TIDM63AS

RNS Number : 6217Q

HSBC Bank plc

20 February 2019

HSBC Bank plc 2018 Annual Report and Accounts

In fulfilment of its obligations under section 4.1.3 and 6.3.5(1) of the Disclosure Guidance and Transparency Rules, HSBC Bank plc (the "Company") hereby releases the unedited full text of its 2018 Annual Report and Accounts for the year ended 31 December 2018.

The document is now available on the Company's website at:

http://www.hsbc.com/investor-relations/subsidiary-company-reporting

A copy of the above document has been submitted to the UK Listing Authority and will shortly be available for inspection at the UK Listing Authority's Document Viewing Facility via the National Storage Mechanism which is located at http://www.morningstar.co.uk/uk/NSM.

HSBC Bank plc

Annual Report &

Accounts 2018

 
 Contents 
                                               Page 
 Strategic Report 
 Highlights                                       2 
 Purpose and strategy                             3 
 Products and services                            5 
 How we do business                               6 
 Key performance indicators                       8 
 Economic background and outlook                  9 
 Financial summary                               10 
 Risk overview                                   20 
 Report of the Directors 
 Risk                                            22 
 - Our risk appetite                             22 
 - Top and emerging risks                        22 
 - Areas of special interest                     25 
 - Risk management                               25 
 - Other material risks                          38 
 - Key developments and risk profile             39 
 Capital                                         78 
 - Capital management                            78 
 - Capital overview                              78 
 Corporate Governance Report                     81 
 - Directors                                     81 
 - Company Secretary                             81 
 - Board of Directors                            81 
 - Directors' emoluments                         82 
 - Board committees                              82 
 - Dividends                                     84 
                                               ---- 
 - Internal control                              84 
 - Employees                                     85 
 - Auditors                                      86 
 - Conflicts of interest and indemnification 
  of directors                                   86 
 - Statement on going concern                    86 
---------------------------------------------  ---- 
 - Statement of Directors' Responsibilities      87 
 Financial Statements 
 Independent Auditors' Report                    88 
 Financial Statements                            86 
 Notes on the Financial Statements               97 
---------------------------------------------  ---- 
 
 
 Presentation of Information 
 

This document comprises the

Annual Report and Accounts 2018

for HSBC Bank plc ('the bank') and its subsidiaries (together 'the group'). 'We', 'us' and 'our' refer to HSBC Bank plc together with its subsidiaries. It contains the Strategic Report, the Report of the Directors, the Statement of Directors' Responsibilities and Financial Statements, together with the Independent Auditors' Report, as required by the UK Companies Act 2006. References to 'HSBC', 'HSBC Group' or 'Group' within this document mean HSBC Holdings plc together with its subsidiaries.

HSBC Bank plc is exempt from publishing information required by The Capital Requirements Country-by-Country Reporting Regulations 2013, as this information is published by its parent, HSBC Holdings plc. This information will be available in June 2019 on HSBC's website: www.hsbc.com.

Pillar 3 disclosures for the group are also available on www.hsbc.com, under Investors.

All narrative disclosures, tables and graphs within the Strategic Report and Report of the Directors are unaudited unless otherwise stated.

Our reporting currency is GBP sterling.

Unless otherwise specified, all $ symbols represent US dollars.

 
 Cautionary Statement Regarding Forward- 
  Looking Statements 
 

This

Annual Report and Accounts 2018

contains certain forward-looking statements with respect to the financial condition, results of operations and business of the group.

Statements that are not historical facts, including statements about the group's beliefs and expectations, are forward-looking statements. Words such as 'expects', 'anticipates', 'intends', 'plans', 'believes', 'seeks', 'estimates', 'potential' and 'reasonably possible', variations of these words and similar expressions are intended to identify forward-looking statements. These statements are based on current plans, estimates and projections, and therefore undue reliance should not be placed on them. Forward-looking statements speak only as of the date they are made. HSBC Bank plc makes no commitment to revise or update any forward-looking statements to reflect events or circumstances occurring or existing after the date of any forward-looking statement.

Forward-looking statements involve inherent risks and uncertainties. Readers are cautioned that a number of factors could cause actual results to differ, in some instances materially, from those anticipated or implied in any forward-looking statement.

 
 Highlights 
 

The group transferred its UK retail and qualifying commercial banking activities to HSBC UK Bank plc ('HSBC UK') on 1 July 2018 to meet the ring-fencing requirements of the Financial Services (Banking Reform) Act 2013 and related legislation.

The 2018 financial performance and position as disclosed in the Financial Statements and Notes on the Financial Statements on pages 87 to 165, and sections within the Strategic Report and Report of the Directors therefore reflect the transfer. The 2018 results include the income, expenses and cash flows associated with the transferred activities during the six months to 30 June 2018, which are disclosed as discontinued operations in Note 35 on the Financial Statements. Further details are provided in the Structural Reform section on page 18.

 
                                                            Footnotes      2018        2017 
                                                                       --------  ---------- 
                                                               1, 
 For the year (GBPm)                                            2 
                                                                       -------- 
 Profit before tax (reported basis)                                      1,974     2,370 
                                                                       -------   ------- 
 Profit before tax (adjusted basis)                             3        2,100     3,832 
                                                                       ------- 
 Net operating income before change in expected credit 
  losses and other credit impairment charges                    4        9,468    13,052 
 Profit/(loss) attributable to shareholders of the 
  parent company                                                         1,506     1,809 
---------------------------------------------------------  ----------  -------   ------- 
                                                               1, 
 At year-end (GBPm)                                             2 
 Total equity attributable to shareholders of the parent 
  company                                                               26,878    43,462 
 Total assets                                                          604,958   818,868 
---------------------------------------------------------  ----------  -------   ------- 
 Risk-weighted assets                                           5      143,875   233,073 
                                                                       -------   ------- 
 Loans and advances to customers (net of impairment 
  allowances)                                                          111,964   280,402 
 Customer accounts                                                     180,836   381,546 
                                                                       -------   ------- 
 Capital ratios (%)                                            1,6 
                                                           ---------- 
 Common equity tier 1                                                     13.8      11.8 
 Tier 1                                                                   16.0      13.8 
 Total capital                                                            26.2      16.9 
---------------------------------------------------------  ----------  -------   ------- 
 Performance, efficiency and other ratios (annualised          1, 
  %)                                                            2 
 Return on average ordinary shareholders' equity                7          4.2       4.4 
                                                           ---------- 
 Return on average risk-weighted assets                                    1.1       1.0 
---------------------------------------------------------  ----------  -------   ------- 
 Adjusted return on average risk-weighted assets                5          1.1       1.6 
---------------------------------------------------------  ----------  -------   ------- 
 Cost efficiency ratio (reported basis)                         8         77.6      78.2 
---------------------------------------------------------  ----------  -------   ------- 
 Cost efficiency ratio (adjusted basis)                         8         76.1      67.5 
 Jaws (adjusted basis)                                          9         (9.1)     (5.8) 
                                                           ----------  -------   ------- 
 Ratio of customer advances to customer accounts                          61.9      73.5 
---------------------------------------------------------  ----------  -------   ------- 
 

1 The group adopted IFRS 9, as well as the European Union's regulatory transitional arrangements for IFRS 9, on 1 January 2018. Comparative information has not been restated. For further details, refer to 'Changes to accounting from 1 January 2018' on page 10, 'Standards adopted during the year ended 31 December 2018' on page 97 and Note 34 'Effects of reclassifications upon adoption of IFRS 9' on page 158.

2 HSBC completed the ring-fencing of its UK retail banking activities on 1 July 2018, six months in advance of the legal requirement coming into force, transferring circa 14.5 million qualifying RBWM, CMB and GPB customers from the group to HSBC UK, HSBC's ring-fenced bank. This included the transfer of relevant retail banking subsidiaries. We have retained the non-qualifying components, primarily the UK GB&M business and the overseas branches and subsidiaries. For further details, refer to 'Ring-fenced bank' on page 18 and Note 35 'Discontinued operations' on page 161.

3 Adjusted performance is computed by adjusting reported results for the effect of significant items as detailed on pages 12 to 15.

4 Net operating income before change in expected credit losses and other credit impairment charges is also referred to as revenue.

5 The group has adopted the European Union's regulatory transitional arrangements for IFRS 9, on 1 January 2018. These apply to reported and adjusted RWAs for 2018 (and related ratios) throughout the Annual Report and Accounts 2018 unless otherwise stated.

   6      Capital ratios are detailed in the Capital section on pages 69 to 71. 

7 The return on average ordinary shareholders' equity is defined as profit attributable to shareholders of the parent company divided by the average total shareholders' equity. The return on average ordinary shareholders' equity at 31 December 2017 has been restated by 20 basis points to incorporate the tax effect for dividends paid on Additional Tier 1 ('AT1') capital. Dividends paid on AT1 should be net of tax in the calculation.

8 Reported cost efficiency ratio is defined as total operating expenses (reported) divided by net operating income before change in expected credit losses and other credit impairment charges (reported), while adjusted cost efficiency ratio is defined as total operating expenses (adjusted) divided by net operating income before change in expected credit losses and other credit impairment charges (adjusted).

9 Adjusted jaws measures the difference between adjusted revenue and adjusted cost growth rates.

 
 Purpose and strategy 
 
 
 Our purpose 
 

Our purpose is to be where the growth is, connecting customers to opportunities. We enable businesses to thrive and economies to prosper, helping people to fulfil their hopes, dreams and realise their ambitions.

We operate in 18 countries. Our operating entities represent the group to customers, regulators, employees and other stakeholders.

At 31 December 2018, the bank and its subsidiaries had a physical presence in Armenia, Belgium, Czech Republic, France, Germany, Greece, Ireland, Israel, Italy, Luxembourg, Malta, the Netherlands, Poland, Russia, South Africa, Spain, Switzerland and the United Kingdom. Two of these subsidiaries are located in Continental Europe's largest economies (i.e. France and Germany), with a universal banking presence in France.

Preparing for the UK's withdrawal from the European Union

The UK is due to formally leave the European Union (EU) on 29 March 2019. However, there is no certainty on the future relationship between the UK and the EU or indeed on an implementation period. Throughout this period of uncertainty, our priority is to support our clients and continue to service them, independent of the outcome of negotiations.

In preparation for potential outcomes including a possible departure without a Withdrawal Agreement, and to further strengthen our pan-European proposition, we have made changes to our legal entity structure and product offerings.

Legal entity structure

The group currently has branches in seven European Economic Area ('EEA') countries (Belgium, the Netherlands, Luxembourg, Spain, Italy, Ireland and Czech Republic) which rely on passporting out of the UK. Following regulatory approval in 2018, and on the assumption that the UK leaves the EU without the existing passporting or regulatory equivalence framework that supports cross-border business, the branch network is in the process of transferring to HSBC France ('HBFR'), as HSBC's primary banking entity authorised in the EU. We are on track to complete the business transfer in the first quarter of 2019 and good progress is being made on the operational integration with HBFR of its branches in Belgium, Czech Republic, Luxembourg, the Netherlands, Ireland, Italy and Spain.

Product offerings

To accommodate customer migrations and new business after the UK's EU departure, we are expanding and enhancing our capabilities across Europe, where we already have a strong foundation, with a focus on France, the Netherlands and Ireland. Euro clearing capabilities in HBFR are now available and further product launches are planned during the first quarter of 2019.

Potential outcomes arising from the UK's departure from the EU will impact our clients and our employees. Our focus is on mitigating this impact and providing support and guidance throughout the withdrawal process.

Clients

The UK's departure from the EU is likely to have an impact on our clients' operating models including their working capital requirements, investment decisions and financial markets infrastructure access. Our priority is to provide continuity of service and our intention is to minimise the level of change for our customers. However, we will be required to migrate some EEA-incorporated clients from the UK to HSBC France (or another EEA entity). We are in active dialogue with impacted clients to make the transition as smooth as possible.

Employees

The migration of EEA-incorporated clients will require us to strengthen our local teams in Continental Europe and France in particular. We expect the majority of roles to be filled through hires and we have started a recruitment process. Given the scale of our existing business in France, which already has more than 8,000 employees, a strong balance sheet and extensive product capabilities, we are already well prepared to handle the transfer of activities. Throughout, our objective is to minimise the level of change for our people. We are therefore also providing support on settlement applications to EEA staff resident in the UK and UK staff resident in EEA countries.

Nevertheless, London will continue to be an important global financial centre and the best location for our global headquarters. At 31 December 2018, HSBC employed approximately 39,000 people in the UK.

We have made good progress in terms of ensuring we are prepared for potential outcomes from the UK leaving the EU in the first quarter of 2019 under the terms described above, but there remain execution risks, many of them linked to the uncertain outcome of negotiations and potentially tight timelines to implement significant changes to our UK and European operating models.

HSBC worldwide

The group is part of HSBC, which has approximately 229,000 employees working around the world to provide more than 38 million customers with a broad range of banking products and services to meet their financial needs.

HSBC values

HSBC values define who we are as an organisation and what makes us distinctive.

Dependable

   --    We are dependable, standing firm for what is right and delivering on commitments. 

Open

   --    We are open to different ideas and cultures and value diverse perspectives. 

Connected

-- We are connected to our customers, communities, regulators and each other, caring about individuals and their progress.

Our role in society

How we do business is as important as what we do. Our responsibilities to our customers, employees and shareholders as well as to wider society go far beyond simply being profitable.

We seek to build trusting and lasting relationships with our many stakeholders to generate value in society.

 
 Our strategy 
 

HSBC Bank plc's strategic vision is to be the leading international bank in Europe.

The Group's strategy and strategic direction is embedded in HSBC Bank plc's strategy which aims to capture value from its international network.

This strategy is supported by long-term global trends and the Group's combination of strategic advantages.

Long-term trends

Increasing global connectivity

The international flow of goods, services and finance continues to expand, aided by the development of technology and data in personal and commercial exchanges.

Growing individual wealth

Studies indicate half of the world's population is now considered middle class or wealthier and this proportion is expected to grow to approximately two thirds by 2030. The majority of the middle class consumers are expected to be Asian. (Source: Brookings, "A Global Tipping Point: Half the world is now middle class or wealthier" (2018)).

Increasing need for sustainable finance

Climate change is accelerating and global temperatures are trending significantly higher. Investment in renewable energy capacity will be increasingly required. (Source: OECD, Investing in Climate, Investing in Growth (2017); BP, Statistical Review of World Energy; HSBC analysis)

Strategic advantages

Leading international bank

The group derives value from HSBC's network of businesses and geographical reach to support future growth and increase global connectivity. More than 50% of HSBC Group's client revenue is linked to international clients (revenue from international clients is derived from an allocation of adjusted revenue based on internal management information. International clients are businesses and individuals with an international presence). HSBC Group has been chosen by large corporates across regions as their lead international bank (Source: Greenwich Associates - Large Corporate Banking; percentage of large corporates choosing HSBC as their lead international bank).

Exceptional access to high-growth markets

HSBC's network provides access to high-growth developing markets in Asia, the Middle East and Latin America. We use it to enable clients to participate in global growth opportunities and our investments are aligned to high-growth markets to deliver shareholder value. We remain committed to enhanced customer service and investments in technology

Balance sheet strength

The group's diversified business model enables us to support a strong capital, funding and liquidity position, adopt a conservative approach to credit risk and liquidity management and generate stable returns for shareholders.

Strategic priorities

In June 2018, HSBC Group outlined eight strategic priorities to return HSBC to growth, improve returns and enhance customer and employee experience. HSBC Group aim to achieve this through accelerating growth in areas of strength, embracing new technologies, simplifying the organisation and investing in capabilities for the future. As a result of these strategic priorities, HSBC Group has defined overall financial targets.

We aim to:

-- Accelerate growth from our Asian businesses, including in Hong Kong, the Pearl River Delta, ASEAN, and Wealth in Asia, including Insurance and Asset Management; and be the leading bank to support the transition to a low-carbon economy and the China-led Belt and Road Initiative

-- Complete the establishment of our UK ring-fenced bank, increase mortgage market share, grow our commercial customer base, and improve customer service

   --    Gain market share and deliver growth from our international network 
   --    Turn around our US business 
   --    Improve capital efficiency and redeploy capital into higher-return businesses 

-- Create the capacity for increasing investments in growth and technology through efficiency gains

-- Improve our customer service by investing further in technology and our digital capabilities; increasing our reach; and delivering industry-leading financial crime standards

   --    Simplify the organisation and invest in future skills 

HSBC Bank plc delivers the relevant elements of HSBC Group strategy across Europe and overseas branches.

 
 Value of the network 
 

HSBC's network of businesses covers the world's largest and fastest growing trade corridors and economic zones.

Services around the world

We provide products and services to meet our clients' diverse financial needs. HSBC's geographic reach and network of clients allows greater insight into the trade and capital flows across supply chains.

Business synergies

We share resources and product capabilities across our businesses and leverage these synergies when serving our customers. We are able to provide global markets products, for example, to large multinationals as well as to small businesses. We issue insurance products to individuals and corporations alike. Many of our private banking clients are business owners who we also serve as corporate clients.

 
 Products and services 
 

The group manages its products and services through its four businesses: RBWM; CMB; GB&M; GPB; and Corporate Centre.

 
 Retail Banking and Wealth Management 
  ('RBWM') 
 

Customers

RBWM helps over 1.2 million customers across Europe to manage their finances, buy their homes, and save and invest for the future. Our Insurance and Asset Management businesses support all HSBC's global businesses in meeting their customers' needs.

Products and services

RBWM offers a range of services, including personal banking, mortgages, loans, credit cards, savings and investments and insurance. This includes HSBC Jade, Premier and Advance propositions, wealth solutions and financial planning, personal banking and international services. We serve our customers through four main channels: branches, self-service terminals, telephone service centres and digital (internet and mobile banking).

Business synergies

RBWM makes a significant contribution to the overall success of the group. Insurance and Asset Management provide services to clients across all of the global businesses; and the foreign exchange and wealth management needs of RBWM clients create opportunities for GB&M and the Private Bank. There is also successful collaboration between CMB and RBWM in order to provide services to a broad range of business customers.

Areas of focus

RBWM's priorities are to deliver growth, improve returns and enhance customer and employee experience, as it continues to enhance customer centricity and customer service through investments in technology.

 
 Commercial Banking ('CMB') 
 

Customers

CMB customers range from small enterprises focused primarily on their domestic markets through to corporates operating globally.

Products and services

We support our customers with a range of financial products and services to enable them to operate efficiently and meet their business aspirations. We support our customers' operational and transaction banking needs through working capital facilities, payment services and trade solutions. We also offer expertise in capital financing, mergers and acquisitions, and access to financial markets to our customers.

Business synergies

CMB is at the centre of creating revenue synergies within the group. For instance, we work closely with our GB&M colleagues to provide expertise in capital finance solutions to support our CMB clients. Our trade teams within CMB also provide import and export finance solutions to GB&M clients.

Areas of focus

HSBC is focused on creating value from its network.

The group is investing heavily in digital and technology aspects of its core Global Liquidity and Cash Management ('GLCM') and Global Trade and Receivables Finance ('GTRF') propositions.

 
 Global Banking and Markets ('GB&M') 
 

Customers

HSBC Global Banking and Markets is a client-focused business that provides tailored financial solutions to major government, corporate and institutional clients worldwide. We operate in 18 countries across Europe and contribute significant revenues to other regions through our European client base. Managed as a global business, we offer clients geographical reach and deep local knowledge.

Products and services

Our clients are served by teams that bring together relationship managers and product specialists to develop financial solutions that meet individual client needs. We deliver a comprehensive range of services including capital financing, transaction and advisory banking services, trade services, research, securities services and global liquidity and cash management.

Areas of focus

Deepening client relationships, maximising our synergies with the Group and other Businesses, investments in transaction banking platforms and digital programmes focused on clients remains a priority.

Ongoing focus on cost discipline should result in further simplification of the business through streamlining business lines, operations and technology.

Our growth will be underpinned by a focus on highest standards of conduct and financial crime risk management.

 
 Global Private Banking ('GPB') 
 

Customers

GPB serves high net worth individuals and families, including those with international banking needs, through 6 strategic booking centres located in the EMEA region covering 19 target markets.

Products and services

Our products and services include: Investment Management, incorporating advisory, discretionary and brokerage services; Private Wealth Solutions, comprising trusts and estate planning, designed to protect wealth and preserve it for future generations; and a full range of Private Banking services.

Business synergies

GPB collaborates closely with GB&M, CMB and RBWM, to offer propositions to clients that leverage the Group's expertise in asset management, research, insurance, trade finance and capital financing.

Areas of focus

GPB aspires to be the Private Bank of choice to the families of owners and principals of our best corporate clients, and help them preserve their wealth from generation to generation.

 
 Corporate Centre 
 

Corporate Centre comprises Central Treasury, including Balance Sheet Management ('BSM'), certain legacy assets, interests in our associates and joint ventures, and central stewardship costs.

 
 How we do business 
 

We conduct our business intent on supporting the sustained success of our people, customers and communities. To achieve our purpose, we need to build strong relationships with all of our stakeholders - including customers, employees, and the communities in which we operate. In 2018, we launched our ambition to become the healthiest human system in the financial services industry as a way to create stronger connections across these groups. This will enable us to deliver our strategy with our long-term values, and operate the business in a way that is sustainable.

 
 Customers 
 

We create value by providing the products and services our customers need, we aim to do so in a way that makes it easy for them. This helps us to build healthy and sustainable relationships with our customers.

Our customers range from individuals to major international corporate clients.

Taking responsibilities for the service we deliver

We define conduct as delivering fair outcomes for customers and not disrupting the orderly and transparent operation of financial markets. This is central to our long-term success and ability to serve customers. We have clear policies, frameworks and governance in place to protect them. These cover the way we behave, design products and services, train and incentivise employees, and interact with customers and each other. Our Conduct Framework guides activities to strengthen our business and increases our understanding of how the decisions we make affect customers and other stakeholders. Details on our Conduct Framework are available at www.hsbc.com

Acting on feedback

We listen to our customers and know that asking their opinion on our service is core to understanding their needs and concerns. For more details on how we perform with respect to non-financial metrics related to customer, refer to pages 8 and 9.

Acting on customer feedback has helped make our services more accessible and transparent.

Investing in digital

As part of our strategy, HSBC Bank plc is committed to using technology to enhance our customer experience.

Sustainable finance

Supporting sustainable growth

We recognise our wider obligations to the communities where we operate, and understand economic growth must also be sustainable. We will continue to engage with our stakeholders, and set policies that change in line with technology, science and societal expectations.

Our sustainable growth initiatives are set out in an integrated strategy aligned to our Group strategy and our global business operations. These initiatives are managed across three pillars: sustainable finance; sustainable networks and entrepreneurship; and future skills. Our progress update on sustainable finance is included below. The updates on sustainable networks and entrepreneurship and future skills will be published in our 2019 Environmental, Social and Governance ('ESG') Update.

Each and every one of us has a stake in developing a sustainable economic system. It is the combined responsibility of all players in society to respond to climate change, rapid technological change and continuing globalisation to secure a prosperous future. Since its foundation in 1865, HSBC Group has adapted to and helped serve the needs of a changing world. It has financed economic growth, fostered international trade and overcome events such as economic crises. We recognise that governments, corporations, the financial system and civil society are all stakeholders in climate change and sustainability challenges. Now more than ever, there is a need to develop the skills, business innovation and low-carbon solutions needed to secure long-term prosperity for all.

In 2017, HSBC Group launched its sustainability strategy focusing on three main areas: sustainable finance; sustainable networks and entrepreneurship; and future skills. This is underpinned by the Group's sustainability risk policies and approach to sustainable operations. We recognise our wider obligations to the communities in which we operate, and understand economic growth must also be sustainable. We will continue to engage with our stakeholders, and set policies that change in line with technology, science and societal expectations.

Our global progress update on our sustainability strategy is published annually in our HSBC ESG Update. (www.hsbc.com/our-approach/measuring-our-impact).

We define sustainable finance as any form of financial service that integrates ESG criteria into business or investment decisions. Sustainable finance covers the financing and investment activities needed to support the United Nations Sustainable Development Goals ('SDGs'), and the Paris Agreement.

A key objective for HSBC is to provide financing to enable the transition to a low-carbon economy and to help clients manage transition risk. Sustainable financing includes providing credit and lending facilities, as well as advisory services or access to capital markets. In 2017 HSBC committed to USD100 billion of financing and investments by 2025 to develop clean energy, lower-carbon technologies, and projects that contribute to the delivery of the Paris Climate agreement and the UN SDGs.

Sustainable finance case study

Société du Grand Paris ('SGP'), a state owned infrastructure entity established the first ever 100% Green Euro Medium Term Note ('EMTN') Programme and the net proceeds of the inaugural bond will be exclusively dedicated to finance the Grand Paris Express automatic metro, which is a key feature of the French Government Climate Plan. The project is anticipated to help create between 250,000 to 400,000 housing units, reduce 27 million tons of CO2 emissions by 2050 and substantially reduce commuting travel time on various journeys throughout the Greater Paris area.

In October 2018, HSBC France acted as joint Bookrunner on SGP's 10-year inaugural green benchmark of their Green EMTN Programme, a EUR 1.75 billion 1.125% green bond.

Sustainable finance training

In order to raise awareness of the transition to a low-carbon economy, the bank ran Sustainability training programmes in conjunction with Earthwatch, an environmental charity. In 2018 we ran 5 off-site training programmes where 87 employees attended the 2-day offsite Sustainability Training Programme whilst 11 senior leaders attended a 3-day Sustainability Leadership Programme. In addition, we launched on-line training in collaboration with the Cambridge Institute of Sustainability Leadership on our HSBC University platform.

How we do business in the community

Future skills

As part of HSBC's sustainability strategy the bank is focusing on Future Skills - for our customers, employees and for the people in our local communities. This is being achieved by concentrating on two key areas: employability and financial capability.

Employability

In France, HSBC is supporting Fondation Entreprende in order to increase Senior entrepreneurship. Due to high levels of unemployment of senior people (50% of 55-64 year olds), an increasing number of these people are choosing to become entrepreneurs as a way to maintain a social and economic activity (90,000 enterprises created by senior people in 2017). HSBC France supports Fondation Entreprendre to conduct market surveys, create an incubator to support Senior company creation and allow staff to volunteer as coaches in order to further develop the incubator.

Financial capability

Providing our customers, our communities and our employees with the skills and knowledge needed to thrive in the global economy, we are helping people secure their financial futures through building financial capability.

Community investment

We have a proud record of supporting the local communities and environments in which we operate. Thousands of HSBC employees across Europe are involved every year by volunteering with our charity partnerships and programmes. All employees can take a minimum of two days to volunteer for a charity of their choice in work time. There is also a fund to match fundraising or volunteering in their own time for up to three charities. Our local charity funding supports vulnerable people through the generations. We supported 43 charities across Europe raising a total of USD 7.9 million. Across their own time as well as work time our employees volunteered a total of 22,227 hours.

 
 Empowering people 
 

Enabling a diverse and inclusive environment for all

Our commitment

We are committed to a thriving environment where people are valued, respected and supported to fulfil their potential. By building upon the extraordinary range of ideas, backgrounds, styles and perspectives of our employees we can drive better outcomes for our stakeholders including customers, communities, suppliers and shareholders.

Gender balance at senior levels

We continue to focus on improving gender balance in senior leadership in line with our 30% Club CEO Campaign commitment to reach 30% women in senior leadership roles by 2020. In order to achieve that aspirational target, we set an objective of at least a 21.8% female share of our senior leadership by the end of 2018 in Europe. We achieved 23.3%, a 2.7 percentage point increase on our 2017 position.

Employee networks

We have seven global employee networks as well as our HSBC Communities, which include common interest groups. They provide spaces for colleagues to speak up about internal and commercial issues and opportunities, make connections, and learn from each other. The networks focus on gender, age, ethnicity, LGBT+, faith, working parents and carers, and ability.

