CRR Case Summaries and Entity-specific Press Notices
The FRC publishes, on a quarterly basis, summaries of its findings from recently closed reviews that resulted in a substantive question to a company (‘Case Summaries’). In addition, it publishes the names of companies whose reviews were closed in the previous quarter without the need for a substantive question. No Case Summary is prepared for such reviews.
Case Summaries, which are available for cases closed in the quarter ending March 2021 onwards, are included in the table below. As, currently, the FRC is subject to existing legal restrictions on disclosing confidential information received from a company, the Case Summaries can only be disclosed with the company's consent. Where consent has been withheld by the company, that fact is disclosed in the table.
From March 2018 until March 2021, the FRC published the names of companies whose reviews were closed in the previous quarter but did not prepare Case Summaries. However, on an exceptional basis, specific cases may be publicised through entity-specific Press Notices, which can also be found in the table below.
The FRC’s reviews are based solely on the company’s annual report and accounts (or interim reports) and do not benefit from detailed knowledge of the company’s business or an understanding of the underlying transactions entered into. They are, however, conducted by staff of the FRC who have an understanding of the relevant legal and accounting framework. The FRC’s correspondence with the company provides no assurance that the annual report and accounts (or interim reports) are correct in all material respects; the FRC’s role is not to verify the information provided but to consider compliance with reporting requirements. The FRC’s correspondence is written on the basis that the FRC (which includes the FRC’s officers, employees and agents) accepts no liability for reliance on its letters or Case Summaries by the company or any third party, including but not limited to investors and shareholders.
Key
- Only a certain number of CRR’s reviews result in substantive questioning of the Board. Matters raised may cover questions of recognition, measurement and/or disclosure.
- CRR’s routine reviews of companies’ annual reports and accounts generally cover all parts over which the FRC has statutory powers (that is, strategic reports, directors’ reports and financial statements). Similarly, CRR’s routine reviews of companies’ interim reports will generally cover all information in that document. Limited scope reviews arise for a number of reasons, including those conducted when a company’s annual report and accounts or interim report are selected for thematic review or reviews that have been prompted by a complaint. In accordance with the FRC's Operating Procedures, for Corporate Reporting Review, CRR does not identify those companies whose reviews were prompted by a complaint.
- The FRC may ask a company to refer to its exchanges with CRR when the company makes a change to a significant aspect of its annual report and accounts or interim report in response to a review.
- Case closed after 1 January 2021 but performed under operating procedures that did not allow for the publication of Case Summaries.
- From the quarter ended June 2023, the FRC started identifying the auditor of the annual report and accounts, or the audit firm that issued a review report on the interim report, that was the subject of the CRR review. This information was also back-dated for closed cases publicised from the quarter ended September 2022. Cases marked N/A relate to those published prior to September 2022 or interim reviews that did not have a review opinion.’
Case Summaries
CRR Case Summaries and Entity-specific Press Notices (Excel version)
Entity | QinetiQ Group plc (3) |
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Balance Sheet Date | 31 March 2022 |
Exchange of Substantive Letters (1) | Yes |
Scope of Review (2) | Full |
Quarter Published | June 2023 |
Auditor (5) | PricewaterhouseCoopers LLP |
Case Summary / Press Notice |
We asked the company to explain its basis for accounting for Research & Development Expenditure Credits (RDECs) under IAS 12 ‘Income Taxes’, as opposed to IAS 20 ‘Government Grants’, which is the more common treatment. The company explained the factors it considered to support its application of IAS 12 to the credits. However, we highlighted other factors that might indicate that IAS 20 is the more appropriate standard. As a result of this, the company reconsidered its approach and agreed to change its accounting policy to apply IAS 20 instead of IAS 12. As this change in accounting policy affected the primary statements, we asked the company to disclose that the matter had come to its attention as a result of our enquiry. We also questioned the appropriateness of the presentation of a proportion of the RDECs on a net basis. These related to contracts with the Ministry of Defence (‘MoD’) and were to be passed through to the MoD following receipt and approval by the Single Source Regulations Office (‘SSRO’). However, as this matter will no longer be relevant following a decision by the SSRO that the MoD had no valid claim to the credits, we did not consider it proportionate to pursue the matter further. |
Entity | Clarkson PLC (3) |
Balance Sheet Date | 31 December 2021 |
Exchange of Substantive Letters (1) | Yes |
Scope of Review (2) | Full |
