate impacts into overall
results.
Results form part of the risk
management process.
Scenario results are used to inform
NWM Group’s business and capital
plans.
Develop and
agree
management
actions
Scenario results are analysed by
subject matter experts. Appropriate
management actions are then
developed.
Scenario results and management
actions are reviewed by the relevant
Executive Risk Committees and
Board Risk Committees and agreed
by the relevant Boards.
Stress testing is used widely across NatWest Group, including at
NWM Group level. The diagram below summarises key areas of
focus.
Stress testing
usage within
NatWest
Group
Contingency
planning & management
actions
Assess financial
performance
Capital
adequacy
Earnings
stability
Sector review
& credit limit
setting
Business
vulnerabilities
analysis
Tail risk
assessment
Early
warning
indicators
(4)
Risk
mitigation
(1)
Strategic
financial
& capital
planning
(2)
Risk
appetite
(3)
Risk
monitoring
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
30
Risk management framework continued
Specific areas that involve capital management include:
Strategic financial and capital planning
– by assessing the
impact of sensitivities and scenarios on the capital plan and
capital ratios.
Risk appetite
– by gaining a better understanding of the
drivers of, and the underlying risks associated with, risk
appetite.
Risk monitoring
– by monitoring the risks and horizon-
scanning events that could potentially affect NWM Group’s
financial strength and capital position.
Risk mitigation
–
by identifying actions to mitigate risks, or
those that could be taken, in the event of adverse changes to
the business or economic environment. Principal risk
mitigating actions are documented in NWM Group’s recovery
plan
.
Reverse stress testing is also carried out in order to identify and
assess scenarios that would cause NWM Group’s business model
to become unviable. Reverse stress testing allows potential
vulnerabilities in the business model to be examined more fully.
Capital sufficiency – going concern forward-looking view
Going concern capital requirements are examined on a forward-
looking basis – including as part of the annual budgeting process
– by assessing the resilience of capital adequacy and leverage
ratios under hypothetical future states. These assessments
include assumptions about regulatory and accounting factors
(such as IFRS 9). They incorporate economic variables and key
assumptions on balance sheet and P&L drivers, such as
impairments, to demonstrate that NWM Group and its operating
subsidiaries maintain sufficient capital.
A range of future states are tested. In particular, capital
requirements are assessed:
Based on a forecast of future business performance, given
expectations of economic and market conditions over the
forecast period.
Based on a forecast of future business performance under
adverse economic and market conditions over the forecast
period. Scenarios of different severity may be examined.
The examination of capital requirements under both normal and
adverse economic and market conditions enables NWM Group to
determine whether its projected business performance meets
internal plans and regulatory capital requirements.
The potential impact of normal and adverse economic and
market conditions on capital requirements is assessed through
stress testing, the results of which are not only used widely
across NWM Group but also by the regulators to set specific
capital buffers. NWM Group takes part in stress tests run by
regulatory authorities to test industry-wide vulnerabilities under
crystallising global and domestic systemic risks.
Under stress testing, the peak-to-trough change in CET1 may be
affected by the transitions from Stage 1 to Stage 2 in stress
conditions. Stress and peak-to-trough movements are used to
help assess the amount of capital NWM Group needs to hold in
stress conditions in accordance with the capital risk appetite
framework.
Internal assessment of capital adequacy
An internal assessment of material risks is carried out annually to
enable an evaluation of the amount, type and distribution of
capital required to cover these risks. This is referred to as the
Internal Capital Adequacy Assessment Process (ICAAP). The
ICAAP consists of a point-in-time assessment of exposures and
risks at the end of the financial year together with a forward-
looking stress capital assessment. The ICAAP is approved by the
Board and submitted to the PRA.
The ICAAP is used to form a view of capital adequacy separately
to the minimum regulatory requirements. The ICAAP is used by
the PRA to assess NWM Group’s specific capital requirements
through the Pillar 2 framework.
Capital allocation
NWM Group has mechanisms to allocate capital across its
businesses. These aim to optimise the use of capital resources
taking into account applicable regulatory requirements, strategic
and business objectives and risk appetite. The framework for
allocating capital is approved by the CFO with support from the
Assets & Liabilities Committee.
Governance
Capital management is subject to substantial review and
governance. The Board approves the capital plans, including
those for key legal entities and businesses as well as the results
of the stress tests relating to those capital plans.
Stress testing – liquidity
Liquidity risk monitoring and contingency planning
A suite of tools is used to monitor, limit and stress test the
liquidity and funding risks on the balance sheet. Limit frameworks
are in place to control the level of liquidity risk, asset and liability
mismatches and funding concentrations. Liquidity and funding
risks are reviewed at significant legal entity and business levels
daily, with performance reported to the Assets & Liabilities
Committee on a regular basis. Liquidity Condition Indicators are
monitored daily. This ensures any build-up of stress is detected
early and the response escalated appropriately through recovery
planning.
Internal assessment of liquidity
Under the liquidity risk management framework, NWM Group
maintains the Internal Liquidity Adequacy Assessment Process.
This includes assessment of net stressed liquidity outflows under
a range of extreme but plausible stress scenarios detailed in the
following table.
Type
Description
Idiosyncratic
scenario
The market perceives NWM Group to be
suffering from a severe stress event, which
results in an immediate assumption of
increased credit risk or concerns over
solvency.
Market-wide
scenario
A market stress event affecting all
participants in a market through contagion,
potential counterparty failure and other
market risks. NWM Group is affected under
this scenario but no more severely than any
other participants with equivalent exposure.
Combined
scenario
This scenario models the combined impact
of an idiosyncratic and market stress
occurring at once, severely affecting funding
markets and the liquidity of some assets.
NWM Group uses the most severe outcome to set the internal
stress testing scenario which underpins its internal liquidity risk
appetite. This complements the regulatory liquidity coverage ratio
requirement.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
31
Risk management framework continued
Stress testing – recovery and resolution planning
Within NWM Group, both NWM Plc and NWM N.V. each have a
recovery plan explaining how they would identify and respond to
a financial stress event and restore their financial position so that
they remain viable on an ongoing basis.
The recovery plan ensures risks that could delay the
implementation of a recovery strategy are highlighted and
preparations are made to minimise the impact of these risks.
Preparations include:
Developing a series of recovery indicators to provide early
warning of potential stress events.
Clarifying roles, responsibilities and escalation routes to
minimise uncertainty or delay.
Developing a recovery playbook to provide a concise
description of the actions required during recovery.
Detailing a range of options to address different stress
conditions.
Appointing dedicated option owners to reduce the risk of
delay and capacity concerns.
The plan is intended to enable critical services and products to be
maintained, as well as core business lines while operating within
risk appetite and restoring financial condition. It is assessed for
appropriateness on an ongoing basis. The NWM Plc plan is
reviewed and approved by the Board prior to submission to the
PRA.
Fire drill simulations of possible recovery events are used to test
the effectiveness of the recovery plans. The fire drills are
designed to replicate possible financial stress conditions and allow
senior management to rehearse the responses and decisions that
may be required in an actual stress event. The results and
lessons learnt from the fire drills are used to enhance the overall
approach to recovery planning.
Under the resolution assessment part of the PRA rulebook,
NatWest Group is required to carry out an assessment of its
preparations for resolution, submit a report of the assessment to
the PRA and publish a summary of this report.
Resolution would be implemented if NatWest Group was assessed
by the UK authorities to have failed and the appropriate regulator
put it into resolution. The process of resolution is owned and
implemented by the Bank of England (as the UK resolution
authority). NatWest Group ensures ongoing maintenance and
enhancements of its resolution capabilities, in line with regulatory
requirements.
Stress testing – market risk
Non-traded market risk
Non-traded exposures are reported to the PRA on a quarterly
basis. This provides the regulator with an overview of NatWest
Group’s banking book interest rate exposure. The report includes
detailed product information analysed by interest rate driver and
other characteristics, including accounting classification, currency
and counterparty type.
Scenario analysis based on hypothetical adverse scenarios is
performed on non-traded exposures as part of the Bank of
England and European Banking Authority stress test exercises.
NatWest Group also produces an internal scenario analysis as
part of its financial planning cycles.
Non-traded exposures are capitalised through the ICAAP. This
covers gap risk, basis risk, credit spread risk, pipeline risk,
structural foreign exchange risk, prepayment risk, equity risk and
accounting volatility risk. The ICAAP is completed with a
combination of value and earnings measures. The total non-
traded market risk capital requirement is determined by adding
the different charges for each sub risk type.
The ICAAP methodology captures at least ten years of historical
volatility, produced with a 99% confidence level. Methodologies
are reviewed by NatWest Group Model Risk and the results are
approved by the NatWest Group Technical Asset & Liability
Management Committee.
Non-traded market risk stress results are combined with those
for other risks into the capital plan presented to the Board. The
cross-risk capital planning process is conducted once a year, with
a planning horizon of five years. The scenario narratives cover
both regulatory scenarios and macroeconomic scenarios
identified by NatWest Group.
Vulnerability-based stress testing begins with the analysis of a
portfolio and expresses its key vulnerabilities in terms of plausible,
vulnerability scenarios under which the portfolio would suffer
material losses. These scenarios can be historical,
macroeconomic or forward-looking/hypothetical. Vulnerability-
based stress testing is used for internal management information
and is not subject to limits. The results for relevant scenarios are
reported to senior management.
Traded market risk
NWM Group carries out regular market risk stress testing to
identify vulnerabilities and potential losses in excess of, or not
captured in, value-at-risk. The calculated stresses measure the
impact of changes in risk factors on the fair values of the trading
portfolios.
NWM Group conducts historical, macroeconomic and
vulnerability-based stress testing. Historical stress testing is a
measure that is used for internal management. Using the
historical simulation framework employed for value-at-risk, the
current portfolio is stressed using historical data since 1 January
2005. This methodology simulates the impact of the 99.9
percentile loss that would be incurred by historical risk factor
movements over the period, assuming variable holding periods
specific to the risk factors and the businesses.
Historical stress tests form part of the market risk limit
framework and their results are reported regularly to senior
management. Macroeconomic stress tests are carried out
periodically as part of the bank-wide, cross-risk capital planning
process. The scenario narratives are translated into risk factor
shocks using historical events and insights by economists, risk
managers and the first line.
Market risk stress results are combined with those for other risks
into the capital plan presented to the Board. The cross-risk
capital planning process is conducted once a year, with a
planning horizon of five years. The scenario narratives cover both
regulatory scenarios and macroeconomic scenarios.
Vulnerability-based stress testing begins with the analysis of a
portfolio and expresses its key vulnerabilities in terms of plausible
vulnerability scenarios under which the portfolio would suffer
material losses. These scenarios can be historical,
macroeconomic or forward-looking/hypothetical. Vulnerability-
based stress testing is used for internal management information
and is not subject to limits. The results for relevant scenarios are
reported to senior management
.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
32
Risk management framework continued
Internal scenarios - climate
During 2023, NWM Group continued to review and refine its
internal scenarios where appropriate.
In addition, NWM Group vulnerabilities are considered as part of
the development of all NatWest Group-wide integrated scenarios
and exercises.
In 2023, NatWest Group deployed a new in-house corporate
transition risk model, as part of an internal scenario analysis
exercise, to assess climate transition related credit risks to
corporate counterparties.
This involved running the following two climate scenarios:
A disruptive policy response scenario, where the introduction
of policy from the Network for Greening the Financial System
delayed transition scenario, is accelerated to this decade.
Inevitable policy response 1.8°C scenario, which anticipates
investor, corporate and civil society pressure will push
policymakers to make changes between 2023 and 2033, that
could result in warming at or below 1.8°C by 2100.
These scenarios tested NatWest Group’s resilience to alternative
transition pathways, including a disruptive transition, and to
identify losses that are sensitive to scenario policy and
technology assumptions.
The corporate transition risk model and internal exercise builds
on the learnings from the Climate Biennial Exploratory Scenario
and integrates climate into ICAAP. The model is capable of
accounting for sector specific exposure to climate-related
transition risks and counterparty specific response to a limited set
of demand shocks and rising carbon prices, by mitigating
emissions and passing costs through to customers.
Regulatory stress testing
The Bank of England published the results of the 2022 annual
cyclical scenario (ACS) stress test on 12 July 2023. The results of
this stress test, and other relevant information, will be used to
help inform NWM Group and NatWest Group capital buffers (both
the UK countercyclical capital buffer rate and PRA buffers).
The 2022 stress test aimed to assess the impact of a UK and
global macroeconomic stress on UK banks, spanning a five-year
period from Q3 2022 to Q2 2027. It is a coherent ‘tail risk’
scenario, designed to be severe and broad enough to assess the
resilience of UK banks to a range of adverse shocks.
The stress scenario is broadly similar to the 2019 ACS and more
severe overall than the global financial crisis, with the key
difference being elevated levels of inflation. Annual UK inflation
averaged around 11% over the first three years of the scenario,
peaking at 17% in early 2023.
The stress test was based on an end-of-June 2022 balance sheet
starting position.
Further details can be found at:
https://www.bankofengland.co.uk/stress-testing/2023/bank-of-
england-stress-testing-results
Following the UK’s exit from the European Union on 31
December 2020, only relevant European subsidiaries of NatWest
Group will take part in the European Banking Authority stress
tests. NatWest Group itself does not participate.
NatWest Group, including NWM Group, is taking part in the Bank
of England’s system-wide exploratory scenario in 2023/24. The
objective of the exercise is to understand the risks and
behaviours flowing from non-bank financial institutions under
stress, and how these risks could amplify market shocks and
pose a risk to financial stability. The Bank of England will publish
a report on this scenario in 2024 following completion of the
exercise.
In addition to its participation in NatWest Group’s stress testing
programme, NWM Group has a further regulatory commitment in
relation to its traded risk model approvals for market risk (IMA)
and counterparty credit risk (IMM). A robust stress testing
framework is a regulatory requirement.
The purpose of this stress testing framework includes the
identification of possible causes of large losses, an estimation of
their size and potential impact on capital adequacy together with
the identification of steps that could be taken to manage those
exposures as required. Such risk management-led stress testing
covers both traded market risk and counterparty credit risk and
is used to monitor and set risk appetite.
The requirements of NWM Group’s stress testing programme are
codified in NWM Group’s stress testing policy and associated
mandatory procedures.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
33
Market
risk
(audited)
NWM Group is exposed to traded market risk through its trading
activities and to non-traded market risk through its banking
activities. Traded and non-traded market risk exposures are
managed and discussed separately. The traded market risk
section begins below. The non-traded market risk section begins
on page 36.
Pension-related activities also give rise to market risk. Refer to
page 65 for more information on risk related to pensions.
Traded market risk
Definition
(audited)
Traded market risk is the risk of losses in trading book positions
from fluctuations in market variables, such as interest rates,
credit spreads, foreign exchange rates, equity prices, implied
volatilities and asset correlations.
Sources of risk
(audited)
Traded market risk mainly arises from NWM Group’s trading
activities. These activities provide a range of financing, risk
management and investment services to clients – including
corporations and financial institutions – around the world. From a
market risk perspective, activities are focused on rates;
currencies; and traded credit.
NWM Group undertakes transactions in financial instruments
including debt securities, as well as securities financing and
derivatives.
The key categories of traded market risk are interest rate risk,
credit spread risk and foreign currency price risk.
Trading activities may also give rise to counterparty credit risk.
For further detail, refer to the Credit risk section
.
Key developments in 2023
The year was marked by periods of increased market
volatility reflecting UK political developments, global
inflationary concerns, the ongoing Russia-Ukraine conflict
and the Israeli–Hamas conflict.
The significant volatility in Gilts, sterling swaps and inflation
entered the rolling window for the value-at-risk (VaR)
calculation during 2023. However, traded VaR and stressed
value-at-risk (SVaR) remained within appetite and, on an
average basis, at similar levels compared to 2022, aided by
NWM Group’s continued disciplined approach to risk-taking.
Governance
(audited)
Market risk policy statements set out the governance and risk
management framework. Responsibility for identifying,
measuring, monitoring and controlling market risk arising from
trading activities lies with the relevant trading business. The
Market Risk function independently advises on, monitors and
challenges the risk-taking activities undertaken by the trading
business ensuring these are within the constraints of the market
risk framework, policies, and risk appetite statements and
measures.
Risk appetite
NWM Group’s qualitative appetite for traded market risk is set
out in the traded market risk appetite statement. Quantitative
appetite is expressed in terms of exposure limits. The limits at
NWM Group level comprise VaR, SVaR and stress-testing. More
details on these are provided on the following pages.
For each trading business, a document known as a dealing
authority compiles details of all applicable limits and trading
restrictions. The desk-level mandates comprise qualitative limits
related to the product types within the scope of each desk, as
well as quantitative metrics specific to the desk’s market risk
exposures. These additional limits and metrics aim to control
various risk dimensions such as exposure size, aged inventory,
currency and tenor.
The limits are reviewed to reflect changes in risk appetite,
business plans, portfolio composition and the market and
economic environments and recalibrated to ensure that they
remain aligned to NWM Group RWA targets. Limit reviews focus
on optimising the alignment between traded market risk
exposure and capital usage.
To ensure approved limits are not breached and that NWM
Group remains within its risk appetite, triggers have been set
such that if exposures exceed a specified level, action plans are
developed by the relevant business and the Market Risk function
and implemented.
The risk appetite statements and associated measures are
reviewed at least annually by the relevant legal entity board on
the relevant board risk committee’s recommendation to ensure
they remain appropriate and aligned to strategy. For more detail
on risk appetite, refer to page 28.
Monitoring and mitigation
Traded market risk is identified and assessed by gathering,
analysing, monitoring and reporting market risk information at
desk, business and NWM Group-wide levels. Industry expertise
continued system developments and techniques such as stress
testing are also used to enhance the effectiveness of the
identification and assessment of all material market risks.
Traded market risk exposures are monitored against limits and
analysed daily. A daily report summarising the position of
exposures against limits at desk, business and NWM Group levels
is provided to senior management and market risk managers
across the function. Limit reporting is supplemented with
regulatory capital and stress testing information as well as ad-
hoc reporting.
A risk review of trading businesses is undertaken weekly with
senior risk and front office staff. This includes a review of profit
and loss drivers, notable position concentrations and other
positions of concern.
Business profit and loss performance is monitored automatically
through loss triggers which, if breached, require a remedial
action plan to be agreed between the Market Risk function and
the business. The loss triggers are set using both a fall-from-peak
approach and an absolute loss level. In addition, regular updates
on traded market risk positions are provided to NWM Group’s
Executive Risk Committee and Board Risk Committee.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
34
Traded market risk continued
Measurement
(audited)
NWM Group uses VaR, SVaR and the incremental risk charge
(IRC) to capitalise traded market risk. Risks that are not
adequately captured by VaR or SVaR are captured by the Risks
Not In VaR (RNIV) framework to ensure that NWM Group is
adequately capitalised for market risk. In addition, stress testing
is used to identify any vulnerabilities and potential losses.
The key inputs into these measurement methods are market
data and risk factor sensitivities. Sensitivities refer to the changes
in trade or portfolio value that result from small changes in
market parameters that are subject to the market risk limit
framework. Revaluation ladders are used in place of sensitivities
to capture the impact of large moves in risk factors or the joint
impact of two risk factors.
The suite of internal metrics used for risk management purposes
at NWM Group level have been designed to capture correlation
effects and to allow for an aggregated view of traded market risk
across risk types, markets and business lines while also taking
into account the characteristics of each risk type.
Value-at-risk
For internal risk management purposes, VaR assumes a time
horizon of one trading day and a confidence level of 99%.
The internal VaR model – which captures all trading book
positions including those products approved by the regulator – is
based on a historical simulation, utilising market data from the
previous 500 days. During 2023, an update was made to the VaR
model to make it more sensitive to recent market conditions,
following approval from the PRA.
The model also captures the potential impact of interest rate risk,
credit spread risk, foreign currency price risk, equity price risk
and commodity price risk.
When simulating potential movements in such risk factors, a
combination of absolute, relative and rescaled returns is used.
The performance and adequacy of the VaR model are tested
regularly through the following processes:
Back-testing: Internal and regulatory back-testing is
conducted on a daily basis. For further information on back-
testing, refer to the following page.
Ongoing model validation: VaR model performance is
assessed both regularly and, on an ad-hoc basis if market
conditions or portfolio profile change significantly.
Model Risk Management review: As part of the model
lifecycle, all risk models (including the VaR model) are
independently reviewed to ensure the model is still fit for
purpose given current market conditions and portfolio
profile. For further detail on the independent model
validation carried out by Model Risk Management, refer to
page 73. More information relating to pricing and market
risk models is presented in the NatWest Group Pillar 3
Report.
One-day 99% traded internal VaR
The table below shows one-day 99% internal VaR for the trading portfolios of NWM Group, split by exposure type.
2023
2022
Average
Maximum
Minimum
Period end
Average
Maximum
Minimum
Period end
Traded internal VaR (1-day 99%)
£m
£m
£m
£m
£m
£m
£m
£m
Interest rate
9.8
19.3
4.3
7.4
7.3
12.6
4.1
9.0
Credit spread
6.2
7.1
4.9
6.8
7.8
12.0
6.0
6.4
Currency
2.3
7.0
0.9
1.8
3.1
8.0
1.2
1.5
Equity
-
0.1
-
0.1
-
0.3
-
-
Diversification
(1)
(7.0)
(7.2)
(7.5)
(6.8)
Total
11.3
20.0
6.6
8.9
10.7
15.1
7.2
10.1
(1)
NWM Group benefits from diversification across various financial instrument types, currencies and markets. The extent of the diversification benefit depends on the correlation between
the assets and risk factors in the portfolio at a particular time. The diversification factor is the sum of the VaR on individual risk types less the total portfolio VaR.
On an average basis, traded VaR remained at similar levels
in 2023 compared to 2022.
The increase in average interest rate VaR, compared to
2022, reflected an increase in curve risk in sterling and euro
flow trading.
The decrease in average credit spread VaR mostly reflected
a tightening of credit spreads on the net longer credit profile
over the period.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
35
Traded market risk continued
VaR back-testing
The main approach employed to assess the VaR model’s ongoing performance is back-testing, which counts the number of days when
a loss exceeds the corresponding daily VaR estimate, measured at a 99% confidence level.
Two types of profit and loss (P&L) are used in back-testing comparisons: Actual P&L and Hypothetical P&L. For more details on the
back-testing approach and the differences between internal and regulatory VaR, refer to the Market risk section of the NatWest Group
Pillar 3 Report.
The table below shows regulatory back-testing exceptions in NWM Plc for the 250-business-day period to 31 December 2023 for one-
day 99% traded regulatory VaR compared with Actual and Hypothetical (Hypo) P&L.
Back-testing exceptions
Actual
Hypo
NWM Plc
-
-
In the 250-day rolling window to 31 December 2023, there were no NWM Plc Actual or Hypothetical VaR P&L back-testing
exceptions.
The table below shows internal back-testing exceptions in the major NWM businesses for the 250-business-day period to 31 December
2023. Internal back-testing compares one-day 99% traded internal VaR with Actual and Hypo P&L.
Back-testing exceptions
Actual
Hypo
Rates
-
-
Currencies
-
-
Credit
1
1
xVA
-
-
The back-testing exception was driven by losses in Financials in March 2023 due to increased credit market volatility following the
collapse of Silicon Valley Bank.
Stressed VaR (SVaR)
As with VaR, the SVaR methodology produces estimates of the potential change in the market value of a portfolio, over a specified
time horizon, at a given confidence level. SVaR is a VaR-based measure using historical data from a one-year period of stressed
market conditions. A simulation of 99% VaR is run on the current portfolio for each 250-day period from 2005 to the current VaR date,
moving forward one day at a time. The SVaR is the worst VaR outcome of the simulated results.
This is in contrast with VaR, which is based on a rolling 500-day historical data set. A time horizon of ten trading days is assumed with
a confidence level of 99%. NWM Group’s internal traded SVaR model captures all trading book positions.
The table below analyses 10-day 99% internal SVaR for the trading portfolios of NWM Group.
2023
2022
Average
Maximum
Minimum
Period end
Average
Maximum
Minimum
Period end
£m
£m
£m
£m
£m
£m
£m
£m
Total internal traded SVaR
56
140
28
36
70
206
34
40
Traded SVaR was, on an average basis, lower in 2023 than in 2022, following the reduction in tenor basis risk in sterling flow
trading resulting from the VaR model update in Q3 2022.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
36
Traded market risk continued
Risks Not In VaR (RNIVs)
The RNIV framework is used to identify and quantify market risks
that are not fully captured by the internal VaR and SVaR models.
RNIV calculations form an integral part of ongoing model and
data improvement efforts to capture all market risks in scope for
model approval in VaR and SVaR.
For further qualitative and quantitative disclosures on RNIVs,
refer to the Market risk section of the NatWest Group Pillar 3
Report.
Stress testing
For information on stress testing, refer to page 29.
Incremental risk charge (IRC)
The IRC model quantifies the impact of rating migration and
default events on the market value of instruments with
embedded credit risk (in particular, bonds and credit default
swaps) held in the trading book. It further captures basis risk
between different instruments, maturities and reference entities.
For further qualitative and quantitative disclosures on the IRC,
refer to the Market risk section of the NatWest Group Pillar 3
Report.
Non-traded market risk
Definition
(audited)
Non-traded market risk is the risk to the value of assets or
liabilities outside the trading book, or the risk to income, that
arises from changes in market prices such as interest rates,
foreign exchange rates and equity prices, or from changes in
managed rates.
Sources of risk
(audited)
The key sources of non-traded market risk are interest rate risk,
credit spread risk, foreign exchange risk and equity risk.
For detailed qualitative and quantitative information on each of
these risk types, refer to the separate sub-sections starting on
the following page.
Key developments in 2023
NWM Plc’s non-traded market risk internal VaR increased
on an average and period-end basis compared to 2022,
reflecting time series impacts and the growth in the banking
book. The increase was driven by the rising trend in credit
spread VaR – reflecting increased holdings of bonds in the
liquidity portfolio – and in interest rate VaR. However,
interest rate VaR experienced a downward trend in the
second half of the year.
NWM Plc maintains a structural hedge of its common equity
and reserves. At 31 December 2023 the notional amount of
the structural hedge in place was £3.4 billion (£3.3 billion at
31 December 2022). NWM N.V. also maintains a structural
hedge of its common equity and reserves; at 31 December
2023, the notional amount of this hedge, in sterling
equivalent terms, was £1.4 billion (£1.6 billion at 31
December 2022).
Governance
(audited)
Responsibility for identifying, measuring, monitoring and
controlling market risk arising from non-trading activities lies with
the relevant business. Oversight is provided by NWM Group’s
Non-Traded Market Risk function.
Risk positions are reported regularly to NWM Group’s Executive
Risk Committee and the Board Risk Committee, as well as to the
Assets & Liabilities Committee (ALCo). Non-traded market risk
policy statements set out the governance and risk management
framework.
Non-traded market risk is managed separately on both sides of
the ring-fence. It is aggregated and monitored against risk
appetite at both NWM Plc and NatWest Group levels.
Risk appetite
NWM Group’s qualitative appetite is set out in the non-traded
market risk appetite statement.
Its quantitative appetite is expressed in terms of exposure limits.
At the NWM Plc level, the Board limit comprises a VaR measure.
This is supplemented with SVaR, sensitivities (including to the
CET1 ratio), earnings-at-risk and economic-value-of-equity
measures monitored at Executive governance level.
To ensure limits are not breached and that NWM Plc remains
within its risk appetite, triggers have been set such that if
exposures exceed a specified level, action plans are developed by
the business, Non-Traded Market Risk and Finance for
implementation. Limits are reviewed regularly to reflect changes
in risk appetite, business plans, portfolio composition and the
external environment. For further information on risk appetite,
refer to page 28.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
37
Non-traded market risk continued
Non-traded internal VaR (one-day 99%)
The market risk exposures arising as a result of banking activities are measured using a combination of value-based metrics (VaR and
sensitivities) and earnings-based metrics. The following table shows NWM Plc’s one-day internal banking book VaR at a 99%
confidence level, split by risk type. VaR values for each year are calculated based on one-day values for each of the 12 month-end
reporting dates. For NWM N.V., refer to the appropriate key point below the table.
2023
2022
Average
Maximum
Minimum
Period end
Average
Maximum
Minimum
Period end
NWM Plc
£m
£m
£m
£m
£m
£m
£m
£m
Interest rate
5.2
7.4
3.0
5.6
4.1
7.0
2.3
5.8
Credit spread
5.6
7.3
3.8
7.3
3.5
4.7
3.0
3.9
Foreign exchange rate
3.5
4.8
2.8
4.8
3.6
4.8
2.8
4.7
Equity risk
1.2
1.2
1.1
1.1
1.4
2.6
1.1
1.1
Diversification
(1)
(6.0)
(5.7)
(5.1)
(5.6)
Total
9.5
13.1
7.1
13.1
7.5
9.9
5.7
9.9
(1)
NWM Plc benefits from diversification across various financial instrument types, currencies and markets. The extent of the diversification benefit depends on the correlation between the
assets and risk factors in the portfolio at a particular time. The diversification factor is the sum of the VaR on individual risk types less the total portfolio VaR.
In NWM Plc, non-traded market risk internal VaR increased
on both an average and period-end basis compared to
2022, reflecting time series impacts and the growth in the
banking book.
The increase was driven by the rising trend in credit spread
VaR – reflecting increased holdings of bonds in the liquidity
portfolio – and in interest rate VaR. However, interest rate
VaR experienced a downward trend in the second half of
the year.
Foreign exchange rate and equity risks decreased slightly.
In NWM N.V., in sterling equivalent terms, non-traded
market risk VaR was £0.7 million on an average basis (2022
- £0.6 million) and £0.6 million on a period-end basis (2022 -
£0.4 million).
Interest rate risk
Non-traded interest rate risk (NTIRR) mainly arises from capital
hedges, in portfolios held for liquidity purposes and from interest
rate repricing mismatches between assets and liabilities in other
portfolios. When aggregated, these products form portfolios of
assets and liabilities with varying degrees of sensitivity to changes
in market interest rates. Mismatches can give rise to volatility in
net interest income as interest rates vary.
NTIRR comprises the following three primary risk types:
Gap risk: arises from the timing of rate changes in non-
trading book instruments. The extent of gap risk depends on
whether changes to the term structure of interest rates
occur consistently across the yield curve (parallel risk) or
differentially by period (non-parallel risk).
Basis risk: captures the impact of relative changes in interest
rates for financial instruments that have similar tenors but
are priced using different interest rate indices, or on the
same interest rate indices but with different tenors.
Option risk: arises from option derivative positions or from
optional elements embedded in assets, liabilities and/or off-
balance sheet items, where NWM Group or its customer can
alter the level and timing of their cash flows.
To manage exposures within appetite, NWM Group aggregates its
interest rate positions and hedges these externally using cash and
derivatives (primarily interest rate swaps).
Credit spread risk
Credit spread risk arises from the potential adverse economic
impact of a change in the spread between bond (or other credit-
sensitive instrument) yields and swap rates, where the portfolios
are accounted at fair value through other comprehensive income.
Credit risk also arises on loan portfolios classified at fair value.
To ensure NWM Group can continue to meet its obligations in the
event that access to wholesale funding markets is restricted, it
maintains a liquidity buffer in the form of bond portfolios –
comprising primarily high-quality securities – and central bank
cash.
Credit spread risk is monitored daily through sensitivities and VaR
measures. Exposures and limit utilisations are reported to senior
management on a regular basis. The dealing mandates in place
for the bond portfolios further mitigate the risk by imposing
constraints by duration, asset class and credit rating.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
38
Non-traded market risk continued
Foreign exchange risk
Non-traded foreign exchange risk arises from two main sources:
Structural foreign exchange rate risk – mainly arises from
the capital deployed in foreign subsidiaries and branches.
Transactional foreign exchange rate risk – arises from
customer transactions and profits and losses that are in a
currency other than the functional currency.
Structural foreign exchange rate risk is assessed and managed
by NWM Plc Treasury, with the aim of reducing NWM Plc’s solo
CET1 ratio sensitivity to unexpected movements in spot foreign
exchange rates.
The position is managed within risk appetite levels under
delegated authority from NWM Plc ALCo. The sensitivity of the
CET1 ratio to exchange rates is reported to NWM Plc senior
management monthly.
Gains or losses arising from the retranslation of net investments
in overseas operations are recognised in equity reserves and
reduce the sensitivity of capital ratios to foreign exchange rate
movements primarily arising from the retranslation of non-
sterling denominated RWAs.
Foreign exchange exposures arising from customer transactions
are hedged by businesses on a regular basis in line with NatWest
Group policy.
Foreign exchange exposures
The table below shows NWM Group’s structural foreign currency exposures.
Structural
Residual
Net investments
Net
foreign
structural
in foreign
investment
currency
Economic
foreign currency
operations
hedges
exposures
hedges
exposures
2023
£m
£m
£m
£m
£m
US dollar
(1)
1,181
(228)
953
(902)
51
Euro
2,420
(420)
2,000
-
2,000
Swiss franc
192
(192)
-
-
-
Other non-sterling
355
(74)
281
-
281
4,148
(914)
3,234
(902)
2,332
2022
US dollar
(1)
1,239
(303)
936
(936)
-
Euro
2,702
(420)
2,282
-
2,282
Swiss franc
184
(184)
-
-
-
Other non-sterling
390
(78)
312
-
312
4,515
(985)
3,530
(936)
2,594
(1)
Economic hedges of US dollar net investments in foreign operations represent US dollar equity securities that do not qualify as net investment hedges for accounting purposes.
Sterling strengthened against the US dollar, to 1.27 at 31
December 2023 compared to 1.21 at 31 December 2022. It
also strengthened against the euro, to 1.15 at 31 December
2023 compared to 1.13 at 31 December 2022.
Changes in foreign currency exchange rates affect equity in
proportion to structural foreign currency exposure. For
example, a 5% strengthening or weakening in foreign
currencies against sterling would result in a gain or loss of
£0.2 billion in equity, respectively.
Risk and capital management continued
Capital, liquidity and funding risk
NWM Group continually ensures a comprehensive approach is
taken to the management of capital, liquidity and funding,
underpinned by frameworks, risk appetite and policies, to
manage and mitigate capital, liquidity & funding risks. The
framework ensures the tools and capability are in place to
facilitate the management and mitigation of risk ensuring the
Group operates within its regulatory requirements and risk
appetite.
(audited)
Definitions
Regulatory capital consists of reserves and instruments issued
that are available, have a degree of permanency and are
capable of absorbing losses. A number of strict conditions are set
by applicable regulations to determine capital eligibility.
Capital risk is the inability to conduct business in base or stress
conditions on a risk or leverage basis due to insufficient qualifying
capital as well as the failure to assess, monitor, plan and manage
capital adequacy requirements.
Liquidity consists of assets that can be readily converted to cash
within a short timeframe at a reliable value. Liquidity risk is the
risk of being unable to meet actual or potential financial
obligations in a timely manner when they fall due in the short
term.
Funding consists of on-balance sheet liabilities that are used to
provide cash to finance assets. Funding risk is the risk that
current or prospective financial obligations cannot be met as they
fall due in the medium to long term, either at all or without
increasing funding costs unacceptably.
Liquidity and funding risks arise in a number of ways, including
through the maturity transformation role that banks perform.
The risks are dependent on factors such as:
Maturity profile;
Composition of sources and uses of funding;
The quality and size of the liquidity portfolio;
Wholesale market conditions; and
Depositor and investor behaviour.
(audited)
Sources
Capital
The eligibility of instruments and financial resources as regulatory
capital is laid down by applicable regulation. Capital is
categorised by applicable regulation under two tiers (Tier 1 and
Tier 2) according to the ability to absorb losses on either a going
or gone concern basis, degree of permanency and the ranking of
loss absorption. There are three broad categories of capital
across these two tiers:
CET1 capital - CET1 capital must be perpetual and capable
of unrestricted and immediate use to cover risks or losses as
soon as these occur. This includes ordinary shares issued and
retained earnings.
Additional Tier 1 (AT1) capital - This is the second type of loss
absorbing capital and must be capable of absorbing losses on
a going concern basis. These instruments are perpetual in
nature, with an initial call period of at least five years from
issue and are written off or converted into CET1 capital if a
pre-specified CET1 ratio is reached. The sum of CET1 and
AT1 capital is referred to as Tier 1 capital.
Tier 2 capital - Tier 2 capital is the bank entities’
supplementary capital and provides loss absorption on a gone
concern basis. Gone concern refers to the situation in which
resources must be available to enable an orderly resolution,
in the event that the Bank of England (BoE) deems that NWM
Plc has failed. Tier 2 capital absorbs losses after Tier 1
capital. It typically consists of subordinated debt securities
with a minimum initial maturity of five years.
Minimum requirement for own funds and eligible liabilities
(MREL)
In addition to capital, other specific loss absorbing instruments,
including senior notes with a residual maturity of at least one
year issued by NWM Plc, may be used to cover certain gone
concern capital requirements.
Liquidity
NWM Group maintains a prudent approach to the definition of
liquidity portfolio to ensure it is available when and where
required, taking into account regulatory, legal and other
constrains.
Liquidity portfolio is divided into primary and secondary liquidity
as follows:
Primary liquidity is LCR eligible assets and includes cash and
balances at central banks, Treasury bills and high-quality
government securities.
Secondary liquidity is assets eligible as collateral for local
central bank liquidity facilities. These assets include own-
issued securitisations or whole loans that are retained on
balance sheet and pre-positioned with a central bank so that
they may be converted into additional sources of liquidity at
very short notice.
Funding
NWM Group’s primary funding sources are as follows:
Type
Description
Wholesale
Includes:
markets
Short-term (less than 1 year)
unsecured money market
funding.
Commercial paper and
certificates of deposit.
Secured repo market funding.
Term debt
Includes:
Long-term (typically more than
1 year) senior unsecured and
secured debt securities.
Long-term subordinated
liabilities.
Internal capital
Includes:
and MREL
Equity, AT1, Tier 2 capital
instruments and MREL issued
to NatWest Group plc (under
the Single Point of Entry
regime).
Managing capital, liquidity and funding requirements:
regulated entities
In line with paragraph 135 of IAS 1 ‘Presentation of Financial
Statements’, NWM Group manages capital having regard to
regulatory requirements. Regulatory capital, MREL, RWA and
leverage is monitored and reported on an individual regulated
bank legal entity basis (‘bank entity’), which is the CRR
transitional basis as relevant in the UK and EU.
Liquidity metrics including the LCR are presented for the solo
legal entity as regulated by the PRA. Disclosures for funding
sources and notes issued are presented for NWM Group rather
than for NatWest Markets Plc.
NWM Group
Annual Report and Accounts 2023
39
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
40
Capital, liquidity and funding risk continued
Key developments in 2023
NWM Plc’s RWAs increased by £0.7 billion to £22.1 billion at
31 December 2023, reflecting increased credit and
counterparty credit risk, partially offset by decreases in
market risk and operational risk.
NWM Plc’s CET1 ratio decreased by 10 basis points to 17.1%
at 31 December 2023, from 17.2% at 31 December 2022,
largely driven by the increase in RWAs and other movements
in reserves and regulatory adjustments.
The leverage ratio decreased by 40 basis points to 5.0%. The
decrease was due to a £8.8 billion increase in leverage
exposure partially offset by a £0.1 billion increase in Tier 1
capital. The key drivers in the leverage exposure were an
increase in off balance sheet items and other financial assets.
NWM Plc’s MREL at 31 December 2023 was £7.6 billion, or
34.5% of RWAs, compared to £8.7 billion or 40.4% of RWAs at
31 December 2022. The decrease in the year was largely
due to the redemption of a $0.6 billion internal Tier 2
instrument, decrease in senior unsecured debt driven by a
€0.6 billion instrument now classified as ineligible and other
movements in reserves and regulatory adjustments.
The NWM Plc liquidity portfolio was £14.7 billion at 31
December 2023, a decrease of £4.4 billion compared with
£19.1 billion at the prior year end.
The LCR for NWM Plc was 183% at 31 December 2023,
compared with 253% at 31 December 2022.
Capital management
Capital management is the process by which banks ensure that
they have sufficient capital and other loss absorbing instruments
to operate effectively. This includes meeting minimum regulatory
requirements, operating within Board-approved risk appetite,
maintaining credit ratings and supporting strategic goals. Capital
management is critical in supporting banks businesses. Capital
management within NWM Group is executed in accordance with
the NatWest Group-wide framework.
NWM Plc’s capital plans are produced and updated by the bank
on a monthly basis. This process includes integration into
NatWest Group’s wider annual budgeting process and is
summarised below. Other elements of capital management,
including risk appetite and stress testing, are set out on pages 28
and 29.
Produce
A capital plan is produced for NWM Plc
capital
using a five-year planning horizon under
plans
expected and stress conditions. Stressed
capital plans are produced to support
internal stress testing through the ICAAP
or for regulatory purposes.
A shorter term (rolling 12 month)
forecast is updated frequently in
response to actual performance, changes
in internal and external business
environment and to manage risks and
opportunities.
Assess
Capital plans are developed to ensure
capital
that capital of sufficient quantity and
adequacy
quality is planned to be available to
support NWM Group’s business and
strategic plans over the planning horizon
within approved risk appetite, as
determined via stress testing, and
minimum regulatory requirements.
Impact assessment captures input from
across NWM Group including from
businesses.
Inform
Capital planning informs potential capital
capital
actions including managing capital
actions
through new issuance, redemptions or
internal transactions.
Decisions on capital actions will be
influenced by strategic and regulatory
requirements, the cost and prevailing
market conditions.
As part of capital planning, NWM Group
will monitor its portfolio of capital
securities and assess the optimal blend.
Capital planning is one of the tools that NWM Group uses to
monitor and manage capital adequacy risk on a going and gone
concern basis, including the risk of excessive leverage.
Liquidity and funding management
Liquidity and funding management follows a similar process to
that outlined above for capital.
Liquidity portfolio management
The size of the portfolio is determined by reference to NWM
Group’s liquidity risk appetite. Consistent with NatWest Group,
NWM Group retains a prudent approach to setting the
composition of the liquidity portfolio, which is subject to internal
policies and limits covering quality of counterparty, maturity mix
and currency mix. NWM Group categorises its liquidity portfolio,
including its locally managed liquidity portfolios, into primary and
secondary liquid assets. The majority of the NWM Plc portfolio is
managed by NatWest Holdings Treasury on behalf of NWM Plc,
for which the NatWest Markets Treasurer is responsible.
NatWest Markets Securities Inc. and NatWest Markets N.V., both
of which are significant operating subsidiaries of NWM Plc, hold
locally managed liquidity portfolios to comply with local
regulations that differ from PRA rules.
The liquidity value of the portfolio is determined by taking current
market prices and applying a discount or haircut, to determine a
liquidity value that represents the amount of cash that can be
generated by the asset.
Funding risk management
NWM Group manages funding risk through a comprehensive
framework which measures and monitors the funding risk on the
balance sheet.
The long-term obligations of NWM Group must be met with
diverse and stable funding sources, the behavioural maturity of
these liabilities must at a minimum equal those of the assets.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
41
Capital, liquidity and funding risk continued
Minimum requirements
Capital ratios
The bank entities are subject to minimum capital requirements relative to RWAs. The table below summarises the minimum ratios of
capital to RWAs that the UK bank entities are expected to have to meet.
Type
CET1
Total Tier 1
Total capital
Minimum capital requirements
4.5%
6.0%
8.0%
Capital conservation buffer
(1)
2.5%
2.5%
2.5%
Countercyclical capital buffer
(1)
1.0%
1.0%
1.0%
Total
(2)
8.0%
9.5%
11.5%
(1)
The institution specific countercyclical capital buffer requirement is based on the weighted average of geographical exposures. The Financial Policy Committee increased the UK CCyB
rate from 1% to 2% effective from 5 July 2023. The Central Bank of Ireland increased CCyB on Irish exposures from 0% to 0.5% applicable 15 June 2023 and 1% from 24 November
2023. A further increase to 1.5% will be effective 7 June 2024. The capital conservation buffer and the countercyclical capital buffer are required to be met with CET1 capital only.
(2)
In addition, NWM Plc is subject to Pillar 2A requirements for CET1, AT1 and T2.
Refer to the NWM Plc Pillar 3 report for further details on these additional capital requirements.
Leverage ratio
The table below summarises the minimum ratios of capital to leverage exposure under the binding PRA UK leverage framework
applicable for NWM Plc.
Type
CET1
Total tier 1
Minimum ratio
2.44%
3.25%
Countercyclical leverage ratio buffer
(1)
0.4%
0.4%
Total
2.84%
3.65%
(1)
The countercyclical leverage ratio buffer is set at 35% of NWM Plc’s CCyB. The UK CCyB increased from 1% to 2% from 5 July 2023. Foreign exposure may be subject to different CCyB
rates depending on the rates set in those jurisdictions.
Liquidity ratio
NWM Plc has a minimum Liquidity Coverage Ratio (LCR) requirement under the PRA framework of 100%.
Measurement
Capital, RWAs and leverage
Capital resources, RWAs and leverage based on the PRA transitional arrangements for NWM Plc are set out below. Regulatory capital
is monitored and reported at legal entity level for large subsidiaries of NatWest Group.
2023
2022
Capital adequacy ratios
%
%
CET1
17.1
17.2
Tier 1
20.2
20.4
Total
23.0
25.7
Total MREL
34.5
40.4
Capital
£m
£m
CET1
3,776
3,682
Tier 1
4,455
4,361
Total
5,072
5,502
Total MREL
(1)
7,627
8,652
RWAs
Credit risk
7,895
7,110
Counterparty credit risk
6,516
5,682
Market risk
6,366
7,152
Operational risk
1,322
1,478
Total RWAs
22,099
21,422
(1)
Includes senior debt instruments issued to NatWest Group plc with a regulatory value of £2.6 billion (2022 - £3.2 billion).
Leverage
2023
2022
Tier 1 capital (£m)
4,455
4,361
Leverage exposure (£m)
(1)
89,929
81,083
Leverage ratio (%)
5.0
5.4
(1)
Leverage exposure is broadly aligned to the accounting value of on and off-balance sheet exposures, subject to specific adjustments for derivatives, securities financing positions and off-
balance sheet exposures.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
42
Capital, liquidity and funding risk continued
Leverage exposure
The leverage metrics for UK entities are calculated in accordance with the Leverage ratio (CRR) part of the PRA Rulebook.
2023
2022
Leverage
£m
£m
Cash and balances at central banks
8,607
13,467
Trading assets
28,411
27,301
Derivatives
75,832
96,258
Financial assets
32,930
27,011
Other assets
4,878
5,024
Total assets
150,658
169,061
Derivatives
- netting
(73,927)
(95,223)
- potential future exposures
15,691
16,540
Securities financing transactions gross up
1,301
2,862
Undrawn commitments
8,493
5,239
Regulatory deductions and other adjustments
(3,373)
(3,077)
Exclusion of core UK-group exposures
(310)
(852)
Claims on central banks
(8,604)
(13,467)
Leverage exposure
89,929
81,083
Liquidity portfolio
The table below shows the composition of the liquidity portfolio with primary liquidity aligned to high-quality liquid assets on a
regulatory LCR basis. Secondary liquidity comprises of assets which are eligible as collateral for local central bank liquidity facilities and
do not form part of the LCR eligible high-quality liquid assets.
2023
2022
(5)
£m
£m
Cash and balances at central banks
8,547
13,414
High quality government/MDB/PSE and GSE bonds
(1)
6,054
5,538
Extremely high quality covered bonds
1
1
LCR Level 1 eligible assets
14,602
18,953
LCR Level 2 eligible assets
(2)
104
90
Primary liquidity (HQLA)
(3)
14,706
19,043
Secondary liquidity
(4)
39
68
Total liquidity value
14,745
19,111
(1)
Multilateral development bank abbreviated to MDB, public sector entities abbreviated to PSE and government sponsored entities abbreviated to GSE.
(2)
Includes Level 2A and Level 2B.
(3)
High-quality liquid assets abbreviated to HQLA.
(4)
Comprises assets eligible for discounting at the Bank of England and other central banks which do not form part of the LCR high-quality liquid assets.
(5)
Comparative periods have been re-presented on an LCR basis in line with the Liquidity portfolio definition as of 31 December 2023.
The table below shows the liquidity value of the liquidity portfolio by currency.
GBP
USD
EUR
Other
Total
Total liquidity portfolio
£m
£m
£m
£m
£m
2023
5,153
3,350
6,150
92
14,745
2022
(5)
8,964
3,442
6,611
94
19,111
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
43
Capital, liquidity and funding risk continued
Funding sources
(audited)
The table below shows NWM Group’s carrying values of the principal funding sources based on contractual maturity.
2023
2022
Short-term
Long-term
Short-term
Long-term
less than
more than
less then
more than
1 year
1 year
Total
1 year
1 year
Total
£m
£m
£m
£m
£m
£m
Bank deposits
1,622
645
2,267
2,427
642
3,069
of which: repos (amortised cost)
452
-
452
799
-
799
Customer deposits
6,990
8
6,998
3,353
261
3,614
of which: repos (amortised cost)
418
-
418
-
254
254
Trading liabilities
(1)
Repos
(2)
26,634
268
26,902
23,740
-
23,740
Derivative cash collateral received
15,062
-
15,062
17,663
-
17,663
Other bank and customer deposits
768
382
1,150
414
654
1,068
Debt securities in issue
418
288
706
54
743
797
42,882
938
43,820
41,871
1,397
43,268
Other financial liabilities
Customer deposits (designated at fair value)
193
1,066
1,259
253
797
1,050
Debt securities in issue
Commercial paper and certificates of deposits
4,228
205
4,433
3,084
85
3,169
Medium term notes (MTNs)
3,759
13,849
17,608
2,368
14,050
16,418
Subordinated liabilities
-
274
274
206
260
466
8,180
15,394
23,574
5,911
15,192
21,103
Amounts due to holding company and
fellow subsidiaries
(3)
Internal MREL
434
2,636
3,070
2,199
974
3,173
Other bank and customer deposits
1,620
-
1,620
1,288
-
1,288
Subordinated liabilities
839
183
1,022
-
1,519
1,519
2,893
2,819
5,712
3,487
2,493
5,980
Total funding
62,567
19,804
82,371
57,049
19,985
77,034
Of which: available in resolution
(4)
3,093
2,753
(1)
Funding sources excludes short positions of £9,803 million (2022 - £9,524 million) reflected as trading liabilities on the balance sheet.
(2)
Comprises Central and other bank repos of £3,957 million (2022 - £1,642 million), other financial institution repos of £20,394 million (2022 - £19,354 million) and other corporate repos of
£2,551 million (2022 - £2,744 million).
(3)
Amounts due to holding company and fellow subsidiaries relating to non-financial instruments of £90 million (2022 - £211 million) and Nil intercompany settlement balances (2022 – £26
million) have been excluded from the table.
(4)
Eligible liabilities (as defined in the Banking Act 2009 as amended from time to time) that meet the eligibility criteria set out in the regulations, rules, policies, guidelines, or statements of
the Bank of England including the Statement of Policy published in December 2021 (updating June 2018).
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
44
Capital, liquidity and funding risk continued
Senior notes and subordinated liabilities - residual maturity profile by instrument type
(audited)
The table below shows NWM Group’s debt securities in issue, subordinated liabilities and internal resolution instruments by residual
maturity.
Trading
liabilities
Other financial liabilities
Debt securities
Amounts due to holding company and fellow
in issue
Debt securities in issue
subsidiaries
Commercial
Subordinated
Subordinated
Total notes
MTNs
paper and CDs
MTNs
liabilities
Total
Internal MREL
liabilities
in issue
2023
£m
£m
£m
£m
£m
£m
£m
£m
Less than 1 year
418
4,228
3,759
-
7,987
434
839
9,678
1-3 years
48
205
9,342
18
9,565
1,722
-
11,335
3-5 years
-
-
3,851
-
3,851
914
-
4,765
More than 5 years
240
-
656
256
912
-
183
1,335
Total
706
4,433
17,608
274
22,315
3,070
1,022
27,113
2022
Less than 1 year
54
3,084
2,368
206
5,658
2,199
-
7,911
1-3 years
474
73
9,011
-
9,084
974
830
11,362
3-5 years
37
12
4,403
18
4,433
-
-
4,470
More than 5 years
232
-
636
242
878
-
689
1,799
Total
797
3,169
16,418
466
20,053
3,173
1,519
25,542
The table below shows the currency breakdown of total notes in issue.
GBP
USD
EUR
Other
Total
2023
£m
£m
£m
£m
£m
Commercial paper and CDs
1,195
1,347
1,891
-
4,433
MTNs
1,734
4,450
9,135
2,995
18,314
External subordinated liabilities
19
17
238
-
274
Internal MREL due to NatWest Group plc
-
2,156
914
-
3,070
Subordinated liabilities due to NatWest Group plc
-
183
839
-
1,022
Total
2,948
8,153
13,017
2,995
27,113
2022 total
1,816
9,892
11,160
2,674
25,542
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
45
Credit risk
Definition
(audited)
Credit risk is the risk that customers, counterparties or issuers fail
to meet a contractual obligation to settle outstanding amounts.
Sources of risk
(audited)
The principal sources of credit risk for NWM Group are lending,
off-balance sheet products, derivatives and securities financing,
debt securities, and settlement risk through trading activities.
Key developments in 2023
(audited)
The credit profile remained stable, but the outlook is uncertain
from inflationary pressure, compounded by higher interest
rates and geopolitical tension. NWM Group has yet to see
signs of financial stress materially affect customers’ ability to
repay.
Expected credit loss (ECL) was stable in 2023, with a small
overall increase driven by business growth.
Current and potential credit exposure increased in the context
of planned business growth. The effect of inflation and higher
interest rates on customers continues to be assessed. Sector
appetite is reviewed regularly and where appropriate adjusted
for those sectors most effected by current economic and
geopolitical conditions.
NWM Group continued to progress embedding climate change
considerations in credit assessment and monitoring, including
scenario analysis to assess the materiality of climate change
risks.
Governance
(audited)
The Credit Risk function provides oversight and challenge of
frontline credit risk management activities. Authority is delegated
to credit risk officers who operate within designated limits set at a
customer level and a portfolio level.
Governance activities include:
Defining and proposing credit risk appetite measures for
Board approval.
Establishing credit risk policy, standards and toolkits which set
out the mandatory limits and parameters required to ensure
that credit risk is managed within risk appetite and which
provide the minimum standards for the identification,
assessment, management, monitoring and reporting of credit
risk.
Oversight of the first line of defence to ensure that credit risk
remains within the appetite set by the Board and that it is
being managed adequately and effectively.
Assessing the adequacy of ECL provisions including approving
key IFRS 9 inputs (such as significant increase in credit risk
(SICR) thresholds) and any necessary in-model and post
model adjustments through provisions and model committees.
Development and approval of credit grading models.
Providing regular reporting on credit risk to the Board.
The Credit Risk Committee provides oversight of the overall credit
risk profile and sector/product/asset class concentrations.
Risk appetite
Credit risk appetite is approved by the Board and is set and
monitored through a risk appetite framework.
The framework has been designed to reflect factors that influence
the ability to operate within risk appetite. Tools such as stress
testing and economic capital are used to measure credit risk
volatility and develop links between the framework and risk
appetite limits.
Risk appetite statements and associated measures are reviewed
at least annually by the Board on the Board Risk Committee’s
recommendation to ensure they remain appropriate and aligned
to strategy.
Operational limits are used to manage concentrations of risk
which may arise across four lenses – single name, sector, country
and product and asset classes.
The framework is supported by a suite of transactional
acceptance standards that set out the risk parameters within
which businesses should operate.
Identification and measurement
Credit stewardship
(audited)
Risks are identified through relationship management and credit
stewardship of customers and portfolios. Credit stewardship takes
place throughout the customer relationship, beginning with the
initial approval. It includes the application of credit assessment
standards, credit risk mitigation and collateral, ensuring that credit
documentation is complete and appropriate, carrying out regular
portfolio or customer reviews and problem debt identification and
management.
Asset quality
(audited)
All credit grades map to an asset quality (AQ) scale, used for
financial reporting. This AQ scale is based on Basel probability of
defaults. Performing loans are defined as AQ1-AQ9 (where the
probability of default (PD) is less than 100%) and defaulted non-
performing loans as AQ10 or Stage 3 under IFRS 9 (where the PD
is 100%). Loans are defined as defaulted when the payment
status becomes 90 days past due, or earlier if there is clear
evidence that the borrower is unlikely to repay, for example
bankruptcy or insolvency.
Counterparty credit risk
Counterparty credit risk arises from the obligations of customers
under derivative and securities financing transactions. It is a
material part of NWM Group’s credit risk.
NWM Group mitigates counterparty credit risk through
collateralisation and netting agreements, which allow amounts
owed by NWM Group to a counterparty to be netted against
amounts the counterparty owes NWM Group.
Mitigation
Mitigation techniques, as set out in the appropriate credit risk
toolkits and transactional acceptance standards, are used in the
management of credit portfolios across NWM Group. These
techniques mitigate credit concentrations in relation to an
individual customer, a borrower group or a collection of related
borrowers. Where possible, customer credit balances are netted
against obligations. Mitigation tools can include structuring a
security interest in a physical or financial asset, the use of credit
derivatives including credit default swaps, credit-linked debt
instruments and securitisation structures, and the use of
guarantees and similar instruments (for example, credit insurance)
from related and third parties.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
46
Credit risk continued
Assessment and monitoring
Customers, including corporates, banks and other financial
institutions are managed on an individual basis. Customers are
aggregated as a single risk when sufficiently interconnected to the
extent that a failure of one could lead to the failure of another.
A credit assessment is carried out before credit facilities are made
available to customers. The assessment process is dependent on
the complexity of the transaction. Credit approvals are subject to
environmental, social and governance risk policies which restrict
exposure to certain highly carbon intensive industries as well as
those with potentially heightened reputational impacts. Customer
specific climate risk commentary is now mandatory.
For lower risk transactions below specific thresholds, credit
decisions can be approved through a combination of fully
automated or relationship manager self-sanctioning within the
business. This process is facilitated through an auto-decision
making system, which utilises scorecards, strategies and policy
rules.
For all other transactions, credit is only granted to customers
following joint approval by an approver from the business and the
credit risk function, or by two credit officers. The joint business
and credit approvers act within a delegated approval authority
under the Wholesale Credit Authorities framework policy. The
level of delegated authority held by approvers is dependent on
their experience and expertise with only a small number of senior
executives holding the highest approval authority.
Transactional acceptance standards provide detailed transactional
lending and risk acceptance metrics and structuring guidance. As
such, these standards provide a mechanism to manage risk
appetite at the customer/transaction level and are supplementary
to the established credit risk appetite.
Credit grades (PD) and loss given default (LGD) are reviewed and
if appropriate reapproved annually. The review process assesses
borrower performance, including reconfirmation or adjustment of
risk parameter estimates; the adequacy of security; compliance
with terms and conditions; and refinancing risk.
Problem debt management
Early problem identification
Each sector has defined early warning indicators to identify
customers experiencing financial difficulty, and to increase
monitoring if needed. Early warning indicators may be internal,
such as a customer’s bank account activity, or external, such as a
publicly listed customer’s share price. If early warning indicators
show a customer is experiencing potential or actual difficulty, or if
relationship managers or credit officers identify other signs of
financial difficulty, they may decide to classify the customer within
the Risk of Credit Loss framework. Broader macro-economic
trends including commodity prices, foreign exchange rates and
consumer and government spend are also tracked, helping inform
decisions on sector risk appetite. Customer level early warning
indicators are regularly reviewed to ensure alignment with
prevailing economic conditions, ensuring both the volume and
focus of alerts is aligned to the point-in-time risk within each
sector.
The aligned Risk of Credit Loss and Viability framework
This framework focuses on all Wholesale customers to provide
early identification of credit deterioration, support intelligent risk-
taking, ensure fair and consistent customer outcomes and provide
key insights into Wholesale lending portfolios. Expert judgement is
applied by experienced credit risk officers to classify cases into
categories that reflect progressively deteriorating credit risk to
NWM Group. There are two classifications in the framework that
apply to non-defaulted customers who are in financial stress –
Heightened Monitoring and Risk of Credit Loss. For the purposes
of provisioning, all exposures categorised as Heightened
Monitoring or Risk of Credit Loss are categorised as Stage 2 and
subject to a lifetime loss assessment. The framework also applies
to those customers that have met NWM Group’s default criteria
(AQ10 exposures). Defaulted exposures are categorised as Stage
3 impaired for provisioning purposes.
Customers classified in the Heightened Monitoring category are
those who are still performing but have certain characteristics –
such as trading issues, covenant breaches, material PD
downgrades and past due facilities – that may affect the ability to
meet repayment obligations. Heightened Monitoring customers
require pre-emptive actions to return or maintain their facilities
within risk appetite.
Risk of Credit Loss customers are performing customers that
have met the criteria for Heightened Monitoring and also pose a
risk of credit loss to NWM Group in the next 12 months should
mitigating action not be taken or not be successful.
Once classified as either Heightened Monitoring or Risk of Credit
Loss, a number of mandatory actions are taken in accordance
with policies. Actions include a review of the customer’s credit
grade, facility and security documentation and the valuation of
security. Depending on the severity of the financial difficulty and
the size of the exposure, the customer relationship strategy is
reassessed by credit officers, by specialist credit risk or
relationship management units in the relevant business, or by
Restructuring.
Restructuring
Where customers are categorised as Risk of Credit Loss,
relationships are mainly managed by the Restructuring team in
NatWest Bank Plc as a service to NWM Group. The team protects
NWM Group’s capital by working with corporate and commercial
customers to support their turnaround and recovery strategies
and enable them to return to mainstream banking.
Forbearance
(audited)
Forbearance takes place when a concession is made on the
contractual terms of a loan/debt in response to a customer’s
financial difficulties. The aim of forbearance is to support and
restore the customer to financial health while minimising risk. The
type of forbearance offered is tailored to the customer’s individual
circumstances and may involve covenant waivers, amendments
to margins, payment concessions and loan rescheduling (including
extensions in contractual maturity), capitalisation of arrears, and
debt forgiveness or debt-for-equity swaps.
Provisioning for forbearance
Provisions for forborne loans are assessed in accordance with
normal provisioning policies. The customer’s financial position and
prospects – as well as the likely effect of the forbearance,
including any concessions granted, and revised PD or LGD
gradings – are considered in order to establish whether an
impairment provision increase is required.
Loans granted forbearance are individually credit assessed in
most cases. Performing loans subject to forbearance treatment
are categorised as Stage 2 and subject to a lifetime loss
assessment.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
47
Credit risk continued
Forbearance may result in the value of the outstanding debt
exceeding the present value of the estimated future cash flows.
This difference will lead to a customer being classified as non-
performing.
In the case of non-performing forborne loans, an individual loan
impairment provision assessment generally takes place prior to
forbearance being granted. The amount of the loan impairment
provision may change once the terms of the forbearance are
known, resulting in an additional provision charge or a release of
the provision in the period the forbearance is granted.
The transfer of loans from impaired to performing status follows
assessment by relationship managers and credit. When no further
losses are anticipated and the customer is expected to meet the
loan’s revised terms, any provision is written-off or released and
the balance of the loan can be returned to performing status once
exit criteria, as set out by regulatory guidance, is met.
Credit grading models
Credit grading models is the collective term used to describe all
models, frameworks and methodologies used to calculate PD,
exposure at default (EAD), LGD, maturity and the production of
credit grades.
Credit grading models are designed to provide:
An assessment of customer and transaction characteristics.
A meaningful differentiation of credit risk.
Accurate internal default rate, loss and exposure estimates
that are used in the capital calculation or wider risk
management purposes.
Impairment, provisioning and write-offs
(audited)
In the overall assessment of credit risk, impairment provisioning
and write-offs are used as key indicators of credit quality.
NWM Group’s IFRS 9 provisioning models, which use existing IRB
models as a starting point, incorporate term structures and
forward-looking information. Regulatory conservatism within the
IRB models has been removed as appropriate to comply with the
IFRS 9 requirement for unbiased ECL estimates.
Five key areas may materially influence the measurement of
credit impairment under IFRS 9 – two of these relate to model
build and three relate to model application:
Model build:
The determination of economic indicators that have most
influence on credit loss for each portfolio and the severity of
impact (this leverages existing stress testing models which are
reviewed annually).
The build of term structures to extend the determination of
the risk of loss beyond 12 months that will influence the
impact of lifetime loss for exposures in Stage 2.
Model application:
The assessment of the SICR and the formation of a
framework capable of consistent application.
The determination of asset lifetimes that reflect behavioural
characteristics while also representing management actions
and processes (using historical data and experience).
The choice of forward-looking economic scenarios and their
respective probability weights.
For accounting policy information refer to Accounting policy 2.3
for further details.
IFRS 9 ECL model design principles (audited)
Modelling of ECL for IFRS 9 follows the conventional approach to
divide the estimation of credit losses into its component parts of
PD, LGD and EAD.
To meet IFRS 9 requirements, the PD, LGD and EAD parameters
differ from their Pillar 1 internal ratings based (IRB) counterparts
in the following aspects:
Unbiased
– material regulatory conservatism has been
removed from IFRS 9 parameters to produce unbiased
estimates.
Point-in-time
– IFRS 9 parameters reflect actual economic
conditions at the reporting date instead of long-run average
or downturn conditions.
Economic forecasts
– IFRS 9 PD estimates and, where
appropriate, EAD and LGD estimates reflect forward-looking
economic conditions.
Lifetime measurement
– IFRS 9 PD, LGD and EAD are
provided as multi-period term structures up to exposure
lifetimes instead of over a fixed one-year horizon.
IFRS 9 requires that at each reporting date, an entity shall assess
whether the credit risk on an account has increased significantly
since initial recognition. Part of this assessment requires a
comparison to be made between the current lifetime PD (i.e. the
PD over the remaining lifetime at the reporting date) and the
equivalent lifetime PD as determined at the date of initial
recognition.
For assets originated before IFRS 9 was introduced, comparable
lifetime origination PDs did not exist. These have been
retrospectively created using the relevant model inputs applicable
at initial recognition.
PD estimates
PD models use a point-in-time/through-the-cycle framework to
convert one-year regulatory PDs into point-in-time estimates that
reflect economic conditions at the reporting date. The framework
utilises credit cycle indices (CCIs) for a comprehensive set of
region/industry segments. Further detail on CCIs is provided in the
Economic loss driver’s section.
One-year point-in-time PDs are extended to forward-looking
lifetime PDs using a conditional transition matrix approach and a
set of econometric forecasting models.
LGD estimates
The general approach for the IFRS 9 LGD models is to leverage
corresponding IRB LGD models with bespoke adjustments to
ensure estimates are unbiased and, where relevant, forward-
looking.
Forward-looking economic information is incorporated into LGD
estimates using the existing point-in-time/through-the-cycle
framework. For low-default portfolios, including sovereigns and
banks, loss data is too scarce to substantiate estimates that vary
with economic conditions. Consequently, for these portfolios, LGD
estimates are assumed to be constant throughout the projection
horizon.
EAD estimates
EAD values are projected using product specific credit conversion
factors (CCFs), closely following the product segmentation and
approach of the respective IRB model. However, the CCFs are
estimated over multi-year time horizons and contain no regulatory
conservatism or downturn assumptions.
No explicit forward-looking information is incorporated, on the
basis of analysis showing the temporal variation in CCFs is mainly
attributable to changes in exposure management practices rather
than economic conditions.
Risk and capital management continued
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Annual Report and Accounts 2023
48
Credit risk continued
Governance and post model adjustments (audited)
The IFRS 9 PD, EAD and LGD models are subject to NWM
Group’s model risk policy that stipulates periodic model
monitoring, periodic re-validation and defines approval procedures
and authorities according to model materiality. Various post model
adjustments were applied where management judged they were
necessary to ensure an adequate level of overall ECL provision.
All post model adjustments were subject to review, challenge and
approval through model or provisioning committees.
Post model adjustments will remain a key focus area of NWM
Group’s ongoing ECL adequacy assessment process. A holistic
framework has been established including reviewing a range of
economic data, external benchmark information and portfolio
performance trends with a particular focus on segments of the
portfolio that are likely to be more susceptible to high inflation,
rising interest rates and supply chain disruption.
ECL post model adjustments
(audited)
The table below shows ECL post model adjustments.
2023
2022
£m
£m
Deferred model calibrations
-
-
Economic uncertainty
13
1
Other adjustments
-
-
Total
13
1
Of which:
- Stage 1
10
-
- Stage 2
3
1
- Stage 3
-
-
Significant increase in credit risk (SICR)
(audited)
Exposures that are considered significantly credit deteriorated
since initial recognition are classified in Stage 2 and assessed for
lifetime ECL measurement (exposures not considered deteriorated
carry a 12-month ECL). NWM Group has adopted a framework to
identify deterioration based primarily on relative movements in
lifetime PD supported by additional qualitative backstops. The
principles applied are consistent across NWM Group and align to
credit risk management practices, where appropriate.
The framework comprises the following elements:
IFRS 9 lifetime PD assessment (the primary driver) –
on
modelled portfolios, the assessment is based on the relative
deterioration in forward-looking lifetime PD and is assessed
monthly. To assess whether credit deterioration has occurred,
the residual lifetime PD at balance sheet date (which PD is
established at date of initial recognition) is compared to the
current PD. If the current lifetime PD exceeds the residual
origination PD by more than a threshold amount, deterioration
is assumed to have occurred and the exposure transferred
into Stage 2 for a lifetime loss assessment. In broad terms, a
doubling of PD would indicate a SICR. However, the PD uplift
must be at least 0.1%.
Qualitative high-risk backstops
– the PD assessment is
complemented with the use of qualitative high-risk backstops
to further inform whether significant deterioration in lifetime
risk of default has occurred. The qualitative high-risk backstop
assessment includes the use of the mandatory 30+ days past
due backstop, as prescribed by IFRS 9 guidance, and other
features such as forbearance support and exposures
managed within the Risk of Credit Loss framework.
The criteria are based on a significant amount of empirical
analysis and seek to meet three key objectives:
Criteria effectiveness
– the criteria should be effective in
identifying significant credit deterioration and prospective
default population.