More information about our diversity and inclusion activity is available at www.hsbc.com/our-approach/measuring-our-impact

Whistleblowing

It is important to have a culture where our people feel able to speak up. Individuals are encouraged to raise concerns about wrongdoing or unethical conduct through the usual reporting and escalation channels. However, we understand that there are circumstances where people need to raise concerns more discreetly. HSBC Confidential is a global whistleblower platform that enables all of our people, past and present, to raise issues in confidence and without fear of retaliation.

Whistleblowing concerns are investigated thoroughly and independently. Some of the common themes that have been referred to HSBC Confidential include behaviour and conduct, allegations of fraud, and weaknesses with information security. Remedial activity has been undertaken where appropriate, including disciplinary action and adjustments to variable pay, performance ratings and behaviour ratings. Processes have also been enhanced where needed. HSBC does not condone or tolerate any acts of retaliation against those who raise concerns, and has a strict policy prohibiting any such acts. Senior management are made aware of the existence and the outcome of cases where retaliation has been alleged. Making malicious or false claims is incompatible with our values.

The Group Audit Committee has responsibility for oversight of HSBC's whistleblowing arrangements and receives regular updates on the status of whistleblowing arrangements and outcomes.

363 cases were raised during 2018 (2017: 461 cases). All cases were subject to investigation. In 24% of the closed cases in 2018 (2017: 33%), allegations were substantiated in whole or in part and appropriate remedial action taken.

From 1 July 2018, cases relating to the ring-fenced activities of HSBC UK Bank plc have been excluded from the group's totals.

 
 Tax 
 

Our approach to tax

We apply the spirit as well as the letter of the law in all territories where we operate, and have adopted the UK Code of Practice for the Taxation of Banks. As a consequence, we pay our fair share of tax in the countries in which we operate. We continue to strengthen our processes to help ensure our banking services are not associated with any arrangements known or suspected to facilitate tax evasion.

HSBC continues to apply global initiatives to improve tax transparency such as:

   --    the US Foreign Account Tax Compliance Act ('FATCA'); 

-- the OECD Standard for Automatic Exchange of Financial Account Information (also known as the Common Reporting Standard);

   --    the Capital Requirements Directive IV ('CRD IV') Country by Country Reporting; 
   --    the OECD Base Erosion and Profit Shifting ('BEPS') initiative; and 

-- the UK legislation on the corporate criminal offence ('CCO') of failing to prevent the facilitation of tax evasion.

We do not expect the BEPS or similar initiatives adopted by national governments to adversely impact our results.

 
 Key Performance Indicators 
 

The Board of Directors tracks the group's progress in implementing its strategy with a range of financial and non-financial measures or key performance indicators ('KPIs'). Progress is assessed by comparison with the group strategic priorities, operating plan targets and historical performance.

The group reviews its KPIs regularly in light of its strategic objectives and may adopt new or refined measures to better align the KPIs to HSBC's strategy and strategic priorities.

 
 Financial KPIs 
 
 
                                     2018      2017 
                                   ------  -------- 
 Profit before tax (reported) 
  (GBPm)                           1,974   2,370 
 Profit before tax (adjusted) 
  (GBPm)                           2,100   3,832 
---------------------------------          ----- 
 Jaws (adjusted) (%)                (9.1)   (5.8) 
--------------------------------- 
 Cost efficiency ratio 
  (reported) (%)                    77.6    78.2 
---------------------------------  -----   ----- 
 Cost efficiency ratio 
  (adjusted) (%)                    76.1    67.5 
--------------------------------- 
 Return on average risk-weighted 
  assets (%)                         1.1     1.0 
---------------------------------  -----   ----- 
 Adjusted return on 
  average risk-weighted 
  assets (%)                         1.1     1.6 
---------------------------------  -----   ----- 
 Common equity tier 
  1 capital ratio (%)               13.8    11.8 
---------------------------------  -----   ----- 
 

Profit before tax (reported/adjusted): Reported profit before tax is the profit as reported under IFRS. Adjusted profit before tax adjusts the reported profit for the effect of significant items as detailed on pages 12 to 15.

Reported profit before tax was lower year-on-year. This was primarily in GB&M due to lower revenue, mainly in Global Markets, and higher operating expenses due to the non-repeat of 2017 provision releases relating to legal and regulatory matters. This was partly offset by lower Expected Credit Losses/Loan Impairment Charges (ECL/LICs).

Adjusted profit before tax decreased due to the impact of the discontinued operations from 1 July 2018. Revenue was also lower in GB&M, mainly in Global Markets, and in Corporate Centre due to losses on Legacy Credit portfolio disposals. Lower revenue was partly offset by lower ECL/LICs in GB&M.

Adjusted jaws measures the difference between adjusted revenue and adjusted cost growth rates (excluding the effects of costs-to-achieve and other significant items as detailed on pages 12 to 15). Our target is to grow revenues faster than operating expenses on an adjusted basis. This is referred to as positive jaws.

In 2018, revenue reduced by 29% and our operating expenses also went down, but by 19.9%. Jaws was therefore a negative 9.1%.

Adjusted costs decreased due to the impact of discontinued operations. Costs were also lower due to the transfer of costs from the bank to a separate service company in 2018. Since these costs had been recharged to other entities in the Group in 2017, there was an offsetting reduction in intercompany revenue. Adjusted revenue decreased due to the impact of discontinued operations, lower income in GB&M, mainly in Global Markets, and lower intercompany revenue in Corporate Centre.

Cost efficiency ratio (reported/adjusted) is measured as total operating expenses divided by net operating income before expected credit losses and other credit impairment charges.

In 2018, reported revenue decreased by 27% while reported operating expenses decreased by 28%. The cost efficiency ratio therefore improved by 0.6 percentage points.

Reported revenue and operating expenses decreased due to the impact of the discontinued operations on 1(st) July 2018. Excluding this, the cost efficiency ratio worsened by 7.1 percentage points mainly due to lower revenue and higher costs in GB&M.

The cost efficiency ratio (adjusted) worsened by 8.7 percentage points from 2017 as costs increased by more than revenue.

Return on risk-weighted assets ratio (reported/adjusted) is measured as pre-tax profit divided by average risk-weighted assets.

The reported return on average risk-weighted assets has increased by 0.1%. Of this, an increase of 0.3% was due to the impact of discontinued operations. Excluding this, the decrease in return on average risk-weighted assets was driven by lower profitability in GB&M.

The adjusted return on average risk-weighted assets has decreased by 0.5%. Of this, a decrease of 0.2% was due to the impact of discontinued operations. Excluding this, the decrease in return on average risk-weighted assets was driven by lower profitability in GB&M and Corporate Centre.

Common equity tier 1 ('CET1') capital ratio represents the ratio of common equity tier 1 capital to total risk-weighted assets. CET1 capital is the highest quality form of capital comprising shareholders' equity and related non-controlling interests less regulatory deductions and adjustments. The group seeks to maintain a strong capital base to support the development of its business and meet regulatory capital requirements at all times.

The CET1 capital ratio increased during the year mainly due to the implementation of the ring-fencing transfer scheme alongside the capital contribution from HSBC Holdings plc and HSBC UK Holdings Ltd.

 
 Non-financial KPIs 
 

We also monitor a range of non-financial KPIs focusing on customers, people, culture and values including customer service satisfaction, employee involvement and engagement, and diversity and sustainability.

For details on customer service and satisfaction please refer below; for the remaining non-financial KPIs refer to the Corporate Governance section on pages 72 to 78.

Customer service and satisfaction

RBWM

For RBWM in France the core metric used to assess performance is the Customer Recommendation Index (CRI), which measures customers' likelihood to recommend the banks' products and services, tracked relative to the competitor set.

In 2018, the CRI score remains consistent year on year and similar to the 2017 score. HSBC ranks in the top 3 banks within the competitive set and as such meets the target. HSBC performs well on key attributes versus competition, particularly on wealth solutions, reliability, relationship manager, customer service and international. However, there has been a slight decline in HSBC's performance compared with 2017, particularly in areas such as Customer Service and understanding.

HSBC will build on the positive momentum since 2017 in perceptions of its digital services, making it essential to continue supporting investments in Digital banking. This will help further boost perceptions of accessibility.

CMB

Customer experience, satisfaction and conduct are key priorities for CMB in Continental Europe. We continue to remain focused on enhancing our insights through relevant and measurable metrics that enables us to improve understanding of our customers. This in turn continues to help us to drive appropriate actions across our customers' experience with us.

In 2018, our customers have indicated that the key strengths of our existing franchise are the skills and knowledge of our people and our global international network. This is further complemented by our product and service capabilities which support our customers' business aspirations. We have received a number of external recognitions including 'Best in service for Trade Finance in Western Europe' from Euromoney in 2018.

Conversely, we acknowledge that we do not always consistently meet our customers' expectations. To address this, we are streamlining the onboarding process and conducting deep dives in these areas to identify opportunities for improvement. Further work has been planned for this year across all of these areas, focusing on utilising customer insights to drive appropriate changes required to improve overall customer experience and satisfaction.

GB&M

The core internal metric used to assess the strength of our client relationships in GB&M is the Client Engagement Score (a composite measure made up of seven questions, covering satisfaction, advocacy, loyalty, trust, emotion, value and rapport) which is tracked over time. The measure provides a score out of 100 and is benchmarked against the competition (competitors are self-defined by respondents).

In 2018 the Client Engagement Score for HSBC in Continental Europe was 86, in line with competitor scores, and slightly above the HSBC global score of 85. Our staff are considered a real asset by clients, consistently scoring highly on their professional integrity.

In Greenwich Associates' 2018 Large Corporate Cash Management report, HSBC continues to be second in Market Penetration among Top-Tier European companies (companies with at least EUR 2bn turnover per annum). Account opening is an area that our clients have highlighted where their experience lags behind their expectation levels. We will continue to build on the improvements we have already made, with a focus on simplifying the documentation process and increasing the responsiveness and resolution of errors.The bank won a number of awards in Europe in 2018, including Most Innovative Bank for Western Europe (The Banker Awards 2018).

 
 Economic background and 
  outlook 
 
 
 UK 
 

UK real GDP rose by 0.2% in the last quarter of 2018, a sharp slowdown from the Q3 growth rate of 0.6% quarter-on-quarter. The year-on-year GDP growth rate was 1.3%, the joint slowest pace since 2012. The unemployment rate was broadly steady over the second half of 2018 - in November it stood at 4.0%, the lowest since February 1975. Employment as a percentage of the population aged 16-64 was 75.8% in November, a series high. The annual rate of wage growth rose over the course of the year, increasing to a new ten-year high of 3.4% for the three months to November. The annual Consumer Price Index (CPI) inflation rate dropped to 1.8% in January, down from 3.0% a year earlier, due to lower energy prices and a waning inflationary impact of the drop in sterling in 2016. The Bank of England increased Bank Rate in August, from 0.50% to 0.75%.

HSBC Global Research forecasts assume that the UK avoids a departure from the EU without a Withdrawal Agreement and begins to move towards agreement on a multi-year transition period. Under this assumption, calendar year GDP growth is expected to edge up to 1.6% in 2019 and 2020, from 1.4% in 2018. The unemployment rate is forecast to remain low, at around the 4% mark. CPI inflation is expected to fall to around 1.5% by Q4 2019, driven by recent oil price falls and soft underlying price pressures. Given outstanding uncertainties, mainly relating to the UK's withdrawal from the EU, the central forecast is for no Bank Rate rises through 2019 and 2020. But if a Withdrawal Agreement can be approved smoothly and quickly, the Bank of England might be more minded to raise rates.

 
 Eurozone 
 

Eurozone economic growth slowed through the course of 2018. GDP increased by 0.2% in the fourth quarter of 2018, unchanged versus Q3. The annual growth rate slowed from 1.6% to 1.2%, the weakest since 2013. In terms of quarterly growth in the fourth quarter, Germany's economy stagnated following a 0.2% contraction in Q3. Italy's economy contracted for the second successive quarter (-0.2% quarter-on-quarter following -0.1% in Q3). France saw an expansion of 0.3% for the second quarter in a row, while the Spanish economy continued its robust expansion by growing 0.7%. Relative to strong growth seen in 2017, the 2018 slowdown was largely driven by a softening in net exports and investment. The labour market remained fairly robust, though. The unemployment rate fell to a ten-year low of 7.9% in November, while annual wage growth climbed to a ten-year high of 2.5% in the third quarter of 2018. The Harmonised Index of Consumer Prices (HICP) rate of inflation softened towards the end of year, dropping to 1.4% in January, reflecting the impact of lower oil prices.

Following GDP growth of 1.8% in 2018, HSBC Global Research forecasts GDP to grow by 1.4% in 2019 and 1.3% in 2020. In terms of the drivers of growth, net exports are expected to remain subdued, while household spending is expected to make relatively solid gains, as a result of further rises in household income growth. But, given this subdued rate of economic growth, inflationary pressure is unlikely to build very rapidly. As a result of oil price falls, the HICP inflation rate is expected to fall to just below 1% in the autumn of 2019, before recovering thereafter, reaching a (still subdued) rate of 1.6% in 2020. In light of this soft inflation backdrop, alongside risks to the growth outlook, the European Central Bank (ECB) is forecast to keep key policy rates on hold throughout this year and next.

 
 Financial summary 
 
 
 Use of non-GAAP financial measures 
 

Our reported results are prepared in accordance with IFRSs, as detailed in the Financial Statements starting on page 86. In measuring our performance, the financial measures that we use include those derived from our reported results in order to eliminate factors that distort year-on-year comparisons. These are considered non-GAAP financial measures.

Non-GAAP financial measures are described and reconciled to the closest reported financial measure when used.

The global business segmental results on pages 12 to 15 are presented on an adjusted basis in accordance with IFRS 8 'Operating Segments' as detailed in 'Basis of preparation'.

Adjusted performance

Adjusted performance is computed by adjusting reported results for the year-on-year effects of significant items that distort year-on-year comparisons.

We use 'significant items' to describe collectively the group of individual adjustments excluded from reported results when arriving at adjusted performance. These items are ones that management and investors would ordinarily identify and consider separately when assessing performance to understand better the underlying trends in the business.

We consider adjusted performance provides useful information for investors by aligning internal and external reporting, identifying and quantifying items management believes to be significant and providing insight into how management assesses year-on-year performance.

 
 Basis of preparation 
  Global businesses are our reportable 
  segments under IFRS 8. 
  The global business results are 
  assessed by the chief operating 
  decision maker on the basis of adjusted 
  performance that removes the effects 
  of significant items from reported 
  results. We therefore present these 
  results on an adjusted basis. 
  Reconciliations of reported and 
  adjusted performance are presented 
  on pages 12 to 15. Our operations 
  are closely integrated and, accordingly, 
  the presentation of data includes 
  internal allocations of certain 
  items of income and expense. These 
  allocations include the costs of 
  certain support services and global 
  functions to the extent that they 
  can be meaningfully attributed to 
  operational business lines. While 
  such allocations have been made 
  on a systematic and consistent basis, 
  they necessarily involve a degree 
  of subjectivity. Costs which are 
  not allocated to global businesses 
  are included in Corporate Centre. 
  Where relevant, income and expense 
  amounts presented include the results 
  of inter-segment funding along with 
  intercompany and inter-business 
  line transactions. All such transactions 
  are undertaken on arm's length terms. 
  The intra-group elimination items 
  are presented in the Corporate Centre. 
========================================== 
 

A description of the Global businesses is provided in the Strategic Report, page 5

 
 Changes to accounting from 1 January 
  2018 
 

IFRS 9

The group adopted the requirements of IFRS 9 'Financial Instruments' on 1 January 2018, with the exception of the provisions relating to the presentation of gains and losses on financial liabilities designated at fair value, which were adopted on 1 January 2017. The impact of transitioning to IFRS 9 at

1 January 2018 on the consolidated financial statements of the group was a decrease in net assets of GBP532m, arising from:

   --    a decrease of GBP764m from additional impairment allowances; 

-- an increase of GBP58m from the remeasurement of financial assets and liabilities as a consequence of classification changes, mainly from revoking fair value accounting designations for certain subordinated debt instruments; and

   --    an increase in net deferred tax assets of GBP174m. 

Refer to 'Standards adopted during the year ended 31 December 2018' on page 97 and Note 34 'Effects of reclassifications upon adoption of IFRS 9' for further details.

Changes in accounting policy

We have considered market practices for the presentation of certain financial liabilities which contain both deposit and derivative components and were previously included in 'Trading liabilities'. Such liabilities amounted to GBP17,958m at 31 December 2017. We have concluded that a change in accounting policy and presentation is appropriate, since it would better align with the presentation of similar financial instruments by peers and therefore provide more relevant information about the effect of these financial liabilities on our financial position and performance.

As a result, rather than being classified as held for trading, these liabilities are classified as 'Financial liabilities designated at fair value' from 1 January 2018. Comparative information has not been restated.

A further consequence of this change in presentation is that movements in fair value attributable to changes in own credit risk of these liabilities are presented in other comprehensive income with the remaining fair value movements presented in profit or loss in accordance with the accounting policy adopted in 2017. Previously, all fair value movements related to these liabilities were included in profit or loss. For 2017, a loss of GBP335m relating to changes in the credit risk of these liabilities was included in 'Net income from financial instruments held for trading or managed on a fair value basis' with a credit of GBP96m recognised in 'Tax expense'. If the change in accounting policy had been applied retrospectively, these amounts would have been recognised in other comprehensive income, thereby resulting in a net increase in profit after tax for 2017 of GBP239m.

Cash collateral, margin and settlement accounts included in 'Trading assets' (GBP26,447m), 'Loans and advances to banks'

(GBP573m) and 'Loans and advances to customers' (GBP394m) at 31 December 2017 were reclassified to 'Prepayments, accrued income and other assets' at 1 January 2018 in accordance with IFRS 9. Cash collateral, margin and settlement accounts included in 'Trading liabilities' (GBP30,755m), 'Deposits by banks' (GBP570m) and 'Customer accounts' (GBP548m) at 31 December 2017 were reclassified to 'Accruals, deferred income and other liabilities' at 1 January 2018 as this presentation is considered to provide more relevant information, given the change in presentation for the financial assets. Comparative information has not been restated.

Refer to 'Standards adopted during the year ended 31 December 2018' on page 97 and Note 34 'Effects of reclassifications upon adoption of IFRS 9' for further details.

Income statement presentation

The classification and measurement requirements under IFRS 9, which was adopted from 1 January 2018, are based on an entity's assessment of both the business model for managing the assets and the contractual cash flow characteristics of the assets. The standard contains a classification for items measured mandatorily at fair value through profit or loss as a residual category. Given its residual nature, the presentation of the income statement has been updated to separately present items in this category which are of a dissimilar nature or function, in line with IAS 1 'Presentation of Financial Statements' requirements. Comparative information has been re-presented. There is no net impact on total operating income.

Prior to 2018, foreign exchange movements on some financial instruments designated at fair value were presented in the same line in the income statement as the underlying fair value movement on these instruments. In 2018, foreign exchange movements on these instruments and their economic hedges are presented together within 'Net income from financial instruments held for trading or managed on a fair value basis'. Comparative information has been re-presented. As a result, the amount reported in 'Changes in fair value of long-term debt and related derivatives' decreased by GBP402m for 2017. There is no net impact on total operating income.

 
 Summary consolidated income statement for the year ended(1) 
                                                                               2018        2017 
                                                                 Footnotes     GBPm        GBPm 
 Net interest income                                                         3,660     6,181 
 Net fee income                                                              2,044     2,989 
 Net income from financial instruments measured at fair 
  value                                                            2, 3      2,645     3,505 
 Gains less losses from financial investments                                   12       262 
 Net insurance premium income                                                2,005     1,809 
                                                                            ------ 
 Other operating income                                                        580       796 
--------------------------------------------------------------  ----------  ------   ------- 
 Total operating income                                              4      10,946    15,542 
--------------------------------------------------------------  ----------  ------   ------- 
  - of which: Discontinued operations                                        3,132     5,997 
--------------------------------------------------------------  ----------  ------   ------- 
 Net insurance claims, benefits paid and movement in 
  liabilities to policyholders                                              (1,478)   (2,490) 
 Net operating income before expected credit losses 
  and other credit impairment charges                                        9,468    13,052 
--------------------------------------------------------------  ----------  ------   ------- 
 Change in expected credit losses and other credit impairment 
  charges                                                                     (159)         N/A 
 Loan impairment charges and other credit risk provisions                       N/A     (495) 
 Net operating income                                                        9,309    12,557 
  - of which: Discontinued operations                                        3,037     5,767 
-------------------------------------------------------------- 
 Total operating expenses                                            4      (7,351)  (10,208) 
  - of which: Discontinued operations                                       (1,894)   (4,635) 
-------------------------------------------------------------- 
 Operating profit                                                            1,958     2,349 
--------------------------------------------------------------  ----------  ------   ------- 
 Share of profit/(loss) in associates and joint ventures                        16        21 
 Profit before tax                                                  1,3      1,974     2,370 
--------------------------------------------------------------  ----------  ------   ------- 
  - of which: Discontinued operations                                        1,143     1,132 
--------------------------------------------------------------  ----------  ------   ------- 
 Tax expense                                                                  (442)     (528) 
--------------------------------------------------------------  ----------  ------   ------- 
 Profit/(loss) for the year                                                  1,532     1,842 
--------------------------------------------------------------  ----------  ------   ------- 
 Profit/(loss) attributable to shareholders of the parent 
  company                                                                    1,506     1,809 
 Profit attributable to non-controlling interests                               26        33 
--------------------------------------------------------------  ----------  ------   ------- 
 

1 The group adopted IFRS 9 on 1 January 2018. Comparative information has not been restated, apart from the re-presentation of certain income statement line items. For further details, refer to 'Changes to accounting' on page 10, 'Standards adopted during the year ended 31 December 2018' on page 97, and Note 34 'Effects of reclassifications upon adoption of IFRS 9' on page 158.

2 On 1 July 2018, HSBC completed the ring-fencing of its UK retail banking activities transferring qualifying RBWM, CMB and GPB customers from the group to HSBC UK, HSBC's ring-fenced bank. This included the transfer of relevant retail banking subsidiaries. We have retained the non-qualifying components, primarily the UK GB&M business and the overseas branches and subsidiaries. Refer to 'Ring-fenced bank' on page 18 and Note 35 'Discontinued operations' on page 161 for further details.

-- We have considered market practices for the presentation of certain financial liabilities which contain both deposit and derivative components and were previously included in 'Trading liabilities'. Such liabilities amounted to GBP17,958m at 31 December 2017. These liabilities are classified as 'Financial liabilities designated at fair value' from 1 January 2018. Comparative information has not been restated. For 2017, a loss of GBP335m relating to changes in the credit risk of these liabilities was included in 'Net income from financial instruments held for trading or managed on a fair value basis' with a credit of GBP96m recognised in 'Tax expense'. If the change in accounting policy had been applied retrospectively, these amounts would have been recognised in other comprehensive income, thereby resulting in a net increase in profit for 2017 of GBP239m. Refer to 'Changes to accounting from 1 January 2018' on page 10 and Note 34 'Effects of reclassifications upon adoption of IFRS 9' for further details.

   4      Total operating income and expenses include significant items as detailed on pages 12 to 15. 
 
 Reported performance 
 

Reported profit before tax was GBP1,974m, GBP396m lower than 2017.

Net interest income ('NII') decreased by GBP2,521m or 41%. Of this, GBP1,855m was due to the impact of discontinued operations. Excluding this, NII decreased in Corporate Centre in Balance Sheet Management ('BSM') due to the effect of de-risking activities undertaken in 2017 and due to higher funding costs driven by liquidity requirements resulting from the ring-fencing of the UK bank. In GB&M, NII decreased due to margin compression and lower client activity in Global Markets. In RBWM, income decreased due to the transfer of our operations in Turkey to HSBC Middle East Holdings B.V and HSBC Bank Middle East Limited in June 2017, and from adverse market valuation adjustments on insurance manufacturing in France.

Net fee income decreased by GBP945m or 32%. Of this, GBP798m was due to the impact of discontinued operations. Excluding this, net fee income decreased in GB&M due to lower Global Banking revenue reflecting lower volumes and fee compression, in particular across Debt Capital Markets, Equity Capital Markets and Advisory product lines. In RBWM, income decreased due to the transfer of our operations in Turkey to HSBC Middle East Holdings B.V and HSBC Bank Middle East Limited in June 2017.

Net income from financial instruments designated at fair value decreased by GBP860m or 25%. Of this, GBP34m was due to the impact of discontinued operations. Income also decreased in RBWM in the Insurance business primarily reflecting deteriorating equity market conditions in France, which impacted the value of equity and unit trust assets supporting insurance contracts. Corresponding movements were recorded in the liabilities to customers, reflecting the extent to which they participate in the investment performance of the associated assets. The offsetting movements are recorded in 'Net insurance claims and benefits paid and movement in liabilities to policyholders'. This was partly offset in GB&M reflecting net adverse movements in debit valuation adjustments on derivative contracts.

Gains less losses from financial investments decreased by GBP250m or 95%. Of this, GBP40m was due to the impact of discontinued operations. Excluding this, income decreased in GB&M due to lower disposal gains in Principal Investments. In Corporate Centre, income decreased, notably in the UK, due to losses in Legacy Credit following portfolio disposals, undertaken to run-down the legacy business to release capital for other purposes.

Net insurance premium income increased by GBP196m or 11%, primarily due to increased net insurance premium income in France driven by improved commercial performance.

Net insurance claims, benefits paid and movement in liabilities to policyholders decreased by GBP1,012m or 41%. This was primarily in the Insurance business largely reflecting lower returns on financial assets supporting contracts where the policyholder is subject to part or all of the investment risk. This reflected unfavourable equity market performance in France compared with favourable performance in 2017 as well as higher claims and benefits paid. These decreases were partly offset by the impact of higher new business in France. The gains or losses recognised on the financial assets measured at fair value through profit and loss that are held to support these insurance contract liabilities are reported in 'Net income from financial instruments designated at fair value'.

Other operating income decreased by GBP214m or 27%. Of this, GBP133m was due to discontinued operations. Excluding this, income decreased in Corporate Centre due mainly to lower recharges to other entities in the Group reflecting the transfer of certain costs to ServCo in 2018. This was partly offset by increases in RBWM driven in part by favourable movements in the present value of in-force long-term insurance business ('PVIF') in 2018 compared with 2017, in GB&M from the recovery of costs relating to the foreign exchange business from other HSBC Group entities, and in CMB in part due to the non-repeat of prior year fair value losses on investment properties in Malta.

Changes in expected credit losses and other impairment charges ('ECL') were GBP159m in 2018. Of this, GBP94m related to discontinued operations. The remaining charge was mainly in GB&M in the construction and retail sectors, partly offset by releases of provisions in the retail and telecoms sectors. In Corporate Centre, there was a net ECL release following Legacy Credit portfolio disposals.

Loan impairment charges and other credit risk provisions ('LICs') were GBP495m in 2017. Of this, GBP229m was due to discontinued operations. The remaining charge was mainly in GB&M due to two large corporate exposures in the construction and retail sectors. This was partly offset in Corporate Centre by net releases in Legacy Credit following portfolio disposals.

Total operating expenses decreased by GBP2,857m or 28%. Of this, GBP2,742m was due to the impact of discontinued operations. The decrease also included the impact of a number of significant items including:

-- a decrease in costs-to-achieve of GBP551m, comprising costs relating to the achievement of strategic actions following the completion of this programme at the end of 2017;

   --   lower UK customer redress costs of GBP19m; partly offset by 

-- net legal and regulatory provision releases of GBP70m in 2018, compared with releases in 2017 of GBP540m;

   --   higher costs of structural reform of GBP141m. 

