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 | Alpha Growth Plc (3) |
|---|---|
| Balance Sheet Date | 31 December 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | December 2024 |
| Auditor (5) | PKF Littlejohn LLP |
| Case Summary / Press Notice |
Consolidation of insurance subsidiaries We asked the company for further information about how the assets and liabilities of insurance subsidiaries had been presented in the consolidated financial statements, and the basis for presenting all assets and liabilities of insurance subsidiaries within a single asset and single liability line item in the consolidated statement of financial position, as this appeared to aggregate items which were not similar in nature. We also questioned why the cash and cash equivalents balances held by insurance subsidiaries were not reflected in the consolidated statement of cash flows. The company explained that the financial assets held by the insurance subsidiaries are held solely to back the associated liabilities and that the presentation was adopted to clearly identify this. However, after further consideration the company agreed to restate the consolidated statement of financial position by providing appropriate disaggregation of the assets and liabilities of the insurance subsidiaries. The company also agreed to restate the consolidated statement of cash flows to include cash and cash equivalents held by insurance subsidiaries. Revenue of Alpha International Life Assurance Company (AILAC) We asked the company for further information about the terms of the acquisition of Alpha International Life Assurance Company (AILAC), and in particular the point at which income in relation to AILAC was recognised. The company explained that control of AILAC was achieved upon receiving regulatory approval in November 2022, but also noted that a fee was charged for management and advisory services performed from August 2022. Segmental reporting We asked the company for an explanation of the basis on which they concluded that the company has a single operating segment. The company provided a satisfactory explanation; however, we noted that this matter should be kept under review as the company grows. Future impact of IFRS 17, ‘Insurance Contracts’ We questioned the company’s assertion that IFRS 17 would not have a material impact on the group, given the nature of the company’s business, and asked for further information about the nature of the contracts issued by the insurance subsidiaries. The company explained that the majority of the contracts issued by the insurance subsidiaries do not contain significant insurance risk but that it was assessing the impact of IFRS 17 on those contracts that do contain significant insurance risk. Recoverability of Interval Fund Expenses We asked the company for further information about the recoverability of the interval fund expenses recognised as a receivable by the company. The company provided a satisfactory explanation. TCFD disclosures We noted the limited TCFD reporting and asked the company to explain what additional or improved disclosures it expected to make in its next annual report and accounts. The company agreed to consider our thematic reviews and expand the TCFD disclosures in the next annual report and accounts. Earnings per share We questioned the calculation of diluted earnings per share, as options and warrants were shown to be dilutive, despite having a weighted average exercise price which appeared to be above the average market price of ordinary shares in the period. The company agreed to restate the calculation of diluted earnings per share in the next annual report and accounts. Other disclosures We asked the company to enhance its disclosures in relation to (i) key performance indicators (KPIs) in the strategic report, (ii) the management of capital, (iii) fair value of financial instruments, and (iv) liquidity risk. The company agreed to make a number of disclosure enhancements in its next annual report and accounts in these areas. |
| Entity | Global Ports Holding PLC |
| Balance Sheet Date | 31 March 2023 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | June 2024 |
| Auditor (5) | PKF Littlejohn LLP |
| Case Summary / Press Notice |
Warrants over ordinary shares We asked the company to explain the accounting treatment applied to certain warrants which were issued in connection with a financing agreement. The company explained the accounting policy applied to the warrants, noted that the equity element was immaterial, and confirmed that they had since been settled. Task Force on Climate-related Financial Disclosures (‘TCFD’) We questioned why TCFD-aligned disclosures had not been presented. The company undertook to present a statement of consistency with TCFD aligned disclosures in their 2024 annual report and accounts. Accounting for Global Ports Canary Islands S.L. We sought clarification of the basis on which the group’s investment in Global Ports Canary Islands S.L. was included in the consolidated financial statements. The company clarified that Global Ports Canary Islands S.L. is a subsidiary and is consolidated within the group’s accounts. Cash flow statement We asked the company to explain the way in which amounts included in the cash flow statement in respect of related party receivables, related party payables, proceeds from loans and borrowings, and repayment of borrowings, reconcile to corresponding amounts reported elsewhere in the annual report and accounts. The company provided a satisfactory reconciliation. Parent company investments We asked the company to explain how the Directors had satisfied themselves that there was no impairment to recognise in respect of the parent company’s investments in subsidiary undertakings. The company provided a satisfactory response. |
| Entity | Goodwin PLC |
| Balance Sheet Date | 30 April 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | March 2024 |
| Auditor (5) | RSM UK Audit LLP |
| Case Summary / Press Notice |