Quarter Published | March 2023 |
Auditor (5) | PricewaterhouseCoopers LLP |
Case Summary / Press Notice |
Transactions in company shares relating to employee incentives in the statement of cash flows The consolidated cash flow statement presented a cash outflow within financing activities in relation to the company’s acquisition of its own shares. The notes to the financial statements indicated that this outflow, and the movements in bonus accruals (presented within operating activities in the statement of cash flows), were presented net of an amount relating to the settlement of employee incentives using the company’s shares. We asked the company to explain the rationale for the adjustments that resulted in the net presentation of each item. As a result of our enquiry, the company reconsidered its approach and agreed to restate the comparative cash flows in its next annual report and accounts to present the total amount paid for its shares within financing activities and to make a corresponding adjustment to movements in bonus accruals within operating activities. As the restatement affected a primary statement, we asked the company to disclose the fact that the matter had come to its attention as result of our enquiry. |
Entity | Dignity plc (3) |
Balance Sheet Date | 31 December 2021 |
Exchange of Substantive Letters (1) | Yes |
Scope of Review (2) | Full |
Quarter Published | March 2023 |
Auditor (5) | Ernst & Young LLP |
Case Summary / Press Notice |
Impairment testing and related disclosures We asked the company for further information about how impairment testing was performed, including how cash-generating units (CGUs) were identified and the funeral market share assumptions applied in testing. The company explained that, in addition to its goodwill impairment test, other non-current assets were assessed for impairment at a cost centre level, using CGUs which consist of a local network of funeral branches. The company agreed to enhance its description of these matters in future accounts to meet the requirements of IAS 36, ‘Impairment of Assets’, paragraph 130(d)(i). The company provided the market share assumptions used and agreed to disclose these values in future accounts, as well as an explanation of how these assumptions differ from past experience or external information, as required by IAS 36, paragraphs 134(d)(ii) and (f)(ii). Impairment of financial assets We asked the company to explain its rationale for not presenting apparently material impairment losses in relation to financial assets on the face of the consolidated income statement as required by paragraph 82(ba) of IAS 1, ‘Presentation of Financial Statements’. The company agreed to present this charge on the face of the income statement in future financial statements to the extent material and agreed to restate the 2021 comparatives to the 2022 income statement accordingly. As the restatement affected a primary statement, we asked the company to disclose the fact that the matter had come to its attention as a result of our enquiry. |
Entity | EVRAZ plc (3) |
Balance Sheet Date | 31 December 2021 |
Exchange of Substantive Letters (1) | Yes |
Scope of Review (2) | Full |
Quarter Published | March 2023 |
Auditor (5) | Ernst & Young LLP |
Case Summary / Press Notice |
Dividends We asked the company for further information about its basis for recognising a liability for interim dividends paid after the year end. In such cases, an obligation does not normally exist prior to payment unless the directors have taken steps to establish a legally binding liability at an earlier date. The company confirmed that no such obligation existed and agreed to revise its accounting policy in the 2022 financial statements with a restatement of the 2021 comparatives in the Statement of Financial Position. As the restatement affected a primary statement, we asked the company to disclose the fact that the matter had come to its attention as a result of our enquiry. We also asked the company for clarification of the current position in respect of certain dividends paid in breach of the procedural requirements of the Companies Act 2006. The company’s 2021 financial statements disclosed the expected steps intended to rectify the position. However, the company did not propose a special resolution at the Annual General Meeting in June 2022, as described in the disclosures. The company provided a satisfactory response in respect of its current intentions. |
Entity | Hotel Chocolat Group Plc (3) |
Balance Sheet Date | 27 June 2021 |
Exchange of Substantive Letters (1) | Yes |
Scope of Review (2) | Full |
Quarter Published | March 2023 |
Auditor (5) | N/A |
Case Summary / Press Notice | Consent withheld |
Entity | Just Group plc (3) |
Balance Sheet Date | 31 December 2021 |
Exchange of Substantive Letters (1) | Yes |
Scope of Review (2) | Limited |
Quarter Published | March 2023 |
Auditor (5) | PricewaterhouseCoopers LLP |
Case Summary / Press Notice |