Excluding these items, operating expenses decreased in Corporate Centre, partly offset by higher costs in GB&M. Lower costs in Corporate Centre were mainly due to the transfer of certain costs to a service company ServCo in 2018. Since these costs had been recharged from the bank to other entities in the Group in 2017, there was an offsetting reduction in intercompany revenue. The costs moved to ServCo primarily related to premises and equipment, and electronic data processing. Higher costs in GB&M were driven by higher temporary staff costs relating to regulatory projects and higher indirect taxes.

For further details of significant items affecting revenue and costs, please refer to significant revenue/cost items by business segment on pages 12 and 13.

Tax expense totalled GBP442m in 2018 compared with GBP528m in 2017. The effective rate of 22.4% in 2018 was broadly in line with prior year.

 
 Adjusted performance 
 
 
 Significant revenue items by business segment - (gains)/losses 
                                                                             Corporate 
 Audited                                       RBWM     CMB    GB&M   GPB       Centre      Total 
                                               GBPm    GBPm    GBPm  GBPm         GBPm       GBPm 
                                              -----  ------  ------  ----  -----------  --------- 
 31 Dec 2018 
-------------------------------------------- 
 Reported revenue                             2,580  2,479   4,249    249      (89)      9,468 
                                              -----  -----   -----   ----  -------      ------ 
 Significant revenue items                        -    (34)    (42)     -        2         (74) 
                                              -----  -----   -----   ----  -------      ------ 
 - UK customer redress programmes                 -    (34)      -      -        -         (34) 
 - debit valuation adjustment on derivative 
  contracts                                       -      -     (42)     -        -         (42) 
-------------------------------------------- 
 - fair value movement on non-qualifying 
  hedges                                          -      -       -      -        2           2 
-------------------------------------------- 
 Adjusted revenue                             2,580  2,445   4,207    249      (87)      9,394 
--------------------------------------------  -----  -----   -----   ----  -------      ------ 
 31 Dec 2017 
--------------------------------------------  -----  ------  ------  ----  -----------  --------- 
 Reported revenue                             4,097  3,490   4,436    321      708      13,052 
 Significant revenue items                        2     77     166      -      (65)        180 
                                              -----  -----   -----   ----  -------      ------ 
 - UK customer redress programmes                 -     73       2      -        -          75 
 - debit valuation adjustment on derivative 
  contracts                                       -      -     164      -        -         164 
-------------------------------------------- 
 - fair value movement on non-qualifying 
  hedges                                          -      -       -      -       (4)         (4) 
-------------------------------------------- 
 - provisions arising from on-going 
  review of compliance with the CCA in 
  the UK                                          2      4       -      -        -           6 
-------------------------------------------- 
 - gain on disposal of HSBC's interest 
  in VocaLink Holdings Limited                    -      -       -      -      (61)        (61) 
--------------------------------------------  -----  -----   -----   ----  -------      ------ 
 Adjusted revenue                             4,099  3,567   4,602    321      643      13,232 
--------------------------------------------  -----  -----   -----   ----  -------      ------ 
 
 
 Significant cost items by business segment - (recoveries)/charges 
                                                                                Corporate 
 Audited                                         RBWM      CMB     GB&M    GPB     Centre       Total 
                                                 GBPm     GBPm     GBPm   GBPm       GBPm        GBPm 
--------------------------------------------  -------  -------  -------  -----  ---------  ---------- 
 31 Dec 2018 
--------------------------------------------  -------  -------  -------  -----  ---------  ---------- 
 Reported operating expenses                  (2,102)  (1,143)  (3,335)  (188)      (583)   (7,351) 
 Significant cost items                           68        9      (56)     -        179       200 
--------------------------------------------  ------   ------   ------   ----   --------   ------- 
 - costs of structural reform(1)                   -        4       26      -        154       184 
-------------------------------------------- 
 - UK customer redress programmes                 68        5      (17)     -          -        56 
-------------------------------------------- 
 - restructuring and other related costs           -        -        -      -         30        30 
-------------------------------------------- 
 - settlements and provisions in connection 
  with legal and regulatory matters                -        -      (65)     -         (5)      (70) 
--------------------------------------------  ------   ------   ------   ----   --------   ------- 
 Adjusted operating expenses                  (2,034)  (1,134)  (3,391)  (188)      (404)   (7,151) 
--------------------------------------------  ------   ------   ------   ----   --------   ------- 
 31 Dec 2017 
 Reported operating expenses                  (3,641)  (1,571)  (2,885)  (251)    (1,860)  (10,208) 
--------------------------------------------  ------   ------   ------   ----   --------   ------- 
 Significant cost items                          569       20     (396)    (1)     1,090     1,282 
--------------------------------------------  ------   ------   ------   ----   --------   ------- 
 - costs to achieve                               69        6      147     (1)       817     1,038 
-------------------------------------------- 
 - costs to establish UK ring-fenced 
  bank                                             5        1        -      -        251       257 
-------------------------------------------- 
 - UK customer redress programmes                495       12        2      -          -       509 
-------------------------------------------- 
 - settlements and provisions in connection 
  with legal and regulatory matters                -        -     (551)     -         11      (540) 
-------------------------------------------- 
 - costs associated with the UK's exit 
  from the EU                                      -        1        6      -         11        18 
--------------------------------------------  ------   ------   ------   ----   --------   ------- 
 Adjusted operating expenses                  (3,072)  (1,551)  (3,281)  (252)      (770)   (8,926) 
--------------------------------------------  ------   ------   ------   ----   --------   ------- 
 

1 The current year 'cost of structural reform' includes 'costs associated with the UK's exit from the EU' of GBP97m and 'costs to establish UK ring-fenced bank' of GBP87m.

 
 Net impact on profit before tax by business segment 
                                                                      Corporate 
 Audited                                  RBWM     CMB    GB&M   GPB     Centre     Total 
                                          GBPm    GBPm    GBPm  GBPm       GBPm      GBPm 
                                          ----  ------  ------  ----  ---------  -------- 
 31 Dec 2018 
 Reported profit/(loss) before tax         375  1,310     804    62       (577)  1,974 
----------------------------------------  ----  -----   -----   ---   --------   ----- 
 Net impact on reported profit and loss     68    (25)    (98)    -        181     126 
---------------------------------------- 
 - Significant revenue items                 -    (34)    (42)    -          2     (74) 
---------------------------------------- 
 
   *    Significant cost items              68      9     (56)    -        179     200 
----------------------------------------  ----  -----   -----   ---   --------   ----- 
 Adjusted profit/(loss) before tax         443  1,285     706    62       (396)  2,100 
----------------------------------------  ----  -----   -----   ---   --------   ----- 
 31 Dec 2017 
 Reported profit/(loss) before tax         329  1,779   1,193    60       (991)  2,370 
----------------------------------------  ----  -----   -----   ---   --------   ----- 
 Net impact on reported profit and loss    571     97    (230)   (1)     1,025   1,462 
---------------------------------------- 
 - Significant revenue items                 2     77     166     -        (65)    180 
---------------------------------------- 
 - Significant cost items                  569     20    (396)   (1)     1,090   1,282 
----------------------------------------        -----   -----   ---   --------   ----- 
 Adjusted profit/(loss) before tax         900  1,876     963    59         34   3,832 
----------------------------------------  ----  -----   -----   ---   --------   ----- 
 

By operating segment:

 
 Adjusted profit for the year 
 (Audited)                                                                          2018 
                                                                                              Corporate 
                                                             RBWM      CMB     GB&M    GPB       Centre      Total 
                                                             GBPm     GBPm     GBPm   GBPm         GBPm       GBPm 
                                                          -------  -------  -------  -----  -----------  --------- 
 Net operating income before change in expected 
  credit losses and other credit 
  impairment charges(1)                                    2,580    2,445    4,207    249      (87)       9,394 
--------------------------------------------------------  ------   ------   ------   ----   ------       ------ 
 - external                                                2,530    2,252    4,554    248     (190)       9,394 
 - inter-segment                                              50      193     (347)     1      103            - 
 Change in expected credit losses and other 
  credit impairment charges                                 (103)     (26)    (110)     1       79         (159) 
--------------------------------------------------------  ------   ------   ------   ----   ------  ---  ------ 
 Net operating income                                      2,477    2,419    4,097    250       (8)       9,235 
--------------------------------------------------------  ------   ------   ------   ----   ------       ------ 
 Total operating expenses                                 (2,034)  (1,134)  (3,391)  (188)    (404)      (7,151) 
--------------------------------------------------------  ------   ------   ------   ----   ------       ------ 
 Operating profit                                            443    1,285      706     62     (412)       2,084 
--------------------------------------------------------  ------   ------   ------   ----   ------       ------ 
 Share of profit/(loss) in associates and 
  joint ventures                                               -        -        -      -       16           16 
--------------------------------------------------------  ------   ------   ------   ----   ------  ---  ------ 
 Adjusted profit before tax(2)                               443    1,285      706     62     (396)       2,100 
--------------------------------------------------------  ------   ------   ------   ----   ------       ------ 
                                                                %        %        %      %                       % 
 Adjusted cost efficiency ratio                             78.8     46.4     80.6   75.5                  76.1 
--------------------------------------------------------  ------   ------   ------   ----   -----------  ------ 
                                                                                    2017 
 Net interest income                                       3,185    2,323      856    175     (283)       6,256 
 Net fee income                                              963    1,138      762    117        9        2,989 
 Net trading income                                           13       40    2,368      9      113        2,543 
 Other income                                                (62)      66      616     20      804        1,444 
 Net operating income before loan impairment 
  charges and other credit risk                            4,099    3,567    4,602    321      643       13,232 
 
   *    external                                           3,840    3,784    5,142    242      224       13,232 
 
   *    inter-segment                                        259     (217)    (540)    79      419            - 
 Loan impairment charges and other credit 
  risk provisions                                           (127)    (140)    (358)   (10)     140         (495) 
 Net operating income                                      3,972    3,427    4,244    311      783       12,737 
--------------------------------------------------------  ------   ------   ------   ----   ------  ---  ------ 
 Total operating expenses                                 (3,072)  (1,551)  (3,281)  (252)    (770)      (8,926) 
 
   *    employee compensation and benefits                  (973)    (507)  (1,014)   (82)     (41)      (2,617) 
 
   *    general and administrative expenses               (2,084)  (1,027)  (2,262)  (168)    (212)      (5,753) 
 
   *    depreciation and impairment of property, plant a 
  nd 
        equipment                                             (6)     (17)      (3)    (1)    (293)        (320) 
 
   *    amortisation and impairment of intangible assets      (9)       -       (2)    (1)    (224)        (236) 
--------------------------------------------------------  ------   ------   ------   ----   ------       ------ 
 Operating profit                                            900    1,876      963     59       13        3,811 
--------------------------------------------------------  ------   ------   ------   ----   ------  ---  ------ 
 Share of profit in associates and joint 
  ventures                                                     -        -        -      -       21           21 
--------------------------------------------------------  ------   ------   ------   ----   ------  ---  ------ 
 Adjusted profit before tax(2)                               900    1,876      963     59       34        3,832 
                                                          ------   ------   ------   ----   ------  ---  ------ 
                                                                %        %        %      %                       % 
 Adjusted cost efficiency ratio                             74.9     43.5     71.3   78.5                  67.5 
--------------------------------------------------------  ------   ------   ------   ----   -----------  ------ 
 

1 Net operating income before change in expected credit losses and other credit impairment charges/Net operating income before loan impairment charges and other credit provisions also referred to as revenue.

   2      The group adopted IFRS 9 on 1 January 2018. Comparative information has not been restated. 

Adjusted performance

Our adjusted profit before tax decreased by GBP1,732m or 45% compared with 2017. Adjusted profit before tax decreased due to the impact of discontinued operations and lower revenue, partly offset by lower ECL and operating expenses.

Adjusted revenue decreased by GBP3,838m or 29%. Of this, GBP2,912m was due to the impact of discontinued operations. Revenue was also lower in GB&M due to a decrease in Global Markets revenue, notably in Rates due to lower volumes and margin compression as a result of challenging market conditions and reduced client activity. Revenue was also lower in Global Banking due to lower volumes and fee compression across a number of product lines. In Corporate Centre, revenue decreased mainly due to lower recharges to other entities in the Group, offset by lower operating expenses. This reflected the transfer of certain costs to ServCo in 2018. This was partly offset by higher revenue in CMB, primarily driven by higher revenue in the UK achieved through collaboration between our global businesses.

Adjusted ECL/LICs were GBP336m or 68% lower. Of this, GBP136m was due to the impact of discontinued operations. In 2018, ECL net charges (excluding discontinued operations) were primarily in GB&M due to an increase in charges in Global Banking, notably in the construction and retail sectors in the UK and Italy. This was partly offset by provision releases in Corporate Centre in Legacy Credit following portfolio disposals. In 2017, net LICs (excluding discontinued operations) were primarily driven by a number of large exposures in GB&M in Global Banking in the retail and construction sectors in the UK. This was partly offset by provision releases in Corporate Centre following disposal of assets in Legacy Credit.

Adjusted operating expenses decreased by GBP1,775m or 20%. Of this, GBP1,629m was due to the impact of discontinued operations. The remaining decrease was in Corporate Centre, primarily driven by the transfer of costs to ServCo in 2018. Since these costs had previously been recharged to other entities in the Group in 2017, there was an offsetting reduction in intercompany revenue. This was partly offset by an increase in operating expenses in GB&M reflecting higher costs relating to temporary staff and higher indirect taxes.

Retail Banking and Wealth Management

Adjusted profit before tax of GBP443m was GBP457m or 51% lower than 2017. Of this, GBP454m was due to the impact of discontinued operations.

Revenue decreased by GBP1,519m or 37%. Of this, GBP1,506m was due to the impact of discontinued operations. Revenue also decreased due to the transfer of our operations in Turkey to HSBC Middle East Holdings B.V and HSBC Bank Middle East Limited in June 2017. In France revenue was lower reflecting margin compression on lending and deposits, partly offset in insurance manufacturing due to favourable movements in the present value of in-force long-term insurance business ('PVIF') in 2018 compared with 2017. Our revenue was higher in the Channel Islands reflecting growth in deposit balances and higher margins.

ECL/LICs decreased by GBP24m or 19%. In 2018, ECL of GBP103m included charges relating to discontinued operations of GBP101m as well as increased provisions in Malta driven by model changes. In 2017, LICs of GBP127m included charges relating to discontinued operations of GBP103m, charges in our Turkey operations of GBP10m, as well as individually assessed provisions in France and Greece.

Operating expenses decreased by GBP1,038m or 34%. Of this, GBP1,050m was due to the impact of discontinued operations. Operating expenses also decreased due to the transfer of our operations in Turkey to HSBC Middle East Holdings B.V and HSBC Bank Middle East Limited in June 2017. This was partly offset by an increase in operating expenses, mainly in France due to higher staff, marketing and training costs.

Commercial Banking

Adjusted profit before tax of GBP1,285m was GBP591m or 31% lower than 2017. Of this, GBP596m was due to the impact of discontinued operations.

Revenue decreased by GBP1,122m or 31%. Of this, GBP1,146m was due to the impact of discontinued operations. Excluding this, revenue increased, mainly in the UK through collaboration between our global businesses.

ECL/LICs decreased by GBP114m or 81%. In 2018, ECL of GBP26m included net releases relating to discontinued operations of GBP8m. There were also charges in the UK relating to exposures in Turkey. In 2017, LICs of GBP140m included charges relating to discontinued operations of GBP116m as well as provisions in Armenia and Germany, partly offset by releases in Greece and Spain.

Operating expenses decreased by GBP417m or 27%. Of this, GBP426m was due to the impact of discontinued operations. Excluding this, expenses increased due to higher IT costs in France.

Global Banking and Markets

Adjusted profit before tax of GBP706m was GBP257m or 27% lower, primarily reflecting lower revenue and higher operating expenses, partly offset by lower LICs/ECL.

Revenue decreased by GBP395m or 9%. Of this, GBP76m was due to the impact of discontinued operations. Revenue decreased mainly in Global Markets, notably in Rates due to lower volumes and margin compression as a result of challenging market conditions and reduced client activity. Revenue was also lower in Global Banking, particularly across Debt Capital Markets, Equity Capital Markets and Advisory product lines due to lower volumes and fee compression.

ECL/LICs decreased by GBP248m or 69%. In 2018, ECL of GBP109m were in the construction and retail sectors, partly offset by releases of provisions in the retail and telecommunications sectors. In 2017, LICs of GBP357m mainly comprised two large exposures in the construction and retail sectors.

Operating expenses increased by GBP110m or 3%. Operating expenses related to discontinued operations decreased by GBP79m. Excluding this, the increase in operating expenses was due to higher temporary staff costs relating to regulatory projects, higher indirect taxes, and a legal settlement in relation to a class action.

Global Private Banking

Adjusted profit before tax of GBP62m was GBP3m or 5% higher than 2017. Excluding discontinued operations, profit before tax increased by a further GBP7m from 2017.

Revenue decreased by GBP72m or 22%. Of this, GBP90m was due to the impact of discontinued operations. Excluding this, revenue increased in the Channel Islands from increased deposits and higher income on deposits due to the increase in interest rates.

ECL/LICs decreased by GBP11m. Of this, GBP10m was due to the impact of discontinued operations. ECL in 2018 were therefore broadly in line with LICs in 2017.

Operating expenses decreased by GBP64m or 25%. Of this, GBP73m was due to the impact of discontinued operations. Excluding this, operating expenses were higher, driven by increased costs in Channel Islands relating to collaboration services from HSBC UK.

Corporate Centre

Adjusted loss before tax of GBP396m was GBP430m lower than 2017. Of this, GBP93m was due to the impact of discontinued operations. Excluding this, profit before tax decreased due to lower revenue and higher ECL/LICs, partly offset by lower operating expenses.

Revenue decreased by GBP730m. Of this, GBP96m was due to the impact of discontinued operations. Excluding this, revenue decreased mainly due to lower recharges to other entities in the Group, offset by lower operating expenses. This reflected the transfer of certain costs to ServCo in 2018. Revenue was also lower due to increased losses on Legacy Credit portfolio disposals as we accelerated the run-down of this legacy business to release capital for other purposes.

ECL/LICs decreased by GBP61m or 43%, mainly driven by impairment provision releases in Legacy Credit in 2018 following asset portfolio disposals.

Operating expenses decreased by GBP366m or 47%, mainly due to the transfer of certain costs to ServCo in 2018. Since these costs had previously been recharged from the bank to other entities in the Group in 2017, there was an offsetting reduction in intercompany revenue. The costs moved to ServCo related to premises and equipment, and electronic data processing.

 
 Dividends 
 

The consolidated reported profit for the year attributable to the shareholders of the bank was GBP

1,506m

.

Interim dividends of GBP583m, in lieu of a final dividend in respect of the previous financial year, and GBP234m in respect of 2018 were paid on the ordinary share capital during the year.

A second interim dividend of GBP406m, in lieu of a final dividend in respect of the current year, was declared after 31 December 2018, payable on 26 February 2019.

In addition, a special dividend of GBP674m on the ordinary share capital of HSBC Bank plc in respect of the current year was declared after 31 December 2018, payable on 26 February 2019.

Further information about the results is given in the consolidated income statement on page 87.

 
 Review of business position 
 
 
 Summary consolidated balance sheet at 31 Dec 
                                                            2018       2017 
                                                            GBPm       GBPm 
 Total assets(1,2)                                       604,958  818,868 
-------------------------------------------------------  -------  ------- 
 Cash and balances at central banks                       52,013   97,601 
 Trading assets(3)                                        95,420  145,725 
 Financial assets designated and otherwise mandatorily 
  measured at fair value through profit or loss           17,799        N/A 
 Financial assets designated at fair value                   N/A    9,266 
 Derivatives                                             144,522  143,335 
 Loans and advances to banks(3)                           13,628   14,149 
 Loans and advances to customers(3)                      111,964  280,402 
 Reverse repurchase agreements - non-trading              80,102   45,808 
 Financial investments                                    47,272   58,000 
 Other assets(3)                                          42,238   24,582 
-------------------------------------------------------  -------  ------- 
 Total liabilities(1,2)                                  577,549  774,819 
-------------------------------------------------------  -------  ------- 
 Deposits by banks(4)                                     24,532   29,349 
 Customer accounts(4)                                    180,836  381,546 
 Repurchase agreements - non-trading                      46,583   37,775 
 Trading liabilities(4,5)                                 49,514  106,496 
 Financial liabilities designated at fair value(5)        36,922   18,249 
 Derivatives                                             139,932  140,070 
 Debt securities in issue                                 22,721   13,286 
 Liabilities under insurance contracts                    20,657   21,033 
 Other liabilities(4)                                     55,852   27,015 
-------------------------------------------------------  -------  ------- 
 Total equity(1,2)                                        27,409   44,049 
-------------------------------------------------------  -------  ------- 
 Total shareholders' equity                               26,878   43,462 
 Non-controlling interests                                   531      587 
-------------------------------------------------------  -------  ------- 
 

1 The group adopted IFRS 9 together with voluntary changes to accounting policy and presentation on 1 January 2018. Comparative information has not been restated. For further details, refer to 'Changes to accounting from 1 January 2018' on page 10, 'Standards adopted during the year ended 31 December 2018' on page 97, and Note 34 'Effects of reclassifications upon adoption of IFRS 9' on page 158.

2 On 1 July 2018, HSBC completed the ring-fencing of its UK retail banking activities transferring qualifying RBWM, CMB and GPB customers from the group to HSBC UK. This included the transfer of relevant retail banking subsidiaries. We have retained the non-qualifying components, primarily the UK GB&M business and the overseas branches and subsidiaries. Refer to 'Ring-fenced bank' on page 18 and Note 35 'Discontinued operations' on page 161 for further details.

3 Cash collateral, margin and settlement accounts included in 'Trading assets' (GBP26,447m), 'Loans and advances to banks' (GBP573m) and 'Loans and advances to customers' (GBP394m) at 31 December 2017 were reclassified to 'Prepayments, accrued income and other assets' at 1 January 2018 in accordance with IFRS 9. Comparative information has not been restated. Refer to 'Changes to accounting from 1 January 2018' on page 10 and Note 34 'Effects of reclassifications upon adoption of IFRS 9' for further details.

4 Cash collateral, margin and settlement accounts included in 'Trading liabilities' (GBP30,755m), 'Deposits by banks' (GBP570m) and 'Customer accounts' (GBP548m) at 31 December 2017 were reclassified to 'Accruals, deferred income and other liabilities' at 1 January 2018 as this presentation is considered to provide more relevant information, given the change in presentation for the financial assets. Comparative information has not been restated. Refer to 'Changes to accounting from 1 January 2018' on page 10 and Note 34 'Effects of reclassifications upon adoption of IFRS 9' for further details.

5 We have considered market practices for the presentation of certain financial liabilities which contain both deposit and derivative components and were previously included in 'Trading liabilities'. Such liabilities amounted to GBP17,958m at 31 December 2017. These liabilities are classified as 'Financial liabilities designated at fair value' from 1 January 2018. Comparative information has not been restated. Refer to 'Changes to accounting from 1 January 2018' on page 10 and Note 34 'Effects of reclassifications upon adoption of IFRS 9' for further details.

 
 Balance sheet information by global business 
 (Audited) 
                                      RBWM      CMB     GB&M     GPB  Corporate      Total 
                                                                         Centre 
                                      GBPm     GBPm     GBPm    GBPm       GBPm       GBPm 
 31 Dec 2018 
--------------------------------- 
 Loans and advances to customers    21,924   29,021   56,464   3,541      1,014  111,964 
 Customer accounts                  29,961   34,716  103,387   6,514      6,258  180,836 
 31 Dec 2017 
---------------------------------  -------  -------  -------  ------  ---------  --------- 
 Loans and advances to customers   117,933   84,947   63,379   7,372      6,771  280,402 
 Customer accounts                 151,985  100,831   94,069  12,774     21,887  381,546 
---------------------------------  -------  -------  -------  ------  ---------  ------- 
 

There are no reconciling items between the adjusted and reported view of the balance sheet for 2018 and 2017.

The group maintained a strong and liquid balance sheet with the ratio of customer advances to customer accounts of 61.9% compared with 73.5% at 31 December 2017.

The reduction in the ratio of customer advances to customer accounts, as well as the reduction in the overall balance sheet size is a result of ring-fencing. Notably this impacted:

Assets

   --    Loans and advances to customers, which decreased by 60%; 
   --    Cash and balances at central banks, which decreased by 47%; 
   --    Financial investments, which decreased by 18%; 

Liabilities

   --    Customer accounts decreased by 53%; 

Equity

   --    The equity balance decreased by 38% as a result of transfer to HSBC UK. 

Trading assets and liabilities decreased by 35% and 54% respectively as a result of reclassifications upon adoption of IFRS 9 as well as a reduction in equities business.

Debt securities in issue increased by 71% due to funding initiatives driven by both internal and regulatory requirements.

Repurchase and reverse repurchase agreements (non-trading) increased by 23% and 75% respectively as a result of increased market activity.

 
 Reported performance by country 
 
 
 Profit before tax - by country 
                                        Retail 
                                       Banking                Global 
                                           and               Banking      Global 
                                        Wealth  Commercial       and     Private  Corporate 
                                    Management     Banking   Markets     Banking     Centre    Total 
                      Footnotes           GBPm        GBPm      GBPm        GBPm       GBPm     GBPm 
-------------------  ----------  -------------  ----------  --------  ----------  ---------  ------- 
 31 Dec 2018 
-------------------  ---------- 
 United Kingdom           1            402           1,018       582      44          (535)  1,511 
                                 ---------      ----------  --------  ------      --------   ----- 
 France                                (42)            128        20      12           (75)     43 
                                 ---------      ----------  --------  ------      --------   ----- 
 Germany                                10              64        74       6            (3)    151 
                                 ---------      ----------  --------  ------      --------   ----- 
 Other                                   5             100       128       -            36     269 
-------------------  ----------  ---------      ----------  --------  ------      --------   ----- 
 Profit before tax                     375           1,310       804      62          (577)  1,974 
-------------------  ----------  ---------      ----------  --------  ------      --------   ----- 
 
 31 Dec 2017 
 United Kingdom                        320           1,491       704      50          (950)  1,615 
-------------------  ---------- 
 France                                 (8)            158       181       4          (121)    214 
-------------------  ---------- 
 Germany                                16              48       111       7            30     212 
-------------------  ---------- 
 Turkey                   2             (9)              8        19       -             2      20 
-------------------  ---------- 
 Other                                  10              74       178      (1)           48     309 
-------------------  ----------  ---------      ----------  --------  ------      --------   ----- 
 Profit before tax                     329           1,779     1,193      60          (991)  2,370 
-------------------  ----------  ---------      ----------  --------  ------      --------   ----- 
 

1 On 1 July 2018, HSBC completed the ring-fencing of its UK retail banking activities transferring qualifying RBWM, CMB and GPB customers from the group to HSBC UK. This included the transfer of relevant retail banking subsidiaries. We have retained the non-qualifying components, primarily the UK GB&M business and the overseas branches and subsidiaries. Refer to 'Ring-fenced bank' on page 18 and Note 35 Discontinued operations on page 161 for further details.

2 On 29 June 2017, the Turkish operations transferred to HSBC Middle East Holdings B.V. and HSBC Bank Middle East Limited.

 
 Net interest margin 
 

Net interest margin is calculated by dividing net interest income as reported in the income statement by the average balance of interest-earning assets. Average balances are based on daily averages of the group's activities.

Net interest margin of 0.88% was 48 basis points ('bps') lower than in 2017, including the effects of significant items, foreign currency translation and impacted by the transfer of the UK businesses to HSBC UK.