Stage 2 stability
– the criteria should not introduce
unnecessary volatility in the Stage 2 population.
Portfolio analysis
– the criteria should produce results which
are intuitive when reported as part of the wider credit
portfolio.
Monitoring the effect on relative PD deterioration when originating
new lending at times of weaker economic outlook (therefore,
higher PDs at initial recognition) is important to ensure SICR
criteria remains effective.
Asset lifetimes
(audited)
The choice of initial recognition and asset duration is another
critical judgement in determining the quantum of lifetime losses
that apply.
The date of initial recognition reflects the date that a transaction
(or account) was first recognised on the balance sheet; the PD
recorded at that time provides the baseline used for subsequent
determination of SICR as detailed above.
For asset duration, the approach applied in line with IFRS 9
requirements is:
Term lending – the contractual maturity date, reduced for
behavioural trends where appropriate (such as, expected
prepayment and amortisation).
Revolving facilities – asset duration is based on annual
customer review schedules and will be set to the next review
date.
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Annual Report and Accounts 2023
49
Credit risk continued
Economic loss drivers
(audited)
Introduction
The portfolio segmentation and selection of economic loss drivers
for IFRS 9 follows the approach used in stress testing. To enable
robust modelling the forecasting models for each portfolio
segment (defined by product or asset class and where relevant,
industry sector and region) are based on a selected, small number
of economic variables, (typically three to four) that best explain
the temporal variations in portfolio loss rates. The process to
select economic loss drivers involves empirical analysis and expert
judgement.
The most material economic loss drivers for the UK portfolios
include UK gross domestic product (GDP), world GDP, the
unemployment rate, the house price index, and the Bank of
England base rate. Similar metrics are used for other key country
exposures in NWM Group.
Economic scenarios
At 31 December 2023, the range of anticipated future economic
conditions was defined by a set of four internally developed
scenarios and their respective probabilities. In addition to the base
case, they comprised upside, downside and extreme downside
scenarios. The scenarios primarily reflected the current risks
faced by the economy, particularly in relation to the path of
inflation and interest rates.
For 2023, the four scenarios were deemed appropriate in
capturing the uncertainty in economic forecasts and the non-
linearity in outcomes under different scenarios. These four
scenarios were developed to provide sufficient coverage across
potential rises in unemployment, inflation, asset price declines and
the degree of permanent damage to the economy, around which
there remains pronounced levels of uncertainty.
Upside
– This scenario assumes robust growth as inflation falls
sharply and rates are lowered more quickly than expected.
Consumer spending is supported by savings built up since COVID-
19 and further helped by fiscal support and strong business
investment. The labour market remains resilient, with the
unemployment rate falling. The housing market slows down
compared to the previous year but remains robust.
Compared to 31 December 2022, the upside scenario remains
similarly configured, exploring a more benign set of economic
outcomes, including a stronger performing stock market, real
estate prices, and supported by a stronger global growth
backdrop, relative to the base case view. Reflecting recent
outturn data, inflation falls back quicker and the labour market is
tighter than previously assumed.
Base case
– High inflation and tight monetary policy leads to
muted economic growth. However, continued disinflation allows
an easing cycle to start in 2024. The unemployment rate rises
modestly but there are no wide-spread job losses. Inflation
moderates and falls to a target level of 2% by early 2025. The
housing market experiences modest nominal price decline but the
extent of the decline is lower than experienced during prior
stresses. Housing market activities remain weak but gains pace
gradually as interest rates fall and real income recovers.
Since 31 December 2022, the economic outlook has improved as
energy prices fell sharply and the labour market remained
resilient. The near-term inflation outlook remains elevated and
upside risks remain but they have reduced since last year. Rates
increased to levels higher than expected previously and are
expected to remain higher for longer. Economic growth is still
expected to be muted in the near-term. The base case now
assumes muted growth in 2023 as opposed to a mild recession
assumed previously. The unemployment rate still rises but the
peak is marginally lower and is underpinned by a resilient labour
market The peak to trough house price correction remains
broadly similar to the previous assumption but the timing of the
fall is more spread out.
Downside
– Inflation resurges as energy prices rise and core
inflation remains persistently high. The economy experiences a
recession as consumer confidence weakens due to a fall in real
income. Interest rates are raised higher than the base case and
remain elevated for longer. High rates are assumed to have a
more significant impact on the labour market. Unemployment is
higher than the base case scenario while house prices experience
declines comparable to previous episodes of stress.
Compared to 31 December 2022, the downside scenario explores
risks associated with ongoing price pressures and significantly
higher interest rates across the period. This contrasts with last
year’s scenario, which assumed lower rates than the base case
view. Partly as a result, UK economic activity and labour market
are slightly weaker. Nominal asset prices, while experiencing
declines comparable with past downturns, perform slightly better
than previously assumed.
Extreme downside
– This scenario assumes a classical recession
with loss of consumer confidence leading to a deep economic
recession. This results in widespread job losses with the
unemployment rate rising above the levels seen during the 2008
financial crisis. Rates are cut sharply in response, leading to some
support to the recovery. House prices lose approximately a third
of their value.
Compared to 31 December 2022, the extreme downside again
captures an extreme set of economic outcomes, with very sharp
falls in asset prices and a marked deterioration in the labour
market. The key difference is the assumed path for interest rates.
Unlike at 31 December 2022, when recessionary risks were
explored in the context of a stubbornly high inflation environment,
both inflation and interest rates are now assumed to follow a
significantly lower trajectory – consistent with recession driven by
material weakness in domestic demand.
Risk and capital management continued
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Annual Report and Accounts 2023
50
Credit risk continued
Main macroeconomic variables
The main macroeconomic variables for each of the four scenarios used for expected credit loss (ECL) modelling are set out in the main
macroeconomic variables table below.
31 December 2023
31 December 2022
Extreme
Weighted
Extreme
Weighted
Upside
Base case
Downside
downside
average
Upside
Base case
Downside
downside
average
Five-year summary
%
%
%
%
%
%
%
%
%
%
GDP
1.8
1.0
0.5
(0.3)
0.9
2.2
1.3
0.8
0.4
1.2
Unemployment
3.5
4.6
5.2
6.8
4.8
3.9
4.5
4.9
6.7
4.8
House price index
3.9
0.3
(0.4)
(5.7)
0.3
5.1
0.8
(0.7)
(4.4)
0.6
Commercial real estate price
3.1
(0.2)
(2.0)
(6.8)
(0.6)
1.2
(1.9)
(2.8)
(9.1)
(2.5)
Consumer price index
1.7
2.6
5.2
1.8
2.8
3.6
4.2
4.4
8.2
4.8
Bank of England base rate
3.8
3.7
5.6
2.9
4.0
2.4
3.1
1.5
4.5
2.8
UK stock price index
4.8
3.3
1.2
(0.4)
2.8
3.0
1.4
(1.1)
(3.7)
0.5
World GDP
3.7
3.2
2.7
1.8
3.0
3.7
3.3
1.7
1.1
2.7
Probability weight
21.2
45.0
20.4
13.4
18.6
45.0
20.8
15.6
(1)
The five-year summary runs from 2023-27 for 31 December 2023 and from 2022-26 for 31 December 2022.The table shows CAGR for annual GDP, average levels for the
unemployment rate and Bank of England base rate and Q4 to Q4 CAGR for other parameters.
Probability weightings of scenarios
NWM Group’s quantitative approach to IFRS 9 multiple economic
scenarios (MES) involves selecting a suitable set of discrete
scenarios to characterise the distribution of risks in the economic
outlook and assigning appropriate probability weights. This
quantitative approach is used for 31 December 2023.
The approach involves comparing UK GDP paths for NWM
Group’s scenarios against a set of 1,000 model runs, following
which, a percentile in the distribution is established that most
closely corresponded to the scenario. Probability weight for base
case is set first based on judgement, while probability weights for
the alternate scenarios are assigned based on these percentiles
scores.
The assigned probability weights were judged to be aligned with
the subjective assessment of balance of the risks in the economy.
The weights were broadly comparable to those used at 31
December 2022 but with slightly less downside skew. This is
reasonable as the inflation outturn since then has been
encouraging, with continued disinflation and a reduced risk of
stagflation. However, the risks still remain elevated and there is
considerable uncertainty in the economic outlook, particularly with
respect to persistence and the range of outcomes on inflation.
Given that backdrop, NWM Group judges it appropriate that
downside-biased scenarios have higher combined probability
weights than the upside-biased scenario. It presents good
coverage to the range of outcomes assumed in the scenarios,
including the potential for a robust recovery on the upside and
exceptionally challenging outcomes on the downside. A 21.2%
weighting was applied to the upside scenario, a 45.0% weighting
applied to the base case scenario, a 20.4% weighting applied to
the downside scenario and a 13.4% weighting applied to the
extreme downside scenario.
UK gross domestic product (£bn)
2023Q1
2024Q1
2025Q1
2026Q1
2027Q1
2028Q1
2000
2100
2200
2300
2400
2500
2600
Upside
Base case
Downside
Extreme downside
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Annual Report and Accounts 2023
51
Credit risk continued
Bank of England base rate (%)
2023Q1
2024Q1
2025Q1
2026Q1
2027Q1
2028Q1
0
1
2
3
4
5
6
7
Upside
Base case
Downside
Extreme downside
UK unemployment rate (%)
2023Q1
2024Q1
2025Q1
2026Q1
2027Q1
2028Q1
0
1
2
3
4
5
6
7
8
9
Upside
Base case
Downside
Extreme downside
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Annual Report and Accounts 2023
52
Credit risk continued
Economic loss drivers
(audited)
Annual figures
Extreme
Weighted
Upside
Base case
Downside
downside
average
GDP - annual growth
%
%
%
%
%
2023
0.5
0.5
0.5
0.5
0.5
2024
3.6
0.4
(1.1)
(2.7)
0.3
2025
2.3
1.3
0.4
(1.6)
1.0
2026
1.2
1.6
1.2
1.2
1.4
2027
1.2
1.4
1.3
1.2
1.3
2028
1.2
1.4
1.3
1.2
1.3
Unemployment rate - annual average
2023
4.2
4.2
4.2
4.2
4.2
2024
3.9
4.7
5.2
6.2
4.8
2025
3.2
4.7
5.8
8.4
5.1
2026
3.2
4.6
5.6
8.0
5.0
2027
3.3
4.6
5.5
7.4
4.8
2028
3.3
4.5
5.3
6.7
4.7
House price index - four quarter change
2023
(2.9)
(2.9)
(2.9)
(2.9)
(2.9)
2024
7.2
(5.0)
(7.1)
(11.5)
(3.7)
2025
9.4
3.1
(3.1)
(14.2)
1.2
2026
2.8
3.4
5.5
(5.8)
2.7
2027
3.3
3.4
6.1
7.2
4.3
2028
3.5
3.4
4.4
6.6
3.9
Commercial real estate price - four quarter change
2023
(7.2)
(7.2)
(7.2)
(7.2)
(7.2)
2024
12.7
-
(7.3)
(18.4)
(1.2)
2025
3.5
2.7
(2.0)
(20.0)
(0.5)
2026
4.6
2.0
3.8
6.7
3.4
2027
2.9
1.9
3.1
8.5
3.0
2028
1.3
0.8
2.6
8.6
2.0
Consumer price index - four quarter change
2023
4.6
4.6
4.6
4.6
4.6
2024
0.9
2.5
8.5
(1.2)
2.9
2025
0.7
2.0
5.3
1.7
2.4
2026
1.1
1.9
3.8
2.0
2.1
2027
1.2
1.9
3.7
2.0
2.2
2028
1.1
1.9
3.6
2.0
2.1
Bank of England base rate - annual average
2023
4.68
4.68
4.68
4.68
4.68
2024
4.79
4.77
6.10
4.00
4.94
2025
3.46
3.46
6.08
2.06
3.81
2026
3.17
2.85
5.69
2.00
3.38
2027
2.75
2.75
5.31
2.00
3.17
2028
2.50
2.75
5.06
2.25
3.10
UK stock price index - four quarter change
2023
3.7
3.7
3.7
3.7
3.7
2024
8.1
3.2
(17.4)
(41.5)
(5.9)
2025
5.1
3.2
8.7
24.9
6.5
2026
3.6
3.2
7.9
16.7
5.5
2027
3.6
3.2
5.6
11.0
4.6
2028
2.9
3.2
5.3
9.9
4.3
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
53
Credit risk continued
Economic loss drivers
(audited)
Worst points
31 December 2023
31 December 2022
Extreme
Weighted
Extreme
Weighted
Downside
downside
average
Downside
downside
average
%
Quarter
%
Quarter
%
%
Quarter
%
Quarter
%
GDP
(1.2)
Q3 2024
(4.5)
Q4 2024
0.3
(3.2)
Q4 2023
(4.7)
Q4 2023
(0.8)
Unemployment rate - peak
5.8
Q1 2025
8.5
Q2 2025
5.2
6.0
Q1 2024
8.5
Q3 2024
5.4
House price index
(12.5)
Q4 2025
(31.7)
Q2 2026
(6.5)
(15.0)
Q1 2025
(26.2)
Q3 2025
(3.4)
Commercial real estate price
(16.6)
Q1 2025
(39.9)
Q3 2025
(10.2)
(21.8)
Q4 2023
(46.8)
Q3 2024
(16.4)
Consumer price index
10.3
Q1 2023
10.3
Q1 2023
10.3
15.7
Q1 2023
17.0
Q4 2023
11.7
Bank of England base rate
6.5
Q4 2024
5.3
Q4 2023
5.3
4.0
Q1 2023
6.0
Q1 2024
4.1
UK stock price index
(14.3)
Q4 2024
(39.3)
Q4 2024
(2.4)
(26.0)
Q4 2023
(48.7)
Q4 2023
(14.1)
(2)
Unless specified otherwise, the figures show falls relative to the starting period. The calculations are performed over five years, with a starting point of Q4 2022 for 31 December 2023
scenarios and Q4 2021 for 31 December 2022 scenarios.
Use of the scenarios in lending
Wholesale lending follows a continuous scenario approach to
calculate ECL. PD and LGD values arising from multiple economic
forecasts (based on the concept of credit cycle indices) are
simulated around the central projection. The central projection is
a weighted average of economic scenarios with the scenarios
translated into credit cycle indices using the Wholesale economic
response models.
UK economic uncertainty
The high inflation environment alongside high interest rates are
presenting significant headwinds for some businesses and
consumers, in many cases compounding. These cost pressures
remain a feature of the economic environment, though they are
expected to moderate over 2024 and 2025 in the base case
scenario. NWM Group has considered where these are most
likely to affect the customer base, with the cost of borrowing
during 2023 for both businesses and consumers presenting an
additional affordability challenge.
The effects of these risks are not expected to be fully captured
by forward-looking credit modelling, particularly given the high
inflation environment, low unemployment base-case outlook. Any
incremental ECL effects for these risks will be captured via post
model adjustments and are detailed further in the Governance
and post model adjustments section.
Model and monitoring enhancements
In lending, new economic response models were introduced in
2022 and 2023 that follow an improved modelling approach and
put higher weight on stock price indices compared to previous
models.
Measurement uncertainty and ECL sensitivity analysis
(audited)
The recognition and measurement of ECL is complex and
involves the use of significant judgement and estimation,
particularly in times of economic volatility and uncertainty. This
includes the formulation and incorporation of multiple forward-
looking economic conditions into ECL to meet the measurement
objective of IFRS 9. The ECL provision is sensitive to the model
inputs and economic assumptions underlying the estimate.
The impact arising from the base case, upside, downside and
extreme downside scenarios was simulated. In the simulations,
NWM Group has assumed that the economic macro variables
associated with these scenarios replace the existing base case
economic assumptions, giving them a 100% probability weighting
and therefore serving as a single economic scenario.
These scenarios were applied to all modelled portfolios in the
analysis below, with the simulation impacting both PDs and
LGDs. Post model adjustments included in the ECL estimates that
were modelled were sensitised in line with the modelled ECL
movements, but those that were judgemental in nature, primarily
those for deferred model calibrations and economic uncertainty,
were not (refer to the Governance and post model adjustments
section) on the basis these would be re-evaluated by
management through ECL governance for any new economic
scenario outlook and not be subject to an automated calculation.
As expected, the scenarios create differing impacts on ECL by
portfolio and the impacts are deemed reasonable. In this
simulation, it is assumed that existing modelled relationships
between key economic variables and loss drivers hold, but in
practice other factors would also have an impact, for example,
potential customer behaviour changes and policy changes by
lenders that might impact on the wider availability of credit.
The focus of the simulations is on ECL provisioning requirements
on performing exposures in Stage 1 and Stage 2. The simulations
are run on a stand-alone basis and are independent of each
other; the potential ECL impacts reflect the simulated impact at
31 December 2023. Scenario impacts on SICR should be
considered when evaluating the ECL movements of Stage 1 and
Stage 2. In all scenarios the total exposure was the same but
exposure by stage varied in each scenario.
Stage 3 provisions are not subject to the same level of
measurement uncertainty – default is an observed event as at
the balance sheet date. Stage 3 provisions therefore were not
considered in this analysis.
NWM Group’s core criterion to identify a SICR is founded on PD
deterioration. Under the simulations, PDs change and result in
exposures moving between Stage 1 and Stage 2 contributing to
the ECL impact.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
54
Credit risk continued
Moderate
Extreme
Moderate upside
downside
downside
31 December 2023
Actual
Base scenario
scenario
scenario
scenario
Stage 1 modelled loans (£m)
14,390
14,413
14,425
14,390
13,906
Stage 1 modelled ECL (£m)
24
21
20
26
39
Stage 1 coverage (%)
0.17%
0.15%
0.14%
0.18%
0.28%
Stage 2 modelled loans (£m)
565
542
530
565
1,049
Stage 2 modelled ECL (£m)
8
7
6
8
16
Stage 2 coverage (%)
1.42%
1.29%
1.13%
1.42%
1.53%
Stage 1 and Stage 2 modelled loans (£m)
14,955
14,955
14,955
14,955
14,955
Stage 1 and Stage 2 modelled ECL (£m)
32
28
26
34
55
Stage 1 and Stage 2 coverage (%)
0.21%
0.19%
0.17%
0.23%
0.37%
Variance – (lower)/higher to actual total Stage 1 and Stage 2 ECL (£m)
(4)
(6)
2
23
Reconciliation to Stage 1 and Stage 2 flow exposure (£m)
Modelled loans
14,955
14,955
14,955
14,955
14,955
Other asset classes
34,900
34,900
34,900
34,900
34,900
(1)
Variations in future undrawn exposure values across the scenarios are modelled, however the exposure position reported is that used to calculate modelled ECL as at 31 December 2023
and therefore does not include variation in future undrawn exposure values.
(2)
Reflects ECL for all modelled exposure in scope for IFRS 9. The analysis excludes non-modelled portfolios and exposures relating to bonds and cash.
(3)
All simulations are run on a stand-alone basis and are independent of each other, with the potential ECL impact reflecting the simulated impact as at 31 December 2023. The simulations
change the composition of Stage 1 and Stage 2 exposure, but total exposure is unchanged under each scenario as the loan population is static.
(4)
Refer to the Economic loss drivers’ section for details of economic scenarios.
(5)
Refer to the NWM Group 2022 Annual Report and Accounts for 2022 comparatives.
Measurement uncertainty and ECL adequacy
(audited)
A net improvement in the economic scenarios since 2022
resulted in a reduction in modelled ECL.
Given that continued uncertainty remained due to high
inflation, rising interest rates during 2023 and supply chain
disruption, NWM Group utilised a framework of quantitative
and qualitative measures to support the levels of ECL
coverage. This included economic data, credit performance
insights, supply chain contagion analysis and problem debt
trends. This was particularly important for consideration of
post model adjustments.
As the effects of these economic risks evolve into 2024, there
is a risk of further credit deterioration. However, the income
statement effect of this should have been mitigated by the
forward-looking provisions retained on the balance sheet at
31 December 2023.
There are a number of key factors that could drive further
downside to impairments, through deteriorating economic and
credit metrics and increased stage migration as credit risk
increases for more customers. Such factors which could
impact the IFRS 9 models, include an adverse deterioration in
unemployment and GDP in the economies in which NWM
Group operates.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
55
Credit risk – Trading activities
This section details the credit risk profile of NWM Group's trading activities.
Securities financing transactions and collateral
(audited)
The table below shows securities financing transactions in NWM Group. Balance sheet captions include balances held at all
classifications under IFRS.
Reverse repos
Repos
Of which:
Outside
Of which:
Outside
can be
netting
can be
netting
Total
offset
arrangements
Total
offset
arrangements
2023
£m
£m
£m
£m
£m
£m
Gross
41,750
41,292
458
44,028
43,308
720
IFRS offset
(16,257)
(16,257)
-
(16,257)
(16,257)
-
Carrying value
25,493
25,035
458
27,771
27,051
720
Master netting arrangements
(669)
(669)
-
(669)
(669)
-
Securities collateral
(24,175)
(24,175)
-
(26,382)
(26,382)
-
Potential for offset not recognised under IFRS
(24,844)
(24,844)
-
(27,051)
(27,051)
-
Net
649
191
458
720
-
720
2022
Gross
36,945
36,411
534
39,340
34,857
4,483
IFRS offset
(14,547)
(14,547)
-
(14,547)
(14,547)
-
Carrying value
22,398
21,864
534
24,793
20,310
4,483
Master netting arrangements
(2,445)
(2,445)
-
(2,445)
(2,445)
-
Securities collateral
(19,221)
(19,221)
-
(17,865)
(17,865)
-
Potential for offset not recognised under IFRS
(21,666)
(21,666)
-
(20,310)
(20,310)
-
Net
732
198
534
4,483
-
4,483
Debt securities
(audited)
The table below shows debt securities held at mandatory fair value through profit or loss by issuer as well as ratings based on the
lowest of Standard & Poor’s, Moody’s and Fitch. Refer to Note 12 on Trading assets and trading liabilities for details on short positions.
Central and local government
Financial
UK
US
Other
institutions
Corporate
Total
2023
£m
£m
£m
£m
£m
£m
AAA
-
-
1,333
1,132
-
2,465
AA to AA+
-
2,600
19
762
4
3,385
A to AA-
2,729
-
1,017
251
283
4,280
BBB- to A-
-
-
693
295
489
1,477
Non-investment grade
-
-
-
198
149
347
Unrated
-
-
-
-
-
-
Total
2,729
2,600
3,062
2,638
925
11,954
2022
AAA
-
-
469
766
3
1,238
AA to AA+
-
2,345
1,042
1,114
21
4,522
A to AA-
2,205
-
372
77
29
2,683
BBB- to A-
-
-
916
149
296
1,361
Non-investment grade
-
-
-
65
49
114
Unrated
-
-
-
1
3
4
Total
2,205
2,345
2,799
2,172
401
9,922
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
56
Credit risk – Trading activities continued
Derivatives
(audited)
The table below shows third party derivatives by type of contract. The master netting agreements and collateral shown do not result
in a net presentation on the balance sheet under IFRS.
2023
2022
Notional
GBP
USD
EUR
Other
Total
Assets
Liabilities
Notional
Assets
Liabilities
£bn
£bn
£bn
£bn
£bn
£m
£m
£bn
£m
£m
Gross exposure
83,276
76,879
101,020
95,478
IFRS offset
(5,242)
(5,242)
(2,509)
(2,509)
Carrying value
2,797
2,922
5,934
1,120
12,773
78,034
71,637
13,470
98,511
92,969
Of which:
Interest rate
(1)
2,510
1,530
5,389
227
9,656
43,767
37,974
10,319
52,529
47,873
Exchange rate
286
1,387
535
893
3,101
34,085
33,337
3,136
45,746
44,821
Credit
1
5
10
-
16
182
326
15
236
275
Equity and commodity
-
-
-
-
-
-
-
-
-
-
Carrying value
12,773
78,034
71,637
13,470
98,511
92,969
Counterparty mark-to-market
netting
(59,827)
(59,827)
(76,722)
(76,722)
Cash collateral
(12,272)
(6,590)
(14,064)
(9,480)
Securities collateral
(3,084)
(1,663)
(4,210)
(1,185)
Net exposure
2,851
3,557
3,515
5,582
Banks
(2)
333
556
647
669
Other financial institutions
(3)
1,424
1,295
1,724
1,936
Corporate
(4)
1,058
1,667
1,062
2,890
Government
(5)
36
39
82
87
Net exposure
2,851
3,557
3,515
5,582
UK
1,277
1,884
1,257
2,753
Europe
800
1,209
1,195
1,990
US
607
381
753
626
RoW
167
83
310
213
Net exposure
2,851
3,557
3,515
5,582
Asset quality of
uncollateralised
derivative assets
AQ1-AQ4
2,376
3,001
AQ5-AQ8
471
498
AQ9-AQ10
4
16
Net exposure
2,851
3,515
(1)
The notional amount of interest rate derivatives includes £6,677 billion (2022 – £7,651 billion) in respect of contracts cleared through central clearing counterparties.
(2)
Transactions with certain counterparties with which NWM Group has netting arrangements but collateral is not posted on a daily basis; certain transactions with specific terms that may
not fall within netting and collateral arrangements; derivative positions in certain jurisdictions where the collateral agreements are not deemed to be legally enforceable.
(3)
Includes transactions with securitisation vehicles and funds where collateral posting is contingent on NWM Group’s external rating.
(4)
Mainly large corporates with which NWM Group may have netting arrangements in place, but operational capability does not support collateral posting.
(5)
Sovereigns and supranational entities with no collateral arrangements, collateral arrangements that are not considered enforceable, or one-way collateral agreements in their favour.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
57
Credit risk – Net credit exposures for banking and trading activities
Asset quality
(audited)
The table below shows the current and potential exposure by high-level asset class and asset quality. It represents total credit risk for
assets held in the banking book in addition to counterparty credit risk for traded products. Refer to page 61 for a mapping of AQ band
to probability of default range and indicative external credit rating.
Cash &
Collateralised
Uncollateralised
balances at
Sovereign debt
Loans and
Other debt
rate risk
rate risk
Repo and reverse
Off-balance
central banks
securities
other lending
securities
management
management
repo
sheet items
Leasing
Total
2023
£m
£m
£m
£m
£m
£m
£m
£m
£m
£m
AQ1-AQ4
13,831
3,585
11,600
11,533
1,869
1,313
1,398
3,117
27
48,273
AQ5-AQ8
-
-
962
302
151
290
47
19
-
1,771
AQ9
-
-
26
-
1
-
-
-
-
27
AQ10
-
-
3
1
-
2
-
-
-
6
Current exposure
13,831
3,585
12,591
11,836
2,021
1,605
1,445
3,136
27
50,077
Potential exposure
13,831
3,585
26,814
11,836
9,411
4,093
2,305
4,187
27
76,089
2022
AQ1-AQ4
17,007
5,695
9,987
5,538
2,360
1,964
1,659
596
29
44,835
AQ5-AQ8
-
-
687
305
164
327
25
21
-
1,529
AQ9
-
-
23
-
2
13
-
-
-
38
AQ10
-
-
47
1
-
-
-
-
-
48
Current exposure
17,007
5,695
10,744
5,844
2,526
2,304
1,684
617
29
46,450
Potential exposure
17,007
5,695
24,235
5,844
11,488
4,749
2,206
1,715
29
72,968
Measured against NWM Group’s asset quality scale, 96% (2022 – 96%) of total current exposure was rated in the AQ1-AQ4 bands,
which in the context of external credit ratings was equivalent to an investment grade rating of BBB- or better.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
58
Credit risk – Banking activities
Introduction
This section details the credit risk profile of NWM Group’s banking activities. For accounting policy information refer to Accounting
policy 2.3 and Note 14 to the consolidated financial statements for policies and critical judgements relating to impairment loss
determination.
Financial instruments within the scope of the IFRS 9 ECL framework
(audited)
Refer to Note 9 to the consolidated financial statements for balance sheet analysis of financial assets that are classified as amortised
cost or fair value through other comprehensive income (FVOCI), the starting point for IFRS 9 ECL framework assessment.
Financial assets
31 December 2023
31 December 2022
Gross
ECL
Net
Gross
ECL
Net
£bn
£bn
£bn
£bn
£bn
£bn
Balance sheet total gross amortised cost and FVOCI
51.0
42.8
In scope of IFRS 9 ECL framework
43.7
40.1
% in scope
86%
94%
Loans to customers - in scope - amortised cost
13.0
-
13.0
10.2
-
10.2
Loans to customers - in scope - FVOCI
0.1
-
0.1
0.1
-
0.1
Loans to banks - in scope - amortised cost
1.2
-
1.2
1.0
-
1.0
Total loans - in scope
14.3
-
14.3
11.3
-
11.3
Stage 1
13.7
-
13.7
10.8
-
10.8
Stage 2
0.6
-
0.6
0.5
-
0.5
Stage 3
-
-
-
-
-
-
Other financial assets - in scope - amortised cost
25.4
-
25.4
22.8
-
22.8
Other financial assets - in scope - FVOCI
4.0
-
4.0
6.0
-
6.0
Total other financial assets - in scope
29.4
-
29.4
28.8
-
28.8
Stage 1
29.3
-
29.3
28.8
-
28.8
Stage 2
0.1
-
0.1
-
-
-
Stage 3
-
-
-
Out of scope of IFRS 9 ECL framework
7.3
na
7.3
2.7
na
2.7
Loans to customers - out of scope - amortised cost
-
na
-
-
na
-
Loans to banks - out of scope - amortised cost
0.1
na
0.1
0.2
na
0.2
Other financial assets - out of scope - amortised cost
7.1
na
7.1
2.6
na
2.6
Other financial assets - out of scope - FVOCI
0.1
na
0.1
(0.1)
na
(0.1)
na = not applicable
The assets outside the scope of IFRS 9 ECL framework were as
follows:
Settlement balances, items in the course of collection, cash
balances and other non-credit risk assets of £7.3 billion (2022
– £2.7 billion). These were assessed as having no ECL unless
there was evidence that they were defaulted.
Equity shares of £0.1 billion (2022 – £0.1 billion) as not within
the IFRS 9 ECL framework by definition.
Fair value adjustments on loans and debt securities hedged
by interest rate swaps, where the underlying loan was within
the IFRS 9 ECL scope of nil (2022 – £(0.2) billion).
In scope assets also include an additional £1.3 billion (2022 – £0.4
billion) of inter-Group assets not shown in the table above.
Contingent liabilities and commitments
In addition to contingent liabilities and commitments disclosed in
Note 25 to the consolidated financial statements, reputationally-
committed limits are also included in the scope of the IFRS 9 ECL
framework. These were offset by £0.2 billion (2022 – £0.2 billion)
out of scope balances primarily related to facilities that, if drawn,
would not be classified as amortised cost or FVOCI, or undrawn
limits relating to financial assets exclusions. Total contingent
liabilities (including financial guarantees) and commitments within
IFRS 9 ECL scope of £15.6 billion (2022 – £14.7 billion) comprised
Stage 1 £15.1 billion (2022 – £13.3 billion); Stage 2 £0.5 billion
(2022 – £1.4 billion); and Stage 3 nil (2022 – nil).
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
59
Credit risk – Banking activities continued
Portfolio summary
(audited)
The table below shows gross loans and ECL, by stage, within the scope of the IFRS 9 ECL framework.
2023
2022
£m
£m
Loans - amortised cost and FVOCI
Stage 1
13,686
10,791
Stage 2
558
497
Stage 3
25
49
Of which: individual
17
37
Of which: collective
8
12
Inter-Group
(1)
1,264
434
Total
15,533
11,771
ECL provisions
Stage 1
24
20
Stage 2
8
8
Stage 3
24
26
Of which: individual
16
15
Of which: collective
8
11
Inter-Group
(1)
1
-
Total
57
54
ECL provisions coverage
(2)
Stage 1 (%)
0.18
0.19
Stage 2 (%)
1.43
1.61
Stage 3 (%)
96.00
53.06
Total
0.39
0.48
Impairment losses
ECL charge/(releases)
Stage 1
1
8
Stage 2
4
14
Stage 3
(3)
(14)
Of which: individual
(2)
(15)
Of which: collective
(1)
1
Third party
2
8
Inter-Group
-
-
Total
2
8
Amounts written-off
5
55
Of which: individual
4
55
Of which: collective
1
-
(1)
NWM Group’s intercompany assets were classified in Stage 1. The ECL for these loans was £0.6 million (2022 – £0.4 million).
(2)
ECL provisions coverage is calculated as ECL provisions divided by loans – amortised cost and FVOCI. It is calculated on loans and total ECL provisions, including ECL for other (non-loan)
assets and unutilised exposure. Some segments with a high proportion of debt securities or unutilised exposure may result in a not meaningful coverage ratio.
(3)
The table shows gross loans only and excludes amounts that are outside the scope of the ECL framework. Refer to the financial instruments within the scope of the IFRS 9 ECL framework
section for further details. Other financial assets within the scope of the IFRS 9 ECL framework were cash and balances at central banks totalling £13.8 billion (2022 – £17.0 billion) and
debt securities of £15.6 billion (2022 – £11.8 billion).
(4)
The stage allocation of the ECL charge was aligned to the stage transition approach that underpins the analysis in the Flow statement section.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
60
Credit risk – Banking activities continued
Sector analysis – portfolio summary
(audited)
The table below shows financial assets and off-balance sheet exposures gross of ECL and related ECL provisions, impairment by
sector, asset quality and geographical region based on the country of operation of the customer. The tables below report only third-
party exposures and related ECL provisions, charges and write-offs.
Property
Corporate
FI (1)
Sovereign
Total
2023
£m
£m
£m
£m
£m
Loans by geography
50
1,063
12,798
358
14,269
- UK
24
554
4,049
59
4,686
- Other Europe
25
387
3,952
227
4,591
- RoW
1
122
4,797
72
4,992
Loans by stage
50
1,063
12,798
358
14,269
- Stage 1
19
922
12,387
358
13,686
- Stage 2
21
126
411
-
558
- Stage 3
10
15
-
-
25
of which: individual
7
10
-
-
17
of which: collective
3
5
-
-
8
Weighted average life
(4)
- ECL measurement (years)
2
4
2
-
2
Weighted average 12 months PDs
(4)
- IFRS 9 (%)
0.84
1.66
0.17
0.01
0.25
- Basel (%)
0.61
1.61
0.13
0.01
0.20
ECL provisions by geography
7
24
24
1
56
- UK
4
4
11
1
20
- Other Europe
3
12
7
-
22
- RoW
-
8
6
-
14
ECL provisions by stage
7
24
24
1
56
- Stage 1
-
4
19
1
24
- Stage 2
-
3
5
-
8
- Stage 3
7
17
-
-
24
of which: individual
4
12
-
-
16
of which: collective
3
5
-
-
8
ECL provisions coverage (%)
14.00
2.26
0.19
0.28
0.39
- Stage 1 (%)
-
0.43
0.15
0.28
0.18
- Stage 2 (%)
-
2.38
1.22
-
1.43
- Stage 3 (%)
70.00
113.33
-
-
96.00
ECL (release)/charge - Third party
(1)
(7)
10
-
2
Amounts written-off
-
4
1
-
5
Other financial assets by asset quality
(2)
1
81
12,059
17,250
29,391
- AQ1-AQ4
1
81
11,709
17,250
29,041
- AQ5-AQ8
-
-
350
-
350
- AQ9
-
-
-
-
-
Off-balance sheet
201
6,527
8,897
-
15,625
- Loan commitments
188
6,507
8,150
-
14,845
- Financial guarantees
13
20
747
-
780
Off-balance sheet by asset quality
(2)
201
6,527
8,897
-
15,625
- AQ1-AQ4
183
6,049
8,697
-
14,929
- AQ5-AQ8
16
457
200
-
673
- AQ9
-
-
-
-
-
- AQ10
2
21
-
-
23
For the notes to this table refer to the following page.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
61
Credit risk – Banking activities continued
Sector analysis – portfolio summary
(audited)
Property
Corporate
FI (1)
Sovereign
Total
2022 (3)
£m
£m
£m
£m
£m
Loans by geography
193
874
9,913
357
11,337
- UK
48
239
3,564
72
3,923
- Other Europe
145
476
2,706
202
3,529
- RoW
-
159
3,643
83
3,885
Loans by stage
193
874
9,913
357
11,337
- Stage 1
33
607
9,797
354
10,791
- Stage 2
149
232
116
-
497
- Stage 3
11
35
-
3
49
of which: individual
8
26
-
3
37
of which: collective
3
9
-
-
12
Weighted average life
(4)
- ECL measurement (years)
1
3
3
-
3
Weighted average 12 months PDs
(4)
- IFRS 9 (%)
2.55
2.73
0.20
0.03
0.41
- Basel (%)
0.64
1.48
0.13
0.02
0.22
ECL provisions by geography
8
28
14
4
54
- UK
4
9
8
1
22
- Other Europe
4
10
3
-
17
- RoW
-
9
3
3
15
ECL provisions by stage
8
28
14
4
54
- Stage 1
1
5
12
2
20
- Stage 2
1
5
2
-
8
- Stage 3
6
18
-
2
26
of which: individual
3
10
-
2
15
of which: collective
3
8
-
-
11
ECL provisions coverage (%)
4.15
3.20
0.14
1.12
0.48
- Stage 1 (%)
3.03
0.82
0.12
0.56
0.19
- Stage 2 (%)
0.67
2.16
1.72
-
1.61
- Stage 3 (%)
54.55
51.43
-
66.67
53.06
ECL (release)/charge - Third party
(6)
6
7
1
8
Amounts written-off
-
55
-
-
55
Other financial assets by asset quality
(2)
49
155
6,097
22,478
28,779
- AQ1-AQ4
-
141
5,777
22,478
28,396
- AQ5-AQ8
49
14
320
-
383
- AQ9
-
-
-
-
-
Off-balance sheet
186
7,281
7,067
-
14,534
- Loan commitments
173
7,256
6,481
-
13,910
- Financial guarantees
13
25
586
-
624
Off-balance sheet by asset quality
(2)
186
7,281
7,067
-
14,534
- AQ1-AQ4
168
6,679
6,864
-
13,711
- AQ5-AQ8
16
600
203
-
819
- AQ9
-
-
-
-
-
- AQ10
2
2
-
-
4
(1)
Financial institutions (FI) include transactions, such as securitisations, where the underlying assets may be in other sectors.
(2)
AQ bandings are based on Basel PDs and mapping is as follows:
Internal asset quality band
Probability of default range
Indicative S&P rating
AQ1
0% -0.034%
AAA to AA
AQ2
0.034% - 0.048%
AA to AA-
AQ3
0.048% - 0.095%
A+ to A
AQ4
0.095% - 0.381%
BBB+ to BBB-
AQ5
0.381% - 1.076%
BB+ to BB
AQ6
1.076% - 2.153%
BB- to B+
AQ7
2.153% - 6.089%
B+ to B
AQ8
6.089% - 17.222%
B- to CCC+
AQ9
17.222% - 100%
CCC to C
AQ10
100%
D
(3)
Previously published sectors for the Wholesale portfolio have been re-presented to reflect updated internal sector reporting.
(4)
Not within audit scope.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
62
Credit risk – Banking activities continued
Sector analysis – portfolio summary
(audited)
The table below shows ECL by stage for the Wholesale portfolio, including selected sectors that contain an element of exposure
classified as heightened climate-related risk.
Loans - amortised cost and FVOCI
Off-balance sheet
ECL provisions
Stage 1
Stage 2
Stage 3
Total
Loan
Contingent
Stage 1
Stage 2
Stage 3
Total
2023
£m
£m
£m
£m
commitments
liabilities
£m
£m
£m
£m
Property
(1)
19
21
10
50
188
13
-
-
7
7
Financial institutions
(2)
12,387
411
-
12,798
8,150
747
19
5
-
24
Sovereign
358
-
-
358
-
-
1
-
-
1
Corporate
922
126
15
1,063
6,507
20
4
3
17
24
Of which:
Agriculture
1
-
-
1
1
-
-
-
-
-
Airlines and aerospace
23
-
-
23
279
-
-
-
-
-
Automotive
2
-
-
2
601
-
-
-
-
-
Building materials
4
-
4
8
171
1
-
-
2
2
Chemicals
11
-
-
11
67
-
-
-
-
-
Industrials
29
57
-
86
235
5
1
1
-
2
Land transport & logistics
51
5
-
56
311
2
-
-
-
-
Leisure
3
-
-
3
158
-
-
-
-
-
Mining & metals
-
-
3
3
-
-
-
-
3
3
Oil and gas
2
-
1
3
52
1
-
-
3
3
Power utilities
113
-
-
113
2,735
2
-
-
-
-
Retail
5
2
-
7
392
2
-
1
-
1
Shipping
2
-
-
2
-
-
-
-
-
-
Water & waste
30
14
-
44
35
-
-
-
-
-
Total
13,686
558
25
14,269
14,845
780
24
8
24
56
2022 (3)
Property
(1)
33
149
11
193
173
13
1
1
6
8
Financial institutions
(2)
9,797
116
-
9,913
6,481
586
12
2
-
14
Sovereign
354
-
3
357
-
-
2
-
2
4
Corporate
607
232
35
874
7,256
25
5
5
18
28
Of which:
Agriculture
-
2
-
2
1
-
-
-
-
-
Airlines and aerospace
-
22
1
23
412
-
-
1
1
2
Automotive
2
43
-
45
623
2
-
1
-
1
Building materials
2
2
4
8
17
1
-
-
2
2
Chemicals
13
-
-
13
64
-
-
-
-
-
Industrials
34
56
-
90
271
5
1
-
-
1
Land transport & logistics
18
53
-
71
314
1
-
1
-
1
Leisure
1
-
-
1
158
-
-
-
-
-
Mining & metals
-
-
3
3
-
-
-
-
3
3
Oil and gas
3
-
20
23
549
1
-
-
2
2
Power utilities
118
-
-
118
2,595
2
1
-
-
1
Retail
9
-
-
9
518
4
-
-
-
-
Shipping
2
-
-
2
14
-
-
-
-
-
Water & waste
32
-
-
32
256
-
-
-
-
-
Total
10,791
497
49
11,337
13,910
624
20
8
26
54
(1)
Property comprises Commercial Real Estate, Housing Associations and Construction.
(2)
Financial institutions (FI) include transactions, such as securitisations, where the underlying assets may be in other sectors.
(3)
Previously published sectors for the Wholesale portfolio have been re-presented to reflect updated internal sector reporting.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
63
Credit risk – Banking activities continued
Sector analysis – portfolio summary
(audited)
Forbearance
The table below shows forbearance, Heightened Monitoring and Risk of Credit Loss by sector. This table show current exposure but
reflects risk transfers where there is a guarantee by another customer.
FI
Property
Sovereign
Other
Total
2023
£m
£m
£m
£m
£m
Forbearance (flow)
-
3
-
4
7
Forbearance (stock)
-
3
-
8
11
Heightened Monitoring and Risk of Credit Loss
-
-
-
4
4
2022
Forbearance (flow)
-
-
-
20
20
Forbearance (stock)
-
-
-
45
45
Heightened Monitoring and Risk of Credit Loss
-
-
-
7
7
Credit risk enhancement and mitigation
(audited)
The table below shows exposures of modelled portfolios within the scope of the ECL framework and related credit risk enhancement
and mitigation (CREM).
Gross
Maximum credit risk
CREM by type
CREM coverage
Exposure post CREM
exposure
ECL
Total
Stage 3
Financial (1)
Property
Other (2)
Total
Stage 3
Total
Stage 3
2023
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
£bn
Financial assets
Cash and balances at central banks
13.8
-
13.8
-
-
-
-
-
-
13.8
-
Loans - amortised cost
(3)
14.3
0.1
14.2
-
2.2
-
-
2.2
-
12.0
-
Debt securities
15.6
-
15.6
-
-
-
-
-
-
15.6
-
Total financial assets
43.7
0.1
43.6
-
2.2
-
-
2.2
-
41.4
-
Contingent liabilities
and commitments
15.6
-
15.6
-
1.3
0.1
-
1.4
-
14.2
-
Total off-balance sheet
15.6
-
15.6
-
1.3
0.1
-
1.4
-
14.2
-
Total exposure
59.3
0.1
59.2
-
3.5
0.1
-
3.6
-
55.6
-
2022
Financial assets
Cash and balances at central banks
17.0
-
17.0
-
-
-
-
-
-
17.0
-
Loans - amortised cost
(3)
11.3
-
11.3
-
1.1
-
-
1.1
-
10.2
-
Debt securities
11.8
-
11.8
-
-
-
-
-
-
11.8
-
Total financial assets
40.1
-
40.1
-
1.1
-
-
1.1
-
39.0
-
Contingent liabilities
and commitments
14.5
-
14.5
-
1.6
0.1
-
1.7
-
12.8
-
Total off-balance sheet
14.5
-
14.5
-
1.6
0.1
-
1.7
-
12.8
-
Total exposure
54.6
-
54.6
-
2.7
0.1
-
2.8
-
51.8
-
(1)
Includes cash and securities collateral.
(2)
Includes guarantees and charges over trade debtors.
(3)
NWM Group holds collateral in respect of individual loans – amortised cost to banks and customers. This collateral includes mortgages over property; charges over business assets such
as plant and equipment, inventories and trade debtors; and guarantees of lending from parties other than the borrower. NWM Group obtains collateral in the form of securities in reverse
repurchase agreements. Collateral values are capped at the value of the loan.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
64
Credit risk – Banking activities continued
Flow statement
(audited)
The flow statement that follows shows the main ECL and related income statement movements. It also shows the changes in ECL as
well as the changes in related financial assets used in determining ECL. Due to differences in scope, exposures may differ from those
reported in other tables, principally in relation to exposures in Stage 1 and Stage 2.
These differences do not have a material ECL impact. Other points to note:
Financial assets include treasury liquidity portfolios, comprising balances at central banks and debt securities, as well as loans. Both
modelled and non-modelled portfolios are included.
Stage transfers (for example, exposures moving from Stage 1 into Stage 2) are a key feature of the ECL movements, with the net
re-measurement cost of transitioning to a worse stage being a primary driver of income statement charges. Similarly, there is an
ECL benefit for accounts improving stage.
Changes in risk parameters shows the reassessment of the ECL within a given stage, including any ECL overlays and residual
income statement gains or losses at the point of write-off or accounting write-down.
Other (P&L only items) includes any subsequent changes in the value of written-down assets along with other direct write-off items
such as direct recovery costs. Other (P&L only items) affects the income statement but does not affect balance sheet ECL
movements.
Amounts written-off represent the gross asset written-down against accounts with ECL, including the net asset write-down for any
debt sale activity.
Stage 1
Stage 2
Stage 3
Total
Financial
Financial
Financial
Financial
assets
ECL
assets
ECL
assets
ECL
assets
ECL
NWM Group
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January 2023
39,875
20
491
8
58
26
40,424
54
Currency translation and other adjustments
(986)
1
(11)
(1)
-
(6)
(997)
(6)
Inter-Group transfers
-
-
-
-
-
-
-
-
Transfers from Stage 1 to Stage 2
(777)
(2)
777
2
-
-
-
-
Transfers from Stage 2 to Stage 1
407
5
(407)
(5)
-
-
-
-
Net re-measurement of ECL on stage transfer
(3)
6
-
3
Changes in risk parameters
(1)
-
5
4
Other changes in net exposure
10,649
4
(162)
(1)
(30)
3
10,457
6
Other (P&L only items)
1
(1)
(11)
(11)
Income statement (releases)/charges
1
4
(3)
2
Amounts written-off
-
-
(1)
(1)
(4)
(4)
(5)
(5)
At 31 December 2023
49,168
24
687
8
24
24
49,879
56
Net carrying amount
49,144
679
-
49,823
At 1 January 2022
33,383
6
197
3
95
75
33,675
84
2022 movements
6,492
14
294
5
(37)
(49)
6,749
(30)
At 31 December 2022
39,875
20
491
8
58
26
40,424
54
Net carrying amount
39,855
483
32
40,370
The ECL profile was broadly stable, with the increase in Stage 1 reflecting asset growth.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
65
Pension risk
Definition
Pension risk is defined as the inability to meet contractual
obligations and other liabilities to the established employee or
related company pension scheme.
Sources of risk
NWM Group has exposure to pension risk through its defined
benefit schemes worldwide. The two largest NWM Group
schemes are the AA and the NatWest Markets sections of The
NatWest Group Pension Fund with a combined £0.9 billion of
assets and £0.6 billion of liabilities at 31 December 2023 (2022 –
£0.9 billion of assets and £0.6 billion of liabilities). Refer to Note 5
to the consolidated financial statements, for further details on
NWM Group’s pension obligations, including sensitivities to the
main risk factors.
Pension scheme liabilities vary with changes in long-term interest
rates and inflation as well as with pensionable salaries, the
longevity of scheme members and legislation. Pension scheme
assets vary with changes in interest rates, inflation expectations,
credit spreads, exchange rates, and equity and property prices.
However, the Trustee of NWM Group’s largest scheme (the AA
section of the NatWest Group Pension Fund) has now completed
a buy-in transaction with a third party insurer. Under the buy-in
policy, the insurer makes payments to the scheme to cover
pension benefits paid to members and as a result the scheme is
protected against all material longevity and investment risks.
Conversely, these risks have been replaced with the risk that the
insurer defaults on payments due to the scheme.
NWM Group is also exposed to the risk that the schemes’ assets,
together with future returns and additional future contributions,
are estimated to be insufficient to meet liabilities as they fall due.
In such circumstances, NWM Group could be obliged (or might
choose) to make additional contributions to the schemes or be
required to hold additional capital to mitigate this risk.
On 16 June 2023, the High Court issued a ruling in respect of
Virgin Media v NTL Pension Trustees II Limited (and others) calling
into question the validity of rule amendments made to defined
benefit pension schemes contracted-out on a Reference Scheme
Test basis between 6 April 1997 and 5 April 2016. Amendments
to these pension schemes over this time required confirmation
from the Scheme Actuary that the Reference Scheme Test would
continue to be met. In the absence of such a confirmation, the
Rule amendment would be void. Following the review of a
selection of amendments judged as material, the liabilities
disclosed in Note 5 to the consolidated financial statements
include no adjustments for the potential impact of this ruling.
Future developments will be kept under review.
Key developments in 2023
As explained above, during the year, the Trustee of the AA
section of the NatWest Group Pension Fund completed a buy-
in transaction, passing all material longevity and investment
risk for the section to an insurer. For further details, refer to
Note 5 to the consolidated financial statements.
Governance
The Pension Committee, chaired by the Chief Financial Officer,
reviews and monitors risk management, asset and liability
strategy and financing issues on behalf of NWM Group. As part of
its remit, the Committee:
Considers the financial strategy, risk management and policy
implications of NWM Group pension schemes.
Reviews and recommends NWM Group pension risk appetite
to the NWM Group Executive Risk Committee and the NWM
Group Board Risk Committee.
Reviews the pension impact on the capital plan for NWM
Group and escalates any concerns to the NWM Group Assets
& Liabilities Committee.
The performance of NatWest Group’s material pension funds
(including those sponsored by NWM Group) is reviewed by
NatWest Group’s Assets & Liabilities Committee.
Risk appetite
NWM Group maintains an independent view of the risk inherent in
its pension funds. NWM Group has a pension risk appetite
statement incorporating defined metrics against which risk is
measured that is reviewed at least annually by the Board on the
Board Risk Committee’s recommendation to ensure they remain
appropriate and aligned to strategy.
Policies and standards are in place to provide formal controls for
pension risk reporting, modelling, governance and stress testing.
A pension risk policy, which sits within the enterprise-wide risk
management framework, is also in place and is subject to
associated framework controls.
Monitoring and measurement
Pension risk is monitored by the NWM Group Executive Risk
Committee and the NWM Group Board Risk Committee by way of
the monthly risk management report, whilst the NatWest Group
Asset & Liability Management Committee receives updates on the
performance of NatWest Group’s material pension funds. Relevant
pension risk matters are escalated to the Board as applicable.
Stress tests are carried out each year on NWM Group’s material
defined benefit pension schemes. These tests are also used to
satisfy the requests of regulatory bodies such as the Bank of
England.
The stress testing framework includes pension risk capital
calculations for the purposes of the Internal Capital Adequacy
Assessment Process as well as additional stress tests for a
number of internal management purposes. The results of the
stress tests and their consequential impact on NWM Group’s
balance sheet, income statement and capital position are
incorporated into NWM Group’s and overall NatWest Group stress
test results.
Mitigation
As a result of the buy-in transaction for NWM Group’s largest
scheme (the AA section of the NatWest Group Pension Fund), the
scheme is now protected against all material longevity and
investment risks.
If, in an extreme scenario, the insurer was unable to make
payments due to the scheme under the buy-in policy, NWM Group
would continue to be responsible for financially supporting the
scheme to meet pension benefits. However, there are significant
mitigations in place against this risk, in particular the insurance
regulatory regime and residual surplus assets retained within the
scheme. The financial strength of the third party insurer will also
be monitored on a periodic basis by the Trustee and NatWest
Group.
The NatWest Markets section of the NatWest Group Pension Fund
is also well protected against interest rate and inflation risks and is
being run on a low investment risk basis with relatively small
equity risk exposure.
The NatWest Markets section of the
NatWest Group Pension Fund also use derivatives to manage the
allocation of the portfolio to different asset classes and to manage
risk within asset classes.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
66
Pension risk continued
The potential impact of climate change is one of the factors
considered in managing the assets of the pension schemes. The
Trustee monitors the risk to its investments from changes in the
global economy and invests, where return justifies the risk, in
sectors that reduce the world’s reliance on fossil fuels, or that
may otherwise promote environmental benefits. Further details
regarding the NatWest Group Pension Fund Trustee’s approach
to managing climate change risk can be found in its Responsible
Ownership Policy, its net zero commitment and its climate
disclosures produced on an annual basis, as required by The
Occupational Pension Schemes (Climate Change Governance and
Reporting) Regulations 2021.
Compliance and conduct risk
Definition
Compliance risk is the risk that NWM Group fails to observe the
letter and spirit of all relevant laws, codes, rules, regulations and
standards of good market practice.
Conduct risk is the risk of inappropriate behaviour towards
customers, or in the markets in which NWM Group operates,
which leads to poor or inappropriate customer outcomes.
The consequences of failing to meet compliance and/or conduct
responsibilities can be significant and could result, for example, in
legal action, regulatory enforcement, material financial loss and/or
reputational damage.
Sources of risk
Compliance and conduct risks exist across all stages of NWM
Group’s relationships with its customers and arise from a variety
of activities including product design, marketing and sales,
complaint handling, staff training, and handling of confidential
inside information.
As set out in Note 25 to the consolidated financial statements,
members of NatWest Group are party to legal proceedings and
are subject to investigation and other regulatory action in the UK,
the US and other jurisdictions.
Key developments in 2023
Further progress was made on the compliance agenda during
2023. Significant enhancements were made to the compliance
and conduct framework with the introduction of numerous
new tools to manage the risk profile. These include a
compliance and conduct risk directory, new risk standards
and toolkits which support NWM Group to measure and
manage compliance accurately and efficiently, and a
regulatory compliance operational policy framework to ensure
key regulatory requirements are captured. These new tools
align with the existing enterprise-wide risk management
framework.
From a conduct risk perspective, the NatWest Group-wide
programme established to deliver Consumer Duty
requirements met the first regulatory milestone of application
to open book products and services by July 2023. The focus is
now on closed book products and services, which is expected
to conclude before the end of July 2024.
The focus on consumer protection and supporting customers
with their financial needs continues, given the ongoing cost-of-
living challenges and their impact on customers in vulnerable
situations. Vulnerable customer outcomes are also an integral
part of our
enhanced
‘Good Customer Outcome’ reporting
which was introduced through the Consumer Duty
programme.
In December 2021, NatWest Markets Plc pled guilty to one
count of wire fraud and one count of securities fraud, related
to historical spoofing conduct by former employees in US
Treasuries markets, between 2008 and 2014 and, separately,
during approximately three months in 2018. In line with the
plea agreement with the Department of Justice, an
independent monitor was appointed in 2022. The Monitor
issued his first report in October 2023 which included
observations and recommendations. NWM is in the process of
responding to the observations and recommendations
contained in this report. Work with the DoJ monitor is
expected to last three years, but there is a possibility that it
could be extended.
Governance
NWM Group defines appropriate standards of compliance and
conduct and ensures adherence to those standards through its
risk management framework. To support ongoing oversight of the
management of the compliance and conduct risk profile there are
a number of committees in place. These include a NatWest Group
Consumer Duty Executive Steering Group and conflicts of interest
fora across both the first and second line of defence. Relevant
compliance and conduct matters are escalated through the
Executive Risk Committee and Board Risk Committee.
Risk appetite
The Risk appetite statement and associated measures for
compliance and conduct risks are approved at least annually by
the Board on the Board Risk Committee’s recommendation to
ensure they remain appropriate and aligned to strategy. Risk
appetite statements articulate the levels of risk that legal entities,
businesses and functions work within when pursuing their
strategic objectives and business plans.
A range of controls are operated to ensure the business delivers
good customer outcomes and is conducted in accordance with
legal and regulatory requirements. A suite of risk policies, risk
standards and regulatory compliance operational policies
addressing compliance and conduct risks set appropriate
standards across NWM Group including some NatWest Group
policies and procedures. Ongoing monitoring and targeted
assurance are carried out as appropriate.
Monitoring and measurement
Compliance and conduct risks are measured and managed
through ongoing assessment and regular risk reporting to NWM
Group’s senior risk committees and at Board level. The
compliance and conduct risk framework facilitates the consistent
monitoring and measurement of compliance with laws and
regulations and the delivery of consistently good customer
outcomes. The first line of defence is responsible for effective risk
identification, reporting and monitoring, with oversight, challenge
and review by the second line. Compliance and conduct risk
management is also integrated into NWM Group’s strategic
planning cycle.
Mitigation
Activity to mitigate the most material compliance and conduct
risks is carried out across NWM Group with specific areas of focus
in the customer-facing businesses and legal entities. Examples of
mitigation include consideration of customer needs in business
and product planning, targeted training, conflicts of interest
management, market conduct surveillance, complaints
management, mapping of priority regulatory requirements and
independent monitoring activity. Internal policies help support a
strong customer and market conduct focus across NWM Group.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
67
Financial crime risk
Definition
Financial crime risk is the risk that NWM
Group's products,
services, employees and/or third parties are intentionally or
unintentionally used to facilitate financial crime in the form of
money laundering, terrorist financing, bribery and corruption,
sanctions and tax evasion, as well as external or internal fraud.
Sources of risk
Financial crime risk may be present if NWM Group’s customers,
employees or third parties undertake or facilitate financial crime,
or if NWM Group’s products or services are intentionally or
unintentionally
used to facilitate such crime. Financial crime risk is
an inherent risk across all lines of business and there is a risk of
employees or external third parties conducting intentional
fraudulent activity.
Key developments in 2023
Across NatWest Group, significant investment continued to be
made to support delivery of the multi-year transformation plan
across financial crime risk management including
enhancements that were made to technology, data quality
and data analytics to improve the effectiveness of systems
used to monitor customers and transactions.
NWM Group adopted and embedded the NatWest Group
centralised hub model and One Bank approach to financial
crime risk management. This has led to better outcomes,
including a consistent understanding of controls and oversight
across NWM.
NatWest Group held financial crime roadshows and events
were held throughout the year to further embed financial
crime risk management culture and behaviours.
NWM Group supported the NatWest Group initiatives to
enhance public-private partnerships through forums such as
the Joint Money Laundering Intelligence Taskforce
Following completion of the Customer Due Diligence (CDD)
remediation programme in Q1 2023, NWM Financial Crime
moved to an In Appetite RTA – CEC2 ‘On Watch’ status in
April 2023, and formally moved to CEC2 ‘In Appetite’ status in
November 2023.
NWM Group Financial Crime completed a deep-dive on all
German entities across the Group which provided key
observations for enhancements / streamlining of processes
and resource.
Implementation of release 8 of Quantexa Fusion went live
successfully in November 2023 - this release embedded all
changes to scores which were approved over the summer
and removed the need for manual alert closures.
Governance
The Financial Crime Risk Committee (FCRC), which is chaired by
the Head of Financial Crime, is NWM Group’s second line of
defence financial crime risk oversight forum. The committee
reviews and monitors key financial crime risks providing guidance,
challenge, recommendations and decisions on issues affecting
NWM Group globally. Where appropriate, the committee escalates
material financial crime risks and issues across NWM Group to the
NWM Executive Risk Committee and NWM Group Board Risk
Committee. The committee is an escalation point for the Financial
Crime oversight committee (FCOC) which is first line owned and
the principal financial crime committee in NWM Group.
Risk appetite
There is no appetite to operate in an environment where systems
and controls do not enable the effective identification, assessment,
monitoring, management and mitigation of financial crime risk.
NatWest Group’s systems and controls must be comprehensive
and proportionate to the nature, scale and complexity of its
businesses.
NWM Group operates a framework with preventative and
detective controls designed to mitigate the risk that it could
facilitate financial crime. These controls are supported by a suite
of policies, procedures and guidance to ensure they operate
effectively.
Monitoring and measurement
Financial crime risks are identified and reported through
continuous risk management and regular reporting to NWM
Group’s senior risk committees and both the NatWest Group and
NWM Group Boards. Quantitative and qualitative data is reviewed
and assessed to measure whether financial crime risk is within
risk appetite.
Mitigation
Through the financial crime framework, relevant policies, systems,
processes and controls are used to mitigate and manage financial
crime risk. This includes the use of dedicated screening and
monitoring systems and controls to identify people, organisations,
transactions and behaviours that may require further investigation
or other actions. Centralised expertise within NatWest Group is
available to detect and disrupt threats to NWM Group and its
customers.
Intelligence is shared with law enforcement, regulators and
government bodies to strengthen national and international
defences against those who would misuse the financial system for
criminal motives.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
68
Climate risk
Definition
Climate risk is the threat of financial loss or adverse non-financial
impacts associated with climate change and the political,
economic and environmental responses to it.
Sources of risk
Physical risk
Physical risks may arise from climate and weather-related events
such as heatwaves, droughts, floods, storms and sea level rises.
They can potentially result in financial losses, impairing asset
values and the creditworthiness of borrowers. NWM Group could
be exposed to physical risks directly by the effects on its property
portfolio and, indirectly, by the impacts on the wider economy as
well as on the property and business interests of its customers.
Transition risk
Transition risks may arise from the process of adjustment towards
a low-carbon economy. Changes in policy, technology and
sentiment could prompt reassessment of customers’ financial risk
and may lead to falls in the value of a large range of assets. NWM
Group could be exposed to transition risks directly through the
costs of adaptation within economic sectors and markets as well
as supply chain disruption leading to financial impacts on it and its
customers. Potential indirect effects include the erosion of NWM
Group’s competitiveness, profitability, reputational damage and
liability risk.
Liability risk
Liability risks may arise if stakeholders consider NWM Group’s
climate risk management practises and disclosures insufficient and
responsible for, or attributable to, stakeholder losses.
NWM Group business activity
NWM Group identified a number of climate-related risks that may
affect its businesses and strategy.
Emissions resulting from NWM Group business activities include:
Financed emissions attributable to lending and investments.
Facilitated emissions attributable to underwriting activities.
Emissions attributable to the trading book (including fixed
income and currencies).
Emissions from NWM Group’s own operations
(1)
.
Estimating financed and facilitated emissions and assessing
climate impact on NWM Group’s business activities involves data
limitations and other challenges, particularly as estimation
methodologies evolve.
Financing activities
Financed emissions – lending and investments
Given the smaller size of the banking book relative to NWM
Group’s underwriting activities and trading book, financed
emissions currently play a limited role within NWM Group. Drawn
lending exposures, as defined by the Partnership for Carbon
Accounting Financials (PCAF) standard, account for
approximately 13% of NWM Group’s total assets, as at 31
December 2023. The undrawn loan commitments are currently
excluded, and therefore could potentially increase the financed
emission estimations during challenging market conditions if called
up by customers.
NWM Group exposure to heightened climate-related risk sectors
is summarised on page 62 (loans, loan commitments and
contingent obligations by sector). Due to a lack of granular
availability of customer level climate data, financial institutions are
still developing measurement methodologies and capabilities to
assess their scope three emissions. Therefore, estimated financed
emission figures linked to lending exposures will increase once
scope three emissions are incorporated.
Facilitated emissions – bond underwriting
Facilitation activities differ from on-balance sheet lending in two
respects. They are off-balance sheet (representing services rather
than financing) and they can take the form of a flow activity
(temporary association with transactions) rather than a stock
activity (recorded on the balance sheet). Refer to page 70 for the
NWM Group estimate of facilitated emissions.
Trading book
Trading book activities (which includes fixed income and
currencies) are also impacted by climate-related risks. Preliminary
analysis carried out in 2022 indicated that climate risk drivers
were not likely to put NWM Group out of appetite for market risk.
Over the course of 2023, NWM Group’s scenario analysis work
continued to build internal capability and mitigate some of the
limitations identified in previous scenario exercises. As it relates to
market risk stress testing for issuer risk, counterparty risk and
macro-parameters, NWM Group continues to be resilient to
climate driven market moves.
Due to the size of the trading book within NWM Group, the
associated carbon emissions have the potential to be significant.
However, at present, the scale of these emissions is uncertain
given that trading book positions are typically shorter term and
more dynamic than those in the banking book. This is currently an
industry-wide challenge with no agreed approach on
quantification of trading book related emissions.
Key developments in 2023
The in-house climate risk modelling capabilities were
enhanced, supporting integration of climate risk within capital
adequacy (ICAAP); impairment (IFRS 9); and other risk
management processes. More details are disclosed in the
Scenario analysis section below.
Full roll out of first-generation qualitative climate risk
scorecards.
NatWest Group, including NWM Group, began development of
a climate decisioning framework to further embed climate
within customer journeys. This includes second-generation
climate risk scorecards (enhancing quantitative considerations)
as well as a customer transition plan assessment. The initial
phased roll-out is scheduled for 2024 on a test and learn
basis.
NWM Group improved the oversight of climate-related risk
through regular reporting and review of climate risk indicators
and operational measures, to inform monthly risk committee
updates.
Scenario analysis of potential greenwashing risks was
undertaken, driven by a hypothetical risk scenario where
increased competition in the green finance market led to less
efficient product designs and diminished robustness of
governance.
Enhancements were made to NWM Group’s product
governance in line with regulatory guidance, with the inclusion
of climate and environmental, social and governance language
to improve conduct and reputational risk controls and
processes to support sustainable finance business.
Recognising the inextricable link between climate risk and
nature degradation, NatWest Group including NWM Group
added nature risk to its climate risk considerations within the
risk directory and policy, for consideration from 2024.
NWM N.V. Group is subject to European Central Bank
regulations and is required to be more advanced on
environmental risk compared to NatWest Group. In 2023,
NWM N.V. Group undertook initial environmental risk
assessments as well as implementing environmental risk
scorecards for three priority sectors.
(1)
NatWest Group report emissions at a consolidated group level. NWM Group own
operations are therefore subsumed into NatWest Group’s estimation of own operational
footprint for the consolidated group.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
69
Climate risk continued
Governance
The NWM Plc Board is responsible for monitoring and overseeing
climate-related risk within NWM Group’s overall business strategy
and risk appetite. This includes progress towards delivering on
NatWest Group’s strategy, including climate ambitions and
targets. The potential impact, likelihood and preparedness of
climate-related risk are reported regularly to NatWest Group’s
Board Risk Committee and NatWest Group Board.
The NWM Plc Board Risk Committee is responsible for the
oversight of NWM Group’s risk profile. As part of the integrated
cross-bank approach, the NWM Plc CEO, supported by the
Interim Deputy CEO, is designated to support the NatWest Group
CEO in discharging the Senior Management Function (SMF) 1
accountability for identifying and managing the risk and
opportunities from climate change. The NWM Climate &
Sustainability Committee is the senior NWM Group forum which
has the objective of assessing and managing climate-related risks
and opportunities. This forum enables the NWM Group CEO to
discharge the delegated SMF accountability, supported by the
Interim Deputy CEO.
A Climate Change Executive Steering Group is in place at
NatWest Group and is responsible for overseeing the direction of
and progress against climate-related commitments, including
activities in NWM Group. The NatWest Group Climate Centre of
Excellence supports the Climate Change Executive Steering
Group as it supervises strategic implementation and delivery,
including within NWM Group.
Risk appetite
NWM Group supports NatWest Group’s ambition to be a leading
bank in the UK, helping to address the climate challenge. This
ambition is underpinned by activity to at least halve the climate
impact of NatWest Group’s financing activity by 2030 (against a
2019 baseline) and to achieve net zero by 2050.
Work continued in 2023 to mature NatWest Group’s climate-
related risk capabilities. NWM Group operational limits have been
developed, and a suite of key risk indicators has been built out.
These measures provide management with information, including
balance sheet exposure to heightened climate risk sectors and
financed emissions.
The overall suite of metrics is used to inform climate risk reporting
to senior risk management forums, linking risk management to
NatWest Group’s strategic priorities.
Mitigation
NatWest Group including NWM Group, focused on continuing to
develop the capabilities to use scenario analysis to identify the
most material climate risks and opportunities for its customers,
seeking to harness insights to inform risk management practices,
maximise the opportunities arising from a transition to a low-
carbon economy and support decision making.
Scenario analysis
Scenario analysis allows NWM Group to test a range of possible
future climate pathways and understand the nature and
magnitude of the risks they present. The purpose of scenario
analysis is not to forecast the future but to understand and
prepare to manage risks that could arise.
NatWest Group leads the development of credit risk scenario
modelling capabilities for NatWest Group as a whole, as well as
including other legal entities within NatWest Group, such as NWM
Group. This includes both the developed capability and the
execution of scenario analysis for NWM Group.
In 2023, material enhancements to NatWest Group’s scenario
generation capability covered the maturing of sectoral and
corporate transition risk modelling capabilities as well as the
development of physical risk scenario analysis capability.
As well as capturing transition-driven risk in its ICAAP P2B and
IFRS 9 ECL measurement frameworks, NatWest Group undertook
two climate scenarios as part of a dedicated end-to-end
transition-driven exercise focused on large and mid-corporates.