Climate-related financial disclosures We asked the company to explain the extent to which consideration of climate-related matters affected the recognition, measurement and disclosure of items in the financial statements. The company noted that it had not performed a full assessment at the time of completing the 2022 annual report and accounts. It agreed to disclose any climate-related matters which are identified as affecting the recognition and measurement of items in future financial statements. We also noted that the strategic report’s climate-related disclosures did not appear to meet the Listing Rules requirements or be consistent with the Task Force on Climate-related Financial Disclosures (TCFD) recommendations in several areas. We encouraged the company to review the findings of the FRC’s ‘CRR Thematic review of TCFD disclosures and climate in the financial statements’ and the FCA’s ‘Review of TCFD-aligned disclosures by premium listed commercial companies’. We performed a limited scope review of the company’s climate-related financial disclosures in its 2023 annual report, and were pleased to see improved disclosures. We made a number of observations, intended to promote further improvement of its disclosures in future reports. Revenue recognition We sought further information about contract modifications and claims. The company confirmed the nature of movements in the period, and agreed both to clarify its accounting policy disclosure for performance obligations satisfied over time in respect of engineered bespoke products, and to disclose, when material, additional information that helps users understand the potential upward and downward changes in revenue. We also asked the company to clarify the extent of estimation uncertainty and significant judgement affecting its recognition of revenue and contract balances. Having considered the company’s response, we observed that the disclosures could be enhanced by the inclusion of quantitative information, where material, and the omission or segregation of non-critical judgements and estimates. Corporate governance reporting As part of the FRC’s non-statutory monitoring of reporting against the 2018 UK Corporate Governance Code, we invited the company to comment on our observations on its corporate governance report. It provided an explanation of its approach to these matters, noting that information elsewhere in the annual report was intended to communicate, for example, the company’s purpose, its engagement with shareholders and employees, and its alignment of directors’ interests with those of shareholders as a whole. The company also identified improvements to be made in its future reporting, which we welcomed |
| Entity | London Stock Exchange Group plc |
| Balance Sheet Date | 31 December 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | March 2024 |
| Auditor (5) | Ernst & Young LLP |
| Case Summary / Press Notice |
Alternative Performance Measures (‘APMs’) We made a number of observations about the presentation of certain APMs and asked how the directors intended to address these matters in the 2023 annual report and accounts. The company satisfactorily explained the improvements it will make to its disclosure of APMs in future annual reports and accounts. These improvements include giving, where possible, equivalent IFRS amounts for the financial highlights, an enhanced explanation about the limitations of the company’s APMs and appropriate cross-referencing. Climate-related financial disclosures We made a number of observations about the climate-related financial disclosures and asked how the directors intended to reflect them in the 2023 disclosures and TCFD statement of compliance. The company satisfactorily explained the changes it will make to enhance its climate-related financial disclosures in future annual reports and accounts. These enhancements include more streamlined reporting, providing clearer descriptions relating to the Recommended Disclosures under the Strategy Recommendation, commentary for material movements in Scope 3 emissions and a more detailed definition of the term ‘net zero’. |
| Entity | Macfarlane Group PLC |
| Balance Sheet Date | 31 December 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | March 2024 |
| Auditor (5) | Deloitte LLP |
| Case Summary / Press Notice |
We noted that the company’s annual report did not include a clear statement setting out whether the report included climate‐related financial disclosures consistent with the recommendations and recommended disclosures of the Taskforce for Climate-related Financial Disclosures (TCFD), as required by the Listing Rules. We also noted that the report did not include all the disclosures required in circumstances where a listed company’s report is not consistent with all of the TCFD recommendations and recommended disclosures. We closed our enquiries after the company agreed to provide a clearer TCFD compliance statement in its future reports, and to enhance its disclosures about any TCFD recommendations and recommended disclosures not included in such reports. |
| Entity | Mast Energy Developments PLC |
| Balance Sheet Date | 31 December 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Limited |
| Quarter Published | March 2024 |
| Auditor (5) | Crowe U.K. LLP |
| Case Summary / Press Notice |
This company was selected as part of our thematic review of TCFD disclosures of metrics and targets and, as such, only disclosures relevant to this area were reviewed. Statement of consistency with the TCFD Recommendations and Recommended Disclosures The company’s annual report did not include an explanation of the extent of the report’s consistency with the TCFD recommendations and recommended disclosures. We asked the company to confirm that such a statement would be included in future annual reports. The company agreed to provide a clear statement of the extent of consistency with the TCFD recommendations and recommended disclosures in its next annual report. This would include, if necessary, the identification of any information not included, an explanation of why it was not included, any steps taken or plans made in order to make those disclosures in the future, and the timeframe within which it expects to be able to do so. |
| Entity | Northern Electric plc |
| Balance Sheet Date | 31 December 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Limited |