Loss attributable to ordinary equity holders used for earnings per share (‘EPS’) We asked the company to explain the basis on which it had concluded that the loss recognised on redemption of the company’s equity classified Tier 1 notes should not be deducted when calculating the loss attributable to ordinary equity holders used in the calculation of EPS, as they appeared to have similar characteristics to preference shares classified as equity. Following our correspondence, the company reconsidered its treatment of the Tier 1 notes and concluded that the requirements in IAS 33 regarding equity preference shares should have been applied to them. It agreed to restate the comparative amounts for EPS in the consolidated statement of comprehensive income in its 2022 annual report and accounts, and also proposed to disclose the judgement required in determining the treatment of the Tier 1 notes in the EPS calculation. As the restatement affected a primary statement, we asked the company to disclose the fact that the matter had come to its attention as a result of our enquiry. |
Entity | Langley Holdings plc (3) |
Balance Sheet Date | 31 December 2021 |
Exchange of Substantive Letters (1) | Yes |
Scope of Review (2) | Limited |
Quarter Published | March 2023 |
Auditor (5) | Saffery Champness LLP |
Case Summary / Press Notice | Consent withheld |
Entity | Petrofac Limited (3) |
Balance Sheet Date | 31 December 2021 |
Exchange of Substantive Letters (1) | Yes |
Scope of Review (2) | Full |
Quarter Published | March 2023 |
Auditor (5) | Ernst & Young LLP |
Case Summary / Press Notice |
Classification of cash flows in relation to restricted cash, amounts owed to and from group entities and related derivatives We requested an explanation of the basis for presenting working capital adjustments relating to other net current financial assets within operating activities in the consolidated statement of cash flows, as well as a breakdown of these adjustments. The company provided the information and indicated in its analysis that the adjustments comprised cash flows in relation to restricted cash and derivatives. It agreed to include an explanation for this treatment of restricted cash in its next annual report and accounts. We requested similar information in respect of the parent company’s statement of cash flows for the classification within operating activities of working capital adjustments relating to other financial assets and liabilities, and cash flow movements in amounts due to and from group entities and related derivatives. In its response the company reconsidered its approach and agreed to restate the comparative cash flows in its next annual report and accounts to present movements in restricted cash (the principal component of the other financial assets and liabilities line) within investing activities and the cash flows in relation to amounts due to and from group entities within financing and investing activities, respectively. It also agreed to restate the related derivative cash flows on the same basis. Classification of cash receipts from subleases During our correspondence, we also questioned the basis for classifying cash receipts from subleases to joint operation partners within financing activities in the consolidated statement of cash flows. As a result of our enquiry, the company concluded that sublease receipts should be presented within investing activities and agreed to restate the comparative consolidated statement of cash flows and make consequential changes to its comparative consolidated income statement to present the lease finance income and expense on a gross basis, in its next annual report and accounts. In addition, the company agreed to enhance its IFRS 16 ‘Leases’ disclosures in relation to the subleases to joint operation partners. As these restatements affected the primary statements, we asked the company to disclose the fact that the matters had come to its attention as result of our enquiry. |
Entity | Rathbones Group Plc (3) |
Balance Sheet Date | 31 December 2021 |
Exchange of Substantive Letters (1) | Yes |
Scope of Review (2) | Full |
Quarter Published | March 2023 |
Auditor (5) | Deloitte LLP |
Case Summary / Press Notice |
Statement of cash flows We asked the company for further information about how the repayment of debt following the acquisition of Saunderson House was treated in the consolidated statement of cash flows. The company clarified that the repayment was made to a third party and explained that following further discussions, it had concluded that it would be more appropriate to classify the third-party debt repayment as a financing outflow in the consolidated statement of cash flows. The company agreed to restate the comparative period of the consolidated statement of cash flows in its 2022 Annual Report and Accounts. As the change affected a primary statement, we asked the company to disclose the fact that the matter had come to its attention as a result of our enquiry. We asked the company for further information about amounts reported in the consolidated statement of cash flows for the repurchase and issue of ordinary shares, and the purchase and sale of investment securities. The company provided a satisfactory answer to our questions and gave an undertaking to provide enhanced note disclosures in its 2022 Annual Report and Accounts. Share-based payments We asked the company for further information about the amounts presented in the primary financial statements for share-based payments. The company provided a satisfactory answer to our questions and gave an undertaking to provide enhanced disclosures in its 2022 Annual Report and Accounts by providing further disaggregation of amounts presented in the consolidated statement of changes in equity relating to share-based payments. |
Entity | Tyman Plc (3) |
Balance Sheet Date | 31 December 2021 |