The exercise provided an up-to-date view of corporate exposures
which is relevant for NatWest Markets N.V..
With NatWest Group’s transition risk capabilities reaching a steady
state during 2023, focus started to shift to commencing the
development of physical risk capabilities, with the
acknowledgement that current modelling and scenarios may not
capture the level of systemic risk or the severe long-term effects
of irreversible climate change.
There are several challenges with climate scenario analysis,
including access to climate data. NatWest Group continued to
develop its specialist climate data capabilities, including bringing in
new data sets to increase the granularity for which climate risks
are assessed. NWM Group as part of NatWest Group continues to
work with industry and customers to develop solutions.
Traded market risk
The NWM Group traded market risk stress test was updated from
a carbon intensity approach to an internal gross value add (GVA)
stress approach. The new methodology uses credit spread
adjustments derived from the GVA shocks developed by NatWest
Group, capturing both the costs and opportunities associated with
the climate transition and their impact on the trading book.
Stress exposures continue to be calculated and monitored
monthly along with other climate-related market risks, for
example, holdings of green gilts.
Liquidity risk
Within NWM Group, climate risk is included in liquidity stress
testing in the form of major climate-related disruption in the UK
and northern Europe. This leads to wide-spread disruption and a
temporary fall in economic output, with a higher demand for cash
from certain impacted business sectors due to the uncertainty.
Volatility in financial markets impacts GBP, UK bonds and asset
prices, while non-UK/European depositors re-evaluate their
exposure to the UK/European financial sector. For 2023 reporting,
climate is not the most severe scenario within the suite of
scenarios used for calculating the stressed outflow coverage ratio
disclosed on page 20.
Stress testing and ICAAP
Climate risk is explicitly considered under one of the 2023 ICAAP
scenarios. Starting with a metric for transition difficulty, the
approach differentially widens counterparty credit spreads to
reflect relative risks arising from specific sector membership (coal,
oil, gas and petroleum exposures receive the most substantial
adjustment). The approach aligns to internal traded market risk
transition risk assessments.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
70
Climate risk continued
Estimate of facilitated emissions on corporate bond
underwriting
Banks play a key role as facilitators between issuers and
investors, by offering and conducting financial intermediation
activities critical to the functioning of capital markets.
NWM Group’s capital markets underwriting activities for
corporate counterparties are generally driven by existing NatWest
Group lending relationships. Facilitated emissions will fluctuate
year-on-year subject to the underwriting mandates and changes
in those lending relationships.
Facilitated emissions included in this section relate to corporate
bond underwriting activities which equate to 21% of NWM Group’s
total bond underwriting
(1)
and results in absolute facilitated
emissions of 1.5 MtCO2e for 2023.
NWM Group used recommendations of the PCAF consultation
paper issued in September 2022
(3)
to assess facilitated emissions
included in this section. In December 2023, PCAF published an
accounting and reporting standard for facilitated emissions for
capital market instruments
(2)
. NWM Group are working to assess
the requirements of this standard for future reporting.
For 2023 reporting, the NWM Group facilitated emissions metrics
published, relate only to capital markets’ corporate bond
underwriting activities for public debt issuance
(4)
and include green
bonds as defined by the International Capital Market Association’s
Green Bond Principles or EU GBS, to show the differentiation
between conventional and green bonds as alluded to by PCAF,
while being consistent with 2022 disclosures. In estimating
facilitated emissions, NWM Group expects that green bonds have
a reduced emissions intensity. However, given that this calculation
and methodology has yet to be developed NWM Group have not
attributed a lower emission intensity. Emissions reported are
based on 100% weighting and absolute emissions versus
percentages utilised in 2022. It is important to note that the
absolute amounts presented are estimates and may be subject to
change given changing baselines over time.
The graph below shows NWM Group’s estimated facilitated emissions from corporate bond underwriting activities in 2023, as
attributed to NWM Group and split between conventional and green bond underwriting, where applicable.
The estimated facilitated emissions are
most significant in the power utilities
sector, making up 36% of the total
corporate facilitated emissions. However,
it is important to note that more than
50% are green bonds.
The second and third highest
contributing sectors are from the
chemical and building materials
industries, whilst NWM Group’s total
underwriting in these sectors was
relatively small (5% and 3% respectively).
The remaining ten sectors contributed
29% of estimated facilitated emissions
whilst representing more than half of
total corporate bond underwriting (67%).
Oil and gas was only 1% of the total
corporate bond underwriting volumes
and constituted 2% of the facilitated
emissions.
NWM Group methodology used for estimation
The PCAF consultation paper
(3)
recommended splitting the responsibility among the transaction facilitators (passive and active) based on volumes, which NWM Group sourced from
league tables. This determines the proportion of the ‘facilitated’ part of the transaction each facilitator takes responsibility for, thus providing the volume against which facilitated
emissions is estimated. Co-managers are not counted and therefore such volumes are not taken into consideration. The 2023 PCAF standard
(2)
allows the use of either league tables
based on fees or the value of the volume.
NWM Group followed both the PCAF consultation paper
(3)
and the published standard
(2)
guidance to define an issuer as solely corporates that issue a debt or equity capital markets
instruments. Financial institutions, sovereigns, supranationals and agency issuers, as well as securitised products, are out of scope both for the guidance in the consultation paper
(3)
and
the standard published by PCAF
(2)
.
In alignment with 2022 reporting, NWM Group applied a 100% weighting factor for the emissions estimation of corporate bond underwriting activities. The PCAF standard
(2)
requires a
weighting factor of 33%.
In line with the PCAF consultation paper
(3)
and the published standard
(2)
, to estimate greenhouse gas emissions, NWM Group sourced customer-level emissions data, where possible. If
customer-level data is unavailable, emission sector averages (with a PCAF data quality score of 5) are used for emission intensities from 2022 and applied against 2023 underwriting
volumes
(6)
Currently, there is not a commonly agreed methodology for measuring the carbon footprint of green bonds. NWM Group shows the breakdown of conventional versus green bonds to
highlight the expected difference of facilitated emissions associated with the conventional versus green bond underwriting. Sustainable-linked and sustainability bond activities are
treated as conventional bonds for the purpose of estimating and reporting on facilitated emissions
(5)
.
(1)
Where NWM Group is a facilitator (active or passive) as defined by the PCAF consultation paper
(3)
and published standard
(2).
(2)
https://carbonaccountingfinancials.com/files/PCAF-PartB-Facilitated-Emissions-Standard-Dec2023.pdf
(3)
September 2022 - PCAF launches public consultation on Capital Markets Facilitated Emissions methodology (carbonaccountingfinancials.com)
(4)
Includes public debt: all types of bonds issued for general purposes. Facilitated debt investments in private companies (including private credit), public equity: common stock (IPOs and follow-on
issuances) and preferred shares and facilitated equity investments in private companies (including private placements) are not included, since this is not business that NWM Group undertakes.
Syndicated loans are within the scope of PCAF’s Facilitated Emissions Standard. However, where these remain on NWM Group’s balance sheet we have included them in our financed emission
estimates and excluded them from our estimate of facilitated emissions.
(5)
NatWest Group 2023 climate and sustainable funding and financing inclusion criteria was used to determine the assets, activities and companies eligible for inclusion.
https://www.natwestgroup.com/content/dam/natwestgroup_com/natwestgroup/pdf/climate-and-sustainable-funding-and-financing-inclusion-criteria-2021-V1.3.pdf
(6)
NWM Group aims to estimate facilitated emissions using the latest data available, recognising there may be a lag between the availability of emissions data and the date of record for reporting. As a
consequence of this lag, more recent changes in a counterparties activities may not be reflected in the estimate of facilitated emissions. NWM Group continues to refine its estimates as NWM Group
enhances its understanding, calculation methodologies and data. Also, methodologies to calculate emissions for certain sectors are still under development. Based on these limitations, NWM Group
expects its estimates to change as NWM Group improves the granularity and coverage of customer climate data and develop methodologies further.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
71
Operational risk
Definition
Operational risk is the risk of loss resulting from inadequate or
failed internal processes, people and systems, or external events.
It arises from day-to-day operations and is relevant to every
aspect of the business.
Sources of risk
Operational risk may arise from a failure to manage operations,
systems, processes, transactions, and assets appropriately. This
can take the form of human error, an inability to deliver change
adequately or on time, the non-availability of technology services,
or the loss of customer data. Systems failure, theft of NatWest
Group property, information loss and the impact of natural, or
man-made, disasters – as well as the threat of cyber-attacks –
are sources of operational risk.
Operational risk can also arise from a failure to account for
changes in law or regulations or to take appropriate measures to
protect assets.
Key developments in 2023
A review of the NatWest Group Risk Directory was completed
and benchmarked against industry standard, to ensure
comprehensive coverage of all operational risks.
The operational risk policy was reviewed, refreshed, and
supported by the development of a suite of new risk
standards, operational guidance and risk toolkits to enable
effective policy application.
The enhanced risk and control self-assessment approach
continued to be rolled out and embedded with a focus on
material operational risks across key end-to-end processes.
Given the risk associated with the processing of payments,
and as such, a NatWest Group-wide programme on the
movement of funds was mobilised, which focused on
enhancing payment related controls.
Governance
The governance arrangements in place for operational risk are
aligned to the requirements set out in the Board-approved
enterprise-wide risk management framework and are consistent
with achieving safety, soundness and sustainable risk outcomes.
The Operating Committee discusses operational risk matters
relating to the control environment, NWM’s implementation of the
enterprise-wide risk management framework, risk identification
and oversight of return-to-appetite plans. Significant issues are
escalated to the Board Risk Committee.
Risk appetite
Operational risk appetite supports effective management of all
operational risks. It expresses the level and types of operational
risk NatWest Group is willing to accept to achieve its strategic
objectives and business plans. NatWest Group’s operational risk
appetite quantitative and qualitative statements encompass the
full range of operational risks faced by its legal entities,
businesses, and functions.
The Risk appetite statement and measures for operational risk
are approved at least annually by the NWM Group Board on the
NWM Group Board Risk Committee’s recommendation to ensure
they remain appropriate and aligned to strategy.
Mitigation
Risks are mitigated by applying key preventative and detective
controls. This is an integral step in the risk self-assessment
methodology which determines residual risk exposure. Control
owners are accountable for the design, execution, performance,
and maintenance of key controls. Key controls are regularly
assessed for adequacy and tested for effectiveness. The results
are monitored and, where a material change in performance is
identified, the associated risk is re-evaluated.
All residual risks that exceed the target appetite position are
subject to action plans to bring them within appetite.
The Control Environment Certification (CEC) process is a half-
yearly self-assessment by the CEOs of NatWest Group’s
customer-facing business areas, as well as the heads of its
support functions. NatWest Group uses this process as an
effective means to provide a consistent and comparable view on
the adequacy and effectiveness of the internal control
environment.
CEC covers material risks and the underlying key controls,
including financial, operational and compliance controls, as well
as their supporting risk management frameworks. The CEC
outcomes and progress on control environment improvements,
are reported to Board Risk Committee. They are also shared
with internal and external auditors.
The CEC process helps to ensure compliance with the NatWest
Group Policy Framework, Sarbanes-Oxley 404 requirements
concerning internal control over financial reporting, and certain
requirements of the UK Corporate Governance Code.
Monitoring and measurement
Operational risk is measured and managed through continuous
assessment and regular reporting to NWM Group’s senior risk
committees and at Board-level.
Risk and control self-assessments are used across all business
areas and support functions to identify and assess material
operational risks, conduct risks and key controls. All risks and
controls are mapped to NatWest Group’s Risk Directory. Risk
assessments are refreshed at an appropriate frequency and
dynamically in response to internal and external events via a
triggers process to ensure they remain relevant and that they
capture any emerging risks.
The process is designed to confirm that risks are effectively
managed in line with risk appetite. Key controls are tested at the
appropriate frequency to verify that they remain fit-for-purpose
and operate effectively to reduce the identified risks.
NWM Group uses the standardised approach to calculate its Pillar
1 operational risk capital requirement. This is based on
multiplying three years’ average historical gross income by
coefficients set by the regulator based on business line.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
72
Operational risk continued
As part of the wider Internal Capital Adequacy Assessment
Process an operational risk economic capital model is used to
assess Pillar 2A, which is a risk-sensitive add-on to Pillar 1. The
model uses historical loss data (internal and external) and
forward-looking scenario analysis to provide a risk-sensitive view
of NWM’s Pillar 2A capital requirement.
Scenario analysis is used to assess how severe but plausible
operational risks will affect NWM Group. It provides a forward-
looking basis for evaluating and managing operational risk
exposures.
Refer to the Capital, liquidity and funding risk section for the
operational risk capital requirement figures.
Operational resilience and security
NWM Group manages and monitors operational resilience
through its enhanced risk and control self-assessment
methodology. This is underpinned by setting and monitoring of
forward-looking risk indicators and performance metrics for the
operational resilience of important business services. Progress
continues on meeting regulatory expectations for operational
resilience, with involvement in a number of industry-wide
operational resilience forums. This enables a cross-sector view of
the operational resilience risk profile and the pace of ongoing
innovation and change, both internally and externally.
Event and loss data management
The operational risk event and loss data management process
ensures NWM Group captures and records operational risk
financial and non-financial events that meet defined criteria. Loss
data is used for regulatory and industry reporting and is included
in capital modelling when calculating economic capital for
operational risk. The most serious events are escalated in a
simple, standardised process to all senior management, by way
of an early event escalation process. NWM Group has not
experienced a cyber security breach or associated material loss
in the last three years.
All financial impacts and recoveries associated with an
operational risk event are reported against the date they were
recorded in NatWest Group’s financial accounts. A single event
can result in multiple losses (or recoveries) that may take time to
crystallise. Losses and recoveries with a financial accounting date
in 2023 may relate to events that occurred, or were identified in,
prior years. NatWest Group purchases insurance, against specific
losses, including cyber-attacks, and to comply with statutory or
contractual requirements.
Model risk
Definition
Model risk is the potential for adverse consequences from model
errors or the inappropriate use of modelled outputs to inform
business decisions. A model is defined as a quantitative method,
system, or approach that applies statistical, economic, financial,
accounting, mathematical or data science theories, techniques
and assumptions to process input data into estimates.
Sources of risk
NWM Group uses a variety of models in the course of its business
activities. Examples include the use of model outputs to support
measuring and assessing risk exposures (including credit and
market risk), valuation of positions, calculating regulatory capital
and liquidity requirements and automation of operational
processes. The models used for stress-testing purposes also play
a key role in ensuring NWM Group holds sufficient capital, even in
stressed market scenarios.
Model applications may give rise to different risks depending on
the business segment in which they are used. Model risk is
therefore assessed separately for each business segment in
addition to the overall assessment made for NWM Group.
Key developments in 2023
Following extensive model remediation work, NWM Group
returned to being within model risk appetite in April 2023.
Ongoing remediation work continues to be a key focus to
further strengthen the model risk appetite position and is
closely monitored.
NWM Group’s model risk management practices continued to
evolve, supported by a dedicated model risk management
enhancement programme, set up in response to the PRA’s
Supervisory Statement 1/23. An updated Group model risk
policy was approved by the NatWest Group Board Risk
Committee.
Implementation of model risk procedures, aligned to the
delivery and embedding of the enterprise-wide risk
management framework, continued. This was supported by
significant model inventory design enhancements and a bank-
wide model risk data remediation exercise. This activity
improved the quality and completeness of model risk data
held within the model inventory system and enabled
enhanced insights and reporting capabilities.
Governance
A governance framework is in place to ensure policies and
processes relating to models are appropriate and effective. Two
roles are key to this – model risk owners and model validation
leads. Model risk owners are responsible for model approval and
ongoing performance monitoring. Model validation leads, in the
second line, are responsible for oversight, including ensuring that
models are independently validated prior to use and on an
ongoing basis aligned to the model’s risk rating.
The NWM Group model management committee is used to
escalate model risk matters to senior management where
required.
The committee also supports model risk owners in their
approvals of models for use. Models used for regulatory reporting
may additionally require regulatory approval before
implementation. Further escalation can also be made to the
NatWest Group Model Risk Oversight Committee. The NatWest
Group Model Risk Oversight committee further enhances model
risk governance by providing a platform for executive level
discussion on emerging risks, identification of systemic risks and
the evolution of model risk management practices. NWM Group is
considered in scope of the NatWest Group Model Risk Oversight
committee.
Risk appetite
Model risk appetite is set in order to limit the level of model risk
that NWM Group is willing to accept in the course of its business
activities. NWM Group risk appetite and associated measures are
approved by the NWM Group Board on recommendation of the
Board Risk Committee at least annually and aligns to the
NatWest Group’s model risk appetite statement. The first line is
responsible for monitoring performance against appetite,
reporting on the model population and remediating models
outside appetite.
Monitoring and measurement
Model risk is measured and managed through continuous
assessment and regular reporting to NatWest Group’s senior risk
committees and at Board level.
Policies, toolkits and model standards related to the development,
validation, approval, implementation, use and ongoing monitoring
of models are in place to ensure adequate control across the
lifecycle of an individual model.
Risk and capital management continued
NWM Group
Annual Report and Accounts 2023
73
Model risk continued
Validation of material models is conducted by an independent risk
function comprising of skilled, well-informed subject matter
experts. This is completed for new models or material
amendments to existing models and as part of an ongoing
periodic programme to assess model performance. The
frequency of periodic validation is aligned to the risk rating of the
model. The independent validation focuses on a variety of model
features, including modelling approach, the nature of the
assumptions used, the model’s predictive ability and complexity,
the data used in the model, its implementation and its compliance
with regulation.
The level of risk relating to an individual model is assessed
through a model risk rating. A quantitative approach is used to
determine the risk rating of each model based on the model’s
materiality and validation rating. This approach provides the basis
for model risk appetite measures and enables model risk to be
robustly monitored and managed across NWM Group.
Ongoing performance monitoring is conducted by model owners
and overseen by the model validators to ensure parameter
estimates and model constructs remain fit for purpose, model
assumptions remain valid and that models are being used
consistently with their intended purpose. This allows timely action
to be taken to remediate poor model performance and/or any
control gaps or weaknesses.
Mitigation
By their nature – as approximations of reality –
model risk is
inherent in the use of models. It is managed by refining or
redeveloping models where appropriate – either due to changes
in market conditions, business assumptions or processes – and
by applying adjustments to model outputs (either quantitative or
based on expert opinion). Enhancements may also be made to
the process within which the model output is used in order to
further limit risk levels.
Reputational risk
Definition
Reputational risk is defined as the risk of damage to stakeholder
trust due to negative consequences arising from internal actions
or external events.
Sources of risk
The three primary drivers of reputational risk are: failure in
internal risk management systems, processes or culture; NWM
Group’s actions materially conflicting with stakeholder
expectations; and contagion (when NWM Group’s reputation is
damaged by failures in key sectors including the Group’s supply
chain or other partnerships.)
Key developments in 2023
Reputational risks were elevated in relation to the departure
of Alison Rose as NatWest Group Chief Executive Officer and
issues that had arisen in connection with account closure
decisions that attracted significant public and media attention.
Relevant updates to the Reputational Risk Framework are
being implemented following an independent legal review of
customer account closures and internal reviews.
Reputational risk registers are in place across all
relevant
business areas.
New environmental, social and ethical (ESE) risk acceptance
criteria were created to support the management of human
rights risk and will be implemented in 2024.
All climate focused ESE risk acceptance criteria (mining and
metals, power generation and oil and gas) underwent a
review to ensure they reflect the current risk landscape.
Governance
A reputational risk policy supports reputational risk management
across NWM Group. Reputational risk registers are used to
manage reputational risks identified within relevant business
areas. These are reported to the relevant NatWest Markets
business risk committee.
Material reputational risks to NWM Group are escalated via the
NatWest Group reputational risk register which is reported at
every meeting of the NatWest Group Reputational Risk
Committee.
The NatWest Group Reputational Risk Committee
also opines on matters that represent material reputational risks.
The NatWest Group Executive and Board Risk Committees
oversee the identification and reporting of reputational risk via
the NatWest group Risk Report.
Risk appetite
NWM Group manages and articulates its appetite for reputational
risk through a qualitative reputational risk appetite statement and
associated quantitative measures which are set at NatWest
Group level.
NWM Group seeks to identify, measure and manage risk aligned
to stakeholder trust. However, reputational risk is inherent in
NWM Group’s operating environment and public trust is a specific
factor in setting reputational risk appetite.
Monitoring and measurement
Relevant internal and external factors are monitored through
regular reporting via reputational risk registers at NatWest
Markets business or legal entity level. They are escalated, where
appropriate, to the relevant NatWest Markets executive
committee and where material, to the NatWest Group
Reputational Risk Committee.
Additional key risk indicators for material risks being monitored
are also reported to Group Reputational Risk Committee and to
the Executive and Board Risk Committees via the NatWest Group
Risk Report.
Mitigation
Standards of conduct are in place across NWM Group requiring
strict adherence to policies, procedures and ways of working to
ensure business is transacted in a way that meets – or exceeds –
stakeholder expectations.
External events that could cause reputational damage are
identified and mitigated through NWM Group’s top and emerging
threats process (where sufficiently material) as well as through
the NatWest Group and business level reputational risk registers.
NatWest Group has in recent years been the subject of
investigations and reviews by a number of regulators and
governmental authorities, some of which have resulted in past
fines, settlements and public censure. Refer to the Litigation and
regulatory matters section of Note 25 to the consolidated
financial statements for details of material matters currently
affecting NatWest Markets.
Report of the directors
NWM Group
Annual Report and Accounts 2023
74
The directors present their report together with the audited
accounts for the year ended 31 December 2023.
Other information incorporated into this report by reference can
be found at:
Page
Financial review
20
Board of directors and secretary
23
Share capital and reserves
147
Post balance sheet events
161
Risk factors
165
Group structure
NatWest Markets Plc (‘NWM Plc’) is a wholly-owned subsidiary of
NatWest Group plc (‘NWG plc’ or ‘the ultimate holding company’).
The NatWest Markets Group (‘NWM Group’) comprises NWM Plc
and its subsidiary and associated undertakings. The term
‘NatWest Group’ comprises NatWest Group plc and its
subsidiaries. NatWest Group plc is incorporated in the UK and
has its registered office at 36 St Andrew Square, Edinburgh, EH2
2YB.
Details of NWM Plc’s principal subsidiary undertakings and their
activities are shown in Note 16 to the consolidated financial
statements. A full list of related undertakings of NWM Plc is
shown in Note 34 to the consolidated financial statements.
The financial statements of NWG plc can be obtained from
NatWest Group Legal, Governance and Regulatory Affairs,
Gogarburn, Edinburgh, EH12 1HQ, the Registrar of Companies or
at natwestgroup.com.
Activities
NWM Group offers debt financing, risk management and trading
solutions to customers.
Results and dividends
The loss attributable to the ordinary shareholders of NWM Group
for the year ended 31 December 2023 was £168 million
compared with a loss of £335 million for the year ended 31
December 2022. as set out in the consolidated income statement
on page 90.
No dividends were paid to NatWest Group plc during the year.
Employees
At 31 December 2023, NWM Group employed 1,700 people
(excluding temporary staff). Details of all related costs are
included in Note 3 to the consolidated financial statements
.
Corporate Governance statement
For the financial year ended 31 December 2023, the company
has chosen to report against the Wates Corporate Governance
Principles for Large Companies (the Wates Principles) and the
disclosures below explain how the company has applied the
Wates Principles in the context of its corporate governance
arrangements.
1. Purpose and leadership
Strategy
NatWest Group’s strategy is set and approved by the NatWest
Group plc Board. The NWM Plc Board (‘the Board’) reviews and
sets the strategic direction of NWM Plc and, as appropriate, the
strategies for each of its businesses within the parameters set by
the NatWest Group plc Board. It subsequently oversees the
execution of the strategy and holds management to account for
its delivery.
Further information on NatWest Group’s progress against its
strategy can be found in the NatWest Group plc 2023 Annual
Report and Accounts.
Culture
The NatWest Group plc Board is supported in monitoring culture
across NatWest Group by the Group Sustainable Banking
Committee and the Group Board Risk Committee. NatWest
Group is on a journey towards a generative risk culture whereby
risk is simply part of the way people work and think.
Building a healthy culture that embodies Our Values is a core
priority for NatWest Group.
Our Values, which guide the way NatWest Group identifies the
right people to serve customers well, and how to manage,
engage and reward colleagues, are at the heart of Our Code (the
NatWest Group-wide Code of Conduct).
There is regular reporting to the Board on culture, so as to
provide appropriate oversight of culture matters. More
specifically, with regards to risk culture, continued progress has
been made towards addressing historical conduct issues,
including risk appetite enhancements and increased monitoring of
conduct risk and surveillance remediation. This supports our
ambition to create a positive culture and strengthen ‘good
conduct’ outcomes for clients.
2. Board Composition
The Board
The Board has seven directors comprising: the Chairman, two
executive directors (being the Chief Executive Officer and Chief
Financial Officer) and four independent non-executive directors.
The size of the Board is considered appropriate, taking into
account the size and scale of NWM Plc’s business.
The Chairman
The role of the Chairman is to lead the Board and ensure its
overall effectiveness. This is distinct and separate from that of
the Chief Executive Officer who manages the business day-to-
day. The Chairman is also a member of the NWG plc Board
which provides an appropriate linkage to the wider NatWest
Group and ensures alignment and awareness in respect of
NatWest Group-wide matters.
Non-Executive Directors
The majority of the Board comprises independent non-executive
Directors. Their role is to challenge and scrutinise the
performance of management and to help develop proposals on
strategy. They also review the performance of management in
meeting agreed goals and objectives and monitor the firm’s risk
profile. The non-executive directors combine broad business and
commercial expertise and bring experience from a wealth of
areas including audit, banking, finance, human resources,
technology, and telecommunications.
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Annual Report and Accounts 2023
75
The Board periodically undertakes an independence assessment
of the non-executive directors. With the exception of the
Chairman, who is a member of the NatWest Group plc Board, all
non-executive directors are considered to be independent and
there are no relationships or circumstances that are likely to
affect their judgement.
Induction Training
All new directors undergo a formal induction programme upon
joining the Board which is coordinated by the Company
Secretary and tailored to their individual needs. This includes
meetings with other directors, senior executives and business
heads. Meetings with the external auditor, legal counsel and
other key stakeholders are arranged as appropriate. Directors
also receive comprehensive guidance from the Company
Secretary on NWM Plc’s corporate governance framework and
associated policies, including their duties as directors.
Continuous Development
Non-executive directors discuss their professional development
annually with the Chairman. Directors maintain their knowledge
and familiarity with NWM Plc through regular meetings with
senior management (including representatives of NatWest Group)
and participate in scheduled Board training and other external
sessions as appropriate.
During 2023, teach-in sessions on climate, Capital Markets,
Trading and Technology amongst others were arranged for the
directors. Directors may also request individual in-depth briefings
from time to time on areas of particular interest.
Board Diversity
The Board is committed to promoting diversity and inclusion in
the boardroom and aims to meet industry targets and
recommendations wherever possible. The Board has a
Boardroom Inclusion Policy which aims to promote diversity and
inclusion in the composition of the Board of Directors and in the
nomination and appointment process. The Policy reflects the
values of the wider NatWest Group, its Inclusion Policy and
relevant legal, regulatory or best practice requirements.
Committees
The responsibilities of the Board are executed, in part, through its
committees (namely, the Audit Committee, the Board Risk
Committee, the Performance and Remuneration Committee and
the Nominations and Governance Committee). All matters that
the Board has specifically delegated to these committees are set
out in their terms of reference (ToRs). All other matters, including
responsibility for the day-to-day operation of NWM Plc (that are
not specifically reserved for the Board or delegated to a
committee) are delegated to the NWM Plc Chief Executive Officer
(CEO) in accordance with such policies and directions as the
Board determines appropriate, including the NWM Plc CEO’s role
profile.
Succession
The Board is responsible for ensuring that NWM Plc has in place
succession plans for the Board and senior management so as to
maintain an appropriate balance of skills and experience. The
NatWest Group Nominations and Governance Committee is also
required to approve all appointments to the Board, reflecting the
company’s position as a subsidiary of NatWest Group.
Board Effectiveness
The effectiveness of the Board, including the Chairman, individual
directors and committees, is assessed periodically. The Board
considers such assessments to play an important role in the
identification of areas for further improvement, focus and for
strengthening its overall performance.
The Company Secretary
In fulfilling its role, the Board is supported by the Company
Secretary. The Company Secretary is responsible for ensuring
good information flows between the Board and its committees
and between senior management and non-executive directors,
as well as facilitating induction and assisting with professional
development of non-executive directors, as required. The
directors may also seek independent, professional advice, where
necessary, at NWM Plc’s expense.
3. Director Responsibilities
Policy & Framework
NatWest Group has in place a Corporate Governance
Framework, including a Corporate Governance Policy. All
directors of NWM Plc are required to ensure that they are
familiar with the Corporate Governance Framework and that
NWM Plc complies with it. NWM Plc also produces and maintains
a document called ‘Our Governance’ which sets out the high-
level governance framework for NWM Plc at both regional and
global levels.
The Board has a programme of six scheduled meetings every
year. The Board ToRs include a formal schedule of matters
specifically reserved for the Board which are reviewed at least
annually. Each director has a role profile which clearly articulates
their responsibilities and accountabilities. Similarly, any additional
regulatory responsibilities and accountabilities where any of the
directors undertake a Senior Manager Function (as defined under
the Prudential Regulation Authority’s and Financial Conduct
Authority’s ‘Senior Manager Regimes’) are set out in their
Statement of Responsibilities.
To support them in the discharge of their duties, all directors
receive regular and timely information on all key aspects of the
business including financial performance, strategy, key risks, and
market conditions.
Conflicts of Interest
The Board follows NatWest Group’s guidance relating to
directors’ conflicts of interest.
The Board has the power to authorise any actual or potential
conflicts of interest in accordance with the Companies Act 2006
and NWM Plc’s Articles of Association. The company maintains a
register of directors’ interests and appointments and there is
discussion of directors’ conflicts in Board meetings, as required.
During the year, none of the directors declared any material
interest, directly or indirectly, in any contract of significance with
any company within NatWest Group.
All directors were reminded of their obligations in respect of
transacting in NWM Plc securities (Personal Account Dealing) and
all directors have confirmed that they have complied with their
obligations.
Report of the directors continued
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Annual Report and Accounts 2023
76
Board Committees
In order to provide effective oversight and leadership, the Board
has established a number of committees with particular
responsibilities:
The Audit Committee
comprises at least two independent non-
executive directors, one of whom is the Chair of the Board Risk
Committee. The Committee assists the Board in discharging its
responsibilities for monitoring the integrity of the financial
statements. It reviews the accounting policies, financial reporting
and regulatory compliance practices of NWM Plc, its system and
standards of internal controls, and monitors the processes for
internal audit and external audit.
The Board Risk Committee
comprises at least two independent
non-executive directors, one of whom is the Chair of the Audit
Committee and one of whom is a member of the NWM RemCo.
The Committee provides oversight and advice to the Board in
relation to current and potential future risk exposures and future
risk profile, including determination of risk appetite, the
effectiveness of the risk management framework and (in
conjunction with the Audit Committee) internal controls required
to manage risk. The Committee also reviews compliance with
NatWest Group Policy Framework and reviews the performance
of NWM Plc relative to risk appetite.
The Performance and Remuneration Committee (RemCo)
comprises at least four independent non-executive directors and
oversees the implementation of the Group-wide Remuneration
Policy within NWM. It also considers and makes
recommendations on remuneration arrangements for senior
executives of NWM Plc.
The Nominations and Governance Committee
comprises the
Chair and at least two other independent non-executive
directors. It is responsible for assisting the Board in the formal
selection and appointment of directors. It reviews the structure,
size and composition of the Board and membership and chairship
of Board committees.
4. Opportunity and risk
The role of the Board is to promote the long-term success of
NWM Plc and the delivery of sustainable value to its shareholder.
The Board reviews and approves risk appetite for strategic and
material risks in accordance with NatWest Group’s risk appetite
framework; monitors performance against risk appetite for NWM
Plc; and considers any material risks and approves (as
appropriate) recommended actions escalated by the NWM Plc
Board Risk Committee.
NWM Plc’s risk strategy is informed and shaped by an
understanding of the risk landscape including a range of
significant risks and uncertainties in the external economic,
political and regulatory environments.
NWM Plc complies with NatWest Group’s risk appetite
framework, which is approved annually by the NWG plc Board, in
line with NatWest Group’s risk appetite statements, frameworks
and policies. NatWest Group risk appetite is set in line with overall
strategy.
NatWest Group operates an integrated risk management
framework, which is centred on the embedding of a strong risk
culture. The framework ensures the tools and capability are in
place to facilitate sound risk management and decision-making
across the organisation.
NWM Plc also complies with the NatWest Group Policy
Framework, the purpose of which is to ensure that NatWest
Group establishes and maintains NatWest Group-wide policies
that adequately address the risks inherent in its business
activities.
Further information on NWM Plc’s risk management framework
including risk culture, risk governance, risk appetite, risk controls
and limits, and risk identification and measurement can be found
in the Risk overview section of this report.
5. Remuneration
The NatWest Group Remuneration Policy provides a consistent
policy across all NatWest Group companies and ensures
compliance with regulatory requirements. The remuneration
policy is aligned with the business strategy, objectives, values and
long-term interests of the company. The policy supports a culture
where individuals are rewarded for delivering sustained
performance in line with risk appetite and for demonstrating the
right conduct and behaviours.
The Performance and Remuneration Committee (RemCo)
reviews remuneration for executives of the company and
considers reports on the wider workforce including annual pay
outcomes and diversity information. The RemCo helps to ensure
that the remuneration policies, procedures and practices being
applied are appropriate at NWM Plc level.
Executive remuneration structures incentivise individuals to
deliver sustainable performance based on strategic objectives for
NatWest Group and the relevant business area. Performance is
assessed against a balanced scorecard of financial and non-
financial measures and variable pay is subject to deferral as well
as malus and clawback provisions to ensure rewards are justified
in the long-term.
The approach to performance management provides clarity for
colleagues on how their contribution links to NatWest Group’s
purpose and colleagues are set goals across a balanced
scorecard of financial and non-financial measures. NatWest
Group continues to pay colleagues fairly for the work they do
supported by simple and transparent pay structures in line with
industry best practices. This clarity and certainty on how pay is
delivered is also helping to improve employees’ financial
wellbeing, which is a core priority in NatWest Group’s wellbeing
plans. Following on from extensive support provided in 2022 to
help our colleagues with the cost of living, NatWest Group
continued targeted action in 2023 to help those colleagues most
likely to be affected by the sudden spike in inflation. In the UK,
NatWest Group’s rates of pay continue to exceed the Living
Wage Foundation benchmarks and NatWest Group ensure
employees performing the same role are paid fairly.
NatWest Group ensures colleagues have a common awareness
of the financial and economic factors affecting its performance
through quarterly ‘Results Explained’ communications and
Workplace Live events with the Group Chief Executive Officer
and Chief Financial Officer.
Further information on the remuneration policy, pay ratios and
employee share plans can be found in the Directors’
remuneration report (DRR) of the NatWest Group plc 2023
Annual Report and Account. Gender and Ethnicity Pay Gap
information can be found in the Strategic report section of the
NatWest Group plc 2023 Annual Report and Accounts along with
the steps being taken to build an inclusive and engaged
workforce.
Report of the directors continued
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Annual Report and Accounts 2023
77
6. Stakeholder relationships and engagement
NWM Plc is committed to managing the wider social,
environmental and economic impacts of its operations which
includes the way it deals with its customers and manages the
sustainability of its supply chain.
The Board recognises the importance of engaging with
stakeholders and discussions at Board meetings are focused
around the impact that NWM Plc’s activities may have on key
stakeholder groups. The Board reporting style has a specific
section focussing on the stakeholder impacts to support decision-
making.
For further details on the Board’s engagement with employees,
customers, suppliers and others, and how these stakeholders’
interests have influenced one of the Board’s principal decisions,
refer to pages 17 to 18 of the Strategic report.
Internal control over financial reporting
The internal controls over financial reporting for NWM Group are
consistent with those at NatWest Group level. NWM Group has
designed and assessed the effectiveness of its internal control
over financial reporting as of 31 December 2023 based on the
criteria set forth by the Committee of Sponsoring Organizations
of the Treadway Commission in the 2013 publication of ‘Internal
Control – Integrated Framework’. As part of the assessment,
management have considered the additional activities required
for its internal control over financial reporting during the year,
such as oversight on controls performed on NWM Group’s behalf,
to better reflect the size, scale and overall materiality of the
business profile compared to the NatWest Group framework. Any
deficiencies identified are reported to NWM Group Audit
Committee along with management’s remediation plans.
Directors’ interests
Where directors of NWM Plc are also directors of NWG plc, their
interests in the shares of the ultimate holding company at 31
December 2023 are shown in the Annual report on remuneration
section of the NatWest Group plc 2023 Annual Report and
Accounts.
None of the directors held an interest in the loan capital of the
ultimate holding company or in the shares or loan capital of NWM
Plc or any of its subsidiaries, during the period from 1 January
2023 to 15 February 2024.
Directors' indemnities
In terms of section 236 of the Companies Act 2006 (the
‘Companies Act’), Qualifying Third Party Indemnity Provisions
have been issued by the ultimate holding company to NWM Plc
directors, individuals authorised by the PRA/FCA and certain
directors and/or officers of NatWest Group’s subsidiaries and all
trustees of NatWest Group pension schemes.
Going concern
NWM Plc’s business activities and financial position, the factors
likely to affect its future development and performance and its
objectives and policies in managing the financial risks to which it
is exposed, and its capital are discussed in the Financial review.
The risk factors which could materially affect NWM Plc’s future
results are set out on pages 165 to 186. NWM Plc’s regulatory
capital resources and significant developments in 2023, and
anticipated future developments are detailed in the Capital,
liquidity and funding section on pages 39 to 44. This section also
describes NWM Plc’s funding and liquidity profile, including
changes in key metrics and the build-up of liquidity reserves.
Having reviewed NWM Plc’s principal risks, forecasts, projections
and other relevant evidence, the directors have a reasonable
expectation that NWM Plc will continue in operational existence
for a period of 12 months from the date of this report.
Accordingly, the financial statements of NWM Plc have been
prepared on a going concern basis.
Political donations
During 2023, no political donations were made in the UK or EU,
nor any political expenditure incurred in the UK or EU.
Directors’ disclosure to auditors
Each of the directors at the date of approval of this report
confirms that:
(a)
so far as the director is aware, there is no relevant audit
information of which NWM Plc’s auditors are unaware; and
(b)
the director has taken all the steps that they ought to have
taken as a director to make himself/herself aware of any
relevant audit information and to establish that NWM Plc’s
auditors are aware of that information.
This confirmation is given and should be interpreted in
accordance with the provisions of section 418 of the Companies
Act.
Auditors
Ernst & Young LLP (EY LLP) are the auditors and have indicated
their willingness to continue in office. A resolution to re-appoint
EY LLP as NWM Plc’s auditors will be proposed at the
forthcoming NatWest Group Annual General Meeting.
By order of the Board
Sarah Beddows
Company Secretary
15 February 2024
NatWest Markets Plc
is registered in Scotland No. SC090312
Statement of directors’ responsibilities
NWM Group
Annual Report and Accounts 2023
78
This statement should be read in conjunction with the responsibilities of the auditor set out in their report on pages 80 to 89.
The directors are responsible for the preparation of the Annual Report and Accounts. The directors are required to prepare Group
financial statements, and as permitted by the Companies Act 2006 have elected to prepare company financial statements, for each
financial year in accordance with UK adopted International Accounting Standards, International Financial Reporting Standards (IFRS) as
issued by the International Accounting Standards Board and IFRS as adopted by the European Union. They are responsible for
preparing financial statements that present fairly the financial position, financial performance and cash flows of NWM Group and NWM
Plc. In preparing those financial statements, the directors are required to:
select suitable accounting policies and then apply them consistently;
make judgements and estimates that are reasonable, relevant and reliable; and
state whether applicable accounting standards have been followed, subject to any material departures disclosed and explained in the
financial statements.
prepare the financial statements on a going concern basis unless it is inappropriate to presume that the company and Group will continue
in business
The directors are responsible for keeping proper accounting records which disclose with reasonable accuracy at any time the financial
position of NWM Group and to enable them to ensure that the Annual Report and Accounts complies with the Companies Act 2006.
They are also responsible for safeguarding the assets of NWM Plc and NWM Group and hence for taking reasonable steps for the
prevention and detection of fraud and other irregularities.
Under applicable law and regulations, the directors are also responsible for preparing a Strategic report and Report of the directors,
that comply with that law and those regulations. The directors are responsible for the maintenance and integrity of the corporate and
financial information included on the company’s website.
The directors confirm that to the best of their knowledge:
the financial statements, prepared in accordance with UK adopted International Accounting Standards, IFRS as issued by the International
Accounting Standards Board and IFRS as adopted by the European Union, give a true and fair view of the assets, liabilities, financial
position and profit or loss of NWM Plc and the undertakings included in the consolidation taken as a whole; and
the Strategic report and Report of the directors (incorporating the Financial review) includes a fair review of the development and
performance of the business and the position of NWM Plc and the undertakings included in the consolidation taken as a whole, together
with a description of the principal risks and uncertainties that they face.
By order of the Board
Frank Dangeard
Robert Begbie
Simon Lowe
Chairman
Chief Executive Officer
Chief Financial Officer
15 February 2024
Board of directors
Chairman
Executive directors
Non-executive directors
Frank Dangeard
Robert Begbie
Simon Lowe
Vivek Ahuja
Tamsin Rowe
Anne Simpson
Sabrina Wilson
Financial statements
NWM Group
Annual Report and Accounts 2023
79
Contents
Page
Independent auditor’s report
80
Consolidated income statement
90
Consolidated statement of comprehensive income
90
Balance sheet
91
Statement of changes in equity
92
Cash flow statement
93
Accounting policies
94
Notes to the accounts
1
Net interest income
100
2
Non-interest income
100
3
Operating expenses
101
4
Geographical segment analysis
102
5
Pensions
103
6
Auditor’s remuneration
107
7
Tax
107
8
Profit/loss dealt with in the accounts of NWM Plc
109
9
Financial instruments - classification
110
10
Financial instruments - valuation
114
11
Financial instruments - maturity analysis
127
12
Trading assets and liabilities
131
13
Derivatives
132
14
Loan impairment provisions
142
15
Other financial assets
143
16
Investment in group undertakings
144
17
Other assets
144
18
Other financial liabilities
144
19
Subordinated liabilities
145
20
Other liabilities
146
21
Share capital and reserves
147
22
Structured entities
148
23
Asset transfers
149
24
Capital resources
150
25
Memorandum items
151
26
Non-cash and other items
156
27
Analysis of changes in financing during the year
157
28
Analysis of cash and cash equivalents
157
29
Directors’ and key management remuneration
158
30
Transactions with directors and key management
158
31
Related parties
159
32
Ultimate holding company
161
33
Post balance sheet events
161
34
Related undertakings
162
Independent auditor’s report to the members of NatWest
Markets Plc
NWM Group
Annual Report and Accounts 2023
80
Opinion
In our opinion:
The financial statements of NatWest Markets Plc (the ‘Bank’) and its subsidiaries (together, the ‘Group’) give a true and fair view
of the state of the Group’s and of the Bank’s affairs as at 31 December 2023 and of the Group’s loss for the year then ended;
The Group financial statements have been properly prepared in accordance with UK adopted international accounting standards
(‘IAS’) and International Financial Reporting Standards (‘IFRS’) as adopted by the European Union and IFRS as issued by the
International Accounting Standards Board (‘IASB’);
The Bank’s financial statements have been properly prepared in accordance with UK adopted international accounting standards
as applied in accordance with section 408 of the Companies Act 2006; and IFRS as issued by the IASB; and
The financial statements of the Group have been prepared in accordance with the requirements of the Companies Act 2006.
We have audited the financial statements (see table below) of the Group and the Bank for the year ended 31 December 2023 which
comprise:
Group
Bank
Consolidated balance sheet as at 31 December 2023;
Consolidated income statement for the year then ended;
Consolidated statement of comprehensive income for the
year then ended;
Consolidated statement of changes in equity for the year
then ended;
Consolidated cash flow statement for the year then
ended;
Accounting Policies;
Related Notes 1 to 34 to the financial statements; and
Risk and capital management sections identified as
‘audited’.
Balance sheet as at 31 December 2023;
Statement of changes in equity for the year
then ended;
Cash flow statement for the year then
ended; and
Related Notes 1 to 34 to the financial
statements.
The financial reporting framework that has been applied in their preparation is applicable law and UK adopted international accounting
standards and as regards to the Group financial statements, IFRS as adopted by the European Union and IFRS as issued by the IASB,
and as regards the Bank’s financial statements, as applied in accordance with section 408 of the Companies Act 2006.
Basis for opinion
We conducted our audit in accordance with International Standards on Auditing (UK) (ISAs (UK)) and applicable law. Our responsibilities
under those standards are further described in the Auditor’s responsibilities for the audit of the financial statements section of our
report. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
Independence
We are independent of the Group and the Bank in accordance with the ethical requirements that are relevant to our audit of the
financial statements in the UK, including the FRC’s Ethical Standard as applied to listed public interest entities, and we have fulfilled our
other ethical responsibilities in accordance with these requirements.
The non-audit services prohibited by the FRC’s Ethical Standard were not provided to the Group or the Bank and we remain
independent of the Group and the Bank in conducting the audit.
Conclusions relating to going concern
In auditing the financial statements, we have concluded that the directors’ use of the going concern basis of accounting in the
preparation of the financial statements is appropriate. Our evaluation of the directors’ assessment of the Group and Bank’s ability to
continue to adopt the going concern basis of accounting included:
In conjunction with our walkthrough of the Group’s financial close process, we confirmed our understanding of the directors’ going
concern assessment process. We engaged with management to determine if key factors were considered in the assessment.
We evaluated the directors’ going concern assessment which included reviewing their evaluation of business and strategic plans on
future capital adequacy, liquidity and funding positions of the Group and Bank. The assessment of these positions considered the
results of internal stress tests, including the consideration of credit risk, market risk, climate risk, compliance and conduct risk, and
operational risk.
We evaluated the directors’ going concern assessment by considering the Group and Bank’s ability to continue as a going concern
under different scenarios considering the current uncertain geopolitical and economic outlook.
We reviewed the Group’s going concern disclosures included in the Annual Report and Accounts in order to assess that the
disclosures were appropriate and in conformity with the reporting standards
.
Independent auditor’s report to the members of NatWest Markets Plc continued
NWM Group
Annual Report and Accounts 2023
81
Based on the work we have performed, we have not identified any material uncertainties relating to events or conditions that,
individually or collectively, may cast significant doubt on the Group and Bank’s ability to continue as a going concern for a period of
twelve months from when the financial statements are authorised for issue.
Our responsibilities and the responsibilities of the directors with respect to going concern are described in the relevant sections of this
report. However, because not all future events or conditions can be predicted, this statement is not a guarantee as to the Group’s or
Bank’s ability to continue as a going concern.
An overview of the scope of NatWest Markets Plc and Group audits
Tailoring the scope
Our assessment of audit risk, our evaluation of materiality and our allocation of performance materiality determine our audit scope for
each component within the Group.
Taken together, this enables us to form an opinion on the consolidated financial statements. We
take into account size, risk profile, the organisation of the Group and effectiveness of the Group wide controls, changes in the business
environment, the potential impact of climate change and other factors such as the results from the work of Internal Audit when
assessing the level of work to be performed at each component.
In assessing the risk of material misstatement to the Group financial statements, and to ensure we had adequate quantitative
coverage of significant accounts in the financial statements, we identified five components of the Group which represent the principal
reporting legal entities within the Group and the Group’s central functions.
Of the components listed below, we performed an audit of the complete financial information of two components (“full scope
components”) which were selected based on their size or risk characteristics. For the specific scope components we performed audit
procedures on specific accounts within that component that we considered had the potential for the greatest impact on the significant
accounts in the financial statements either because of the size of these accounts or their risk profile. We also performed specified
procedures over certain aspects of selected accounts within certain components.
Component
Scope
Key locations
NatWest Markets Plc
Full
United Kingdom, India, Poland and Singapore
NatWest Markets N.V.
Full
United Kingdom, India, Netherlands and Poland
NatWest Markets Securities Inc.
Specific
United States
NatWest Markets Securities Japan Limited
Central Functions*
Specified procedures
Specific/specified
procedures
Japan
United Kingdom, India and Poland
*
Central functions comprise EY functional component teams focused on the audit of specific balances and/or specific procedures across in scope legal entity components.
The table below illustrates the coverage obtained from the work performed by our audit teams. We considered total assets, total
equity and the total income to verify we had appropriate overall coverage.
Full scope
Specific
scope
Specified
procedures
Other
procedures*
Total
Total assets
89%
11%
<1%
-
100%
Total equity
99%
-
-
1%
100%
Total income (absolute)
84%
14%
-
2%
100%
*Other procedures include analytical procedures.
Involvement with component teams
In establishing our overall approach to the Group audit, we determined the type of work that needed to be undertaken at each of the
components by us, as the primary audit engagement team, or by component auditors from other EY global network firms operating
under our instruction.
The primary audit engagement team interacted regularly with the component audit teams where appropriate throughout the course of
the audit, which included holding planning meetings, maintaining regular communications on the status of the audit, reviewing key
working papers and taking responsibility for the scope and direction of the audit process. The primary audit engagement team
continued to follow a programme of oversight visits that has been designed to ensure that the Senior Statutory Auditor, or another
Group audit partner, has ongoing interaction with full scope and specific scope locations. During the current year’s audit cycle, visits
were undertaken by the primary audit engagement team to Poland and India. These visits involved meetings with local management,
discussions with the component team on the audit approach and significant issues arising from their work. This, together with the
additional procedures performed at Group level, gave us appropriate evidence for our opinion on the Group financial statements.
Independent auditor’s report to the members of NatWest Markets Plc continued
NWM Group
Annual Report and Accounts 2023
82
Climate change
Stakeholders are increasingly interested in how climate change will impact companies. The Group has determined that the most
significant future impacts from climate change on its operations will be from physical risk, transition risk and liability risk These are
explained in the Climate Risk section within the Risk and capital management section of the Annual Report and Accounts, which form
part of the “Other information,” rather than the audited financial statements. Our procedures on these disclosures consisted solely of
considering whether they are materially inconsistent with the financial statements, or our knowledge obtained in the course of the
audit or otherwise appear to be materially misstated, in line with our responsibilities on “Other information”.
The Group has explained in the Accounting Policies note, how they have reflected the impact of climate change in their financial
statements, and the significant judgements and estimates relating to climate change. The Group notes that many of the effects arising
from climate change will be longer term in nature, with an inherent level of uncertainty, and have limited effect on accounting
judgments and estimates for the current period.
Our audit effort in considering the impact of climate change on the financial statements was focused on evaluating the Group’s
assessment of the impact of climate risk, their climate commitments and the significant judgements and estimates disclosed in the
Accounting Policies note, and whether these have been appropriately reflected in the asset values where these are impacted by future
cashflows, and the nature and timing of future cash flows, and in the timing and nature of liabilities recognised following the
requirements of UK adopted international accounting standards, IFRS as adopted by the European Union and IFRS as issued by the
IASB. As part of this evaluation, we performed our own risk assessment to determine the risk of material misstatement in the financial
statements from climate change which needed to be considered in our audit. We also evaluated the Directors’ considerations of
climate change risks in their assessment of going concern and associated disclosures. Where considerations of climate change were
relevant to our assessment of going concern, these are described above.
Based on our work we have considered the impact of climate change on the financial statements to impact certain key audit matters.
Details of our procedures and findings are included in our explanation of key audit matters below, where relevant.
Key audit matters
Key audit matters are those matters that, in our professional judgement, were of most significance in our audit of the financial
statements of the current period and include the most significant assessed risks of material misstatement (whether or not due to fraud)
that we identified. These matters included those which had the greatest effect on: the overall audit strategy, the allocation of
resources in the audit; and directing the efforts of the engagement team. These matters were addressed in the context of our audit of
the financial statements as a whole, and in our opinion thereon, and we do not provide a separate opinion on these matters.
Independent auditor’s report to the members of NatWest Markets Plc continued
NWM Group
Annual Report and Accounts 2023
83
Risk
Our response to the risk
Valuation of financial instruments with higher risk characteristics
As at 31 December 2023 the company held financial
instruments with higher risk characteristics. These
included (but are not limited to) reported level 3 assets
of £1.3 billion (2022: £1.7 billion) and level 3 liabilities
of £0.7 billion (2022: £1.0 billion) whose value is
dependent upon unobservable inputs, as reported in
Note 10 to the financial statements.
The valuation of those financial instruments with
higher risk characteristics can include significant
judgement as outlined below. The fair value of these
instruments can involve complex valuation models and
significant fair value adjustments, both of which may
be reliant on inputs where there is limited market
observability.
Management’s estimates which required significant
judgement include:
Complex models:
complex-model-dependent
valuations of financial instruments, which include
interest rate swaps linked to pre-payment
behaviour and interest rate options with exotic
features;
Illiquid inputs:
Pricing inputs and calibrations for
illiquid instruments, including fair value loan
exposures for which there is no active market.
Additionally, derivative instruments whose
valuation is dependent on discount rates
associated with complex collateral arrangements;
and
Fair value adjustments:
The appropriateness of
fair value adjustments made to derivative
valuations including Funding Valuation
Adjustments (FVA) and Credit Valuation
Adjustments (CVA) relating to counterparties
whose credit spread may not be observable, and
material product and deal specific valuation
adjustments on long dated derivative portfolios
Controls testing:
We evaluated the design and operating effectiveness of controls relating
to financial instrument valuation including independent price verification,
valuation models governance, collateral management, income statement
analysis, and the associated controls over relevant information technology
systems. We also observed the Valuation Committees where valuation
inputs, assumptions and adjustments were discussed and approved.
We involved our financial instrument valuation and modelling specialists to
assist us in performing procedures including the following:
Complex models
: Testing a sample of complex model-dependent
valuations by performing independent revaluation to assess the
appropriateness of models and the adequacy of assumptions and
inputs used by the Group;
Illiquid inputs
: Independently re-pricing a sample of financial
instruments that had been valued using illiquid pricing inputs, using
alternative pricing sources where available, to evaluate management’s
valuation; and
Fair value adjustments
: Comparing fair value adjustment
methodologies to current market practice and assessing the
appropriateness and adequacy of the valuation adjustment framework
in light of emerging market practice and changes in the risk profile of
the underlying portfolio; and revaluing a sample of counterparty level
FVA and CVA, comparing funding spreads to third party data,
independently challenging illiquid CVA inputs, and testing material
product and deal specific adjustments on the long-dated derivatives
portfolio.
Throughout our audit procedures we considered the current uncertain
geopolitical and economic outlook, including market volatility and the
impact of climate change on the valuation of financial instruments,
particularly in relation to long-dated illiquid positions.
In addition, we assessed whether there were any indicators of aggregate
bias in financial instrument marking and methodology assumptions.
We performed back-testing analysis of recent trade activity and asset
disposals to evaluate the drivers of significant differences between book
value and trade value to assess the impact on the fair value of similar
instruments within the portfolio. We performed an analysis of significant
collateral discrepancies with counterparties to assess the potential impact
on the fair value of the underlying (and similar) financial instruments.
Key observations communicated to the Group Audit Committee
We are satisfied that the assumptions used by management to reflect the fair value of financial instruments with higher risk
characteristics are in accordance with IFRS. We highlighted the following to the Group Audit Committee:
Complex model-dependent valuations were appropriate based on the output of our independent revaluations, analysis of trade
activity, assessment of the output of the independent price verification process, inspection of collateral disagreements and peer
benchmarking;
The fair value estimates of financial instruments with illiquid inputs appropriately reflected pricing information available at 31
December 2023; and
Valuation adjustments applied to derivative portfolios for credit, funding and other risks were recorded in accordance with the
requirements of IFRS considering trade activity for positions with common risk characteristics, analysis of market data and
peer benchmarking.
Relevant references in the Annual Report and Accounts
Accounting policies
Note 10 to the financial statements
Independent auditor’s report to the members of NatWest Markets Plc continued
NWM Group
Annual Report and Accounts 2023
84
Risk
Our response to the risk
Expected Credit Loss provisions (‘ECL’) under IFRS 9
At 31 December 2023 the Group
reported total gross loans of
£15.5 billion (2022: £11.8 billion)
and £57 million of expected
credit loss provisions under IFRS
9 (2022: £54 million) as detailed
in Note 14 to the financial
statements.
Determining the appropriate ECL
requires management judgement.
Estimates can be subjective and
there remains uncertainty related
to the current geopolitical and
economic outlook.
Given the nature of the Group’s
loan portfolio we assessed that
the most significant factor
impacting ECL is:
The completeness of stage 3
assets:
Default events
impacting stage 1 and 2
loans which are not captured
or appropriately evaluated
on a timely basis.
Controls testing:
We evaluated the design and operating effectiveness of credit monitoring controls. This includes
our evaluation of the governance process, where we observed the Group Provision Committee
meetings, where
judgements and estimates with respect to ECL are discussed and approved.
The completeness of stage 3 assets
We evaluated the criteria used to allocate a financial asset to stage 3 in accordance with IFRS 9.
To test appropriate staging of loan facilities, for a sample of loans we recalculated the staging of
assets based on management’s criteria to assess if they were allocated to the appropriate
stage. We assessed whether credit reviews performed by management appropriately
considered relevant risk factors and identified events of default. Our testing focused on
borrowers who may have a higher risk of default and considered the impact of climate change.
Key observations communicated to the Group Audit Committee
We are satisfied that provisions for the impairment of loans were reasonable and recognised in accordance with IFRS 9. We
highlighted the following to the Group Audit Committee:
Based on the results of our testing we concluded that the completeness of loans in Stage 3 is appropriate
Relevant references in the Annual Report and Accounts
Credit Risk section of the Risk and capital management section
Accounting policies
Note 14 to the financial statements
Independent auditor’s report to the members of NatWest Markets Plc continued
NWM Group
Annual Report and Accounts 2023
85
Risk
Our response to the risk
Provisions for litigation
At 31 December 2023, the Group has
reported £141 million (2022: £225 million) of
provisions for conduct, litigation and other
regulatory matters, as detailed in Note 20 to
the financial statements.
Regulatory scrutiny and the continued litigious
environment give rise to a high level of
management judgement in determining the
appropriate provision for each case.
Management judgement is needed to
determine whether a present obligation
existed, and a provision should be recorded
as at 31 December 2023 in accordance with
the accounting criteria set out under IAS 37.
We identified certain significant legal matters
where management’s estimates required
significant judgement including:
IAS37 assessment:
Determination of
whether an outflow in respect of these
legal matters is probable and can be
estimated reliably.
Controls testing:
We evaluated the design and operating effectiveness of key controls over the
identification, estimation, monitoring and disclosure of provisions whilst
considering the potential for management override of controls. The controls
tested, among others, included those to identify and monitor claims, determine
when a provision is required and to ensure the completeness and accuracy of
data used to estimate provisions.
IAS37 assessment:
We examined relevant regulatory and legal correspondence to assess
developments in the significant legal matters identified. We understood and
assessed the provisioning methodology as well as testing the underlying data and
assumptions used in the determination of the provisions recorded for these
matters.
We considered the accuracy of management’s historical estimates and
considered peer bank settlements in similar cases where appropriate.
We conducted inquiries with internal legal counsel and obtained confirmations
from the Group’s external legal counsel to assist us in evaluating the existence of
an obligation and in assessing management’s estimate of potential outflow at
year-end.
We assessed management’s conclusion by evaluating the underlying information
used in estimating the provisions including the consideration of alternate sources.
Key observations communicated to the Group Audit Committee
We are satisfied that provisions for significant legal matters were reasonable and recognised in accordance with IAS 37.
Relevant references in the Annual Report and Accounts
Report of the Group Audit Committee
Accounting policies
Notes 20 and 25 to the financial statements
Independent auditor’s report to the members of NatWest Markets Plc continued
NWM Group
Annual Report and Accounts 2023
86
Risk
Our response to the risk
IT systems and controls impacting financial reporting
The IT environment is complex and critical to
the proper functioning of the Bank due to the
large volume of transactions processed in
multiple locations. The IT environment is
underpinned by a suite of IT general controls,
including those relating to access
management.
A growing dependency on third parties,
increased use of cloud platforms,
decommissioning of legacy systems and
implementation of new systems also adds to
this complexity.
We evaluated the design and operating effectiveness of IT general controls
relating to the applications, operating systems and databases relevant to financial
reporting.
For systems outsourced to third party service providers, we tested IT general
controls through evaluating the relevant Service Organisation Controls (“SOC”)
reports (where available). Where a SOC report was not available, we identified
and assessed compensating controls to address risks to financial reporting.
Where control deficiencies were identified, we tested remediation activities
performed by management and/or compensating controls in place.
We also performed a further aggregation analysis of access management
deficiencies identified by us and by management to consider the pervasiveness of
findings identified
and adapted our audit testing as required.
Key observations communicated to the Group Audit Committee
Based on our testing procedures, including validating management’s remediation activities, and testing of compensating controls,
we are satisfied that reliance can be placed upon IT general controls impacting material financial reporting systems. We highlighted
the following to the Group Audit Committee:
Where issues were noted in relation to IT general controls, these were remediated by 31 December 2023 or mitigated by
compensating controls.
Independent auditor’s report to the members of NatWest Markets Plc continued
NWM Group
Annual Report and Accounts 2023
87
Our application of materiality
We apply the concept of materiality in planning and performing the audit, in evaluating the effect of identified misstatements on the
audit and in forming our audit opinion.
Materiality
The magnitude of an omission or misstatement that, individually or in the aggregate, could reasonably be expected to influence the
economic decisions of the users of the financial statements. Materiality provides a basis for determining the nature and extent of our
audit procedures.
We determined materiality for the Group and Bank to be £63 million (2022- £66 million), which is 1% (2022 - 1%) of shareholder’s
equity of the Bank.
Performance materiality
The application of materiality at the individual account or balance level.
It is set at an amount to reduce to an appropriately low level
the probability that the aggregate of uncorrected and undetected misstatements exceeds materiality.
On the basis of our risk assessments, together with our assessment of the Group’s overall control environment, our judgement was
that performance materiality be set at 50% (2022: 50%) of our planning materiality, namely £31.5 million (2022: £33 million).
We have
set performance materiality at this percentage (which is at the lowest end of the acceptable range of our audit methodology) based on
various considerations including the past history of misstatements and other factors affecting the entity and its financial reporting.
Audit work at component locations for the purpose of obtaining audit coverage over significant financial statement accounts is
undertaken based on a percentage of total performance materiality. The performance materiality set for each component is based on
the relative scale and risk of the component to the Group as a whole and our assessment of the risk of misstatement at that
component.
In the current year, the range of performance materiality allocated to components was between £16 million and £31.5
million (2022: £16 million and £33 million).
Reporting threshold
An amount below which identified misstatements are considered as being clearly trivial.
We agreed with the Group Audit Committee that we would report to them all uncorrected audit differences in excess of £3 million
(2022: £3 million), which is set at 5% of planning materiality, as well as differences below that threshold that, in our view, warranted
reporting on qualitative grounds.
We evaluate any uncorrected misstatements against both the quantitative measures of materiality discussed above and in light of
other relevant qualitative considerations in forming our opinion.
Other information
The other information comprises the information included in the Annual Report and Accounts (including the Strategic Report, Financial
Review, Risk and capital management sections not identified as ‘audited’, Report of the directors, Statement of directors’
responsibilities, Risk factors and Forward-looking statements and Non-IFRS financial measures) other than the financial statements and
our auditor’s report thereon. The directors are responsible for the other information contained within the annual report.
Our opinion on the financial statements does not cover the other information and, except to the extent otherwise explicitly stated in
this report, we do not express any form of assurance conclusion thereon.
Our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent
with the financial statements or our knowledge obtained in the course of the audit or otherwise appears to be materially misstated. If
we identify such material inconsistencies or apparent material misstatements, we are required to determine whether this gives rise to
a material misstatement in the financial statements themselves. If, based on the work we have performed, we conclude that there is a
material misstatement of the other information, we are required to report that fact.
We have nothing to report in this regard.
Opinions on other matters prescribed by the Companies Act 2006
In our opinion, based on the work undertaken in the course of the audit:
the information given in the Strategic report and the Report of the directors for the financial year for which the financial statements
are prepared is consistent with the financial statements; and
the Strategic report and Report of the directors have been prepared in accordance with applicable legal requirements.
Independent auditor’s report to the members of NatWest Markets Plc continued
NWM Group
Annual Report and Accounts 2023
88
Matters on which we are required to report by exception
In the light of the knowledge and understanding of the Group and the Bank and its environment obtained in the course of the audit, we
have not identified material misstatements in the Strategic report or the Report of the directors.
We have nothing to report in respect of the following matters in relation to which the Companies Act 2006 requires us to report to you
if, in our opinion:
adequate accounting records have not been kept by the Group and the Bank, or returns adequate for our audit have not been
received from branches not visited by us; or
the Group’s and Bank’s financial statements are not in agreement with the accounting records and returns; or
certain disclosures of directors’ remuneration specified by law are not made; or
we have not received all the information and explanations we require for our audit
Responsibilities of directors
As explained more fully in the Statement of directors’ responsibilities, the directors are responsible for the preparation of the financial
statements and for being satisfied that they give a true and fair view, and for such internal control as the directors determine is
necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error.
In preparing the financial statements, the directors are responsible for assessing the Group and Bank’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 Bank to cease operations, or have no realistic alternative but to do so.
Auditor’s responsibilities for the audit of the financial statements
Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material
misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high
level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material
misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the
aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial
statements.
Explanation as to what extent the audit was considered capable of detecting irregularities, including fraud
Irregularities, including fraud, are instances of non-compliance with laws and regulations. We design procedures in line with our
responsibilities, outlined above, to detect irregularities, including fraud. The risk of not detecting a material misstatement due to fraud is
higher than the risk of not detecting one resulting from error, as fraud may involve deliberate concealment by, for example, forgery or
intentional misrepresentations, or through collusion. The extent to which our procedures are capable of detecting irregularities,
including fraud is detailed below. However, the primary responsibility for the prevention and detection of fraud rests with both those
charged with governance of the Group and the Bank, and management.
We obtained an understanding of the legal and regulatory frameworks that are applicable to the Group and determined that the
most significant are the regulations of the Prudential Regulation Authority (PRA), the Financial Conduct Authority (FCA) and the
Companies Act 2006.
We understood how the Group is complying with those frameworks by making inquiries of management, Internal Audit and those
responsible for legal and compliance matters. We also reviewed correspondence between the Group and regulatory bodies;
reviewed minutes of the Board and other key committees; and gained an understanding of the Group’s governance framework.
We assessed the susceptibility of the Group financial statements to material misstatement, including how fraud might occur by
considering the controls established to address risks identified to prevent or detect fraud. We also identified the risks of fraud in our
key audit matters as described above. Our procedures over our key audit matters and other significant accounting estimates
included challenging management on the assumptions made and judgements required in determining these estimates. Our
procedures also involved journal entry testing, with a focus on journals meeting our defined risk criteria based on our
understanding of the business.
We designed our audit procedures to identify non-compliance with laws and regulations. Our procedures involved inquiries of legal
counsel, management and Internal Audit. We also tested controls and performed procedures to respond to the fraud risks as
identified in our key audit matters. These procedures were performed by both the primary audit engagement team and component
teams with oversight from the primary audit engagement team.
The Group operates in the banking industry which is a highly regulated environment. As such, the Senior Statutory Auditor
considered the experience and expertise of the engagement team to ensure that the team had the appropriate competence and
capabilities, involving specialists where appropriate.
A further description of our responsibilities for the audit of the financial statements is located on the Financial Reporting Council’s
website at https://www.frc.org.uk/auditorsresponsibilities.
This description forms part of our auditor’s report.
Independent auditor’s report to the members of NatWest Markets Plc continued
NWM Group
Annual Report and Accounts 2023
89
Other matters we are required to address
Following the recommendation from the NatWest Group Audit Committee we were appointed by NatWest Group Plc at its annual
general meeting on 4 May 2016 to audit the financial statements of the Group and the Bank for the year ended 31 December
2016 and subsequent financial periods.
The period of total uninterrupted engagement including previous renewals and reappointments is eight years, covering periods
from our appointment through 31 December 2023.
The non-audit services prohibited by the FRC’s Ethical Standard were not provided to the Group or the Bank and we remain
independent of the Group and the Bank in conducting the audit.
The audit opinion is consistent with the additional report to the Group Audit Committee.
Use of our report
This report is made solely to the Group’s and the Bank’s members, as a body, in accordance with Chapter 3 of Part 16 of the
Companies Act 2006. Our audit work has been undertaken so that we might state to the Group’s and the Bank’s members those
matters we are required to state to them in an auditor’s report and for no other purpose. To the fullest extent permitted by law, we do
not accept or assume responsibility to anyone other than the Group and the Bank, and the Group’s and the Bank’s members as a
body, for our audit work, for this report, or for the opinions we have formed.