| Quarter Published | March 2024 |
| Auditor (5) | Deloitte LLP |
| Case Summary / Press Notice |
This company was selected as part of our thematic review of TCFD disclosures of metrics and targets and, as such, only disclosures relevant to these areas were reviewed. Statement of consistency with the TCFD Recommendations and Recommended Disclosures We were unable to find two documents referred to in the company’s TCFD disclosures on the Group website, or an explanation, as required by the Listing Rules, as to why disclosures had been provided outside the annual report. Based on the available information, it was unclear which disclosures were considered sufficient to comply with the four TCFD recommendations and 11 recommended disclosures. The company acknowledged that one document had not been uploaded to the specified website, and that another was not in an easily navigable location. The company agreed to provide a clear statement of consistency with the TCFD recommendations and recommended disclosures, including precise references to the relevant disclosures, in future annual reports and accounts; and to disclose the reasons for not including various disclosures in the annual report, where necessary. |
| Entity | Pinewood Technologies Group PLC (formerly Pendragon PLC) |
| Balance Sheet Date | 31 December 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | March 2024 |
| Auditor (5) | KPMG LLP |
| Case Summary / Press Notice |
Parent company’s investment in subsidiaries We asked the company to clarify its approach to assessing the recoverable amount of its directly-held subsidiaries, with particular reference to amounts excluded from cash flow forecasting for cash generating units (CGUs) and adjustments overlaid on value-in-use estimates, and an apparent inconsistency relating to the extent of estimation uncertainty involved. Having received a satisfactory response to our enquiries, we encouraged the company to enhance its explanation of the methodology applied, where that differs from the assessment of CGUs for the consolidated accounts. The company also agreed to ensure that the key estimates disclosure relating to assets and liabilities in the parent company’s balance sheet in the 2023 annual report and accounts is reflective of any significant risk at 31 December 2023. Environmental report We invited the company to comment on our observations on aspects of its compliance with the Taskforce for Climate-related Financial Disclosures (TCFD) recommendations, as required by the Listing Rules, principally in respect of climate-related effects on strategy and relevant metrics and targets. The company agreed to enhance its TCFD disclosures by including in its 2023 annual report and accounts: an analysis of the key risks over defined short-, medium- and long-term horizons; risks, impacts and mitigations that are specific to its circumstances; further detail linking metrics to material risks and opportunities; clarification of the nature of metrics used to form views on likely trends in demand; and further details of carbon reduction targets, with the related timeline |
| Entity | W.A.G Payment Solutions plc |
| Balance Sheet Date | 31 December 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | March 2024 |
| Auditor (5) | PricewaterhouseCoopers LLP |
| Case Summary / Press Notice |
Revenue Recognition We asked the company to provide further information about the factors they considered in concluding that they were acting as principal in fuel sales within the Eurowag acceptance network. They company provided the information requested and agreed to enhance disclosure of the judgement involved in its 2023 Annual Report and Accounts. TCFD disclosures We asked the company to clearly explain in its future reporting the extent to which it believed its Taskforce for Climate-related Financial Disclosures (TCFD) disclosures were consistent with the requirements of the Listing Rules, and how they felt the disclosures could be improved. The company explained how it was planning to improve these disclosures in future reports. Software as a service The company had capitalised significant internal software development costs, and we questioned whether any of these costs related to ‘Software as a Service’ arrangements, and if so, how the company has accounted for any customisation or configuration costs associated with these arrangements. The company provided a satisfactory response. Factoring of receivables We asked the company how it used factoring for its own working capital management purposes and in contractual arrangements with customers. The company provided a satisfactory response to our queries and agreed to enhance disclosures in its 2023 Annual Report and Accounts and to clearly delineate factoring for working capital management from factoring services to customers. Deferred and contingent consideration We asked the company to reconcile amounts recognised on the balance sheet relating to deferred and contingent consideration on business combinations to the amounts included in the notes to the accounts, and to provide further details of the circumstances in which the contingent consideration would be payable. The company provided a satisfactory response to our queries. Ultimate controlling party We queried if the company considered Mr Vohanka, its CEO, to be its ultimate controlling party, and the factors it had considered in reaching this decision. The company clarified that it did not consider Mr Vohanka to be the ultimate controlling party and agreed to provide disclosure of this judgement, and the rationale, in its 2023 Annual Report and Accounts. |
| Entity | Genus Plc |
| Balance Sheet Date | 30 June 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2023 |
| Auditor (5) | Deloitte LLP |
| Case Summary / Press Notice |