Exchange of Substantive Letters (1) | Yes |
Scope of Review (2) | Full |
Quarter Published | March 2023 |
Auditor (5) | PricewaterhouseCoopers LLP |
Case Summary / Press Notice |
Offsetting of deferred tax balances We asked for further information about the company’s application of paragraph 74 of IAS 12 ‘Income Taxes’ to its deferred tax asset and liability balances, which were presented on a gross basis in the accounts. The company concluded that certain asset and liability balances arose in the same tax jurisdiction and met the criteria for offsetting under IAS 12. The company agreed to restate the 31 December 2021 comparatives in its 2022 accounts, offsetting these balances. Offsetting of bank overdraft The company presented its cash at bank and bank overdraft balances on a net basis in the accounts on the basis of its cash pooling arrangements giving a legal right of offset. We asked for further information about the application of paragraph 42(b) of IAS 32 ‘Financial Instruments: Presentation’, in conjunction with the IFRS Interpretation Committee’s March 2016 decision regarding cash-pooling arrangements. Following a review of their cash pooling arrangements, the company concluded that, although there is a legal right of offset, as they did not settle the entire period-end balance subsequent to the year-end and had further transactions before the next net settlement date, the second criterion of IAS 32 paragraph 42 was not met. The company agreed to restate the 31 December 2021 comparatives in its 2022 accounts, presenting the balances on a gross basis. As both of the above restatements related to a primary statement, we asked the company to disclose that the matters had come to its attention as a result of our enquiry. Research and development expenditure We asked for further information about the company’s development costs and the associated accounting policy. The company provided further context for its development activities and explained its policy in more detail. It agreed to make some clarifications to its policy in its 2022 accounts, and to disclose the total R&D costs expensed to the income statement in accordance with IAS 38 ‘Intangible Assets’. |
Entity | ScS Group plc (3) |
Balance Sheet Date | 31 July 2021 |
Exchange of Substantive Letters (1) | Yes |
Scope of Review (2) | Full |
Quarter Published | December 2022 |
Auditor (5) | N/A |
Case Summary / Press Notice |
Product warranty sales We questioned the basis for recognising revenue from the sale of product warranties as principal. As a result of our enquiry, the company reconsidered the principal versus agent requirements in IFRS 15 ‘Revenue from Contracts with Customers’ and reviewed the accounting treatment adopted by its peers. The company concluded that it did not control product warranties before transferring them to the customer and that revenue related to the sale of these warranties should have been recognised as agent rather than as principal. Consequently, the company agreed to restate the comparative amounts in the following year’s income statement. As the change affected a primary statement, we asked the company to disclose the fact that the matter had come to its attention as result of our enquiry. The company also agreed to make certain improvements to its accounting policy for product warranty sales and enhance certain other revenue-related disclosures. Product guarantees We asked the company to explain the accounting treatment of its 12-month and 20-year product guarantees. The company satisfactorily responded to our query. |
Entity | YouGov plc (3) |
Balance Sheet Date | 31 July 2021 |
Exchange of Substantive Letters (1) | Yes |
Scope of Review (2) | Full |
Quarter Published | December 2022 |
Auditor (5) | N/A |
Case Summary / Press Notice |
Capitalisation of panel acquisition costs The company recognises intangible assets relating to its consumer panels, which comprise some of the costs of recruiting new members to the panel. We requested further information from the company to help us understand the basis for the conclusion that these costs meet the criteria for capitalisation, which it disclosed as a critical judgement. We enquired specifically about the unit of account applied to panel assets and how this links to the way in which the panel assets are utilised and managed. We also asked the company to explain how the requirements of IAS 38, ‘Intangible Assets’, had been considered when developing its accounting policy. The company explained that each monthly cohort of panellists in an individual country is recognised as a separate asset. The company explained the basis for capitalising panel acquisition costs and the rationale for using the unit of account chosen. The company agreed to enhance the critical judgement disclosure in its 2022 annual report and accounts. Statement of cash flows We asked the company to confirm whether the cash flow for ‘settlement of deferred consideration’ related to consideration which was contingent upon the future employment of the former owners of acquired businesses. The company confirmed it was and acknowledged that the resulting cash flow should have been classified as an operating rather than investing cash flow. We requested an explanation of the calculation of cash flow amounts for both ‘purchase of intangible assets’ and ‘acquisition of subsidiaries’ as it appeared some cash flows were included within