Manprit Dosanjh
(
Senior
statutory auditor
)
for and on behalf of Ernst & Young LLP, Statutory Auditor
London, United Kingdom
15 February 2024
 
Consolidated income statement
For the year ended 31 December 2023
NWM Group
Annual Report and Accounts 2023
90
2023
2022
Note
£m
£m
Interest receivable
2,186
745
Interest payable
(1,831)
(654)
Net interest income
1
355
91
Fees and commissions receivable
377
349
Fees and commissions payable
(175)
(158)
Income from trading activities
477
389
Other operating income
35
18
Non-interest income
2
714
598
Total income
1,069
689
Staff costs
(418)
(400)
Premises and equipment
(66)
(60)
Other administrative expenses
(642)
(652)
Depreciation and amortisation
(16)
(16)
Operating expenses
3
(1,142)
(1,128)
Loss before impairment losses
(73)
(439)
Impairment losses
14
(2)
(8)
Operating loss before tax
(75)
(447)
Tax (charge)/credit
7
(23)
183
Loss for the year
(98)
(264)
Attributable to:
Ordinary shareholders
(168)
(335)
Paid-in-equity holders
70
70
Non-controlling interests
-
1
(98)
(264)
Consolidated statement of comprehensive income
For the year ended 31 December 2023
2023
2022
£m
£m
Loss for the year
(98)
(264)
Items that do not qualify for reclassification
Remeasurement of retirement benefit schemes
(113)
(68)
Changes in fair value of credit in financial liabilities designated at FVTPL
(39)
50
FVOCI financial assets
7
(2)
Tax
42
32
(103)
12
Items that do qualify for reclassification
FVOCI financial assets
5
(31)
Cash flow hedges
(1)
178
(475)
Currency translation
(132)
245
Tax
(48)
142
3
(119)
Other comprehensive loss after tax
(100)
(107)
Total comprehensive loss for the year
(198)
(371)
Attributable to:
Ordinary shareholders
(268)
(442)
Paid-in equity holders
70
70
Non-controlling interests
-
1
(198)
(371)
The accompanying notes on pages 100 to 163, the accounting policies on pages 94 to 99 and the audited sections of the Financial
review and Risk and capital management on pages 20 to 73 form an integral part of these financial statements.
(1)
Refer to footnotes 3 and 4 of the statement of changes in equity
 
 
Balance sheet
As at 31 December 2023
NWM Group
Annual Report and Accounts 2023
91
NWM Group
NWM Plc
2023
2022
2023
2022
Note
£m
£m
£m
£m
Assets
Cash and balances at central banks
9
13,831
17,007
8,607
13,467
Trading assets
12
45,324
45,291
28,411
27,301
Derivatives
13
79,332
100,154
75,832
96,258
Settlement balances
9
7,227
2,558
2,168
1,686
Loans to banks - amortised cost
9
1,246
1,146
910
815
Loans to customers - amortised cost
9
12,986
10,171
12,104
9,154
Amounts due from holding company and fellow subsidiaries
31
1,730
740
6,472
6,665
Other financial assets
15
15,723
11,870
13,444
10,377
Investments in group undertakings
16
-
-
2,320
2,626
Other assets
17
518
832
390
712
Total assets
177,917
189,769
150,658
169,061
Liabilities
Bank deposits
9
2,267
3,069
1,909
2,936
Customer deposits
9
6,998
3,614
3,060
2,665
Amounts due to holding company and fellow subsidiaries
31
5,802
6,217
14,385
12,867
Settlement balances
9
6,641
2,010
400
1,133
Trading liabilities
12
53,623
52,792
34,079
33,225
Derivatives
13
71,981
93,585
69,404
90,754
Other financial liabilities
18
23,574
21,103
20,655
18,396
Other liabilities
20
653
816
453
567
Total liabilities
171,539
183,206
144,345
162,543
Owners' equity
21
6,380
6,565
6,313
6,518
Non-controlling interests
(2)
(2)
-
-
Total equity
6,378
6,563
6,313
6,518
Total liabilities and equity
177,917
189,769
150,658
169,061
Owners’ equity of NWM Plc as at 31 December 2023 includes the loss for the year of £169 million (2022 loss - £79 million).
The accompanying notes on pages 100 to 163, the accounting policies on pages 94 to 99 and the audited sections of the Financial
review and Risk and capital management on pages 20 to 73 form an integral part of these financial statements.
The accounts were approved by the Board of directors on 15 February 2024 and signed on its behalf by:
Frank Dangeard
Robert Begbie
Simon Lowe
NatWest Markets Plc
Chairman
Chief Executive Officer
Chief Financial Officer
Registration No. SC090312
 
 
Statement of changes in equity
For the year ended 31 December 2023
NWM Group
Annual Report and Accounts 2023
92
NWM Group
NWM Plc
2023
2022
2023
2022
Note
£m
£m
£m
£m
Called-up share capital - at 1 January and 31 December
21
400
400
400
400
Paid-in equity - at 1 January and 31 December
21
904
904
904
904
Share premium account - at 1 January and 31 December
1,946
1,946
1,946
1,946
Merger reserve - at 1 January
-
-
-
-
Additions
(14)
-
-
-
At 31 December
(14)
-
-
-
FVOCI reserve - at 1 January
3
33
(2)
18
Unrealised gains/(losses)
11
(44)
6
(27)
Realised losses/(gains)
3
5
-
(2)
Tax
(4)
9
(4)
9
At 31 December
13
3
-
(2)
Cash flow hedging reserve - at 1 January
(294)
47
(284)
46
Amount recognised in equity
(3)
(29)
(424)
(56)
(406)
Amount transferred from equity to earnings
(4)
207
(51)
201
(58)
Tax
(48)
134
(48)
134
At 31 December
(164)
(294)
(187)
(284)
Foreign exchange reserve - at 1 January
232
(13)
(78)
(218)
Retranslation of net assets
(143)
325
(85)
151
Foreign currency gains/(losses) on hedges of net assets
19
(75)
5
(11)
Recycled to profit or loss on disposal of businesses
(8)
(5)
1
-
At 31 December
100
232
(157)
(78)
Retained earnings - at 1 January
3,374
4,138
3,632
4,253
Loss attributable to ordinary shareholders and other equity owners
(98)
(265)
(169)
(79)
Paid-in equity dividends paid
(70)
(70)
(70)
(70)
Ordinary dividends paid
-
(430)
-
(430)
Capital contribution
(2)
115
-
115
-
Realised (losses)/gains in period on FVOCI equity shares
- gross
(2)
6
-
6
- tax
-
10
-
10
Remeasurement of the retirement benefit schemes
- gross
(113)
(68)
(113)
(68)
- tax
40
23
40
23
Changes in fair value of credit in financial liabilities designated at FVTPL
- gross
(39)
50
(16)
7
- tax
6
(2)
6
(2)
Share-based payments
- gross
(14)
(18)
(14)
(18)
- tax
(4)
-
(4)
-
At 31 December
3,195
3,374
3,407
3,632
Owners' equity at 31 December
6,380
6,565
6,313
6,518
Non-controlling interests - at 1 January
(2)
(3)
-
-
Profit attributable to non-controlling interests
-
1
-
-
At 31 December
(2)
(2)
-
-
Total equity at 31 December
6,378
6,563
6,313
6,518
Attributable to:
Ordinary shareholders
5,476
5,661
5,409
5,614
Paid-in equity holders
904
904
904
904
Non-controlling interests
(2)
(2)
-
-
6,378
6,563
6,313
6,518
(1)
The total distributable reserves for NWM Plc is £3,063 million (2022 – £3,268 million).
(2)
During H1 2023, NatWest Markets invoked a claim against the parent, NatWest Group plc, in respect of a legacy (non-trading) matter which was covered by an indemnity agreement.
This resulted in a capital contribution.
(3)
The change in the cash flow hedging reserve is driven by realised accrued interest transferred into the income statement and a decrease in swap rates compared to prior periods where
they rose. The portfolio of hedging instruments is predominantly received fixed swaps.
(4)
As referred in Note 13, amount transferred from equity to the income statement is mostly recorded within net interest income mainly in loans to customers, balances at central banks
and other financial liabilities as per Note 1.
The accompanying notes on pages 100 to 163, the accounting policies on pages 94 to 99 and the audited sections of the Financial
review and Risk and capital management on pages 20 to 73 form an integral part of these financial statements.
 
 
Cash flow statement
For the year ended 31 December 2023
NWM Group
Annual Report and Accounts 2023
93
NWM Group
NWM Plc
2023
2022
2023
2022
Note
£m
£m
£m
£m
Cash flows from operating activities
Operating loss before tax
(75)
(447)
(141)
(264)
Adjustments for:
Non-cash and other items
26
173
(488)
21
(368)
Changes in operating assets and liabilities
26
2,617
6,293
(672)
5,883
Income taxes received
99
135
116
144
Net cash flows from operating activities
(1)
2,814
5,493
(676)
5,395
Cash flows from investing activities
Sale and maturity of other financial assets
5,399
5,935
3,752
4,797
Purchase of other financial assets
(9,253)
(9,093)
(6,771)
(7,601)
Income received on other financial assets
632
236
573
252
Fair value given for businesses acquired
(27)
-
-
-
Purchase of investment in associates
-
(1)
-
(1)
Dividends received from subsidiaries
-
-
349
53
Sale of property, plant and equipment
1
20
1
-
Purchase of property, plant and equipment
(3)
(2)
-
-
Net cash flows from investing activities
(3,251)
(2,905)
(2,096)
(2,500)
Cash flows from financing activities
Redemption of subordinated liabilities
(676)
(481)
(595)
(277)
Interest paid on subordinated liabilities
(71)
(92)
(57)
(73)
Issue of MRELs
1,699
986
1,699
986
Maturity of MRELs
(1,744)
(1,862)
(1,744)
(1,862)
Interest paid on MRELs
(175)
(151)
(175)
(151)
Dividends paid
(70)
(500)
(70)
(500)
Capital Contribution
115
-
115
-
Net cash flows from financing activities
27
(922)
(2,100)
(827)
(1,877)
Effects of exchange rate on cash and cash equivalents
(526)
1,090
(336)
691
Net (decrease)/increase in cash and cash equivalents
(1,885)
1,578
(3,935)
1,709
Cash and cash equivalents at 1 January
26,828
25,250
20,923
19,214
Cash and cash equivalents at 31 December
28
24,943
26,828
16,988
20,923
(1)
NWM Group includes interest received of £1,981 million (2022 - £637 million) and interest paid of £1,738 million (2022 - £524 million), and NWM Plc includes interest received of £1,836
million (2022 - £677 million) and interest paid of £1,611 million (2022 - £557 million).
The accompanying notes on pages 100 to 163, the accounting policies on pages 94 to 99 and the audited sections of the Financial
review and Risk and capital management on pages 20 to 73 form an integral part of these financial statements.
 
NWM Group
Annual Report and Accounts 2023
94
Accounting policies
1. Presentation of financial statements
NatWest Markets Plc (NWM Plc) is incorporated in the UK and
registered in Scotland. The financial statements are presented in
the functional currency, pounds sterling.
The audited financial statements include audited sections of the
Risk and capital management section. The directors have
prepared the financial statements on a going concern basis after
assessing the principal risks, forecasts, projections and other
relevant evidence over the twelve months from the date the
financial statements are approved (see the Report of the
directors) and in accordance with UK adopted International
Accounting Standards (IAS), International Financial Reporting
Standards (IFRS) as issued by the International Accounting
Standards Board (IASB), and IFRS as adopted by the European
Union. The critical and material accounting policies and related
judgements are set out below.
The financial statements are presented on a historical cost basis
except for certain financial instruments which are stated at fair
value.
The effect of the amendments to IFRS effective from 1 January
2023 on our financial statements was immaterial.
We have applied the exception issued by the IASB in May 2023
from the accounting requirements for deferred taxes in IAS 12
Income taxes in respect of Pillar Two income taxes. Accordingly,
we have not recognised or disclosed information about deferred
tax assets and liabilities related to Pillar Two income taxes.
Our consolidated financial statements incorporate the results of
NWM Plc and the entities it controls. Control arises when we
have the power to direct the activities of an entity so as to affect
the return from the entity. Control is assessed by reference to
our ability to enforce our will on the other entity, typically through
voting rights. The consolidated financial statements are prepared
under consistent accounting policies.
A subsidiary is included in the consolidated financial statements
at fair value on acquisition from the date it is controlled by us
until the date we cease to control it through a sale or a
significant change in circumstances. Changes in our interest in a
subsidiary that do not result in us ceasing to control that
subsidiary are accounted for as equity transactions.
How Climate risk affects our accounting judgements
and estimates
Business planning
Key financial estimates are based on management's latest five-
year revenue and cost forecasts. The outputs from this forecast
affect forward-looking accounting estimates. Measurement of
deferred tax and expected credit losses are highly sensitive to
reasonably possible changes in those anticipated conditions. In
2023, our scenario planning was enhanced by the further
integration of NatWest Group’s climate transition plan, including
the assessment of climate-related risks and opportunities.
Our Climate transition plan includes an assessment of:
Changes in products, services and business operations
to support customer transition towards net zero.
Financial impacts of supporting customer transition,
including investment required. The linkage between our
financial plan and our Climate transition plan will
continue to be developed and refreshed annually as
part of the financial planning cycle.
The climate impact of policies, using the UK Climate
Change Committee (UK CCC) Balanced Net Zero (BNZ)
pathway scenario, aligned with the UK’s Sixth Carbon
Budget. In addition, we have used the credibility ratings
for sectoral policies provided by the UK CCC 2023
Progress Report, published in June, to the Parliament to
develop a BNZ adjusted pathway to reflect estimated
time delays of these policies.
There remains considerable uncertainty regarding this policy
response, including the effect of wider geo-political
uncertainty on governmental ambitions regarding climate
transition and the effect of decarbonisation on wider
economic growth, technology development and customer
behaviours.
Information used in other accounting estimates
We make use of reasonable and supportable information to make
accounting judgements and estimates. This includes information
about the observable effects of the physical and transition risks of
climate change on the current creditworthiness of borrowers,
asset values and market indicators. It also includes the effect on
our competitiveness and profitability. Many of the effects arising
from climate change will be longer term in nature, with an
inherent level of uncertainty, and have limited effect on
accounting judgements and estimates for the current period.
Some physical and transition risks can manifest in the shorter
term. The following items represent the most significant effects:
The classification of financial instruments linked to climate,
or other sustainability indicators: consideration is given to
whether the effect of climate related terms prevent the
instrument cashflows being solely payments of principal and
interest.
The use of market indicators as inputs to fair value is
assumed to include current information and knowledge
regarding the effect of climate risk.
Effect of climate change in the estimation of expected
credit loss
We are monitoring the effect of the physical and transition
consequences of climate change on our experience of loan loss.
We use available information regarding the effect of climate
transition policy largely driven by carbon prices as an adjustment
to macroeconomic factors that are used as inputs to the models
that generate PD and LGD outcomes, which are key inputs to
the ECL calculation. The determination of whether specific loss
drivers and climate events generate specific losses is ongoing
and is necessary to determine how sensitive changes in ECL
could be to climate inputs.
Future cashflows are discounted, so long dated cashflows are
less likely to affect current expectations on credit loss. Our
assessment of sector specific risks, and whether additional
adjustments are required, include expectations of the ability of
those sectors to meet their financing needs in the market.
Changes in credit stewardship and credit risk appetite that stem
from climate considerations, such as oil and gas, will directly
affect our positions.
Accounting policies continued
NWM Group
Annual Report and Accounts 2023
95
2. Critical accounting policies
The judgements and assumptions involved in our accounting policies that are considered by the Board to be the most important to the
portrayal of our financial condition are noted below. The use of estimates, assumptions or models that differ from those adopted by us
would affect our reported results. Management’s consideration of uncertainty is outlined in the relevant sections of this document,
including the ECL estimate in the Risk and capital management section.
Information used for significant estimate
Further
Policy
Judgement
Estimate
information
Deferred
Determination of whether sufficient sustainable
Our estimates are based on the five-year
Note 7
tax
taxable profits will be generated in future years
revenue and cost forecasts (which include
to recover the deferred tax asset.
inherent uncertainties).
Fair value –
Classification of a fair value instrument as level
Estimation of the fair value, where it is
Note 10
financial
3, where the valuation is driven by
reasonably possible to have alternative
instruments
unobservable inputs.
assumptions in determining the FV.
Loan
Definition of default against which to apply PD,
ECL estimates contain a number of
Note 14
impairment
LGD and EAD models.
measurement uncertainties (such as the
provisions
Selection of multiple economic scenarios.
weighting of multiple economic scenarios) and
Criteria for a significant increase in credit risk.
disclosures include sensitivities to show impact
Identification of risks not captured by the
on other reasonably possible scenarios.
models.
Provisions
Determination of whether a present obligation
Provisions remain sensitive to the assumptions
Note 20
for liabilities
exists in respect of customer redress, litigation
used in the estimate. We consider a wide range
and
and other regulatory, property and other
of possible outcomes. It is often not practical to
charges
provisions.
meaningfully quantify ranges of possible
Legal proceedings often require a high degree
outcomes, given the uncertainties involved.
of judgement and these are likely to change as
the matter progresses.
Changes in judgements and assumptions could result in a material adjustment to those estimates in future reporting periods.
2.1. Deferred tax
Deferred tax is the estimated tax expected to be payable or
recoverable in respect of temporary differences between the
carrying amount of an asset or liability for accounting purposes
and the carrying amount for tax purposes in the future. Deferred
tax liabilities are generally recognised for all taxable temporary
differences and deferred tax assets are recognised to the extent
their recovery is probable.
Deferred tax is calculated using tax rates expected to apply in
the periods when the assets will be realised or the liabilities
settled, based on tax rates and laws enacted, or substantively
enacted, at the balance sheet date.
Deferred tax asset recoverability is based on the level of
supporting offsetable deferred tax liabilities we have and of our
future taxable profits. These future taxable profits are based on
our five-year revenue and cost forecasts and the expectation of
long term economic growth beyond this period. The five-year
forecast takes account of management’s current expectations on
competitiveness and profitability. The long term growth rate
reflects external indicators which will include market expectations
on climate risk. We do not consider any additional adjustments to
this indicator.
2.2. Fair value – financial instruments
We measure financial instruments at fair value when they are
classified as mandatory fair value through profit or loss; held-for-
trading; designated fair value through profit or loss and fair value
through other comprehensive income and they are recognised in
the financial statements at fair value. All derivatives are
measured at fair value.
We manage some portfolios of financial assets and financial
liabilities based on our net exposure to either market or credit
risk. In these cases, the fair value is derived from the net risk
exposure of that portfolio with portfolio level adjustments applied
to incorporate bid-offer spreads, counterparty credit risk, and
funding costs (see ‘Valuation Adjustments’).
Where the market for a financial instrument is not active, fair
value is established using a valuation technique. These valuation
techniques involve a degree of estimation, the extent of which
depends on the instrument’s complexity and the availability of
market-based data. The complexity and uncertainty in the
financial instrument’s fair value is categorised using the fair value
hierarchy.
The use of market indicators as inputs to fair value is assumed to
include current information and knowledge regarding the effect
of climate risk.
Accounting policies continued
NWM Group
Annual Report and Accounts 2023
96
2. Critical accounting policies continued
2.3. Loan impairment provisions: expected credit
losses (ECL)
At each balance sheet date each financial asset or portfolio of
financial assets measured at amortised cost or at fair value
through other comprehensive income, issued financial guarantee
and loan commitment (other than those classified as held for
trading) is assessed for impairment. Any change in impairment is
reported in the income statement.
Loss allowances are forward-looking, based on 12-month ECL
where there has not been a significant increase in credit risk
rating, otherwise allowances are based on lifetime expected
losses.
ECL are a probability-weighted estimate of credit losses. The
probability is determined by the risk of default which is applied to
the cash flow estimates. In the absence of a change in credit
rating, allowances are recognised when there is a reduction in
the net present value of expected cash flows.
Following a
significant increase in credit risk, ECL are adjusted from 12
months to lifetime. This will lead to a higher impairment charge.
The measurement of expected credit loss considers the ability of
borrowers to make payments as they fall due. Future cashflows
are discounted, so long dated cashflows are less likely to affect
current expectations on credit loss. Our assessment of sector
specific risks, and whether additional adjustments are required,
include expectations on the ability of those sectors to meet their
financing needs in the market.
Changes in credit risk appetite and how we manage credit
positions that stem from climate considerations, such as oil and
gas, will directly affect our positions.
Judgement is exercised as follows:
Models
– in certain low default portfolios, Basel parameter
estimates are also applied for IFRS 9.
Non-modelled portfolios
- use a standardised capital
requirement under Basel II. Under IFRS 9, they have bespoke
treatments for the identification of significant increase in
credit risk. Benchmark PDs, EADs and LGDs are reviewed
annually for appropriateness. The ECL calculation is based on
expected future cash flows, which is typically applied at a
portfolio level.
Multiple economic scenarios (MES)
– the central, or base,
scenario is most critical to the ECL calculation, independent
of the method used to generate a range of alternative
outcomes and their probabilities.
Significant increase in credit risk
- IFRS 9 requires that at
each reporting date, an entity shall assess whether the credit
risk on an account has increased significantly since initial
recognition. Part of this assessment requires a comparison to
be made between the current lifetime PD (i.e. the current
probability of default over the remaining lifetime) with the
equivalent lifetime PD as determined at the date of initial
recognition.
On restructuring where a financial asset is not derecognised, the
revised cash flows are used in re-estimating the credit loss.
Where restructuring causes derecognition of the original financial
asset, the fair value of the replacement asset is used as the
closing cash flow of the original asset.
Where, in the course of the orderly realisation of a loan, it is
exchanged for equity shares or property, the exchange is
accounted for as the sale of the loan and the acquisition of equity
securities or investment property. Where our acquired interest is
in equity shares, relevant policies for control, associates and joint
ventures apply.
Impaired financial assets are written off and therefore
derecognised from the balance sheet when we conclude that
there is no longer any realistic prospect of recovery of part, or
all, of the loan. For financial assets that are individually assessed
for impairment, the timing of the write-off is determined on a
case-by-case basis. Such financial assets are reviewed regularly,
and write-off will be prompted by bankruptcy, insolvency, re-
negotiation, and similar events.
Business loans are generally written off within five years.
2.4. Provisions
We recognise a provision for a present obligation resulting from a
past event when it is more likely than not that we will be required
to pay to settle the obligation and the amount of the obligation
can be estimated reliably.
Provision is made for restructuring costs, including the costs of
redundancy, when we have a constructive obligation. An
obligation exists when we have a detailed formal plan for the
restructuring and have raised a valid expectation in those
affected either by starting to implement the plan or by
announcing its main features.
We recognise any onerous cost of the present obligation under a
contract as a provision. An onerous cost is the unavoidable cost
of meeting our contractual obligations that exceed the expected
economic benefits. When we intend to vacate a leasehold
property or right of use asset, the asset would be tested for
impairment and a provision may be recognised for the ancillary
contractual occupancy costs.
3. Material accounting policies
3.1. Revenue recognition
Interest receivable and payable are recognised in the income
statement using the effective interest rate method for: all
financial instruments measured at amortised cost; debt
instruments measured as fair value through other comprehensive
income; and the effective part of any related accounting hedging
instruments.
Other interest relating to financial instruments measured at fair
value is recognised as part of the movement in fair value and is
reported in income from trading activities or other operating
income as relevant. Fees in respect of services are recognised as
the right to consideration accrues through the performance of
each distinct service obligation to the customer. The
arrangements are generally contractual and the cost of providing
the service is incurred as the service is rendered. The price is
usually fixed and always determinable.
3.2. Staff costs
Employee costs, such as salaries, paid absences, and other
benefits are recognised over the period in which the employees
provide the related services to us. Employees may receive
variable compensation in cash, in deferred cash or debt
instruments of NWM Group or in ordinary shares of NatWest
Group plc subject to deferral, clawback and forfeiture criteria. We
operate a number of share-based compensation schemes under
which we grant awards of NatWest Group plc shares and share
options to our employees. Such awards are subject to vesting
conditions.
Accounting policies continued
3. Material accounting policies continued
Variable compensation that is settled in cash or debt instruments
is charged to the income statement on a straight-line basis over
the period during which services are provided, taking account of
forfeiture and clawback criteria. The value of employee services
received in exchange for NatWest Group plc shares and share
options is recognised as an expense over the vesting period,
subject to deferral, clawback cancelation and forfeiture criteria
with a corresponding increase in equity. The fair value of shares
granted is the market price adjusted for the expected effect of
dividends as employees are not entitled to dividends until shares
are vested.
The fair value of options granted is determined using option
pricing models to estimate the numbers of shares likely to vest.
These consider the exercise price of the option, the current share
price, the risk-free interest rate, the expected volatility of the
share price over the life of the option and other relevant factors
such as the dividend yield.
Defined contribution pension scheme
A scheme where we pay fixed contributions and there is no legal
or constructive obligation to pay further contributions or benefits.
Contributions are recognised in the income statement as
employee service costs accrue.
Defined benefit pension scheme
A scheme that defines the benefit an employee will receive on
retirement and is dependent on one or more factors such as age,
salary, and years of service. The net of the recognisable scheme
assets and obligations is reported on the balance sheet in other
assets or other liabilities. The defined benefit obligation is
measured on an actuarial basis. The charge to the income
statement for pension costs (mainly the service cost and the net
interest on the net defined benefit asset or liability) is recognised
in operating expenses.
Actuarial gains and losses (i.e., gains and/or losses on re-
measuring the net defined benefit asset or liability
due to
changes in actuarial measurement assumptions) are recognised
in other comprehensive income in full in the period in which they
arise, and not subject to recycling to the income statement.
The difference between scheme assets and scheme liabilities, the
net defined benefit asset or liability, is recognised on the balance
sheet if the criteria of the asset ceiling test are met. This requires
the net defined benefit surplus to be limited to the present value
of any economic benefits available to us in the form of refunds
from the plan or reduced contributions to it.
We will recognise a liability where a minimum funding
requirement exists for any of our defined benefit pension
schemes. This reflects agreed minimum funding and the
availability of a net surplus as determined as described above.
When estimating the liability for minimum funding requirements
we only include contributions that are substantively or
contractually agreed and do not include contingent and
discretionary features, including dividend-linked contributions or
contributions subject to contingent events requiring future
verification.
We will recognise a net defined benefit asset when the net
defined benefit surplus can generate a benefit in the form of a
refund or reduction in future contributions to the plan. The net
benefit pension asset is recognised at the present value of the
benefits that will be available to us excluding interest and the
effect of the asset ceiling (if any, excluding interest). Changes in
the present value of the net benefit pension asset are recognised
immediately in other comprehensive income.
3.3. Foreign currencies
Foreign exchange differences arising on the settlement of foreign
currency transactions and from the translation of monetary
assets and liabilities are reported in income from trading activities
except for differences arising on cash flow hedges and hedges of
net investments in foreign operations.
NWM Group
Annual Report and Accounts 2023
97
Non-monetary items denominated in foreign currencies that are
stated at fair value are translated into the functional currency at
the foreign exchange rates ruling at the dates the values are
determined. Translation differences are recognised in the income
statement except for differences arising on non-monetary
financial assets classified as fair value through other
comprehensive income.
Income and expenses of foreign subsidiaries and branches are
translated into sterling at average exchange rates unless these
do not approximate the foreign exchange rates ruling at the
dates of the transactions. Foreign exchange differences arising
on the translation of a foreign operation are recognised in other
comprehensive income. The amount accumulated in equity is
reclassified from equity to the income statement on disposal of a
foreign operation.
3.4. Tax
Tax encompassing current tax and deferred tax is recognised in
the income statement except when taxable items are recognised
in other comprehensive income or equity. Tax consequences
arising from servicing financial instruments classified as equity are
recognised in the income statement.
Accounting for taxes is judgemental and carries a degree of
uncertainty because tax law is subject to interpretation, which
might be questioned by the relevant tax authority. We recognise
the most likely current and deferred tax liability or asset,
assessed for uncertainty using consistent judgements and
estimates. Current and deferred tax assets are only recognised
where their recovery is deemed probable, and current and
deferred tax liabilities are recognised at the amount that
represents the best estimate of the probable outcome having
regard to their acceptance by the tax authorities.
3.5. Financial instruments
Financial instruments are measured at fair value on initial
recognition on the balance sheet.
Monetary financial assets are classified into one of the following
subsequent measurement categories (subject to business model
assessment and review of contractual cash flow for the purposes
of sole payments of principal and interest where applicable):
amortised cost
measured at cost using the effective interest
rate method, less any impairment allowance;
fair value through other comprehensive income (FVOCI)
measured at fair value, using the effective interest rate
method and changes in fair value through other
comprehensive income;
mandatory fair value through profit or loss (MFVTPL)
measured at fair value and changes in fair value reported in
the income statement; or
designated at fair value through profit or loss (DFV)
measured
at fair value and changes in fair value reported in the income
statement.
Classification by business model reflects how we manage our
financial assets to generate cash flows. A business model
assessment helps to ascertain the measurement approach
depending on whether cash flows result from holding financial
assets to collect the contractual cash flows, from selling those
financial assets, or both.
Business model assessment of assets is made at portfolio level,
being the level at which they are managed to achieve a
predefined business objective. This is expected to result in the
most consistent classification of assets because it aligns with the
stated objectives for the portfolio, its risk management,
manager’s remuneration and the ability to monitor sales of assets
from a portfolio. When a significant change to our business is
communicated to external parties, we reassess our business
model for managing those financial assets. We reclassify financial
assets if we have a significant change to the business model. A
reclassification is applied prospectively from the reclassification
date.
Accounting policies continued
NWM Group
Annual Report and Accounts 2023
98
3. Material accounting policies continued
The contractual terms of a financial asset; any leverage features;
prepayment and extension terms; and discounts or penalties to
interest rates that are part of meeting environmental, social and
governance targets as well as other contingent and leverage
features, non-recourse arrangements and features that could
modify the timing and/or amount of the contractual cash flows
that might reset the effective rate of interest; are considered in
determining whether cash flows are solely payments of principal
and interest.
Certain financial assets may be designated at fair value through
profit or loss (DFV) upon initial recognition if such designation
eliminates, or significantly reduces, accounting mismatch
.
Equity shares are measured at fair value through profit or loss
unless specifically elected as at fair value through other
comprehensive income (FVOCI).
Upon disposal, the cumulative gains or losses in fair value
through other comprehensive income reserve are recycled to the
income statement for monetary assets and for non-monetary
assets (equity shares) the cumulative gains or losses are
transferred directly to retained earnings.
Regular way purchases and sales of financial assets classified as
amortised cost are recognised on the settlement date; all other
regular way transactions in financial assets are recognised on the
trade date.
Financial liabilities are classified into one of following
measurement categories:
amortised cost
measured at cost using the effective interest
rate method;
held for trading
measured at fair value and changes in fair
value reported in income statement; or
designated at fair value through profit or loss
measured at
fair value and changes in fair value reported in the income
statement except changes in fair value attributable to the
credit risk component recognised in other comprehensive
income when no accounting mismatch occurs.
3.6. Financial guarantee contracts
Under a financial guarantee contract, we, in return for a fee,
undertake to meet a customer’s obligations under the terms of a
debt instrument if the customer fails to do so. A financial
guarantee not designated as fair value through profit or loss is
recognised as a liability; initially at fair value and subsequently at
the higher of its initial value less cumulative amortisation and any
provision under the contract measured in accordance with our
ECL accounting policy. Amortisation is calculated to recognise
fees receivable in the income statement over the period of the
guarantee. A separate asset is recognised in respect of fees
receivable for provision of the financial guarantee.
3.7. Netting
Financial assets and financial liabilities are offset, and the net
amount presented on the balance sheet when, and only when,
we currently have a legally enforceable right to set off the
recognised amounts and we intend either to settle on a net basis
or to realise the asset and settle the liability simultaneously. We
are party to a number of arrangements, including master netting
agreements, that give us the right to offset financial assets and
financial liabilities, but where we do not intend to settle the
amounts net or simultaneously, the assets and liabilities
concerned are presented separately on the balance sheet.
3.8. Capital instruments
We classify a financial instrument that we issue as a liability if it is
a contractual obligation to deliver cash or another financial asset,
or to exchange financial assets or financial liabilities on potentially
unfavourable terms and as equity if we evidence a residual
interest in our assets after the deduction of liabilities. Incremental
costs and related tax that are directly attributable to an equity
transaction are deducted from equity.
3.9. Derivatives and hedging
Derivatives are reported on the balance sheet at fair value.
We use derivatives as part of our trading activities, to manage
our own risk such as interest rate, foreign exchange, or credit
risk or in certain customer transactions. Not all derivatives used
to manage risk are in hedge accounting relationships (an IFRS
method to reduce accounting mismatch from changes in the fair
value of derivatives reported in the income statement).
Gains and losses arising from changes in the fair value of
derivatives that are not in hedge relationships are recognised in
Income from trading activities unless those derivatives are
managed together with financial instruments designated at fair
value; these gains and losses are included in Other operating
income.
Hedge accounting
Hedge accounting relationships are designated and documented
at inception in line with the requirements of IAS 39 Financial
instruments – Recognition and Measurement. The documentation
identifies the hedged item, the hedging instrument and details of
the risk that is being hedged and the way in which effectiveness
will be assessed at inception and during the period of the hedge.
When designating a hedging relationship, we consider: the
economic relationship between the hedged item (including the
risk being hedged) and the hedging instrument; the nature of the
risk; the risk management objective and strategy for undertaking
the hedge; and the appropriateness of the method that will be
used to assess hedge effectiveness.
Designated hedging relationships must be expected to be highly
effective both on a prospective and retrospective basis. This is
assessed using regression techniques which model the degree of
offsetting between the changes in fair value or cash flows
attributable to the hedged risk and the changes in fair value of
the designated hedging derivatives. Ineffectiveness is measured
based on actual levels of offsetting and recognised in the income
statement.
We enter into three types of hedge accounting relationships.
Fair value hedge
The gain or loss on the hedging instrument and the hedged item
attributable to the hedged risk is recognised in the income
statement. Where the hedged item is measured at amortised
cost, the balance sheet amount of the hedged item is also
adjusted.
Cash flow hedge
The effective portion of the designated hedge relationship is
recognised in other comprehensive income and the ineffective
portion in the income statement. When the hedged item
(forecasted cash flows) results in the recognition of a financial
asset or financial liability, the cumulative gain or loss is
reclassified from equity to the income statement in the same
periods in which the hedged forecasted cash flows affect the
income statement.
Accounting policies continued
NWM Group
Annual Report and Accounts 2023
99
3. Material accounting policies continued
Hedge of net investment in a foreign operation
In the hedge of a net investment in a foreign operation, the
effective portion of the designated hedge relationship is
recognised in other comprehensive income. Any ineffective
portion is recognised in profit or loss. Non-derivative financial
liabilities as well as derivatives may be designated as a hedging
instrument in a net investment hedge.
Discontinuation of hedge accounting
Hedge accounting is discontinued if the hedge no longer meets
the criteria for hedge accounting
i.e. the hedge is not highly
effective in offsetting changes in fair value or cash flows
attributable to the hedged risk, consistent with the documented
risk management strategy; the hedging instrument expires or is
sold, terminated or exercised; or if hedge designation is revoked.
For fair value hedging any cumulative adjustment is amortised to
the income statement over the life of the hedged item. Where the
hedged item is no longer on the balance sheet the adjustment to
the hedged item is reported in the income statement.
For cash flow hedging the cumulative unrealised gain or loss is
reclassified from equity to the income statement when the
hedged cash flows occur or, if the forecast transaction results in
the recognition of a financial asset or financial liability, when the
hedged forecast cash flows affect the income statement. Where
a forecast transaction is no longer expected to occur, the
cumulative unrealised gain or loss is reclassified from equity to
the income statement immediately.
For net investment hedging on disposal or partial disposal of a
foreign operation, the amount accumulated in equity is
reclassified from equity to the income statement.
3.10. Investment in Group undertakings
Our investments in Group undertakings (subsidiaries) are stated
at cost less any impairment.
4. Future accounting developments
International Financial Reporting Standards
Effective 1 January 2024
Classification of Liabilities as Current or Non-current
(Amendments to IAS 1);
Non-current Liabilities with Covenants (Amendments to IAS
1)
Lease Liability in a Sale and Leaseback (Amendments to IFRS
16)
Supplier Finance Arrangements (Amendments to IAS 7 and
IFRS 7)
Effective 1 January 2025
Lack of Exchangeability (Amendments to IAS 21)
We are assessing the effect of adopting these amendments on
our financial statements but do not expect the effect to be
material.
NWM Group
Annual Report and Accounts 2023
100
Notes to the consolidated financial statements
1 Net interest income
2023
2022
£m
£m
Balances at central banks and loans to banks - amortised cost
759
198
Loans to customers - amortised cost
672
273
Amounts due from holding company and fellow subsidiaries
30
12
Other financial assets
725
262
Interest receivable
2,186
745
Balances with banks
120
72
Customer deposits
312
63
Amounts due to holding company and fellow subsidiaries
319
178
Other financial liabilities
1,080
341
Interest payable
1,831
654
Net interest income
355
91
Interest income on financial instruments measured at amortised cost and debt instruments classified as FVOCI is measured using the
effective interest rate which allocates the interest income or interest expense over the expected life of the asset or liability at the rate
that exactly discounts all estimated future cash flows to equal the instrument's initial carrying amount. Calculation of the effective
interest rate takes into account fees payable or receivable that are an integral part of the instrument's yield, premiums or discounts on
acquisition or issue, early redemption fees and transaction costs. All contractual terms of a financial instrument are considered when
estimating future cash flows.
For accounting policy information refer to Accounting policy 3.1.
2 Non-interest income
2023
2022
Analysis of net fees and commissions
£m
£m
Fees and commissions receivable
- Lending and financing
91
88
- Brokerage
42
44
- Underwriting fees
122
117
- Other
122
100
Total
377
349
Fees and commissions payable
(175)
(158)
Net fees and commissions
202
191
Income from trading activities
Foreign exchange
166
237
Interest rate
385
92
Credit
(72)
18
Changes in fair value of own debt and derivative liabilities attributable to own credit risk
- debt securities in issue and derivative liabilities
(2)
42
477
389
Other operating income
Loss on redemption of own debt
(14)
(74)
Operating lease and other rental income
1
1
Changes in fair value of financial assets and liabilities designated at fair value through profit or loss
(1)
(154)
16
Hedge ineffectiveness
3
(7)
Profit on disposal of amortised cost assets
1
87
Loss on disposal of fair value through other comprehensive income assets
(1)
(7)
Dividend income
5
6
Other income
(2)
194
(4)
35
18
Total
714
598
(1)
Includes related derivatives.
(2)
Other income includes a new profit share agreement with fellow NatWest Group subsidiaries that commenced in 2023. The profit share arrangement was introduced during the year to
reward NWM Group on an arm’s length basis for its contribution to the performance of the NatWest Group Commercial & Institutional business segment, 2023 being the first full year
with the Commercial & Institutional segment in place.
For accounting policy information refer to Accounting policy 3.1 and 3.3.
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
101
3 Operating expenses
2023
2022
£m
£m
Wages, salaries and other staff costs
264
244
Temporary and contract costs
7
5
Social security costs
40
40
Bonus awards
93
92
Pension costs
14
19
- defined benefit schemes (see Note 5)
(6)
2
- defined contribution schemes
20
17
Staff costs
418
400
Premises and equipment
66
60
Depreciation and amortisation
16
16
Other administrative expenses
(1,2)
642
652
Administrative expenses
724
728
1,142
1,128
(1)
Includes £540 million (2022 - £552 million) recharges from other NatWest Group entities, mainly NWB Plc which provides the majority of shared services (including technology) and
operational processes.
(2)
Includes litigation and other regulatory costs. Further details are provided in Note 20.
For accounting policy information refer to Accounting policy 3.2.
The average number of persons employed, rounded to the nearest hundred, during the year, excluding temporary staff, was 1,600
(2022 – 1,600). The number of persons employed by NWM Group at 31 December 2023, excluding temporary staff, was as follows:
2023
2022
UK
900
900
USA
300
300
Rest of the World
500
400
Total
1,700
1,600
Bonus awards
The following tables analyse NWM Group's bonus awards.
2023
2022
Change
£m
£m
%
Non-deferred cash awards
(1)
3
3
-
Deferred cash awards
67
70
(4%)
Deferred share awards
23
28
(18%)
Total deferred bonus awards
90
98
(8%)
Total bonus awards
(2)
93
101
(8%)
2023
2022
Reconciliation of bonus awards to income statement charge
£m
£m
Bonuses awarded
93
101
Less: deferral of charge for amounts awarded for current year
(35)
(41)
Income statement charge for amounts awarded in current year
58
60
Add: current year charge for amounts deferred from prior years
36
35
Less: forfeiture of amounts deferred from prior years
(1)
(3)
Income statement charge for amounts deferred from prior years
35
32
Income statement charge for bonus awards
(2)
93
92
(1)
Non-deferred cash awards are limited to £2000 for all employees.
(2)
Excludes other performance related compensation.
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
102
4 Geographical segment analysis
The geographical analysis in the tables below has been compiled on the basis of location of office where the transactions are recorded.
UK
USA
Europe
RoW
Total
2023
£m
£m
£m
£m
£m
Total revenue
2,273
167
545
90
3,075
Interest receivable
1,729
39
406
12
2,186
Interest payable
(1,548)
(1)
(280)
(2)
(1,831)
Fees and commissions receivable
68
72
180
57
377
Fees and commissions payable
(133)
(22)
(20)
-
(175)
Income from trading activities
394
66
(2)
19
477
Other operating income
82
(10)
(39)
2
35
Total income
592
144
245
88
1,069
Operating (loss)/profit before tax
(235)
44
91
25
(75)
Total assets
119,783
23,724
32,539
1,871
177,917
Total liabilities
125,058
22,106
22,853
1,522
171,539
Contingent liabilities and commitments
8,732
-
6,717
21
15,470
2022
Total revenue
1,012
117
280
92
1,501
Interest receivable
614
37
85
9
745
Interest payable
(582)
(2)
(67)
(3)
(654)
Fees and commissions receivable
47
65
178
59
349
Fees and commissions payable
(120)
(21)
(17)
-
(158)
Income from trading activities
366
1
-
22
389
Other operating income
(15)
14
17
2
18
Total income
310
94
196
89
689
Operating (loss)/profit before tax
(474)
(46)
41
32
(447)
Total assets
130,145
25,977
30,679
2,968
189,769
Total liabilities
132,315
27,034
22,040
1,817
183,206
Contingent liabilities and commitments
7,036
-
7,544
17
14,597
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
103
5 Pensions
Defined contribution schemes
NWM Group sponsors a number of defined contribution pension
schemes in different territories, which new employees are offered
the opportunity to join.
Defined benefit schemes
NWM Group sponsors a number of pension schemes in the UK
and overseas, including the AA and NatWest Markets (NWM)
sections of the NatWest Group Pension Fund which operate
under UK trust law and are managed and administered on behalf
of their members in accordance with the terms of the trust deed,
the scheme rules and UK legislation.
Pension fund trustees are appointed to operate each fund and
ensure benefits are paid in accordance with the scheme rules
and national law. The trustees are the legal owner of a scheme’s
assets and have a duty to act in the best interests of all scheme
members.
The schemes generally provide a pension of one-sixtieth of final
pensionable salary for each year of service prior to retirement up
to a maximum of 40 years and are contributory for current
members. These have been closed to new entrants for over ten
years, although active members continue to build up additional
pension benefits, currently subject to 2% maximum annual salary
inflation, while they remain employed by NWM Group.
The corporate trustee is NatWest Pension Trustee Limited (the
Trustee), a wholly owned subsidiary of NWB Plc. The Board of
the Trustee includes member trustee directors selected from
eligible active staff, deferred and pensioner members who apply
and trustee directors appointed by NatWest Group. Under UK
legislation, a defined benefit pension scheme is required to meet
the statutory funding objective of having sufficient and
appropriate assets to cover its liabilities (the pensions that have
been promised to members).
Investment strategy
The assets of the AA section represent 79% of all plan assets at
31 December 2023 (2022 – 81% of plan assets) and are invested
as shown below.
During 2023, the Trustee completed a buy-in transaction for the
AA section, passing all material longevity and investment risk for
the section to an insurer. At 31 December 2023, the assets of
this section comprised mainly of the buy-in asset (a bulk annuity
policy valued at £546m under IAS 19, covering 99% of the
defined benefit obligation attributable to this section), together
with residual assets of c. £145m. In exchange for an upfront
premium paid to the insurer, the buy-in asset provides a stream
of cashflows to the Trustee replicating payments due to
members.
The premium was determined by the insurer using its pricing
basis. Under IAS 19, the value placed on this asset mirrors the
valuation of the defined benefit obligations covered, incorporating
an assessment of credit risk. Since the insurer’s pricing basis is
more conservative than the best-estimate valuation under IAS
19, an asset loss arises at the outset, which is recognised
through OCI along with the impact of other movements in asset
values over the year. In future, the buy-in asset value will move
in line with movements in the defined benefit obligations covered,
meaning that the scheme is protected against longevity and
market risk.
The NWM section employs physical, derivative and non-derivative
instruments to achieve a desired asset class exposure and to
reduce the scheme’s interest rate, inflation and currency risk.
This means that the net funding position is considerably less
sensitive to changes in market conditions than the value of the
assets or liabilities in isolation.
In particular, the Trustee hedges
movements in interest rates and inflation.
Swaps have been executed at prevailing market rates and within
standard market bid/offer spreads with a number of
counterparty banks, including NWB Plc.
2023
2022
Major classes of plan assets as a percentage of total plan assets
Quoted
Unquoted
Total
Quoted
Unquoted
Total
of the AA section
%
%
%
%
%
%
Equities
-
-
-
-
2.1
2.1
Index linked bonds
-
-
-
30.8
-
30.8
Government bonds
-
-
-
16.5
-
16.5
Corporate and other bonds
1.6
2.7
4.3
20.2
6.4
26.6
Real estate
-
-
-
-
-
-
Derivatives
-
-
-
-
4.3
4.3
Buy-in insurance contracts
-
79.4
79.4
-
-
-
Cash and other assets
-
16.3
16.3
-
19.7
19.7
1.6
98.4
100.0
67.5
32.5
100.0
5 Pensions continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
104
The schemes do not invest directly in NWM Group but can have exposure to NWM Group. The trustees are responsible for ensuring
that indirect investments in NWM Group do not exceed the 5% regulatory limit.
AA section
All schemes
(3)
Present
Present
Fair
value of
Net
Fair
value of
Asset
Net
value of
defined
pension
value of
defined
ceiling/
pension
plan
benefit
asset/
plan
benefit
minimum
asset/
assets
obligation
(1)
(liability)
assets
obligation
(1)
funding
(2)
(liability)
Changes in value of net pension asset/(liability)
£m
£m
£m
£m
£m
£m
£m
At 1 January 2022
1,153
(855)
298
1,473
(1,153)
(80)
240
Currency translation and other adjustments
-
-
-
-
-
-
-
Income statement - operating expenses
20
(16)
4
26
(27)
(1)
(2)
Other comprehensive income
(369)
300
(69)
(509)
429
12
(68)
Contributions by employer
2
-
2
8
-
-
8
Contributions by plan participants and other scheme members
Benefits paid
(40)
40
-
(52)
52
-
-
Assets and liabilities extinguished on settlements
-
-
-
(4)
4
-
-
Transfers to/from fellow subsidiaries
-
-
-
(2)
2
-
-
At 1 January 2023
766
(531)
235
940
(693)
(69)
178
Currency translation and other adjustments
-
-
-
-
3
-
3
Income statement - operating expenses
Net interest expense
38
(26)
12
47
(35)
(3)
9
Gain on curtailments
-
-
-
-
-
-
Current service cost
-
(1)
(1)
-
(3)
-
(3)
38
(27)
11
47
(38)
(3)
6
Other comprehensive income
Return on plan assets excluding recognised interest income
(88)
-
(88)
(95)
-
-
(95)
Experience gains and losses
-
(16)
(16)
-
(18)
-
(18)
Effect of changes in actuarial financial assumptions
-
(13)
(13)
-
(16)
-
(16)
Effect of changes in demographic assumptions
-
8
8
-
9
-
9
Asset ceiling adjustments
-
-
-
-
-
7
7
(88)
(21)
(109)
(95)
(25)
7
(113)
Contributions by employer
(5)
3
-
3
9
-
-
9
Benefits paid
(28)
28
-
(31)
31
-
-
Assets and liabilities extinguished on settlements
-
-
-
-
-
-
-
Transfers to/from fellow subsidiaries
-
-
-
-
-
-
-
At 31 December 2023
(4)
691
(551)
140
870
(722)
(65)
83
(1)
Defined benefit obligations are subject to annual valuation by independent actuaries.
(2)
In recognising the net surplus or deficit of a pension scheme, the funded status of each scheme is adjusted to reflect any minimum funding requirement imposed on the sponsor and any
ceiling on the amount that the sponsor has an unconditional right to recover from a scheme.
(3)
Includes the NWM Section which has a net pension asset of £nil at 31 December 2023 (2022- net pension asset of £nil). This scheme has plan assets of £162 million, a defined benefit
obligation of £96 million and an asset ceiling of £66 million (2022- £155 million, £86 million and £69 million respectively).
(4)
On 16 June 2023 the High Court issued a ruling in respect of Virgin Media v NTL Pension Trustees II Limited (and others), which has the potential to affect the defined benefit obligation
(DBO) values. Reasonable due diligence has concluded that the DBO values above require no adjustment for the impact of this case. Further details included under the Pension Risk
section of this report.
(5)
NWM Group expects to make contributions to the AA section of £2.6 million and to the NWM section of £4.6 million in 2024.
All schemes
2023
2022
Amounts recognised on the balance sheet
£m
£m
Fund asset at fair value
870
940
Present value of fund liabilities
(722)
(693)
Funded status
148
247
Assets ceiling/minimum funding
(65)
(69)
83
178
2023
2022
Net pension asset/(liability) comprises
£m
£m
Net assets of schemes in surplus (included in Other assets, Note 17)
145
241
Net liabilities of schemes in deficit (included in Other liabilities, Note 20)
(62)
(63)
83
178
5 Pensions continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
105
Funding and contributions by NWM Group
In the UK, the trustees of defined benefit pension schemes are
required to perform funding valuations at least every three years.
The trustees and the sponsoring company, with the support of
the Scheme Actuary, agree the assumptions used to value the
liabilities and determine future funding requirements. The funding
assumptions incorporate a margin for prudence over and above
the expected cost of providing the benefits promised to
members, taking into account the sponsor’s covenant and the
investment strategy of the scheme. Similar arrangements apply
in the other territories where NWM Group sponsors defined
benefit pension schemes.
The triennial funding valuation of the AA and NWM sections as at
31 December 2020 was completed during 2021. This determined
the funding level to be 108% and 111% respectively, based on
pension liabilities of £1,071 million and £267 million. No further
deficit contributions are due.
The key assumptions used to determine the funding liabilities
were the discount rate, which is determined based on a gilt yield
curve plus 0.4% per annum, and mortality assumptions, which
result in life expectancies of 28.3/30.1 years for males/females
who were age 60 and 30.2/31.8 years from age 60 for
males/females who were aged 40 at the valuation date.
Accounting assumptions
Placing a value on NWM Group’s defined benefit pension
schemes’ liabilities require NWM Group’s management to make a
number of assumptions, with the support of independent
actuaries. The ultimate cost of the defined benefit obligations
depends upon actual future events and the assumptions made
are unlikely to be exactly borne out in practice, meaning the final
cost may be higher or lower than expected
.
The most significant assumptions used for the AA section are shown below:
Principal IAS 19 actuarial assumptions
2023
2022
%
%
Discount rate
4.8
5.0
Inflation assumption (RPI)
3.1
3.2
Rate of increase in salaries
1.8
1.8
Rate of increase in deferred pensions
2.5
2.5
Rate of increase in pensions in payment
2.9
3.0
Lump sum conversion rate at retirement
15
18
Longevity at age 60:
years
years
Current pensioners
Males
27.4
27.9
Females
29.4
29.8
Future pensioners, currently aged 40
Males
29.0
29.5
Females
30.7
31.2
The above financial assumptions are long-term assumptions set with reference to the period over which the obligations are expected to be settled.
Discount rate
The IAS 19 valuation uses a single discount rate set by reference to the yield on a basket of ‘high quality’ sterling corporate bonds.
Significant judgement is required when setting the criteria for bonds to be included in the basket of bonds that determines the discount
rate used in the IAS 19 valuations. The criteria include issue size, quality of pricing and the exclusion of outliers. Judgement is also
required in determining the shape of the yield curve at long durations: a constant credit spread relative to gilts is assumed. Sensitivity
to the main assumptions is presented below
.
5 Pensions continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
106
The table below shows how the present value of the net pension asset of the AA section would change if the key assumptions used
were changed independently. In practice the variables have a degree of correlation and do not move completely in isolation.
(Decrease)
(Decrease)
Increase
increase
increase
in net pension
in value of
in value of
(obligations)/
assets
liabilities
assets
2023
£m
£m
£m
0.5% increase in interest rates/discount rate
(35)
(35)
-
0.25% increase in inflation
12
12
-
0.5% increase in credit spreads
(35)
(35)
-
Longevity increase of one year
19
19
-
0.25% additional rate of increase in pensions in payment
15
15
-
Increase in equity values of 10%
(1)
1
-
1
2022
0.5% increase in interest rates/discount rate
(50)
(34)
(16)
0.25% increase in inflation
24
12
12
0.5% increase in credit spreads
-
(34)
34
Longevity increase of one year
-
17
(17)
0.25% additional rate of increase in pensions in payment
-
15
(15)
Increase in equity values of 10%
(1)
2
-
2
(1)
Includes both quoted and private equity.
Note the longevity sensitivities quoted above reflect the impact of a one-year increase to single life annuities. As can be seen from the
table above, the funded status of the AA section is no longer sensitive to credit spreads and longevity, because the insured asset value
moves in line with the underlying liabilities. For completeness, the table below shows the combined change in the defined benefit
obligation as a result of larger movements in credit spreads / life expectancies, but note that, at 2023, these movements will be
mitigated by corresponding movements in the insured asset value.
Change in life expectancies
-2 years
-1 year
No change
+1 year
+2 years
2023
£m
£m
£m
£m
£m
Change in credit spreads
+50 bps
(72)
(53)
(35)
(17)
-
No change
(39)
(19)
-
19
38
-50 bps
(2)
19
40
60
81
2022
Change in credit spreads
+50 bps
(72)
(53)
(34)
(15)
2
No change
(40)
(20)
-
20
40
-50 bps
(2)
17
39
61
83
The defined benefit obligation is attributable to the different classes of AA section members in the following proportions:
2023
2022
Membership category
%
%
Active members
-
0.2
Deferred members
51.4
50.7
Pensioners and dependants
48.6
49.1
100.0
100.0
The experience history of the AA section is shown below:
2023
2022
History of defined benefit schemes
£m
£m
Fair value of plan assets
691
766
Present value of plan obligations
(551)
(531)
Net surplus
140
235
Experience losses on plan liabilities
(16)
(45)
Experience (losses)/gains on plan assets
(88)
(369)
Actual return on plan assets
(50)
(349)
Actual return on plan assets
(6.6%)
(30.3%)
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
107
6 Auditor’s remuneration
Amounts payable to the NWM Group’s auditors for statutory audit and other services are set out below:
2023
2022
£m
£m
Fees payable for:
- the audit of the NWM Group’s annual accounts
7.1
6.8
- the audit of NWM Plc’s subsidiaries
3.9
3.1
- audit-related assurance services
1.5
-
Total audit and audit-related assurance services fees
12.4
9.9
Other assurance services
0.1
-
Corporate finance services
0.3
0.2
Total other services
0.4
0.2
Fees payable to the auditor for non-audit services are disclosed in the consolidated financial statements of NatWest Group plc.
7 Tax
2023
2022
£m
£m
Current tax
(Charge)/credit for the year
(2)
43
(Under)/over provision in respect of prior years
(67)
28
(69)
71
Deferred tax
Credit for the year
52
143
UK tax rate change impact
-
25
Net increase/(decrease) in the carrying value of deferred tax assets in respect of UK
and Netherlands losses
12
(53)
Under provision in respect of prior years
(18)
(3)
Tax (charge)/credit for the year
(23)
183
Current tax for the year ended 31 December 2023 is based on blended rates of 23.5% for the standard rate of UK corporation tax and
4.25% for the UK banking surcharge.
The actual tax charge differs from the expected tax credit, computed by applying the standard rate of UK corporation tax of 23.5%
(2022 – 19%), as follows:
2023
2022
£m
£m
Expected tax credit
18
85
Losses and temporary differences in year where no deferred tax asset recognised
-
(18)
Foreign profits taxed at other rates
(15)
(5)
Items not allowed for tax:
- losses on disposal and write-downs
-
(1)
- UK bank levy
(3)
(5)
- regulatory and legal actions
1
(13)
- other disallowable items
(10)
(6)
Non-taxable RPI related uplift on index linked gilts
6
67
Other non-taxable items
(2)
3
Unrecognised losses brought forward and utilised
27
6
(Decrease)/increase in the carrying value of deferred tax assets in respect of:
- UK losses
(3)
(53)
- Netherlands losses
15
-
Banking surcharge
11
59
Tax on paid-in equity dividends
17
14
UK tax rate change impact
-
25
Adjustments in respect of prior years
(1)
(85)
25
Actual tax (charge)/credit
(23)
183
(1)
Prior year tax adjustments incorporate refinements to tax computations made on submission and agreement with the tax authorities and adjustments to provisions in respect of
uncertain tax positions.
On 11 July 2023, the UK Government, where the parent company is incorporated, enacted the Pillar 2 income taxes legislation
effective for the Group’s financial year beginning 1 January 2024. Under the legislation, NatWest Group plc will be required to pay, in
the UK, top-up tax on profits of its subsidiaries that are taxed at a Pillar 2 effective tax rate of less than 15 per cent. This legislation is
expected to have no material impact for NWM Group.
7 Tax continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
108
Judgement: tax contingencies
NWM Group’s corporate income tax credit and its provisions for corporate income taxes necessarily involve a significant degree of
estimation and judgement. The tax treatment of some transactions is uncertain and tax computations are yet to be agreed with the
relevant tax authorities. NWM Group recognises anticipated tax liabilities based on all available evidence and, where appropriate, in the
light of external advice. Any difference between the final outcome and the amounts provided will affect current and deferred corporate
income tax charges in the period when the matter is resolved.
For accounting policy information refer to Accounting policy 2.1.
Deferred tax
NWM Group
NWM Plc
2023
2022
2023
2022
£m
£m
£m
£m
Deferred tax asset (included in Other assets, Note 17)
(55)
(46)
-
-
Deferred tax liability (included in Other liabilities, Note 20)
54
101
49
92
Net deferred tax (asset)/liability
(1)
55
49
92
Net deferred tax (asset)/liability comprised:
NWM Group
Accelerated
Tax
losses
capital
Expense
Financial
carried
Pension
allowances
provisions
instruments (1)
forward
Other
Total
£m
£m
£m
£m
£m
£m
£m
At 1 January 2022
98
259
(29)
100
(104)
2
326
Charge/(credit) to
income statement:
2
(151)
6
(27)
57
1
(112)
Credit to other comprehensive income
(18)
-
-
(139)
-
-
(157)
Currency translation and other adjustments
-
-
-
-
(2)
-
(2)
At 31 December 2022
82
108
(23)
(66)
(49)
3
55
Charge/(credit) to
income statement
3
(33)
15
(8)
(6)
(17)
(46)
(Credit)/charge to other comprehensive income
(38)
-
-
41
-
4
7
Currency translation and other adjustments
(17)
-
-
-
-
(17)
At 31 December 2023
47
58
(8)
(33)
(55)
(10)
(1)
NWM Plc
Accelerated
Tax
losses
capital
Expense
Financial
carried
Pension
allowances
provisions
instruments (1)
forward
Other
Total
£m
£m
£m
£m
£m
£m
£m
At 1 January 2022
98
250
(29)
91
(56)
(2)
352
Charge/(credit) to
income statement
2
(148)
6
(18)
53
3
(102)
Credit to other comprehensive income
(18)
-
-
(139)
-
(1)
(158)
At 31 December 2022
82
102
(23)
(66)
(3)
-
92
Charge/(credit) to
income statement
3
(29)
15
(10)
3
(15)
(33)
(Credit)/charge to other comprehensive income
(38)
-
-
41
-
4
7
Currency translation and other adjustments
(17)
-
-
-
-
(17)
At 31 December 2023
47
56
(8)
(35)
-
(11)
49
(1)
The in-year movement predominantly relates to cash flow hedges.
Deferred tax assets in respect of unused tax losses are recognised if the losses can be used to offset probable future taxable profits
after taking into account the expected reversal of other temporary differences. Recognised deferred tax assets in respect of tax losses
are analysed below.
2023
2022
£m
£m
UK tax losses carried forward
- NWM Plc
-
3
Total
-
3
Overseas tax losses carried forward
- NWM N.V.
55
46
Total
55
49
Notes to the consolidated financial statements continued
7 Tax continued
Critical accounting policy: Deferred tax
The deferred tax liability of £54 million at 31 December 2023
(2022 – liability of £101 million) includes a deferred tax asset on
losses of £0 million (2022 - £3 million). The deferred tax asset of
£55 million as at 31 December 2023 (2022 - £46 million)
comprises losses which arose in the Netherlands.
The main UK corporation tax increased from 19% to 25%, and
the UK banking surcharge decreased from 8% to 3%, from 1 April
2023. NWM Group’s closing deferred tax assets and liabilities are
therefore recognised based on these rates.
Judgement
- NWM Group has considered the carrying value of
deferred tax assets and management considers that sufficient
sustainable taxable profits will be generated in future years to
recover the remaining deferred tax asset.
Estimate
– These estimates are partly based on forecast
performance. They have regard to inherent uncertainties. The
deferred tax asset in NWM Plc is supported by way of future
reversing taxable temporary differences on which deferred tax
liabilities are recognised at 31 December 2023.
UK tax losses
Under UK tax rules, tax losses can be carried forward indefinitely.
As the recognised tax losses in NWM Plc arose prior to 1 April
2015, credit in future periods is given against 25% of profits at
the main rate of UK corporation tax, excluding the Banking
Surcharge rate introduced by The Finance (No. 2) Act 2015.
NWM Plc
- A deferred tax asset of £0 million (2022 - £3 million)
has been recognised at 31 December 2023. The basis of
recognition in NWM plc is by way of future reversing taxable
temporary differences on which deferred tax liabilities are
recognised at 31 December 2023. Losses of £5,558 million have
not been recognised in the deferred tax balance at 31 December
2023.
Overseas tax losses
– A deferred tax asset of £55 million (2022 - £46
NWM N.V
.
million) has been recognised in respect of losses of £213 million of
total losses of £2,496 million carried forward at 31 December
2023. NWM N.V. Group considers it to be probable, based on its
5 year budget forecast, that future taxable profit will be available
against which the tax losses and tax credits can be partially
utilised. The tax losses and the tax credits have no expiry date.
Unrecognised deferred tax
Deferred tax assets of £3,460 million (2022 - £3,601 million) have
not been recognised in respect of tax losses and other deductible
temporary differences carried forward of £12,567 million (2022 -
£13,045 million) in jurisdictions where doubt exists over the
availability of future taxable profits. Of these losses and other
deductible temporary differences, £34 million expire within five
years and £4,488 million thereafter. The balance of tax losses
and other deductible temporary differences carried forward has
no expiry date.
There are no unrecognised deferred tax liabilities in respect of
retained earnings of overseas subsidiaries and held-over gains on
the incorporation of certain overseas branches.
8 Profit/(loss) dealt with in the accounts of NWM Plc
As permitted by section 408(3) of the Companies Act 2006, no income statement for NWM Plc has been presented as a primary
financial statement.
NWM Group
Annual Report and Accounts 2023
109
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
110
9 Financial instruments - classification
Judgement: classification of financial assets
Classification of financial assets between amortised cost and fair value through other comprehensive income requires a degree of
judgement in respect of business models and contractual cashflows.
The business model criteria is assessed at a portfolio level to determine whether assets are classified as held to collect or held to
collect and sell. Information that is considered in determining the applicable business model includes: the portfolio’s policies and
objectives; how the performance and risks of the portfolio are managed, evaluated and reported to management; and the
frequency, volume and timing of sales in prior periods, sales expectation for future periods, and the reasons for sales.
The contractual cash flow characteristics of financial assets are assessed with reference to whether the cash flows represent solely
payments of principal and interest (SPPI). A level of judgement is made in assessing terms that could change the contractual cash
flows so that it would not meet the condition for SPPI, including contingent and leverage features,
non-recourse arrangements and
features that could modify the time value of money.
We originate loans that include features that change the contractual cash flows based on the borrower meeting certain contractually
specified environmental, social and governance (ESG) targets. These are known as ESG-linked (or sustainability-linked) loans. As part
of the terms of these loans, the contractual interest rate is reduced or increased if the borrower meets (or fails to meet) specific
targets linked to the activity of the borrower for example reducing carbon emissions, increase the level of diversity at Board level, or
achieving a sustainable supply chain. ESG features are first assessed to ascertain whether the adjustment to the contractual cash
flows results in a de minimis exposure to risks or volatility in those contractual cash flows. If this is the case the classification of the loan
is not affected. If the effect of the ESG feature is assessed as being more than de minimis, we apply judgement to ensure that the ESG
features do not generate compensation for risks that are not in line with a basic lending arrangement. This includes amongst other
aspects a review of the consistency of the ESG targets with the asset or activity of the borrower, and consideration of the targets
within our risk appetite. Some of these loans are an integral part of NatWest Group’s climate and sustainable funding and financing
target.
For accounting policy information refer to Accounting policies 3.5, 3.7 and 3.9.
The following tables analyse NWM Group’s financial assets and liabilities in accordance with the categories of financial instruments in
IFRS 9.
NWM Group
MFVTPL
DFV
FVOCI
Amortised cost
Other assets
Total
Assets
£m
£m
£m
£m
£m
£m
Cash and balances at central banks
13,831
13,831
Trading assets
45,324
45,324
Derivatives
(1)
79,332
79,332
Settlement balances
7,227
7,227
Loans to banks - amortised cost
(2)
1,246
1,246
Loans to customers - amortised cost
12,986
12,986
Amounts due from holding company and fellow
subsidiaries
273
-
-
1,263
194
1,730
Other financial assets
48
5
4,115
11,555
15,723
Other assets
518
518
31 December 2023
124,977
5
4,115
48,108
712
177,917
Cash and balances at central banks
17,007
17,007
Trading assets
45,291
45,291
Derivatives
(1)
100,154
100,154
Settlement balances
2,558
2,558
Loans to banks - amortised cost
(2)
1,146
1,146
Loans to customers - amortised cost
10,171
10,171
Amounts due from holding company and fellow
subsidiaries
274
-
-
438
28
740
Other financial assets
80
-
6,040
5,750
11,870
Other assets
832
832
31 December 2022
145,799
-
6,040
37,070
860
189,769
9 Financial instruments – classification continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
111
NWM Group
Held-for-trading
DFV
Amortised cost
Other liabilities
Total
Liabilities
£m
£m
£m
£m
£m
Bank deposits
(3)
2,267
2,267
Customer deposits
6,998
6,998
Amounts due to holding company and fellow subsidiaries
1,028
-
4,696
78
5,802
Settlement balances
6,641
6,641
Trading liabilities
53,623
53,623
Derivatives
(1)
71,981
71,981
Other financial liabilities
3,106
20,468
23,574
Other liabilities
(4)
48
605
653
31 December 2023
126,632
3,106
41,118
683
171,539
Bank deposits
(3)
3,069
3,069
Customer deposits
3,614
3,614
Amounts due to holding company and fellow subsidiaries
1,129
-
4,884
204
6,217
Settlement balances
2,010
2,010
Trading liabilities
52,792
52,792
Derivatives
(1)
93,585
93,585
Other financial liabilities
2,722
18,381
21,103
Other liabilities
(4)
53
763
816
31 December 2022
147,506
2,722
32,011
967
183,206
(1)
Includes net hedging derivative assets of £118 million (2022 - £122 million) and net hedging derivative liabilities of £267 million (2022 - £170 million).
(2)
Includes items in the course of collection from other banks of £92 million (2022 - £156 million).
(3)
Includes items in the course of transmission to other banks of £81 million (2022 - £236 million).
(4)
Includes lease liabilities of £41 million (2022 - £47 million), held at amortised cost.
The following tables show the bank’s financial assets and financial liabilities in accordance with the categories of financial instruments
in IFRS 9.
NWM Plc
MFVTPL
FVOCI
Amortised cost
Other assets
Total
Assets
£m
£m
£m
£m
£m
Cash and balances at central banks
8,607
8,607
Trading assets
28,411
28,411
Derivatives
(1)
75,832
75,832
Settlement balances
2,168
2,168
Loans to banks - amortised cost
(2)
910
910
Loans to customers - amortised cost
12,104
12,104
Amounts due from holding company and fellow subsidiaries
3,313
-
2,925
234
6,472
Other financial assets
47
3,756
9,641
13,444
Investment in group undertakings
2,320
2,320
Other assets
390
390
31 December 2023
107,603
3,756
36,355
2,944
150,658
Cash and balances at central banks
13,467
13,467
Trading assets
27,301
27,301
Derivatives
(1)
96,258
96,258
Settlement balances
1,686
1,686
Loans to banks - amortised cost
(2)
815
815
Loans to customers - amortised cost
9,154
9,154
Amounts due from holding company and fellow subsidiaries
3,536
-
3,070
59
6,665
Other financial assets
79
4,870
5,428
10,377
Investment in group undertakings
2,626
2,626
Other assets
712
712
31 December 2022
127,174
4,870
33,620
3,397
169,061
9 Financial instruments – classification continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
112
NWM Plc
Held-for-trading
DFV
Amortised cost
Other liabilities
Total
Liabilities
£m
£m
£m
£m
£m
Bank deposits
(3)
1,909
1,909
Customer deposits
3,060
3,060
Amounts due to holding company and fellow subsidiaries
7,810
-
6,456
119
14,385
Settlement balances
400
400
Trading liabilities
34,079
34,079
Derivatives
(1)
69,404
69,404
Other financial liabilities
2,176
18,479
20,655
Other liabilities
(4)
7
446
453
31 December 2023
111,293
2,176
30,311
565
144,345
Bank deposits
(3)
2,936
2,936
Customer deposits
2,665
2,665
Amounts due to holding company and fellow subsidiaries
6,024
-
6,626
217
12,867
Settlement balances
1,133
1,133
Trading liabilities
33,225
33,225
Derivatives
(1)
90,754
90,754
Other financial liabilities
1,951
16,445
18,396
Other liabilities
(4)
8
559
567
31 December 2022
130,003
1,951
29,813
776
162,543
(1)
Includes net hedging derivative assets of £118 million (2022 - £122 million) and net hedging derivative liabilities of £267 million (2022 - £170 million).