 
 Net interest income 
                                       2018        2017 
                                       GBPm        GBPm 
                                   --------  ---------- 
 Interest income                     7,422     9,043 
---------------------------------  -------   ------- 
 Interest expense                   (3,762)   (2,862) 
---------------------------------            ------- 
 Net interest income                 3,660     6,181 
---------------------------------  -------   ------- 
 Average interest-earning assets   417,569   453,182 
---------------------------------  ------- 
 
                                          %           % 
---------------------------------  --------  ---------- 
 Gross interest yield                 1.58      1.84 
---------------------------------  ------- 
 Less: cost of funds                 (0.77)    (0.53) 
---------------------------------  -------   ------- 
 Net interest spread                  0.81      1.31 
---------------------------------  -------   ------- 
 Net interest margin(1)               0.88      1.36 
---------------------------------  -------   ------- 
 
   1      Net interest margin is net interest income expressed as an annualised percentage of average interest-earning assets. 
 
 Summary of interest income by asset type 
                                                   2018                           2017 
                                        Average  Interest             Average  Interest 
                                        balance    income  Yield(1)   balance    income    Yield(1) 
                                           GBPm      GBPm         %      GBPm      GBPm           % 
                                                                                         ---------- 
 Short term funds and loans and 
  advances to banks                     85,186        146      0.17   78,133         53      0.07 
-------------------------------------  -------   --------  --------  ------- 
 Loans and advances to customers       188,956      4,865      2.57  266,491      7,136      2.68 
-------------------------------------                      --------                      -------- 
 Reverse repurchase agreements - 
  non trading                           64,462        404      0.63   44,739        186      0.42 
-------------------------------------                      --------                      -------- 
 Financial investments                  52,153        902      1.73   63,462        943      1.49 
------------------------------------- 
 Other interest-earning assets          26,812        268      1.00      357         18      5.04 
-------------------------------------  -------   --------  --------  -------   --------  -------- 
 Total interest-earning assets         417,569      6,585      1.58  453,182      8,336      1.84 
-------------------------------------  -------   --------  --------  -------   --------  -------- 
 Trading assets and financial assets 
  designated or mandatorily measured 
  at fair value(2)                      70,958      1,906      2.69       N/A       N/A         N/A 
-------------------------------------  -------   --------  --------  --------  --------  ---------- 
 Trading assets and financial assets 
  designated at fair value(2)               N/A       N/A       N/A   82,765      1,685      2.04 
-------------------------------------  --------  --------  --------  -------   --------  -------- 
 Expected credit losses provision       (2,051)         -         -       N/A       N/A         N/A 
-------------------------------------  -------   --------  --------  --------  --------  ---------- 
 Impairment allowance                       N/A       N/A       N/A   (2,328)         -         - 
                                                 --------                      -------- 
 Non-interest-earning assets           263,691          -         -  300,521          -         - 
                                       -------   --------  --------            -------- 
 Total assets                          750,167      8,491      1.13  834,140     10,021      1.20 
-------------------------------------  -------   --------  --------  -------   --------  -------- 
 

1 Yield calculations include negative interest on assets recognised as interest expense in the income statement.

2 Interest income arising from trading assets is included within 'Net trading income' in the income statement.

 
 Summary of interest expense by type of liability and equity 
                                                         2018                          2017 
                                              Average     Interest         Average     Interest 
                                              balance   expense(1)  Cost   balance   expense(1)    Cost 
                                                 GBPm         GBPm     %      GBPm         GBPm       % 
-------------------------------------------            ----------- 
 Deposits by banks                             21,716          109  0.50    17,293           54  0.31 
-------------------------------------------  --------  -----------  ----  --------  -----------  ---- 
 Financial liabilities designated 
  at fair value - own debt issued              16,178          187  1.16    17,307          218  1.26 
-------------------------------------------  --------  -----------  ----  --------  -----------  ---- 
 Customer accounts                            222,970        1,343  0.60   308,944        1,279  0.41 
-------------------------------------------  --------  -----------  ----  --------  -----------  ---- 
 Repurchase agreements - non trading           49,523          389  0.79    39,239          152  0.39 
-------------------------------------------  --------  -----------  ----  --------  -----------  ---- 
 Debt securities in issue and subordinated 
  debts                                        34,969          600  1.72    21,846          377  1.73 
-------------------------------------------  --------  -----------  ----  --------  -----------  ---- 
 Other interest-bearing liabilities            32,729          297  0.91     1,114           75  6.73 
-------------------------------------------  --------  -----------  ----  --------  -----------  ---- 
 Total interest-bearing liabilities           378,085        2,925  0.77   405,743        2,155  0.53 
-------------------------------------------  --------  -----------  ----  --------  -----------  ---- 
 Trading liabilities and financial 
  liabilities designated at fair 
  value (excluding own debt issued)(2)         65,768        1,617  2.46    91,830        1,167  1.27 
                                                       -----------                  ----------- 
 Non-interest-bearing current accounts         53,741            -     -    49,527            -     - 
 Total equity and other non-interest 
  bearing liabilities                         252,573            -     -   287,040            -     - 
-------------------------------------------  --------  -----------  ----  --------  -----------  ---- 
 Total equity and liabilities                 750,167        4,542  0.61   834,140        3,322  0.40 
-------------------------------------------  --------  -----------  ----  --------  -----------  ---- 
 

1 Cost of funding calculations include negative interest on liabilities recognised as interest income in the income statement.

2 Interest expense arising from trading liabilities is included within 'Net trading income' in the income statement.

 
 Structural reform 
 

UK exit from EU

The structural reform in preparation of the UK's withdrawal from the EU is described under Areas of special interest within the Risk section, page 23.

Ring-fenced bank

Policy background

The UK Financial Services (Banking Reform) Act 2013 and associated secondary legislation and regulatory rules required UK deposit-taking banks with more than GBP25bn of 'core deposits' (broadly from individuals and small to medium-sized businesses) to separate their UK retail banking activities from their other wholesale and investment banking activities by

1 January 2019. The resulting UK ring-fenced bank ('RFB') entities need to be legally distinct, operationally separate and economically independent from the non-ring-fenced bank entities.

Ring-fencing rules have been published by the Prudential Regulation Authority ('PRA') determining how ring-fenced banks are permitted to operate. Further rules published by the FCA set out the disclosures that non-ring-fenced banks are required to make to prospective customers who are individuals.

Ring-fencing implementation

HSBC completed the ring-fencing of its UK retail banking activities on 1 July 2018, six months in advance of the legal requirement coming into force, transferring circa 14.5 million qualifying RBWM, CMB and GPB customers from HSBC Bank plc to HSBC UK Bank plc ('HSBC UK'), HSBC's ring-fenced bank. This included the transfer of relevant retail banking subsidiaries. HSBC Bank plc, which is HSBC's non-ring-fenced bank, has retained the non-qualifying components, primarily the UK GB&M business and the overseas branches and subsidiaries. The two banking entities will operate alongside each other, supported by services received from HSBC Global Services (UK) Limited ('UK ServCo').

The primary means of transferring HSBC Bank plc's qualifying customers and subsidiaries to HSBC UK was through a court-approved ring-fencing transfer scheme ('RFTS') as provided for in Part VII, section 106 of the Financial Services and Markets Act 2000 (as amended) ('FSMA'). In addition to these transfers, certain items were transferred through other legal arrangements.

Establishment of HSBC UK Bank plc

The establishment of HSBC UK was accounted for as a group restructuring. HSBC's accounting policy for such transactions requires that assets and liabilities were recognised by HSBC UK at their existing carrying amounts in the financial statements of the group.

 
 Risk overview 
 

The group continuously identifies and monitors risks. This process, which is informed by its risk factors and the results of its stress testing programme, gives rise to the classification of certain principal risks. Changes in the assessment of principal risks may result in adjustments to the group's business strategy and, potentially, its risk appetite.

Our banking risks are credit risk, operational risk, market risk, liquidity and funding risk, compliance risk and reputational risk. We also incur insurance risk.

In addition to these banking risks, we have identified top and emerging risks with the potential to have a material impact on our financial results or reputation and the sustainability of our long-term business model.

The exposure to our risks and risk management of these are explained in more detail in the Risk section of the Report of the Directors on pages 20 to 35.

During 2018, a number of changes to our top and emerging risks have been made, to reflect the revised assessment of their effect on the group. Two risks have been removed, 'Turning of the Credit cycle'; this risk will be controlled in line with the group's approach to managing credit through the cycle and "Increasing Regulatory expectations"; this risk has been removed as specific high impact regulatory change initiatives have dedicated coverage (such as the HSBC programme to manage the impact of the UK's exit from the EU) and the associated implications of such change initiatives will be covered through Execution Risk.

A new risk 'IBOR (Inter Bank Offered Rate) transition' was added during 2018 and also includes LIBOR (London Inter Bank Offered Rate).

 
 
 Externally driven 
   UK exit from         p    The UK is due to leave the EU in March 2019 and negotiations 
    EU                        are ongoing. We will continue to work with regulators, 
                              governments and our customers to manage the risks 
                              of the UK's exit from the EU (and the current period 
                              of uncertainty) as they arise, particularly across 
                              those sectors most impacted. 
  -------------------       ------------------------------------------------------------- 
   Geopolitical         p    We continually assess the impact of geopolitical events 
    risk                      on our businesses and exposures across Europe and 
                              take steps to mitigate them, where required, to help 
                              ensure that we remain within risk appetite. We have 
                              also strengthened physical security at our premises 
                              where the risk of terrorism is heightened. 
   Cyber threat         u    We continue to strengthen our cyber control framework, 
    and unauthorised          in line with the changing threat environment and improve 
    access to systems         our resilience and cybersecurity capabilities, including 
                              threat detection and analysis, access control, payment 
                              system controls, data protection, network controls 
                              and backup and recovery. 
  -------------------  ---  ------------------------------------------------------------- 
   Regulatory           u    We continue to enhance our management of conduct in 
    focus on conduct          a number of areas, including the treatment of potentially 
    of business               vulnerable customers, market surveillance, employee 
                              training and performance. 
  -------------------  ---  ------------------------------------------------------------- 
   Financial Crime      u    We have integrated the majority of the Global Standards 
    Compliance                programme financial crime risk core capabilities into 
                              our day-to-day operations during 2018, and expect 
                              to complete the transition to business and function 
                              management in the first half of 2019. We continue 
                              to take further steps to refine and strengthen our 
                              defences against financial crime by applying advanced 
                              analytics and artificial intelligence. 
  -------------------       ------------------------------------------------------------- 
   Market illiquidity   u    We monitor risks closely and report regularly on illiquidity 
    and volatility            and concentration risks to the PRA. 
  -------------------  ---  ------------------------------------------------------------- 
   IBOR transition      --   We are evaluating the impact on HSBC's products, services 
                              and processes as the industry accord evolves, with 
                              the intention of minimising disruption through appropriate 
                              mitigating actions. 
  -------------------  ---  ------------------------------------------------------------- 
 Internally driven 
   People risk          u    We continue to increase our focus on resource planning 
                              and employee retention and to equip line managers 
                              with the skills to both manage change and support 
                              their employees. 
  -------------------       ------------------------------------------------------------- 
   IT systems           u    We continue to monitor and improve service resilience 
    infrastructure            across our technology infrastructure, enhancing our 
    and resilience            problem diagnosis/resolution and change execution 
                              capabilities, reducing service disruption to our customers. 
  -------------------  ---  ------------------------------------------------------------- 
   Execution risk       u    We continue to strengthen our prioritisation and governance 
                              processes for significant strategic, regulatory and 
                              compliance projects. 
  -------------------  ---  ------------------------------------------------------------- 
   Model risk           p    We have enhanced our model risk governance framework 
                              by establishing an independent second line of defence 
                              Model Risk Management sub-function, and enhancing 
                              our existing policy and standards in order to address 
                              evolving regulatory, external and internal requirements. 
  -------------------  ---  ------------------------------------------------------------- 
   Data management      p    We continue to improve our insights, consistency of 
                              data aggregation, reporting and decisions through 
                              ongoing enhancement of our data governance, data quality, 
                              data privacy and architecture framework. 
  -------------------  ---  ------------------------------------------------------------- 
 
 
 p    Risk has heightened during 2018 
 u    Risk remains at the same level 
       as 2017 
 --   New risk introduced in 2018 
 
 
 On behalf of the Board 
 J Fleurant, Director 
 19 February 2019 
 Registered number 
  14259 
 

r

 
 Risk 
                                           Page 
 Our risk appetite                           22 
                                         ------ 
 Top and emerging risks                      22 
                                         ------ 
 Externally driven                           22 
---------------------------------------  ------ 
 Internally driven                           24 
---------------------------------------  ------ 
 Areas of special interest                   25 
                                         ------ 
 Risk management                             25 
                                         ------ 
 Our risk management framework               25 
---------------------------------------  ------ 
 Our material banking and insurance 
  risks                                      28 
---------------------------------------  ------ 
 Credit risk management                      29 
---------------------------------------  ------ 
 Liquidity and funding risk management       32 
---------------------------------------  ------ 
 Market risk management                      32 
---------------------------------------  ------ 
 Operational risk management                 35 
---------------------------------------  ------ 
 Regulatory compliance risk management       35 
---------------------------------------  ------ 
 Financial crime risk management             36 
---------------------------------------  ------ 
 Insurance manufacturing operations 
  risk management                            37 
---------------------------------------  ------ 
 Other material risks                      34 
---------------------------------------  ---- 
 Reputational risk management              34 
---------------------------------------  ---- 
 Pension risk management                   34 
---------------------------------------  ---- 
 Key developments and risk profile           39 
---------------------------------------  ------ 
 Key developments in 2018                    39 
---------------------------------------  ------ 
 Credit risk in 2018                         39 
---------------------------------------  ------ 
 Summary of credit risk                    35 
---------------------------------------  ---- 
 Management of liquidity and funding 
  risk profile                               68 
---------------------------------------  ------ 
 Market risk profile                         70 
---------------------------------------  ------ 
 Operational risk profile                    73 
---------------------------------------  ------ 
 Insurance manufacturing operations 
  risk profile                               73 
---------------------------------------  ------ 
 
 
 Our risk appetite 
 

Throughout its history HSBC has maintained a risk profile that has developed in line with its strategy and business objectives.

The following principles guide the group's overarching risk appetite and determine how its businesses and risks are managed:

Financial position

   --    Strong capital position, defined by regulatory and internal ratios. 
   --    Liquidity and funding management for each entity on a stand-alone basis. 

Operating model

-- Ambition to generate returns in line with our risk appetite and strong risk management capability.

   --    Ambition to deliver sustainable earnings and appropriate  returns for shareholders. 

Business practice

-- Zero tolerance for knowingly engaging in any business, activity or association where foreseeable reputational risk or damage has not been considered and/or mitigated.

-- No appetite for deliberately or knowingly causing detriment to consumers arising from our products and services or incurring a breach of the letter or spirit of regulatory requirements.

   --    No appetite for inappropriate market conduct by a member of staff or by any group business. 

Enterprise-wide application

Our risk appetite encapsulates consideration of financial and non-financial risks and is expressed in both quantitative and qualitative terms. It is applied at the global business level, at the country level and to material European entities.

 
 Top and emerging risks 
 

Top and emerging risks are those that may impact on the financial results, reputation or business model of the bank. If these risks were to occur, they could have a material effect on the group. The exposure to these risks and our risk management approach are explained in more detail below.

Externally driven

Process of UK withdrawal from the European Union

Uncertainty regarding the terms of the UK's exit agreement and its future relationship (including trading) with both the EU and the rest of the world is expected to continue for the next few years at least. Market volatility will therefore persist as the UK continues its negotiations with the EU and its potential future trading partners around the world. Throughout this period, we will continually update our assessment of potential consequences for our customers, products and banking model and re-evaluate our mitigating actions accordingly.

The scale and nature of the impact on HSBC will depend on the precise terms on which HSBC and its customers will be able to conduct cross-border business following the UK's departure from the EU. Changes to the UK's current trade relationships could require changes to HSBC's banking model to ensure we continue to comply with law and regulation in meeting the needs of our customers and conducting our business. Such changes could, among other things, increase our operating costs and require us to relocate staff and businesses to other jurisdictions. In addition, any negative impact on the economy, demand for borrowing and capital flows as a result of the aforementioned uncertainty, volatility or result of UK negotiations could have a consequential negative impact on HSBC.

Mitigating actions

-- We have undertaken a comprehensive impact assessment to understand the range of potential implications for our customers, our products and our business. We have identified actions to ensure we can continue to serve our customers across the UK and Europe, and have started implementing them.

-- We actively monitor our portfolio to identify areas of stress, supported by stress testing analyses. Vulnerable sectors will be subject to management review to determine if any adjustments to risk policy or appetite are required. As part of our stress testing programme, in addition to the Bank of England regulatory stress test which incorporated assumptions of a UK departure from the EU without a Withdrawal Agreement, we have conducted additional specific stress tests incorporating a number of internal macroeconomic and event-driven scenarios to assess a range of risks and provide management with a wider view of possible scenarios and outcomes from the UK's EU departure.

-- We will continue to work with regulators, governments and our clients in an effort to manage risks as they arise, particularly across the most impacted sectors.

We believe we are well placed to withstand these risks, but would nevertheless be affected by severe shocks. For further details, see 'Areas of special interest' section.

Geopolitical risk

Our operations and portfolios are exposed to risks associated with political instability, civil unrest and military conflict which could lead to disruption to our operations, physical risk to our staff and/or physical damage to our assets. In addition rising protectionism and the increased trend of using trade and investment policies as diplomatic tools may also adversely affect global trade flows. Geopolitical risk remained heightened throughout 2018.

The growing presence of populist parties means political systems across Europe are increasingly fragmented, volatile and less predictable. Political uncertainty remains high in the UK as its departure from the EU continues to dominate the political agenda. The persistent threat of terrorist attacks remains.

Mitigating actions

-- We continually monitor the geopolitical outlook, in particular in countries where we have material exposures and/or a physical presence.

-- We use internal stress tests and scenario analysis as well as regulatory stress test programmes, to adjust limits and exposures to reflect our risk appetite and mitigate risks as appropriate.

-- We have taken steps to enhance physical security in those countries deemed to be at high risk from terrorism.

Cyber threat and unauthorised access to systems

HSBC and other public and private organisations continue to be the targets of increasingly sophisticated cyber attacks. Ransomware and distributed denial of service attacks appear to be an increasingly dominant threat to the financial industry, which may result in disruption to our operations and customer-facing websites, financial loss or loss of customer data.

Mitigating actions

-- We continue to strengthen our capabilities to protect against increasingly sophisticated malware, denial of service attacks and loss of data, as well as enhancing our security event detection and incident response processes. As well as technological improvement there is an increasing awareness of the cyber threat within our business, supported by formal training and the implementation of a number of specific cyber related working groups leading to an improving control environment around the end user and third party environment.

-- Cyber risk is a top priority of the Board and is regularly reported to ensure appropriate visibility, governance and executive support for our ongoing cybersecurity programme.

-- We participate in intelligence sharing with both law enforcement and industry schemes to help improve our understanding of, and ability to respond to, the evolving threats faced by us and our peers.

Regulatory focus on conduct of business

Financial institutions remain under considerable scrutiny regarding conduct of business, particularly in relation to fair outcomes for customers and orderly and transparent operations in financial markets. Regulators, prosecutors, the media and the public all have heightened expectations as to the behaviour and conduct of financial institutions, and any shortcomings or failure to demonstrate adequate controls are in place to mitigate such risks could result in regulatory sanctions, fines or an increase in civil litigation.

In September 2017, HBSC Holdings and HSBC North America Holdings Inc. ('HNAH') consented to a civil money penalty order with the US Federal Reserve Board ('FRB') in connection with its investigation into HSBC's historical foreign exchange activities. Under the terms of the order, HSBC Holdings and HNAH agreed to undertake certain remedial steps and to pay a civil money penalty to the FRB. In January 2018, HSBC Holdings entered into a three-year deferred prosecution agreement with the Criminal Division of the US Department of Justice ('DoJ') relating to HSBC's historical foreign exchange sales and trading activities. Under the terms of the deferred prosecution agreement, HSBC agreed to undertake certain remedial steps; to provide annual reports to the DoJ and to pay a financial penalty and restitution. For further details, see Note 32 of the Financial Statements.

Mitigating actions

-- We have continued to enhance our management of conduct in areas including the treatment of potentially vulnerable customers, market surveillance, employee training and performance management (see 'Regulatory compliance risk management' on page 31.

Financial crime compliance

Financial institutions remain under considerable regulatory scrutiny regarding their ability to prevent and detect financial crime. Financial crime threats continue to evolve, often in tandem with geopolitical developments. The highly speculative, volatile and opaque nature of virtual currencies as well as the pace of new currencies and associated technological developments creates challenges in effectively managing financial crime risks. The evolving regulatory environment continues to present execution challenge. An increasing trend towards greater data privacy requirements may affect our ability to effectively manage financial crime risks.

In December 2012, among other agreements, HSBC Holdings plc ('HSBC Holdings') consented to a cease-and-desist order with the US Federal Reserve Board ('FRB') and agreed to an undertaking with the UK Financial Conduct Authority ('FCA') to comply with certain forward-looking AML and sanctions-related obligations. HSBC Holdings also agreed to retain an independent compliance monitor - who is for FCA purposes a 'Skilled Person' under section 166 of the Financial Services and Markets Act, and for FRB purposes an 'Independent Consultant - to produce annual assessments of the Group's AML and sanctions compliance programme. HSBC Holdings entered into an agreement with the Office of Foreign Assets Control ('OFAC') regarding historical transactions involving parties subject to OFAC sanctions. The Skilled Person/Independent Consultant will continue to conduct country reviews and provide periodic reports for a period of time at the FCA's and FRB's discretion. The role of the Skilled Person/Independent Consultant is discussed on page 33.

Mitigating actions

-- HSBC continues to enhance financial crime risk management capabilities; investing in the next generation of tools to fight financial crime by applying advanced analytics and artificial intelligence.

-- HSBC are developing procedures and controls to manage the risks associated with direct and indirect exposure to virtual currencies.

-- HSBC continues to work with jurisdictions and relevant bodies to address data privacy challenges through international standards, guidance and legislation to enable effective management of financial crime risk.

-- We continue to ensure that the reforms we have put in place are both effective and sustainable over the long term.

Market illiquidity and volatility

Market liquidity, as defined by the ability to trade the desired volume of a financial security in a timely manner, continues to be sporadic. Liquidity remains challenging due to multiple factors: regulatory demands such as increased capital requirements constraining the overall balance sheet size of financial institutions, the implementation of the Volcker rule, which prohibits certain trading activities, and the impact of revised collateral requirements.

This is a market-wide issue, where HSBC may suffer losses or incur lower revenue.

Mitigating actions

-- We continually monitor our illiquid positions and concentration risks, adjusting our market risk limits and risk appetite where appropriate.

IBOR transition

Interbank Offered Rates ('IBORs') including LIBOR (London Interbank Offered Rate) are used to set interest rates on hundreds of trillions of US dollars' worth of different types of financial transactions and are used extensively for valuation purposes, risk measurement and performance benchmarking.

Following the recommendations of the Financial Stability Board, a fundamental review and reform of the major interest rates benchmarks, including IBORs, are underway across the world's largest financial markets. In some cases, the reform will include replacing interest rate benchmarks with alternative Risk Free Rates ('RFRs'). This replacement process is at different stages, and is progressing at different speeds, across several major currencies.

There is therefore uncertainty as to the basis, method and timing of transition and their implications on the participants in the financial markets.

HSBC has identified a number of potential prudential, conduct and systemic risks associated with the transition.

Mitigating actions

-- The Group has established a Global Programme across all of our Global Businesses to coordinate HSBC's transition activities and to assess the potential risks and impacts of any transition.

-- The Group will continue to engage with industry participants and the official sector to support an orderly transition.

-- We will continue to contribute to the ongoing Global Programme work to determine the volume and value of customer exposures potentially impacted by the transition from IBORs.

Internally driven

People risk

Our people are critical to our success and it is important that we identify, manage and mitigate any risks that might have an impact on our people feeling empowered and able to thrive in their careers, as well as being able to support our customers and the communities they serve. We aim to foster a culture that proactively promotes the right colleague behaviours and conduct, and that we have the right number of people with the right skills, knowledge and capabilities to be able to do the right thing for our customers. We have processes in place to identify where this might not be the case and to mitigate the risk accordingly.

We continually assess the impact of geopolitical events on our businesses and exposures. Some events, such as the UK's exit from the EU, result in increased people risks to be assessed in the UK and across a number of European sites, and for steps to be taken to mitigate such risks, where required.

Our success in delivering the Group's strategic priorities, as well as proactively managing the regulatory environment, depends on the continuous development and retention of our leadership and high performing employees. The ability to continue to attract, train, motivate and retain highly qualified professionals in an employment market where expertise is often mobile and in short supply is critical, particularly as our business lines execute their strategic business outlooks.

Mitigating actions

-- We have plans in place to manage the potential impacts resulting from the UK exit from the EU.

-- HSBC University is focused on developing opportunities and tools for now, next and future skills, personal skills to 'learn, adapt and evolve' and leaders to create an environment for success.

-- HSBC is building the healthiest human system where colleagues can thrive. A number of initiatives to improve our 'Ways of Working' (e.g. simplifying processes and governance, adopting new behaviours) and encourage an open and positive culture have been launched. We also promote a diverse and inclusive workforce and provide active support across a wide range of health and wellbeing activities.

IT systems infrastructure and resilience

HSBC continues to invest in the reliability and resilience of the group's IT systems and crucial services, which could result in reputational and regulatory damage.

Mitigating actions

-- Strategic initiatives are transforming how technology is developed, delivered and maintained, with a particular focus on providing high quality, stable and secure services. As part of this, we are concentrating on materially improving system resilience and service continuity testing. In addition we have enhanced the security of our development lifecycle and improved our testing processes and tools.

-- During 2018, we continued to monitor and upgrade our IT systems, simplifying our service provision and replacing older IT infrastructure and applications.

Execution risk

In order to deliver our strategic objectives and meet mandatory regulatory requirements, it is important for HSBC to maintain a strong focus on execution risk. This requires robust management of significant resource--intensive and time--sensitive programmes. Risks arising from the magnitude and complexity of change may include regulatory censure, reputational damage or financial losses. Current major initiatives include managing the operational implications of updating our business model following the UK's vote to leave the EU.

Mitigating actions

-- Our prioritisation and governance processes for significant projects are monitored by the group's Executive Committee.

-- In 2018, we continued to manage execution risks through closely monitoring the punctual delivery of critical initiatives, internal and external dependencies, and key risks, to allow better portfolio management across the group.

Model risk

We use models for a range of purposes in managing our business, including regulatory capital calculations, stress testing, credit approvals, financial crime risk management and financial reporting. Evolving regulatory requirements have had a significant impact on our approach to model risk management, which poses execution challenges. The adoption of more sophisticated modelling approaches and technology across the industry could also lead to increased model risk.

Mitigating actions

-- We established a model risk management sub-function in the second line of defence to strengthen governance and oversight of this risk type.

-- We enhanced our model risk governance framework while partnering with the business in order to enable more effective management of model risk in a commercial context. As we adopt new modelling technologies, we are updating our model risk management framework and governance standards to help drive the evolution of the overall governance framework to ensure best practice.

Data management

The group currently uses a large number of systems and applications to support key business processes and operations. As a result, we often need to reconcile multiple data sources to reduce the risk of error. HSBC, along with other organisations, also needs to respond to the increasing external and regulatory expectations regarding data privacy and protection capabilities across our customer data systems.

Mitigating actions

-- We continue to improve data quality across a large number of systems globally. Our data management, aggregation and oversight continues to strengthen and enhance the effectiveness of internal systems and processes. We are implementing data controls for critical processes in the 'front-office' systems to improve our data capture at the point of entry. HSBC has achieved its objective of meeting a "largely compliant" rating in support of the Basel Committee for Banking Supervision (BCBS 239) principles.

-- Through the Group's Global Data Management Framework, we have embedded governance processes to proactively monitor the quality of critical customer, product and transaction data and resolving associated data issues in a timely manner. We have also implemented data controls in order to improve the reliability of data used by our customers and staff.