both. The company confirmed that it had double-counted some amounts by including them in both cash flows and also identified several other offsetting errors made in the presentation of the cash flow statement. The company agreed to restate the comparatives in its next annual report and accounts for each of the above changes. As all of these affected a primary statement, we asked the company to disclose the fact that the matters had come to its attention as a result of our enquiry. We also asked the company to explain the rationale for classifying some intercompany cash flows in the parent company cash flow statement. The company acknowledged that it would have been more appropriate to reclassify some of the amounts but noted that it intended to adopt FRS 101, ‘Reduced Disclosure Framework’, and take the exemption from presenting a parent company statement of cash flows in its future reporting. We closed our enquiries on this basis. Deferred tax assets for share options We requested more information on how the tax impact of share options, both current and deferred, has been accounted for and whether the reductions in deferred tax assets related to the exercise of share options. IAS 12, ‘Income Taxes’, requires tax deductions in excess of the cumulative remuneration expense for share-based payments to be recognised directly in equity. The company confirmed that it had correctly accounted for the split in deferred tax between the income statement and equity. However, on the exercise of the share options all current tax, and the reversal of previously accumulated deferred tax, had been included incorrectly within the income statement, despite the total tax deductions being in excess of the cumulative remuneration expense for the associated share-based payments. Following our enquiry, the company also identified additional adjustments to the presentation of deferred tax assets and liabilities. The company agreed to restate the comparatives in its next annual report and accounts for each of the above changes. As all of these affected a primary statement, we asked the company to disclose the fact that the matters had come to its attention as a result of our enquiry. Other deferred tax assets We also asked the company to explain the extent to which the change in the future UK corporation tax rate had been recognised in the carrying amount of deferred tax assets and the reasons for a reclassification of deferred tax assets. The company explained how it had considered the impact of the rate change. It also confirmed that several of the items included within the reclassification should not have been described as such. The company agreed to correct this in future annual reports and accounts, noting that it did not consider the amounts to be material. |
Entity | Carnival plc (3) |
Balance Sheet Date | 30 November 2020 |
Exchange of Substantive Letters (1) | Yes |
Scope of Review (2) | Full |
Quarter Published | September 2022 |
Auditor (5) | N/A |
Case Summary / Press Notice |
Our enquiries related to the Strategic Report and IFRS financial statements of Carnival plc for the year ended 30 November 2020. The combined US GAAP financial statements of Carnival Corporation and plc for that year, mentioned below, were not within the scope of our inquiries. The disclosure of the possible effects of climate change on the Company’s business
The company explained that it had subsequently enhanced its disclosures in the above respects in its Strategic Report and IFRS financial statements for the year ended 30 November 2021. The company undertook to include in its future Strategic Reports a summary of the impact of the business on the environment and disclosure of appropriately balanced information regarding the usage of LNG, reflecting the different views as to the impact of LNG on the environment relative to other fossil fuels. The company also agreed to continue to monitor environmental developments and to update its disclosure of the potential effect of climate change on significant judgements and estimates, including in relation to impairment and useful lives of ships, as the company’s understanding of the actual and potential impacts develops and changes in the related assumptions are made. We also asked the company to consider clearer signposting in the various documents that form its annual report to the individual disclosures required under subsections 414CB(2)(a) to (e) and subsections 172(1)(a) to (f) of the Act (as required under section 414CZA). The company included clearer signposting to these disclosures in its 2021 Strategic Report. Alternative performance measures (‘APMs’) We asked the company to consider how it might improve the presentation of financial information in the Strategic Report (which is based on the US GAAP results of Carnival Corporation and plc rather than the IFRS results of Carnival plc) to align with the European Securities and Markets Authority (‘ESMA’) ‘Guidelines on Alternative Performance Measures’ as regards prominence compared with, and reconciliations to, the IFRS financial statement figures. We also asked the company to reconsider the granularity of the related reconciliation provided in the segment reporting note in line with paragraph 28 of IFRS 8, ‘Operating Segments’. The company committed to present key IFRS measures for Carnival plc in its 2022 and future Strategic Reports. It also provided a more granular reconciliation