(2)
Includes items in the course of collection from other banks of £90 million (2022 - £119 million).
(3)
Includes items in the course of transmission to other banks of £68 million (2022 - £236 million).
(4)
Includes lease liabilities of £2 million (2022 - £4 million), held at amortised cost.
Financial instruments – financial assets and liabilities that can be offset
The tables below present information on financial assets and liabilities that are offset on the balance sheet under IFRS or subject to
enforceable master netting agreements together with financial collateral received or given.
NWM Group
Instruments which can be offset
Potential for offset not recognised by IFRS
Net amount
Effect of
after effect
master
of netting
Instruments
netting
agreements
outside
Balance
and similar
Cash
Securities
and related
netting
Balance
Gross
IFRS offset
sheet
agreements
collateral
collateral
collateral
agreements
sheet total
2023
£m
£m
£m
£m
£m
£m
£m
£m
£m
Derivative assets
84,096
(5,242)
78,854
(60,165)
(13,233)
(3,084)
2,372
478
79,332
Derivative liabilities
76,721
(5,242)
71,479
(60,165)
(6,590)
(1,663)
3,061
502
71,981
Net position
7,375
-
7,375
-
(6,643)
(1,421)
(689)
(24)
7,351
Trading reverse repos
39,573
(16,257)
23,316
(664)
-
(22,461)
191
378
23,694
Trading repos
42,441
(16,257)
26,184
(664)
-
(25,520)
-
718
26,902
Net position
(2,868)
-
(2,868)
-
-
3,059
191
(340)
(3,208)
Non trading reverse repos
1,718
-
1,718
(5)
-
(1,713)
-
81
1,799
Non trading repos
867
-
867
(5)
-
(862)
-
2
869
Net position
851
-
851
-
-
(851)
-
79
930
2022
Derivative assets
102,003
(2,509)
99,494
(77,232)
(15,181)
(4,210)
2,871
660
100,154
Derivative liabilities
95,206
(2,509)
92,697
(77,232)
(9,584)
(1,185)
4,696
888
93,585
Net position
6,797
-
6,797
-
(5,597)
(3,025)
(1,825)
(228)
6,569
Trading reverse repos
35,612
(14,510)
21,102
(2,445)
-
(18,458)
199
435
21,537
Trading repos
33,767
(14,510)
19,257
(2,445)
-
(16,812)
-
4,483
23,740
Net position
1,845
-
1,845
-
-
(1,646)
199
(4,048)
(2,203)
Non trading reverse repos
801
(38)
763
-
-
(763)
-
98
861
Non trading repos
1,091
(38)
1,053
-
-
(1,053)
-
-
1,053
Net position
(290)
-
(290)
-
-
290
-
98
(192)
9 Financial instruments - classification continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
113
NWM Plc
Instruments which can be offset
Potential for offset not recognised by IFRS
Net amount
after effect
of netting
Instruments
Effect of
agreements
outside
Balance
master
Cash
Securities
and related
netting
Balance
Gross
IFRS offset
sheet
netting
collateral
collateral
collateral
agreements
sheet total
2023
£m
£m
£m
£m
£m
£m
£m
£m
£m
Derivative assets
89,762
(14,325)
75,437
(59,881)
(10,752)
(2,688)
2,116
395
75,832
Derivative liabilities
82,553
(13,544)
69,009
(59,881)
(5,376)
(1,141)
2,611
395
69,404
Net position
(1)
7,209
(781)
6,428
-
(5,376)
(1,547)
(495)
-
6,428
Trading reverse repos
12,858
(1,898)
10,960
(130)
-
(10,830)
-
355
11,315
Trading repos
13,306
(1,898)
11,408
(130)
-
(11,278)
-
717
12,125
Net position
(448)
-
(448)
-
-
448
-
(362)
(810)
Non trading reverse repos
1,718
-
1,718
(5)
-
(1,713)
-
81
1,799
Non trading repos
867
-
867
(5)
-
(862)
-
2
869
Net position
851
-
851
-
-
(851)
-
79
930
2022
Derivative assets
109,877
(14,187)
95,690
(77,254)
(12,274)
(3,636)
2,526
568
96,258
Derivative liabilities
103,312
(13,260)
90,052
(77,254)
(7,824)
(810)
4,164
702
90,754
Net position
(1)
6,565
(927)
5,638
-
(4,450)
(2,826)
(1,638)
(134)
5,504
Trading reverse repos
12,545
(4,128)
8,417
(181)
-
(8,228)
8
142
8,559
Trading repos
8,361
(4,128)
4,233
(181)
-
(4,052)
-
4,483
8,716
Net position
4,184
-
4,184
-
-
(4,176)
8
(4,341)
(157)
Non trading reverse repos
801
(38)
763
-
-
(763)
-
98
861
Non trading repos
1,091
(38)
1,053
-
-
(1,053)
-
-
1,053
Net position
(290)
-
(290)
-
-
290
-
98
(192)
(1)
The net IFRS offset balance of £781 million (2022 - £927 million) relates to variation margin netting reflected on other balance sheet lines.
Notes to the consolidated financial statements continued
10 Financial instruments - valuation
Page
Financial instruments
Critical accounting policy: Fair value
114
Valuation
Fair value hierarchy
(D)
115
Valuation techniques
(D)
115
Inputs to valuation models
(D)
115
Valuation control
(D)
116
Key areas of judgement
(D)
116
Assets and liabilities split by fair value
hierarchy level
(T)
117
Valuation adjustments
Fair value adjustments made
(T)
119
Funding valuation adjustments (FVA)
(D)
119
Credit valuation adjustments (CVA)
(D)
119
Bid-offer
(D)
119
Product and deal specific
(D)
119
Own credit
(D)
119
Level 3 additional information
Level 3 ranges of unobservable inputs
(D)
120
Level 3 instruments, valuation
techniques and inputs
(T)
120
Level 3 sensitivities
(D)
121
Alternative assumptions
(D)
121
Other considerations
(D)
121
High and low range of fair value of
level 3 assets and liabilities
(T)
122
Movement in Level 3 assets and liabilities
over the reporting period
(D)
123
Movement in level 3 assets and liabilities
(T)
123
Fair value of financial instruments measured
at amortised cost
Fair value of financial instruments
measured at amortised cost on the balance sheet
(T)
125
(D) = Descriptive; (T) = Table
Critical accounting policy: Fair value - financial
instruments
Financial instruments classified as mandatory fair value through
profit or loss; held-for-trading; designated fair value through
profit or loss and fair value through other comprehensive income
are recognised in the financial statements at fair value. All
derivatives are measured at fair value.
Fair value is the price that would be received to sell an asset or
paid to transfer a liability in an orderly transaction between
market participants at the measurement date. A fair value
measurement considers the characteristics of the asset or liability
and the assumptions that a market participant would consider
when pricing the asset or liability.
NWM Group manages some portfolios of financial assets and
financial liabilities based on its net exposure to either market or
credit risk. In these cases, the fair value is derived from the net
risk exposure of that portfolio with portfolio level adjustments
applied to incorporate bid-offer spreads, counterparty credit risk,
and funding costs (see ‘Valuation Adjustments’).
Where the market for a financial instrument is not active, fair
value is established using a valuation technique. These valuation
techniques involve a degree of estimation, the extent of which
depends on the instrument’s complexity and the availability of
market-based data. The complexity and uncertainty in the
financial instrument’s fair value is categorised using the fair value
hierarchy.
For accounting policy information refer to Accounting policies 2.2,
3.5 and 3.9.
NWM Group
Annual Report and Accounts 2023
114
10 Financial instruments – valuation continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
115
Fair value hierarchy
Financial instruments carried at fair value have been classified
under the fair value hierarchy. The classification ranges from
level 1 to level 3, with more expert judgement and price
uncertainty for those classified at level 3.
The determination of an instrument’s level cannot be made at a
global product level as a single product type can be in more than
one level. For example, a single name corporate credit default
swap could be in level 2 or level 3 depending on the level of
market activity for the referenced entity.
Level 1
– instruments valued using unadjusted quoted prices in
active and liquid markets, for identical financial instruments.
Examples include government bonds, listed equity shares and
certain exchange-traded derivatives.
Level 2
- instruments valued using valuation techniques that have
observable inputs. Observable inputs are those that are readily
available with limited adjustments required. Examples include
most government agency securities, investment-grade corporate
bonds, certain mortgage products – including collateralised loan
obligations (CLOs), most bank loans, repos and reverse repos,
state and municipal obligations, most notes issued, certain money
market securities, loan commitments and most over the counter
(OTC) derivatives.
Level 3
- instruments valued using a valuation technique where
at least one input which could have a significant effect on the
instrument’s valuation, is not based on observable market data.
Examples include non-derivative instruments which trade
infrequently, certain syndicated and commercial mortgage loans,
private equity, and derivatives with unobservable model inputs.
Valuation techniques
NWM Group derives the fair value of its instruments differently
depending on whether the instrument is a non-modelled or a
modelled product.
Non-modelled products
are valued directly from a price input,
typically on a position-by-position basis. Examples include equities
and most debt securities.
Non-modelled products can fall into any fair value levelling
hierarchy depending on the observable market activity, liquidity,
and assessment of valuation uncertainty of the instruments. The
assessment of fair value and the classification of the instrument
to a fair value level is subject to the valuation controls discussed
in the Valuation control section.
Modelled products
valued using a pricing model range in
complexity from comparatively vanilla products such as interest
rate swaps and options (e.g., interest rate caps and floors)
through to more complex derivatives (e.g., balance guaranteed
swaps).
For modelled products the fair value is derived using the model
and the appropriate model inputs or parameters, as opposed to a
cash price equivalent. Model inputs are taken either directly or
indirectly from available data, where some inputs are also
modelled.
Fair value classification of modelled instruments is either level 2
or level 3, depending on the product/model combination, the
observability and quality of input parameters and other factors.
All these must be assessed to classify a position. The modelled
product is assigned to the lowest fair value hierarchy level of any
significant input used in that valuation.
Most derivative instruments, for example vanilla interest rate
swaps, foreign exchange swaps and liquid single name credit
derivatives, are classified as level 2. This is because they are
vanilla products valued using standard market models and with
observable inputs. Level 2 products range from vanilla to more
complex products, where the more complex products remain
classified as level 2 due to the low materiality of any
unobservable inputs.
Inputs to valuation models
When using valuation techniques, the fair value can be
significantly affected by the choice of valuation model and
underlying assumptions. Factors considered include the cashflow
amounts and timing of those cash flows, and application of
appropriate discount rates, incorporating both funding and credit
risk. Values between and beyond available data points are
obtained by interpolation and extrapolation. The principal inputs
to these valuation techniques are as follows:
Bond prices
- quoted prices are generally available for
government bonds, certain corporate securities, and some
mortgage-related products.
Credit spreads/margins
- these reflect credit default swap levels
or the return required over a benchmark rate or index to
compensate for the referenced credit risk. Where available, these
are derived from the price of credit default swaps or other credit-
based instruments, such as debt securities. When direct prices
are not available; credit spreads/margins are determined with
reference to available prices of entities with similar
characteristics.
Interest rates
- these are principally based on interest rate swap
prices referencing Interbank Offered Rates (IBOR) and overnight
interest rates, including SONIA (Sterling Overnight Interbank
Average Rate). Other quoted interest rates may also be used
from both the bond, and futures markets.
Foreign currency exchange rates
- there are observable prices
both for spot and forward contracts and futures in the world's
major currencies.
Equity and equity index prices
- quoted prices are generally
readily available for equity shares listed on the world's major
stock exchanges and for major indices on such shares.
Price volatilities and correlations
- volatility is a measure of the
tendency of a price to change with time. Correlation measures
the degree which two or more prices or variables are observed
to move together. Variables that move in the same direction
show positive correlation; those that move in opposite directions
are negatively correlated.
Prepayment rates
- rates used to reflect how fast a pool of
assets prepay. The fair value of a financial instrument that can be
prepaid by the issuer or borrower differs from that of an
instrument that cannot be prepaid. When valuing prepayable
instruments, the value of this prepayment option is considered.
Recovery rates/loss given default
- these are used as an input to
valuation models and reserves for asset-backed securities and
other credit products as an indicator of severity of losses on
default. Recovery rates are primarily sourced from market data
providers or the value of the underlying collateral
.
10 Financial instruments – valuation continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
116
Valuation control
NWM Group's control environment for the determination of the
fair value of financial instruments includes formalised procedures
for the review and validation of fair values. The review of market
prices and inputs is performed by an independent price
verification (IPV) team.
IPV is a key element of the control environment. Valuations are
first performed by the business which entered into the
transaction. These valuations are then reviewed by the IPV team,
independent of those trading the financial instruments, in light of
available pricing evidence.
Independent pricing data is collated from a range of sources.
Each source is reviewed for quality and the independent data
applied in the IPV processes using a formalised input quality
hierarchy. Consensus services are one source of independent
data and encompass interest rate, currency, credit, and bond
markets, providing comprehensive coverage of vanilla products
and a wide selection of exotic products.
Where measurement differences are identified through the IPV
process these are grouped by the quality hierarchy of the
independent data. If the size of the difference exceeds defined
thresholds, an adjustment is made to bring the valuation to within
the independently calculated fair value range.
IPV takes place at least monthly, for all fair value financial
instruments. The IPV control includes formalised reporting and
escalation of any valuation differences in breach of established
thresholds.
The quality and completeness of the information gathered in the
IPV process gives an indication as to the liquidity and valuation
uncertainty of an instrument and forms part of the information
considered when determining fair value hierarchy classifications.
Initial fair value level classification of a financial instrument is
carried out by the IPV team. These initial classifications are
subject to senior management review. Particular attention is paid
to instruments transferring from one level to another, new
instrument classes or products, instruments where the
transaction price is significantly different from the fair value and
instruments where valuation uncertainty is high.
Valuation Committees are made up of valuation specialists and
senior business representatives from various functions and
oversee pricing, reserving and valuations issues. These
committees meet monthly to review and ratify any methodology
changes. The Executive Valuation Committee meets quarterly to
address key material and subjective valuation issues, to review
items escalated by Valuation Committees and to discuss other
relevant industry matters.
The Group model risk policy sets the policy for model
documentation, testing and review. Governance of the model risk
policy is carried out by the Group model risk oversight
committee, which comprises model risk owners and independent
model experts. All models are required to be independently
validated in accordance with the Model Risk Policy.
Key areas of judgement
Over the years the business has simplified, with most products
classified as level 1 or 2 of the fair value hierarchy. However, the
diverse range of products historically traded by NWM Group
means some products remain classified as level 3. Level 3
indicates a significant level of pricing uncertainty, where expert
judgement is used. As such, extra disclosures are required in
respect of level 3 instruments.
In general, the degree of expert judgement used and hence
valuation uncertainty depends on the degree of liquidity of an
instrument or input.
Where markets are liquid, little judgement is required. However,
when the information regarding the liquidity in a particular
market is not clear, a judgement may need to be made. For
example, for an equity traded on an exchange, daily volumes of
trading can be seen, but for an OTC derivative, assessing the
liquidity of the market with no central exchange is more
challenging.
A key related matter is where a market moves from liquid to
illiquid or vice versa. Where this movement is considered
temporary, the fair value level is not changed. For example, if
there is little market trading in a product on a reporting date but
at the previous reporting date and during the intervening period
the market has been liquid. In this case, the instrument will
continue to be classified at the same level in the hierarchy.
This is to provide consistency so that transfers between levels
are driven by genuine changes in market liquidity and do not
reflect short term or seasonal effects. Material movements
between levels are reviewed quarterly by the business and IPV.
The breadth and depth of the IPV data allows for a rules-based
quality assessment to be made of market activity, liquidity, and
pricing uncertainty, which assists with the process of allocation to
an appropriate level. Where suitable independent pricing
information is not readily available, the quality assessment will
result in the instrument being assessed as level 3.
10 Financial instruments – valuation continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
117
The table below shows the assets and liabilities held by NWM Group split by fair value hierarchy level. Level 1 are considered the most
liquid instruments, and level 3 the most illiquid, valued using expert judgement and so carry the most significant price uncertainty.
NWM Group
2023
2022
Level 1
Level 2
Level 3
Total
Level 1
Level 2
Level 3
Total
£m
£m
£m
£m
£m
£m
£m
£m
Assets
Trading assets
Loans
-
33,161
209
33,370
-
34,974
395
35,369
Securities
8,447
3,493
14
11,954
7,463
2,458
1
9,922
Derivatives
Interest rate
1
44,272
670
44,943
5
53,365
727
54,097
Foreign exchange
-
34,143
65
34,208
-
45,707
114
45,821
Other
-
73
108
181
-
54
182
236
Amounts due from holding company and fellow
-
273
-
273
-
274
-
274
subsidiaries
Other financial assets
Loans
-
-
111
111
-
34
160
194
Securities
2,905
1,058
94
4,057
4,958
891
77
5,926
Total financial assets held at fair value
11,353
116,473
1,271
129,097
12,426
137,757
1,656
151,839
As % of total fair value assets
9%
90%
1%
8%
91%
1%
Liabilities
Amounts due to holding company and fellow
-
1,028
-
1,028
-
1,129
-
1,129
subsidiaries
Trading liabilities
Deposits
-
43,113
1
43,114
-
42,470
1
42,471
Debt securities in issue
-
706
-
706
-
797
-
797
Short positions
7,936
1,865
2
9,803
7,462
2,062
-
9,524
Derivatives
Interest rate
-
37,838
454
38,292
2
47,668
702
48,372
Foreign exchange
-
33,306
58
33,364
-
44,840
98
44,938
Other
-
137
188
325
-
76
199
275
Other financial liabilities
Deposits
-
1,259
-
1,259
-
1,050
-
1,050
Debt securities in issue
-
1,607
3
1,610
-
1,327
-
1,327
Subordinated liabilities
-
237
-
237
-
345
-
345
Total financial liabilities held at fair value
7,936
121,096
706
129,738
7,464
141,764
1,000
150,228
As % of total fair value liabilities
6%
93%
1%
5%
94%
1%
10 Financial instruments – valuation continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
118
NWM Plc
2023
2022
Level 1
Level 2
Level 3
Total
Level 1
Level 2
Level 3
Total
£m
£m
£m
£m
£m
£m
£m
£m
Assets
Trading assets
Loans
-
19,030
193
19,223
-
19,618
347
19,965
Securities
5,804
3,370
14
9,188
5,025
2,310
1
7,336
Derivatives
Interest rate
-
40,594
643
41,237
-
48,804
692
49,496
Foreign Exchange
-
34,350
65
34,415
-
46,414
114
46,528
Other
-
72
108
180
-
52
182
234
Amounts due from holding company and fellow
subsidiaries
-
3,313
-
3,313
-
3,536
-
3,536
Other financial assets
Loans
-
-
111
111
-
34
133
167
Securities
2,604
1,001
87
3,692
4,082
628
72
4,782
Total financial assets held at fair value
8,408
101,730
1,221
111,359
9,107
121,396
1,541
132,044
As % of total fair value assets
8%
91%
1%
7%
92%
1%
Liabilities
Amounts due to holding company and fellow
-
7,810
-
7,810
-
6,024
-
6,024
subsidiaries
Trading liabilities
Deposits
-
25,706
1
25,707
-
24,337
1
24,338
Debt securities in issue
-
706
-
706
-
797
-
797
Short positions
5,859
1,805
2
7,666
6,113
1,977
-
8,090
Derivatives
Interest rate
-
35,225
352
35,577
-
44,330
560
44,890
Foreign Exchange
-
33,450
58
33,508
-
45,494
98
45,592
Other
-
131
188
319
-
73
199
272
Other financial liabilities
Deposits
-
1,015
-
1,015
-
770
-
770
Debt securities in issue
-
1,161
-
1,161
-
1,059
-
1,059
Subordinated liabilities
-
-
-
-
-
122
-
122
Total financial liabilities held at fair value
5,859
107,009
601
113,469
6,113
124,983
858
131,954
As % of total fair value liabilities
5%
94%
1%
5%
94%
1%
(1)
Transfers between levels are deemed to have occurred at the beginning of the quarter in which the instrument was transferred.
(2)
For an analysis of debt securities held at mandatory fair value through profit or loss by issuer as well as ratings and derivatives, by type and contract, refer to Risk and capital
management – Credit risk.
10 Financial instruments – valuation continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
119
Valuation adjustments
When valuing financial instruments in the trading book,
adjustments are made to mid-market valuations to cover bid-
offer spread, funding and credit risk. These adjustments are
presented in the table below:
NWM Group
2023
2022
£m
£m
Funding valuation adjustments
9
7
Credit valuation adjustments
236
300
Bid-offer
70
103
Product and deal specific
104
140
Total
419
550
NWM Plc
2023
2022
£m
£m
Funding valuation adjustments
23
21
Credit valuation adjustments
126
181
Bid-offer
66
93
Product and deal specific
105
145
Total
320
440
The decrease in CVA was driven by credit spreads tightening
and a reduction in exposures, primarily due to portfolio ageing,
partially offset by new trade activity. Interest rates tightening,
trade restructuring and trade specific valuation adjustments were
the drivers of the decrease in product and deal specific. The
decrease in bid-offer was driven by risk reduction.
Funding valuation adjustments (FVA)
FVA represents an estimate of the adjustment that a market
participant would make to incorporate funding costs and benefits
that arise in relation to derivative exposures. FVA is calculated as
a portfolio level adjustment and can result in either a funding
charge (positive) or funding benefit (negative).
Funding levels are applied to estimated potential future
exposures. For uncollateralised derivatives, the exposure reflects
the future valuation of the derivative. For collateralised
derivatives, the exposure reflects the difference between the
future valuation of the derivative and the level of collateral
posted.
Credit valuation adjustments (CVA)
CVA represents an estimate of the adjustment to fair value that
is made to incorporate the counterparty credit risk inherent in
derivative exposures. CVA is calculated on a portfolio basis
reflecting an estimate of the amount a third party would charge
to assume the credit risk.
Collateral held under a credit support agreement is factored into
the CVA calculation. In such cases where NWM Group holds
collateral against counterparty exposures, CVA is held to the
extent that residual risk remains.
FVA and CVA are actively managed by a credit and market risk
hedging process, and therefore movements in CVA and FVA are
partially offset by trading revenue on the hedges.
Bid-offer
Fair value positions are required to be marked to exit levels,
represented by bid (long positions) or offer (short positions) levels.
Non-derivative positions are typically marked directly to bid or
offer prices. However derivative exposures are adjusted to exit
levels by taking bid-offer reserves calculated on a portfolio basis.
The reserving approach is based on current market bid-offer
spreads and standard market bucketing of risk.
Bid-offer spreads vary by maturity and risk type to reflect
different spreads in the market. For positions where there is no
observable quote, the bid-offer spreads are widened in
comparison to proxies to reflect reduced liquidity or observability.
Netting is applied on a portfolio basis to reflect the value at which
NWM Group believes it could exit the net risk of the portfolio,
rather than the sum of exit costs for each of the portfolio’s
individual trades. This is applied where the asset and liability
positions are managed as a portfolio for risk and reporting
purposes.
Product and deal specific
On initial recognition of financial assets and liabilities valued using
valuation techniques which have a significant dependence on
information other than observable market data, any difference
between the transaction price and that derived from the
valuation technique is deferred. Such amounts are recognised in
the income statement over the life of the transaction; when
market data becomes observable; or when the transaction
matures or is closed out as appropriate. On 31 December 2023,
net gains of £78 million (2022 - £74 million) were carried forward.
During the year, net gains of £119 million (2022 - £97 million)
were deferred and £115 million (2022 - £94 million) were
recognised in the income statement.
Where system generated valuations do not accurately reflect
market prices, manual valuation adjustments are applied either at
a position or portfolio level. Manual adjustments are subject to
the scrutiny of independent control teams and are subject to
monthly review by senior management.
Own Credit
NWM Group considers the effect of its own credit standing when
valuing financial liabilities recorded at fair value. Own credit
spread adjustments are made when valuing issued debt held at
fair value, including issued structured notes. An own credit
adjustment is applied to positions where it is believed that
counterparties would consider NWM Group’s creditworthiness
when pricing trades.
10 Financial instruments – valuation continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
120
Level 3 additional information
For illiquid assets and liabilities, classified as level 3, additional information is provided on the valuation techniques used and price
sensitivity of the products to those inputs. This is to enable the reader to gauge the level of uncertainty that arises from positions with
significant unobservable inputs or modelling parameters.
Level 3 ranges of unobservable inputs
The table below provides additional information on level 3 instruments and inputs. This shows the valuation technique used for the fair
value calculation, the unobservable inputs and input range.
NWM Group
2023
2022
Financial instrument
Valuation technique
Unobservable inputs
Units
Low
High
Low
High
Trading assets and Other financial assets
Loans
Price-based
Price
%
-
123
-
113
Discount cash flow
Credit spreads
bps
49
119
56
114
Debt securities
Price-based
Price
%
-
119
-
255
Equity Shares
Price-based
Price
GBP
-
32,142
-
34,027
Net asset valuation
Fund NAV
%
80
120
80
120
Derivative assets and liabilities
Credit derivatives
Credit derivative pricing
Credit spreads
bps
13
600
7
530
Option pricing
Correlation
%
(15)
95
(15)
95
Volatility
%
30
80
30
80
Upfront points
%
-
99
-
99
Recovery rate
%
-
60
-
60
Interest rate & FX
Option pricing
Correlation
%
(50)
99
(50)
100
derivatives
Volatility
%
30
111
30
127
Constant
prepayment rate
%
2
22
2
21
Mean reversion
-
%
20
-
92
Inflation volatility
%
2
2
1
2
Inflation rate
%
2
3
2
3
NWM Plc
2023
2022
Financial instrument
Valuation technique
Unobservable inputs
Units
Low
High
Low
High
Trading assets and Other financial assets
Loans
Price-based
Price
%
-
123
-
113
Discount cash flow
Credit spreads
bps
49
119
56
114
Debt securities
Price-based
Price
%
-
104
-
255
Equity Shares
Price-based
Price
GBP
-
6,744
-
5,369
Derivative assets and liabilities
Credit derivatives
Credit derivative pricing
Credit spreads
bps
13
600
7
530
Option pricing
Correlation
%
(15)
95
(15)
95
Volatility
%
30
80
30
80
Upfront points
%
-
99
-
99
Recovery rate
%
-
60
-
60
Interest rate & FX
Option pricing
Correlation
%
(50)
99
(50)
100
derivatives
Volatility
%
30
111
30
127
Constant
prepayment rate
%
2
22
2
21
Mean reversion
%
-
20
-
92
Inflation volatility
%
2
2
1
2
Inflation rate
%
2
3
2
3
(1)
Valuation: for private equity investments, values may be estimated by looking at past prices of similar stocks and from valuation statements where valuations are usually derived from
earnings measures such as EBITDA or net asset value (NAV). Similarly for equity or bond fund investments, prices may be estimated from valuation or credit statements using NAV or
similar measures.
(2)
NWM Group and NWM Plc do not have any material liabilities measured at fair value that are issued with an inseparable third party credit enhancement
.
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
121
10 Financial instruments – valuation continued
Level 3 sensitivities
The level 3 sensitivities presented below are calculated at a trade
or low-level portfolio basis rather than an overall portfolio basis.
As individual sensitivities are aggregated with no reflection of the
correlated nature between instruments, the overall portfolio
sensitivity may not be accurately reflected. For example, some
portfolios may be negatively correlated to others, where a
downwards movement in one asset would produce an upwards
movement in another. However, due to the additive presentation
of the above figures this correlation impact cannot be displayed.
As such, the actual potential downside sensitivity of the total
portfolio may be less than the non-correlated sum of the additive
figures as shown in the below table.
Alternative assumptions
Reasonably plausible alternative assumptions of unobservable
inputs are determined based on a specified target level of
certainty of 90%.
Alternative assumptions are determined with reference to all
available evidence including consideration of the following: quality
of independent pricing information considering consistency
between different sources, variation over time, perceived
tradability or otherwise of available quotes; consensus service
dispersion ranges; volume of trading activity and market bias
(e.g. one-way inventory); day 1 profit or loss arising on new
trades; number and nature of market participants; market
conditions; modelling consistency in the market; size and nature
of risk; length of holding of position; and market intelligence.
Other considerations
Whilst certain inputs used to calculate CVA, FVA and own credit
adjustments are not based on observable market data, the
uncertainty of these inputs is not considered to have a significant
effect on the net valuation of the related derivative portfolios and
issued debt.
As such, the fair value levelling of the derivative portfolios and
issued debt is not determined by CVA, FVA or own credit inputs.
In addition, any fair value sensitivity driven by these inputs is not
included in the level 3 sensitivities presented.
10 Financial instruments – valuation continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
122
The table below shows the high and low range of fair value of the level 3 assets and liabilities. This range incorporates the range of fair
value inputs as described in the previous table.
NWM Group
2023
2022
Level 3
Favourable
Unfavourable
Level 3
Favourable
Unfavourable
£m
£m
£m
£m
£m
£m
Assets
Trading assets
Loans
209
-
-
395
10
(10)
Securities
14
-
-
1
-
-
Derivatives
Interest rate
670
20
(20)
727
30
(30)
Foreign exchange
65
-
-
114
10
(10)
Other
108
10
(10)
182
10
(10)
Other financial assets
Loans
111
-
-
160
-
-
Securities
94
10
(10)
77
10
(10)
Total
1,271
40
(40)
1,656
70
(70)
Liabilities
Trading liabilities
Deposits
1
-
-
1
-
-
Short positions
2
-
-
-
-
-
Derivatives
Interest rate
454
10
(10)
702
30
(30)
Foreign exchange
58
-
-
98
-
-
Other
188
10
(10)
199
-
-
Other financial liabilities - debt
securities in issue
3
-
-
-
-
-
Total
706
20
(20)
1,000
30
(30)
NWM Plc
2023
2022
Level 3
Favourable
Unfavourable
Level 3
Favourable
Unfavourable
£m
£m
£m
£m
£m
£m
Assets
Trading assets
Loans
193
-
-
347
-
-
Securities
14
-
-
1
-
-
Derivatives
Interest rate
643
20
(20)
692
30
(30)
Foreign exchange
65
-
-
114
10
(10)
Other
108
10
(10)
182
10
(10)
Other financial assets
Loans
111
-
-
133
-
-
Securities
87
10
(10)
72
10
(10)
Total
1,221
40
(40)
1,541
60
(60)
Liabilities
Trading liabilities
Deposits
1
-
-
1
-
-
Short positions
2
-
-
-
-
-
Derivatives
Interest rate
352
10
(10)
560
20
(20)
Foreign exchange
58
-
-
98
10
(10)
Other
188
10
(10)
199
-
-
Total
601
20
(20)
858
30
(30)
10 Financial instruments – valuation continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
123
Movement in Level 3 assets and liabilities over the reporting period
The following table shows the movement in level 3 assets and liabilities in the year.
NWM Group
Other
Other
Other
Other
Derivatives
trading
financial
Total
Derivatives
trading
financial
Total
assets
assets (2)
assets (3)
assets
liabilities
liabilities (2)
liabilities
liabilities
2023
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January
1,023
396
237
1,656
999
1
-
1,000
Amounts recorded in the income
statement
(1)
(150)
(89)
3
(236)
(323)
-
-
(323)
Amount recorded in the statement of
comprehensive income
-
-
20
20
-
-
-
-
Level 3 transfers in
6
15
-
21
7
2
-
9
Level 3 transfers out
(5)
(32)
-
(37)
(9)
(2)
-
(11)
Purchases/originations
178
8
3
189
195
2
3
200
Settlements/other decreases
(70)
(8)
(7)
(85)
(51)
-
-
(51)
Sales
(137)
(66)
(52)
(255)
(116)
-
-
(116)
Foreign exchange and other adjustments
(2)
(1)
1
(2)
(2)
-
-
(2)
At 31 December
843
223
205
1,271
700
3
3
706
Amounts recorded in the income
statement in respect of balances held
at period end - unrealised
67
(39)
3
31
(130)
-
-
(130)
2022
At 1 January
1,066
742
156
1,964
614
3
-
617
Amounts recorded in the income
statement
(1)
26
30
(6)
50
399
(1)
-
398
Amount recorded in the statement of
comprehensive income
-
-
(41)
(41)
-
-
-
-
Level 3 transfers in
193
1
34
228
78
3
-
81
Level 3 transfers out
(122)
(147)
(35)
(304)
(61)
(3)
-
(64)
Purchases/originations
355
274
130
759
387
1
-
388
Settlements/other decreases
(40)
(75)
-
(115)
(41)
-
-
(41)
Sales
(458)
(432)
(2)
(892)
(383)
(2)
-
(385)
Foreign exchange and other adjustments
3
3
1
7
6
-
-
6
At 31 December
1,023
396
237
1,656
999
1
-
1,000
Amounts recorded in the income
statement in respect of balances held
at period end - unrealised
26
30
(6)
50
399
(1)
-
398
10 Financial instruments – valuation continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
124
NWM Plc
Other
Other
Other
Other
Derivatives
trading
financial
Total
Derivatives
trading
financial
Total
assets
assets (2)
assets (3)
assets
liabilities
liabilities (2)
liabilities
liabilities
2023
£m
£m
£m
£m
£m
£m
£m
£m
At 1 January
988
348
205
1,541
857
1
-
858
Amounts recorded in the income
statement
(1)
(142)
(92)
3
(231)
(251)
-
-
(251)
Amount recorded in the statement of
comprehensive income
-
-
21
21
-
-
-
-
Level 3 transfers in
6
15
-
21
5
2
-
7
Level 3 transfers out
(5)
(7)
-
(12)
(6)
(2)
-
(8)
Purchases/originations
178
2
-
180
151
2
-
153
Settlements/other decreases
(70)
(1)
(7)
(78)
(43)
-
-
(43)
Sales
(137)
(60)
(26)
(223)
(116)
-
-
(116)
Foreign exchange and other adjustments
(2)
2
2
2
1
-
-
1
At 31 December
816
207
198
1,221
598
3
-
601
Amounts recorded in the income statement
in respect of balances held at period end
- unrealised
62
(39)
3
26
(108)
-
-
(108)
2022
At 1 January
990
670
154
1,814
583
3
-
586
Amounts recorded in the income
statement
(1)
52
29
(6)
75
320
(1)
-
319
Amount recorded in the statement of
comprehensive income
-
-
(38)
(38)
-
-
-
-
Level 3 transfers in
193
1
34
228
76
3
-
79
Level 3 transfers out
(122)
(146)
(34)
(302)
(59)
(3)
-
(62)
Purchases/originations
352
161
98
611
347
-
-
347
Settlements/other decreases
(32)
(60)
(1)
(93)
(36)
-
-
(36)
Sales
(445)
(307)
(2)
(754)
(373)
(2)
-
(375)
Foreign exchange and other adjustments
-
-
-
-
(1)
1
-
-
At 31 December
988
348
205
1,541
857
1
-
858
Amounts recorded in the income statement
in respect of balances held at period end
- unrealised
52
29
(6)
75
320
(1)
-
319
(1)
For NWM Group, net gains on trading assets and liabilities of £84 million (2022 – £342 million losses) were recorded in income from trading activities. Net gains on other instruments
of £3 million (2022 – £6 million losses) were recorded in other operating income and interest income as appropriate. For NWM Plc, net gains on trading assets and liabilities of £17
million (2022 – £238 million losses) were recorded in income from trading activities. Net gains on other instruments of £3 million (2022 – £6 million losses) were recorded in other
operating income and interest income as appropriate.
(2)
Other trading assets and other trading liabilities comprise assets and liabilities held at fair value in trading portfolios.
(3)
Other financial assets comprise fair value through other comprehensive income, designated as at fair value through profit or loss and other fair value through profit or loss.
10 Financial instruments – valuation continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
125
Fair value of financial instruments measured at amortised cost on the balance sheet
The following table shows the carrying value and fair value of financial instruments measured at amortised cost on the balance sheet.
NWM Group
Items where fair
Carrying
Fair
Fair value hierarchy level
value approximates
value
value
Level 2
Level 3
carrying value
2023
£bn
£bn
£bn
£bn
£bn
Financial assets
Cash and balances at central banks
13.8
13.8
-
-
13.8
Settlement balances
7.2
7.2
-
-
7.2
Loans to banks
1.2
1.2
0.2
0.1
0.9
Loans to customers
13.0
13.0
1.6
11.4
-
Amounts due from holding company
and fellow subsidiaries
1.3
1.3
-
1.2
0.1
Other financial assets - securities
11.6
11.5
0.9
10.6
-
2022
Financial assets
Cash and balances at central banks
17.0
17.0
-
-
17.0
Settlement balances
2.6
2.6
-
-
2.6
Loans to banks
1.1
1.1
0.5
0.5
0.1
Loans to customers
10.2
10.1
0.9
9.2
-
Amounts due from holding company
and fellow subsidiaries
0.4
0.4
-
0.3
0.1
Other financial assets - securities
5.8
5.7
-
5.7
-
2023
Financial liabilities
Bank deposits
2.3
2.3
0.5
1.7
0.1
Customer deposits
7.0
7.0
0.4
6.5
0.1
Amounts due to holding company
and fellow subsidiaries
4.7
4.7
4.1
0.6
-
Settlement balances
6.6
6.6
-
-
6.6
Other financial liabilities
Debt securities in issue
20.4
20.2
16.5
3.7
-
Subordinated liabilities
-
-
-
-
-
2022
Financial liabilities
Bank deposits
3.1
3.1
0.8
2.0
0.3
Customer deposits
3.6
3.6
0.3
3.2
0.1
Amounts due to holding company
and fellow subsidiaries
4.9
4.8
4.6
-
0.2
Settlement balances
2.0
2.0
-
-
2.0
Other financial liabilities
Debt securities in issue
18.4
17.6
14.8
2.8
-
Subordinated liabilities
0.1
0.1
0.1
-
-
10 Financial instruments – valuation continued
Fair value of financial instruments measured at amortised cost on the balance sheet continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
126
NWM Plc
Items where fair
Carrying
Fair
Fair value hierarchy level
value approximates
value
value
Level 2
Level 3
carrying value
2023
£bn
£bn
£bn
£bn
£bn
Financial assets
Cash and balances at central banks
8.6
8.6
-
-
8.6
Settlement balances
2.2
2.2
-
-
2.2
Loans to banks
0.9
0.9
0.2
0.1
0.6
Loans to customers
12.1
12.1
1.6
10.5
-
Amounts due from holding company
and fellow subsidiaries
2.9
2.8
-
2.6
0.2
Other financial assets - securities
9.6
9.6
0.7
8.9
-
2022
Financial assets
Cash and balances at central banks
13.5
13.5
-
-
13.5
Settlement balances
1.7
1.7
-
-
1.7
Loans to banks
0.8
0.8
0.3
0.4
0.1
Loans to customers
9.2
9.1
0.9
8.2
-
Amounts due from holding company
and fellow subsidiaries
3.1
3.1
-
2.4
0.7
Other financial assets - securities
5.4
5.3
-
5.3
-
2023
Financial liabilities
Bank deposits
1.9
2.0
0.5
1.4
0.1
Customer deposits
3.1
3.1
0.4
2.6
0.1
Amounts due to holding company
and fellow subsidiaries
6.5
6.5
4.1
1.4
1.0
Settlement balances
0.4
0.4
-
-
0.4
Other financial liabilities
Debt securities in issue
18.5
18.2
15.2
3.0
-
2022
Financial liabilities
Bank deposits
2.9
2.9
0.8
1.9
0.2
Customer deposits
2.7
2.7
0.3
2.3
0.1
Amounts due to holding company
and fellow subsidiaries
6.6
6.6
4.7
0.9
1.0
Settlement balances
1.1
1.1
-
-
1.1
Other financial liabilities
Debt securities in issue
16.4
15.8
13.8
2.0
-
The assumptions and methodologies underlying the calculation of fair values of financial instruments at the balance sheet date are as
follows:
Short-term financial instruments
For certain short-term financial instruments, including but not
limited to; cash and balances at central banks, settlement
balances, loans with short-term maturities and customer demand
deposits, carrying value is deemed a reasonable approximation of
fair value.
Loans to banks and customers
In estimating the fair value of net loans to customers and banks
measured at amortised cost, NWM Group’s loans are segregated
into appropriate portfolios reflecting the characteristics of the
constituent loans. Loans are valued using contractual cashflows
that are discounted using a market discount rate that
incorporates the current spread for the borrower or where this is
not observable, the spread for borrowers of a similar credit
standing.
Debt securities and subordinated liabilities
Most debt securities are valued using quoted prices in active
markets or from quoted prices of similar financial instruments.
The remaining population is valued using discounted cashflows at
current offer rates.
Bank and customer deposits
Fair values of deposits are estimated using contractual cashflows
using a market discount rate incorporating the current spread.
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
127
11 Financial instruments - maturity analysis
Remaining maturity
The following table shows the residual maturity of financial instruments, based on contractual date of maturity:
NWM Group
2023
2022
Less than
More than
Less than
More than
12 months
12 months
Total
12 months
12 months
Total
£m
£m
£m
£m
£m
£m
Assets
Cash and balances at central banks
13,831
-
13,831
17,007
-
17,007
Trading assets
36,496
8,828
45,324
35,658
9,633
45,291
Derivatives
29,995
49,337
79,332
38,174
61,980
100,154
Settlement balances
7,227
-
7,227
2,558
-
2,558
Loans to banks - amortised cost
1,246
-
1,246
1,129
17
1,146
Loans to customers - amortised cost
5,032
7,954
12,986
4,282
5,889
10,171
Amounts due from holding company and fellow subsidiaries
(1)
1,462
74
1,536
615
97
712
Other financial assets
1,453
14,270
15,723
3,955
7,915
11,870
Liabilities
Bank deposits
1,622
645
2,267
2,427
642
3,069
Customer deposits
6,990
8
6,998
3,353
261
3,614
Amounts due to holding company and fellow subsidiaries
(2)
2,897
2,827
5,724
3,519
2,494
6,013
Settlement balances
6,641
-
6,641
2,010
-
2,010
Trading liabilities
45,336
8,287
53,623
42,744
10,048
52,792
Derivatives
30,433
41,548
71,981
39,166
54,419
93,585
Other financial liabilities
8,181
15,393
23,574
6,129
14,974
21,103
Lease liabilities
8
33
41
8
39
47
NWM Plc
2023
2022
Less than
More than
Less than
More than
12 months
12 months
Total
12 months
12 months
Total
£m
£m
£m
£m
£m
£m
Assets
Cash and balances at central banks
8,607
-
8,607
13,467
-
13,467
Trading assets
21,047
7,364
28,411
20,085
7,216
27,301
Derivatives
29,990
45,842
75,832
38,402
57,856
96,258
Settlement balances
2,168
-
2,168
1,686
-
1,686
Loans to banks - amortised cost
910
-
910
798
17
815
Loans to customers - amortised cost
4,745
7,359
12,104
4,062
5,092
9,154
Amounts due from holding company and fellow subsidiaries
(1)
5,145
1,093
6,238
4,068
2,538
6,606
Other financial assets
916
12,528
13,444
2,727
7,650
10,377
Liabilities
Bank deposits
1,351
558
1,909
2,338
598
2,936
Customer deposits
3,059
1
3,060
2,411
254
2,665
Amounts due to holding company and fellow subsidiaries
(2)
11,439
2,827
14,266
9,808
2,842
12,650
Settlement balances
400
-
400
1,133
-
1,133
Trading liabilities
27,341
6,738
34,079
24,230
8,995
33,225
Derivatives
30,234
39,170
69,404
39,380
51,374
90,754
Other financial liabilities
6,149
14,506
20,655
4,419
13,977
18,396
Lease liabilities
2
-
2
2
2
4
(1)
Amounts due from holding company and fellow subsidiaries relating to non-financial instruments of £194 million (2022 – £28 million) for NWM Group and £234 million (2022 - £59 million)
for NWM Plc have been excluded from the tables.
(2)
Amounts due to holding company and fellow subsidiaries relating to non-financial instruments of £78 million (2022 - £204 million) for NWM Group and £119 million (2022 - £217 million)
for NWM Plc have been excluded from the tables.
11 Financial instruments - maturity analysis continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
128
Assets and liabilities by contractual cash flows up to
20 years
The tables below show the contractual undiscounted cash flows
receivable and payable, up to a period of 20 years, including
future receipts and payments of interest of financial assets and
liabilities by contractual maturity. The balances in the following
tables do not agree directly with the consolidated balance sheet,
as the tables include all cash flows relating to principal and future
coupon payments, presented on an undiscounted basis. The
tables have been prepared on the following basis:
Financial assets have been reflected in the time band of the latest
date on which they could be repaid, unless earlier repayment can
be demanded by NWM Group. Financial liabilities are included at
the earliest date on which the counterparty can require
repayment, regardless of whether or not such early repayment
results in a penalty. If repayment is triggered by, or is subject to,
specific criteria such as market price hurdles being reached, the
asset is included in the time band that contains the latest date on
which it can be repaid, regardless of early repayment. The
liability is included in the time band that contains the earliest
possible date on which the conditions could be fulfilled, without
considering the probability of the conditions being met.
For
example, if a structured note is automatically prepaid when an
equity index exceeds a certain level, the cash outflow will be
included in the less than three months’ period whatever the level
of the index at the year end.
The settlement date of debt securities in issue, issued by certain
securitisation vehicles consolidated by NWM Group depends on
when cash flows are received from the securitised assets. Where
these assets are prepayable, the timing of the cash outflow
relating to securities assumes that each asset will be prepaid at
the earliest possible date. As the repayments of assets and
liabilities are linked, the repayment of assets in securitisations is
shown on the earliest date that the asset can be prepaid, as this
is the basis used for liabilities.
The principal amounts of financial liabilities that are repayable
after 20 years or where the counterparty has no right to
repayment of the principal, are excluded from the table along
with interest payments after 20 years.
The maturity of guarantees and commitments is based on the
earliest possible date they would be drawn in order to evaluate
NWM Group’s liquidity position.
MFVTPL assets of £125 billion (2022 - £146 billion) for NWM
Group, £107 billion (2022 - £127 billion) for NWM Plc, HFT
liabilities of £126 billion (2022 - £147 billion) for NWM Group and
£111 billion (2022 - £130 billion) for NWM Plc have been excluded
from the following tables.
11 Financial instruments - maturity analysis continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
129
NWM Group
0-3 months
3-12 months
1-3 years
3-5 years
5-10 years
10-20 years
2023
£m
£m
£m
£m
£m
£m
Assets by contractual maturity up to 20 years
Cash and balances at central banks
13,831
-
-
-
-
-
Derivatives held for hedging
(1)
(13)
47
63
7
2
Settlement balances
7,227
-
-
-
-
-
Loans to banks - amortised cost
1,228
19
-
-
-
-
Loans to customers - amortised cost
2,189
3,924
4,926
2,111
1,799
93
Amounts due from holding company and fellow subsidiaries
(1)
1,189
-
1
-
8
65
Other financial assets
(2)
1,109
1,039
2,334
1,606
4,266
4,765
Finance lease
-
-
1
-
-
-
26,772
4,969
7,309
3,780
6,080
4,925
2023
Liabilities by contractual maturity up to 20 years
Bank deposits
1,087
541
645
-
-
-
Customer deposits
5,317
1,708
3
1
2
19
Amounts due to holding company and fellow subsidiaries
(3)
1,434
435
1,730
915
183
-
Settlement balances
6,641
-
-
-
-
-
Derivatives held for hedging
28
110
199
84
14
-
Other financial liabilities
2,400
6,183
10,075
4,166
348
505
Lease liabilities
1
4
9
15
12
-
16,908
8,981
12,661
5,181
559
524
Guarantees and commitments notional amount
Guarantees
(4)
754
-
-
-
-
-
Commitments
(5)
13,639
-
-
-
-
-
14,393
-
-
-
-
-
NWM Group
0-3 months
3-12 months
1-3 years
3-5 years
5-10 years
10-20 years
2022
£m
£m
£m
£m
£m
£m
Assets by contractual maturity up to 20 years
Cash and balances at central banks
17,007
-
-
-
-
-
Derivatives held for hedging
2
13
46
13
7
1
Settlement balances
2,558
-
-
-
-
-
Loans to banks - amortised cost
1,128
2
17
-
-
-
Loans to customers - amortised cost
1,623
3,183
3,253
1,787
1,451
146
Amounts due from holding company and fellow subsidiaries
(1)
328
10
-
1
9
68
Other financial assets
(2)
1,700
2,648
2,744
1,501
1,952
1,417
Finance lease
-
-
1
-
-
-
24,346
5,856
6,061
3,302
3,419
1,632
2022
Liabilities by contractual maturity up to 20 years
Bank deposits
1,302
1,135
643
-
-
-
Customer deposits
2,286
1,339
21
1
2
20
Amounts due to holding company and fellow subsidiaries
(3)
190
2,199
1,805
-
190
-
Settlement balances
2,010
-
-
-
-
-
Derivatives held for hedging
17
76
202
53
21
-
Other financial liabilities
1,600
4,345
9,113
5,271
401
437
Lease liabilities
1
7
12
10
17
-
7,406
9,101
11,796
5,335
631
457
Guarantees and commitments notional amount
Guarantees
(4)
594
-
-
-
-
-
Commitments
(5)
12,873
-
-
-
-
-
13,467
-
-
-
-
-
For notes to the above table refer to the following page.
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
130
11 Financial instruments - maturity analysis continued
NWM Plc
0-3 months
3-12 months
1-3 years
3-5 years
5-10 years
10-20 years
2023
£m
£m
£m
£m
£m
£m
Assets by contractual maturity up to 20 years
Cash and balances at central banks
8,607
-
-
-
-
-
Derivatives held for hedging
(1)
(13)
46
62
6
2
Settlement balances
2,168
-
-
-
-
-
Loans to banks - amortised cost
892
19
-
-
-
-
Loans to customers - amortised cost
2,136
3,632
4,505
1,932
1,751
93
Amounts due from holding company and fellow subsidiaries
(1)
1,692
132
742
277
8
65
Other financial assets
(2)
956
816
2,186
1,596
3,986
3,914
16,450
4,586
7,479
3,867
5,751
4,074
2023
Liabilities by contractual maturity up to 20 years
Bank deposits
1,075
280
558
-
-
-
Customer deposits
1,911
1,172
3
1
2
3
Amounts due to holding company and fellow subsidiaries
(3)
3,194
435
1,729
915
183
-
Settlement balances
400
-
-
-
-
-
Derivatives held for hedging
29
109
199
84
14
-
Other financial liabilities
1,702
4,703
9,920
3,898
340
167
Lease liabilities
-
1
-
-
-
-
8,311
6,700
12,409
4,898
539
170
Guarantees and commitments notional amount
Guarantees
(4)
296
-
-
-
-
-
Commitments
(5)
8,339
-
-
-
-
-
8,635
-
-
-
-
-
NWM Plc
0-3 months
3-12 months
1-3 years
3-5 years
5-10 years
10-20 years
2022
£m
£m
£m
£m
£m
£m
Assets by contractual maturity up to 20 years
Cash and balances at central banks
13,467
-
-
-
-
-
Derivatives held for hedging
4
11
47
13
7
1
Settlement balances
1,686
-
-
-
-
-
Loans to banks - amortised cost
796
2
17
-
-
-
Loans to customers - amortised cost
1,537
3,007
2,696
1,609
1,329
146
Amounts due from holding company and fellow subsidiaries
(1)
1,148
349
931
345
226
68
Other financial assets
(2)
1,449
1,982
2,515
1,415
1,846
1,321
20,087
5,351
6,206
3,382
3,408
1,536
2022
Liabilities by contractual maturity up to 20 years
Bank deposits
1,302
1,045
599
-
-
-
Customer deposits
1,689
987
21
1
2
3
Amounts due to holding company and fellow subsidiaries
(3)
1,582
2,199
2,153
-
190
-
Settlement balances
1,133
-
-
-
-
-
Derivatives held for hedging
18
76
201
53
21
-
Other financial liabilities
743
3,478
8,512
5,164
401
161
Lease liabilities
1
1
2
-
-
-
6,468
7,786
11,488
5,218
614
164
Guarantees and commitments notional amount
Guarantees
(4)
144
-
-
-
-
-
Commitments
(5)
6,956
-
-
-
-
-
7,100
-
-
-
-
-
(1)
Amounts due from holding company and fellow subsidiaries relating to non-financial instruments have been excluded from the tables.
(2)
Other financial assets excludes equity shares.
(3)
Amounts due to holding company and fellow subsidiaries relating to non-financial instruments have been excluded from the tables.
(4)
NWM Group is only called upon to satisfy a guarantee when the guaranteed party fails to meet its obligations. NWM Group expects most guarantees it provides to expire unused.
(5)
NWM Group has given commitments to provide funds to customers under undrawn formal facilities, credit lines and other commitments to lend subject to certain conditions being met
by the counterparty. NWM Group does not expect all facilities to be drawn, and some may lapse before drawdown.
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
131
12 Trading assets and liabilities
Trading assets and liabilities comprise assets and liabilities held at fair value in trading portfolios.
NWM Group
NWM Plc
2023
2022
2023
2022
Assets
£m
£m
£m
£m
Loans
Reverse repos
23,694
21,537
11,315
8,559
Collateral given
8,914
12,719
7,263
10,468
Other loans
762
1,113
645
938
Total loans
33,370
35,369
19,223
19,965
Securities
Central and local government
- UK
2,729
2,205
2,729
2,204
- US
2,600
2,345
33
41
- Other
3,062
2,799
3,062
2,799
Financial institutions and Corporate
3,563
2,573
3,364
2,292
Total securities
11,954
9,922
9,188
7,336
Total
45,324
45,291
28,411
27,301
Liabilities
Deposits
Repos
26,902
23,740
12,125
8,716
Collateral received
15,062
17,663
12,455
14,556
Other deposits
1,150
1,068
1,127
1,066
Total deposits
43,114
42,471
25,707
24,338
Debt securities in issue
706
797
706
797
Short positions
Central and local government
- UK
1,893
2,313
1,893
2,268
- US
2,071
1,293
17
52
- Other
4,049
3,936
4,033
3,920
Financial institutions and Corporate
1,790
1,982
1,723
1,850
Total short positions
9,803
9,524
7,666
8,090
Total
53,623
52,792
34,079
33,225
For accounting policy information refer to Accounting policy 3.5.
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
132
13 Derivatives
NWM Group uses derivatives as part of its trading activities or to manage its own risk such as interest rate, foreign exchange, or credit
risk.
NWM Group
Notional
Asset
Liability
Traded on
Traded on
Traded on
recognised
Traded over
recognised
Traded over
recognised
Traded over
exchanges
the counter
Total
exchanges
the counter
Total
exchanges
the counter
Total
2023
£bn
£bn
£bn
£m
£m
£m
£m
£m
£m
Interest rate
819
8,870
9,689
48
44,895
44,943
34
38,258
38,292
- Swaps
-
5,952
5,952
-
34,181
34,181
-
27,191
27,191
- Options
510
1,676
2,186
48
10,714
10,762
34
11,067
11,101
- Forwards and futures
309
1,242
1,551
-
-
-
-
-
-
Exchange rate
1
3,108
3,109
-
34,208
34,208
-
33,364
33,364
- Swaps
-
449
449
-
8,150
8,150
-
7,355
7,355
- Options
1
674
675
-
4,181
4,181
-
4,197
4,197
- Spot, forwards and futures
-
1,985
1,985
-
21,877
21,877
-
21,812
21,812
Credit
-
16
16
-
181
181
-
325
325
Equity and commodity
-
-
-
-
-
-
-
-
-
Total
820
11,994
12,814
48
79,284
79,332
34
71,947
71,981
2022
Interest rate
707
9,649
10,356
113
53,984
54,097
33
48,339
48,372
- Swaps
-
6,813
6,813
-
39,648
39,648
-
32,746
32,746
- Options
296
1,420
1,716
113
14,336
14,449
33
15,593
15,626
- Forwards and futures
411
1,416
1,827
-
-
-
-
-
-
Exchange rate
2
3,143
3,145
-
45,821
45,821
-
44,938
44,938
- Swaps
-
439
439
-
11,808
11,808
-
10,415
10,415
- Options
2
835
837
-
6,375
6,375
-
6,647
6,647
- Spot, forwards and futures
-
1,869
1,869
-
27,638
27,638
-
27,876
27,876
Credit
-
15
15
-
236
236
-
275
275
Equity and commodity
-
-
-
-
-
-
-
-
-
Total
709
12,807
13,516
113
100,041
100,154
33
93,552
93,585
13 Derivatives continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
133
NWM Plc
Notional
Asset
Liability
Traded on
Traded on
Traded on
recognised
Traded over
recognised
Traded over
recognised
Traded over
exchanges
the counter
Total
exchanges
the counter
Total
exchanges
the counter
Total
2023
£bn
£bn
£bn
£m
£m
£m
£m
£m
£m
Interest rate
794
8,473
9,267
48
41,189
41,237
34
35,543
35,577
- Swaps
-
5,607
5,607
-
30,760
30,760
-
24,769
24,769
- Options
511
1,679
2,190
48
10,429
10,477
34
10,774
10,808
- Forwards and futures
283
1,187
1,470
-
-
-
-
-
-
Exchange rate
-
3,116
3,116
-
34,415
34,415
-
33,508
33,508
- Swaps
-
449
449
-
8,154
8,154
-
7,360
7,360
- Options
-
673
673
-
4,184
4,184
-
4,194
4,194
- Spot, forwards and futures
-
1,994
1,994
-
22,077
22,077
-
21,954
21,954
Credit
-
15
15
-
180
180
-
319
319
Equity and commodity
-
-
-
-
-
-
-
-
-
Total
794
11,604
12,398
48
75,784
75,832
34
69,370
69,404
2022
Interest rate
688
8,152
8,840
113
49,383
49,496
33
44,857
44,890
- Swaps
-
5,680
5,680
-
35,456
35,456
-
29,662
29,662
- Options
296
1,425
1,721
113
13,927
14,040
33
15,195
15,228
- Forwards and futures
392
1,047
1,439
-
-
-
-
-
-
Exchange rate
2
3,176
3,178
-
46,528
46,528
-
45,592
45,592
- Swaps
-
440
440
-
11,814
11,814
-
10,430
10,430
- Options
2
835
837
-
6,370
6,370
-
6,641
6,641
- Spot, forwards and futures
-
1,901
1,901
-
28,344
28,344
-
28,521
28,521
Credit
-
15
15
-
234
234
-
272
272
Equity and commodity
-
-
-
-
-
-
-
-
-
Total
690
11,343
12,033
113
96,145
96,258
33
90,721
90,754
Included in the tables above is the notional amount of £6,677 billion (2022 - £7,651 billion) for NWM Group and £6,063 billion (2022 -
£5,971 billion) for NWM Plc of interest rate derivatives that are traded over the counter and settled through central clearing. NWM
Group and NWM Plc has no other type of derivatives that are settled through central counterparties.
13 Derivatives continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
134
Hedge accounting using derivatives
For accounting policy information refer to Accounting policies 3.5
and 3.9.
Refer to Note 31 for amounts due from/to fellow NatWest Group
subsidiaries.
NWM Group applies hedge accounting to reduce the accounting
mismatch caused in the income statement by using derivatives to
hedge the following risks: interest rate, foreign exchange and the
foreign exchange risk associated with net investment in foreign
operations.
NWM Group’s interest rate hedging relates to the management of
NWM Group’s non-trading structural interest rate risk, caused by
the mismatch between fixed interest rates and floating interest
rates on its financial instruments. NWM Group manages this risk
within approved limits. Residual risk positions are hedged with
derivatives, principally interest rate swaps.
Cash flow hedges of interest rate risk relate to exposures to the
variability in future interest payments and receipts due to the
movement of interest rates on forecast transactions and on
financial assets and financial liabilities. This variability in cash flows
is hedged by interest rate swaps, which convert variable cash
flows into fixed. For these cash flow hedge relationships, the
hedged items are actual and forecast variable interest rate cash
flows arising from financial assets and financial liabilities with
interest rates linked to the relevant interest rates, most notably
SOFR, EURIBOR, European Central Bank deposit rate, SONIA and
the Bank of England Official Bank Rate. The variability in cash
flows due to movements in the relevant interest rate is hedged;
this risk component is identified using the risk management
systems of NWM Group and encompasses the majority of cash
flow variability risk.
Suitable larger fixed rate financial instruments are subject to fair
value hedging in line with documented risk management
strategies.
Fair value hedges of interest rate risk involve interest rate swaps
transforming the fixed interest rate risk in financial assets and
financial liabilities to floating. The hedged risk is the risk of
changes in the hedged item’s fair value attributable to changes in
the interest rate risk component of the hedged item. The
significant interest rates identified as risk components are SOFR,
EURIBOR and SONIA. These risk components are identified using
the risk management systems of NWM Group and encompass the
majority of the hedged item’s fair value risk.
NWM Group hedges the exchange rate risk of its net investment
in foreign currency denominated operations with currency
borrowings and forward foreign exchange contracts.
NWM Group reviews the value of the investments’ net assets,
executing hedges where appropriate to reduce the sensitivity of
capital ratios to foreign exchange rate movement. Hedge
accounting relationships will be designated where required.
Exchange rate risk also arises in NWM Group where payments
are denominated in currencies other than the functional currency.
Residual risk positions are hedged with cross currency basis
swaps fixing the exchange rate the payments will be settled in.
The derivatives are documented as cash flow hedges.
For all cash flow hedging, fair value hedge relationships and net
investment hedging, NWM Group determines that there is an
economic relationship between the hedged item and hedging
instrument via assessing the initial and ongoing effectiveness by
comparing movements in the fair value of the expected highly
probable forecast interest cash flows/ fair value of the hedged
item attributable to the hedged risk with movements in the fair
value of the expected changes in cash flows from the hedging
instrument. The method used for comparing movements is either
regression testing, or the dollar offset method. The method for
testing effectiveness and the period over which the test is
performed depends on the applicable risk management strategy
and is applied consistently to each risk management strategy.
Hedge effectiveness is assessed on a cumulative basis and the
determination of effectiveness is in line with the requirements of
IAS 39.
NWM Group uses either the actual ratio between the hedged item
and hedging instrument(s) or one that minimises hedge
ineffectiveness to establish the hedge ratio for hedge accounting.
Hedge ineffectiveness is measured in line with the requirements of
IAS 39 and recognised in the income statement as it arises.
13 Derivatives continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
135
Derivatives in hedge accounting relationships
Included in the table below are derivatives held for hedging as follows.
NWM Group
2023
2022
Changes in fair
Changes in fair
value used for
value used for
hedge
hedge
Notional
Assets
Liabilities
ineffectiveness (1)
Notional
Assets
Liabilities
ineffectiveness (1)
£bn
£m
£m
£m
£bn
£m
£m
£m
Fair value hedging
Interest rate contracts
(2)
18.9
260
611
372
20.6
215
917
(647)
Cash flow hedging
Interest rate contracts
5.7
45
368
206
5.8
1
492
(436)
Exchange rate contracts
5.5
104
251
-
5.0
121
109
(10)
Net investment hedging
Exchange rate contracts
0.1
2
-
(2)
0.3
1
5
4
30.2
411
1,230
576
31.7
338
1,523
(1,089)
IFRS netting and clearing
house settlements
(293)
(963)
(216)
(1,353)
118
267
122
170
NWM Plc
2023
2022
Changes in fair
Changes in fair
value used for
value used for
hedge
hedge
Notional
Assets
Liabilities
ineffectiveness (1)
Notional
Assets
Liabilities
ineffectiveness (1)
£bn
£m
£m
£m
£bn
£m
£m
£m
Fair value hedging
Interest rate contracts
(2)
18.7
261
609
371
20.2
213
915
(642)
Exchange rate contracts
-
-
-
-
0.2
-
5
5
Cash flow hedging
Interest rate contracts
4.3
23
364
173
4.2
-
483
(427)
Exchange rate contracts
5.5
104
251
-
5.0
121
109
(10)
Net investment hedging
Exchange rate contracts
0.1
2
-
(2)
0.1
1
-
(1)
28.6
390
1,224
542
29.7
335
1,512
(1,075)
IFRS netting and clearing
house settlements
(272)
(957)
(213)
(1,342)
118
267
122
170
(1)
The change in fair value per hedge ineffectiveness includes instruments that were derecognised in the year.
13 Derivatives continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
136
Hedge ineffectiveness
Hedge ineffectiveness recognised in other operating income in continuing operations comprised.
NWM Group
2023
2022
£m
£m
Fair value hedging
(Loss)/gain on hedged items attributable to the hedged risk
(370)
643
Gain/(loss) on the hedging instruments
372
(647)
Fair value hedging ineffectiveness
2
(4)
Cash flow hedging
Interest rate risk
1
(3)
Cash flow hedging ineffectiveness
1
(3)
Total
3
(7)
The main sources of ineffectiveness for interest rate risk hedge accounting relationships are:
The effect of the counterparty credit risk on the fair value of the interest rate swap which is not reflected in the fair value of the
hedged item attributable to the change in interest rate (fair value hedge);
Differences in the repricing basis between the hedging instrument and hedged cash flows (cash flow hedge); and
Upfront present values on the hedging derivatives where hedge accounting relationships have been designated after the trade
date (cash flow hedge and fair value hedge).
13 Derivatives continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
137
Maturity of notional hedging contracts
The following table shows the period in which notional of the hedging contract ends.
NWM Group
3-12 months
1-3 years
3-5 years
5-10 years
Over 10 years
0-3 months
Total
2023
£bn
£bn
£bn
£bn
£bn
£bn
£bn
Fair value hedging
Interest rate risk
Hedging assets
-
-
1.2
1.4
0.7
0.2
3.5
Hedging liabilities
0.9
1.3
7.0
4.5
1.5
0.2
15.4
2022
Fair value hedging
Interest rate risk
Hedging assets
0.5
1.5
1.0
0.9
0.1
0.2
4.2
Hedging liabilities
0.1
3.1
8.1
3.7
1.2
0.2
16.4
2023
Cash flow hedging
Interest rate risk
Hedging assets
0.1
0.6
2.1
0.9
2.0
-
5.7
Exchange rate risk
Hedging liabilities
-
0.5
2.3
2.5
0.2
-
5.5
2022
Cash flow hedging
Interest rate risk
Hedging assets
-
0.5
2.3
1.0
2.0
-
5.8
Exchange rate risk
Hedging liabilities
-
0.9
2.8
1.1
0.2
-
5.0
NWM Plc
3-12 months
1-3 years
3-5 years
5-10 years
Over 10 years
0-3 months
Total
2023
£bn
£bn
£bn
£bn
£bn
£bn
£bn
Fair value hedging
Interest rate risk
Hedging assets
-
-
1.2
1.4
0.7
0.2
3.5
Hedging liabilities
0.9
1.0
7.0
4.5
1.6
0.2
15.2
2022
Fair value hedging
Interest rate risk
Hedging assets
0.4
1.5
1.0
0.9
0.1
0.2
4.1
Hedging liabilities
-
3.1
7.8
3.8
1.2
0.2
16.1
2023
Cash flow hedging
Interest rate risk
Hedging assets
0.1
0.4
1.6
0.7
1.5
-
4.3
Exchange rate risk
Hedging liabilities
-
0.5
2.3
2.5
0.2
-
5.5
2022
Cash flow hedging
Interest rate risk
Hedging assets
-
0.3
1.8
0.6
1.5
-
4.2
Exchange rate risk
Hedging liabilities
-
0.9
2.8
1.1
0.2
-
5.0
13 Derivatives continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
138
Average fixed interest rates
Average fixed rate for cash flow hedges, interest rate risk.
NWM Group
0-3 months
3-12 months
1-3 years
3-5 years
5-10 years
Over 10 years
Total
2023
%
%
%
%
%
%
%
Average fixed interest rate
Hedging assets
2.03
1.77
1.48
1.49
2.03
-
1.72
2022
Average fixed interest rate
Hedging assets
1.75
1.28
1.52
1.43
1.54
-
1.50
NWM Plc
0-3 months
3-12 months
1-3 years
3-5 years
5-10 years
Over 10 years
Total
2023
%
%
%
%
%
%
%
Average fixed interest rate
Hedging assets
1.37
1.35
1.12
1.10
1.80
-
1.38
2022
Average fixed interest rate
Hedging assets
-
0.56
1.21
0.65
1.13
-
1.06
Average foreign exchange rates
For cash flow hedging of exchange rate risk, the average foreign exchange rates applicable across the relationships for NWM Group
and NWM Plc were as below for the main currencies hedged.
2023
2022
USD/GBP
1.25
1.24
JPY/GBP
132.89
132.89
JPY/USD
129.75
128.29
NOK/USD
9.21
9.21
13 Derivatives continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
139
Analysis of hedged items and related hedging instruments
The table below analyses assets and liabilities including intercompany, subject to hedging derivatives.