-- To address global data privacy and protection regulations, HSBC is leveraging outcomes from the Global Data Protection Regulations (GDPR) initiative to roll-out and implement a global and consistent data privacy framework, while tailoring it to address any country specific regulations where required.

-- We have also initiated efforts to modernize our data architecture and infrastructure through adoption of big data, cloud, machine learning, advanced analytics and visualization technologies.

 
 Areas of special interest 
 

Process of UK withdrawal from the European Union

The UK is due to formally leave the EU on 29 March 2019. The UK's withdrawal from the EU may adversely affect our operating model and financial results. Before 29 March, the UK and the EU are seeking to finalise the Article 50 Withdrawal Agreement, which will need to be approved by their respective parliaments. A comprehensive trade deal will not be concluded within this time frame. A period of transition until 31 December 2020 has been agreed between the UK and the EU. However, there will be no legal certainty until this is enshrined in the Withdrawal Agreement.

The modalities of the UK's exit from the European Union will likely to have a significant impact on general economic conditions in the UK and the European Union. The UK's future relationship with the EU and its trading relationships with the rest of the world will likely take a number of years to resolve. This may result in a prolonged period of uncertainty, unstable economic conditions and market volatility, including currency fluctuations. Throughout this period of uncertainty, our priority is to support our clients and continue to service them, independent of the outcome of negotiations.

To ensure continuity of service, independent of the outcome of negotiations, our robust contingency plan is based on a scenario whereby the UK leaves the EU without the existing passporting or regulatory equivalence framework that supports cross-border business. HSBC's programme to manage the impact of the UK leaving the EU was set up in 2017 and now has in excess of 1,000 employees covering all businesses and functions. It focuses on four main components: legal entity restructuring, platform build, clients and employees.

Legal entity restructuring

On 1 January 2018, the activities of HSBC Bank plc's branch in Greece were transferred to a new branch of HSBC France ('HBFR') in Greece.

On 1 August 2018, the group transferred two wholly owned subsidiaries, HSBC Bank Polska S.A. and HSBC Institutional Trust Services (Ireland) DAC to its subsidiary, HBFR.

The group currently has branches in seven European Economic Area ('EEA') countries (Belgium, the Netherlands, Luxembourg, Spain, Italy, Ireland and Czech Republic) which rely on passporting out of the UK. Following regulatory approval in 2018, and on the assumption that the UK leaves the EU without the existing passporting or regulatory equivalence framework that supports cross-border business, the branch network is in the process of transferring to HBFR, as HSBC's primary banking entity authorised in the EU.

The transfer of branches is happening in several steps:

   --     establishment of new branches of HBFR 
   --     business transfer to the newly established branches 
   --     de-registration of the group's branches. 

We are on track to complete the business transfer in the first quarter of 2019 and good progress is being made on the operational integration with HBFR of its branches in Belgium, Czech Republic, Luxembourg, the Netherlands, Ireland, Italy and Spain.

Platform build

To accommodate customer migrations and new business after the UK's EU departure, we are expanding and enhancing our product offering and building new capabilities across Europe, where we already have a strong foundation, with a focus on France, the Netherlands and Ireland. Euro clearing capabilities are now available in HBFR and further product launches are planned during the first quarter of 2019.

Potential outcomes arising from the UK's departure from the EU will impact our clients and our employees. Our focus is on mitigating this impact and providing support and guidance throughout the withdrawal process.

Clients

The UK's departure from the EU is likely to have an impact on our clients' operating models including their working capital requirements, investment decisions and financial markets infrastructure access. Our priority is to provide our clients continuity of service and our intention is to minimise the level of change for our customers. However, some of our EEA-incorporated customers will no longer be able to be serviced out of the UK under the scenario planned for and will need to be migrated from the UK to HBFR (or another EEA entity). Relationship Managers are in active dialogue with affected clients and are working with them on an appropriate migration plan, including the timely execution of legal documentation. To provide clients with a better understanding of these implications, we are organising client events and communications.

Employees

The migration of EEA-incorporated clients will require us to strengthen our local teams in Continental Europe, and France in particular. We expect the majority of roles to be filled through hires and we have started a recruitment process. Throughout, our objective is to minimise the level of change for our people and to ensure any transition is as smooth as possible.

Given the scale and capabilities of our existing business in France, which already has more than 8,000 employees, a strong balance sheet and extensive product capabilities, we are well prepared to handle the transfer of activities.

Beyond the transfer of roles to Continental Europe, we are also providing support to our UK employees resident in EEA countries and EEA employees resident in the UK, for example on settlement applications.

Nevertheless, London will continue to be an important global financial centre and the best location for our global headquarters. At 31 December 2018, HSBC employed approximately 39,000 people in the UK.

Across the programme, we have made good progress in terms of ensuring we are prepared for the UK leaving the EU in the first quarter of 2019 under the terms described above, but there remain execution risks, many of them linked to the uncertain outcome of negotiations and potentially tight timelines to implement significant changes to our UK and European operating models.

If these risks materialise, HSBC's clients and employees are likely to be affected. The exact impact on our clients will depend on their individual circumstances and, in a worst case scenario, could include disruption to the provision of products and services.

We have carried out detailed reviews of our credit portfolios to determine those sectors and customers most vulnerable to the UK's exit from the EU. For further details please see 'Impact of UK economic uncertainty on ECL' on page 44.

 
 Risk management 
 

As a provider of banking and financial services, the group actively manages risk as a core part of its day-to-day activities. It continues to maintain a strong liquidity position and is well positioned for the evolving regulatory landscape.

Our risk management framework

An established risk governance framework and ownership structure ensures oversight of, and accountability for, the effective management of risk. The group's risk management framework fosters the continuous monitoring of the risk environment and an integrated evaluation of risks and their interactions. Integral to the group's risk management framework are risk appetite, stress testing and the identification of emerging risks.

The bank's Risk Committee focuses on risk governance and provides a forward-looking view of risks and their mitigation. The Risk Committee is a committee of the Board and has responsibility for oversight and advice to the Board on, inter alia, the bank's risk appetite, tolerance and strategy, systems of risk management, internal control and compliance. Additionally, members of the Risk Committee attend meetings of the Chairman's Nominations and Remuneration Committee at which the alignment of the reward structures to risk appetite is considered.

In carrying out its responsibilities, the Risk Committee is closely supported by the Chief Risk Officer, the Chief Financial Officer, the Head of Internal Audit and the Heads of Compliance, together with other business functions on risks within their respective areas of responsibility.

Three lines of defence

To create a robust control environment to manage risks, we use an activity-based three lines of defence model, whereby the activity a member of staff undertakes drives which line they reside within. This model delineates management accountabilities and responsibilities for risk management and the control environment.

The model underpins our approach to risk management by clarifying responsibility, encouraging collaboration and enabling efficient coordination of risk and control activities. The three lines are summarised below:

-- The first line of defence owns the risks and is responsible for identifying, recording, reporting and managing them, and ensuring that the right controls and assessments are in place to mitigate them.

-- The second line of defence sets the policy and guidelines for managing specific risk areas, provides advice and guidance in relation to the risk, and challenges the first line of defence on effective risk management.

-- The third line of defence is our Internal Audit function, which provides independent and objective assurance of the adequacy of the design and operational effectiveness of the group's risk management framework and control governance process.

Our risk culture

Risk culture refers to HSBC's norms, attitudes and behaviours related to risk awareness, risk taking and risk management.

HSBC has long recognised the importance of a strong risk culture, the fostering of which is a key responsibility of senior executives. Our risk culture is reinforced by the HSBC Values and our Global Standards programme. It is instrumental in aligning the behaviours of individuals with our attitude to assuming and managing risk, which helps to ensure that our risk profile remains in line with our risk appetite.

We use clear and consistent employee communication on risk to convey strategic messages and set the tone from senior management and the Board. We also deploy mandatory training on risk and compliance topics to embed skills and understanding in order to strengthen our risk culture and reinforce the attitude to risk in the behaviour expected of employees, as described in our risk policies.

The risk culture is reinforced by HSBC Group's approach to remuneration. Individual awards, including those for senior executives, are based on compliance with the HSBC Values and the achievement of both financial and non-financial objectives, that are aligned to our risk appetite and global strategy.

Whistleblowing

We operate a global whistleblowing standard, HSBC Confidential, allowing staff to report matters of concern confidentially. We also maintain an external email address for concerns about accounting and internal financial controls or auditing matters (accountingdisclosures@hsbc.com).

For further details, see page 6 of the How we do Business section.

Risk appetite

The group's Risk Appetite Statement describes the types and levels of risk that the group is prepared to accept in executing its strategy. Quantitative and qualitative metrics are assigned to 14 key categories, including: earnings, capital (including leverage measures), liquidity and funding, interest rate risk in the banking book, credit risk, traded risk, operational risk, model risk and regulatory compliance.

Measurement against the metrics:

   --    guides underlying business activity; 
   --    informs risk-adjusted remuneration; 

-- enables the key underlying assumptions to be monitored and, where necessary, adjusted through subsequent business planning cycles; and

   --    promptly identifies business decisions needed to mitigate risk. 

The Risk Appetite Statement is approved by the Board following advice from the Risk Committee. It is part of the annual planning process, in which global businesses, geographical regions and functions are required to articulate their individual risk appetite statements. These are aligned with the group strategy, and provide a risk profile of each global business, region or function in the context of the individual risk categories.

Stress testing

Stress testing is an important tool for banks and regulators to assess vulnerabilities in individual banks and/or the financial banking sector under hypothetical adverse scenarios. The results of stress testing are used to assess banks' resilience to a range of adverse shocks and to assess their capital adequacy.

HSBC Bank plc is subject to regulatory stress testing in several jurisdictions. These requirements are increasing in frequency and granularity. They include the programmes of the Bank of England ('BoE'), Prudential Regulation Authority ('PRA') and the European Banking Authority ('EBA'). Assessment by regulators is on both a quantitative and qualitative basis, the latter focusing on our portfolio quality, data provision, stress testing capability and capital planning processes.

A number of internal macroeconomic and event-driven scenarios specific to the European region were considered and reported to senior management during the course of the year, focusing in particular on the ramifications of various potential scenarios relating to the UK exit from the EU, before and after the successful completion of the ring-fencing of HSBC UK at 1 July 2018. We have worked closely with Group Stress Testing and France to ensure that the impact of the various planned transfers of branches and customers to France, as part of our preparation for the UK's exit from the EU, can be appropriately reflected and modelled in our internal and regulatory stress testing exercises. The group also conducts Reverse Stress Testing. This exercise requires a firm to assess scenarios and circumstances that would render its business model unviable, thereby identifying potential business vulnerabilities.

In 2018, the Group participated in the successful completion of the annual BoE concurrent stress testing exercise. The Annual Cyclical Scenario was materially unchanged from 2017, incorporating a synchronised global downturn affecting Asia and the UK in particular. Financial markets come under severe stress with a reduction in global risk appetite and reductions in market liquidity. The UK experiences a slowdown driven by the downturn in its trading partners, fall in confidence, and a sharp sterling depreciation leading to inflationary pressure on imports. In response monetary policy tightening leads to a steep rise in market and lending interest rates in the UK while global yield curves remain flat.

The BoE published the results of the 2018 Concurrent Stress Test in December 2018, confirming that these tests did not reveal any capital inadequacies for the HSBC Group. At the European level, the results of the EBA 2018 exercise were published in November 2018 and likewise demonstrated HSBC's continuing capital strength.

Our material banking and insurance risks

The material risk types associated with our banking and insurance manufacturing operations are described in the following tables.

 
 Description of risks - banking operations 
 
 Credit risk (see page 26) 
 The risk of               Credit risk                     Credit risk is: 
  financial loss            arises principally               *    measured as the amount that could be lost if a 
  if a customer             from direct                           customer or counterparty fails to make repayments; 
  or counterparty           lending, trade 
  fails to meet             finance and 
  an obligation             leasing business,                *    monitored using various internal risk management 
  under a contract.         but also from                         measures and within limits approved by individuals 
                            certain other                         within a framework of delegated authorities; and 
                            products such 
                            as guarantees 
                            and derivatives.                 *    managed through a robust risk control framework that 
                                                                  outlines clear and consistent policies, principles 
                                                                  and guidance for risk managers. 
------------------------  ------------------------------  ------------------------------------------------------------ 
 Liquidity and funding risk 
  (see page 28) 
 The risk that             Liquidity risk                  Liquidity and funding risk is: 
  we do not have            arises from                     *    measured using a range of different metrics including 
  sufficient financial      mismatches in                        the liquidity coverage ratio and net stable funding 
  resources to              the timing of                        ratio; 
  meet our obligations      cash flows. 
  as they fall              Funding risk 
  due or that               arises when                     *    assessed through the internal liquidity adequacy 
  we can only               illiquid asset                       assessment process ('ILAAP'); 
  do so at an               positions cannot 
  excessive cost.           be funded at 
  Funding Risk              the expected                    *    monitored against the group's liquidity and funding 
  is the risk               terms and when                       risk framework; and 
  that funding              required. 
  considered to 
  be sustainable,                                           *    managed on a stand-alone basis with no reliance on 
  and therefore                                                  any group entity (unless pre-committed) or central 
  used to fund                                                   bank unless this represents routine established 
  assets, is not                                                 business-as-usual market practice. 
  sustainable 
  over time. 
------------------------  ------------------------------  ------------------------------------------------------------ 
 Market risk (see page 28) 
 The risk that             Exposure to                     Market risk is: 
  movements in             market risk                       *    measured using sensitivities, value at risk ('VaR') 
  market factors           is separated                           and stress testing, giving a detailed picture of 
  such as foreign          into two portfolios:                   potential gains and losses for a range of market 
  exchange rates,           *    trading portfolios; and          movements and scenarios, as well as tail risks over 
  interest rates,                                                 specified time horizons; 
  credit spreads, 
  equity prices             *    non-trading portfolios. 
  and commodity                                              *    monitored using VaR, stress testing and other 
  prices will                                                     measures, including the sensitivity of net interest 
  reduce our income        Market risk                            income and the sensitivity of structural foreign 
  or the value             exposures arising                      exchange; and 
  of our portfolios.       from our insurance 
                           operations are 
                           discussed on                      *    managed using risk limits approved by the risk 
                           page 65.                               management meeting ('RMM') and the RMM in various 
                                                                  global businesses. 
------------------------  ------------------------------  ------------------------------------------------------------ 
 Operational risk (see page 
  31) 
 The risk to               Operational                     Operational risk is: 
  achieving our             risk arises                     *    measured using the risk and control assessment 
  strategy or               from day-to-day                      process, which assesses the level of risk and 
  objectives as             operations or                        effectiveness of controls, and is also measured for 
  a result of               external events,                     economic capital management using risk event losses 
  inadequate or             and is relevant                      and scenario analysis; 
  failed internal           to every aspect 
  processes, people         of our business. 
  and systems               Regulatory compliance           *    monitored using key indicators and other internal 
  or from external          risk and financial                   control activities; and 
  events.                   crime compliance 
                            risk are discussed 
                            below.                          *    managed primarily by global business and functional 
                                                                 managers that identify and assess risks, implement 
                                                                 controls to manage them and monitor the effectiveness 
                                                                 of these controls utilising the operational risk 
                                                                 management framework. 
------------------------  ------------------------------  ------------------------------------------------------------ 
 Regulatory compliance risk 
  (see page 31) 
 The risk that             Regulatory compliance           Regulatory compliance risk is: 
  we fail to observe        risk is part                    *    measured by reference to identified metrics, incident 
  the letter and            of operational                       assessments, regulatory feedback and the judgement 
  spirit of all             risk, and arises                     and assessment of our Regulatory Compliance teams; 
  relevant laws,            from the risks 
  codes, rules,             associated with 
  regulations               breaching our                   *    monitored against the first line of defence risk and 
  and standards             duty to customers                    control assessments, the results of the monitoring 
  of good market            and other counterparties,            and control activities of the second line of defence 
  practice, and             inappropriate                        functions, and the results of internal and external 
  incur fines               market conduct                       audits and regulatory inspections; and 
  and penalties             and breaching 
  and suffer damage         other regulatory 
  to our business           standards.                      *    managed by establishing and communicating appropriate 
  as a consequence.                                              policies and procedures, training employees in them, 
                                                                 and monitoring activity to assure their observance. 
                                                                 Proactive risk control and/or remediation work is 
                                                                 undertaken where required. 
------------------------  ------------------------------  ------------------------------------------------------------ 
 Financial crime compliance risk (see page 32) 
 The risk that             Financial crime                 Financial crime compliance risk is: 
  we knowingly              compliance risk                 *    measured by reference to identified metrics, incident 
  or unknowingly            is part of operational               assessments, regulatory feedback and the judgement 
  help parties              risk and arises                      and assessment of our Financial Crime Compliance 
  to commit or              from day-to-day                      teams; 
  to further potentially    banking operations. 
  illegal activity 
  through the                                               *    monitored against our financial crime compliance risk 
  group.                                                         appetite statement and metrics, the results of the 
                                                                 monitoring and control activities of the second line 
                                                                 of defence functions, and the results of internal and 
                                                                 external audits and regulatory inspections; and 
 
 
                                                            *    managed by establishing and communicating appropriate 
                                                                 policies and procedures, training employees in them, 
                                                                 and monitoring activity to ensure their observance. 
                                                                 Proactive risk control and/or remediation work is 
                                                                 undertaken where required. 
------------------------  ------------------------------  ------------------------------------------------------------ 
 
 
 Other material risk 
 
 Reputational risk (see page 34) 
 The risk of          Primary reputational   Reputational risk is: 
  failure to meet      risks arise             *    measured by reference to our reputation as indicated 
  stakeholder          directly from                by our dealings with all relevant stakeholders, 
  expectations         an action or                 including media, regulators, customers and employees; 
  as a result          inaction by 
  of any event,        HSBC, its employees 
  behaviour, action    or associated           *    monitored through a reputational risk management 
  or inaction,         parties that                 framework that is integrated into the group's broader 
  either by the        are not the                  risk management framework; and 
  group itself,        consequence 
  our employees        of another type 
  or those with        of risk. Secondary      *    managed by every member of staff, and covered by a 
  whom we are          reputational                 number of policies and guidelines. There is a clear 
  associated.          risks are those              structure of committees and individuals charged with 
                       arising indirectly           mitigating reputational risk. 
                       and are a result 
                       of a failure 
                       to control any 
                       other risks. 
-------------------  ---------------------  ------------------------------------------------------------- 
 Pension risk (see page 34) 
 The risk of          Pension risk           Pension risk is: 
  increased costs      arises from             *    measured in terms of the schemes' ability to generate 
  to the group         investments                  sufficient funds to meet the cost of their accrued 
  from offering        delivering an                benefits; 
  post-employment      inadequate return, 
  benefit plans        adverse changes 
  to its employees.    in interest             *    monitored through the specific risk appetite that has 
                       rates or inflation,          been developed at HSBC Group and Regional levels; and 
                       or members living 
                       longer than 
                       expected. Pension       *    managed locally through the Pensions Oversight Forum 
                       risk also includes           and ultimately through the RMM. 
                       the operational 
                       and reputational 
                       risk of sponsoring 
                       pension plans. 
-------------------  ---------------------  ------------------------------------------------------------- 
 

Our insurance manufacturing subsidiaries are regulated separately from our banking operations. Risks in our insurance entities are managed using methodologies and processes that are subject to Group oversight. Our insurance operations are also subject to some of the same risks as our banking operations, which are covered by the group's risk management processes.

 
 Description of risks - insurance manufacturing operations 
 
 Financial risk (see page 
  65) 
 Our ability      Exposure to                                                Financial risk is: 
 to effectively   financial risks                                             *    measured (i) for credit risk, in terms of economic 
 match            arises from:                                                     capital and the amount that could be lost if a 
 liabilities       *    market risk affecting the fair values of financial         counterparty fails to make repayments; (ii) for 
 arising under          assets or their future cash flows;                         market risk, in terms of economic capital, internal 
 insurance                                                                         metrics and fluctuations in key financial variables; 
 contracts                                                                         and (iii) for liquidity risk, in terms of internal 
 with the asset    *    credit risk; and                                           metrics, including stressed operational cash flow 
 portfolios                                                                        projections; 
 that 
 back them is      *    liquidity risk of entities not being able to make 
 contingent on          payments to policyholders as they fall due.           *    monitored through a framework of approved limits and 
 the management                                                                    delegated authorities; and 
 of financial 
 risks and the 
 extent to                                                                    *    managed through a robust risk control framework that 
 which                                                                             outlines clear and consistent policies, principles 
 these are                                                                         and guidance. This includes using product design and 
 borne                                                                             asset liability matching and bonus rates. 
 by 
 policyholders. 
---------------  ---------------------------------------------------------  ----------------------------------------------------------- 
 Insurance risk (see page 
  68) 
 The risk that,   The cost of                                                Insurance risk is: 
 over time, the    claims and benefits                                        *    measured in terms of life insurance liabilities and 
 cost of the       can be influenced                                               economic capital allocated to insurance underwriting 
 contract,         by many factors,                                                risk; 
 including         including mortality 
 claims and        and morbidity 
 benefits          experience,                                                *    monitored though a framework of approved limits and 
 may exceed the    as well as lapse                                                delegated authorities; and 
 total amount      and surrender 
 of premiums       rates. 
 and investment                                                               *    managed through a robust risk control framework that 
 income                                                                            outlines clear and consistent policies, principles 
 received.                                                                         and guidance. This includes using product design, 
                                                                                   underwriting, reinsurance and claims-handling 
                                                                                   procedures. 
---------------  ---------------------------------------------------------  ----------------------------------------------------------- 
 

Credit risk management

(Audited)

Of the risks in which we engage, credit risk generates the largest regulatory capital requirements.

The principal objectives of our credit risk management are:

-- to maintain across the group a strong culture of responsible lending and a robust risk policy and control framework;

-- to both partner and challenge Global Businesses in defining, implementing and continually re-evaluating our risk appetite under actual and scenario conditions; and

   --    to ensure there is independent, expert scrutiny of credit risks, their costs and mitigation. 

Within the bank, the Credit Risk function is headed by the European Chief Risk Officer who reports to the Chief Executive Officer, with a functional reporting line to HSBC Group Chief Risk Officer. Its responsibilities are:

-- to formulate credit policy. Compliance, subject to approved dispensations, is mandatory for all operating companies which must develop local credit policies consistent with group policies that very closely reflect Group policy;

-- to guide operating companies on the group's appetite for credit risk exposure to specified market sectors, activities and banking products and controlling exposures to certain higher-risk sectors;

-- to undertake an independent review and objective assessment of risk. Credit risk assesses all credit facilities and exposures over designated limits, prior to the facilities being committed to customers or transactions being undertaken;

   --    to monitor the performance and management of portfolios across the group; 

-- to control exposure to sovereign entities, banks and other financial institutions, as well as debt securities which are not held solely for the purpose of trading;

-- to set policy on large credit exposures, ensuring that concentrations of exposure by counterparty, sector or geography do not become excessive in relation to the group's capital base, and remain within internal and regulatory limits;

-- to maintain and develop the risk rating framework and systems through Model Oversight Committees (MOCs). MOCs are in place to oversee risk rating governance for the wholesale and retail models that are used within the group;

-- to report on retail portfolio performance, high risk portfolios, risk concentrations, large impaired accounts, impairment allowances and stress testing results and recommendations to the group's Risk Management Meeting, the group's Risk Committee and the Board; and

-- to act on behalf of the group as the primary interface for credit-related issues, with the BoE, the PRA, local regulators, rating agencies, analysts and counterparts in major banks and non-bank financial institutions.

Concentration of credit risk exposure

(Audited)

Concentrations of credit risk arise when a number of counterparties or exposures have comparable economic characteristics, or are engaged in similar activities, or operate in the same geographical areas/industry sectors, so that their collective ability to meet contractual obligations is uniformly affected by changes in economic, political or other conditions. The group uses a number of controls and measures to minimise undue concentration of exposure in the group's portfolios across industry, country and customer groups. These include portfolio and counterparty limits, approval and review controls, and stress testing.

Wrong-way risk occurs when a counterparty's exposures are adversely correlated with its credit quality. There are two types of wrong-way risk:

-- general wrong-way risk occurs when the probability of counterparty default is positively correlated with general risk factors such as where the counterparty is resident and/or incorporated in a higher-risk country and seeks to sell a non-domestic currency in exchange for its home currency; and

-- specific wrong-way risk occurs in self-referencing transactions. These are transactions in which exposure is driven by capital or financing instruments issued by the counterparty and occurs where exposure from HSBC's perspective materially increases as the value of the counterparty's capital or financing instruments referenced in the contract decreases. It is HSBC policy that specific wrong-way risk transactions are approved on a case-by-case basis.

We use a range of procedures to monitor and control wrong-way risk, including requiring entities to obtain prior approval before undertaking wrong-way risk transactions outside pre-agreed guidelines.

Credit quality of financial instruments

(Audited)

Our credit risk rating systems and processes differentiate exposures in order to highlight those with greater risk factors and higher potential severity of loss. In the case of individually significant accounts, risk ratings are reviewed regularly and any amendments are implemented promptly. Within the group's retail business, risk is assessed and managed using a wide range of risk and pricing models to generate portfolio data.

Our risk rating system facilitates the internal ratings-based approach under the Basel framework adopted by HSBC Group to support calculation of the minimum credit regulatory capital requirement.

Special attention is paid to problem exposures in order to accelerate remedial action. Where appropriate, operating companies use specialist units to provide customers with support to help them avoid default returning to sound trading wherever possible.

The Credit Review and Risk Identification team reviews the robustness and effectiveness of key management, monitoring and control activities.

Risk rating scales

The Customer Risk Rating ('CRR') 10-grade scale summarises a more granular underlying 23-grade scale of obligor probability of default ('PD'). All distinct HSBC customers are rated using one of these two PD scales, depending on the degree of sophistication of the Basel II approach adopted for the exposure.

Each CRR band is associated with an external rating grade by reference to long-run default rates for that grade, represented by the average of issuer-weighted historical default rates. This mapping between internal and external ratings is an indication only and may vary over time.

The Expected Loss ('EL') 10-grade scale for retail business summarises a more granular underlying EL scale for these customer segments; this combines obligor and facility/product risk factors in a composite measure. For debt securities and certain other financial instruments, external ratings have been aligned to the five quality classifications based upon the mapping of related CRR to external credit grades.

For the purpose of the following disclosure, retail loans which are past due up to 89 days and are not otherwise classified as EL 9 or EL 10, are not disclosed within the EL grade to which they relate, but are separately classified as past due but not impaired. The following tables set out the group's distribution of financial instruments by measures of credit quality.

The five credit quality classifications defined each encompasses a range of granular internal credit rating grades assigned to wholesale and retail lending businesses and the external ratings attributed by external agencies to debt securities.

For debt securities and certain other financial instruments, external ratings have been aligned to the five quality classifications based upon the mapping of related CRR to external credit ratings. The mapping is reviewed on a regular basis and the most recent review resulted in sovereign BBB+ and BBB exposures previously mapped to Credit Quality band 'Good' being mapped to Credit Quality band 'Strong'. Sovereign BB+ and BB exposures previously mapped to Credit Quality band 'Satisfactory' were mapped to Credit Quality band 'Good'. This represents a change in disclosure mapping unrelated to changes in counterparty creditworthiness.