between the combined group US GAAP and plc IFRS results in the segment reporting note for the year ended 30 November 2021. We encouraged the company to include a cross-reference to this reconciliation from the Strategic Report. Cash flow statements We asked for more information on the gross cash payments to, and receipts from, other group entities reported as net amounts in the group cash flow statement. The company satisfactorily explained the presentation of cash flows on a net basis in relation to amounts owed to other group entities. We also questioned the classification of cash flows in relation to loans to other group entities as financing activities in the parent company cash flow statement, rather than investing activities under paragraphs 6 and 16(e) of IAS 7 ‘Statement of Cash Flows’. The company identified that certain cash flows in relation to loans to other group entities had been incorrectly presented as financing activities in the years ended 30 November 2020 and 2021 and stated that it would restate the comparative parent company statement of cash flows for the year ended 30 November 2021 included in the 2022 financial statements to present these cash flows within investing activities. As the matter related to a primary statement, we asked the company to disclose that the matter had come to its attention as a result of our enquiry. Accounting for foreign exchange We requested further information on the foreign exchange accounting policy applied by the parent company in its individual financial statements. The company explained its foreign exchange accounting policy in relation to the parent company’s individual financial statements and undertook to expand its policy wording in its 2022 financial statements. As a result of our enquiries the company revised its net investment hedging accounting treatment and the translation of investments in subsidiaries, and recognised immaterial adjustments in its 2021 parent company financial statements to amend its previous accounting treatment in these respects. Accounting for dry-docking costs We asked the company to clarify its accounting policy in relation to dry-docking costs in the light of the requirements of paragraph 14 of IAS 16, ‘Property, Plant and Equipment’. The company satisfactorily responded to our enquiry and revised the accounting policy wording for dry-docking costs in its IFRS financial statements for the year ended 30 November 2021. |
Entity | Chill Brands Group plc (3) |
Balance Sheet Date | 31 March 2021 |
Exchange of Substantive Letters (1) | Yes |
Scope of Review (2) | Full |
Quarter Published | September 2022 |
Auditor (5) | PKF Littlejohn LLP |
Case Summary / Press Notice |
Payment for the purchase of a domain name The company’s condensed consolidated statement of cash flows, in its interim results for the six months ended 30 September 2021, includes a cash outflow described as ‘Purchase of intangible assets’ of £1,195,898. We asked the company to confirm the cost of the domain name at 30 September 2021 and explain how this was determined. It explained that the cost of the domain name was £1,195,898 and that this amount is specified in the purchase agreement. We also asked how the cash outflow for the purchase of the domain name, presented in the 2021 interim results, relates to the statement in the company’s RNS of 26 April 2022, about its £3.5 million fundraising. This noted that one of the uses of the funds will be settlement of the outstanding balance owed in respect of purchasing the domain name. The company acknowledged that the cash flow statement should only have included the amount actually paid during the period to 30 September 2021. The company confirmed that it will:
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Entity | FirstGroup plc (3) |
Balance Sheet Date | 31 March 2021 |
Exchange of Substantive Letters (1) | Yes |
Scope of Review (2) | Full |
Quarter Published | September 2022 |
Auditor (5) | N/A |
Case Summary / Press Notice |
Transfers between property, plant, and equipment and right of use assets We asked the company for additional information about transfers between property, plant, and equipment (PPE) and right of use assets including factors considered in concluding that transfers met the criteria to be considered sales, any judgements involved, and the treatment of related cash flows. The company explained that they had reassessed the accounting treatment adopted for certain transactions accounted for as sale and leasebacks, and had concluded these should have been treated as financing transactions. The company told us that the proceeds from these transactions had been incorrectly netted off purchases of PPE in the cash flow statement, and that these cash flows should have been classified as financing activities. The company also explained that cash flows relating to certain lease buy outs had been incorrectly reported within purchases of PPE rather than as repayments of lease liabilities. The company agreed to restate the comparative amounts in the consolidated cash flow statement to correct these items in its 2022 annual report and accounts, in addition to making certain reclassifications in the notes to the accounts. As the restatement affects a primary statement, the company also agreed to disclose in its 2022 report and accounts that the matter came to its attention as a result of the Financial Reporting Council’s enquiry. |