NWM Group
Carrying value
Impact on
Changes in fair
of hedged
hedged items
value used as a basis
assets and
included in
to determine
liabilities
carrying value
ineffectiveness (1)
2023
£m
£m
£m
Fair value hedging - interest rate
Other financial assets - securities
3,661
(40)
84
Bank and customer deposits
745
(3)
(6)
Other financial liabilities - debt securities in issue
15,198
(307)
(402)
Subordinated liabilities
1,040
(24)
(46)
Total
16,983
(334)
(454)
2022
Fair value hedging - interest rate
Other financial assets - securities
4,086
(161)
(230)
Bank and customer deposits
565
(3)
3
Other financial liabilities - debt securities in issue
15,570
(786)
801
Subordinated liabilities
1,113
(56)
69
Total
17,248
(845)
873
2023
Cash flow hedging - interest rate
Loans to banks and customers - amortised cost
5,684
(200)
Other financial assets - securities
102
(5)
Total
5,786
(205)
Cash flow hedging - exchange rate
Other financial liabilities - debt securities in issue
2,736
-
2022
Cash flow hedging - interest rate
Loans to banks and customers - amortised cost
5,756
427
Other financial assets - securities
85
6
Total
5,841
433
Cash flow hedging - exchange rate
Other financial liabilities - debt securities in issue
3,096
10
13 Derivatives continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
140
Analysis of hedged items and related hedging instruments - continued
NWM Plc
Carrying value
Impact on
Changes in fair
of hedged
hedged items
value used as a basis
assets and
included in
to determine
liabilities
carrying value
ineffectiveness (1)
2023
£m
£m
£m
Fair value hedging - interest rate
Other financial assets - securities
3,661
(40)
84
Bank and customer deposits
745
(3)
(6)
Other financial liabilities - debt securities in issue
14,940
(306)
(401)
Subordinated liabilities
1,040
(24)
(46)
Total
16,725
(333)
(453)
Fair value hedging - exchange rate
Other
-
-
-
2022
Fair value hedging - interest rate
Other financial assets - securities
4,086
(161)
(229)
Bank and customer deposits
565
(3)
3
Other financial liabilities - debt securities in issue
15,295
(784)
798
Subordinated liabilities
1,039
(55)
66
Total
16,899
(842)
867
Fair value hedging - exchange rate
Other
173
26
(5)
2023
Cash flow hedging - interest rate
Loans to banks and customers - amortised cost
4,240
(167)
Other financial assets - securities
102
(5)
Total
4,342
(172)
Cash flow hedging - exchange rate
Other financial liabilities - debt securities in issue
2,736
-
2022
Cash flow hedging - interest rate
Loans to banks and customers - amortised cost
4,117
418
Other financial assets - securities
85
6
Total
4,202
424
Cash flow hedging - exchange rate
Other financial liabilities - debt securities in issue
3,096
10
(1)
The change in fair value per hedge ineffectiveness includes instruments that were derecognised in the year.
13 Derivatives continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
141
Analysis of cash flow and foreign exchange hedge reserve
The following table shows a pre-tax analysis of the cash flow hedge reserve and foreign exchange hedge reserve.
NWM Group
2023
2022
Foreign
Foreign
Cash flow
exchange
Cash flow
exchange
hedge reserve
hedge reserve
hedge reserve
hedge reserve
£m
£m
£m
£m
Continuing
Interest rate risk
(260)
-
(468)
-
Foreign exchange risk
(4)
(13)
-
(29)
De-designated
Interest rate risk
41
-
64
-
Foreign exchange risk
-
(170)
-
(173)
Total
(223)
(183)
(404)
(202)
NWM Plc
2023
2022
Foreign
Foreign
Cash flow
exchange
Cash flow
exchange
hedge reserve
hedge reserve
hedge reserve
hedge reserve
£m
£m
£m
£m
Continuing
Interest rate risk
(284)
-
(459)
-
Foreign exchange risk
(4)
1
-
(1)
De-designated
Interest rate risk
41
-
64
-
Foreign exchange risk
-
27
-
24
Total
(247)
28
(395)
23
NWM Group
2023
2022
Foreign
Foreign
Cash flow
exchange
Cash flow
exchange
hedge reserve
hedge reserve
hedge reserve
hedge reserve
£m
£m
£m
£m
Amount recognised in equity
Interest rate risk
62
-
(440)
(64)
Foreign exchange risk
(91)
19
16
(11)
Total
(29)
19
(424)
(75)
Amount transferred from equity to earnings
Interest rate risk to net interest income
121
-
(40)
-
Foreign exchange risk to net interest income
86
-
(11)
-
Foreign exchange risk to non interest income
-
-
-
7
Total
207
-
(51)
7
NWM Plc
2023
2022
Foreign
Foreign
Cash flow
exchange
Cash flow
exchange
hedge reserve
hedge reserve
hedge reserve
hedge reserve
£m
£m
£m
£m
Amount recognised in equity
Interest rate risk
36
-
(422)
-
Foreign exchange risk
(92)
5
16
(11)
Total
(56)
5
(406)
(11)
Amount transferred from equity to earnings
Interest rate risk to net interest income
115
-
(47)
-
Foreign exchange risk to net interest income
86
-
(11)
-
Total
201
-
(58)
-
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
142
14 Loan impairment provisions
Loan exposure and impairment metrics
The table below summarises loans and related credit impairment measures within the scope of ECL framework.
NWM Group
NWM Plc
31 December
31 December
31 December
31 December
2023
2022
2023
2022
£m
£m
£m
£m
Loans - amortised cost
- Stage 1
13,686
10,791
12,584
9,713
- Stage 2
558
497
436
228
- Stage 3
25
49
25
49
Of which: individual
17
37
17
37
Of which: collective
8
12
8
12
- Inter-Group
1,264
434
2,623
2,324
Total
15,533
11,771
15,668
12,314
ECL provisions
(1)
- Stage 1
24
20
17
15
- Stage 2
8
8
7
3
- Stage 3
24
26
24
26
Of which: individual
16
15
16
15
Of which: collective
8
11
8
11
- Inter-Group
1
-
3
4
Total
57
54
51
48
ECL provision coverage
(2)
- Stage 1 (%)
0.18
0.19
0.14
0.15
- Stage 2 (%)
1.43
1.61
1.61
1.32
- Stage 3 (%)
96.00
53.06
96.00
53.06
- Inter-Group (%)
0.08
-
0.11
0.17
Total
0.39
0.48
0.37
0.44
Impairment (releases)/losses
ECL (release)/charge
- Stage 1
1
8
3
7
- Stage 2
4
14
3
3
- Stage 3
(3)
(14)
(3)
(14)
Of which: individual
(2)
(15)
(2)
(15)
Of which: collective
(1)
1
(1)
1
- Third party
2
8
3
(4)
- Inter-Group
-
-
-
-
Total
2
8
3
(4)
Amounts written off
5
55
3
14
Of which: individual
4
55
2
14
Of which: collective
1
-
1
-
(1)
NWM Group’s intercompany assets were classified as Stage 1. The ECL for these loans was £1 million at 31 December 2023.
(2)
ECL provisions coverage is calculated as total ECL provisions divided by third party loans – amortised cost and FVOCI.
(3)
The table shows gross loans only and excludes amounts that are outside the scope of the ECL framework. Refer to page 58 for Financial instruments within the scope of the IFRS 9 ECL
framework for further details. Other financial assets within the scope of the IFRS 9 ECL framework were cash and balances at central banks totalling £13.8 billion (2022 – £17.0 billion)
and debt securities of £15.6 billion (2022 – £11.8 billion).
Credit risk enhancement and mitigation
For information on Credit risk enhancement and mitigation held
as security, refer to Risk and capital management – Credit risk
enhancement and mitigation section.
Critical accounting policy: Loan impairment provisions
Accounting policy 2.3 sets out how the expected loss approach is
applied. At 31 December 2023, customer loan impairment
provisions amounted to £57 million (2022 - £54 million). A loan is
impaired when there is objective evidence that the cash flows will
not occur in the manner expected when the loan was advanced.
Such evidence includes changes in the credit rating of a borrower,
the failure to make payments in accordance with the loan
agreement, significant reduction in the value of any security,
breach of limits or covenants, and observable data about relevant
macroeconomic measures.
The impairment loss is the difference between the carrying value
of the loan and the present value of estimated future cash flows
at the loan's original effective interest rate.
The measurement of credit impairment under the IFRS expected
loss model depends on management’s assessment of any
potential deterioration in the creditworthiness of the borrower, its
modelling of expected performance and the application of
economic forecasts. All three elements require judgements that
are potentially significant to the estimate of impairment losses. For
further information and sensitivity analysis, refer to Risk and
capital management – Measurement uncertainty and ECL
sensitivity analysis section.
IFRS 9 ECL model design principles
Refer to Credit risk – IFRS 9 ECL model design principles section
for further details.
Approach for multiple economic scenarios (MES)
The base scenario plays a greater part in the calculation of ECL
than the approach to MES. Refer to Credit risk – Economic loss
drivers – Probability weightings of scenarios section for further
details.
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
143
15 Other financial assets
NWM Group
Debt securities
Central and local
government
Other
Equity
US
Other
debt
Total
shares
Loans
Total
2023
£m
£m
£m
£m
£m
£m
£m
Mandatory fair value through profit or loss
-
-
1
1
1
46
48
Designated as at fair value
-
3
2
5
-
-
5
Fair value through other comprehensive income
2,472
573
948
3,993
57
65
4,115
Amortised cost
-
-
11,555
11,555
-
-
11,555
Total
2,472
576
12,506
15,554
58
111
15,723
2022
Mandatory fair value through profit or loss
-
-
2
2
1
77
80
Designated as at fair value
-
-
-
-
-
-
-
Fair value through other comprehensive income
3,920
1,213
700
5,833
90
117
6,040
Amortised cost
-
-
5,750
5,750
-
-
5,750
Total
3,920
1,213
6,452
11,585
91
194
11,870
NWM Plc
Debt securities
Central and local
government
Other
Equity
US
Other
debt
Total
shares
Loans
Total
2023
£m
£m
£m
£m
£m
£m
£m
Mandatory fair value through profit or loss
-
-
1
1
-
46
47
Fair value through other comprehensive income
2,393
352
900
3,645
46
65
3,756
Amortised cost
-
-
9,641
9,641
-
-
9,641
Total
2,393
352
10,542
13,287
46
111
13,444
2022
Mandatory fair value through profit or loss
-
-
2
2
-
77
79
Fair value through other comprehensive income
3,714
559
465
4,738
42
90
4,870
Amortised cost
-
-
5,428
5,428
-
-
5,428
Total
3,714
559
5,895
10,168
42
167
10,377
There were no significant acquisitions of equity shares in either year. NWM Group disposed of equity shares in UBS Equity Funds of
£35 million in the year (2022 - £69 million). There are no significant dividends on equity shares held at FVOCI in either year.
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
144
16 Investments in Group undertakings
Investments in group undertakings are carried at cost less impairment losses. Movements during the year were as follows:
NWM Plc
2023
2022
£m
£m
At 1 January
2,626
2,481
Currency translation and other adjustments
(13)
64
Additional investments in Group undertakings
-
-
Net (impairment)/reversal of impairment of investments
(293)
81
At 31 December
2,320
2,626
The 2023 net impairment of investments consists primarily of the impairment of NWM Plc’s investments in RBS Holdings N.V. due to a
change in its net asset value driven by a dividend payment in 2023. The net reversal of impairments of investments in 2022 was
related mainly to RBS Asia Financial Services Limited and RBS Holdings N.V.
NWM Plc’s subsidiaries are assessed for potential impairment of investment based on net asset value. Fair value measurement for this
purpose was categorised as Level 3 of the fair value hierarchy.
The principal subsidiary undertakings of the company are shown below. Their capital consists of ordinary shares and additional Tier 1
notes which are unlisted. All of these subsidiaries are included in NWM Group’s consolidated financial statements and have an
accounting reference date of 31 December.
Country of incorporation and
Nature of business
principal area of operation
Group interest
NatWest Markets Securities Inc.
Broker dealer
US
100%
NatWest Markets N.V.
Banking
Netherlands
100%
For accounting policy information refer to Accounting policy 3.10.
Full information on all related undertakings is included in Note 34.
17 Other assets
NWM Group
NWM Plc
2023
2022
2023
2022
£m
£m
£m
£m
Property, plant and equipment
57
59
12
8
Pension schemes in net surplus (Note 5)
145
241
145
241
Accrued income
39
111
28
101
Tax recoverable
106
294
106
295
Deferred tax (Note 7)
55
46
-
-
Other assets
116
81
99
67
Total
518
832
390
712
18 Other financial liabilities
NWM Group
NWM Plc
2023
2022
2023
2022
£m
£m
£m
£m
Customer deposits - designated as at fair value through profit or loss
1,259
1,050
1,015
770
Debt securities in issue
Medium term notes
17,608
16,418
16,580
15,553
Commercial paper and certificates of deposit
4,433
3,169
3,041
1,931
Subordinated liabilities
Designated as at fair value through profit or loss
238
345
-
122
Amortised cost
36
121
19
20
Total
23,574
21,103
20,655
18,396
For accounting policy information refer to Accounting policy 3.5 and 3.8.
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
145
19 Subordinated liabilities
NWM Group
NWM Plc
2023
2022
2023
2022
£m
£m
£m
£m
Dated loan capital
255
446
-
122
Undated loan capital
19
20
19
20
Total
274
466
19
142
(1)
Excludes amounts due to holding company and fellow subsidiaries of £1,022 million (2022 - £1,519 million) for NWM Group and NWM Plc.
The following tables analyse third party subordinated liabilities:
First call
Maturity
Capital
2023
2022
Dated loan capital
date
date
treatment
£m
£m
€145.6 million
Floating rate notes
-
Apr-2023
Tier 2
-
122
-
122
Undated loan capital
£31 million
7.380% notes
-
-
Not applicable
1
2
£16 million
5.630% notes
Sep-2026
-
Not applicable
18
18
19
20
The following tables analyse intercompany subordinated liabilities:
NWM Group and Bank
2023
2022
£m
£m
Dated loan capital
1,022
1,020
Undated loan capital
-
499
Total
1,022
1,519
First call
Maturity
Capital
2023
2022
Dated loan capital
date
date
treatment
£m
£m
€950 million
3.280% notes
-
Mar-2024
Tier 2
839
830
$250 million
4.960% notes
-
Jan-2034
Tier 2
183
190
1,022
1,020
Undated loan capital
$600 million
Floating rate notes
Jun-2013
-
Tier 2
-
499
-
499
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
146
20 Other liabilities
NWM Group
NWM Plc
2023
2022
2023
2022
£m
£m
£m
£m
Lease liabilities
41
47
2
4
Provisions for liabilities and charges
180
274
124
161
Retirement benefit liabilities (Note 5)
62
63
59
55
Accruals
182
224
113
178
Deferred income
47
35
38
24
Current tax
3
21
2
12
Deferred tax (Note 7)
54
101
49
92
Other liabilities
84
51
66
41
Total
653
816
453
567
NWM Group
Litigation and
other regulatory
Other (1)
Total
£m
£m
£m
At 1 January 2023
225
49
274
Currency translation and other movements
(9)
(1)
(10)
Charge to income statement
20
13
33
Release to income statement
(33)
(4)
(37)
Provisions utilised
(62)
(18)
(80)
At 31 December 2023
141
39
180
NWM Plc
Litigation and
other regulatory
Other (1)
Total
Provisions for liabilities and charges
£m
£m
£m
At 1 January 2023
132
29
161
Currency translation and other movements
(7)
-
(7)
Charge to income statement
20
6
26
Release to income statement
(3)
(4)
(7)
Provisions utilised
(39)
(10)
(49)
At 31 December 2023
103
21
124
(1)
Materially comprises provisions relating to restructuring costs.
Provisions are liabilities of uncertain timing or amount and are recognised when there is a present obligation as a result of a past
event, the outflow of economic benefit is probable and the outflow can be estimated reliably. Any difference between the final outcome
and the amounts provided will affect the reported results in the period when the matter is resolved.
For accounting policy information refer to Accounting policy 2.4.
Critical accounting policy: Provisions for liabilities
The key judgement is involved in determining whether a present obligation exists. There is often a high degree of uncertainty and
judgement is based on the specific facts and circumstances relating to individual events in determining whether there is a present
obligation. Judgement is also involved in estimation of the probability, timing and amount of any outflows. Where NWM Group can look
to another party such as an insurer to pay some or all of the expenditure required to settle a provision, any reimbursement is
recognised when, and only when, it is virtually certain that it will be received.
Estimates -
Provisions are liabilities of uncertain timing or amount and are recognised when there is a present obligation as a result of
a past event, the outflow of economic benefit is probable, and the outflow can be estimated reliably. Any difference between the final
outcome and the amounts provided will affect the reported results in the period when the matter is resolved.
Litigation and other regulatory: NWM Group is engaged in various legal proceedings, both in the UK and in overseas jurisdictions,
including the US. For further information in relation to legal proceedings and discussion of the associated uncertainties, refer to
Note 25.
Other provisions: These materially comprise provisions for onerous contracts and restructuring costs. Onerous contract provisions
comprise an estimate of the costs involved in fulfilling the terms and conditions of contracts net of any expected benefits to be
received. Redundancy and restructuring provisions comprise the estimated cost of restructuring, including redundancy costs where
an obligation exists.
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
147
21 Share capital and reserves
Number of shares
2023
2022
2023
2022
Allotted, called up and fully paid
£m
£m
000s
000s
Ordinary shares of £1
400
400
399,517
399,517
Ordinary shares
In 2023, NWM Plc paid ordinary dividends £nil (2022 - £430
million).
Paid-in equity
Comprises equity instruments issued by NWM Plc other than
those legally constituted as shares.
Additional Tier 1 instruments issued by NWM Plc having the legal
form of debt are classified as equity under IFRS. The coupons on
these instruments are non-cumulative and payable at NWM Plc’s
discretion.
2023
2022
£m
£m
Additional Tier 1 instruments
US$950 million 7.9604% instruments callable
August 2025
749
749
US$200 million 5.540% instruments callable
August 2025
155
155
904
904
Capital recognised for regulatory purposes cannot be redeemed
without Prudential Regulation Authority consent. This includes
ordinary shares, preference shares and additional Tier 1
instruments.
Reserves
NWM Plc optimises capital efficiency by maintaining reserves in
subsidiaries, including regulated entities. Certain preference
shares and subordinated debt are also included within regulatory
capital. The remittance of reserves to the parent or the
redemption of shares or subordinated capital by regulated
entities may be subject to maintaining the capital resources
required by the relevant regulator.
For accounting policy information refer to Accounting policy 3.8.
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
148
22 Structured entities
A structured entity (SE) is an entity that has been designed such
that voting or similar rights are not the dominant factor in
deciding who controls the entity, for example when any voting
rights relate to administrative tasks only and the relevant
activities are directed by means of contractual arrangements.
SEs are usually established for a specific, limited purpose, they do
not carry out a business or trade and typically have no
employees.
Securitisations
In a securitisation, assets, or interests in a pool of assets, are
transferred to a SE which then issues liabilities to third party
investors.
NWM Group’s involvement in client securitisations takes a
number of forms. It may provide secured finance to, or purchase
asset-backed notes from, client sponsored SEs secured on assets
transferred by the client entity; purchase asset backed securities
issued by client sponsored SEs in the primary or secondary
markets; or provide liquidity facilities to client sponsored SEs. In
addition, NWM Group arranges or acts as lead manager or
placement agent in client primary markets securitisations. NWM
Group provides portfolio structured derivative hedging solutions
to clients.
Covered debt programme
NWM Group has assigned certain loans to customers and other
debt instruments to bankruptcy remote limited liability
partnerships to provide security for issues of debt securities by
NWM Group. NWM Group retains all of the risks and rewards of
these assets and continues to recognise them. The partnerships
are consolidated by the NWM Group, and the related covered
debt included within other financial liabilities. At 31 December
2023, £1,283 million (2022 - £1,164 million) of loans and other
debt instruments provided security for £1,497 million (2022 –
£1,290 million) debt securities in issue and other borrowing by
NWM Plc and NWM Group.
Lending of own issued securities
NWM Plc has issued, retained, and lent debt securities under
securities lending arrangements. Under standard terms in the UK
and US markets, the recipient has an unrestricted right to sell or
re-pledge collateral, subject to returning equivalent securities on
maturity of the transaction.
NWM Plc retains all of the risks and
rewards of own issued liabilities lent under such arrangements
and does not recognise them.
At 31 December 2023, £2,312
million (2022 - £2,419 million) of secured own issued liabilities
have been retained and lent under securities lending
arrangements. At 31 December 2023, £2,414 million (2022 -
£2,244 million) of loans and other debt instruments provided
security for secured own issued liabilities that have been retained
and lent under securities lending arrangements.
Unconsolidated structured entities
The term ‘unconsolidated structured entities’ refers to structured entities not controlled by NWM Group, and which are established
either by NWM Group or a third party. An interest in a structured entity is any form of contractual or non-contractual involvement
which creates variability in returns for NWM Group arising from the performance of the entity. Such interests include holdings of debt
or equity securities, derivatives that transfer financial risks from the entity to NWM Group, provision of lending and loan commitments,
financial guarantees and investment management agreements. NWM Group enters into transactions with unconsolidated structured
entities in the normal course of business to facilitate customer transactions, to provide risk management services and for specific
investment opportunities. Structured entities may take the form of funds, trusts, partnerships, securitisation vehicles, and private
investment companies. NWM Group considers itself to be the sponsor of a structured entity where it is primarily involved in the set up
and design of the entity and where NWM Group transfers assets to the entity, markets products associated with the entity in its own
name, and/or provides guarantees in relation to the performance of the entity.
The nature and extent of NWM Group’s interests in structured entities is summarised below.
2023
2022
Asset-backed
Investment
Asset-backed
Investment
securitisation
funds
securitisation
funds
vehicles
and other
Total
vehicles
and other
Total
£m
£m
£m
£m
£m
£m
Assets
Trading assets
303
311
614
616
137
753
Derivatives
134
-
134
343
-
343
Loans to customers
2,487
634
3,121
2,395
273
2,668
Other financial assets
10,475
1,063
11,538
4,932
849
5,781
Total
13,399
2,008
15,407
8,286
1,259
9,545
Liabilities
Derivatives
214
17
231
388
22
410
Total
214
17
231
388
22
410
Off balance sheet
Liquidity facilities/loan commitments
1,758
312
2,070
1,474
236
1,710
Guarantees
-
117
117
-
93
93
Total
1,758
429
2,187
1,474
329
1,803
Maximum exposure
14,943
2,420
17,363
9,372
1,566
10,938
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
149
23 Asset transfers
Transfers that do not qualify for derecognition
NWM Group enters into securities financing, reverse repurchase
and total return agreements in accordance with normal market
practice which includes the provision of additional collateral if
necessary.
Under standard terms in the UK and US markets, the
recipient has an unrestricted right to sell or repledge collateral,
subject to returning equivalent securities on maturity of the
transaction.
Securities sold under repurchase transactions and transactions
with the substance of securities repurchase agreements are not
derecognised if the NWM Group retains substantially all the risks
and rewards of ownership. The fair value (and carrying value) of
securities transferred under such transactions included on the
balance sheet, are set out below. All of these securities could be
sold or repledged by the holder.
NWM Group
NWM Plc
2023
2022
2023
2022
The following assets have failed derecognition
(1)
£m
£m
£m
£m
Trading assets
7,907
6,668
7,330
4,413
Other financial assets
2,296
761
1,907
761
Total
10,203
7,429
9,237
5,174
(1)
Associated liabilities were £10,085 million for the NWM Group (2022 - £7,364 million) and £9,148 million for NWM Plc (2022 - £5,116 million).
Assets pledged as collateral
NWM Group pledges collateral with its counterparties in respect of derivative liabilities and bank and stock borrowings.
NWM Group
NWM Plc
2023
2022
2023
2022
Assets pledged against liabilities
£m
£m
£m
£m
Trading assets
10,749
14,776
8,600
12,017
Other financial assets
(1)
5,483
2,938
4,621
2,565
16,232
17,714
13,221
14,582
(1)
Includes pledges for stock borrowing.
The following table analyses assets that have been transferred but have failed the derecognition rules under IFRS 9 and therefore
continue to be recognised on NWM Plc’s balance sheet.
2023
2022
Asset type
£m
£m
Loans and other debt instruments - covered debt programme
(1)
1,637
1,164
Loans and other debt instruments - own issued retained lent securities
(2)
2,414
2,244
(1)
The associated liabilities for covered debt programme were £1,497 million (2022 - £1,290 million).
(2)
The associated own issued securities that were retained and lent under securities lending arrangements were £2,312 million (2022 - £2,419 million).
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
150
24 Capital resources
Regulatory capital for NWM Plc legal entity is assessed against minimum requirements that are set out under the UK Capital
Requirements Regulation. Transitional arrangements on the phasing in of end-point capital resources are set by the PRA.
The capital resources under the PRA transitional basis for NWM Plc are set out below.
2023
2022
Shareholders’ equity
£m
£m
Shareholders’ equity
6,313
6,518
Other equity instruments
(904)
(904)
5,409
5,614
Regulatory adjustments and deductions
Own credit
25
11
Defined benefit pension fund adjustment
(94)
(159)
Cash flow hedging reserve
187
284
Prudential valuation adjustments
(160)
(197)
Expected losses less impairments
(6)
(3)
Instruments of financial sector entities where the institution has a significant investment
(1,585)
(1,869)
Adjustments under IFRS 9 transitional arrangements
1
1
Other adjustments for regulatory purposes
(1)
-
(1,633)
(1,932)
CET1 capital
3,776
3,682
Additional Tier 1 (AT1) capital
Qualifying instruments and related share premium
904
904
Tier 1 deductions
Instruments of financial sector entities where the institution has a significant investment
(225)
(225)
Tier 1 capital
4,455
4,361
Qualifying Tier 2 capital
Qualifying instruments and related share premium
1,022
1,555
Tier 2 deductions
Instruments of financial sector entities where the institution has a significant investment
(421)
(441)
Other regulatory adjustments
16
27
(405)
(414)
Tier 2 capital
617
1,141
Total regulatory capital
5,072
5,502
In the management of capital resources, NWM Plc is governed by
NatWest Group's policy to maintain a strong capital base and to
utilise it efficiently throughout its activities to optimise the return
to shareholders while maintaining a prudent relationship between
the capital base and the underlying risks of the business. In
carrying out this policy, NatWest Group has regard to the
supervisory requirements of the PRA. The PRA uses capital ratios
as a measure of capital adequacy in the UK banking sector,
comparing a bank's capital resources with its risk-weighted
assets (the assets and off-balance sheet exposures are weighted
to reflect the inherent credit and other risks); by international
agreement, the Pillar 1 capital ratios, excluding capital buffers,
should be not less than 8% with a Common Equity Tier 1
component of not less than 4.5%. NWM Plc has complied with the
PRA’s capital requirements throughout the year. NWM Plc is also
subject to a Pillar 2 requirement.
Subsidiaries and sub-groups within NWM Group, principally
banking entities, are subject to various individual regulatory
capital requirements in the UK and overseas. Furthermore, the
payment of dividends by subsidiaries and the ability of members
of NatWest Group to lend money to other members of NatWest
Group is subject to restrictions such as local regulatory or legal
requirements, the availability of reserves and financial and
operating performance.
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
151
25 Memorandum items
Contingent liabilities and commitments
The amounts shown in the table below are intended only to provide an indication of the volume of business outstanding at 31
December 2023. Although the NWM Group is exposed to credit risk in the event of a customer’s failure to meet its obligations, the
amounts shown do not, and are not intended to, provide any indication of NWM Group’s expectation of future losses.
For accounting policy information refer to Accounting policy 2.4.
NWM Group
NWM Plc
2023
2022
2023
2022
£m
£m
£m
£m
Contingent liabilities and commitments
Guarantees and assets pledged as collateral security
754
594
296
144
Other contingent liabilities
26
30
26
30
Standby facilities, credit lines and other commitments
14,690
13,973
9,304
7,967
Total
15,470
14,597
9,626
8,141
Banking commitments and contingent obligations, which have
been entered into on behalf of customers and for which there are
corresponding obligations from customers, are not included in
assets and liabilities. NWM Group’s maximum exposure to credit
loss, in the event of its obligation crystallising and all
counterclaims, collateral or security proving valueless, is
represented by the contractual nominal amount of these
instruments included in the table above. These commitments and
contingent obligations are subject to NWM Group’s normal credit
approval processes.
Guarantees
- NWM Group gives guarantees on behalf of
customers. A financial guarantee represents an irrevocable
undertaking that NWM Group will meet a customer’s specified
obligations to a third party if the customer fails to do so. The
maximum amount that NWM Group could be required to pay
under a guarantee is its principal amount as in the table above.
NWM Group expects most guarantees it provides to expire
unused.
Other contingent liabilities
- these include standby letters of
credit, supporting customer debt issues and contingent liabilities
relating to customer trading activities such as those arising from
performance and customs bonds, warranties and indemnities.
Standby facilities and credit lines
- under a loan commitment
NWM Group agrees to make funds available to a customer in the
future. Loan commitments, which are usually for a specified term
may be unconditionally cancellable or may persist, provided all
conditions in the loan facility are satisfied or waived.
Commitments to lend include commercial standby facilities and
credit lines, liquidity facilities to commercial paper conduits and
unutilised overdraft facilities.
Other commitments
- these include documentary credits, which
are commercial letters of credit providing for payment by NWM
Group to a named beneficiary against presentation of specified
documents, forward asset purchases, forward deposits placed
and undrawn note issuance and revolving underwriting facilities,
and other short-term trade related transactions.
Risk-sharing arrangements
During 2019 NWM Plc and NWM N.V. established limited risk-
sharing arrangements that facilitated the smooth provision of
services to NatWest Markets’ customers. The arrangements,
which NWM Plc recognises as financial guarantees within
Amounts due to subsidiaries, include:
The provision of a funded guarantee of up to £1.0 billion by
NWM Plc to NWM N.V. that limits NWM N.V.’s exposure to
large individual customer credits to 10% of NWM N.V.’s
capital. Funding is provided by NWM Plc deposits placed with
NWM N.V. of not less than the guaranteed amount.
At 31
December 2023, the deposits amounted to £0.7 billion and
the guaranteed fees in the year were £4.6 million.
The provision of funded and unfunded guarantees by NWM
Plc in respect of NWM N.V.’s Legacy portfolio. At 31
December 2023 the exposure at default covered by the
guarantees was approximately £0.2 billion (of which £27
million was cash collateralised). Fees of £1.4 million in relation
to the guarantees were recognised in the year.
Indemnity deed
In April 2019, NWM Plc and NWB Plc entered into a cross
indemnity agreement for losses incurred within the entities in
relation to business transferred to or from the ring-fenced
bank under the NatWest Group’s structural re-organisation.
Under the agreement, NWM Plc is indemnified by NWB Plc
against losses relating to the NWB Plc transferring businesses
and ring-fenced bank obligations and NWB Plc is indemnified
by NWM Plc against losses relating to NWM Plc transferring
businesses and non-ring-fenced bank obligations with effect
from the relevant transfer date.
Litigation
25 Memorandum items continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
152
Litigation and regulatory matters
NWM Plc and its subsidiary and associated undertakings (NWM
Group) are party to various legal proceedings and are involved in,
or subject to, various regulatory matters, including as the subject
of investigations and other regulatory and governmental action
(Matters) in the United Kingdom (UK), the United States (US), the
European Union (EU) and other jurisdictions.
NWM Group recognises a provision for a liability in relation to
these Matters when it is probable that an outflow of economic
benefits will be required to settle an obligation resulting from past
events, and a reliable estimate can be made of the amount of the
obligation.
In many of the Matters, it is not possible to determine whether
any loss is probable, or to estimate reliably the amount of any
loss, either as a direct consequence of the relevant proceedings
and regulatory matters or as a result of adverse impacts or
restrictions on NWM Group’s reputation, businesses and
operations. Numerous legal and factual issues may need to be
resolved, including through potentially lengthy discovery and
document production exercises and determination of important
factual matters, and by addressing novel or unsettled legal
questions relevant to the proceedings in question, before the
probability of a liability, if any, arising can reasonably be
estimated in respect of any Matter. NWM Group cannot predict
if, how, or when such claims will be resolved or what the
eventual settlement, damages, fine, penalty or other relief, if any,
may be, particularly for Matters that are at an early stage in
their development or where claimants seek substantial or
indeterminate damages.
There are situations where NWM Group may pursue an
approach that in some instances leads to a settlement
agreement. This may occur in order to avoid the expense,
management distraction or reputational implications of continuing
to contest liability, or in order to take account of the risks
inherent in defending or contesting Matters, even for those for
which NWM Group believes it has credible defences and should
prevail on the merits. The uncertainties inherent in all Matters
affect the amount and timing of any potential economic outflows
for both Matters with respect to which provisions have been
established and other contingent liabilities in respect of any such
Matter.
It is not practicable to provide an aggregate estimate of potential
liability for our Matters as a class of contingent liabilities.
The future economic outflow in respect of any Matter may
ultimately prove to be substantially greater than, or less than, the
aggregate provision, if any, that NWM Group has recognised in
respect of such Matter. Where a reliable estimate of the
economic outflow cannot be reasonably made, no provision has
been recognised. NWM Group expects that in future periods,
additional provisions and economic outflows relating to Matters
that may or may not be currently known by NWM Group will be
necessary, in amounts that are expected to be substantial in
some instances. Please refer to Note 20 for information on
material provisions.
Matters which are, or could be, material, either individually or in
aggregate, having regard to NWM Group, considered as a whole,
in which NWM Group is currently involved are set out below. We
have provided information on the procedural history of certain
Matters, where we believe appropriate, to aid the understanding
of the Matter.
For a discussion of certain risks associated with NWM Group’s
litigation and regulatory matters (including the Matters), see the
Risk Factor relating to legal, regulatory and governmental actions
and investigations set out on pages 186 to 187.
London Interbank Offered Rate (LIBOR) and other rates
litigation
NWM Plc and certain other members of NatWest Group,
including NatWest Group plc, are defendants in a number of class
actions and individual claims pending in the United States District
Court for the Southern District of New York (SDNY) with respect
to the setting of LIBOR and certain other benchmark interest
rates. The complainants allege that the NWM Group defendants
and other panel banks violated various federal laws, including the
US commodities and antitrust laws, and state statutory and
common law, as well as contracts, by manipulating LIBOR and
prices of LIBOR-based derivatives in various markets through
various means.
Several purported class actions relating to USD LIBOR, as well as
more than two dozen non-class actions concerning USD LIBOR
and involving NWM Group companies, are part of a co-ordinated
proceeding in the SDNY. The class actions include claims on
behalf of persons who purchased LIBOR-linked instruments from
defendants, bonds issued by defendants, persons who transacted
futures and options on exchanges, and lenders who made
LIBOR-based loans. The coordinated proceeding is currently in
the discovery phase. NatWest Group companies’ previously
disclosed settlement of a class action on behalf of bondholder
plaintiffs has received final court approval. The amount of the
settlement was covered by an existing provision.
The non-class claims filed in the SDNY include claims that the
FDIC is asserting on behalf of certain failed US banks. In July
2017, the FDIC, on behalf of 39 of those failed US banks,
commenced substantially similar claims against NWM Plc,
NatWest Group plc and others in the High Court of Justice of
England and Wales. The action alleges collusion with regard to
the setting of USD LIBOR and that the defendants breached UK
and European competition law, as well as asserting common law
claims of fraud under US law. The defendant banks consented to
a request by the FDIC for discontinuance of the claim in respect
of 20 failed US banks, leaving 19 failed US banks as claimants.
The trial is currently anticipated to commence in Q1 2026.
In addition to the USD LIBOR cases described above, there is a
class action relating to derivatives allegedly tied to JPY LIBOR
and Euroyen TIBOR, which was dismissed by the SDNY in
relation to NWM Plc and other NatWest Group companies in
September 2021. That dismissal may be the subject of a future
appeal. The SDNY’s dismissal of another class action, which
related to Euroyen TIBOR futures contracts, was affirmed by the
United States Court of Appeals for the Second Circuit (US Court
of Appeals) in October 2022. The plaintiffs filed a petition with the
United States Supreme Court seeking review of the dismissal, but
that petition was denied in October 2023.
Two other IBOR-related class actions involving NWM Plc,
concerning alleged manipulation of Euribor and Pound Sterling
LIBOR, were previously dismissed by the SDNY for various
reasons. The plaintiffs’ appeals in those two cases remain
pending.
NWM Plc’s previously disclosed settlement of a class action
relating to Swiss Franc LIBOR has received final court approval.
The settlement amount has been paid by NWM Plc and was
covered in full by an existing provision.
In August 2020, a complaint was filed in the United States District
Court for the Northern District of California by several United
States retail borrowers against the USD ICE LIBOR panel banks
and their affiliates (including NatWest Group plc, NWM Plc,
NatWest Markets Securities Inc. (NWMSI) and NWB Plc), alleging
(i) that the very process of setting USD ICE LIBOR amounts to
illegal price-fixing; and (ii) that banks in the United States have
illegally agreed to use LIBOR as a component of price in variable
retail loans. In September 2022, the district court dismissed the
the consolidated motion outside the Israeli jurisdiction. That NWM
25 Memorandum items continued
Notes to the consolidated financial statements continued
certify the class actions. NWM Plc has filed a motion challenging
the permission granted by the court for the
applicants to serve
NWM Group
Annual Report and Accounts 2023
153
Litigation and regulatory matters
complaint. The plaintiffs filed an amended complaint but in
October 2023, the district court dismissed that complaint as well,
and indicated that further amendment would not be permitted.
The plaintiffs have commenced an appeal to the United States
Court of Appeals for the Ninth Circuit which is currently pending.
NWM Plc is also named as a defendant in a motion to certify a
class action relating to LIBOR in the Tel Aviv District Court in
Israel. NWM Plc filed a motion for cancellation of service outside
the jurisdiction, which was granted in July 2020. The claimants
appealed that decision and in November 2020 the appeal was
refused and the claim dismissed by the Appellate Court. The
claim could in future be recommenced depending on the
outcome of an appeal to Israel’s Supreme Court in respect of the
dismissal of the substantive case against banks that had a
presence in Israel.
FX litigation
NWM Plc, NWMSI and/or NatWest Group plc are defendants in
several cases relating to NWM Plc’s foreign exchange (FX)
business.
An FX-related class action, on behalf of ‘consumers and end-user
businesses’, was proceeding in the SDNY against NWM Plc and
others. In March 2023, the court granted summary judgment in
favour of the defendants, dismissing the plaintiffs’ claims. The
plaintiffs have commenced an appeal of that decision as well as a
prior decision denying class certification in the case.
In May 2019, a cartel class action was filed in the Federal Court
of Australia against NWM Plc and four other banks on behalf of
persons who bought or sold currency through FX spots or
forwards between 1 January 2008 and 15 October 2013 with a
total transaction value exceeding AUD $0.5 million. The claimant
has alleged that the banks, including NWM Plc, contravened
Australian competition law by sharing information, coordinating
conduct, widening spreads and manipulating FX rates for certain
currency pairs during this period. NatWest Group plc and NWMSI
have been named in the action as ‘other cartel participants’, but
are not respondents. The claim was served in June 2019 and
NWM Plc filed its defence in March 2022.
In July and December 2019, two separate applications seeking
opt-out collective proceedings orders were filed in the UK
Competition Appeal Tribunal (CAT) against NatWest Group plc,
NWM Plc and other banks. Both applications were brought on
behalf of persons who, between 18 December 2007 and 31
January 2013, entered into a relevant FX spot or outright
forward transaction in the EEA with a relevant financial institution
or on an electronic communications network. In March 2022, the
CAT declined to certify as collective proceedings either of the
applications, which was appealed by the applicants, and the
subject of an application for judicial review. In its amended
judgment in November 2023, the Court of Appeal allowed the
appeal and decided that the claims should proceed on an opt-out
basis. Separately, the court determined which of the two
competing applicants can proceed as class representative, and
dismissed the application for judicial review of the CAT’s decision.
The case has been remitted to the CAT for further case
management and the banks have sought permission to appeal
directly to the UK Supreme Court.
Two motions to certify FX-related class actions were filed in the
Tel Aviv District Court in Israel in September and October 2018,
and were subsequently consolidated into one motion. The
consolidated motion to certify, which names The Royal Bank of
Scotland plc (now NWM Plc) and several other banks as
defendants, was served on NWM Plc in May 2020. The applicants
have sought the court’s permission to amend their motions to
Plc motion remains pending.
In December 2021, a summons was served in the Netherlands
against NatWest Group plc, NWM Plc and NWM N.V. by Stichting
FX Claims on behalf of a number of parties, seeking declarations
from the court concerning liability for anti-competitive FX market
conduct described in decisions of the European Commission (EC)
of 16 May 2019, along with unspecified damages. The claimant
amended its claim to also refer to a 2 December 2021 decision
by the EC, which
described anti-competitive FX market conduct.
NatWest Group plc, NWM Plc and other defendants contested
the jurisdiction of the Dutch court.
In March 2023, the district
court in Amsterdam accepted that it has jurisdiction to hear
claims against NWM N.V. but refused jurisdiction to hear any
claims against the other defendant banks (including NatWest
Group plc and NWM Plc) brought on behalf of the parties
represented by the claimant that are domiciled outside of the
Netherlands. The claimant is appealing that decision and the
defendant banks have brought cross-appeals which seek a ruling
that the Dutch court has no jurisdiction to hear any claims
against the defendant banks domiciled outside of the
Netherlands, including claims brought on behalf of the parties
represented by the claimant that are domiciled in the
Netherlands.
In September 2023, second summonses were served by Stichting
FX Claims on NWM N.V., NatWest Group plc and NWM Plc, for
claims on behalf of a new group of parties that have now been
brought before the district court in Amsterdam. The summonses
seek declarations from the Dutch court concerning liability for
anti-competitive FX market conduct described in the above
referenced decisions of the EC of 16 May 2019 and 2 December
2021, along with unspecified damages.
Certain other foreign exchange transaction related claims have
been or may be threatened. NWM Group cannot predict whether
all or any of these claims will be pursued.
Government securities antitrust litigation
NWMSI and certain other US broker-dealers are defendants in a
consolidated antitrust class action in the SDNY on behalf of
persons who transacted in US Treasury securities or derivatives
based on such instruments, including futures and options. The
plaintiffs allege that the defendants rigged the US Treasury
securities auction bidding process to deflate prices at which they
bought such securities and colluded to increase the prices at
which they sold such securities to the plaintiffs. In March 2022,
the SDNY dismissed the complaint, without leave to re-plead. In
February 2024, the US Court of Appeals affirmed the SDNY’s
decision dismissing the complaint.
Class action antitrust claims commenced in March 2019 are
pending in the SDNY against NWM Plc, NWMSI and other banks
in respect of Euro-denominated bonds issued by various
European central banks (European government bonds or EGBs).
The complaint alleges a conspiracy among dealers of EGBs to
widen the bid-ask spreads they quoted to customers, thereby
increasing the prices customers paid for the EGBs or decreasing
the prices at which customers sold EGBs. The class consists of
those who purchased or sold EGBs in the US between 2007 and
2012. Previously, in March 2022, the SDNY dismissed the claims
against NWM Plc and NWMSI on the ground that the complaint’s
conspiracy allegations were insufficient. However, in September
2023, the SDNY ruled that new allegations which plaintiffs have
included in an amended complaint are sufficient to bring those
NatWest entities back into the case as defendants.
Madoff
25 Memorandum items continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
154
Litigation and regulatory matters
Swaps antitrust litigation
NWM Plc, NWMSI and NatWest Group plc, as well as a number of
other interest rate swap dealers, are defendants in several cases
pending in the SDNY alleging violations of the US antitrust laws in
the market for interest rate swaps. There is a consolidated class
action complaint on behalf of persons who entered into interest
rate swaps with the defendants, as well as non-class action
claims by three swap execution facilities (TeraExchange, Javelin,
and trueEx). The plaintiffs allege that the swap execution facilities
would have successfully established exchange-like trading of
interest rate swaps if the defendants had not unlawfully
conspired to prevent that from happening through boycotts and
other means. Discovery in these cases is complete. In December
2023, the SDNY denied the plaintiffs’ motion for class
certification. The plaintiffs have filed a petition requesting that the
US Court of Appeals review the denial of class certification.
In June 2021, a class action antitrust complaint was filed against
a number of credit default swap dealers, in New Mexico federal
court on behalf of persons who, from 2005 onwards, settled
credit default swaps in the United States by reference to the
ISDA credit default swap auction protocol. The complaint alleges
that the defendants conspired to manipulate that benchmark
through various means in violation of the antitrust laws and the
Commodity Exchange Act. The defendants filed a motion to
dismiss the complaint and, in June 2023, such motion was denied
as regards NWMSI and other financial institutions, but granted as
regards to NWM Plc on the ground that the court lacks
jurisdiction over that entity. As a result, the case entered the
discovery phase as against the non-dismissed defendants. In
January 2024, the SDNY issued an order barring the plaintiffs in
the New Mexico case from pursuing claims based on conduct
occurring before 30 June 2014 on the ground that such claims
were extinguished by a 2015 settlement agreement that resolved
a prior class action relating to credit default swaps.
Odd lot corporate bond trading antitrust litigation
In October 2021, the SDNY granted the defendants’ motion to
dismiss the class action antitrust complaint alleging that from
August 2006 onwards various securities dealers, including
NWMSI, conspired artificially to widen spreads for odd lots of
corporate bonds bought or sold in the United States secondary
market and to boycott electronic trading platforms that would
have allegedly promoted pricing competition in the market for
such bonds. The plaintiffs have filed an appeal.
Spoofing litigation
In December 2021, three substantially similar class actions
complaints were filed in federal court in the United States against
NWM Plc and NWMSI alleging Commodity Exchange Act and
common law unjust enrichment claims arising from manipulative
trading known as spoofing. The complaints refer to NWM Plc’s
December 2021 spoofing-related guilty plea (described below
under “US investigations relating to fixed-income securities”) and
purport to assert claims on behalf of those who transacted in US
Treasury securities and futures and options on US Treasury
securities between 2008 and 2018. In July 2022, defendants filed
a motion to dismiss these claims, which have been consolidated
into one matter in the United States District Court for the
Northern District of Illinois.
NWM N.V. was named as a defendant in two actions filed by the
trustee for the bankrupt estates of Bernard L. Madoff and
Bernard L. Madoff Investment Securities LLC, in bankruptcy
court in New York, which together seek to clawback more than
US$298 million that NWM N.V. allegedly received from certain
Madoff feeder funds and certain swap counterparties. The claims
were previously dismissed, but as a result of an August 2021
decision by the US Court of Appeals, they will now proceed in the
bankruptcy court, where they have been consolidated into one
action, subject to NWM N.V.’s legal and factual defences. In May
2022, NWM N.V. filed a motion to dismiss the amended complaint
in the consolidated action
and such motion was denied in March
2023. As a result, the case has now entered the discovery phase.
EUA trading litigation
NWM Plc was a named defendant in civil proceedings before the
High Court of Justice of England and Wales brought in 2015 by
ten companies (all in liquidation) (the ‘Liquidated Companies’) and
their respective liquidators (together, ‘the Claimants’). The
Liquidated Companies previously traded in European Union
Allowances (EUAs) in 2009 and were alleged to be VAT
defaulting traders within (or otherwise connected to) EUA supply
chains of which NWM Plc was a party. In March 2020, the court
held that NWM Plc and Mercuria Energy Europe Trading Limited
(‘Mercuria’) were liable for dishonestly assisting and knowingly
being a party to fraudulent trading during a seven business day
period in 2009.
In October 2020, the High Court quantified total damages against
NWM Plc and Mercuria at £45 million plus interest and costs, and
permitted the defendants to appeal to the Court of Appeal. In
May 2021 the Court of Appeal set aside the High Court’s
judgment and ordered that a retrial take place before a different
High Court judge. In January 2024, NWM Plc entered into an
agreement to resolve the claim against it. The settlement amount
paid by NWM Plc was covered in full by an existing provision.
US Anti-Terrorism Act litigation
NWM N.V. and certain other financial institutions are defendants
in several actions filed by a number of US nationals (or their
estates, survivors, or heirs), most of whom are or were US
military personnel, who were killed or injured in attacks in Iraq
between 2003 and 2011. NWM Plc is also a defendant in some of
these cases.
According to the plaintiffs’ allegations, the defendants are liable
for damages arising from the attacks because they allegedly
conspired with and/or aided and abetted Iran and certain Iranian
banks to assist Iran in transferring money to Hezbollah and the
Iraqi terror cells that committed the attacks, in violation of the US
Anti-Terrorism Act, by agreeing to engage in ‘stripping’ of
transactions initiated by the Iranian banks so that the Iranian
nexus to the transactions would not be detected.
The first of these actions, alleging conspiracy claims but not
aiding and abetting claims, was filed in the United States District
Court for the Eastern District of New York in November 2014. In
September 2019, the district court dismissed the case, finding
that the claims were deficient for several reasons, including lack
of sufficient allegations as to the alleged conspiracy and
causation. In January 2023, the US Court of Appeals affirmed the
district court’s dismissal of this case. The plaintiffs filed a petition
with the United States Supreme Court seeking review of the
dismissal of their claims and that petition was denied in October
2023. It is anticipated that the plaintiffs will file a motion to re-
open the case to assert aiding and abetting claims that they
previously did not assert. Another action, filed in the SDNY in
2017, which asserted both conspiracy and aiding and abetting
claims, was dismissed by the SDNY in March 2019 on similar
grounds as the first case, but remains subject to appeal to the US
Court of Appeals.
US investigations relating to fixed-income securities
25 Memorandum items continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
155
Litigation and regulatory matters
Other follow-on actions that are substantially similar to those
described above are pending in the same courts.
1MDB litigation
A Malaysian court claim was served in Switzerland in November
2022 by 1MDB, a Sovereign Wealth Fund, in which Coutts & Co
Ltd was named, along with six others, as a defendant in respect
of losses allegedly incurred by 1MDB. It is claimed that Coutts &
Co Ltd is liable as a constructive trustee for having dishonestly
assisted the directors of 1MDB in the breach of their fiduciary
duties by failing (amongst other alleged claims) to undertake due
diligence in relation to a customer of Coutts & Co Ltd, through
which funds totalling c.US$1 billion were received and paid out
between 2009 and 2011. The claimant seeks the return of that
amount plus interest. Coutts & Co Ltd filed an application in
January 2023 challenging the validity of service and the
Malaysian court’s jurisdiction to hear the claim. Before that
application was heard, in April 2023, the claimant filed a notice of
discontinuance of its claim against certain defendants including
Coutts & Co Ltd. The claimant subsequently indicated that it
intended to issue further replacement proceedings. Coutts & Co
Ltd challenged the claimant’s ability to take that step. In August
2023, the court disallowed the discontinuation of the claim by the
claimant (a decision that the claimant has appealed) and directed
that the application by Coutts & Co Ltd challenging the validity of
the proceedings should proceed to a hearing, which took place in
February 2024. Judgment is awaited.
Coutts & Co Ltd (a subsidiary of RBS Netherlands Holdings B.V.,
which in turn is a subsidiary of NWM Plc) is a company registered
in Switzerland and is in wind-down following the announced sale
of its business assets in 2015.
Regulatory matters
NWM Group’s financial condition can be affected by the actions
of various governmental and regulatory authorities in the UK, the
US, the EU and elsewhere. NWM Group companies have
engaged, and will continue to engage, in discussions with
relevant governmental and regulatory authorities, including in the
UK, the US, the EU and elsewhere, on an ongoing and regular
basis, and in response to informal and formal inquiries or
investigations, regarding operational, systems and control
evaluations and issues including those related to compliance with
applicable laws and regulations, including consumer protection,
investment advice, business conduct, competition/anti-trust, VAT
recovery, anti-bribery, anti-money laundering and sanctions
regimes.
Any matters discussed or identified during such discussions and
inquiries may result in, among other things, further inquiry or
investigation, other action being taken by governmental and
regulatory authorities, increased costs being incurred by NWM
Group, remediation of systems and controls, public or private
censure, restriction of NWM Group’s business activities and/or
fines. Any of the events or circumstances mentioned in this
paragraph or below could have a material adverse effect on
NWM Group, its business, authorisations and licences, reputation,
results of operations or the price of securities issued by it, or lead
to material additional provisions being taken.
NWM Group is co-operating fully with the matters described
below.
In December 2021, NWM Plc pled guilty in the United States
District Court for the District of Connecticut to one count of wire
fraud and one count of securities fraud in connection with
historical spoofing conduct by former employees in US Treasuries
markets between January 2008 and May 2014 and, separately,
during approximately three months in 2018. The 2018 trading
occurred during the term of a non-prosecution agreement (NPA)
between NWMSI and the United States Attorney's Office for the
District of Connecticut (USAO CT), under which non-prosecution
was conditioned on NWMSI and affiliated companies not
engaging in criminal conduct during the term of the NPA. The
relevant trading in 2018 was conducted by two NWM traders in
Singapore and breached that NPA. The plea agreement reached
with the US Department of Justice and the USAO CT resolved
both the spoofing conduct and the breach of the NPA.
As required by the resolution and sentence imposed by the court,
NWM Plc is subject to a three-year period of probation scheduled
to end in December 2024. The plea agreement also imposes an
independent corporate monitor. In addition, NWM Plc has
committed to compliance programme reviews and improvements
and agreed to reporting and co-operation obligations.
Other material adverse collateral consequences may occur as a
result of this matter, as further described in the Risk Factor
relating to legal, regulatory and governmental actions and
investigations set out on page 186 to 187.
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
156
26 Non-cash and other items
This note shows non-cash items adjusted for in the cash flow statement and movement in operating assets and liabilities.
NWM Group
NWM Plc
2023
2022
2023
2022
£m
£m
£m
£m
Impairment losses/(releases)
2
8
1
(1)
Depreciation and amortisation
16
16
6
6
Net impairment/(reversal) of impairment of investments in Group undertakings
-
-
293
(81)
Change in fair value taken to profit or loss of other financial assets
-
168
-
168
Change in fair value taken to profit or loss on other financial liabilities
and subordinated liabilities
90
(251)
73
(169)
Elimination of foreign exchange differences
253
(458)
109
(177)
Other non-cash items
198
(82)
203
(60)
Income receivable on other financial assets
(642)
(218)
(582)
(234)
Loss on sale of other financial assets
1
11
-
4
Dividends receivable from subsidiaries
-
-
(349)
(53)
Profit on sale of subsidiaries and associates
-
-
-
(2)
Profit on sale of other assets and net assets and liabilities
(1)
-
(1)
Interest payable on MRELs and subordinated liabilities
252
227
241
210
Loss on redemption of own debt
14
74
14
4
Charges and release on provisions
(4)
15
19
15
Defined benefit pension schemes
(6)
2
(6)
2
Non-cash and other items
173
(488)
21
(368)
Change in operating assets and liabilities
Change in trading assets
372
14,994
(2,317)
14,482
Change in derivatives assets
20,794
4,973
20,371
6,377
Change in settlement balances assets
(4,669)
(419)
(482)
(891)
Change in net loans to banks
247
4
222
29
Change in net loans to customers
(2,812)
(2,703)
(2,946)
(2,336)
Change in amounts due from holding company and fellow subsidiaries
(573)
577
1,879
(105)
Change in other financial assets
84
(62)
62
(35)
Change in other assets
46
(85)
40
(80)
Change in bank deposits
(802)
1,261
(1,027)
1,128
Change in customer deposits
3,384
1,346
395
1,155
Change in amounts due to holding company and fellow subsidiaries
184
719
2,117
2,517
Change in settlement balances liabilities
4,631
(58)
(733)
105
Change in trading liabilities
831
(11,690)
854
(13,894)
Change in derivatives liabilities
(21,604)
(4,912)
(21,350)
(4,342)
Change in other financial liabilities
2,627
2,395
2,353
1,799
Change in other liabilities
(123)
(47)
(110)
(26)
Change in operating assets and liabilities
2,617
6,293
(672)
5,883
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
157
27 Analysis of changes in financing during the year
NWM Group
Share capital, share
premium and
Subordinated
paid-in equity
liabilities
(1)
MRELs
(2)
2023
2022
2023
2022
2023
2022
£m
£m
£m
£m
£m
£m
At 1 January
3,250
3,250
1,985
2,427
3,173
3,857
Redemption of subordinated liabilities
(676)
(481)
Interest paid on subordinated liabilities
(71)
(92)
Issue of MRELs
1,699
986
Maturity and redemption of MRELs
(1,744)
(1,862)
Interest paid on MRELs
(175)
(151)
Net cash flows from financing activities
-
-
(747)
(573)
(220)
(1,027)
Effects of foreign exchange
(61)
154
(124)
304
Changes in fair value of subordinated liabilities and MRELs
33
(153)
57
(98)
Interest payable on subordinated liabilities and MRELs
68
90
184
137
Loss on redemption of own debt
14
74
-
-
Other
-
-
4
(34)
-
-
At 31 December
3,250
3,250
1,296
1,985
3,070
3,173
NWM Plc
Share capital, share
premium and
Subordinated
paid-in equity
liabilities
(1)
MRELs
(2)
2023
2022
2023
2022
2023
2022
£m
£m
£m
£m
£m
£m
At 1 January
3,250
3,250
1,661
1,879
3,173
3,857
Redemption of subordinated liabilities
(595)
(277)
Interest paid on subordinated liabilities
(57)
(73)
Issue of MRELs
1,699
986
Maturity of MRELs
(1,744)
(1,862)
Interest paid on MRELs
(175)
(151)
Net cash flows from financing activities
-
-
(652)
(350)
(220)
(1,027)
Effects of foreign exchange
(55)
126
(124)
304
Changes in fair value of subordinated liabilities and MRELs
16
(71)
57
(98)
Interest payable on subordinated liabilities and MRELs
57
73
184
137
Loss on redemption of own debt
14
4
-
-
At 31 December
3,250
3,250
1,041
1,661
3,070
3,173
(1)
Subordinated liabilities include intercompany subordinated liabilities.
(2)
MREL balances are included in amounts due to holding company and fellow subsidiaries.
28 Analysis of cash and cash equivalents
In the cash flow statement, cash and cash equivalents comprises cash, loans to banks and treasury bills with an original maturity of
less than three months that are readily convertible to known amounts of cash and subject to insignificant risk of change in value.
NWM Group
NWM Plc
2023
2022
2023
2022
£m
£m
£m
£m
Cash and balances at central banks
13,831
17,007
8,607
13,467
Trading assets
8,723
8,318
4,065
5,272
Other financial assets
139
19
139
19
Loans to banks including intragroup balances
(1)
2,250
1,484
4,177
2,165
Cash and cash equivalents
24,943
26,828
16,988
20,923
(1)
NWM Group includes cash collateral posted with bank counterparties in respect of derivative liabilities of £4,305 million (2022 - £4,661 million), and NWM Plc includes cash collateral
posted with bank counterparties in respect of derivative liabilities of £3,656 million (2022 - £3,934 million).
Certain members of NatWest Group are required by law or regulation to maintain balances with the central banks in the jurisdictions in
which they operate. NatWest Markets N.V. had mandatory reserve deposits with De Nederlandsche Bank N.V. of €132 million (2022 -
€64 million).
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
158
29 Directors' and key management remuneration
2023
2022
Directors' remuneration
£000
£000
Non-executive directors emoluments
319
315
Chairman and executive directors emoluments
2,477
2,481
2,796
2,796
Amounts receivable under LTIPs, share option and other plans
604
249
Total
3,400
3,045
The total emoluments and amounts receivable under long-term incentive plans and share option plans of the highest paid director
were £2,153,000 (2022 - £1,946,000).
The executive directors may participate in NatWest Group’s long-term incentive plans, executive share option and share save
schemes. Where directors of the Bank are also directors of NatWest Group, details of their share interests can be found in the 2023
Annual Report and Accounts of the NatWest Group, in line with regulations applying to NatWest Group as a premium listed company.
Compensation of key management
The aggregate remuneration of directors and other members of key management during the year was as follows:
2023
2022
£000
£000
Short term benefits
12,635
14,532
Post employment benefits
592
557
Share-based payments
3,878
4,729
17,105
19,818
Short term benefits include benefits expected to be settled wholly within twelve months of Balance Sheet date. Post-employment
benefits include defined benefit contributions for active members and pension funding to support contributions to the defined
contribution schemes. Share-based payments include awards vesting under rewards schemes.
30 Transactions with directors and key management
At 31 December 2023, amounts outstanding in relation to transactions, arrangements and agreements entered into by authorised
institutions in NatWest Group, as defined in UK legislation, were £229,540 in respect of loans to one director of the company at any
time during the financial period (2022 - £350,982).
For the purposes of IAS 24 Related party disclosures, key management comprises directors of the company and members of the
Executive Committee. Amounts in the table below are attributed to each person at their highest level of NatWest Group key
management.
2023
2022
£000
£000
Loans to customers - amortised cost
230
351
Customer deposits
2,163
2,501
Key management has banking relationships with NatWest Group entities which are entered into in the normal course of business and
on substantially the same terms, including interest rates and security, as for comparable transactions with other persons of a similar
standing or, where applicable, with other employees. These transactions did not involve more than the normal risk of repayment or
present other unfavourable features. Key management had no reportable transactions or balances with the holding company.
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
159
31 Related parties
UK Government
UK Government through HM Treasury is controlling shareholder
of NatWest Group plc as per UK Listing rules. The UK
Government’s shareholding is managed by UK Government
Investments Limited, a company wholly owned by the UK
Government. At 31 December 2023, HM Treasury’s holding in
NatWest Group’s ordinary shares was 37.97%. As a result the UK
Government and UK Government controlled bodies are related
parties of the Group.
NWM Group enters into transactions with many of these bodies.
Transactions include the payment of: taxes principally UK
corporation tax (refer to Note 7) and value added tax; national
insurance contributions; local authority rates; and regulatory fees
and levy; together with banking transactions such as loans and
deposits undertaken in the normal course of banker-customer
relationships.
Bank of England facilities
NWM Group may participate in a number of schemes operated
by the Bank of England in the normal course of business.
Members of NWM Group that are UK authorised institutions are
required to maintain non-interest bearing (cash ratio) deposits
with the Bank of England amounting to 0.382% of their average
eligible liabilities in excess of £600 million. They also have access
to Bank of England reserve accounts: sterling current accounts
that earn interest at the Bank of England base rate.
Other related parties
(a)
In their roles as providers of finance, NWM Group companies
provide development and other types of capital support to
businesses.
(b) To further strategic partnerships, NWM Group may seek to
invest in third parties or allow third parties to hold a minority
interest in a subsidiary of NWM Group. We disclose as related
parties for associates and joint ventures and where equity
interest are over 10%. Ongoing business transactions with
these entities are on normal commercial terms.
(c)
In accordance with IAS 24, transactions, or balances between
NWM Group entities that have been eliminated on
consolidation are not reported.
(d)
NWM Group is recharged from other NatWest Group entities,
mainly NWB Plc which provides the majority of shared
services (including technology) and operational processes.
(e) The primary financial statements include transactions and
balances with its subsidiaries which have been further
disclosed in the relevant parent company notes
.
Holding company and fellow subsidiaries
Transactions NWM Group enters with its holding company and fellow subsidiaries also meet the definition of related party transactions.
The table below discloses transactions between NWM Group and fellow subsidiaries of NatWest Group.
2023
2022
Holding company
Fellow subsidiaries
Total
Holding company
Fellow subsidiaries
Total
£m
£m
£m
£m
£m
£m
Interest receivable
1
29
30
6
6
12
Interest payable
(274)
(45)
(319)
(188)
10
(178)
Fees and commissions receivable
3
68
71
3
82
85
Fees and commissions payable
-
(39)
(39)
-
(49)
(49)
Other operating income
(1)
-
177
177
-
-
-
Other administration expenses
(2)
-
(540)
(540)
-
(575)
(575)
(270)
(350)
(620)
(179)
(526)
(705)
(1)
Other operating income relates to a new profit share arrangement with fellow NatWest Group subsidiaries that commenced in 2023. The profit share arrangement was introduced during
the year to reward NWM Group on an arm’s length basis for its contribution to the performance of the NatWest Group Commercial & Institutional business segment, 2023 being the first
full year with the Commercial & Institutional segment in place.
(2)
Includes internal service recharges of £540 million (2022 - £552 million).
31 Related parties continued
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
160
Amounts due from/to holding company and fellow subsidiaries are as below:
NWM Group
2023
2022
Holding
Fellow
Holding
Fellow
company
subsidiaries
Total
company
subsidiaries
Total
£m
£m
£m
£m
£m
£m
Assets
Trading assets
-
273
273
-
274
274
Loans to banks - amortised cost
-
1,246
1,246
-
406
406
Loans to customers - amortised cost
17
-
17
18
12
30
Settlement balances
-
-
-
-
2
2
Other assets
-
194
194
-
28
28
Amounts due from holding company and fellow subsidiaries
17
1,713
1,730
18
722
740
Derivatives
(1)
761
537
1,298
1,074
569
1,643
Liabilities
Bank deposits - amortised cost
-
537
537
-
108
108
Customer deposits - amortised cost
-
55
55
-
51
51
Trading liabilities
735
293
1,028
811
318
1,129
Settlement balances
-
-
-
-
26
26
Other financial liabilities - subordinated liabilities
1,022
-
1,022
1,519
-
1,519
MREL instruments issued to NatWest Group plc
3,070
-
3,070
3,173
-
3,173
Other liabilities
17
73
90
16
195
211
Amounts due to holding company and fellow subsidiaries
4,844
958
5,802
5,519
698
6,217
Derivatives
(1)
84
260
344
252
364
616
NWM Plc
2023
2022
Holding
Fellow
Holding
Fellow
company
subsidiaries
Subsidiaries
Total
company
Subsidiaries
subsidiaries
Total
£m
£m
£m
£m
£m
£m
£m
£m
Assets
Trading assets
-
272
3,041
3,313
-
274
3,262
3,536
Loans to banks - amortised cost
-
1,049
799
1,848
-
320
1,110
1,430
Loans to customers - amortised cost
-
-
772
772
-
-
892
892
Settlement balances
-
-
91
91
-
2
257
259
Other financial assets
-
-
214
214
-
-
489
489
Other assets
-
183
51
234
-
18
41
59
Amounts due from holding company and fellow subsidiaries
-
1,504
4,968
6,472
-
614
6,051
6,665
Derivatives
(1)
761
537
2,442
3,740
1,074
568
3,381
5,023
Liabilities
Bank deposits - amortised cost
-
538
109
647
-
108
493
601
Customer deposits - amortised cost
-
55
745
800
-
51
1,085
1,136
Trading liabilities
735
292
6,783
7,810
811
318
4,895
6,024
Settlement balances
-
-
906
906
-
26
167
193
Other financial liabilities - subordinated liabilities
1,022
-
-
1,022
1,519
-
-
1,519
MREL instruments issued to NatWest Group plc
3,070
-
-
3,070
3,173
-
-
3,173
Other liabilities
17
50
63
130
16
170
35
221
Amounts due to holding company and fellow subsidiaries
4,844
935
8,606
14,385
5,519
673
6,675
12,867
Derivatives
(1)
84
260
2,676
3,020
252
364
3,677
4,293
(1)
Intercompany derivatives are included within derivative classification on the balance sheet.
There was £28 million (2022 - £28 million) of NWM Group commitments and guarantees related to transactions with fellow group
companies.
Notes to the consolidated financial statements continued
NWM Group
Annual Report and Accounts 2023
161
32 Ultimate holding company
NWM Group’s ultimate holding company is NatWest Group plc which is incorporated in the United Kingdom and registered in Scotland.
As at 31 December 2023, NatWest Group plc heads the largest group in which NWM Group is consolidated. Copies of the consolidated
accounts may be obtained from Legal, Governance & Regulatory Affairs, NatWest Group plc, Gogarburn, PO Box 1000, Edinburgh
EH12 1HQ, the Registrar of Companies or at natwestgroup.com.
Following placing and open offers by NatWest Group plc in December 2008 and April 2009, the UK Government, through HM
Treasury, held 37.97% (at 31 December 2023) of the issued ordinary share capital of NatWest Group plc and was therefore the NWM
Group’s ultimate controlling party.
33 Post balance sheet events
On 9 January 2024, NWM Plc issued a total of €2.5 billion of notes under the EMTN programme in benchmark transactions. There has
been no adjustment to the 31 December 2023 statutory financial statements.
Other than as disclosed in the accounts, there have been no other significant events between 31 December 2023 and the date of
approval of these accounts which would require a change to or additional disclosure
.
Notes to the financial statements continued
NWM Group
Annual Report and Accounts 2023
162
34 Related undertakings
Legal entities and activities at 31 December 2023
In accordance with the Companies Act 2006, NWM Plc’s related undertakings and the accounting treatment for each are listed below.
All undertakings are wholly owned by NWM Plc or subsidiaries of NWM Plc and are consolidated by reason of contractual control
(Section 1162(2) CA 2006), unless otherwise indicated. NWM Group interest refers to ordinary shares of equal values and voting rights
unless further analysis is provided in the notes. Activities are classified in accordance with Annex I to the Capital Requirements
Directive (“CRD V”) and the definitions in Article 4 of the UK Capital Requirements Regulation.
The following table details active related undertakings incorporated in the UK which are 100% owned by NWM Group and
fully consolidated for accounting purposes
Regulatory
Entity name
Activity
treatment
Notes
280 Bishopsgate Finance Ltd
INV
FC
(1)
Care Homes 2 Ltd
BF
FC
(1)
Care Homes 3 Ltd
BF
FC
(1)
Care Homes Holdings Ltd
BF
FC
(1)
Lombard Corporate Finance (11) Ltd
BF
FC
(1)
Lombard Corporate Finance (6) Ltd
BF
FC
(1)
NatWest Markets Secretarial Services Ltd
SC
FC
(1)
NatWest Markets Secured Funding LLP
BF
FC
(7)
Patalex Productions Ltd
BF
FC
(1)
Price Productions Ltd
BF
FC
(1)
Priority Sites Ltd
INV
DE
(1)
R.B. Equipment Leasing Ltd
BF
FC
(1)
R.B. Leasing Company Ltd
BF
FC
(2)
Regulatory
Entity name
Activity
treatment
Notes
RB Investments 3 Ltd
OTH
FC
(1)
RBOS (UK) Ltd
BF
FC
(1)
RBS Management Services (UK) Ltd
SC
FC
(1)
RBS Mezzanine Ltd
BF
FC
(2)
RBS Property Developments Ltd
INV
FC
(2)
RBS Property Ventures Investments Ltd
BF
FC
(2)
Royal Bank Investments Ltd
BF
FC
(2)
Royal Bank Ventures Investments Ltd
BF
FC
(2)
West Register (Hotels Number 3) Ltd
INV
DE
(2)
West Register (Property Investments) Ltd
BF
DE
(2)
West Register (Realisations) Ltd
INV
DE
(2)
Winchcombe Finance Ltd
BF
FC
(1)
The following table details active related undertakings incorporated outside the UK which are 100% owned by NWM Group
and fully consolidated for accounting purposes
Regulatory
Regulatory
Entity name
Activity
treatment
Notes
Entity name
Activity
treatment
Notes
Alcover A.G.
BF
DE
(16)
Random Properties Acquisition Corp. III
INV
FC
(3)
Alternative Investment Fund B.V.
BF
FC
(6)
RBS Acceptance Inc.