 
 Credit quality classification 
                               Sovereign         Other debt 
                            debt securities      securities           Wholesale lending 
                               and bills          and bills            and derivatives              Retail lending 
                                                                                    12-month 
                                                                                 probability 
                                                                                          of  Internal 
                                    External         External         Internal       default    credit        Expected 
                               credit rating    credit rating    credit rating             %    rating          loss % 
                          ------------------  ---------------  --------------- 
 Quality classification 
------------------------ 
                                                                       CRR1 to                  EL1 to 
 Strong                        BBB and above     A- and above          CRR2(1)     0 - 0.169    EL2(2)       0 - 0.999 
                                                                          CRR3       0.170 -       EL3   1.000 - 4.999 
 Good                             BB to BBB-     BBB+ to BBB-                          0.740 
                                BB- to B and     BB+ to B and          CRR4 to       0.741 -    EL4 to  5.000 - 19.999 
 Satisfactory                        unrated          unrated             CRR5         4.914       EL5 
                                                                       CRR6 to       4.915 -    EL6 to        20.000 - 
 Sub-standard                        B- to C          B- to C             CRR8        99.999       EL8          99.999 
                                                                       CRR9 to           100    EL9 to   100+ or 
 Credit impaired                     Default          Default            CRR10                    EL10    defaulted(3) 
------------------------  ------------------  ---------------  ---------------  ------------  --------  -------------- 
 
   1      Customer risk rating ('CRR'). 
   2      Expected loss ('EL'). 

3 The EL percentage is derived through a combination of Probability of Default ('PD') and Loss Given Default ('LGD') and may exceed 100% in circumstances where the LGD is above 100% reflecting the cost of recoveries.

 
 Quality classification definitions 
   *    'Strong': Exposures demonstrate a strong capacity to 
        meet financial commitments, with negligible or low 
        probability of default and/or low levels of expected 
        loss. 
 
 
   *    'Good': Exposures require closer monitoring and 
        demonstrate a good capacity to meet financial 
        commitments, with low default risk. 
 
 
   *    'Satisfactory': Exposures require closer monitoring 
        and demonstrate an average to fair capacity to meet 
        financial commitments, with moderate default risk. 
 
 
   *    'Sub-standard': Exposures require varying degrees of 
        special attention and default risk is of greater 
        concern. 
 
 
   *    'Credit-impaired': Exposures have been assessed as 
        described in Note 1.2(i) in the Financial Statements. 
============================================================= 
 

Renegotiated loans and forbearance

A range of forbearance strategies are employed to improve the management of customer relationships, maximise collection opportunities and, if possible, avoid default, foreclosure or repossession. They include extended payment terms, a reduction in interest or principal repayments, approved external debt management plans, debt consolidations, the deferral of foreclosures and other forms of loan modifications and

re-ageing.

The group's policies and practices are based on criteria which enable local management to judge whether repayment is likely to continue. These typically provide a customer with terms and conditions that are more favourable than those provided initially. Loan forbearance is only granted in situations where the customer has showed a willingness to repay their loan and is expected to be able to meet the revised obligations.

Refinance risk

Personal lending

Interest--only mortgages lending incorporate bullet payments at the point of final maturity. To reduce refinance risk, an initial on-boarding assessment of customers' affordability is made on a capital repayment basis and every customer has a credible defined repayment strategy. Additionally the customer is contacted at least once during the mortgage term to check the status of the repayment strategy. In situations where it is identified that a borrower is expected not to be able either to repay a bullet/balloon payment then the customer will either default on the repayment or it is likely that the bank may need to apply forbearance to the loan. In either circumstance this gives rise to a loss event and an impairment allowance will be considered where appropriate.

Wholesale lending

Many types of wholesale lending incorporate bullet/balloon payments at the point of final maturity; often, the intention or assumption is that the borrower will take out a new loan to settle the existing debt. Where this is true the term refinance risk refers generally to the possibility that, at the point that such a repayment is due, a borrower cannot refinance by borrowing to repay existing debt. In situations where it is identified that a borrower is expected not to be able either to repay a bullet/balloon payment or to be capable of refinancing their existing debt on commercial terms then the customer will either default on the repayment or it is likely that the bank may need to refinance the loan on terms it would not normally offer in the ordinary course of business. In either circumstance this gives rise to a loss event and an impairment allowance will be considered.

Impairment assessment

(Audited)

For details of our impairment policies on loans and advances and financial investments see Note 1.2(i) on the Financial Statements.

Write-off of loans and advances

(Audited)

For details of our accounting policy on the write-off of loans and advances, see Note 1.2(i) on the Financial Statements.

Personal lending

Property collateral for residential mortgages is repossessed and sold on behalf of the borrower only when all normal debt recovery procedures have been unsuccessful. Any portion of the balance not covered following the realisation of security is written-off. Unsecured personal lending products are normally written off, when there is no realistic prospect of recovery, usually when they reached 180 days past due.

In case of some products, e.g. credit cards, it is common for accounts to be written off at the end of the month in which they fall six months past due. Examples of events which may result in early write-off include bankruptcy, deceased customers, fraud and facilities with small balances.

Wholesale lending

Wholesale loans and advances are written off where normal collection procedures have been unsuccessful to the extent that there appears no realistic prospect of repayment. These procedures may include a referral of the business relationship to a debt recovery company. Debt reorganisation will be considered at all times and may involve, in exceptional circumstances and in the absence of any viable alternative, a partial write-off in exchange for a commitment to repay the remaining balance.

In the event of bankruptcy or analogous proceedings, write-off for both personal and wholesale lending may occur earlier than at the

periods stated above. Collections procedures may continue after write-off.

Liquidity and funding risk management

Details of HSBC's Liquidity and Funding Risk Management Framework ('LFRF') can be found in the group's Pillar 3 document.

HSBC requires all operating entities to comply with HSBC Group's LFRF on a stand-alone basis and to meet regulatory and internal minimum requirements at all times. The liquidity coverage ratio ('LCR') and net stable funding ratio ('NSFR') are key components of the LFRF.

The elements of the LFRF are underpinned by a robust governance framework, the two major elements of which are:

   --    Group, regional and entity level asset and liability management committees ('ALCOs'); and 

-- Annual individual liquidity adequacy assessment process ('ILAAP') used to validate risk tolerance and set risk appetite.

The Group's operating entities are predominantly defined on a country basis to reflect the local management of liquidity and funding. However, where appropriate, this definition may be expanded to cover a consolidated group of legal entities or narrowed to a principal office (branch) of a wider legal entity to reflect the management under internal or regulatory definitions.

The RMM reviews and agrees annually the list of entities it directly oversees and the composition of these entities.

Market risk management

Where appropriate, we apply similar risk management policies and measurement techniques to both trading and non-trading portfolios. Our objective is to manage and control market risk exposures to optimise return on risk while maintaining a market profile consistent with our status as one of the world's largest banking and financial services organisations.

The nature of the hedging and risk mitigation strategies performed across the group corresponds to the market risk management instruments available within each operating jurisdiction. These strategies range from the use of traditional market instruments, such as interest rate swaps, to more sophisticated hedging strategies to address a combination of risk factors arising at portfolio level.

Market risk governance

(Audited)

Market risk is managed and controlled through limits approved by the RMM of HSBC Group Management Board ('GMB') for HSBC Holdings and the global businesses. These limits are allocated across business lines and agreed with HSBC Group's legal entities, including HSBC Bank plc.

The management of market risk is principally undertaken in Markets using risk limits allocated from the risk appetite, which is subject to HSBC Bank plc RMM ratification. Limits are set for portfolios, products and risk types, with market liquidity being a primary factor in determining the level of limits set.

Global Risk is responsible for setting market risk management policies and measurement techniques. Each major operating entity has an independent market risk management and control function which is responsible for measuring market risk exposures in accordance with the policies defined by Global Risk, and monitoring and reporting these exposures against the prescribed limits on a daily basis.

Each operating entity is required to assess the market risks arising on each product in its business and to transfer them to either its local Markets unit for management, to Balance Sheet management books or to separate books managed under the supervision of the local ALCO.

The aim is to ensure that all market risks are consolidated within operations which have the necessary skills, tools, management and governance to manage them professionally. In certain cases where the market risks cannot be fully transferred, the group identifies the impact of varying scenarios on valuations or on net interest income resulting from any residual risk positions.

Model risk is governed through Model Oversight Committees ('MOCs') at the regional and global Wholesale Credit and Market Risk levels. They have direct oversight and approval responsibility for all traded risk models utilised for risk measurement and management and stress testing. The MOCs prioritise the development of models, methodologies and practices used for traded risk management within HSBC Group and ensure that they remain within our risk appetite and business plans. The Markets MOC reports into HSBC Group MOC, which oversees all model risk types at Group level. Group MOC informs HSBC Group RMM about material issues at least on a bi-annual basis. The RMM is HSBC Group's 'Designated Committee' according to regulatory rules and has delegated day-to-day governance of all traded risk models to the Markets MOC.

The control of market risk in the trading and non-trading portfolios is based on a policy restricting individual operations to trading within a list of permissible instruments authorised for each site by Global Risk, enforcing new product approval procedures, and restricting trading in the more complex derivative products only to offices with appropriate levels of product expertise and robust control systems.

Market risk measures

Monitoring and limiting market risk exposures

Our objective is to manage and control market risk exposures while maintaining a market profile consistent with the group's risk appetite.

We use a range of tools to monitor and limit market risk exposures including sensitivity analysis, value at risk ('VaR'), and stress testing.

Sensitivity analysis

Sensitivity analysis measures the impact of individual market factor movements on specific instruments or portfolios, including interest rates, foreign exchange rates, credit spreads and equity prices, such as the effect of a one basis point change in yield. We use sensitivity measures to monitor the market risk positions within each risk type. Sensitivity limits are set for portfolios, products and risk types, with the depth of the market being one of the principal factors in determining the level of limits set.

Value at risk

VaR is a technique that estimates the potential losses on risk positions as a result of movements in market rates and prices over a specified time horizon and to a given level of confidence. The use of VaR is integrated into market risk management and is calculated for all trading positions regardless of how the group capitalises those exposures. Where there is not an approved internal model, the group uses the appropriate local rules to capitalise exposures.

In addition, the group calculates VaR for non-trading portfolios in order to have a complete picture of risk. The models are predominantly based on historical simulation. VaR is calculated at a 99% confidence level for a one-day holding period. Where we do not calculate VaR explicitly, we use alternative tools as summarised in the Market Risk Stress testing section.

The VaR models used by us are based predominantly on historical simulation. These models derive plausible future scenarios from past series of recorded market rates and prices, taking into account inter-relationships between different markets and rates such as interest rates and foreign exchange rates. The models also incorporate the effect of option features on the underlying exposures.

The historical simulation models used incorporate the following features:

-- historical market rates and prices are calculated with reference to foreign exchange rates and commodity prices, interest rates, equity prices and the associated volatilities;

-- potential market movements utilised for VaR are calculated with reference to data from the past two years; and

   --    VaR measures are calculated to a 99% confidence level and use a one-day holding period. 

The nature of the VaR models means that an increase in observed market volatility will most likely lead to an increase in VaR without any changes in the underlying positions.

VaR model limitations

Although a valuable guide to risk, VaR should always be viewed in the context of its limitations. For example:

-- the use of historical data as a proxy for estimating future events may not encompass all potential events, particularly those which are extreme in nature;

-- the use of a holding period assumes that all positions can be liquidated or the risks offset during that period. This may not fully reflect the market risk arising at times of severe illiquidity, when the holding period may be insufficient to liquidate or hedge all positions fully;

-- the use of a 99% confidence level by definition does not take into account losses that might occur beyond this level of confidence; and

-- VaR is calculated on the basis of exposures outstanding at the close of business and therefore does not necessarily reflect intra-day exposures.

Risk not in VaR framework

Other basis risks which are not completely covered in VaR, such as the Libor tenor basis, are complemented by our risk not in VaR ('RNIV') calculations, and are integrated into our capital framework.

Risk factors are reviewed on a regular basis and either incorporated directly in the VaR models, where possible, or quantified through the VaR-based RNIV approach or a stress test approach within the RNIV framework. The outcome of the VaR-based RNIV is included in the VaR calculation and back-testing; a stressed VaR RNIV is also computed for the risk factors considered in the VaR-based RNIV approach.

Stress-type RNIVs include a gap risk exposure measure to capture risk on non-recourse margin loans and a de-peg risk measure to capture risk to pegged and heavily managed currencies.

Stress testing

Stress testing is an important procedure that is integrated into our market risk management tool to evaluate the potential impact on portfolio values of more extreme, although plausible, events or movements in a set of financial variables. In such scenarios, losses can be much greater than those predicted by VaR modelling.

Stress testing is implemented at legal entity, regional and overall Group levels. A standard set of scenarios is utilised consistently across all regions within HSBC Group. Scenarios are tailored to capture the relevant events or market movements at each level. The risk appetite around potential stress losses for the group is set and monitored against referral limits.

Market risk reverse stress tests are undertaken on the premise that there is a fixed loss. The stress testing process identifies which scenarios lead to this loss. The rationale behind the reverse stress test is to understand scenarios which are beyond normal business settings that could have contagion and systemic implications.

Stressed VaR and stress testing, together with reverse stress testing and the management of gap risk, provide management with insights regarding the 'tail risk' beyond VaR for which the group's appetite is limited.

Trading portfolios

Back-testing

We routinely validate the accuracy of our VaR models by back-testing them against both actual and hypothetical profit and loss against the corresponding VaR numbers. Hypothetical profit and loss excludes non-modelled items such as fees, commissions and revenues of intra-day transactions.

We would expect on average to see two or three profits in excess of the VaR at 1% confidence level and two or three losses in excess of VaR at the 99% confidence level over a one-year period. The actual number of profits or losses in excess of VaR over this period can therefore be used to gauge how well the models are performing.

We back-test our VaR at various levels which reflect a full legal entity scope of HSBC, including entities that do not have local permission to use VaR for regulatory purposes.

Non-trading portfolios

Non-trading VaR of HSBC Bank plc includes the interest rate risk of non-trading financial instruments held by the global businesses and transferred into portfolios managed by BSM or ALCM functions. In measuring, monitoring and managing risk in our non-trading portfolios, VaR is just one of the tools used. The management of interest rate risk in the banking book is described further in 'Non-trading interest rate risk' below, including the role of BSM. The group's and HSBC Bank plc's control of market risk in the non-trading portfolios is based on transferring the assessed market risk of non-trading assets and liabilities created outside BSM or Markets, to the books managed by BSM, provided the market risk can be neutralised. The net exposure is typically managed by BSM through the use of fixed rate government bonds (liquid asset held in held-to-collect-and-sale (HTCS books)) and interest rate swaps. The interest rate risk arising from fixed rate government bonds held within HTCS portfolios is reflected within the group's non-traded VaR. Interest rate swaps used by BSM are typically classified as either a fair value hedge or a cash flow hedge and included within the group's non-traded VaR. Any market risk that cannot be neutralised in the market is managed by HSBC Bank plc ALCM in segregated ALCO books.

Structural foreign exchange exposure

Structural foreign exchange exposures represent the group's net investments in subsidiaries, branches and associates, the functional currencies of which are currencies other than sterling. An entity's functional currency is that of the primary economic environment in which the entity operates.

Unrealised gains or losses due to revaluations of structured foreign exchange exposures are recognised in other comprehensive income, whereas other unrealised gains or losses arising from revaluations of foreign exchange positions are reflected in the income statement.

The group's structural foreign exchange exposures are managed with the primary objective of ensuring, where practical, that the group's consolidated capital ratios and the capital ratios of individual banking subsidiaries are largely protected from the effect of changes in exchange rates. We hedge structural foreign exchange exposures only in limited circumstances.

Interest rate risk in the banking book

Overview

Interest Rate Risk in the Banking Book ('IRRBB') is the risk of an adverse impact to earnings or capital due to changes in market interest rates. IRRBB is generated by our non-traded assets and liabilities. The Asset, Liability and Capital Management ('ALCM') function is responsible for measuring and controlling IRRBB under the supervision of the RMM who approve risk limits used in the management of interest rate risk. IRRBB is transferred to and managed by BSM, who are overseen by Wholesale Market Risk and Product Control functions.

Key risk drivers

The bank's IRRBB can be segregated into the following drivers:

-- Managed rate risk - the risk that the pricing of products, which are dependent upon business line decisions, do not correlate to movements in market interest rates.

-- Re-investment risk - risk arising due to change in rates when behaviouralised balances are reinvested as per the transfer pricing policy.

-- Basis risk - the risk arising from assets and liabilities that are priced referencing different market indices creating a repricing mismatch.

-- Prepayment risk - the risk that the actual customer prepayment in different interest rate scenarios does not match the profile used to hedge the interest rate risk.

-- Duration risk - the risk that there are changes in the maturities of assets and liabilities due to changes in interest rate, which create or exacerbate a mismatch.

Governance and structure

ALCM monitors and control non-traded interest rate risk as well as reviewing and challenging the business prior to the release of new products and proposed behavioural assumptions used for hedging activities. ALCM is also responsible for maintaining and updating the transfer pricing framework, informing ALCO of the group's overall banking book interest rate risk exposure and managing the balance sheet in conjunction with BSM.

The internal transfer pricing framework is constructed to ensure that structural interest rate risk, arising due to differences in the repricing timing of assets and liabilities, is transferred to BSM and business lines are correctly allocated income and expense based on the products they write, inclusive of activities to mitigate this risk. Contractual principal repayments, payment schedules, expected prepayments, contractual rate indices used for repricing and interest rate reset dates are examples of elements transferred for risk management by BSM.

The internal transfer pricing framework is governed by ALCO whose responsibility it is to define each operating entity's transfer pricing curve as well as to review and approve the transfer pricing policy, including behaviouralisation assumptions used for products where there is either no defined maturity or where customer optionality exists. ALCO is also responsible for monitoring and reviewing the overall structural interest rate risk position. Interest rate behaviouralisation policies have to be formulated in line with HSBC Group's behaviouralisation policies and approved at least annually by local ALCOs.

Non-traded assets and liabilities are transferred to BSM based on their repricing and maturity characteristics. For assets and liabilities with no defined maturity or repricing characteristics behaviouralisation is used to assess the interest rate risk profile.

BSM manages the banking book interest rate positions transferred to it within the Markets Risk limits approved by RMM. Effective governance across BSM is supported by the dual reporting lines it has to the Chief Executive Officer of GB&M and to the HSBC Group Treasurer. BSM will only receive non-trading assets and liabilities as long as they can economically hedge the risk they receive. Hedging is generally managed through vanilla interest rate derivatives or fixed rate government bonds. Any interest rate risk which BSM cannot economically hedge is not transferred and will remain within the business line where the risk is originated.

Measurement of interest rate risk in the banking book

The following measures are used by ALCM to monitor and control interest rate risk in the banking book including:

   --    non-traded VaR; 
   --    net Interest Income ('NII') sensitivity; and 
   --    economic value of equity ('EVE'). 

Non-traded VaR uses the same models as those used in the trading book but for banking book balances.

NII sensitivity reflects the group's sensitivity of earnings to changes in market interest rates. Entities forecast both one year and five year NII sensitivities across a range of interest rate scenarios based on a static balance sheet assumption. Sites include business line rate pass-on assumptions, re-investment of maturing assets and liabilities at market rates per shock scenario and prepayment risk. BSM is modelled based on no management actions i.e. the risk profile at the month end is assumed to remain constant throughout the forecast horizon.

Net interest income sensitivity

A principal part of our management of non-traded interest rate risk is to monitor the sensitivity of expected NII under varying interest rate scenarios (simulation modelling), where all other economic variables are held constant. This monitoring is undertaken by ALCO.

The group applies a combination of scenarios and assumptions relevant to the businesses as well as applying standard scenarios that are required throughout HSBC Group.

Economic value of equity

EVE represents the present value of the future banking book cash flows that could be distributed to equity providers under a managed run-off scenario, i.e. the current book value of equity plus the present value of future net interest income in this scenario. EVE sensitivity is the extent to which the EVE value will change due to a pre-specified movement in interest rates, where all other economic variables are held constant.

Defined benefit pension scheme

Market risk also arises within the group's defined benefit pension schemes to the extent that the obligations of the schemes are not fully matched by assets with determinable cash flows. Refer to Pension risk section on page 34 for additional information.

Operational risk management

Details of our operational risk profile in 2018 can be found on page 65, in 'Operational risk in 2018'.

Overview

The objective of our operational risk management is to manage and control operational risk in a cost-effective manner within targeted levels of operational risk consistent with our risk appetite.

Key developments in 2018

During 2018 we continued to strengthen our approach to managing operational risk as set out in the operational risk management framework ('ORMF'). The approach sets out governance, appetite and provides an end-to-end view of non-financial risks, enhancing focus on the risks that matter most and associated controls. It incorporates a risk management system to enable active risk management.

Activity to strengthen our risk culture and better embed the approach, particularly the three lines of defence model, continued to be a key focus in 2018. The framework sets out our roles and responsibilities for managing operational risk on a daily basis.

Data relating to HSBC UK Bank plc in the risk management system was separated from HSBC Bank plc in advance of the UK ring-fenced bank going live on 1 July 2018.

In accordance with preparations for the UK's withdrawal from the EU, a number of branches within the European Economic Area have been moved under HSBC France in the risk management system, replicating the proposed legal structure of the bank.

Further information on the three lines of defence model can be found in the 'Our risk management framework' section on

page 23.

Governance and structure

The ORMF defines minimum standards and processes, and the governance structure for the management of operational risk and internal control. The ORMF has been codified in a high-level standards manual, supplemented with detailed policies, which describes our approach to identifying, assessing, monitoring and controlling operational risk and gives guidance on mitigating action to be taken when weaknesses are identified.

We have a dedicated Operational Risk sub-function within our Risk function. It is responsible for leading the embedding of the ORMF, and assuring adherence to associated policies and processes across the first and second lines of defence.

Operational Risk reviews the level of implementation of the ORMF and provides updates on progress to the RMM.

Key risk management processes

Business managers throughout HSBC Group are responsible for maintaining an acceptable level of internal control commensurate with the scale and nature of operations, and for identifying and assessing risks, designing controls and monitoring the effectiveness of these controls. The ORMF helps managers to fulfil these responsibilities by defining a standard risk assessment methodology and providing a tool for the systematic reporting of operational loss data.

A Group-wide risk management system is used to record the results of the operational risk management process. Operational risk and control self-assessments, along with issues and action plans, are entered and maintained by business units. Business and functional management monitor the progress of documented action plans to address shortcomings. To help ensure that operational risk losses are consistently reported and monitored at Group level, all Group companies are required to report individual losses when the net loss is expected to exceed $10,000, and to aggregate all other operational risk losses under $10,000. Losses are entered into the Group-wide risk management system and reported to governance on a monthly basis.

Continuity of business operations

The Operational Risk function undertakes business continuity management, which incorporates the development of a plan including a business impact analysis assessing risk when business disruption occurs.

The group maintains a number of dedicated work area recovery sites globally. Regular testing of these facilities is carried out with representation from each business and support function, to ensure business continuity plans remain accurate, relevant and fit for purpose. Where possible, the group has ensured that its critical business systems are not co-located with business system users, thereby reducing concentration risk.

Regulatory compliance risk management

Overview

The Regulatory Compliance sub-function ('RC') provides independent, objective oversight and challenge, and promotes a compliance-orientated culture that supports the business in delivering fair outcomes for customers, maintaining the integrity of financial markets and achieving HSBC's strategic objectives.

Key developments in 2018

There were no material changes to the policies and practices for the management of RC risk in 2018, except for the following:

-- The HBEU Board maintains oversight of conduct matters following the demise of the Conduct & Values Committee in 2018.

-- We implemented a number of initiatives to raise our standards in relation to the conduct of our business, as described below under 'Conduct of business'.

-- The reporting line of the Global Head of Regulatory Compliance was changed from reporting to the Group Chief Risk Officer to reporting to the Group Chief Compliance Officer from

1 November 2018.

Governance and structure

The Europe Head of RC reports into the Global head of RC. Regulatory Compliance and Financial Crime Risk were integrated into a new Compliance function from 1 November, which is headed by the Group Chief Compliance Officer. RC continues to be structured as a global sub function with regional and country RC teams, which support and advise each global business and global function.

Key risk management processes

We regularly review our policies and procedures. Global policies and procedures require the prompt identification and escalation of any actual or potential regulatory breach to RC. Reportable events are escalated to the bank's RMM and Risk Committee, as appropriate. Matters relating to the Group's regulatory conduct of business are reported to the Group Risk Committee.

Conduct of business

In 2018, we have continued to highlight conduct requirements, as a global principle and elsewhere within the risk management framework, reflecting the individual responsibility and accountability we have for delivery of good conduct outcomes for customers and market integrity. Other key activities in 2018 included:

-- the inclusion of an annual conduct objective in performance management scorecards for executive Directors, Group Managing Directors, Group General Managers and Country CEOs across all regions, business lines, global functions and HSBC Operations Services and Technology. Executive Directors are also now subject to a new separate conduct-focused 'long term incentive' measure;

-- further development of digital products and supporting processes to ensure our digital offerings deliver fair outcomes for customers. Governance and controls continue to be strengthened to ensure they remain fit for purpose as new technology is introduced;

-- enhanced global policy requirements helping customers who are, or may become, vulnerable. Business line-led initiatives in specific markets have addressed support for appointed representatives of vulnerable customers, customers in financial distress, financial inclusion, and a pilot programme of training to help customers with or affected by cancer or dementia; and

-- the delivery of our fourth annual global mandatory training course on conduct for all employees. This is complemented by an ongoing programme of newsletter, intranet and live-streamed communications, internal surveys of staff sentiment regarding progress in delivering good conduct, and conduct awareness campaigns.

Further information on our conduct is provided in the Strategic Report on page 6 and www.hsbc.com/conduct, and for conduct-related costs relating to significant items, see page 13.

Financial crime risk management

Overview

HSBC continues to embed a sustainable financial crime risk management capability. We are making good progress with our financial crime control framework enhancements including the three-year programme to further strengthen the bank's anti-bribery and corruption risk management capability. We have made good progress on completing the actions arising from the 2017 country-by-country assessment of our framework. We also continue to take further steps to refine and strengthen our defences against financial crime by applying advanced analytics and artificial intelligence to improve our ability to identify financial crime risk in our customer population.

Key developments in 2018

During 2018, the group continued to increase its efforts to keep financial crime out of the financial system. We have integrated the majority of the Global Standards programme financial crime risk core capabilities into our day-to-day operations during 2018, and expect to complete the closure of the programme infrastructure in 2019.

We have commenced several initiatives to define the next phase of financial crime risk management and to improve effectiveness through the use of artificial intelligence and applying advanced analytics techniques to achieve an intelligence-led financial crime risk management framework for the future.

Working in partnership is vital to managing financial crime risk. HSBC is a strong proponent of public-private partnerships and information-sharing initiatives. During 2018, FCR created new partnerships in HK and Singapore and continues to mature existing partnerships which include UK Joint Money Laundering Intelligence Task Force, US AML Consortium, Australia and Canada in order to bring further benefit to the bank by enhancing the understanding of financial crime risks.

We have delivered a number of enhancements to our control framework around correspondent banking; developed our operating model to address the move of EEA branches to HSBC France; and strengthened the dedicated Financial Crime Risk sub-function.

Key Risk management processes

During 2018 we embedded a robust financial crime risk management governance framework, mandating Financial Crime Risk Management Committees with a standardised agenda and management information at country, region and global business line levels.

During 2018, we also deployed anti-tax evasion controls and established an AB&C Transformation programme to further enhance the policies and controls around identifying and managing the risks of bribery and corruption across our business. We have delivered improvements to our capabilities to manage AB&C risk in our portfolio of third party service providers by undertaking a data quality remediation of existing relationships and providing targeted training to those managing higher risk relationships. For the longer term we established improved AB&C requirements for the strategic third party relationship management system. We have introduced a Fraud transformation programme to strengthen the anti-fraud capabilities. As of January 2019, the Fraud Risk stewards will become a part of FCC and a Risk and Control Framework review is planned.

We are ensuring we retain a strong link between the bank and HSBC UK Bank plc wherever there is commonality of risk or cross reliance for controls between the entities. We have maintained a single investigation function and continue to share issues of relevance between both the First and Second Line including reviews of the respective entities' governance papers and changes to relevant financial crime policies and procedures.