We noted that the company’s annual report did not include a clear statement explaining whether the report included climate‐related financial disclosures consistent with the recommendations and recommended disclosures of the Taskforce for Climate-related Financial Disclosures (TCFD), as required by the Listing Rules. We also identified a number of areas where improvements could be made to the company’s TCFD disclosures. We closed our enquiries after the company confirmed that it will provide a clearer statement that fulfils the requirements of the Listing Rules in its future reports. It agreed to provide explanations about any TCFD recommendations and recommended disclosures not included in its future reports, together with relevant explanations, as required by the Listing Rules. It also agreed to make a number of improvements to the TCFD disclosures, consistent with our expectations as set out in our recent thematic review report. |
| Entity | Volution Group plc |
| Balance Sheet Date | 31 July 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2023 |
| Auditor (5) | Ernst & Young LLP |
| Case Summary / Press Notice |
Contingent consideration in a business combination We asked whether the continuing employment of selling shareholders was a condition for the payment of contingent consideration and whether the payments should have been treated as post-combination remuneration. The company satisfactorily explained that the continuing employment of selling shareholders was not a condition for the payment of contingent consideration. Significant judgements and estimates We asked for further details of the accounting judgements and estimates that are required to be disclosed by the relevant accounting standard. We noted that the precise judgement or nature of the estimation uncertainty was not always apparent. Additionally, some estimates did not appear to have a significant risk of a material adjustment to the carrying amount of assets and liabilities in the next financial year which is the threshold for reporting. The company provided the information requested and agreed to specify, in future annual reports and accounts, which judgements and estimates, if any, are required to be reported. The company also agreed to present any additional judgements and estimates separately. The comparison of avoided emissions to operational emissions Avoided emissions from the sale of heat recovery products were shown as a separate line below the “total scope 1, 2 and 3” emissions, and subtracted from that total to show a new total for “net emissions” in a data table in the strategic report. The comparison was potentially misleading because operational emissions excluded scope 3 emissions from the use of sold products. In addition, the presentation appeared to give the impression that the company’s overall emissions were negative. The company agreed to present a comparison of avoided emissions to scope 1, 2 and 3 emissions in future annual reports and accounts only when emissions from the use of sold products are included in the scope 3 emissions number. The company gave an undertaking to consider the manner in which such information is presented in future annual reports and accounts. The company also agreed to consider whether there is any impact of the exclusion of relevant categories of scope 3 emissions on the consistency of its disclosures with TCFD metrics and targets recommended disclosure (b) and, if so, to report accordingly. Methodology used and level of assurance obtained We questioned whether the company’s disclosures appropriately described the level of assurance obtained over scope 3 emissions and the methodology used in the calculation of avoided emissions. |
| Entity | Anglo American plc |
| 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 |
Significant sources of estimation uncertainty and other disclosures in relation to impairment of metallurgical coal assets. An impairment charge of $0.8bn was recognised in respect of certain metallurgical coal assets during the first half of the year ended 31 December 2021. We asked the company why the assumptions underlying this impairment review were not disclosed as a significant source of estimation uncertainty in the 2021 annual report and accounts. We also asked for information required by paragraph 130 of IAS 36 ‘Impairment of assets’, including the events and circumstances that led to the impairment and the key assumptions on which management based its determination of fair value. The company explained that the relevant disclosures in respect of significant sources of estimation uncertainty and the impairment charge were included in its June 2021 interim financial statements assets, and should have also been included in the December 2021 annual report and accounts. The company undertook to carry such disclosures forward to its annual report and accounts in future, if relevant and material. The company also satisfactorily explained its approach to reassessing key assumptions used in impairment tests carried out during the financial year at the year-end balance sheet date to determine whether they remained appropriate. Strategic report discussion of impairment We asked the company to explain how it had addressed the impairment of metallurgical coal assets in the strategic report, and how such disclosures could be enhanced. The company provided an explanation of the circumstances giving rise to the impairment, and explained that if the disclosures in the interim report had been appropriately included in the annual report, the linkage between the strategic report and the impairment charge would have been clear. It also agreed to consider the recommendations of our thematic report on TCFD and climate in the financial statements, and to provide a clear link between disclosures in the strategic report and those within the financial statements in relation to climate change in future. |
| Entity | Centrica plc |
| Balance Sheet Date | 31 December 2021 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Limited |
| Quarter Published | March 2023 |
| Auditor (5) | Deloitte LLP |
| Case Summary / Press Notice |
This company was selected as part of our thematic review of TCFD and climate and, as such, only disclosures relevant to these areas were reviewed. Relative impact and uncertainty of disclosed climate-related risks and opportunities We asked the company to clarify the relative impact of the disclosed climate-related risks and opportunities on gross margin, and also to give an indication of the level of uncertainty attached to forecasting the impact of potential opportunities.