BF
FC
(3)
Candlelight Acquisition LLC
BF
FC
(3)
RBS Commercial Funding Inc.
BF
FC
(3)
Coutts & Co Ltd
CI
FC
(15)
RBS Employment (Guernsey) Ltd
SC
FC
(21)
Coutts General Partner (Cayman) V Ltd
BF
FC
(14)
RBS Financial Products Inc.
BF
FC
(3)
Financial Asset Securities Corp.
BF
FC
(3)
RBS Group (Australia) Pty Ltd
BF
FC
(8)
KEB Investors, L.P.
BF
FC
(13)
RBS Holdings III (Australia) Pty Ltd
BF
FC
(8)
Maja Finance S.R.L.
BF
FC
(12)
RBS Holdings N.V.
BF
FC
(6)
NatWest Markets Group Holdings Corporation
BF
FC
(3)
RBS Holdings USA Inc.
BF
FC
(3)
NatWest Markets N.V.
CI
FC
(6)
RBS Hollandsche N.V.
BF
FC
(6)
NatWest Markets Securities Inc.
INV
FC
(3)
RBS Investments (Ireland) Ltd
BF
FC
(4)
NatWest Markets Securities Japan Ltd
INV
FC
(19)
RBS Netherlands Holdings B.V.
BF
FC
(6)
NatWest Services Inc.
SC
FC
(3)
RBS Nominees (Hong Kong) Ltd
BF
FC
(19)
R.B. Leasing BDA One Ltd
BF
FC
(18)
RBS Nominees (Ireland) Ltd
BF
FC
(4)
The following table details active related undertakings incorporated in the UK where NWM Group ownership is less than
100%
Accounting
Regulatory
Group
Entity name
Activity
treatment
treatment
%
Notes
Natwest Markets Secured
Funding (LM) Ltd
BF
FC
PC
20
(7)
RBS Sempra Commodities LLP
BF
FC
FC
51
(2)
The following table details active related undertakings incorporated outside the UK where NWM Group ownership is less
than 100%
Accounting
Regulatory
Group
Entity name
Activity
treatment
treatment
%
Notes
Eris Finance S.R.L.
BF
IA
PC
45
(12)
Herge Holding B.V.
BF
IA
PC
63
(17)
Lunar Funding VIII Ltd
BF
FC
DE
0
(5)
Lunar Luxembourg SA
BF
FC
DE
0
(10)
Lunar Luxembourg Series 2019-
BF
FC
DE
0
(10)
04
Lunar Luxembourg Series 2019-
BF
FC
DE
0
(10)
05
Lunar Luxembourg Series 2019-
BF
FC
DE
0
(10)
06
Accounting
Regulatory
Group
Entity name
Activity
treatment
treatment
%
Notes
Lunar Luxembourg Series 2020-
BF
FC
DE
0
(10)
01
Lunar Luxembourg Series 2020-
BF
FC
DE
0
(10)
02
Lunar Luxembourg Series 2022-01
BF
FC
DE
0
(10)
Natwest Markets Secured Funding
BF
FC
FC
0
(11)
DAC
Sempra Energy
Trading Llc
BF
FC
FC
51
(3)
Solar Funding II Ltd
BF
FC
FC
0
(20)
Thames Asset Global
BF
FC
FC
0
(9)
Securitization No.1 Inc.
34 Related undertakings continued
Notes to the financial statements continued
NWM Group
Annual Report and Accounts 2023
163
The following table details related undertakings that are not active (actively being dissolved)
Accounting
Regulatory
Group
Entity name
treatment
treatment
%
Notes
Care Homes 1 Ltd
FC
FC
100
(1)
Churchill Management Ltd
FC
FC
100
(1)
Desertlands Entertainment Ltd
FC
FC
100
(1)
Property Venture Partners Ltd
FC
FC
100
(2)
Accounting
Regulatory
Group
Entity name
treatment
treatment
%
Notes
R.B.S. Special Investments Ltd
FC
FC
100
(1)
RBSM Capital Ltd
FC
FC
100
(2)
RoboScot Equity Ltd
FC
FC
100
(2)
The following table details related undertakings that are dormant
Accounting
Regulatory
Group
 
Entity name
treatment
treatment
%
Notes
Atlas Nominees Ltd
FC
FC
100
(19)
Buchanan Holdings Ltd
FC
FC
100
(1)
N.C. Head Office Nominees Ltd
FC
FC
100
(2)
Project & Export Finance (Nominees) Ltd
FC
FC
100
(1)
Accounting
Regulatory
Group
Entity name
treatment
treatment
%
Notes
RBOS Nominees Ltd
FC
FC
100
(1)
Sixty Seven Nominees Ltd
FC
FC
100
(1)
The Royal Bank Of Scotland (1727) Ltd
FC
FC
100
(2)
The following table details the overseas branches of NWM Group
Subsidiary
Geographic location
NatWest Markets N.V.
France, Germany, Italy, Sweden
Subsidiary
Geographic location
Germany, India, Japan, Singapore,
NatWest Markets Plc
Turkey, United Arab Emirates
Key:
BF
Banking and financial institution
CI
Credit institution
INV
Investment (shares or property) holding company
SC
Service company
TR
Trustee
OTH
Other
DE
Deconsolidated
FC
Full consolidation
PC
Pro-rata consolidation
AHC
Associate held at cost
EAJV
Equity accounting – joint venture
IA
Investment accounting
NC
Not consolidated
Notes
Registered addresses
Country of incorporation
(1)
250 Bishopsgate, London, EC2M 4AA, England
UK
(2)
RBS Gogarburn, 175 Glasgow Road, Edinburgh, EH12 1HQ, Scotland
UK
(3)
251 Little Falls Drive, Wilmington, DE, 19808
USA
(4)
Ulster Bank Head Office, Block B Central Park, Leopardstown, Dublin 18, D18 N153, Ireland
RoI
(5)
Grand Pavilion Commercial Centre, 802 West Bay Road, P.O. Box 31119
Cayman Islands
(6)
Claude Debussylaan 94, Amsterdam, 1082 MD
Netherlands
(7)
1 Bartholomew Lane London EC2N 2AX, England
UK
(8)
Ashurst, Level 16, 80 Collins Street, South Tower, Melbourne, VIC, 3000
Australia
(9)
114 West 47th Street, New York, 10036
USA
(10)
40, Avenue J.F Kennedy, Kirchberg,
L 1855
Luxembourg
(11)
5 Harbourmaster Place, Dublin 1, D01 E7E8
RoI
(12)
Alfieri V. 1, Conegliano
Italy
(13)
Clarendon House, Two Church Street, Suite 104, Reid Street, Hamilton, HM 11
Bermuda
(14)
Maples Corporate Services Limited, P.O. Box 309, 121 South Church Street, George Town, Grand Cayman, KY1-1104
Cayman Islands
(15)
Schuetzengassse 4, CH-8001 Zurich
Switzerland
(16)
Tirolerweg 8, Zug, CH- 6300
Switzerland
(17)
Verlengde Poolseweg 16, Breda, 4818C
Netherlands
(18)
Victoria Place, 5th Floor, 31 Victoria Street, Hamilton, HM 10
Bermuda
(19)
5/F Manulife Place, 348 Kwun Tong Road, Kowloon
Hong Kong
(20)
IFC5, St.Helier, JE1 1ST
Jersey
(21)
Les Echelons Court, Les Echelons, St Peter Port, GY1 1AR
Guernsey
Non-IFRS measures
NWM Group
Annual Report and Accounts 2023
164
NWM Group prepares its financial statements in accordance with
generally accepted accounting principles (GAAP). This document
contains a number of adjusted or alternative performance
measures, also known as non-GAAP or non-IFRS performance
measures. These measures are adjusted for certain items which
management believe are not representative of the underlying
performance of the business and which distort period-on-period
comparison. These non-IFRS measures are not measures within
the scope of IFRS and are not a substitute for IFRS measures.
These measures include:
Management analysis of operating expenses shows litigation
and conduct costs on a separate line on page 21. These
amounts are included within staff costs and other
administrative expenses in the statutory analysis. Other
operating expenses excludes litigation and conduct costs
which are more volatile and may distort comparisons with
prior periods.
Funded assets are defined as total assets less derivative
assets. This measure allows review of balance sheet trends
exclusive of the volatility associated with derivative fair values.
Management view of income by business including shared
revenue and before own credit adjustments. This measure is
used to show underlying income generation in NatWest
Markets excluding the impact of own credit adjustments.
Revenue share refers to income generated by NatWest
Markets products from customers that have their primary
relationship with other NatWest Group subsidiaries, a
proportion of which is shared between NatWest Markets and
those subsidiaries.
Transfer Pricing arrangements with fellow NatWest Group
subsidiaries includes revenue share and a new profit share
arrangement with fellow NatWest Group subsidiaries. The
profit share arrangement was introduced during the year to
reward NWM Group on an arm’s length basis for its
contribution to the performance of the NatWest Group
Commercial & Institutional business segment, 2023 being the
first full year with the Commercial & Institutional segment in
place. The profit share is not allocated to individual NatWest
Markets product areas.
Own credit adjustments are applied to positions where it is
believed that the counterparties would consider NWM Group’s
creditworthiness when pricing trades. The fair value of certain
issued debt securities, including structured notes, is adjusted
to reflect the changes in own credit spreads and the resulting
gain or loss recognised in income.
Operating expenses – management view
Year ended
31 December 2023
31 December 2022
Litigation
Other
Statutory
Litigation
Other
Statutory
and conduct
operating
operating
and conduct
operating
operating
costs
expenses
expenses
costs
expenses
expenses
£m
£m
£m
£m
£m
£m
Staff expenses
12
406
418
5
395
400
Premises and equipment
-
66
66
-
60
60
Depreciation and amortisation
-
16
16
-
16
16
Other administrative expenses
48
594
642
75
577
652
Total
60
1,082
1,142
80
1,048
1,128
Risk Factors
NWM Group
Annual Report and Accounts 2023
165
Principal Risks and Uncertainties
Set out below are certain risk factors that could have a material
adverse effect on NWM Group’s future results, its financial
condition, and/or prospects, and cause them to be materially
different from what is forecast or expected, and directly or
indirectly impact the value of its securities. These risk factors are
broadly categorised and should be read in conjunction with other
risk factors in this section and other parts of this annual report,
including the forward-looking statements section, the strategic
report and the risk and capital management section. They should
not be regarded as a complete and comprehensive statement of
all potential risks and uncertainties facing NWM Group.
Economic and political risk
NWM Group, its customers and its counterparties face
continued economic and political risks and uncertainties in
the UK and global markets, including as a result of inflation
and interest rates, supply chain disruption, and geopolitical
developments.
NWM Group is affected by global economic and market
conditions, particularly those in the UK. Uncertain and volatile
economic conditions can create a challenging operating
environment for financial services companies such as NWM
Group. The outlook for the UK and the global economy is affected
by many factors including: GDP growth, inflation and changing
interest rates, changing asset prices (including residential and
commercial property), energy prices, supply chain disruption, and
changes to monetary and fiscal policy.
These conditions could be exacerbated by a number of factors
including: instability in the UK and/or global financial systems,
market volatility and change, fluctuations in the value of the
pound sterling, new or extended economic sanctions, economic
volatility in the UK or globally, volatility in commodity prices,
political uncertainty or instability (for example the upcoming US
presidential election and the UK general election to take place
before February 2025), or concerns regarding sovereign debt or
sovereign credit ratings, changing demographics in the markets
that NWM Group and its customers serve, increasing social and
other inequalities, rapid changes to the economic environment
due to the adoption of technology, automation, artificial
intelligence, or due to climate change, and/or other sustainability-
related risks. See also ‘Changes in interest rates will continue to
affect NWM Group’s business and results’ and ‘Fluctuations in
currency exchange rates may adversely affect NWM Group’s
results and financial condition’.
NWM Group is also exposed to risks arising out of geopolitical
events or political developments that may hinder economic or
financial activity levels. Political, military or diplomatic events,
geopolitical tensions armed conflict (for example the Russia-
Ukraine and Israel-Hamas conflicts), terrorist acts or threats,
protectionist policies or trade barriers, widespread public health
crises, related potential adverse effects on supply chains and the
responses to any of the above scenarios by various governments
and markets, could negatively affect the business and
performance of NWM Group, including as a result of the direct or
indirect impact on UK, regional or global trade and/or NWM
Group’s customers and counterparties.
In recent years, the UK has experienced significant political
uncertainty and a general election will take place before February
2025. Heightened political uncertainty could lead to a loss of
confidence in the UK, that could in turn, negatively impact the
economy and companies operating in the UK. NatWest Group also
faces political uncertainty in Scotland as a result of a possible
Scottish independence referendum.
Scottish independence may adversely affect NWM Group plc both
in relation to NatWest Group entities incorporated in Scotland and
in other jurisdictions. Any changes to Scotland’s relationship with
the UK or the EU may adversely affect the environment in which
NatWest Group plc and its subsidiaries operate and may require
further changes to NatWest Group (including NWM Group’s
structure), independently or in conjunction with other mandatory
or strategic structural and organisational changes, any of which
could adversely affect NWM Group.
The value of NWM Group’s own and other securities may be
materially affected by market risk, including as a result of market
fluctuations. Market volatility, illiquid market conditions and
disruptions in the financial markets may make it very difficult to
value certain of NWM Group’s own and other securities,
particularly during periods of market displacement. This could
cause a decline in the value of NWM Group’s own and other
securities, or inaccurate carrying values for certain financial
instruments. Similarly, NWM Group trades a considerable amount
of financial instruments (including derivatives) and volatile market
conditions could result in a significant decline in NWM Group’s net
trading income or result in a trading loss.
In addition, financial markets are susceptible to severe events
evidenced by, or resulting in, rapid depreciation in asset values,
which may be accompanied by a reduction in asset liquidity.
Under these conditions, hedging and other risk management
strategies may not be as effective at mitigating losses as they
would be under more normal market conditions. Moreover, under
these conditions, market participants are particularly exposed to
trading strategies employed by many market participants
simultaneously (and often automatically) and on a large scale,
increasing NWM Group’s counterparty risk. NWM Group’s risk
management and monitoring processes seek to quantify and
mitigate NWM Group’s exposure to extreme market moves.
However, market events have historically been difficult to predict,
and NWM Group, its customers and its counterparties could
realise significant losses if extreme market events were to occur.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
Fluctuations in currency exchange rates may adversely
affect NWM Group’s results and financial condition.
Decisions of central banks (including the Bank of England, the
European Central Bank and the US Federal Reserve) and political
or market events which are outside NWM Group’s control, may
lead to sharp and sudden fluctuations in currency exchange rates.
Although NWM Group is principally a UK-focused banking group, it
is subject to structural foreign exchange risk from capital
deployed in NWM Group’s foreign subsidiaries and branches.
NWM Group also issues instruments in non-sterling currencies,
such as USD, that assist in meeting NWM Group’s MREL
requirements. In addition, NWM Group conducts banking activity
in non-sterling currencies (for example, loans, deposits and
dealing activity) which affect its revenue. NWM Group also uses
service providers based outside of the United Kingdom for certain
services and as a result certain operating expenses are subject to
fluctuations in currency exchange rate. NWM Group maintains
policies and procedures designed to manage the impact of its
exposure to fluctuations in currency exchange rates.
Nevertheless, changes in currency exchange rates, particularly in
the sterling-US dollar and sterling-euro rates, may adversely
affect various accounting and financial metrics including the value
of assets, liabilities (including the total amount of MREL-eligible
instruments), income and expenses, RWAs and hence the
reported earnings and financial condition of NWM Group.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, reputation,
and/or its ability to meet regulatory capital adequacy
requirements.
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
166
Changes in interest rates will continue to affect NWM
Group’s business and results.
NWM Group’s performance is affected by changes in interest
rates. Benchmark overnight interest rates, such as the UK base
rate, increased in 2023, although forward rates at 31 December
2023 suggested interest rates may begin to fall in 2024.
Stable interest rates support predictable income flow and less
volatility in asset and liability valuations, although persistently low
and negative interest rates may adversely affect NWM Group.
Further, volatility in interest rates may result in unexpected
outcomes both for interest income and asset and liability
valuations which may adversely affect NWM Group. For example,
unexpected movements in spreads between key benchmark rates
such as sovereign and swap rates may, in turn, affect liquidity
portfolio valuations. In addition, unexpected sharp rises in rates
may also have negative impacts on some asset and derivative
valuations. Furthermore, customer and investor responses to
rapid changes in interest rates can have an adverse effect on
NWM Group. For example, customers may make deposit choices
that provide them with higher returns than those then being
offered by NWM Group, and NWM Group may not respond with
competitive products as rapidly, for example following an interest
rate change which may in turn decrease NWM Group’s net
interest income.
Movements in interest rates also influence and reflect the
macroeconomic situation more broadly, affecting factors such as
business and consumer confidence, property prices, default rates
on loans, customer behaviour, and other indicators that may
indirectly affect NWM Group.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
Continuing uncertainty regarding the effects and extent of
the UK’s post Brexit divergence from EU laws and
regulation, and NWM Group’s post Brexit EU operating
model may adversely affect NWM Group and its operating
environment
.
As a result of the UK’s withdrawal from the EU, certain aspects of
the services provided by NatWest Group require local licences or
individual equivalence decisions (temporary or otherwise) by
relevant regulators. In late 2021 the European Commission
proposed legislation that would require non-EU firms to establish
a branch or subsidiary in the EU before providing ‘banking
services’ in the EU. When these proposals become law all
‘banking services’ provided by NatWest Group (of which NWM
Group forms part) in the EU may be licensable activities in each
EU member state in which it provides such services and member
states may not be permitted to offer bilateral permissions to
financial institutions outside the EU allowing them to provide such
‘banking services’ except in limited circumstances. Furthermore,
failure to extend existing equivalence determinations, exemptions
and derogations in relation to regulations such as margin and
clearing regulations or capital regulations, may adversely affect
customer engagement and/or may significantly negatively impact
the operating model and business operations of NWM Group.
NatWest Group continues to evaluate its EU operating model,
making adaptations as necessary. Changes to NatWest Group’s
and NWM Group’s EU operating model have been, and may
continue to be, costly and failure to receive regulatory permissions
and/or further changes to its business operations, product
offering, customer engagement, and regulatory requirements
could result in further costs and/or regulatory sanction.
Furthermore, transferring business to an EEA based subsidiary,
including in connection with NatWest Group’s Western European
corporate portfolio, is a complex exercise and involves legal,
regulatory and execution risks, and could result in a loss of
business and/or customers or higher than anticipated costs (see
also, ‘The transfer of NatWest Group’s Western European
corporate portfolio involves certain risks.’). Any of the above
could, in turn, adversely affect NWM Group.
On 13 November 2023, the European Central Bank (ECB)
confirmed that RBS Holdings N.V. and its subsidiary NatWest
Markets NV (both subsidiaries of NWM Group) were classified as a
“significant supervised group”. As a result, the ECB assumed
direct supervision of both subsidiaries on 1 January 2024. Direct
ECB supervision could
have an adverse effect on NWM Group’s
business strategy, operating model and prudential requirements.
The long-term effects of Brexit and the uncertainty regarding
NWM Group’s EU operating model may adversely affect NWM
Group and its customers and counterparties who are themselves
dependent on trading with the EU or personnel from the EU. The
long-term effects of Brexit may also be exacerbated by wider UK
and global macroeconomic trends and events.
Uncertainties remain as to the extent to which EU/EEA laws will
diverge from UK law. For example, bank regulation in the UK may
diverge from European bank regulation following the enactment
of the Financial Services and Markets Act 2023 (‘FSMA 2023’)
and the Retained EU Law (Revocation and Reform) Act 2023. In
particular, FSMA 2023 provides for the revocation of Retained EU
Law relating to financial services regulation but sets out that this
process will likely take a number of years and that the intention is
that specific retained EU laws will not be revoked until such time
as replacement regulatory rules are in place. The actions taken by
regulators in response to any new or revised bank regulation and
other rules affecting financial services, may adversely affect NWM
Group, including its business, non-UK operations, group structure,
compliance costs, intragroup arrangements and capital
requirements.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
HM Treasury (or UKGI on its behalf) could exercise a
significant degree of influence over NatWest Group and
NWM Group is controlled by NatWest Group.
In its Autumn Statement 2023 (presented on 22 November 2023),
the UK Government confirmed its commitment to exiting its
shareholding in NatWest Group plc, subject to market conditions.
It also stated that it “intends to fully exit by 2025-26 utilising a
range of disposal methods” and “will explore options to launch a
share sale to retail investors in the next twelve months, subject to
supportive market conditions”.
NatWest Group plc has most recently: (i) carried out a directed
buyback of NatWest Group plc ordinary shares from HM Treasury
in May 2023, and (ii) made purchases under NatWest Group plc’s
on-market buyback programmes announced in July 2023 and
February 2024. NatWest Group plc may participate in similar
directed or on-market buybacks in the near- and medium-term
future. As at 8 January 2024, HM Treasury held 36.94% of the
ordinary share capital with voting rights of NatWest Group plc.
Achievement of the UK Government’s Autumn Statement 2023
objective is likely to entail it selling a significant number of
NatWest Group plc’s shares. The precise timing, method and
extent of further HM Treasury’s disposal of NatWest Group plc’s
shares may be driven by economic as well as other considerations
and is uncertain, which could result in a prolonged period of price
volatility for NatWest Group plc’s ordinary shares and its (and
NatWest Group’s (including NWM Group) other securities.
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
167
Any offers or sales of a substantial number of ordinary shares in
NatWest Group plc by HM Treasury (including at a discount or
with other incentives), market expectations about these offers or
sales, or perceptions about the success or failure of any offers or
sales (including for example, media or public attention on any
such offering or post-offer share price performance), and any
directed, on- or off-market buyback activity by NatWest Group
plc, could affect the prevailing market price for the outstanding
ordinary shares of NatWest Group plc, and, in the case of a
directed, on- or off-market buyback, could reduce NatWest Group
plc’s capital and liquidity, which may have an adverse effect on
NWM Group.
HM Treasury has indicated that it intends to respect the
commercial decisions of NatWest Group and that NatWest Group
entities (including NWM Group) will continue to have their own
independent board of directors and management team
determining their own strategy. However, for as long as HM
Treasury remains NatWest Group plc’s largest single shareholder,
HM Treasury and UK Government Investments Limited (‘UKGI’)
(as manager of HM Treasury’s shareholding) could exercise a
significant degree of influence over NatWest Group (including
NWM Group) including: the election or removal of directors, the
appointment or removal of senior management, NatWest Group’s
(including NWM Group’s) capital strategy, dividend policy,
remuneration policy or the conduct of NatWest Group’s
operations. HM Treasury or UKGI’s approach largely depends on
government policy, which could change. The manner in which HM
Treasury or UKGI exercises HM Treasury’s rights as NatWest
Groups plc’s largest single shareholder could give rise to conflicts
between the interests of HM Treasury and the interests of other
shareholders, including as a result of a change in government
policy, which may in turn adversely affect NatWest Group
(including NWM Group). The exertion of such influence over
NatWest Group could in turn adversely affect the governance or
business strategy of NWM Group.
In addition, NWM Plc is a wholly owned subsidiary of NatWest
Group plc, and NatWest Group plc therefore controls NWM Plc’s
board of directors and NWM Group’s corporate policies and
strategic direction. The interests of NatWest Group plc (as an
equity holder and as NWM Group’s parent) and the interests of
the C&I business segment may differ from the interests of NWM
Group or of potential investors in NWM Group’s securities. See
also, ‘NWM Group has been in a period of significant structural
and other change, including as a result of NatWest Group’s
strategy and NatWest Group’s recent creation of its C&I business
segment (of which NWM Group forms part) and may continue to
be subject to significant structural and other change.’
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
Strategic risk
NWM Group has been in a period of significant structural
and other change, including as a result of NatWest Group’s
strategy and NatWest Group’s creation of its C&I business
segment (of which NWM Group forms part) and may
continue to be subject to significant structural and other
change.
As part of NatWest Group’s strategy, NWM Group’s own strategy
has evolved to focus on serving NatWest Group’s corporate and
institutional customer base via the creation of NatWest Group’s
C&I business segment (which combines the previously separately
reporting NatWest Group’s Commercial, NatWest Markets and
RBS International businesses). Since the quarter ending 30 March
2022, NatWest Group plc has been reporting its results under the
C&I operating segment structure, although NWM Plc continues to
also report on a standalone legal entity basis.
The C&I business segment was created to promote closer
operational and strategic alignment to support NatWest Group
growth, with more integrated services to customers across
NatWest Group entities, within and outside the ring-fenced banks
with the potential increased risk of breach of the UK ring-fencing
regime requiring effective conflicts of interest policies. As a result
of further focusing on NatWest Group’s core C&I customers, NWM
Group’s prospects have become further dependent on the
success and strategy of NatWest Group and its C&I business
segment in particular.
NWM Group’s ability to serve its customers may be adversely
affected by its changing business strategy and customer reactions
to the changing nature of NWM Group’s business model may be
more adverse than expected. Previously anticipated revenue and
profitability levels may not be achieved (including in relation to: the
ability to support customer transactions whilst meeting NWM
Group capital targets, and changes to the availability of risk
capital), in the timescales envisaged or at all. An adverse
macroeconomic environment, political and regulatory uncertainty,
market volatility and change, uncertainties regarding the senior
leadership of NatWest Group, and/or strong market competition
may require NWM Group to adjust aspects of its strategy or the
timeframe for its implementation. It is anticipated that NWM Plc
will continue to generate operating losses in the short-term and
as a result its capital levels may decline.
NWM Group’s strategy requires it to meet cost-reduction targets.
A significant proportion of the cost savings are dependent on
simplification of the IT systems and therefore may not be realised
if IT capabilities are not delivered in line with assumptions. In
addition, the scale of changes that have been concurrently
implemented require the implementation and application of robust
governance and controls frameworks and robust IT systems.
There is a risk that NWM Group may not be successful in
maintaining such governance and control frameworks and IT
systems.
As part of NWM Group’s strategy, NWM Group has set a number
of financial, capital and operational targets and expectations,
which are expected to require further reductions to its wider cost
base. The financial, operational and capital targets and
expectations envisaged by NWM’s strategy may not be met or
maintained in the timeframes expected or at all. In addition,
targets and expectations for NWM Group are based on
management plans, projections and models, and are subject to a
number of key assumptions and judgements, any of which may
prove to be inaccurate. NWM Group has implemented a shared
services model and transfer pricing arrangements with some
entities within NatWest Group’s ring-fenced sub-group (including
NatWest Bank Plc and The Royal Bank of Scotland Plc). NWM
Group therefore relies directly or indirectly on NatWest Group
entities to provide services to itself and its clients. This reliance
has increased as a result of NWM Group joining NatWest Group’s
C&I business segment.
A failure of NWM Group to receive these services may result in
operational risk. See, ‘Operational risks (including reliance on third
party suppliers and outsourcing of certain activities) are inherent
in NWM Group’s businesses.’ In addition, any change to the cost
and/or scope of services provided by NatWest Group may impact
NWM Group’s competitive position and its ability to meet its other
targets.
NWM’s strategy entails legal, execution, operational and
regulatory (including compliance with the UK ring-fencing regime),
conflicts, IT system, cybersecurity, culture, people, conduct,
business and financial risks to NWM Group. As a result, NWM
Group may not be able to successfully implement some or all
aspects of its strategy or may not meet any or all of the related
strategic targets or expectations.
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
168
Each of the risks identified above, individually or collectively, could
adversely affect NWM Group’s products and services offering or
office locations, competitive position, ability to meet targets and
commitments, reputation with customers or business model and
may result in higher-than-expected costs, all of which could
adversely affect NWM Group and its ability to deliver its strategy.
There is a risk that the intended benefits of NatWest Group’s and
NWM Group’s strategies may not be realised in the timelines or in
the manner contemplated, or at all. Various aspects of NWM
Group’s strategy may not be successful, may not be completed as
planned, or at all, or could be phased or could progress in a
manner other than as expected. This could lead to additional
management actions by NatWest Group (or NWM Group),
regulatory action or reduced liquidity and/or funding opportunities.
Any of the above may lead to NWM Group not being viable,
competitive, or profitable, and may have a material adverse effect
on NWM Group’s future results, financial condition, prospects,
and/or reputation.
The transfer of NatWest Group’s Western European
corporate portfolio involves certain risks.
To improve efficiencies and best serve customers following Brexit,
NWM Group expects that certain assets, liabilities, transactions
and activities of NatWest Group (including NatWest Group’s
Western European corporate portfolio principally consisting of
term funding and revolving credit facilities) (the ‘Transfer
Business’), may be: (i) transferred from the ring-fenced subgroup
of NatWest Group to NWM Group, and/or (ii) transferred to the
ring-fenced subgroup of NatWest Group from NWM Group,
subject to regulatory and customer requirements. The timing,
success and quantum of any of these transfers remain uncertain
as is the impact of these transactions on its results of operations.
As a result, this may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
Financial resilience risk
NWM Group may not achieve its ambitions, targets and
guidance it communicates, generate returns or implement its
strategy effectively.
As part of NWM Group’s strategy, NWM Group has set a number
of financial, capital and operational targets and guidance including
in respect of: balance sheet and cost-reduction measures, CET1
ratio targets (for NWM Plc and NWM N.V.), MREL targets,
leverage ratio targets (for NWM Plc and NWM N.V.), targets in
relation to local regulation, funding plans and requirements,
employee engagement, diversity and inclusion as well as climate
strategy (including its climate and sustainable funding and
financing targets) and customer satisfaction targets.
NWM Group’s ability to meet its ambitions, targets and guidance
and make discretionary capital distributions is subject to various
internal and external factors, risks and uncertainties. These
include but are not limited to: UK and global macroeconomic,
political, market and regulatory uncertainties, operational risks
and risks relating to NWM Group’s business model and strategy
(including risks associated with climate and other sustainability-
related issues). See also, ‘NWM Group, its customers and its
counterparties face continued economic and political risks and
uncertainties in the UK and global markets, including as a result of
inflation and interest rates, supply chain disruption, and
geopolitical developments.’
A number of factors may impact NWM Plc and NWM N.V.’s
abilities to maintain their respective CET1 ratio targets, including
the macroeconomic environment, impairments, the extent of
organic capital generation or the reduction of RWA and the
receipt and payment of dividends. NWM Plc may incur disposal
losses as part of the process of exiting positions to reduce RWAs.
Some of these losses may be recognised ahead of the actual
disposals and the losses overall may be higher than anticipated.
NWM Group’s ability to meet its planned reductions in annual
costs may vary considerably from year to year. Furthermore, the
focus on maintaining balance sheet and cost-reduction targets
may result in limited investment in other areas which could affect
NWM Group’s long-term product offering or competitive position
and its ability to meet its other targets, including those related to
customer satisfaction.
In addition, challenging trading conditions may adversely affect
NWM Group’s business and its ability to achieve its targets and
guidance and execute its strategy. Furthermore, NWM Group’s
strategy may not be successfully executed or it may not meet its
ambitions, targets, guidance and expectations.
Any of the above may lead to NWM Group not being a viable,
competitive or profitable banking business and may have a
material adverse effect on NWM Group’s future results, financial
condition, prospects, and/or reputation.
NWM Plc and/or its regulated subsidiaries may not meet the
prudential regulatory requirements for regulatory capital.
NWM Group is required by regulators in the UK, the EU and other
jurisdictions in which it undertakes regulated activities to maintain
adequate financial resources. Adequate capital provides NWM
Group with financial flexibility in the face of turbulence and
uncertainty in the global economy and specifically in its core UK
operations.
NWM Plc’s and NWM N.V.’s target CET1 ratios are based on
regulatory requirements and management actions (see the
targets set forth in each respective entity’s Outlook section) that
rely on internal modelling and risk appetite (including under
stress). As at 31 December 2023, NWM Plc’s solo CET1 ratio was
17.1%. NWM Plc’s current capital strategy is based on the
management of RWAs and other capital management initiatives
(including the reduction of RWAs and the periodic payment of
dividends to NatWest Group plc, NWM Plc’s parent company).
Other factors that could influence NWM Plc and NWM N.V.’s
CET1 ratios include:
a depletion of NWM Plc or NWM N.V.’s capital resources
through reduced profits (which would in turn impact retained
earnings) and may result from revenue attrition or increased
liabilities, sustained periods of low interest rates, reduced
asset values resulting in write-downs or reserve adjustments,
impairments, changes in accounting policy, accounting
charges or foreign exchange movements;
a change in the quantum of NWM Plc’s or NWM N.V.’s RWAs,
stemming from exceeding target RWA levels, regulatory
adjustments (for example, from additional market risk
backtesting exceptions), foreign exchange movements or a
failure in internal controls or procedures to accurately
measure and report RWAs. An increase in RWAs would lead
to a reduction in the CET1 ratio (and increase the amount of
internal MREL required for NWM Plc);
changes in prudential regulatory requirements including the
Total Capital Requirement for NWM Plc (as regulated by the
Prudential Regulation Authority (‘PRA’)) or NWM N.V. (as
regulated by the European Central Bank and De
Nederlandsche Bank, including Pillar 2 requirements and
regulatory buffers as well as any applicable scalars;
further developments of prudential regulation (for example,
finalisation of Basel 3.1 standards), which will impact various
areas including the approach to calculating credit risk, market
risk, leverage ratio, capital floors and operational risk RWAs,
as well as continued regulatory uncertainty on the details
thereto;
further losses (including as a result of extreme one-off
incidents such as cyberattack, fraud or conduct issues) would
deplete capital resources and place downward pressure on
the CET1 ratio; or
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
169
the timing of planned liquidation, disposal and/or capital
releases of capital including on activity or legacy entities
owned by NWM Plc and NWM N.V.
See also ‘NWM Group has been in a period of significant structural
and other change, including as a result of NatWest Group’s
strategy and NatWest Group’s recent creation of its C&I business
segment (of which NWM Group forms part) and may continue to
be subject to significant structural and other change.’
Management actions taken under a stress scenario may affect,
among other things, NWM Group’s product offering, its credit
ratings, its ability to operate its businesses and pursue its current
strategies and strategic opportunities, any of which may
negatively impact investor confidence, and the value of NWM
Group’s securities. See also, ‘NWM Plc and/or its regulated
subsidiaries may not manage their capital, liquidity or funding
effectively which could trigger the execution of certain
management actions or recovery options,’ ‘NatWest Group
(including NWM Group) may become subject to the application of
UK statutory stabilisation or resolution powers which may result
in, for example, the write-down or conversion of NWM Group
entities’ Eligible Liabilities’, and NWM Group may be adversely
affected if NatWest Group fails to meet the requirements of
regulatory stress tests.’
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
NWM Group is reliant on access to the capital markets to
meet its funding requirements, both directly through
wholesale markets, and indirectly through its parent
(NatWest Group) for the subscription to its internal capital
and MREL. The inability to do so may adversely affect NWM
Group.
NatWest Markets Plc’s funding plan anticipates that in 2024, it will
issue £3 to 5 billion of public benchmark issuance, based on its
current and anticipated business activities. NWM Group therefore
has significant anticipated funding requirements and is reliant on
frequent access to the capital markets for funding, at a cost that
can be passed through to its customers. This access entails
execution risk, regulatory risk, risk of reduced commercial activity,
risk of loss of market confidence in NWM Group if it cannot
finance its activities and risk of a ratings downgrade, which could
be influenced by a number of internal or external factors,
including, those summarised in these risk factors.
In addition, NWM Plc receives capital and funding from NatWest
Group plc. NWM Plc has set target levels for different tiers of
capital and for the internal minimum requirements for own funds
and eligible liabilities (‘MREL’), as percentages of its RWAs. The
level of capital and funding required for NWM Plc to meet its
internal targets is therefore a function of the level of RWAs and its
leverage exposure in NWM Plc and this may vary over time.
NWM Plc’s internal MREL comprises the regulatory value of
capital instruments and loss-absorbing senior funding issued by
NWM Plc to its parent, NatWest Group plc, in all cases with a
residual maturity of at least one year. The Bank of England has
identified that the preferred resolution strategy for NatWest Group
is as a single point-of-entry. As a result, NatWest Group plc is the
only entity able to issue Group MREL eligible liabilities to third-
party investors, using the proceeds to fund the internal capital
and MREL targets and/or requirements of its operating entities,
including NWM Plc. NWM Plc is therefore dependent not only on
NatWest Group plc to fund its internal capital targets, but also on
NatWest Group plc’s ability to source appropriate funding.
NWM Plc is also dependent on NatWest Group plc to continue to
fund NWM Plc’s internal MREL targets over time and its ability to
issue and maintain sufficient amounts of external MREL liabilities
to support this. In turn, NWM Plc is required to fund the internal
capital requirements and MREL of its subsidiaries.
Any inability of NWM Group to adequately access the capital
markets, to manage its balance sheet in line with assumptions in
its funding plans, or to issue internal capital and MREL may
adversely affect NWM Group, such that NWM Group may not
constitute a viable banking business and/or NWM Plc or NWM
N.V. may fail to meet their respective regulatory capital and/or
MREL (at present, NWM N.V. does not have its own MREL).
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
NWM Group may not meet the prudential regulatory
requirements for liquidity and funding or may not be able to
adequately access sources of liquidity and funding, which
could trigger the execution of certain management actions
or recovery options.
Liquidity and the ability to raise funds continues to be a key area
of focus for NWM Group and the industry as a whole. NatWest
Group and NWM Plc (on a standalone basis) are required by
regulators in the UK, the EU and other jurisdictions in which they
undertake regulated activities to maintain adequate liquidity and
funding resources. To satisfy its liquidity and funding
requirements, NWM Group may therefore access sources of
liquidity and funding through deposits and wholesale funding,
including debt capital markets and trading liabilities such as
repurchase agreements. As at 31 December 2023, NWM Group
held £9.3 billion in deposits from banks and customers. The level
of deposits and wholesale funding may fluctuate due to factors
outside NWM Group’s control. These factors include: loss of
clients, changes in customer behaviour, loss of clients and/or
investor confidence (including in individual NWM Group entities or
the UK banking sector or the banking sector as a whole), changes
in interest rates, government support, increasing competitive
pressures for bank funding or the reduction or cessation of
deposits and other funding by counterparties, any of which could
result in a significant outflow of deposits or reduction in wholesale
funding within a short period of time. See also, ‘NWM Group has
significant exposure to counterparty and borrower risk’.
An inability to grow, roll-over, or any material decrease in, NWM
Group’s deposits, short-term wholesale funding and short-term
liability financing could, particularly if accompanied by one of the
other factors described above, materially affect NWM Group’s
ability to satisfy its liquidity needs.
NWM Group engages from time to time in ‘fee based borrow’
transactions whereby collateral (such as government bonds) is
borrowed from counterparties on an unsecured basis in return for
a fee. This borrowed collateral may be used by NWM Group to
finance parts of its balance sheet, either in its repo financing
business, derivatives portfolio or more generally across its balance
sheet. If such ‘fee based borrow’ transactions are unwound whilst
used to support the financing of parts of NWM Group balance
sheet, then unsecured funding from other sources would be
required to replace such financing. There is a risk that NWM
Group would be unable to replace such financing on acceptable
terms or at all, which could adversely affect its liquidity position
and have an adverse effect on NWM Group.
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
170
In addition, because ‘fee base borrow’ transactions are conducted
off-balance sheet (due to the collateral being borrowed) investors
may find it more difficult to gauge NWM Group’s creditworthiness,
which may be affected if these transactions were to be unwound
in a stress scenario. Any lack of or perceived lack of
creditworthiness may adversely affect NWM Group.
Macroeconomic developments, political uncertainty, changes in
interest rates, and market volatility, could affect NWM Group’s
ability to access sources of liquidity and funding on satisfactory
terms, or at all. This may result in higher funding costs and failure
to comply with regulatory capital, funding and leverage
requirements. As a result, NWM Plc and its subsidiaries could be
required to change their funding plans and/or their funding
operations. For example, impairments or other losses as well as
increases to capital deductions may result in a decrease to NWM
Plc’s capital base, and/or that of its subsidiaries. If NatWest Group
plc is unable to issue securities externally as planned, this may
have a negative impact on NWM Plc’s current and forecasted
MREL position, particularly if NatWest Group plc is unable to
downstream capital and/or funding to NWM Plc.
This could exacerbate funding and liquidity risk, which may
adversely affect NWM Group.
As at 31 December 2023, NWM Group reported a liquidity
coverage ratio of 183%. If its liquidity position and/or funding were
to come under stress and if NWM Group is unable to raise funds
through deposits, wholesale funding sources or other reliable
funding sources, on acceptable terms, or at all, its liquidity position
would likely be adversely affected. This would mean that NWM
Group might be unable to: meet deposit withdrawals on demand
or satisfy buy back requests, repay borrowings as they mature,
meet its obligations under committed financing facilities, comply
with regulatory funding requirements, undertake certain capital
and/or debt management activities, or fund new loans,
investments and businesses.
If, under a stress scenario, the level of liquidity falls outside of
NWM Group’s risk appetite, there are a range of recovery
management actions that NWM Group could take to manage its
liquidity levels, but any such actions may not be sufficient to
restore adequate liquidity levels, and the related implementation
may have adverse consequences for NWM Group. Under the EU
Bank Recovery and Resolution Directives I and II (‘BRRD’), as
implemented in the UK, NatWest Group must maintain a recovery
plan acceptable to its regulator, such that a breach of NWM
Group’s applicable liquidity requirements would trigger
consideration of NWM Plc’s recovery plan, and in turn may
prompt consideration and execution of NatWest Group’s recovery
plan, to attempt to remediate a deficient liquidity position.
NWM Group may need to liquidate assets to meet its liabilities,
including disposals of assets not previously identified for disposal
to reduce its funding or payment commitments or trigger the
execution of certain management actions or recovery options.
This could also lead to higher funding costs and/or changes to
NWM Group’s funding plans or its operations. In a time of reduced
liquidity or market stress, NWM Group may be unable to sell some
of its assets or may need to sell assets at depressed prices, which
in either case may adversely affect NWM Group.
NWM Group entities independently manage liquidity risk on a
stand-alone basis, including through holding their own liquidity
portfolios. They have restricted access to liquidity or funding from
other NatWest Group entities. NWM Group entities’ management
of their own liquidity portfolios and the structure of capital support
are subject to operational and execution risk.
Continuing market volatility may impact capital and RWAs and
NWM Group and its subsidiaries may be required to adapt their
funding plans or change their operations in order to satisfy their
respective capital and funding requirements, which may have a
negative impact on NWM Group. Market volatility may also result
in increases to leverage exposure.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
NWM Plc and/or its regulated subsidiaries may not manage
their capital, liquidity or funding effectively which could
trigger the execution of certain management actions or
recovery options.
Under the BRRD, as implemented in the UK, NatWest Group must
maintain a recovery plan acceptable to its regulator, such that a
breach of NWM Plc’s applicable capital or leverage, liquidity or
funding requirements would trigger consideration of NWM Plc’s
recovery plan, and in turn may prompt consideration and
execution of NatWest Group’s recovery plan
.
If, under stressed conditions, the liquidity, capital or leverage ratio
were to decline, there are a range of recovery management
actions (focused on risk reduction and mitigation) that NWM Plc
could undertake that may or may not be sufficient to restore
adequate liquidity, capital and leverage ratios. Additional
management options relating to existing capital issuances, asset
or business disposals, capital payments and dividends from NWM
Plc to its parent, could also be undertaken to support NWM Plc’s
capital and leverage requirements.
NatWest Group may also address a shortage of capital in NWM
Plc by providing parental support to NWM Plc. NatWest Group’s
(and NWM Plc’s) regulator may also request that NWM Group
carry out additional capital management actions. The Bank of
England has identified single point-of-entry at NatWest Group plc,
as the preferred resolution strategy for NatWest Group. However,
under certain conditions set forth in the BRRD, as the UK
resolution authority, the Bank of England also has the power to
execute the ‘bail-in’ of certain securities of NWM Group without
further action at NatWest Group level.
Any capital management actions taken under a stress scenario
may, in turn, affect: NWM Group’s product offering, credit ratings,
ability to operate its businesses and pursue its current strategies
and strategic opportunities as well as negatively impacting
investor confidence and the value of NWM Group’s securities. See
also, ‘— NatWest Group (including NWM Group) may become
subject to the application of UK statutory stabilisation or resolution
powers which may result in, for example, the write-down or
conversion of NWM Group entities’ Eligible Liabilities.’ In addition, if
NWM Plc or NWM N.V.’s liquidity position were to be adversely
affected, this may require assets to be liquidated or may result in
higher funding costs, which may adversely affect NWM Group’s
operating performance.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
171
Any reduction in the credit rating and/or outlooks assigned
to NatWest Group plc, any of its subsidiaries (including NWM
Plc or NWM Group subsidiaries) or any of their respective
debt securities could adversely affect the availability of
funding for NWM Group, reduce NWM Group’s liquidity and
funding position and increase the cost of funding.
Rating agencies regularly review NatWest Group plc, NWM Plc
and other NatWest Group entities’ credit ratings and outlooks.
NWM Group entities’ credit ratings and outlooks, could be
negatively affected (directly and indirectly) by a number of factors
that can change over time, including, without limitation: credit
rating agencies’ assessment of NWM Group’s strategy and
management’s capability; its financial condition including in
respect of profitability, asset quality, capital, funding and liquidity,
and risk management practices; the level of political support for
the sectors and regions in which NWM Group operates; the
implementation of structural reform; the legal and regulatory
frameworks applicable to NWM Group’s legal structure; business
activities and the rights of its creditors; changes in rating
methodologies; changes in the relative size of the loss-absorbing
buffers protecting bondholders and depositors; the competitive
environment; political, geopolitical and economic conditions in
NWM Group’s key markets (including inflation and interest rates,
supply chain disruptions and the outcome of any further Scottish
independence referendum); any reduction of the UK’s sovereign
credit rating and market uncertainty. In addition, credit ratings
agencies are increasingly taking into account sustainability-related
factors, including climate, environmental, social and governance
related risk, as part of the credit ratings analysis, as are investors
in their investment decisions.
See also ‘A reduction in the ESG ratings of NatWest Group
(including NWM Group) or NWM Group may have a negative
impact on NatWest Group (including NWM Group)’s or NWM
Group’s reputation and on investors’ risk appetite and customers’
willingness to deal with NatWest Group (including NWM Group) or
NWM Group.’
Any reductions in the credit ratings of NatWest Group plc, NWM
Plc or of certain other NatWest Group entities, including, in
particular, any downgrade below investment grade, or a
deterioration in the capital markets’ perception of NWM Group’s
financial resilience could significantly affect NWM Group’s access
to capital markets, reduce the size of its deposit base and trigger
additional collateral or other requirements in its funding
arrangements or the need to amend such arrangements, which
could adversely affect NWM Group’s (and, in particular, NWM Plc)
liquidity and funding position, cost of funding and its access to
capital markets which could limit the range of counterparties
willing to enter into transactions with NWM Group (and, in
particular, with NWM Plc), on favourable terms, or at all. This may
in turn adversely affect NWM Group’s competitive position and
threaten its prospects.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
NWM Group operates in markets that are highly competitive,
with competitive pressures and technology disruption.
The markets within which NWM Group operates are highly
competitive, and NWM Group expects competition to continue
and intensify in response to various changes including: evolving
customer behaviour, technological changes (including digital
currencies and other instruments, stablecoins and the growth of
digital banking, such as from fintech entrants), competitor
behaviour, new entrants to the market (including non-traditional
financial services providers who may have competitive
advantages in scale, technology and consumer engagement),
competitive foreign exchange offerings, industry trends resulting
in increased disaggregation or unbundling of financial services or
conversely the re-intermediation of traditional banking services,
and the impact of regulatory actions and other factors. In
particular, developments in the financial sector resulting from new
(or more competitive) banking and lending products and services
offered by rapidly evolving incumbents, challengers (including
shadow banks and alternative lenders, i.e. entities which carry out
activities of a similar nature to banks but without the same
regulatory oversight) and new entrants such as technology
companies (which may result in a shift in customer behaviour) and
the introduction of disruptive technology, may impede NWM
Group’s ability to grow or retain its market share and impact its
revenues and profitability. Moreover, innovations such as
biometrics, artificial intelligence (including generative artificial
intelligence), automation, the cloud, blockchain, cryptocurrencies
and quantum computing may rapidly facilitate industry
transformation.
Increasingly, many of the products and services offered by NWM
Group are, and will become, more technology intensive, including
through digitalisation, automation and the use of artificial
intelligence. NWM Group’s ability to develop or acquire such digital
solutions (which also comply with applicable and
evolving
regulations) and their integration in NWM Group’s systems and
controls has become increasingly important to retaining and
growing NWM Group’s competitiveness, market share and
customer business-facing businesses across its geographical
footprint.
There is a risk that NWM Group’s innovation strategy (which
includes investment in its IT capability intended to improve its core
infrastructure and client interface capabilities as well as
investments and strategic partnerships with third party
technology providers) will not be successful or that it will not allow
NWM Group to maintain or grow such innovative products and
services in the future. For example, NWM Group’s current or
future competitors may be more successful than NWM Group in
implementing technologies for delivering products or services to
their clients, which may adversely affect its competitive position.
NWM Group may also fail to identify future opportunities or fail to
derive benefits from technologies in a context of technological
innovation, changing customer behaviour and changing regulatory
demands, resulting in increased competition from traditional
banking businesses as well as new providers of financial services,
including technology conglomerates with strong brand
recognition, that may be able to develop financial services at a
lower cost base. NWM Group’s competitors may also be better
able to attract and retain clients and key employees, may have
more effective IT systems, and may have access to lower cost
funding and/or be able to attract deposits or provide investment-
banking services on more favourable terms than NWM Group.
Although NWM Group invests in new technologies and
participates in industry and research-led initiatives aimed at
developing new technologies, such investments may be insufficient
or ineffective, especially given NWM Group’s focus on cost
efficiencies. This could affect NWM Group’s ability to offer
innovative products or technologies for delivering products or
services to clients, in turn affecting its competitive position. NWM
Group may also fail to identify future opportunities or fail to derive
benefits from technologies in a context of technological
innovation, changing customer behaviour and changing regulatory
demands.
Furthermore, the development of innovative products depends on
NWM Group’s ability to effectively produce, acquire, or manage
underlying high-quality data, failing which its ability to offer
innovative products may be compromised.
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
172
If NWM Group is unable to offer competitive, attractive and
innovative products that are also profitable and rolled out in a
timely manner, it will lose market share, incur losses on some or
all of its initiatives and lose opportunities for growth. In this
context, NWM Group is investing in the automation of certain
solutions and interactions within its customer-facing businesses,
including through automated processes and artificial intelligence.
Such initiatives may result in operational, reputational and
conduct risks if the technology used is not used appropriately, is
defective, inadequate or is not fully integrated into NWM Group’s
current solutions, systems and controls. There can be no certainty
that such initiatives will deliver the expected cost savings and
investment in technology (including automated processes and
artificial intelligence) will likely also result in increased costs for
NWM Group.
In addition, the implementation of NatWest Group’s strategy
(including in relation to acquisitions, divestments, reorganisations
and/or partnerships), delivery on its climate ambition, cost-
controlling measures, as well as employee remuneration
constraints, may also have an impact on NWM Group’s ability to
compete effectively. Intensified competition from incumbents,
challengers and new entrants as well as disintermediation by
large technology companies could affect NWM Group’s ability to
provide satisfactory returns. Moreover, activist investors have
increasingly become engaged and interventionist in recent years,
which may pose a threat to NatWest Group’s (and NWM Group’s)
strategic initiatives.
Furthermore, continued consolidation or technological or other
developments in the financial services industry could result in
NWM Group’s competitors gaining greater capital and other
resources, including the ability to offer a broader and more
attractive or better value range of products and services and
geographic diversity, or the emergence of new competitors.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
NWM Group may be adversely affected if NatWest Group
fails to meet the requirements of regulatory stress tests.
NatWest Group is subject to annual and other stress tests by its
regulator in the UK. Stress tests are designed to assess the
resilience of banks such as NWM Group to potential adverse
economic or financial developments and ensure that they have
robust, forward-looking capital planning processes that account
for the risks associated with their business profile. If the stress
tests reveal that a bank’s existing regulatory capital buffers are
not sufficient to absorb the impact of the stress, then it is possible
that NatWest Group and/or NWM Group may need to take action
to strengthen their capital positions.
Failure by NatWest Group to meet its quantitative and qualitative
requirements of the stress tests set forth by its UK regulators may
result in: NatWest Group’s regulators requiring NatWest Group to
generate additional capital, reputational damage, increased
supervision and/or regulatory sanctions and/or loss of investor
confidence, all of which may have a material adverse effect on
NatWest Group’s (and NWM Group’s) future results, financial
condition, prospects, and/or reputation.
NWM Group has significant exposure to counterparty and
borrower risk including credit losses, which may have an
adverse effect on NWM Group.
Credit risk may arise from a variety of business activities,
including, but not limited to: extending credit to clients through
various lending commitments; entering into swap or other
derivative contracts under which counterparties have obligations
to make payments to NWM Group (including un-collateralised
derivatives); providing short or long-term funding that is secured
by physical or financial collateral whose value may at times be
insufficient to fully cover the loan repayment amount; posting
margin and/or collateral and other commitments to clearing
houses, clearing agencies, exchanges, banks, securities firms and
other financial counterparties; and investing and trading in
securities and loan pools, whereby the value of these assets may
fluctuate based on realised or expected defaults on the underlying
obligations or loans. See also, ‘Risk and capital management —
Credit Risk’. Any negative developments in the activities listed
above may negatively impact NWM Group’s clients and credit
exposures, which may, in turn, adversely affect NWM Group’s
profitability.
NWM N.V., a subsidiary of NWM Plc, has a portfolio of loans and
loan commitments to Western European corporate customers. As
a result, through the NWM N.V. business and NWM Group’s other
activities, NWM Group has exposure to many different sectors,
customers and counterparties, and risks arising from actual or
perceived changes in credit quality and the recoverability of
monies due from borrowers and other counterparties are inherent
in a wide range of NWM Group’s businesses. These risks may be
concentrated for those businesses for which client income is
heavily weighted towards a specific geographic region, industry or
client base. Furthermore, these risks are likely to increase due to
a potential transfer of NatWest Group’s Transfer Business (see
‘The transfer of NatWest Group’s Western European corporate
portfolio involves certain risks’).
The credit quality of NWM Group’s borrowers and other
counterparties may be affected by UK and global macroeconomic
and political uncertainties, prevailing economic and market
conditions. These include factors relating to interest rates and
inflation, changing asset prices (including residential and
commercial property), energy prices, supply chain disruption,
changes to monetary and fiscal policy, the impact of armed
conflict, and the legal and regulatory landscape in the UK and
countries where NWM Group is exposed to credit risk. Any further
deterioration in these conditions or changes to legal or regulatory
landscapes could worsen borrower and counterparty credit
quality or impact the enforcement of contractual rights, increasing
credit risk. NWM Group is exposed to the financial sector,
including sovereign debt securities, financial institutions, financial
intermediation providers (including providing facilities to financial
sponsors and funds, backed by assets or investor commitments)
and securitised products (typically senior lending to special
purpose vehicles backed by pools of financial assets). Concerns
about, or a default by, a financial institution or intermediary could
lead to significant liquidity problems and losses or defaults by
other financial institutions, since the commercial and financial
soundness of many financial institutions and intermediaries is
closely related and interdependent as a result of credit, trading,
clearing and other relationships. Any perceived lack of
creditworthiness of a counterparty or borrower may lead to
market-wide liquidity problems and losses for NWM Group. In
addition, the value of collateral may be correlated with the
probability of default by the relevant counterparty (‘wrong way
risk’), which would increase NWM Group’s potential loss. This
systemic risk may also adversely affect financial intermediaries,
such as clearing agencies, clearing houses, banks, securities firms
and exchanges with which NWM Group interacts on a regular
basis.
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
173
See also, ‘NWM Group is reliant on access to the capital markets
to meet its funding requirements, both directly through wholesale
markets, and indirectly through its parent (NatWest Group) for the
subscription to its internal capital and MREL. The inability to do so
may adversely affect NWM Group.’ and ‘NWM Group may not
meet the prudential regulatory requirements for liquidity and
funding or may not be able to adequately access sources of
liquidity and funding, which could trigger the execution of certain
management actions or recovery options.’
As a result, adverse changes in borrower and counterparty credit
risk may cause additional impairment charges under IFRS 9,
increased repurchase demands, higher costs, additional write-
downs and losses for NWM Group and an inability to engage in
routine funding transactions.
NWM Group has applied an internal analysis of multiple economic
scenarios (MES) together with the determination of specific
overlay adjustments to inform its IFRS 9 ECL (Expected Credit
Loss). The recognition and measurement of ECL is complex and
involves the use of significant judgement and estimation. This
includes the formulation and incorporation of multiple forward-
looking economic scenarios into ECL to meet the measurement
objective of IFRS 9. The ECL provision is sensitive to the model
inputs and economic assumptions underlying the estimate. Going
forward, NWM Group anticipates observable credit deterioration
of a proportion of assets resulting in a systematic uplift in defaults,
which is mitigated by those economic assumption scenarios being
reflected in the Stage 2 ECL across portfolios, along with a
combination of post model overlays in both wholesale and retail
portfolios reflecting the uncertainty of credit outcomes. See also,
‘Risk and capital management – Credit risk’. A credit deterioration
would also lead to RWA increases. Furthermore, the assumptions
and judgements used in the MES and ECL assessment at 31
December 2023 may not prove to be adequate resulting in
incremental ECL provisions for NWM Group.
Due to NWM Group’s exposure to the financial industry, it also
has exposure to shadow banking entities (i.e., entities which carry
out activities of a similar nature to banks without the same
regulatory oversight). NWM Group is required to identify and
monitor its exposure to shadow banking entities, implement and
maintain an internal framework for the identification,
management, control and mitigation of the risks associated with
exposure to shadow banking entities, and ensure effective
reporting and governance in respect of such exposure. If NWM
Group is unable to properly identify and monitor its shadow
banking exposure, maintain an adequate framework, and/or
ensure effective reporting and governance in respect of shadow
banking exposure, this may adversely affect NWM Group.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
NWM Group could incur losses or be required to maintain
higher levels of capital as a result of limitations or failure of
various models.
Given the complexity of NWM Group’s business, strategy and
capital requirements, NWM Group relies on analytical and other
models for a wide range of purposes, including to manage its
business, assess the value of its assets and its risk exposure, as
well as to anticipate capital and funding requirements (including to
facilitate NatWest Group’s mandated stress testing). In addition,
NWM Group utilises models for valuations, credit approvals,
calculation of loan impairment charges on an IFRS 9 basis,
financial reporting and for financial crime (criminal activities in the
form of money laundering, terrorist financing, bribery and
corruption, tax evasion and sanctions as well as external or
internal fraud (collectively, ‘financial crime’)).
NWM Group’s models, and the parameters and assumptions on
which they are based, are periodically reviewed.
As model outputs are imperfect representations of real-world
phenomena or simplifications of complex real-world systems and
processes, and are based on a limited set of observations, model
outputs therefore remain uncertain. NWM Group may face
adverse consequences as a result of actions or decisions based on
models that are poorly developed, incorrectly implemented,
outdated or used inappropriately. This includes models that are
based on inaccurate or non-representative data (for example,
where there have been changes in the micro or macroeconomic
environment in which NWM Group operates) or as a result of the
modelled outcome being misunderstood, or by such information
being used for purposes for which it was not designed. This could
result in findings of deficiencies by NatWest Group’s (and in
particular, NWM Group’s) regulators (including as part of NatWest
Group’s mandated stress testing) and increased capital
requirements, may render some business lines uneconomic, may
require management action or may subject NWM Group to
regulatory sanction, any of which in turn may also have an
adverse effect on NWM Group and its customers.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
NWM Group’s financial statements are sensitive to
underlying accounting policies, judgements, estimates and
assumptions.
The preparation of financial statements requires management to
make judgements, estimates and assumptions that affect the
reported amounts of assets, liabilities, income, expenses,
exposures and RWAs.
While estimates, judgements and assumptions take into account
historical experience and other factors (including market practice
and expectations of future events that are believed to be
reasonable under the circumstances), actual results may differ
due to the inherent uncertainty in making estimates, judgements
and assumptions (particularly those involving the use of complex
models). Further, accounting policy and financial statement
reporting requirements increasingly require management to adjust
existing judgements, estimates and assumptions for the effects of
climate-related, sustainability and other matters that are
inherently uncertain and for which there is little historical
experience which may affect the comparability of NWM Group’s
future financial results with its historical results. Actual results may
differ due to the inherent uncertainty in making climate-related
and sustainability estimates, judgements and assumptions.
Accounting policies deemed critical to NWM Group’s results and
financial position, based upon materiality and significant
judgements and estimates, involve a high degree of uncertainty
and may have a material impact on its results. For 2023, these
include loan impairments, fair value, deferred tax and conduct and
litigation provisions. These are set out in the section ‘Critical
accounting policies’.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
Changes in accounting standards may materially impact
NWM Group’s financial results.
NWM Group prepares its consolidated financial statements in
conformity with the requirements of the Companies Act 2006 and
in accordance with IFRS as issued by the International Accounting
Standards Board.
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
174
Changes in accounting standards or guidance by accounting
bodies or in the timing of their implementation, whether
immediate or foreseeable, could result in NWM Group having to
recognise additional liabilities on its balance sheet, or in further
write-downs or impairments to its assets.
NWM Group’s trading assets amounted to £45.3 billion as at 31
December 2023. The valuation of financial instruments, including
derivatives, measured at fair value can be subjective, in particular
where models are used which include unobservable inputs.
Generally, to establish the fair value of these instruments, NWM
Group relies on quoted market prices or, where the market for a
financial instrument is not sufficiently credible, internal valuation
models that utilise observable market data. In certain
circumstances, the data for individual financial instruments or
classes of financial instruments utilised by such valuation models
may not be available or may become unavailable due to prevailing
market conditions. In these circumstances, NWM Group’s internal
valuation models require NWM Group to make assumptions,
judgements and estimates to establish fair value, which are
complex and often relate to matters that are inherently uncertain.
Any of these factors could require NWM Group to recognise fair
value losses which may have an adverse effect on NWM Group’s
income generation and financial position.
From time to time, the International Accounting Standards Board
may issue new accounting standards or interpretations that could
materially impact how NWM Group calculates, reports and
discloses its financial results and financial condition, and which
may affect NWM Group capital ratios, including the CET1 ratio.
New accounting standards and interpretations that have been
issued by the International Accounting Standards Board but which
have not yet been adopted by NWM Group are discussed in
‘Future accounting developments’.
NatWest Group is subject to Bank of England and PRA
oversight in respect of resolution, and NatWest Group could
be adversely affected should the Bank of England in the
future deem NatWest Group’s preparations to be
inadequate.
NatWest Group is subject to regulatory oversight by the Bank of
England and the PRA and is required (under the PRA rulebook) to
carry out an assessment of its preparations for resolution, submit
a report of the assessment to the PRA, and disclose a summary
of this report. NatWest Group has dedicated significant resources
towards the preparation of NatWest Group for a potential
resolution scenario. In June 2022 the Bank of England
communicated its assessment of NatWest Group’s preparations
and did not identify any shortcomings, deficiencies or substantive
impediments although two areas were highlighted as requiring
further enhancements. NatWest Group could be adversely
affected should future Bank of England assessments deem
NatWest Group’s preparations to be inadequate.
If future Bank of England assessments identify a significant gap in
NatWest Group’s ability to achieve the resolvability outcomes or
reveals that NatWest Group is not adequately prepared to be
resolved, or does not have adequate plans in place to meet
resolvability requirements, NatWest Group may be required to
take action to enhance its preparations to be resolvable, resulting
in additional costs and the dedication of additional resources. Such
a scenario may have an impact on NatWest Group (and NWM
Group) as, depending on the Bank of England’s assessment,
potential action may include, but is not limited to, restrictions on
NatWest Group’s maximum individual and aggregate exposures, a
requirement to dispose of specified assets, a requirement to
change its legal or operational structure, a requirement to cease
carrying out certain activities and/or to maintain a specified
amount of MREL.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
NatWest Group (including NWM Group) may become subject
to the application of UK statutory stabilisation or resolution
powers which may result in, for example, the write-down or
conversion of NWM Group entities’ Eligible Liabilities.
HM Treasury, the Bank of England, the PRA and the FCA
(together, the ‘Authorities’) are granted substantial powers to
resolve and stabilise UK-incorporated financial institutions. Five
stabilisation options exist: (i) transfer of all of the business of a
relevant entity or the shares of the relevant entity to a private
sector purchaser; (ii) transfer of all or part of the business of the
relevant entity to a ‘bridge bank’ wholly-owned by the Bank of
England; (iii) transfer of part of the assets, rights or liabilities of the
relevant entity to one or more asset management vehicles for
management of the transferor’s assets, rights or liabilities; (iv) the
write-down, conversion, transfer, modification, or suspension of
the relevant entity’s equity, capital instruments and liabilities; and
(v) temporary public ownership of the relevant entity. These
options may be applied to NatWest Group plc as the parent
company or to NWM Group, as a subsidiary, where certain
conditions are met (such as, whether the firm is failing or likely to
fail, or whether it is reasonably likely that action will be taken
(outside of resolution) that will result in the firm no longer failing or
being likely to fail). Moreover, there are modified insolvency and
administration procedures for relevant entities within NatWest
Group, and the Authorities have the power to modify or override
certain contractual arrangements in certain circumstances and
amend the law for the purpose of enabling their powers to be
used effectively and may promulgate provisions with retrospective
applicability.
Similar powers may also be exercised with respect to NWM N.V.,
in the Netherlands by the relevant Dutch and European
regulatory authorities.
Under the UK Banking Act 2009, the Authorities are generally
required to have regard to specified objectives in exercising the
powers provided for by the UK Banking Act. One of the objectives
(which is required to be balanced as appropriate with the other
specified objectives) refers to the protection and enhancement of
the stability of the financial system of the UK. Moreover, the ‘no
creditor worse off’ safeguard provides that where resolution
action is taken, the Authorities are required to ensure that no
creditor is in a worse position than if the bank had entered into
normal insolvency proceedings. Although, this safeguard may not
apply in relation to an application of the separate write-down and
conversion power relating to capital instruments in circumstances
where a stabilisation power is not also used, the UK Banking Act
still requires the Authorities to respect the hierarchy on insolvency
when using the write-down and conversion power. Further,
holders of debt instruments which are subject to the power may,
however, have ordinary shares transferred to or issued to them
by way of compensation.
Uncertainty exists as to how the Authorities may exercise their
powers including the determination of actions undertaken in
relation to the ordinary shares and other securities issued by
NatWest Group (including NWM Group), which may depend on
factors outside of NWM Group’s control. Moreover, the UK
Banking Act provisions remain largely untested in practice,
particularly in respect of resolutions of large financial institutions
and groups.
If NatWest Group is at or is approaching the point such that
regulatory intervention is required, there may correspondingly be
a material adverse effect on NWM Group’s future results, financial
condition, prospects, and/or reputation.
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
175
Climate and sustainability-related risks
NWM Group and its value chain face climate-related and
sustainability-related risk that may adversely affect NWM
Group.
NWM Group and its value chain (including its investors,
customers, counterparties (including its suppliers) and employees)
may face financial and non-financial risks arising from
sustainability-related risks, including climate-related risks.
Climate and sustainability-related risks may:
adversely affect asset pricing and valuations of NWM Group’s
own and other securities and, in turn, the wider financial
system;
adversely affect economic activities directly (for example
through lower corporate profitability or the devaluation of
assets) or indirectly (for example through macro-financial
changes);
adversely affect the viability or resilience of business models
over the medium to longer term, particularly those business
models most vulnerable to climate and sustainability-related
risks;
trigger losses stemming directly or indirectly from liability risks,
and/or reputational damage, including as a result of adverse
media coverage, activists, the public, customers,
counterparties (including suppliers) and/or investors
associating NWM Group or its customers with adverse climate
and sustainability-related issues;
adversely affect NWM Group’s ability to contribute to deliver
on NatWest Group’s strategy, including contributing to achieve
NatWest Group’s climate ambitions and targets;
exacerbate other risk categories to which NWM Group is
exposed, including credit risk, operational risk (including
business continuity), market risk (both traded and non-
traded), liquidity and funding risk (for example, net cash
outflows or depletion of liquidity buffers), reputational risk,
pension risk, regulatory compliance risk and conduct risk; and
may have a material adverse effect on NWM Group’s
reputation, future results, financial condition and/or prospects
(including cash flows, access to finance or cost of capital over
the short, medium or long term).
Climate and sustainability matters are becoming increasingly
political and polarised. Some customers, counterparties (including
suppliers) and investors may decide not to do business with NWM
Group because, according to their own assessment, NatWest
Group (including NWM Group) strategy, ambitions and targets
related to climate and sustainability do not meet their
expectations, whereas others may decide not to do business with
NWM Group for failing to progress to contribute to NatWest
Group’s
climate and sustainability-related strategy, ambitions and
targets or if they are of the view that they lack credibility.
If NWM Group fails to identify, assess, prioritise, monitor and react
appropriately to climate and sustainability-related risks, in a timely
manner or at all, climate and sustainability-related physical,
transition and liability risks and opportunities, changing regulatory
and market expectations and societal preferences that NWM
Group, its customers, counterparties (including suppliers) face, this
may have a material adverse effect on NWM Group’s business,
future results, financial condition, prospects, reputation or the
price of its securities.
Climate-related risks may adversely affect the global
financial system, NWM Group or its value chain.
Climate-related risks represent a source of systemic risk in the
global financial system. The financial impacts of climate-related
risks are expected to be widespread and may disrupt the orderly
functioning of financial markets and have an adverse effect on
financial institutions, including NWM Group.
There are significant uncertainties as to the location, extent and
timing of the manifestation of the physical impacts of climate
change, such as more severe and frequent extreme weather
events (storms, flooding, subsidence, heat waves, droughts and
wildfires), rising average global temperatures and sea levels,
nature loss, declining food yields, destruction of critical
infrastructure, supply chain disruption and resource scarcity.