We are investing in the next generation of capabilities to fight financial crime by applying advanced analytics and artificial intelligence. Our commitment to enhance our risk assessment capabilities remains, aiming to deliver more proactive risk management and improve the customer experience.

The Skilled Person

Following expiration in December 2017 of the AML Deferred Prosecution Agreement entered into with the US Department of Justice ('DoJ'), the then Monitor has continued to work under the Direction issued by the UK Financial Conduct Authority ('FCA') in 2012 in his capacity as a Skilled Person under section 166 of the Financial Services and Markets Act. He has also continued to work in his capacity as an Independent Consultant under the 2012 Cease and Desist Order issued by the US Federal Reserve Board ('FRB'). The Skilled Person and the Independent Consultant will continue working for a period of time at the FCA's and FRB's discretion.

The Skilled Person has assessed HSBC's progress towards being able to effectively manage its financial risk on a business as usual basis. The Skilled Person has issued five country reports and two quarterly reports in 2018. The Skilled Person has noted that HSBC continues to make material progress towards its financial crime risk target end state in terms of key systems, processes and people. Nonetheless, the Skilled Person has identified some areas that require further work before HSBC reaches a business as usual state. The Skilled Person has not highlighted potential instances of financial crime.

The Independent Consultant completed his fifth annual assessment. The Independent Consultant concluded that HSBC continues to make significant strides toward establishing an effective sanctions compliance programme, commending HSBC on a largely successful affiliates remediation exercise. He has, however, determined that that certain areas within HSBC's sanctions compliance programme require further work and, as such, HSBC's sanctions programme does not yet operate in a business-as-usual state. The Independent Consultant has commenced his sixth annual assessment which is due to conclude in March 2019.

Throughout 2018, the Financial System Vulnerabilities Committee ('FSVC') received regular reports on HSBC's relationship with the Skilled Person and Independent Consultant. The FSVC received regular updates on the Skilled Person's and Independent Consultant's reviews and has received the Skilled Person's country and quarterly reports and the Independent Consultant's fifth annual assessment report.

Insurance manufacturing operations risk management

Details of changes in our insurance manufacturing operations risk profile in 2018 can be found on page 65 in 'Insurance manufacturing operations risk in 2018'.

There were no material changes to our policies and practices for the management of risks arising in our insurance manufacturing operations in 2018.

Governance

(Audited)

Insurance risks are managed to a defined risk appetite, which is aligned to the bank's risk appetite and risk management framework, including the three lines of defence model. For details on the governance framework, see page 23. The Group Insurance Risk Management Meeting oversees the control framework globally and is accountable to the RBWM Risk Management Meeting on risk matters relating to the insurance business.

The monitoring of the risks within the insurance operations is carried out by insurance risk teams. Specific risk functions, including Wholesale Credit & Market Risk, Operational Risk, Information Security Risk and Financial Crime Risk, support Insurance Risk teams in their respective areas of expertise.

Stress and scenario testing

(Audited)

Stress testing forms a key part of the risk management framework for the insurance business. We participate in local and group-wide regulatory stress tests, including the Bank of England stress test of the banking system, the European Insurance and Occupational Pensions Authority stress test, and individual country insurance regulatory stress tests.

These have highlighted that a key risk scenario for the insurance business is a prolonged low interest rate environment. In order to mitigate the impact of this scenario, the insurance operations are taking a number of actions including repricing some products to reflect lower interest rates, launching less capital intensive products, investing in more capital efficient assets and developing investment strategies to optimise the expected returns against the cost of economic capital.

Management and mitigation of key risk types

Market risk

All our insurance manufacturing subsidiaries have market risk mandates which specify the investment instruments in which they are permitted to invest and the maximum quantum of market risk which they may retain. They manage market risk by using, among others, some or all of the techniques listed below, depending on the nature of the contracts written:

-- For products with discretionary participating features ('DPF'), adjusting bonus rates to manage the liabilities to policyholders. The effect is that a significant portion of the market risk is borne by the policyholder.

-- Asset and liability matching where asset portfolios are structured to meet projected liability cash flows. The group manages its assets using an approach that considers asset quality, diversification, cash flows matching, liquidity, volatility and target investment return. It is not always possible to match asset and liability durations due to uncertainty over the receipt of all future premiums and the timing of claims, and also because the forecast payment dates of liabilities may exceed the duration of the longest-dated investments available. We use models to assess the effect of a range of future scenarios on the values of assets and associated liabilities, and local ALCOs employ the outcomes in determining how to best structure asset holdings to support liabilities.

-- Using derivatives to protect against adverse market movements or better match liability cash flows.

-- For new products with investment guarantees, considering the cost when determining the level of premiums or the price structure.

-- Periodically reviewing products identified as higher risk, which contain investment guarantees and embedded optionality features linked to savings and investment products, for active management.

-- Designing new products to mitigate market risk, such as changing the investment return sharing between policyholders and the shareholder.

   --    Exiting, to the extent possible, investment portfolios whose risk is considered unacceptable. 
   --    Repricing premiums charged to policyholders. 

Credit risk

Our insurance manufacturing subsidiaries are responsible for the credit risk, quality and performance of their investment portfolios. Our assessment of the creditworthiness of issuers and counterparties is based primarily upon internationally recognised credit ratings and other publicly available information.

Investment credit exposures are monitored against limits by our insurance manufacturing subsidiaries, and are aggregated and reported to HSBC Group Insurance Credit Risk and Group Credit Risk functions. Stress testing is performed on the investment

credit exposures using credit spread sensitivities and default probabilities.

We use a number of tools to manage and monitor credit risk. These include a credit report which contains a watch-list of investments with current credit concerns, primarily investments that may be at risk of future impairment or where high concentrations to counterparties are present in the investment portfolio. The report is circulated monthly to senior management in Group Insurance and the individual country chief risk officers to identify investments which may be at risk of future impairment.

Liquidity risk

Risk is managed by cash flow matching and maintaining sufficient cash resources, investing in high credit-quality investments with deep and liquid markets, monitoring investment concentrations and restricting them where appropriate, and establishing committed contingency borrowing facilities.

Insurance manufacturing subsidiaries are required to complete quarterly liquidity risk reports for HSBC Group Insurance Risk function and an annual review of the liquidity risks to which it is exposed.

Insurance risk

The bank primarily uses the following techniques to manage and mitigate insurance risk:

-- product design, pricing and overall proposition management (for example, management of lapses by introducing surrender charges);

   --    underwriting policy; 
   --    claims management processes; and 

-- reinsurance which cedes risks above our acceptable thresholds to an external reinsurer thereby limiting our exposure.

 
 Other material risks 
 

Reputational risk management

Overview

Reputational risk is the risk of failing to meet stakeholder expectations as a result of any event, behaviour, action or inaction, either by HSBC, our employees or those with whom we are associated. Any material lapse in standards of integrity, compliance, customer service or operating efficiency may represent a potential reputational risk. Stakeholder expectations constantly evolve, and so reputational risk is dynamic and varies between geographical regions, groups and individuals. We have an unwavering commitment to operate at the high standards we set for ourselves in every jurisdiction.

Key developments in 2018

In the second half of 2018, as part of a revised enterprise risk management framework, it was agreed that reputational risk would be classified as a 'transverse' risk, which spans both financial and non-financial risk categories. It was also agreed that the overall risk stewardship for reputational risk would be transferred to a single risk steward, the Group Chief Risk Officer. As a result, the reputational risk policy will be revised and updated in 2019. The governance structure, however, remains unchanged.

Governance and structure

The development of policies and an effective control environment for the identification, assessment, management and mitigation of reputational risk, are considered by the Group Reputational Risk Committee which is chaired by the Group Chief Risk Officer. The focus of the Group Reputational Risk Committee is to consider matters arising from clients or transactions that either present a serious potential reputational risk to the Group or merit a Group-led decision to ensure a consistent risk management approach across the regions, global businesses and global functions. Within HBEU, matters arising from clients, transactions and third parties that present a material reputational risk are considered by the Line Of Business Reputational Risk Client Selection Committees. These committees are responsible for keeping the RMMs apprised of areas and activities presenting significant reputational risk and, where appropriate, for making recommendations to the RMM to mitigate such risk.

Key risk management processes

Our Reputational Risk and Client Selection team oversees the identification, management and control of significant reputational risks across the Region. It is responsible for informing on policies to guide HBEU reputational risk management, devising strategies to protect against reputational risk, and advising the regional businesses and regional functions to help them identify, assess and mitigate such risks, where possible. It is supported by Reputational Risk and CSEM teams in each of the businesses. Each global business has an established reputational risk management governance process. The global functions manage and escalate reputational risks within established operational risk frameworks.

Our policies set out our risk appetite and operational procedures for all areas of reputational risk, including financial crime prevention, regulatory compliance, conduct-related concerns, environmental impacts, human rights matters and employee relations.

For further details of our financial crime risk management and regulatory compliance risk management, see 'Financial crime risk management' on page 32 and 'Regulatory compliance risk management' on page 31 respectively.

Further details can be found on www.hsbc.com.

Pension risk management

There were no material changes to our policies and practices for the management of pension risk in 2018.

Governance and structure

A global pension risk framework and accompanying global policies on the management of risks related to defined benefit and defined contribution plans are in place. Pension risk is managed by a network of local and regional pension risk forums. The group's Europe Pension Oversight Forum is responsible for the governance and oversight of pension plans sponsored by HSBC within its European operations.

Key risk management processes

HSBC provides future pension benefits on a defined contribution basis from many of its European operations. However there remain future defined benefit pensions provided in the region.

In defined contribution pension plans, the contributions that HSBC is required to make are known, while the ultimate pension benefit will vary, typically with investment returns achieved by investment choices made by the employee. While the market risk to HSBC of defined contribution plans is low, the bank is still exposed to operational and reputational risk.

In defined benefit pension plans, the level of pension benefit is known. Therefore, the level of contributions required by HSBC will vary due to a number of risks, including:

   --    investments delivering a return below that required to provide the projected plan benefits; 

-- the prevailing economic environment leading to corporate failures, thus triggering write-downs in asset values (both equity and debt);

-- a change in either interest rates or inflation, causing an increase in the value of the plan liabilities; and

   --    plan members living longer than expected (known as 

longevity risk).

Pension risk is assessed using an economic capital model that takes into account potential variations in these factors. The impact of these variations on both pension assets and pension liabilities is assessed using a one-in-200 year stress test. Scenario analysis and other stress tests are also used to support pension risk management.

To fund the benefits associated with defined benefit plans, sponsoring Group companies, and in some instances employees, make regular contributions in accordance with advice from actuaries and in consultation with the plan's trustees where relevant. These contributions are normally set to ensure that there are sufficient funds to meet the cost of the accruing benefits for the future service of active members. However, higher contributions are required when plan assets are considered insufficient to cover the existing pension liabilities. Contribution rates are typically revised annually or once every three years, depending on the plan.

The defined benefit plans invest contributions in a range of investments designed to limit the risk of assets failing to meet a plan's liabilities. Any changes in expected returns from the investments may also change future contribution requirements. In pursuit of these long-term objectives, an overall target allocation of the defined benefit plan assets between asset classes is established. In addition, each permitted asset class has its own benchmarks, such as stock market or property valuation indices. The benchmarks are reviewed at least once every three to five years and more frequently if required by local legislation or circumstances. The process generally involves an extensive asset and liability review.

 
 Key developments and risk profile 
 

Key developments in 2018

-- We continued to strengthen our operational risks controls, as described on page 65 under 'Operational risk in 2018'.

-- We have integrated the majority of the Global Standards programme financial crime risk core capabilities into our day-to-day operations during 2018, and expect to complete the transition to business and function management in the first half of 2019. We continue to take further steps to refine and strengthen our defences against financial crime by applying advanced analytics and artificial intelligence.

-- IFRS 9 introduced new concepts and measures such as significant increase in credit risk and lifetime expected credit losses ('ECL'). Existing stress testing and regulatory models, skills and expertise were adapted in order to meet IFRS 9 requirements. Data from various client, finance and risk systems has been integrated and validated. As a result of IFRS 9 adoption, management has additional insight and measures not previously utilised which, over time, may influence our risk appetite and risk management processes.

Credit risk in 2018

Credit risk is the risk of financial loss if a customer or counterparty fails to meet an obligation under a contract. Credit risk arises principally from direct lending, trade finance and leasing business, but also from certain other products, such as guarantees and derivatives.

1 January 2018 comparative credit disclosures reflecting the adoption of IFRS 9 have been included where available. 31 December 2017 comparative credit tables, which do not reflect the adoption of IFRS 9, have been disclosed separately on pages 55 to 61, as they are not directly comparable.

Refer to 'Standards applied during the year ended 31 December 2018 on page 97 and Note 34 'Effects of reclassifications upon adoption' of IFRS 9 for further details.

There were no material changes to the policies and practices for the management of credit risk in 2018. A summary of our current policies and practices for the management of credit risk is set out in 'Credit risk management' on page 26.

Gross loans and advances to customers of GBP113bn, as defined by IFRS9, have decreased from GBP277bn at 1 January 2018, predominantly due to the separation of the ring--fenced bank. Loans and advances to banks of GBP14bn have increased from GBP13bn at 1 January 2018; Wholesale and personal lending movements are disclosed on pages 49 to 56.

The change in ECL, as it appears in the income statement, for the period was GBP159m.

Our maximum exposure to credit risk is presented on page 41 and credit quality on page 46. While credit risk arises across most of our balance sheet, losses have typically been incurred on loans and advances and securitisation exposures and other structured products. As a result, our disclosures focus primarily on these two areas.

Summary of credit risk

The disclosure below presents the gross carrying/nominal amount of financial instruments to which the impairment requirements in IFRS 9 are applied and the associated allowance for ECL. Due to the forward-looking nature of IFRS 9, the scope of financial instruments on which ECL is recognised is greater than the scope of IAS 39.

The following tables analyse loans by industry sector and the extent in which they are exposed to credit risks.

The allowance for ECL at 31 December 2018 comprised of GBP1,347m in respect of assets held at amortised cost, GBP83m in respect of loan commitments and financial guarantees, and GBP45m in respect of debt instruments measured at fair value through other comprehensive income ('FVOCI').

 
 Summary of financial instruments to which the impairment requirements 
  in IFRS 9 are applied 
 (Audited) 
                                      ----------------------  -----------  ----------------------  ------------- 
                                                  31 Dec 2018                           At 1 Jan 2018 
                                                                Allowance 
                                      Gross carrying/nominal          for  Gross carrying/nominal      Allowance 
                                                      amount       ECL(1)                  amount     for ECL(1) 
------------------------------------ 
 The group                                              GBPm         GBPm                    GBPm           GBPm 
                                      ----------------------  -----------  ----------------------  ------------- 
 Loans and advances to customers 
  at amortised cost                                  113,306      (1,342)                 276,852      (2,893) 
 - personal                                           23,903        (206)                 120,277        (685) 
 - corporate and commercial                           74,058      (1,106)                 133,742      (2,093) 
 - non-bank financial institutions                    15,345         (30)                  22,833        (115) 
                                      ----------------------  ----------   ----------------------  ---------- 
 Loans and advances to banks at 
  amortised 
  cost                                                13,631          (3)                  13,227          (8) 
                                      ----------------------  ----------   ----------------------  ---------- 
 Other financial assets measured 
  at amortised cost                                  165,525          (2)                 179,750          (2) 
 - cash and balances at central 
  banks                                               52,014          (1)                  97,601          (1) 
 - items in the course of collection 
  from other banks                                       839           -                    2,023           - 
 - reverse repurchase agreements 
  - non trading                                       80,102           -                   45,808           - 
 - financial investments                                  13           -                        6           - 
------------------------------------ 
 - prepayments, accrued income and 
  other assets(2)                                     32,557          (1)                  34,312          (1) 
                                      ----------------------  ---------- 
 Total gross carrying amount on 
  balance 
  sheet                                              292,462      (1,347)                 469,829      (2,903) 
------------------------------------  ----------------------  ----------   ----------------------  ---------- 
 Loans and other credit related 
  commitments                                        141,620         (66)                 167,349        (108) 
------------------------------------  ----------------------  ----------   ----------------------  ---------- 
 - personal                                            2,062           -                   39,462           - 
------------------------------------ 
 - corporate and commercial                           69,119         (65)                  81,323        (105) 
------------------------------------ 
 - financial(3)                                       70,439          (1)                  46,564          (3) 
------------------------------------  ----------------------  ----------   ----------------------  ---------- 
 Financial guarantees (4)                              6,054         (17)                   8,301         (32) 
------------------------------------  ----------------------  ----------   ----------------------  ---------- 
 - personal                                               43           -                       70           - 
 - corporate and commercial                            4,429         (16)                   5,972         (32) 
 - financial                                           1,582          (1)                   2,259           - 
------------------------------------  ----------------------  ----------   ----------------------  ---------- 
 Total nominal amount off balance 
  sheet(5)                                           147,674         (83)                 175,650        (140) 
------------------------------------  ----------------------  ----------   ----------------------  ---------- 
                                                     440,136      (1,430)                 645,479      (3,043) 
------------------------------------  ----------------------  ----------   ----------------------  ---------- 
 
                                                                                                      Memorandum 
                                                               Memorandum                              allowance 
                                                                allowance                                    for 
                                                  Fair value   for ECL(6)              Fair value         ECL(6) 
                                                        GBPm         GBPm                    GBPm           GBPm 
                                                                           ----------------------  ------------- 
 Debt instruments measured at fair 
  value through other comprehensive 
  income ('FVOCI')                                    47,172         (45)                  55,045        (166) 
------------------------------------  ----------------------  ----------   ----------------------  ---------- 
 

1 The total ECL is recognised in the loss allowance for the financial asset unless the total ECL exceeds the gross carrying amount of the financial asset, in which case the ECL is recognised as a provision.

2 Includes only those financial instruments which are subject to the impairment requirements of IFRS 9. 'Prepayments, accrued income and other assets' as presented within the consolidated balance sheet on page 89 includes both financial and non-financial assets.

3 31 December 2017 balances have been restated to include GBP32.5bn of loan commitments (unsettled reverse repurchase agreements) not previously identified for disclosure.

4 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

5 Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.

6 Debt instruments measured at FVOCI continue to be measured at fair value with the allowance for ECL as a memorandum item. Change in ECL is recognised in 'Change in expected credit losses and other credit impairment charges' in the income statement.

 
 Summary of financial instruments to which the impairment requirements 
  in IFRS 9 are applied 
 (Audited) 
                                                             ----------------------  ------------- 
                                                                          31 Dec 2018 
                                                                                         Allowance 
                                                             Gross carrying/nominal            for 
                                                                             amount         ECL(1) 
 The bank                                                                      GBPm           GBPm 
                                                             ----------------------  ------------- 
 Loans and advances to customers at amortised cost                           59,527       (744) 
 - personal                                                                   3,249         (9) 
 - corporate and commercial                                                  39,256       (685) 
 - non-bank financial institutions                                           17,022        (50) 
                                                             ----------------------  --------- 
 Loans and advances to banks at amortised cost                               12,689         (3) 
                                                             ----------------------  --------- 
 Other financial assets measured at amortised cost                          124,544         (1) 
 - cash and balances at central banks                                        40,657          - 
 - items in the course of collection from other banks                           442          - 
 - reverse repurchase agreements - non trading                               56,495          - 
 - financial investments                                                          -          - 
----------------------------------------------------------- 
 - prepayments, accrued income and other assets(2)                           26,950         (1) 
                                                             ----------------------  --------- 
 Total gross carrying amount on balance sheet                               196,760       (748) 
-----------------------------------------------------------  ----------------------  --------- 
 Loans and other credit related commitments                                  61,196        (50) 
-----------------------------------------------------------  ----------------------  --------- 
 - personal                                                                     305          - 
----------------------------------------------------------- 
 - corporate and commercial                                                  33,291        (49) 
----------------------------------------------------------- 
 - financial                                                                 27,600         (1) 
-----------------------------------------------------------  ----------------------  --------- 
 Financial guarantees(3)                                                      5,578        (14) 
-----------------------------------------------------------  ----------------------  --------- 
 - personal                                                                       3          - 
 - corporate and commercial                                                   1,846        (13) 
 - financial                                                                  3,729         (1) 
-----------------------------------------------------------  ----------------------  --------- 
 Total nominal amount off balance sheet(4)                                   66,774        (64) 
-----------------------------------------------------------  ----------------------  --------- 
                                                                            263,534       (812) 
-----------------------------------------------------------  ----------------------  --------- 
 
                                                                                        Memorandum 
                                                                                         allowance 
                                                                         Fair value     for ECL(5) 
                                                                               GBPm           GBPm 
 Debt instruments measured at fair value through 
  other comprehensive income ('FVOCI')                                       26,646         (6) 
-----------------------------------------------------------  ----------------------  --------- 
 

1 The total ECL is recognised in the loss allowance for the financial asset unless the total ECL exceeds the gross carrying amount of the financial asset, in which case the ECL is recognised as a provision.

2 Includes only those financial instruments which are subject to the impairment requirements of IFRS 9. 'Prepayments, accrued income and other assets' as presented within the consolidated balance sheet on page 89 includes both financial and non-financial assets.

3 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

4 Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.

5 Debt instruments measured at FVOCI continue to be measured at fair value with the allowance for ECL as a memorandum item. Change in ECL is recognised in 'Change in expected credit losses and other credit impairment charges' in the income statement.

The following table provides an overview of the banks and group's credit risk by stage and industry, and the associated ECL coverage. The financial assets recorded in each stage have the following characteristics:

-- stage 1: unimpaired and without significant increase in credit risk on which a 12-month allowance for ECL is recognised.

-- stage 2: a significant increase in credit risk has been experienced since initial recognition on which a lifetime ECL is recognised.

-- stage 3: objective evidence of impairment, and are therefore considered to be in default or otherwise credit-impaired on which a lifetime ECL is recognised.

-- purchased or originated credit-impaired ('POCI'): Purchased or originated at a deep discount that reflects the incurred credit losses on which a lifetime ECL is recognised.

 
 Summary of credit risk (excluding debt instruments measured at FVOCI) 
  by stage distribution and ECL coverage by industry sector at 
  31 December 2018 
 (Audited) 
                                              Gross carrying/nominal                        Allowance for 
                                                     amount(2)                                   ECL                               ECL coverage % 
                                                                          -------                                  -------                                ------- 
                                           Stage   Stage  Stage                    Stage  Stage  Stage                      Stage  Stage  Stage 
                                               1       2      3  POCI(3)    Total      1      2      3    POCI(3)    Total      1      2      3  POCI(3)    Total 
 The group                                  GBPm    GBPm   GBPm     GBPm     GBPm   GBPm   GBPm   GBPm       GBPm     GBPm      %      %      %        %        % 
                                                                                                                                                          ------- 
 Loans and 
  advances 
  to customers 
  at amortised 
  cost                                   102,129   8,816  2,244      117  113,306  (121)  (171)  (972)   (78)      (1,342)    0.1    1.9   43.3     66.7    1.2 
                                                                                                                            ----- 
 - personal                               22,170   1,206    527        -   23,903    (9)   (27)  (170)     -         (206)      -    2.2   32.3        -    0.9 
 
   *    corporate and commercial          64,822   7,476  1,643      117   74,058   (99)  (132)  (797)   (78)      (1,106)    0.2    1.8   48.5     66.7    1.5 
 
   *    non-bank financial institutions   15,137     134     74        -   15,345   (13)   (12)    (5)     -          (30)    0.1    9.0    6.8        -    0.2 
--------------------------------------- 
 Loans and 
  advances 
  to banks 
  at amortised 
  cost                                    13,565      66      -        -   13,631    (2)    (1)     -      -           (3)      -    1.5      -        -      - 
--------------------------------------- 
 Other financial 
  assets 
  measured 
  at amortised 
  cost                                   165,496      24      5        -  165,525    (1)     -     (1)     -           (2)      -      -   20.0        -      - 
--------------------------------------- 
 Loan and 
  other credit-related 
  commitments                            136,539   4,827    249        5  141,620   (27)   (26)   (13)     -          (66)      -    0.5    5.2        -      - 
--------------------------------------- 
 - personal                                2,005      54      3        -    2,062     -      -      -      -            -       -      -      -        -      - 
 
   *    corporate and commercial          64,428   4,441    245        5   69,119   (26)   (26)   (13)     -          (65)      -    0.6    5.3        -    0.1 
 - financial                              70,106     332      1        -   70,439    (1)     -      -      -           (1)      -      -      -        -      - 
--------------------------------------- 
 Financial 
  guarantees(1)                            5,423     565     64        2    6,054    (4)    (9)    (4)     -          (17)    0.1    1.6    6.3        -    0.3 
 - personal                                   42       -      1        -       43     -      -      -      -            -       -      -      -        -      - 
 
   *    corporate and commercial           3,866     499     62        2    4,429    (4)    (8)    (4)     -          (16)    0.1    1.6    6.5        -    0.4 
 - financial                               1,515      66      1        -    1,582     -     (1)     -      -           (1)      -    1.5      -        -    0.1 
--------------------------------------- 
 At 31 Dec 
  2018                                   423,152  14,298  2,562      124  440,136  (155)  (207)  (990)   (78)      (1,430)      -    1.4   38.6     62.9    0.3 
---------------------------------------  -------  ------  -----  -------  -------  ----   ----   ----   ----       ------   -----  -----  -----  -------  ----- 
 

1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

2 Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.

   3      Purchased or originated credit-impaired ('POCI'). 

Unless identified at an earlier stage, all financial assets are deemed to have suffered a significant increase in credit risk when they are 30 days past due and are transferred from stage 1 to stage 2. The following disclosure presents the ageing of stage 2 financial assets. It distinguishes those assets that are classified as stage 2 when they are less than 30 days past due (1-29 DPD) from those that are more than 30 DPD (30 and > DPD). Past due financial instruments are those loans where customers have failed to make payments in accordance with the contractual terms of their facilities.