Climate targets and ambitions We noted that the summary of the group’s climate transition plan in the annual report included a large number of targets and aspirations, but it was not clear which of these represented firm commitments incorporated into budgets, business plans and accounting assumptions, or which targets are included in the Climate Transition Dashboard used by the Centrica Leadership Team and Board to track progress on the strategic response to climate-related risks and opportunities. The company agreed to clarify both points in future annual reports. We also asked the company to report metrics for each of the targets included in the Climate Transition Dashboard in future years, comparative information for each metric, and an explanation of any significant movements, including where progress has not been as expected. The company agreed to these requests. |
| Entity | Harbour Energy plc |
| Balance Sheet Date | 31 December 2021 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Limited |
| Quarter Published | March 2023 |
| Auditor (5) | Ernst & Young LLP |
| Case Summary / Press Notice |
This company was selected as part of our thematic review of TCFD and climate and, as such, only disclosures relevant to these areas were reviewed. Statement of consistency with the TCFD Recommendations and Recommended Disclosures We noted that the company had not provided all of the recommended disclosures regarding strategy (a) and (b) which the FCA expects that companies will ordinarily be able to provide, partially on grounds of confidentiality. We noted further that the TCFD Recommendations and Listing Rules do not provide an exemption from disclosure on the grounds of confidentiality. The company acknowledged these matters, and explained the reasons for the noted deficiencies in the 2021 TCFD disclosures and the steps being taken to ensure that the 2022 annual report is consistent with FCA expectations on TCFD disclosure. We also noted that the company had not provided all of the information required by paragraph 9.8.6(8)(b)(ii) of the Listing Rules regarding disclosures not included in the 2021 annual report. The company agreed to provide these disclosures in the annual report in future. |
| Entity | Norcros plc |
| Balance Sheet Date | 31 March 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | March 2023 |
| Auditor (5) | BDO LLP |
| Case Summary / Press Notice |
Impairment reviews It was unclear whether certain matters disclosed in the company’s report (namely, climate-related risks and changes in energy prices) were considered to be indicators of potential impairment. We asked the company to explain whether this was the case and, if so, whether it had performed additional impairment calculations, as required by IAS 36. The company clarified that it had identified trading performance and higher UK energy prices as indicators of potential impairment, and explained the impairment review it had performed in respect of the affected cash-generating unit. It also explained that the impairment review and related sensitivity analysis did not identify an impairment loss. We were satisfied with the company’s response and closed our enquiries. In closing the matter, we encouraged the company to consider whether, in such circumstances, users may benefit from additional disclosures (for example, disclosures highlighting that an impairment review was performed and that it did not identify a loss, together with information about key assumptions applied and related sensitivity analyses). TCFD compliance statement We noted that the company’s annual report did not include a clear statement (‘TCFD compliance statement’) setting out whether its disclosures are consistent with the TCFD recommendations and recommended disclosures, as required by paragraph 8(a) of Listing Rule 9.8.6R. We also questioned whether the report included all the disclosures required by paragraph (8)(b)(ii) of the Listing Rule in circumstances where a listed company’s report does not include disclosures consistent with all of the TCFD recommendations and recommended disclosures (for example, steps being taken by the company to be able to provide the missing disclosures and the relevant timeframes). We closed our enquiries after the company agreed to provide a clear TCFD compliance statement in its future reports, and to enhance its disclosures about any TCFD recommendations and recommended disclosures not included in such reports. |