Damage to NWM Group customers’ and counterparties’ (including
suppliers’) properties and operations could disrupt business, result
in the deterioration of the value of collateral or insurance
shortfalls, impair asset values and negatively impact the
creditworthiness of customers and their ability and/or willingness
to pay fees, afford new products or repay their debts, leading to
increased default rates, delinquencies, write-offs and impairment
charges in NWM Group’s portfolios. In addition, NWM Group’s
premises and operations, or those of its critical outsourced
functions may experience damage or disruption leading to
increased costs. Any of these may have a material adverse effect
on NWM Group’s future results, financial condition, prospects,
and/or reputation.
To meet the goals of the UK’s Net Zero Strategy will require a
net-zero transition across all sectors of the UK economy.
The impacts of the extensive social, commercial, technological,
policy and regulatory changes required to achieve this transition
remain uncertain but are expected to be significant, subject to
continuous changes and developments and may be disruptive
across the global economy and markets, especially if these
changes do not occur in an orderly or timely manner or are not
effective in reducing emissions sufficiently in a timely manner, or
at all. NWM Group’s business and customers in some sectors,
including but not limited to, residential mortgages, commercial real
estate, agriculture (primary farming), automotive manufacturing,
aviation, shipping, land transport and logistics (freight road,
passenger rail and road), electricity generation and oil and gas
are expected to be particularly impacted. The timing and pace of
the net-zero transition is also uncertain, will depend on many
factors and uncertainties and may be near-term, gradual and
orderly, or delayed, rapid and disorderly, or a combination of
these.
Climate-related risks may exacerbate the impact of financial and
non-financial risks and they may have a material adverse effect
on NWM Group’s future results, financial condition, prospects,
and/or reputation, including as a result of financial losses caused
directly or indirectly by climate-related litigation and conduct
matters (referred to as ‘liability risk’). See also, ‘NWM Group may
be subject to potential climate and other sustainability-related
litigation, enforcement proceedings, investigations and conduct
risk.’
NWM Group and its value chain may, face other
sustainability-related risks that may adversely affect NWM
Group.
NWM Group and its value chain (including its investors,
customers, counterparties (including its suppliers) and employees)
may face financial and non-financial risks arising from broader (i.e.
non-climate-related) sustainability issues. These include: (i) risks
relating to nature loss (such as the loss and/or decline of the state
of nature including but not limited to, the reduction of any aspect
of biological diversity and other forms of environmental
degradation such as air, water and land pollution, soil quality
degradation and water stress);
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
176
(ii) risks related to societal (including human rights) matters, for
example, climate change and environmental degradation
negatively impacting people’s standard of living and health,
geopolitical tensions and conflict endangering people’s lives and
security, the displacement of communities, the violation of
indigenous people’s rights, unjust working conditions and labour
rights breaches (including discrimination, lack of diversity and
inclusion, inequality, gender/ethnicity pay gap and payments
under the minimum wage), modern slavery, financial crime, data
privacy breaches and lack of support for the vulnerable; and (iii)
governance-related risks (including board diversity, ethics,
executive compensation and management structure).
NWM Group is directly and indirectly exposed to multiple types of
nature-related risks through the breadth of its activities, products
and services offering, including through the risk of default by
customers whose businesses are exposed to nature-related risks.
In 2021, NatWest Group (including NWM Group) first classified
‘Biodiversity and Nature Loss’ as an emerging risk for NatWest
Group (including NWM Group) within its Risk Management
Framework. From January 2024, NatWest Group (including NWM
Group) has expanded its key risk definition from climate risk to
climate and nature risk and updated its climate risk policy to
reflect emerging nature-related risks and to capture requirements
that go beyond climate risk.
NatWest Group (including NWM Group) supports the aims of the
Task Force on Nature Related Financial Disclosure and continues
to enhance its reporting and measurement capabilities,
acknowledging challenges associated with data availability, while
continuing to review evolving disclosure standards and
framework. NatWest Group’s (including NWM Group) approach is
to integrate nature its existing strategy on climate, recognising
there is still, much to do in understanding its impacts and
dependencies on nature as well as our nature-related risks and
opportunities.
There is also increased scrutiny from NWM Group’s investors,
customers, counterparties (including its suppliers), employees,
communities, regulators, the media and other stakeholders on
how NWM Group addresses societal and governance related
matters, including unjust working conditions and labour rights
breaches, resilience in the workplace, safety and wellbeing, data
protection and management, workforce management, human
rights and value chain management. For example, NatWest
Group’s (including NWM Group) ambition is to support
decarbonisation while promoting energy security, may lead to
continued exposure to carbon-intensive activities and sectors
regarded as posing high climate and nature-related and societal
(including human rights) risks, (such as the textiles, agriculture
and mining sectors) each of which may impact NWM Group’s
employees, customers, counterparties (including suppliers) and
stakeholders and their business activities and/or the communities
in
which they operate and, in turn, result in reputational risk for
NWM Group.
There is also growing expectation of the need for a ‘just transition’
and ‘energy justice’ – in recognition that the transition to net zero
should happen in a way that is as fair and inclusive as possible to
everyone concerned. Although NatWest Group (including NWM
Group) continues to evaluate and assess how it integrates ‘just
transition’ considerations into its climate and sustainability
strategy, a failure (or perception of failure) by NatWest Group
(including NWM Group) to sufficiently factor these considerations
into existing products and service offerings may adversely affect
NatWest Group’s (including NWM Group) reputation.
In 2023, NatWest Group (including NWM Group) published its
initial assessment of its ‘salient human rights issues’. Human rights
saliency assessments are high-level scoping exercises based on
internal and external stakeholder engagement and involve
subjective materiality and other judgements including as to
severity and likelihood of human rights impacts. Failure by
NatWest Group (including NWM Group) to identify, assess,
prioritise and monitor any actual or potential adverse human
rights issues that NatWest Group (including NWM Group)
contributes to, or is directly linked to, may adversely impact
people and communities, which in turn may have a material
adverse effect on NWM Group’s future results, financial condition,
prospects and/or reputation.
Sustainability-related risks may have the potential to cause or
stress other financial and non-financial risks, including climate-
related risks, and they may have a material adverse effect on
NWM Group’s future results, financial condition, prospects, and/or
reputation, including as a result of financial losses caused directly
or indirectly by sustainability-related litigation and conduct
matters (referred to as ‘liability risk’). See also, ‘NWM Group may
be subject to potential climate and other sustainability-related
litigation, enforcement proceedings, investigations and conduct
risk’.
NatWest Group’s climate change related strategy, ambitions,
targets and transition plan entail significant execution and/or
reputational risks and are unlikely to be achieved without
significant and timely government policy, technology and
customer behavioural changes.
NatWest Group has an ambition to become a leading bank in the
UK, helping to address the climate challenge.
At NatWest Group’s Annual General Meeting in April 2022,
ordinary shareholders passed an advisory ‘Say on Climate’
resolution endorsing NatWest Group’s previously announced
strategic direction on climate change, including its ambitions to at
least halve the climate impact of its financing activity by 2030,
achieve alignment with the 2015 Paris Agreement and reach net
zero across its financed emissions, assets under management and
operational value chain by 2050. Further, in December 2022,
NatWest Group published its science-based targets validated by
Science Based Target Initiative for 79% of its lending book as at
31 December 2019 and 57% of debt securities and equity shares,
excluding sovereign debt securities.
NatWest Group has also announced and in the future it may also
announce other climate ambitions, targets and initiatives which
support its aim to help addressing the climate challenge.
Making the changes necessary to contribute to achieving NatWest
Group’s strategic direction on climate change, including
contributing to achieve NatWest Group’s climate ambitions and
targets and contributing to execute NatWest Group’s transition
plan, together with the active management of climate and
sustainability-related risks and other regulatory, policy and market
changes, is likely to necessitate material changes to NWM Group’s
business, operating model, its existing exposures and the products
and services NWM Group provides to its customers (potentially on
accelerated timescales). NWM Group may be required to (i)
significantly reduce its financed emissions and its exposure to
customers that do not align with a transition to net zero or do not
have a credible transition plan in place, and (ii) divest or
discontinue certain activities for regulatory or legal reasons or in
response to the transition to a less carbon-dependent economy.
Increases in lending and financing activities may wholly or partially
offset some or all these reductions, which may increase the
extent of changes and reductions necessary.
Making the necessary changes (or not making the necessary
changes in a timely manner, or at all) may have a material
adverse effect on NWM Group’s business and operations, financial
condition, prospects and competitive position and NWM Group’s
ability to contribute to achieving NatWest Group’s climate and
financial ambitions and targets, take advantage of climate
change-related opportunities and generate sustainable returns.
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
177
NWM Group’s ability to contribute to achieving NatWest Group’s
strategy, including contributing to achieve NatWest Group’s
climate ambitions and targets, will significantly depend on many
factors and uncertainties beyond NWM Group’s control. These
include (i) the extent and pace of climate change, including the
timing and manifestation of physical and transition risks; (ii) the
macroeconomic environment; (iii) the effectiveness of actions of
governments, legislators, regulators and businesses; (iv) the
response of the wider society, investors, customers, suppliers and
other stakeholders to mitigate the impact of climate and
sustainability-related risks; (v) changes in customer behaviour and
demand; (vi) appetite for new markets, credit appetite,
concentration risk appetite, lending and underwriting
opportunities; (vii) developments in the available technology; (viii)
the roll-out of low carbon infrastructure; and (ix) the availability of
accurate, verifiable, reliable, auditable, consistent and comparable
data. These external factors and other uncertainties will make it
challenging for NWM Group to contribute to achieving NatWest
Group’s climate ambitions and targets and there is a significant
risk that all or some of these ambitions and targets will not be
achieved or not achieved within the intended timescales.
NWM Group’s ability to contribute to achieving NatWest Group’s
climate ambitions and targets depends to a significant extent on
the timely implementation and integration of appropriate
government policies.
The UK CCC June 2023 Progress Report to the UK Parliament
states that the rate of emissions reduction will need to significantly
increase for the UK to meet its 2030 commitments and continued
delays in policy development and implementation mean
achievement is increasingly challenging.
On 20 September 2023,
the UK Government announced its revised plans on reducing
emissions to reach net zero, including (i) delaying the proposed
ban on the sale of petrol and diesel cars to 2035; (ii) not
proceeding with new policies forcing landlords to upgrade the
energy efficiency of their properties; and (iii) delaying the ban on
new fossil fuel boilers for certain households. Accordingly,
NatWest Group (including NWM Group) considers achievement of
the following ambitions increasingly challenging (i) 50% of NatWest
Group’s mortgage portfolio to have an EPC rating of C or above
by 2030; and (ii) to at least halve the climate impact of NatWest
Group’s financing activity by 2030, against a 2019 baseline.
NatWest Group (including NWM Group) has also stated that it
plans to phase-out coal for UK and non-UK customers who have
UK coal production, coal fired generation and coal related
infrastructure by 1 October 2024, with a full global phase-out by 1
January 2030. Data challenges, particularly the lack of granular
customer information, creates challenges in identifying customers
with ‘coal related infrastructure’ (e.g. transportation and storage)
and other customers with ‘coal- related operations’ within
NatWest Group’s (including NWM Group) large and diversified
customer portfolios. Therefore, there is a risk that some
customers with UK-based coal activities may not have been
identified and that NatWest Group (including NWM Group) will not
be able to identify all relevant activities to achieve these coal
phase-out plans.
Any delay or failure by NWM Group in contributing to set, make
progress against or meet NatWest Group’s climate-related
ambitions,
targets and plans may have a material adverse effect
on NWM Group’s future results, financial condition, prospects,
and/or reputation and may increase the climate and sustainability-
related risks NWM Group faces.
There are significant limitations related to accessing
accurate, reliable, verifiable, auditable, consistent and
comparable climate and other sustainability-related data
that contribute to substantial uncertainties in accurately
modelling and reporting on climate and sustainability
information, as well as making appropriate important
internal decisions.
Meaningful reporting of climate and sustainability-related risks and
opportunities and their potential impacts and related metrics
depends on access to accurate, reliable, verifiable, auditable,
consistent and comparable climate and sustainability-related data
from counterparties (including suppliers) or customers. Data may
not be generally available or, if available, may not be accurate,
reliable, verifiable, auditable, consistent, or comparable. Any
failure of NWM Group to proportionately collect or develop
accurate, reliable, verifiable, auditable, consistent and comparable
counterparty (including supplier) and customer data, may
adversely affect NWM Group’s ability to prepare meaningful
reporting which is relevant, represented in an accurate, verifiable,
comparable and understandable way of the climate and
sustainability-related risks and opportunities, which may adversely
affect NWM Group’s ability to meet external disclosure obligations
and its reputation, business and its competitive position.
In the absence of other sources, reporting of financed emissions,
facilitated emissions and other sustainability data by financial
institutions, including NWM Group, is necessarily based on
aggregated information developed by third parties that may be
prepared in an inconsistent way using different methodologies,
interpretations, or assumptions. NWM Group’s climate and
sustainability-related disclosures use a greater number and level
of assumptions, judgements and estimates than many of its
financial disclosures.
These assumptions, judgements and estimates are highly likely to
change materially over time, and, when coupled with the longer
timeframes used in these climate and sustainability-related
disclosures, make any assessment of materiality inherently
uncertain.
In particular, in the absence of actual emissions monitoring and
measurement, emissions estimates are based on sector and other
assumptions that may not be accurate for a given counterparty
(including supplier) or customer. There may also be data gaps
that are filled using proxy data, such as sectoral averages or use
of emissions estimated by a third party, again developed in a
variety of ways and in some cases not in a timely manner causing
data to be potentially outdated at the time when they are used.
Significant risks, uncertainties and variables are inherent in the
assessment, measurement and mitigation of climate and
sustainability-related risks. These include data quality gaps and
limitations mentioned above, as well as the pace at which climate
science, greenhouse gas accounting standards and various
emissions reduction solutions develop. In addition, there is
significant uncertainty about how climate change and the world’s
transition to a net-zero economy will unfold over time and how
and when climate and sustainability-related risks will manifest.
These timeframes are considerably longer than NWM Group’s
historical and current strategic, financial, resilience and
investment planning horizons.
As a result, NWM Group’s climate and sustainability-related
disclosures may be amended, updated or restated in the future as
the quality and completeness of NWM Group’s data and
methodologies continue to improve.
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
178
These data quality challenges, gaps and limitations may have a
material impact on NWM Group’s ability to make effective
business decisions about climate and sustainability-related risks
and opportunities, including risk management decisions, to comply
with disclosure requirements and to monitor and report progress
in meeting ambitions, targets and pathways.
Climate-related risks are challenging to model due to their
forward-looking nature, the lack of and/or quality of historical
testing capabilities, lack of accuracy, standardisation and
incompleteness of emissions and other climate and sub-sector
related data and the immature nature of risk measurement and
modelling methodologies. As a result, it is very difficult to predict
and model the impact of climate-related risks into precise financial
and economic outcomes.
The evaluation of climate-related risk exposure and the
development of associated potential risk mitigation techniques
largely depend on the choice of climate scenario modelling
methodology and the assumptions made which involves a number
of risks and uncertainties, for example:
climate scenarios are not predictions of what is likely to
happen or what NWM Group would like to happen, rather
they explore the possible implications of different judgements
and assumptions by considering a series of scenarios;
climate scenarios do not provide a comprehensive description
of all possible future outcomes;
lack of specialist expertise in NWM Group that needs to rely
on third party advice, modelling, and data which is also
subject to many limitations and uncertainties;
immaturity of modelling of and data on climate-related risks
on financial assets which will presumably evolve rapidly in the
coming years;
the number of variables and the forward-looking nature of
climate scenarios which makes them challenging to back test
and benchmark;
the significant uncertainty as to how the climate will evolve
over time, how and when governments, regulators,
businesses, investors and customers respond and how those
responses impact the economy, asset valuations, land
systems, energy systems, technology, policy and wider
society;
the assumptions will continue to evolve with more
data/information which may affect the baselines for
comparability across reporting periods and impact internal
and external verification processes; and
the pace of the development of the methodologies across
different sectors may be different and therefore it may be
challenging to report on the whole balance sheet with regard
to financed emissions
.
The calculation method for facilitated emissions in respect of
capital markets activities is still in the process of developing and to
date there is no unified industry approach. Therefore, measuring,
monitoring and reporting on facilitated emissions will present
similar data and modelling challenges as described above for on
balance sheet financed emissions.
Accordingly, these risks and uncertainties coupled with
significantly long timeframes make the outputs of climate-related
risk modelling, climate-related targets (including emission
reduction targets) and pathways, inherently more uncertain than
outputs modelled for traditional financial planning cycles based on
historical financial information. Furthermore, there is a lack of
scientific, industry and regulatory consensus regarding the
appropriate metrics, methodologies, modelling and standardised
reporting to enable the assessment of the location, acuteness,
and severity of climate-related risks and the monitoring and
mitigation of these risks in the economy and financial system.
There is increasing industry concern (acknowledged by the
Network for Greening the Financial System) that model scenarios,
including those provided by central banks and supervisory bodies
and are too benign and may not adequately capture: (i) the
financial implications of increasing frequency and severity of acute
physical risks as global temperatures increase; (ii) second and
third order impacts such as disruptions to supply chains and
increased geo-political risks; nor (iii) possible ‘tipping points’ that
could lead to large, irreversible changes in the climate system (for
example the melting of permafrost or the Greenland and
Antarctic ice sheets).
Capabilities within NWM Group to appropriately assess, model,
report and manage climate-related risks and impacts and the
suitability of the assumptions required to model and manage
climate-related risks appropriately continue to develop. But such
development is still in its early stages. Even when those
capabilities are appropriately developed, the high level of
uncertainty regarding any assumptions modelled, the highly
subjective nature of risk measurement and mitigation techniques,
incorrect or inadequate assumptions and judgements and data
quality gaps and limitations may lead to inadequate risk
management information and frameworks, or ineffective business
adaptation or mitigation strategies or regulatory non-compliance
all of which may have a material adverse effect on NWM Group’s
business, future results, financial condition, prospects, reputation
and the price of its securities.
Failure to implement effective governance, procedures,
systems and controls in compliance with legal, regulatory
requirements and societal expectations to manage climate
and sustainability-related risks and opportunities could
adversely affect NWM Group.
The UK’s prudential regulation of climate-related risk
management is an important driver in how NatWest Group
(including NWM Group) develops its associated risk framework for
financing activities or engaging with counterparties (including
suppliers). Legislative and regulatory authorities are publishing
expectations as to how banks should prudently manage and
transparently disclose climate and sustainability-related risks. In
the UK this includes the Bank of England’s Supervisory Statement
3/19 on the management of climate-related financial risks,
covering governance, risk management, scenario analysis and
disclosure which sets out expectations that firms, such as
NatWest Group (including NWM Group), take a strategic approach
to managing climate-related financial risks, identifying current
risks and those that can plausibly arise in the future, and
appropriate actions to mitigate those risks.
In March 2023 the Bank of England published a report setting out
its latest thinking on climate-related risks and regulatory capital
frameworks. It found there to be uncertainty over whether banks
are sufficiently capitalised for future climate-related losses, and it
stated that it will undertake further analysis to explore whether
changes to the regulatory capital frameworks may be required.
Any failure of NatWest Group (including NWM Group) to fully and
timely embed climate and other sustainability-related risks into its
risk management practices and framework to appropriately
identify, assess, prioritise and monitor the various climate-related
physical and transition risks and other sustainability-related risks
and apply the appropriate product governance process in line
with applicable legal and regulatory requirements and
expectations, may adversely affect NWM Group’s regulatory
compliance, prudential capital requirements, liquidity position and
this may have a material adverse effect on NWM Group’s
business, future results, financial condition, prospects, reputation
or the price of its securities.
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
179
Increasing levels of climate and other sustainability-related
laws, regulation and oversight may adversely affect NWM
Group.
NatWest Group as well as its subsidiaries in the UK, EU and
elsewhere are increasingly becoming subject to more extensive
climate and sustainability-related legal and regulatory
requirements. In the UK, these include mandatory requirements
by the FCA and under the Companies Act 2006 to make climate-
related disclosures consistent with the recommendations of the
Task Force on Climate related Financial Disclosures. In addition, in
August 2023 the FCA set out its intention to consult in 2024 on
rules and guidance for listed companies to disclose in line with the
UK-endorsed ISSB standards and the Transition Plan Taskforce
Disclosure Framework published in October 2023 as a
complementary package. Further regulatory requirements may
emerge as part of the developing UK sustainability-related
disclosure requirements. In the EU, these climate and
sustainability-related legal and regulatory requirements include
the EU Taxonomy, the EU Corporate Sustainability Reporting
Directive (‘CSRD’), the EU Green Bond Standard and proposed
EU Corporate Sustainability Due Diligence Directive (‘CSDDD’).
Certain non-UK subsidiaries of NatWest Group in the EU and
elsewhere may also be subject to EU, national and other climate
and sustainability laws and regulations which in some cases may
differ.
For example, NatWest Group’s Dutch subsidiary, NWM N.V., is
subject to the EU Taxonomy, CSRD, the proposed CSDDD and
other legal, regulatory and supervisory expectations relating to
climate-related and environmental risk management and
disclosure. A failure of NWM Group or any of its subsidiaries
including NWM N.V., to comply with these regulations, whether
through insufficient resources, expertise, support, customer and
counterparty data challenges or otherwise may have an adverse
effect on NWM Group’s reputation and the successful contribution
to the implementation of NatWest Group’s strategy.
In some jurisdictions, particularly the United States, regulatory and
enforcement activity around climate and sustainability initiatives is
becoming increasingly politicised. This has resulted in a
polarisation between promoting more extensive climate and
sustainability-related requirements, such as the proposed SEC
climate disclosure rules, and challenging climate and sustainability-
related initiatives on the basis of allegations that they could
breach applicable laws.
Divergence between UK, EU, US and other climate and
sustainability-related legal and regulatory requirements and their
interpretation may increase the cost of doing business (including
increased operating costs), may result in contentious regulatory
and litigation risk, may require changes to NWM Group’s business
and may restrict NWM Group’s access to the EU/EEA and US
capital markets.
Failure to comply with these divergent legal and regulatory
requirements which are applicable to NWM Group may result in
NWM Group and/or its subsidiaries not meeting applicable
regulatory requirements or investors’ expectations. Compliance
with these complex and evolving climate and sustainability-related
legal and regulatory requirements and voluntary standards and
initiatives is likely to require NWM Group to implement significant
changes to its business models, IT systems, products, governance,
internal controls over financial reporting, disclosure controls and
procedures, modelling capability and risk management systems,
which may increase the cost of doing business, result in higher
capital requirements and entail additional change risk and
increased compliance, regulatory sanctions, conduct and litigation
(including settlements) costs.
Failure to implement and comply with these requirements,
standards and initiatives may also result in investigations and/or
regulatory sanctions, reputational damage and investor
disapproval each of which may have a material adverse effect on
NWM Group’s future results, financial condition, prospects, and/or
reputation.
Increasing regulation of “greenwashing” is likely to increase
the risk of regulatory enforcement and investigation and
litigation.
Misrepresenting or over-emphasising the extent to which an
investment or other type of product takes into account ‘green’,
‘environmentally friendly’, ‘sustainable’ or ‘ethical’ features and
concerns, using misleading labels and language in relation to such
products and/or omitting material information about NWM
Group’s contribution to the climate crisis (including its direct or
indirect contribution to greenhouse gas emissions), or other
sustainability-related issues could potentially result in complaints,
regulatory investigation and/or sanction, claims and/or litigation
and/or reputational damage.
This risk is likely to increase as the UK and other jurisdictions
implement and enforce new anti-greenwashing regulations. For
example, the FCA’s Sustainability Disclosure Requirements and
investment labels policy statement (PS 23/16) published in
November 2023 includes a general anti-greenwashing rule that
requires regulated firms (such as NWM Plc) to ensure that
sustainability claims in financial promotions of their products and
services are consistent with the sustainability characteristics of
the product or service and are fair, clear and not misleading. The
FCA has stated that it would publish guidance as to how
regulated firms should comply with its anti-greenwashing rule
including the requirements for sustainability claims that will
become effective on 31 May 2024 (currently the subject of FCA
consultation paper (GC23/3)). In the EU the European Commission
has proposed a Green Claims Directive which will address false
environmental claims and the proliferation of environmental labels
by requiring certain claims to be substantiated with scientific
evidence and independently verified.
NatWest Group (including NWM Group) plans to invest in
voluntary carbon credits to mitigate emissions beyond its own
value chain whilst transitioning towards a state of net zero
emissions by 2050. NatWest Group (including NWM Group) may
also be involved in trading voluntary carbon credits with its clients,
or facilitating clients to trade these credits. Financial market and
platform regulators are increasingly taking an interest in the
voluntary carbon market and voluntary carbon credits retired,
sold or traded by financial institutions or used by them as part of
their own emissions reduction plans.
NWM Group could
potentially be exposed to financial, litigation, regulatory
enforcement and reputational risk where it retires, facilitates or is
otherwise associated with voluntary carbon credit transactions or
use (including use to offset own emissions). This includes where
voluntary carbon credits are not of sufficient quality, potential
issues or risks with respect to such carbon credits (or projects
through which they are generated) are not adequately disclosed
or stated benefits are exaggerated or misleading and/or such
carbon credits are used either by NWM Group or by a third party
organisation (such as a customer) as a substitute for achieving
appropriate emissions reductions in their own operations.
Any failure of NWM Group to implement robust and effective
climate and sustainability-related disclosure, communications and
product governance policies, procedures and controls to make
accurate public statements and claims about how environmentally
friendly, sustainable or ethical NWM Group’s products and
services are and to apply these in line with applicable legal and
regulatory requirements and expectations, may adversely affect
NWM Group’s regulatory compliance and/or reputation and could
give rise to increased regulatory enforcement, investigation and
litigation.
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
180
NWM Group may be subject to potential climate and other
sustainability-related litigation, enforcement proceedings,
investigations and conduct risk.
Due to increasing new climate and sustainability-related
jurisprudence, laws and regulations in the UK and other
jurisdictions, growing demand from investors and customers for
environmentally sustainable products and services, and regulatory
scrutiny, financial institutions, including NWM Group, may through
their business activities, face increasing litigation, conduct,
enforcement and contract liability risks related to climate change,
nature-related degradation, human rights violations and other
social, governance and sustainability-related issues.
These risks may arise, for example, from claims pertaining to:
-
failure to meet obligations, targets or commitments relating to,
or to disclose accurately, or provide updates on material
climate and/or sustainability-related risks, or otherwise provide
appropriate, balanced, clear, complete, correct, fair,
meaningful, understandable disclosure (which is capable of
being substantiated) to investors, customers, counterparties
(including suppliers) and other stakeholders;
-
conduct, mis-selling and customer protection claims, including
claims which may relate to alleged insufficient product
understanding, unsuitable product offering and /or reliance
upon information provided by NWM Group or claims alleging
u
nfair pricing of climate-related products, for example in
relation to products where limited liquidity or reliable market
data exists for benchmarking purposes or which may be
impacted by future climate policy uncertainty or other factors;
-
marketing that portrays products, securities, activities or
policies as having positive climate, nature-related or
sustainable outcomes to an extent that may not be the case,
or may not adequately be qualified and/or omits material
information about NWM Group’s contribution to the climate
crisis and/or its direct / indirect contribution to greenhouse gas
emissions or other sustainability-related issues;
-
damages claims under various tort theories, including common
law public nuisance claims, or negligent mismanagement of
physical and/or transition risks;
-
alleged violations of officers’, directors’ and other fiduciaries’
duties, for example by financing various carbon-intensive,
environmentally harmful or otherwise highly exposed assets,
companies, and industries;
-
changes in the understanding of what constitutes positive
climate, nature-related or sustainable outcomes as a result of
developing climate science, leading to discrepancy between
current product offerings and investor and/or market and/or
broader stakeholder expectations;
-
any weaknesses or failures in specific systems or processes
associated particularly with climate, nature-related or
sustainability linked products, and/or human rights due
diligence, including any failure in the timely implementation,
onboarding and/or updating of such systems or processes;
-
counterparties, collaborators, customers to whom NWM
Group provides services and third parties in NWM Group’s
value chain who act, or fail to act, or undertake due diligence,
or apply appropriate risk management and product
governance in a manner that may adversely affect NWM
Group’s reputation or sustainability credentials; or
-
NWM Group’s or its customers’, counterparties’ (including
suppliers’) involvement in, or decision not to participate in,
certain industries or projects associated with causing or
exacerbating climate change and nature-related degradation.
Furthermore, there is a risk that shareholders, campaign groups,
customers and activist groups could seek to take legal action
against NWM Group for financing or contributing to climate
change, nature-related degradation and human rights violations,
failure to implement or follow adequate governance procedures
and for not supporting the principles of ‘just transition’ (i.e.
maximising the social benefits of the transition, mitigating the
social risks of the transition, empowering those affected by the
change, anticipating future shifts to address issues up front and
mobilising investments from the public and private sectors).
There is an increase in the number of legal, conduct and
regulatory claims, as well as an increase in the variety of legal
bases being alleged, remedies sought and amount of damages
awarded in legal, conduct and regulatory proceedings,
investigations, administrative actions and other adversarial
proceedings against financial institutions for climate and
sustainability matters. There is a risk that as climate, nature-
related and environmental science develop and societal
understanding of these issues increases and deepens, courts,
regulators and enforcement authorities may apply the then
current understandings of climate and the broader sustainability-
related matters retrospectively when assessing claims about
historical conduct or dealings of financial institutions, including
NWM Group. There is also an increase in enforcement and
litigation focusing on challenging public and private sector
sustainability policies and initiatives intended to address climate
change and nature-related degradation. See also, ‘NWM Group is
exposed to the risk of various litigation matters, regulatory and
governmental actions and investigations as well as remedial
undertakings, the outcomes of which are inherently difficult to
predict, and which could have an adverse effect on NWM Group.’
In addition, supervisors and regulators are increasing their
enforcement focus on climate and sustainability-related matters.
For example, the ECB has stated that enforcement measures in
the form of periodic penalty payments may be imposed on banks
that do not fully align with ECB supervisory expectations of sound
practices for managing climate and environmental risks.
These potential litigation, conduct, enforcement and contract
liability risks may have a material adverse effect on NWM Group’s
ability to contribute to achieving NatWest Group’s strategy,
including NatWest Group’s climate ambitions and targets, and this
may have a material adverse effect on NWM Group’s future
results, financial condition, prospects, and/or reputation.
A reduction in the ESG ratings of NatWest Group or NWM
Group could have a negative impact on NatWest Group’s or
NWM Group’s reputation and on investors’ risk appetite and
customers’ willingness to deal with NatWest Group or NWM
Group
ESG ratings from agencies and data providers which rate how
NatWest Group (including NWM Group) or NWM Group manages
environmental, social and governance risks are increasingly
influencing investment decisions pertaining to NatWest Group’s
and/or NWM Group’s and/or their subsidiaries’ securities or being
used as a basis to label financial products and services as
environmentally friendly or sustainable. ESG ratings are often (i)
unsolicited; (ii) subject to the assessment and interpretation by the
ESG rating agencies; (iii) provided without warranty; (iv) not a
sponsorship, endorsement, or promotion of NatWest Group
(including NWM Group) or NWM Group by the relevant rating
agency; and (v) may depend on many factors some of which are
beyond NatWest Group’s and NWM Group’s control (e.g. any
change in rating methodology). In addition, NWM Group and
certain of its subsidiaries offer and sell products and services to
customers and counterparties based exclusively or largely on a
rating by an unregulated ESG rating agency or data providers.
ESG rating agencies, at this stage, are not subject to any specific
regulatory or other regime or oversight (although there are
proposals by regulators in different jurisdictions to regulate rating
agencies and data providers).
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
181
Regulators have expressed concern that harm may arise from
potential conflicts of interest within ESG rating and review or
second party opinion providers and there is a lack of
transparency in methodologies and data points, which renders
ratings and reviews incomparable between agencies or
providers.
Any material reduction in the ESG ratings of NatWest Group
(including NWM Group) or NWM Group may have a negative
impact on NWM Group’s reputation, could influence investors’ risk
appetite for NWM Group’s and/or its subsidiaries’ securities,
particularly ESG securities, could potentially affect the pricing of
securities issued by NWM Group and/or its subsidiaries and could
affect a customer’s willingness to deal with NWM Group. A
regulatory sanction or enforcement action involving an ESG rating
agency used by a NatWest Group or NWM Group entity could
also have a negative impact on NWM Group’s reputation.
Operational and IT resilience risk
Operational risks (including reliance on third party suppliers
and outsourcing of certain activities) are inherent in NWM
Group’s businesses.
Operational risk is the risk of loss or disruption resulting from
inadequate or failed internal processes, procedures, people or
systems, or from external events, including legal and regulatory
risks, third party processes, procedures, people or systems. NWM
Group operates in a number of countries, offering a diverse range
of products and services supported directly or indirectly by third
party suppliers. As a result, operational risks or losses can arise
from a number of internal or external factors (including for
example, payment errors or financial crime and fraud), for which
there is continued scrutiny by third parties on NWM Group’s
compliance with financial crime requirements; see ‘NWM Group is
exposed to the risk of various litigation matters, regulatory and
governmental actions and investigations as well as remedial
undertakings, the outcomes of which are inherently difficult to
predict, and which could have an adverse effect on NWM Group.’
These risks are also present when NWM Group relies on critical
service providers (suppliers) or vendors to provide services to it or
its clients, as is increasingly the case as NWM Group outsources
certain activities, including with respect to the implementation of
technologies, innovation and responding to regulatory and market
changes.
Operational risks continue to be heightened as a result of the
implementation of NatWest Group’s strategy, and the
organisational and operational changes involved, including
NatWest Group’s phased withdrawal from ROI; NatWest Group’s
current cost-controlling measures; the progression towards
working as One Bank across NatWest Group to serve customers;
and conditions affecting the financial services industry generally
(including macroeconomic and other geopolitical developments) as
well as the legal and regulatory uncertainty resulting from these
conditions. It is unclear as to how the future ways of working may
further evolve, including in respect of how working practices may
develop, or how NWM Group will evolve to best serve its
customers. Any of the above may place significant pressure on
NWM Group’s ability to maintain effective internal controls and
governance frameworks.
In recent years, NWM Group has materially increased its
dependence on NatWest Bank Plc and other NatWest Group
entities for numerous critical services and operations, including,
without limitation, property, finance, accounting, treasury, legal,
risk, regulatory compliance and reporting, financial crime, human
resources, and certain other support and administrative functions.
A failure by NatWest Bank Plc or other NatWest Group entities to
adequately supply these services may expose NWM Group to
critical business failure risk, increased costs and other liabilities.
These and any increases in the cost of these services may
adversely affect NWM Group.
The effective management of operational risks is critical to
meeting customer service expectations and retaining and
attracting client business. Although NWM Group has implemented
risk controls and mitigation actions, with resources and planning
having been devoted to mitigate operational risk, such measures
may not be effective in controlling each of the operational risks
faced by NWM Group.
Ineffective management of such risks may have a material
adverse effect on NWM Group’s future results, financial condition,
prospects, and/or reputation.
NWM Group is subject to sophisticated and frequent
cyberattacks.
NWM Group experiences a constant threat from cyberattacks
across the entire NatWest Group (including NWM Group) and
against NatWest Group and NWM Group’s supply chain,
reinforcing the importance of due diligence of and close working
relationship with, the third parties on which NWM Group relies.
NWM Group is reliant on technology, against which there is a
constantly evolving series of attacks, that are increasing in terms
of frequency, sophistication, impact and severity. As cyberattacks
evolve and become more sophisticated, NWM Group is required
to continue to invest in additional capability designed to defend
against emerging threats. In 2023, NatWest Group and its supply
chain were subjected to a small number of Distributed Denial of
Service and ransomware attacks, which are a pervasive threat to
the financial services industry (including NWM Group). The focus is
to manage the impact of the attacks and sustain availability of
services for NWM Group’s customers. Consequently, NWM Group
continues to invest significant resources in developing and
evolving of cybersecurity controls that are designed to minimise
the potential effect of such attacks. Third parties continue to
make hostile attempts to gain access to, introduce malware
(including ransomware) into and exploit potential vulnerabilities of
NWM Group’s IT systems.
NWM Group has information and cybersecurity controls that seek
to minimise the impact of any such attacks, which are subject to
review on a regular basis, but given the nature of the threat,
there can be no assurance that such measures will prevent the
potential adverse effect of an attack from occurring. See also,
‘NWM Group’s operations are highly dependent on its complex IT
systems and any IT failure could adversely affect NWM Group.’
Any failure in NWM Group’s information and cybersecurity
policies, procedures or controls, may result in significant financial
losses, major business disruption, inability to deliver customer
services, or loss of, or ability to access, data or systems or other
sensitive information (including as a result of an outage) and may
cause associated reputational damage. Any of these factors could
increase costs (including costs relating to notification of, or
compensation for clients and credit monitoring), result in
regulatory investigations or sanctions being imposed or may affect
NWM Group’s ability to retain and attract clients. Regulators in
the UK, US, Europe and Asia continue to recognise cybersecurity
as an important systemic risk to the financial sector and have
highlighted the need for financial institutions to improve their
monitoring and control of, and resilience (particularly of critical
services) to cyberattacks, and to provide timely reporting or
notification of them, as appropriate (including for example, the
new SEC cybersecurity requirements). Furthermore, cyberattacks
on NWM Group’s counterparties and suppliers may also have an
adverse effect on NWM Group’s operations.
Additionally, third parties may induce employees, customers, third
party providers or other users with access to NWM Group’s
systems to wrongfully disclose sensitive information to gain access
to NWM Group’s data or systems or that of NWM Group’s clients
or employees.
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
182
Cybersecurity and information security events can derive from
groups or factors such as: internal or external threat actors,
human error, fraud or malice on the part of NWM Group’s
employees or third parties, including third party providers, or may
result from technological failure.
NWM Group expects greater regulatory engagement, supervision
and enforcement to continue in relation to its overall resilience to
withstand IT and IT-related disruption, either through a
cyberattack or some other disruptive event. Such increased
regulatory engagement, supervision and enforcement is uncertain
in relation to the scope, cost, consequence and the
pace of
change, which may adversely affect NWM Group. Due to NWM
Group’s reliance on technology and the increasing sophistication,
frequency and impact of cyberattacks, such attacks may have an
adverse effect on NWM Group.
In accordance with the Data Protection Act 2018 and the
European Union Withdrawal Act 2018, the Data Protection,
Privacy and Electronic Communications (Amendments Etc.) (EU
Exit) Regulations 2019, as amended by the Data Protection,
Privacy and Electronic Communications (Amendments Etc.) (EU
Exit) Regulations 2020 (‘UK Data Protection Framework’) and
European Banking Authority (‘EBA’) Guidelines on ICT and
Security Risk Management, NWM Group is required to ensure it
implements timely appropriate and effective organisational and
technological safeguards against unauthorised or unlawful access
to the data of NWM Group, its clients and its employees. In order
to meet this requirement, NWM Group relies on the effectiveness
of its internal policies, controls and procedures to protect the
confidentiality, integrity and availability of information held on its IT
systems, networks and devices as well as with third parties with
whom NWM Group interacts. A failure to monitor and manage
data in accordance with the UK Data Protection Framework and
EBA requirements of the applicable legislation may result in
financial losses, regulatory fines and investigations and associated
reputational damage.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation
.
NWM Group operations and strategy are highly dependent
on the accuracy and effective use of data.
NWM Group relies on the effective use of accurate data to
support, monitor, evaluate, manage and enhance its operations,
innovate its products offering, meet its regulatory obligations, and
deliver its strategy. Investment is being made in data tools and
analytics, including raising awareness around ethical data usage
(for example, in relation to the use of artificial intelligence) and
privacy across NWM Group. The availability and accessibility of
current, complete, detailed, accurate and, wherever possible,
machine-readable customer segment and sub-sector data,
together with appropriate governance and accountability for data,
is fast becoming a critical strategic asset, which is subject to
increased regulatory focus. Failure to have or be able to access
that data or the ineffective use or governance of that data could
result in a failure to manage and report important risks and
opportunities or satisfy customers’ expectations including the
inability to deliver products and services. This could also result in a
failure to deliver NWM Group’s strategy and could place NWM
Group at a competitive disadvantage by increasing its costs,
inhibiting its efforts to reduce costs or its ability to improve its
systems, controls and processes which could result in a failure to
deliver NWM Group’s strategy. These data weaknesses and
limitations, or the unethical or inappropriate use of data, and/or
non-compliance with data protection laws could give rise to
conduct and litigation risks and may increase the risk of
operational challenges, losses, reputational damage or other
adverse consequences due to inappropriate models, systems,
processes, decisions or other actions.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
NWM Group relies on attracting, retaining, developing and
remunerating diverse senior management and skilled
personnel (such as market trading specialists), and is
required to maintain good employee relations.
NWM Group’s success depends on its ability to attract, retain,
through creating an inclusive environment, and develop and
remunerate highly skilled and qualified diverse personnel, including
senior management, directors, market trading specialists and key
employees (including for technology and data focused roles), in a
highly competitive market, in an era of strategic change and
under internal cost-reduction pressures. In July 2023, NatWest
Group plc (NWM Group’s parent entity) appointed a new CEO for
an initial term of twelve months, during which it expects to make
a permanent appointment for the role.
The inability to compensate employees competitively and/or any
reduction of compensation, the perception that NWM Group may
not be a viable or competitive business, heightened regulatory
oversight of banks and the increasing scrutiny of, and (in some
cases) restrictions placed upon, employee compensation
arrangements (in particular those of banks in receipt of
government support such as NatWest Group), negative economic
developments or other factors, may have an adverse effect on
NWM Group’s ability to hire, retain and engage well qualified
employees, especially at a senior level, which could adversely
affect NWM Group.
This increases the cost of hiring, training and retaining diverse
skilled personnel. In addition, certain economic, market and
regulatory conditions and political developments may reduce the
pool of candidates for key management and non-executive roles,
including non-executive directors with the right skills, knowledge
and experience, or may increase the number of departures of
existing employees. Moreover, a failure to foster a diverse and
inclusive workforce may adversely affect NWM Group’s employee
engagement and the formulation and execution of its strategy,
and could also have a negative effect on its reputation with
customers, investors and regulators.
Some of NWM Group’s employees are represented by employee
representative bodies, including trade unions and works councils.
Engagement with its employees and such bodies is important to
NWM Group in maintaining good employee relations. Any
breakdown of these relationships may adversely affect NWM
Group.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
NWM Group’s operations are highly dependent on its
complex IT systems and any IT failure could adversely affect
NWM Group.
NWM Group’s operations are highly dependent on the ability to
process a very large number of transactions efficiently and
accurately while complying with applicable laws and regulations.
The proper functioning of NatWest Group’s (including NWM
Group’s) transactional and payment systems, financial crime,
fraud, systems and controls, risk management, credit analysis and
reporting, accounting, customer service and other IT systems
(some of which are owned and operated by other entities in
NatWest Group or third parties), is critical to NWM Group’s
operations.
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
183
Individually or collectively, any system failure, loss of service
availability or breach of data security could potentially cause
significant damage to (i) important business services across NWM
Group and (ii) NWM Group’s ability to provide services to its
clients, which could result in reputational damage, significant
compensation costs and regulatory sanctions (including fines
resulting from regulatory investigations) or a breach of applicable
regulations and could affect NWM Group’s regulatory approvals,
competitive position, business and brands, which could undermine
its ability to attract and retain customers and talent.
NWM Group outsources certain functions as it innovates and
offers new digital solutions to its customers to meet the demand
for online and mobile banking. Outsourcing, alongside remote
working patterns of NWM Group employees, heighten the above
risks.
NWM Group uses IT systems that enable remote working
interface with third-party systems, and NWM Group could
experience service denials or disruptions if such systems exceed
capacity or if NWM Group or a third-party system fails or
experiences any interruptions, all of which could result in business
and customer interruption and related reputational damage,
significant compensation costs, regulatory sanctions and/or a
breach of applicable regulations.
In 2023, NWM Group made considerable investments to further
simplify, upgrade and improve its IT and technology capabilities
(including migration of certain services to cloud platforms). NWM
Group also continues to develop and enhance digital services for
its customers and seeks to improve its competitive position
through enhancing controls and procedures and strengthening
the resilience of services including cybersecurity. Any failure of
these investment and rationalisation initiatives to achieve the
expected results, due to cost challenges or otherwise, may
adversely affect NWM Group’s operations, its reputation and
ability to retain or grow its client business or adversely affect its
competitive position, thereby negatively impacting NWM Group.
See also, ‘NWM Group has been in a period of significant
structural and other change, including as a result of NatWest
Group’s strategy and NatWest Group’s recent creation of its C&I
business segment (of which NWM Group forms part) and may
continue to be subject to significant structural and other change.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
A failure in NWM Group’s risk management framework
could adversely affect NWM Group, including its ability to
achieve its strategic objectives.
A failure in design, or adherence to, NatWest Group’s risk
management framework could adversely affect NWM Group,
including its ability to achieve its strategic objectives. Risk
management is an integral part of all of NWM Group’s activities
and delivery of its long-term strategy. NatWest Group’s
Enterprise-Wide Risk Management Framework sets out NWM
Group’s approach for managing risk within NWM Group including
in relation to risk governance and risk appetite. A failure to
adhere to this framework, or any material weaknesses or
deficiencies in the framework’s controls and procedures, could
adversely affect NWM Group’s financial condition and strategic
delivery including in relation to inaccurate adherence to agreed
risk appetite statements and accurate risk reporting of risk
exposures.
Financial risk management is highly dependent on the use and
effectiveness of internal stress tests and models and ineffective
risk management may arise from a wide variety of factors,
including lack of transparency or incomplete risk reporting,
manual processes and controls, inaccurate data, inadequate IT
systems, unidentified conflicts or misaligned incentives, lack of
accountability control and governance, incomplete risk monitoring
(including trade surveillance) and failures of systems to properly
process all relevant data, risks related to unanticipated behaviour
or performance in algorithmic trading and management or
insufficient challenges or assurance processes or a failure to
commence or timely complete risk remediation projects. Failure to
manage risks effectively, or within regulatory expectations, could
adversely affect NWM Group’s reputation or its relationship with
its regulators, clients, shareholders or other stakeholders.
In addition, financial crime risk management is dependent on the
use and effectiveness of financial crime assessment, systems and
controls. Weak or ineffective financial crime processes and
controls may risk NWM Group inadvertently facilitating financial
crime which may result in regulatory investigation, sanction,
litigation, fines and/or reputational damage. Financial crime
continues to evolve, whether through fraud, scams, cyberattacks
or other criminal activity. These risks are exacerbated as NWM
Group continues to innovate its product offering and increasingly
offers digital solutions to its customers.
NatWest Group (including
NWM Group) has made and continues to make significant, multi-
year investments to strengthen and improve its overall financial
crime control framework with prevention systems and capabilities.
As part of its ongoing programme of investment, there is current
and future investment planned to further strengthen financial
crime controls over the coming years, including investment in new
technologies and capabilities to further enhance customer due
diligence, transaction monitoring, sanctions and anti-bribery and
corruption systems. A number of NWM Group’s financial crime
controls are operated by NatWest Group on behalf of NWM
Group.
NWM Group’s operations are inherently exposed to conduct risks,
which include business decisions, actions or reward mechanisms
that are not responsive to or aligned with NWM Group’s
regulatory obligations, client needs or do not reflect NWM Group’s
customer-focused strategy, ineffective product management,
unethical or inappropriate use of data, information asymmetry,
implementation and utilisation of new technologies, outsourcing of
customer service and product delivery, inappropriate behaviour
towards customers, customer outcomes, the possibility of mis-
selling of financial products and mishandling of customer
complaints. Some of these risks have materialised in the past and
ineffective management and oversight of conduct risks may lead
to further remediation and regulatory intervention or
enforcement.
NWM Group’s businesses are also exposed to risks from
employee, contractor, or service providers misconduct including
non-compliance with policies and regulations, negligence or fraud
(including financial crimes and fraud), any of which could result in
regulatory fines or sanctions and serious reputational or financial
harm to NWM Group. Remote working arrangements for NWM
Group employees place heavy reliance on the IT systems that
enable remote working and may place additional pressure on
NWM Group’s ability to maintain effective internal controls and
governance frameworks and increase operational risk. Remote
working arrangements are also subject to regulatory scrutiny to
ensure adequate recording, surveillance and supervision of
regulated activities and compliance with regulatory requirements
and expectations, including requirements to: meet threshold
conditions for regulated activities; ensure the ability to oversee
functions (including any outsourced functions); ensure no
detriment is caused to customers; and ensure no increased risk of
financial crime.
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
184
NWM Group seeks to embed a risk awareness culture across the
organisation and has implemented policies and allocated new
resources across all levels of the organisation to manage and
mitigate conduct risk and expects to continue to invest in risk
management, including the ongoing development of a NatWest
Group risk management strategy in line with regulatory
expectations. However, such efforts may not insulate NWM Group
from instances of misconduct and no assurance can be given that
NWM Group’s strategy and control framework will be effective.
See also, ‘NWM Group has been in a period of significant
structural and other change, including as a result of NatWest
Group’s strategy and NatWest Group’s recent creation of its C&I
business segment (of which NWM Group forms part) and may
continue to be subject to significant structural and other change.’
Any failure in NWM Group’s risk management framework may
have a material adverse effect on NWM Group’s future results,
financial condition, prospects, and/or reputation and may result in
the inability to achieve its strategic objectives for its clients,
employees and wider stakeholders.
NWM Group’s operations are subject to inherent reputational
risk.
Reputational risk relates to stakeholder and public perceptions of
NWM Group arising from an actual or perceived failure to meet
stakeholder or the public’s expectations, including with respect to
NatWest Group’s strategy and related targets, NWM Group’s
strategy, the progression towards working as One Bank across
the NatWest Group to serve customers, or due to any events,
behaviour, action or inaction by NWM Group, its employees or
those with whom NWM Group is associated. See also, ‘NWM
Group’s businesses are subject to substantial regulation and
oversight, which are constantly evolving and may adversely affect
NWM Group.’
This includes harm to its brand, which may be detrimental to
NWM Group’s business, including its ability to build or sustain
business relationships with clients, stakeholders and regulators,
and may cause low employee morale, regulatory censure or
reduced access to, or an increase in the cost of, funding.
Reputational risk may arise whenever there is, or there is
perceived to be, a material lapse in standards of integrity,
compliance, customer or operating efficiency, or regulatory or
press scrutiny, and may adversely affect NWM Group’s ability to
attract and retain clients. In particular, NWM Group’s ability to
attract and retain clients, and talent, and engage with
counterparties may be adversely affected by factors including:
negative public opinion resulting from the actual or perceived
manner in which NWM Group or any other member of NatWest
Group conducts or modifies its business activities and operations,
media coverage (whether accurate or otherwise), employee
misconduct, NWM Group’s financial performance, IT systems
failures or cyberattacks, data breaches, financial crime and fraud,
the level of direct and indirect government support for NatWest
Group plc, or the actual or perceived practices in the banking and
financial industry in general, or a wide variety of other factors.
Technologies, in particular online social networks and other
broadcast tools that facilitate communication with large audiences
in short timeframes and with minimal costs, may also significantly
increase and accelerate the impact of damaging information and
allegations.
Although NWM Group has implemented a Reputational Risk Policy
to identify, measure and manage material reputational risk
exposures, NWM Group cannot be certain that it will be successful
in avoiding damage to its business from reputational risk.
Any of the above aspects of reputational risk may have a material
adverse effect on NWM Group’s future results, financial condition,
prospects, and/or reputation.
Legal, regulatory and conduct risk
NWM Group’s businesses are subject to substantial
regulation and oversight, which are constantly evolving and
may adversely affect NWM Group.
NWM Group is subject to extensive laws, regulations, guidelines,
corporate governance practice and disclosure requirements,
administrative actions and policies in each jurisdiction in which it
operates, which represents ongoing compliance and conduct
risks. Many of these have been introduced or amended recently
and are subject to further material changes, which may increase
compliance and conduct risks, particularly as EU/EEA and UK
laws diverge as a result of Brexit. NWM Group expects
government and regulatory intervention in the financial services
industry to remain high for the foreseeable future.
Regulators and governments continue to focus on reforming the
prudential regulation of the financial services industry and the
manner in which the business of financial services is conducted.
Measures have included: enhanced capital, liquidity and funding
requirements, through initiatives such as the Basel 3.1 standards
implementation (and any resulting effect on RWAs and models),
the UK ring-fencing regime, the strengthening of the recovery and
resolution framework applicable to financial institutions in the UK,
the EU and the US, financial industry reforms (including in respect
of MiFID II and the FSM Act 2023), LIBOR transition, corporate
governance requirements, rules relating to the compensation of
senior management and other employees, enhanced data
protection and IT resilience requirements, financial market
infrastructure reforms, enhanced regulations in respect of the
provision of ‘investment services and activities’, and increased
regulatory focus in certain areas, including conduct, consumer
protection (such as the FCA’s Consumer Duty) in retail or other
financial markets, competition and disputes regimes, anti-money
laundering, anti-corruption, anti-bribery, anti-tax evasion,
payment systems, sanctions and anti-terrorism laws and
regulations.
In addition, there is significant oversight by competition authorities
of the jurisdictions in which NWM Group operates. The
competitive landscape for banks and other financial institutions in
the UK, EU/EEA, Asia and the US is rapidly changing. Recent
regulatory and legal changes have and may continue to result in
new market participants and changed competitive dynamics in
certain key areas. Regulatory and competition authorities,
including the CMA, are also looking at and focusing more on how
they can support competition and innovation in digital and other
markets.
Recent regulatory changes and heightened levels of public and
regulatory scrutiny in the UK, the EU and the US have resulted in
increased capital, funding and liquidity requirements, changes in
the competitive landscape, changes in other regulatory
requirements and increased operating costs, and have impacted,
and will continue to impact, product offerings and business
models.
Other areas in which, and examples of where, governmental
policies, regulatory and accounting changes and increased public
and regulatory scrutiny may have an adverse effect (some of
which could be material) on NWM Group include, but are not
limited to, the following:
general changes in government, central bank, regulatory or
competition policy, or changes in regulatory regimes that may
influence investor decisions in the jurisdictions in which NWM
Group operates; rules relating to foreign ownership,
expropriation, nationalisation and confiscation or appropriation
of assets;
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
185
new or increased regulations relating to customer data
protection as well as IT controls and resilience, such as the
proposed UK Data Protection and Digital Information Bill (No
2) and in India, the Digital Personal Data Protection Bill 2022;
the introduction of, and changes to, taxes, levies or fees
applicable to NWM Group’s operations, such as the
introduction of global minimum tax rules, changes in tax rates,
changes in the scope and administration of the Bank Levy,
increases in the bank corporation tax surcharge in the UK,
restrictions on the tax deductibility of interest payments or
further restrictions imposed on the treatment of carry-forward
tax losses that reduce the value of deferred tax assets and
require increased payments of tax;
the potential introduction by the Bank of England of a Central
Bank Digital Currency which could result in deposit outflows,
higher funding costs, and/or other implications for UK banks
including NWM Group; and
regulatory enforcement in the form of PRA imposed financial
penalties for failings in banks’ regulatory reporting governance
and controls, and ongoing regulatory scrutiny; the PRA’s
thematic reviews of the governance, controls and processes
for preparing regulatory returns of selected UK banks,
including NatWest Group (of which NWM Group is a part of);
‘Dear CEO’ letters issued by the Bank of England from time to
time;
recent or proposed US regulations around cybersecurity
incidents, climate disclosures, and other climate and
sustainability-related rules;
new or increased regulations relating to financial crime
(including the new criminal offence of failure to prevent fraud);
and
any regulatory requirements relating to the use of artificial
intelligence and large language models across the financial
services industry (such as the European Union Artificial
Intelligence Act).
Any of these developments (including any failure to comply with
new rules and regulations) could also have an adverse effect on
NWM Group’s authorisations and licences, the products and
services that NWM Group may offer, its reputation and the value
of its assets, NWM Group’s operations or legal entity structure,
and the manner in which NWM Group conducts its business.
Material consequences could arise should NWM Group be found
to be non-compliant with these regulatory requirements.
Regulatory developments may also result in an increased number
of regulatory investigations and proceedings and have increased
the risks relating to NWM Group’s ability to comply with the
applicable body of rules and regulations in the manner and within
the timeframes required.
Changes in laws, rules or regulations, or in their interpretation or
enforcement, or the implementation of new laws, rules or
regulations, including contradictory or conflicting laws, rules or
regulations by key regulators or policymakers in different
jurisdictions, or failure by NWM Group to comply with such laws,
rules and regulations, may adversely affect NWM Group’s
business, results of operations and outlook. In addition,
uncertainty and insufficient international regulatory coordination
as enhanced supervisory standards are developed and
implemented may adversely affect NWM Group’s ability to engage
in effective business, capital and risk management planning.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
NWM Group is exposed to the risks of various litigation
matters, regulatory and governmental actions and
investigations as well as remedial undertakings, the
outcomes of which are inherently difficult to predict, and
which could have an adverse effect on NWM Group.
NWM Group’s operations are diverse and complex and it operates
in legal and regulatory environments that expose it to potentially
significant civil actions (including those following on from
regulatory sanction), as well as criminal, regulatory and
governmental proceedings. NWM Group has resolved a number of
legal and regulatory actions over the past several years but
continues to be, and may in the future be, involved in such actions
in the US, the UK, Asia, Europe and other jurisdictions.
NWM Group is, has recently been or will likely be involved in a
number of significant legal and regulatory actions, including
investigations, proceedings and ongoing reviews (both formal and
informal) by governmental law enforcement and other agencies
and litigation proceedings, including in relation to the offering of
securities, conduct in the foreign exchange market, the setting of
benchmark rates such as LIBOR and related derivatives trading,
the issuance, underwriting, and sales and trading of fixed-income
securities (including government securities), product mis-selling,
customer mistreatment, anti-money laundering, antitrust, VAT
recovery and various other issues. There is also an increasing risk
of new class action claims being brought against NWM Group in
the Competition Appeal Tribunal for breaches of competition law.
Legal and regulatory actions are subject to many uncertainties,
and their outcomes, including the timing, amount of fines,
damages or settlements or the form of any settlements, which
may be material and in excess of any related provisions, are often
difficult to predict, particularly in the early stages of a case or
investigation. NWM Group’s expectation for resolution may
change and substantial additional provisions and costs may be
recognised in respect of any matter.
The resolution of significant investigations include: NWM Plc’s
December 2021 spoofing-related guilty plea in the United States
that was agreed with the US Department of Justice (‘DOJ’), and
involves a three-year period of probation, an independent
corporate monitor and the ongoing implementation of
recommendations made by it, and commitments to compliance
programme reviews and improvements and reporting obligations.
In the event that NWM Plc does not meet its obligations to the
DOJ, this may lead to adverse consequences such as increased
costs from any extension of monitorship and/or the period of the
probation, findings that NWM Plc violated its probation term and
possible re-sentencing, amongst other consequences.
For additional information relating to this and other legal and
regulatory proceedings and matters to which NWM Group is
currently exposed, see ‘Litigation and regulatory matters’ at Note
25 to the consolidated accounts.
Recently resolved matters or adverse outcomes or resolution of
current or future legal or regulatory actions, could increase the
risk of greater regulatory and third-party scrutiny and could have
material collateral consequences for NWM Group’s business and
result in restrictions or limitations on NWM Group’s operations.
These may include the effective or actual disqualification from
carrying on certain regulated activities and consequences
resulting from the need to reapply for various important licences
or obtain waivers to conduct certain existing activities of NWM
Group, particularly but not solely in the US, which may take a
significant period of time and the results and implications of which
are uncertain.
Risk Factors continued
NWM Group
Annual Report and Accounts 2023
186
Disqualification from carrying on any activities, whether
automatically as a result of the resolution of a particular matter or
as a result of the failure to obtain such licences or waivers could
adversely affect NWM Group’s business, in particular in the US.
This in turn and/or any fines, settlement payments or penalties
may adversely affect NWM Group. Similar consequences could
result from legal or regulatory actions relating to other parts of
NatWest Group.
Failure to comply with undertakings made by NWM Group to its
regulators, or the conditions of probation resulting from the
spoofing-related guilty plea, may result in additional measures or
penalties being taken against NWM Group. In addition, any failure
to administer conduct redress processes adequately, or to handle
individual complaints fairly or appropriately, could result in further
claims as well as the imposition of additional measures or
limitations on NWM Group’s operations, additional supervision by
NWM Group’s regulators, and loss of investor confidence.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
Changes in tax legislation or failure to generate future
taxable profits may impact the recoverability of certain
deferred tax assets recognised by NWM Group.
In accordance with the accounting policies set out in the section
‘Critical accounting policies ’, NWM Group has recognised
deferred tax assets on losses available to relieve future profits
from tax only to the extent it is probable that they will be
recovered. The deferred tax assets are quantified on the basis of
current tax legislation and accounting standards and are subject
to change in respect of the future rates of tax or the rules for
computing taxable profits and offsetting allowable losses.
Failure to generate sufficient future taxable profits or further
changes in tax legislation (including with respect to rates of tax)
or accounting standards may reduce the recoverable amount of
the recognised tax loss deferred tax assets, amounting to £55
million as at 31 December 2023. Changes to the treatment of
certain deferred tax assets may impact NWM Group’s capital
position. In addition, NWM Group’s interpretation or application of
relevant tax laws may differ from those of the relevant tax
authorities and provisions are made for potential tax liabilities that
may arise on the basis of the amounts expected to be paid to tax
authorities. The amounts ultimately paid may differ materially
from the amounts provided depending on the ultimate resolution
of such matters.
Any of the above may have a material adverse effect on NWM
Group’s future results, financial condition, prospects, and/or
reputation.
Forward looking statements
NWM Group
Annual Report and Accounts 2023
187
Cautionary statement regarding forward-looking
statements
Certain sections in this document contain ‘forward-looking
statements’ as that term is defined in the United States Private
Securities Litigation Reform Act of 1995, such as statements that
include the words ‘expect’, ‘estimate’, ‘project’, ‘anticipate’,
‘commit’, ‘believe’, ‘should’, ‘intend’, ‘will’, ‘plan’, ‘could’,
‘probability’, ‘risk’, ‘Value-at-Risk (VaR)’, ‘target’, ‘goal’, ‘objective’,
‘may’, ‘endeavour’, ‘outlook’, ‘optimistic’, ‘prospects’ and similar
expressions or variations on these expressions. In particular, this
document includes forward-looking targets and guidance relating
to financial performance measures, such as income growth,
operating expense, cost reductions, impairment loss rates,
balance sheet reduction, including the reduction of RWAs, CET1
ratio (and key drivers of the CET1 ratio, including timing, impact
and details), Pillar 2 and other regulatory buffer requirements and
MREL and non-financial performance measures, such as climate
and sustainability-related performance ambitions, targets and
metrics, including in relation to initiatives to transition to a net
zero economy, Climate and Sustainable Funding and Financing
(CSFF) and financed emissions. In addition, this document includes
forward-looking statements relating, but not limited to: planned
cost reductions, disposal losses and strategic costs;
implementation of NatWest Group’s and NWM Group’s strategy
(including in relation to investment programmes relating to digital
transformation of their operations and services and inorganic
opportunities); the timing and outcome of litigation and
government and regulatory investigations; funding plans and
credit risk profile; managing its capital position; liquidity ratio;
portfolios; net interest margin; and drivers related thereto; lending
and income growth, product share and growth in target
segments; impairments and write-downs; restructuring and
remediation costs and charges; NWM Group’s exposure to
political risk, economic assumptions and risk, climate,
environmental and sustainability risk, operational risk, conduct
risk, financial crime risk, cyber, data and IT risk and credit rating
risk and to various types of market risk, including interest rate
risk, foreign exchange rate risk and commodity and equity price
risk; customer experience, including our Net Promotor Score
(NPS); employee engagement and gender balance in leadership
positions.
Limitations inherent to forward-looking statements
These statements are based on current plans, expectations,
estimates, targets and projections, and are subject to significant
inherent risks, uncertainties and other factors, both external and
relating to NatWest Group’s and NWM Group’s strategy or
operations, which may result in NWM Group being unable to
achieve the current plans, expectations, estimates, targets,
projections and other anticipated outcomes expressed or implied
by such forward-looking statements. In addition, certain of these
disclosures are dependent on choices relying on key model
characteristics and assumptions and are subject to various
limitations, including assumptions and estimates made by
management. By their nature, certain of these disclosures are
only estimates and, as a result, actual future results, gains or
losses could differ materially from those that have been estimated.
Accordingly, undue reliance should not be placed on these
statements. The forward-looking statements contained in this
document speak only as of the date we make them and we
expressly disclaim any obligation or undertaking to update or
revise any forward-looking statements contained herein, whether
to reflect any change in our expectations with regard thereto, any
change in events, conditions or circumstances on which any such
statement is based, or otherwise, except to the extent legally
required.
Important factors that could affect the actual outcome
of the forward-looking statements
We caution you that a large number of important factors could
adversely affect our results or our ability to implement our
strategy, cause us to fail to meet our targets, predictions,
expectations and other anticipated outcomes or affect the
accuracy of forward-looking statements described in this
document. These factors include, but are not limited to, those set
forth in the risk factors and the other uncertainties described in
NatWest Markets Plc’s Annual Report and its other public filings.
The principal risks and uncertainties that could adversely affect
NWM Group’s future results, its financial condition and/or
prospects and cause them to be materially different from what is
forecast or expected, include, but are not limited to: economic
and political risk (including in respect of: economic and political
risks and uncertainties in the UK and global markets, including as
a result of GDP growth, inflation and interest rates, supply chain
disruption, and geopolitical developments; changes in interest
rates and foreign currency exchange rates; uncertainty regarding
the effects of Brexit; and HM Treasury’s ownership of NatWest
Group plc); strategic risk (including in respect of: NatWest Group’s
strategy and NatWest Group’s creation of its Commercial &
Institutional segment (of which NWM Group forms part); financial
resilience risk (including in respect of: NWM Group’s ability to
meet targets, generate returns or implement its strategy
effectively; prudential regulatory requirements for capital and
MREL; NWM Group’s reliance on access to capital markets
directly or indirectly through its parent (NatWest Group); capital,
funding and liquidity risk; reductions in the credit ratings; the
competitive environment; the requirements of regulatory stress
tests; counterparty and borrower risk; model risk; sensitivity to
accounting policies, judgements, estimates and assumptions (and
the economic, climate, competitive and other forward looking
information affecting those judgements, estimates and
assumptions); changes in applicable accounting standards; the
adequacy of NatWest Group’s resolution plans; and the
application of UK statutory stabilisation or resolution powers to
NatWest Group); climate and sustainability risk (including in
respect of: risks relating to climate change and sustainability-
related risks; both the execution and reputational risk relating to
NatWest Group’s climate change-related strategy, ambitions,
targets and transition plan; climate and sustainability-related data
and model risk; the failure to implement climate change resilient
governance, procedures, systems and controls; increasing levels
of climate, environmental, human rights and other sustainability-
related laws, regulation and oversight; climate, environmental,
human rights and other sustainability-related litigation,
enforcement proceedings, investigations and conduct risk; and
reductions in ESG ratings); operational and IT resilience risk
(including in respect of: operational risks (including reliance on
third party suppliers); cyberattacks; the accuracy and effective
use of data; attracting, retaining and developing senior
management and skilled personnel; complex IT systems; NWM
Group’s risk management framework; and NWM Group's
reputational risk); and legal, regulatory and conduct risk (including
in respect of: the impact of substantial regulation and oversight;
the outcome of legal, regulatory and governmental actions and
investigations as well as remedial undertakings; and changes in
tax legislation or failure to generate future taxable profits).
Forward looking statements continued
NWM Group
Annual Report and Accounts 2023
188
Climate and sustainability-related disclosures
Climate and sustainability-related disclosures in this document are
not measures within the scope of International Financial Reporting
Standards (‘IFRS’), use a greater number and level of judgements,
assumptions and estimates, including with respect to the
classification of climate and sustainable funding and financing
activities, than our reporting of historical financial information in
accordance with IFRS. These judgements, assumptions and
estimates are highly likely to change materially over time, and,
when coupled with the longer time frames used in these
disclosures, make any assessment of materiality inherently
uncertain. In addition, our climate risk analysis, net zero strategy,
including the implementation of our climate transition plan, remain
under development, and the data underlying our analysis and
strategy remain subject to evolution over time. The process we
have adopted to define, gather and report data on our
performance on climate and sustainability-related measures is not
subject to the formal processes adopted for financial reporting in
accordance with IFRS and there are currently limited industry
standards or globally recognised established practices for
measuring and defining climate and sustainability-related metrics.
As a result, we expect that certain climate and sustainability-
related disclosures made in this document are likely to be
amended, updated, recalculated or restated in the future.
Refer
to the cautionary statement in the section entitled ‘Climate-
related and other forward-looking statements and metrics’ of the
NatWest Group 2023 Climate-related Disclosures Report
published by NatWest Group plc for the consolidated group,
including NatWest Markets Plc.
Cautionary statement regarding Non-IFRS financial
measures and APMs
RBS\Finance\0000012\Secret
NWM Group prepares its financial statements in accordance with
generally accepted accounting principles (GAAP). This document
may contain financial measures and ratios not specifically defined
under GAAP or IFRS (‘Non-IFRS’) and/or alternative performance
measures (‘APMs’) as defined in European Securities and Markets
Authority (‘ESMA’) guidelines. Non-IFRS measures and APMs are
adjusted for notable and other defined items which management
believes are not representative of the underlying performance of
the business and which distort period-on-period comparison. Non-
IFRS measures provide users of the financial statements with a
consistent basis for comparing business performance between
financial periods and information on elements of performance that
are one-off in nature. Any Non-IFRS measures and/or APMs
included in this document, are not measures within the scope of
IFRS, are based on a number of assumptions that are subject to
uncertainties and change, and are not a substitute for IFRS
measures.
The information, statements and opinions contained in this
document do not constitute a public offer under any applicable
legislation or an offer to sell or a solicitation of an offer to buy any
securities or financial instruments or any advice or
recommendation with respect to such securities or other financial
instruments.