 
 Stage 2 days past due analysis at 31 December 2018 
 (Audited)        Gross carrying amount             Allowance for ECL                   ECL coverage % 
                ------------------------  -------------------------------------  --------------------------- 
                        Of which:                       Of which:                         Of which: 
                           1 to   30 and                                                     1 to 
                 Stage       29        >        Stage         1 to       30 and    Stage       29     30 and 
                     2   DPD(1)   DPD(1)            2    29 DPD(1)     > DPD(1)        2   DPD(1)   > DPD(1) 
 The group        GBPm     GBPm     GBPm         GBPm         GBPm         GBPm     GBPm     GBPm       GBPm 
                ------  -------  -------  -----------  -----------  -----------  -------  -------  --------- 
 Loans and 
  advances 
  to customers 
  at amortised 
  cost:          8,816      117      178     (171)          (3)          (6)         1.9      2.6      3.4 
 - Personal      1,206       80       83      (27)          (2)          (4)         2.2      2.5      4.8 
 - Corporate 
  and 
  commercial     7,476       37       95     (132)          (1)          (2)         1.8      2.7      2.1 
 - Non-bank 
  financial 
  institutions     134        -        -      (12)           -            -          9.0        -        - 
                                                                                          -------  ------- 
 Loans and 
  advances 
  to banks at 
  amortised 
  cost              66        5        -       (1)           -            -          1.5        -        - 
                                                                                          -------  ------- 
 Other 
  financial 
  assets 
  measured at 
  amortised 
  cost              24        -        -        -            -            -            -        -        - 
--------------  ------  -------  -------  -------      -------      -------      -------  -------  ------- 
 

1 Days past due ('DPD') Up-to-date accounts in stage 2 are not shown in amounts presented above.

 
 Summary of credit risk (excluding debt instruments measured at FVOCI) 
  by stage distribution and ECL coverage by industry sector at 
  1 January 2018 
                                                  Gross carrying/nominal 
                                                         amount(3)                             Allowance for ECL                          ECL coverage % 
                                           Stage   Stage  Stage                    Stage  Stage    Stage                      Stage  Stage  Stage 
                                               1       2      3  POCI(4)    Total      1      2        3    POCI(4)    Total      1      2      3  POCI(4)    Total 
 The group                                  GBPm    GBPm   GBPm     GBPm     GBPm   GBPm   GBPm     GBPm       GBPm     GBPm      %      %      %        %        % 
 Loans and 
  advances 
  to customers 
  at amortised 
  cost                                   256,850  14,526  5,063      413  276,852  (401)  (566)  (1,852)   (74)      (2,893)    0.2    3.9   36.6     17.9    1.0 
---------------------------------------  -------  ------  -----  -------  -------  ----   ----   ------   ----       ------   -----  -----  -----  -------  ----- 
 - personal                              115,877   3,153  1,247        -  120,277  (129)  (195)    (361)     -         (685)    0.1    6.2   28.9        -    0.6 
--------------------------------------- 
 
   *    corporate and commercial         118,985  10,699  3,645      413  133,742  (267)  (368)  (1,384)   (74)      (2,093)    0.2    3.4   38.0     17.9    1.6 
--------------------------------------- 
 
   *    non-bank financial institutions   21,988     674    171        -   22,833    (5)    (3)    (107)     -         (115)      -    0.4   62.6        -    0.5 
---------------------------------------  -------  ------  -----  -------  -------  ----   ----   ------   ----  ---  ------   -----  -----  -----  -------  ----- 
 Loans and 
  advances 
  to banks 
  at amortised 
  cost                                    12,966     250     11        -   13,227    (5)    (2)      (1)     -           (8)      -    0.8    9.1        -    0.1 
---------------------------------------  -------  ------  -----  -------  -------  ----   ----   ------   ----  ---  ------   -----  -----  -----  -------  ----- 
 Other financial 
  assets measured 
  at amortised 
  cost                                   179,519     225      4        2  179,750    (2)     -        -      -           (2)      -      -      -        -      - 
 Loan and 
  other credit 
  related commitments                    163,726   3,364    225       34  167,349   (42)   (49)     (17)     -         (108)      -    1.5    7.6        -    0.1 
---------------------------------------  -------  ------  -----  -------  -------  ----   ----   ------   ----  ---  ------   -----  -----  -----  -------  ----- 
 - personal                               39,300     112     50        -   39,462     -      -        -      -            -       -      -      -        -      - 
--------------------------------------- 
 
   *    corporate and commercial          77,932   3,182    175       34   81,323   (40)   (48)     (17)     -         (105)    0.1    1.5    9.7        -    0.1 
--------------------------------------- 
 - financial(1)                           46,494      70      -        -   46,564    (2)    (1)       -      -           (3)      -    1.4      -        -      - 
---------------------------------------  -------  ------  -----  -------  -------  ----   ----   ------   ----  ---  ------   -----  -----  -----  -------  ----- 
 Financial 
  guarantees(2)                            7,595     647     43       16    8,301    (4)    (1)     (27)     -          (32)    0.1    0.2   62.8        -    0.4 
---------------------------------------  -------  ------  -----  -------  -------  ----   ----   ------   ----  ---  ------   -----  -----  -----  -------  ----- 
 - personal                                   69       -      1        -       70     -      -        -      -            -       -      -      -        -      - 
--------------------------------------- 
 
   *    corporate and commercial           5,353     561     42       16    5,972    (4)    (1)     (27)     -          (32)    0.1    0.2   64.3        -    0.5 
--------------------------------------- 
 - financial                               2,173      86      -        -    2,259     -      -        -      -            -       -      -      -        -      - 
---------------------------------------  -------  ------  -----  -------  -------  ----   ----   ------   ----  ---  ------   -----  -----  -----  -------  ----- 
                               At 1 Jan 
                                   2018  620,656  19,012  5,346      465  645,479  (454)  (618)  (1,897)   (74)      (3,043)    0.1    3.3   35.5     15.9    0.5 
---------------------------------------  -------  ------  -----  -------  -------  ----   ----   ------   ----       ------   -----  -----  -----  -------  ----- 
 

1 31 December 2017 balances have been restated to include GBP32.5bn of loan commitments (unsettled reverse repurchase agreements) not previously identified for disclosure.

2 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

3 Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.

   4      Purchased or originated credit-impaired ('POCI'). 
 
 Stage 2 days past due analysis at 1 January 2018 
                                             Gross carrying 
                                                  amount              Allowance for ECL           ECL coverage % 
                                                  Of which:                 Of which:                Of which: 
                                                   1 to  30 and                1 to  30 and           1 to 
                                          Stage      29       >     Stage        29       >  Stage      29    30 and 
                                              2  DPD(1)  DPD(1)         2    DPD(1)  DPD(1)      2  DPD(1)  > DPD(1) 
 The group                                 GBPm    GBPm    GBPm      GBPm      GBPm    GBPm      %       %         % 
                                         ------  ------  ------  --------  --------  ------  -----  ------  -------- 
 Loans and advances 
  to customers at amortised 
  cost                                   14,526     477     590  (566)      (49)       (50)    3.9    10.3     8.5 
                                         ------  ------  ------  ----      ----      -----   -----  ------  ------ 
 - personal                               3,153     411     183  (195)      (36)       (36)    6.2     8.8    19.7 
 
   *    corporate and commercial         10,699      66     405  (368)      (13)       (14)    3.4    19.7     3.5 
 
   *    non-bank financial institutions     674       -       2    (3)        -          -     0.4       -       - 
                                         ------  ------  ------  ----      ----      -----   -----  ------  ------ 
 Loans and advances 
  to banks at amortised 
  cost                                      250       1       2    (2)       (2)         -     0.8   200.0       - 
                                         ------  ------  ------  ----      ----      -----   -----  ------  ------ 
 Other financial assets 
  measured at amortised 
  cost                                      225       1      16     -         -          -       -       -       - 
---------------------------------------  ------  ------  ------  ----      ----      -----   -----  ------  ------ 
 

1 Days past due ('DPD') Up-to-date accounts in stage 2 are not shown in amounts presented above.

 
 Summary of credit risk (excluding debt instruments measured at FVOCI) 
  by stage distribution and ECL coverage by industry sector at 
  31 December 2018 
 (Audited) 
                                             Gross carrying/nominal                        Allowance for 
                                                    amount(2)                                   ECL                             ECL coverage % 
                                                                         -------                                  -----                                ------- 
                                           Stage  Stage  Stage                    Stage  Stage  Stage                    Stage  Stage  Stage 
                                               1      2      3  POCI(3)    Total      1      2      3    POCI(3)  Total      1      2      3  POCI(3)    Total 
 The bank                                   GBPm   GBPm   GBPm     GBPm     GBPm   GBPm   GBPm   GBPm       GBPm   GBPm      %      %      %        %        % 
                                                                                                                                                       ------- 
 Loans and 
  advances 
  to customers 
  at amortised 
  cost                                    52,962  5,477    985      103   59,527   (86)  (122)  (461)   (75)      (744)    0.2    2.2   46.8     72.8    1.2 
                                                                                                                         ----- 
 - personal                                3,134     91     24        -    3,249    (1)    (3)    (5)     -         (9)      -    3.3   20.8        -    0.3 
 
   *    corporate and commercial          32,966  5,292    895      103   39,256   (72)  (108)  (430)   (75)      (685)    0.2    2.0   48.0     72.8    1.7 
 
   *    non-bank financial institutions   16,862     94     66        -   17,022   (13)   (11)   (26)     -        (50)    0.1   11.7   39.4        -    0.3 
--------------------------------------- 
 Loans and 
  advances 
  to banks 
  at amortised 
  cost                                    12,629     60      -        -   12,689    (2)    (1)     -      -         (3)      -    1.7      -        -      - 
--------------------------------------- 
 Other financial 
  assets 
  measured 
  at amortised 
  cost                                   124,521     19      4        -  124,544     -      -     (1)     -         (1)      -      -   25.0        -      - 
--------------------------------------- 
 Loan and 
  other credit-related 
  commitments                             58,162  2,889    141        5   61,197   (24)   (24)    (2)     -        (50)      -    0.8    1.4        -    0.1 
--------------------------------------- 
 - personal                                  302      3      -        -      305     -      -      -      -          -       -      -      -        -      - 
 
   *    corporate and commercial          30,549  2,597    141        5   33,292   (23)   (24)    (2)     -        (49)    0.1    0.9    1.4        -    0.1 
 - financial                              27,311    289      -        -   27,600    (1)     -      -      -         (1)      -      -      -        -      - 
--------------------------------------- 
 Financial 
  guarantees(1)                            5,248    277     53        -    5,578    (3)    (7)    (4)     -        (14)    0.1    2.5    7.5        -    0.3 
 - personal                                    3      -      -        -        3     -      -      -      -          -       -      -      -        -      - 
 
   *    corporate and commercial           1,567    227     52        -    1,846    (3)    (6)    (4)     -        (13)    0.2    2.6    7.7        -    0.7 
 - financial                               3,678     50      1        -    3,729     -     (1)     -      -         (1)      -    2.0      -        -      - 
--------------------------------------- 
 At 31 Dec 
  2018                                   253,522  8,722  1,183      108  263,535  (115)  (154)  (468)   (75)      (812)      -    1.8   39.6     69.4    0.3 
---------------------------------------  -------  -----  -----  -------  -------  ----   ----   ----   ----       ----   -----  -----  -----  -------  ----- 
 

1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

2 Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.

   3      Purchased or originated credit-impaired ('POCI'). 

Unless identified at an earlier stage, all financial assets are deemed to have suffered a significant increase in credit risk when they are 30 days past due and are transferred from stage 1 to stage 2. The following disclosure presents the ageing of stage 2 financial assets. It distinguishes those assets that are classified as stage 2 when they are less than 30 days past due (1-29 DPD) from those that are more than 30 DPD (30 and > DPD). Past due financial instruments are those loans where customers have failed to make payments in accordance with the contractual terms of their facilities.

 
 Stage 2 days past due analysis at 31 December 2018 
 (Audited)        Gross carrying amount           Allowance for ECL                ECL coverage % 
                          Of which:                       Of which:                   Of which: 
                            1 to   30 and                   1 to                        1 to 
                  Stage       29        >         Stage       29    30 and    Stage       29      30 and 
                      2   DPD(1)   DPD(1)             2   DPD(1)  > DPD(1)        2   DPD(1)    > DPD(1) 
 The bank          GBPm     GBPm     GBPm          GBPm     GBPm      GBPm     GBPm     GBPm        GBPm 
                -------  -------  -------  ------------  -------  --------  -------  -------  ---------- 
 Loans and 
  advances 
  to customers 
  at amortised 
  cost:           5,477       20        5     (122)            -         -      2.2        -         - 
 - Personal          91       20        5       (3)            -         -      3.3        -         - 
 - Corporate 
  and 
  commercial      5,292        -        -     (108)            -         -      2.0        -         - 
 - Non-bank 
  financial 
  institutions       94        -        -      (11)            -         -     11.7        -         - 
                                                                                     -------  -------- 
 Loans and 
  advances 
  to banks at 
  amortised 
  cost               60        -        -       (1)            -         -      1.7        -         - 
                                                                                     -------  -------- 
 Other 
  financial 
  assets 
  measured at 
  amortised 
  cost               19        -        -        -             -         -        -        -         - 
--------------  -------  -------  -------  -------  ---  -------  --------  -------  -------  -------- 
 

1 Days past due ('DPD') Up-to-date accounts in stage 2 are not shown in amounts presented above.

Credit exposure

Maximum exposure to credit risk

(Audited)

The following table provides information on balance sheet items, offsets, and loan and other credit-related commitments.

The offset on derivatives remains in line with the movements in maximum exposure amounts.

 
 'Maximum exposure to credit risk' 
  table 
  The following table presents our 
  maximum exposure before taking account 
  of any collateral held or other 
  credit enhancements (unless such 
  enhancements meet accounting offsetting 
  requirements). The table excludes 
  financial instruments whose carrying 
  amount best represents the net exposure 
  to credit risk and it excludes equity 
  securities as they are not subject 
  to credit risk. For the financial 
  assets recognised on the balance 
  sheet, the maximum exposure to credit 
  risk equals their carrying amount; 
  for financial guarantees and other 
  guarantees granted, it is the maximum 
  amount that we would have to pay 
  if the guarantees were called upon. 
  For loan commitments and other credit-related 
  commitments, it is generally the 
  full amount of the committed facilities. 
  The offset in the table relates 
  to amounts where there is a legally 
  enforceable right of offset in the 
  event of counterparty default and 
  where, as a result, there is a net 
  exposure for credit risk purposes. 
  However, as there is no intention 
  to settle these balances on a net 
  basis under normal circumstances, 
  they do not qualify for net presentation 
  for accounting purposes. No offset 
  has been applied to off-balance 
  sheet collateral. In the case of 
  derivatives the offset column also 
  includes collateral received in 
  cash and other financial assets. 
=============================================== 
 

Other credit risk mitigants

While not disclosed as an offset in the following 'Maximum exposure to credit risk' table, other arrangements are in place which reduce our maximum exposure to credit risk. These include a charge over collateral on borrowers' specific assets such as residential properties, collateral held in the form of financial instruments that are not held on balance sheet and short positions in securities. In addition, for financial assets held as part of linked insurance/investment contracts the risk is predominantly borne by the policyholder. See Note 28 on the Financial Statements for further details of collateral in respect of certain loans and advances and derivatives.

 
 Maximum exposure to credit risk 
 (Audited) 
                                                       Maximum 
                                                      exposure     Offset        Net 
 The group                                                GBPm       GBPm       GBPm 
 Loans and advances to customers held at amortised 
  cost                                                 111,964   (12,579)   99,385 
                                                     ---------  --------   ------- 
 - personal                                             23,697         -    23,697 
 - corporate and commercial                             72,952   (10,610)   62,342 
 - non-bank financial institutions                      15,315    (1,969)   13,346 
                                                     ---------  --------   ------- 
 Loans and advances to banks at amortised cost          13,628       (12)   13,616 
                                                     ---------  --------   ------- 
 Other financial assets held at amortised cost         165,793   (17,065)  148,728 
---------------------------------------------------  ---------  --------   ------- 
 - cash and balances at central banks                   52,013         -    52,013 
--------------------------------------------------- 
 - items in the course of collection from other 
  banks                                                    839         -       839 
--------------------------------------------------- 
 - reverse repurchase agreements - non trading          80,102   (17,065)   63,037 
--------------------------------------------------- 
 - financial investments                                    13         -        13 
--------------------------------------------------- 
 - prepayments, accrued income and other assets         32,826         -    32,826 
---------------------------------------------------  ---------  --------   ------- 
 Derivatives                                           144,522  (140,644)    3,878 
---------------------------------------------------  ---------  --------   ------- 
 Total on balance sheet exposure to credit risk        435,907  (170,300)  265,607 
---------------------------------------------------  ---------  --------   ------- 
 Total off-balance sheet                               172,073         -   172,073 
---------------------------------------------------  ---------  --------   ------- 
 - financial and other guarantees(1)                    23,244         -    23,244 
--------------------------------------------------- 
 - loan and other credit-related commitments           148,829         -   148,829 
---------------------------------------------------  ---------  --------   ------- 
 31 Dec 2018                                           607,980  (170,300)  437,680 
---------------------------------------------------  ---------  --------   ------- 
 
 
 The bank                                               GBPm       GBPm       GBPm 
 Loans and advances to customers held at amortised 
  cost                                                58,783   (20,045)   38,738 
                                                     -------  --------   ------- 
 - personal                                            3,240         -     3,240 
 - corporate and commercial                           38,571   (10,610)   27,961 
 - non-bank financial institutions                    16,972    (9,435)    7,537 
                                                     -------  --------   ------- 
 Loans and advances to banks at amortised cost        12,686       (22)   12,664 
                                                     -------  --------   ------- 
 Other financial assets held at amortised cost       124,815   (13,401)  111,414 
                                                     -------  --------   ------- 
 - cash and balances at central banks                 40,657         -    40,657 
 - items in the course of collection from other 
  banks                                                  442         -       442 
 - reverse repurchase agreements - non trading        56,495   (13,401)   43,094 
 - financial investments                                   -         -         - 
 - prepayments, accrued income and other assets       27,221         -    27,221 
                                                     -------  --------   ------- 
 Derivatives                                         139,229  (137,504)    1,725 
                                                     -------  --------   ------- 
 Total on balance sheet exposure to credit risk      335,513  (170,972)  164,541 
---------------------------------------------------  -------  --------   ------- 
 Total off-balance sheet                              81,748         -    81,748 
                                                     -------  --------   ------- 
 - financial and other guarantees(1)                  15,860         -    15,860 
--------------------------------------------------- 
 - loan and other credit-related commitments          65,888         -    65,888 
---------------------------------------------------  -------  --------   ------- 
 31 Dec 2018                                         417,261  (170,972)  246,289 
---------------------------------------------------  -------  --------   ------- 
 

1 'Financial and other guarantees' represents 'Financial guarantees' and 'Performance and other guarantees' as disclosed in Note 30.

Concentration of exposure

The geographical diversification of our lending portfolio, and our broad range of global businesses and products, ensured that we did not overly depend on a few markets or businesses to generate growth in 2018.

For an analysis of:

   --    financial investments, see Note 15 on the Financial Statements; 
   --    trading assets, see Note 10 on the Financial Statements; 
   --    derivatives, see page 52 and Note 14 on the Financial Statements; and 

-- loans and advances by industry sector and by the location of the principal operations of the lending subsidiary or by the location of the lending branch, see page 50 for wholesale lending and page 52 for personal lending.

Credit deterioration of financial instruments

(Audited)

A summary of our current policies and practices regarding the identification, treatment and measurement of stage 1, stage 2 and stage 3 (credit impaired) and POCI financial instruments can be found in note 1.2 of the financial statements.

 
 Measurement uncertainty and sensitivity 
  analysis of ECL estimates 
 

Expected credit loss impairment allowances recognised in the financial statements reflect the effect of a range of possible economic outcomes, calculated on a probability-weighted basis, based on the economic scenarios described below. The recognition and measurement of expected credit losses ('ECL') involves the use of significant judgement and estimation. It is necessary to formulate multiple forward-looking economic forecasts and incorporate them into the ECL estimates. HSBC uses a standard framework to form economic scenarios to reflect assumptions about future economic conditions, supplemented with the use of management judgement, which may result in using alternative or additional economic scenarios and/or management adjustments.

Methodology

HSBC has adopted the use of three scenarios, representative of our view of forecast economic conditions, sufficient to calculate unbiased expected loss in most economic environments. They represent a 'most likely outcome' (the Central scenario), and two, less likely 'outer' scenarios, referred to as the Upside and Downside scenarios. Each outer scenario is consistent with a probability of 10%, while the Central scenario is assigned the remaining 80%, according to the decision of HSBC's senior management. This weighting scheme is deemed appropriate for the unbiased estimation of ECL in most circumstances. Key scenario assumptions are set using the average of forecasts of external economists, helping to ensure that the IFRS 9 scenarios are unbiased and maximise the use of independent information. The Central, Upside and Downside scenarios selected with reference to external forecast distributions using the above approach are termed the 'consensus economic scenarios'.

For the Central scenario, HSBC sets key assumptions such as GDP growth, inflation, unemployment and policy interest rates, using either the average of external forecasts (commonly referred to as consensus forecasts) for most economies, or market prices. An external provider's global macro model, conditioned to follow the consensus forecasts, projects the other paths required as inputs to credit models. This external provider is subject to HSBC's risk governance framework, with oversight by a specialist internal unit.

The Upside and Downside scenarios are designed to be cyclical, in that GDP growth, inflation and unemployment usually revert back to the Central scenario after the first three years for major economies. We determine the maximum divergence of GDP growth from the Central scenario using the 10th and the 90th percentile of the entire distribution of forecast outcomes for major economies. While key economic variables are set with reference to external distributional forecasts, we also align the overall narrative of the scenarios to the macroeconomic risks described in HSBC's 'Top and emerging risks' on 20. This ensures that scenarios remain consistent with the more qualitative assessment of these risks. We project additional variable paths using the external provider's global macro model.

We apply the following steps to generate the three economic scenarios:

-- Economic risk assessment: We develop a shortlist of the upside and downside economic and political risks most relevant to HSBC and the IFRS 9 measurement objective.

-- Scenario generation: For the Central scenario, we obtain a pre-defined set of economic paths from the average taken from the consensus survey of professional forecasters. Paths for the two outer scenarios are benchmarked to the Central scenario and reflect the economic risk assessment. We select scenarios that in management's judgement are representative of the probability weighting scheme, informed by the current economic outlook, data analysis of past recessions, and transitions in and out of recession. The key assumptions made, and the accompanying paths, represent our "best estimate" of a scenario at a specified probability. Suitable narratives are developed for the Central scenario and the paths of the two outer scenarios.

-- Variable enrichment: We expand each scenario through enrichment of variables. This includes the production of more than 400 variables that are required to calculate ECL. The external provider expands these scenarios by using as inputs the agreed scenario narratives and the variables aligned to these narratives. Scenarios, once expanded, continue to be benchmarked to latest events and information. Late breaking events could lead to revision of scenarios to reflect management judgement.

The Upside and Downside scenarios are generated at year-end and are only updated during the year if economic conditions change significantly. The Central scenario is generated every quarter. In quarters where only the Central scenario is updated, outer scenarios for use in Wholesale are adjusted such that the relationship between the Central scenario and outer scenarios in the quarter is consistent with that observed at the last full scenario generation. In Retail, three scenarios are run annually to establish the effect of multiple scenarios for each portfolio. This effect is then applied in each quarter with the understanding that the non-linearity of response to economic conditions should not change, unless a significant change in economic conditions occurs.

HSBC recognises that the consensus economic scenario approach, using three scenarios, will be insufficient in certain economic environments. Additional analysis may be requested at management's discretion. This may result in a change in the weighting scheme assigned to the three scenarios or the inclusion of extra scenarios. We anticipate that there will be only limited instances when the standard approach will not apply. We invoked this additional step on 1 January 2018, due to the specific uncertainties facing the UK economy at that time, resulting in the recognition of additional ECL through a management adjustment for economic uncertainty. During 2018 we maintained additional ECL impairment allowances for the UK.

Description of Consensus Central Scenarios

The Consensus Central Scenario

HSBC's central scenario is one of moderate growth over the forecast period 2019-2023. Global GDP growth is expected to be 2.9% on average over the period, which is marginally higher than the average growth rate over the period 2013-2017. Across the key markets, we note that:

-- Expected average rates of GDP growth over the 2019-2023 period are lower than average growth rates achieved over the 2013-2017 period for the UK which reflects expectations that the long-term impact of current economic uncertainty will be moderately adverse.

-- The average unemployment rate over the projection horizon is expected to remain at or below the averages observed in the 2013 -2017 period across all of our major markets.

-- Inflation is expected to be stable despite steady GDP growth and strong labour markets and will remain close to central bank targets in our core markets over the forecast period.

   --    Major central banks are expected to gradually raise their main policy interest rate. 

-- The West Texas Intermediate oil price is forecast to average $63 per barrel over the projection period.

The following table describes key macroeconomic variables and the probabilities assigned in the Consensus Central scenario.

 
 Consensus Central scenario (average 
  2019-2023) 
                                  UK    France 
                                ----  -------- 
 GDP growth rate (%)             1.7     1.5 
 Inflation (%)                   2.1     1.7 
 Unemployment (%)                4.5     7.8 
 Short Term Interest rate 
  (%)                            1.2     0.2 
------------------------------ 
 10 year Treasury bond yields 
  (%)                            2.6     2.0 
------------------------------ 
 House price growth (%)          2.9     1.7 
------------------------------ 
 Equity price growth (%)         3.2     3.1 
------------------------------ 
 Probability (%)                50.0    80.0 
------------------------------  ----  ------ 
 

The Consensus Upside scenario

The economic forecast distribution of risks (as captured by consensus probability distributions of GDP growth) has shown a marginal increase in upside risks for the eurozone, but a decrease of the same for the UK over the course of 2018. Globally, real GDP growth rises in the first two years of the Upside scenario before converging to the Central scenario. Increased confidence, de-escalation of trade tensions and removal of trade barriers, expansionary fiscal policy, positive resolution of economic uncertainty in the UK, stronger oil prices as well as calming of geopolitical tensions are the risk themes that support the 2018 year-end upside scenario.

The following table describes key macroeconomic variables and the probabilities assigned in the Consensus Upside scenario.

 
 Consensus Upside scenario (average 
  2019-2023) 
                                  UK    France 
                                ----  -------- 
 GDP growth rate (%)             2.2     1.9 
 Inflation (%)                   2.3     2.0 
 Unemployment (%)                4.2     7.4 
 Short term interest rate 
  (%)                            1.3     0.2 
------------------------------ 
 10-year treasury bond yields 
  (%)                            2.7     2.0 
------------------------------ 
 House price growth (%)          4.1     2.3 
------------------------------ 
 Equity price growth (%)         6.0     7.3 
------------------------------ 
 Probability (%)                10.0    10.0 
------------------------------  ----  ------ 
 

The Consensus Downside scenario

The distribution of risks (as captured by consensus probability distributions of GDP growth) were broadly stable for the eurozone and the UK (but see discussion on UK economic uncertainty below). Globally, real GDP growth declines for two years in the Downside scenario before recovering to the Central scenario. House price growth either stalls or contracts and equity markets correct abruptly in our major markets. The global slowdown in demand drives commodity prices lower and results in an accompanying fall in inflation. Central Banks remain accommodative. This is consistent with the key risk themes of the downside, such as an intensification of global protectionism and trade barriers, faster than expected tightening of the Fed policy rate, a worsening of economic uncertainty in the UK, China choosing to rebalance with stringent measures, and weaker commodity prices.

The following table describes key macroeconomic variables and the probabilities assigned in the Consensus Downside scenario.

 
 Consensus Downside scenario (average 
  2019-2023) 
                                   UK    France 
                                -----  -------- 
 GDP growth rate (%)             1.1     1.1 
 Inflation (%)                   1.7     1.3 
 Unemployment (%)                4.8     8.2 
 Short Term Interest rate 
  (%)                            0.3    (0.3) 
------------------------------ 
 10 year Treasury bond yields 
  (%)                            1.6     0.9 
------------------------------ 
 House price growth (%)          1.0    (1.3) 
------------------------------ 
 Equity price growth (%)        (0.2)   (2.4) 
------------------------------ 
 Probability (%)                   -    10.0 
------------------------------  ----   ----- 
 

Alternative Downside scenarios

UK economic uncertainty

A number of events occurred over the course of 2018 that led management to re-evaluate the shape of the consensus distribution for the UK. Given the challenges facing economic forecasters in this environment, management was concerned that this distribution did not adequately represent downside risks for the UK. The high level of economic uncertainty that prevailed at the end of 2018, including the lack of progress in agreeing a clear plan for an exit from the EU and the uncertain performance of the UK economy after an exit, was a key factor in this consideration. In management's view, the extent of this uncertainty justifies the use of the following Alternative Downside scenarios, used in place of the consensus downside, with the assigned probabilities:

Alternative Downside scenario 1 (AD1): Economic uncertainty could have a large impact on the UK economy resulting in a long lasting recession with a weak recovery. This scenario reflects the consequences of such a recession with an initial risk-premium shock and weaker long-run productivity growth. This scenario has been used with a 30% weighting.

Alternative Downside scenario 2 (AD2): This scenario reflects the possibility that economic uncertainty could result in a deep cyclical shock triggering a steep depreciation in sterling, a sharp increase in inflation and an associated monetary policy response. This represents a tail risk and has been assigned a 5% weighting.

Alternative Downside scenario 3 (AD3): This scenario reflects the possibility that the adverse impact associated with economic uncertainty currently in the UK could manifest over a far longer period of time with the worst effects occurring later than in the above two scenarios. This scenario is also considered a tail risk and has been assigned a 5% weighting.

The table below describes key macroeconomic variables and the probabilities for each of the Alternative Downside scenarios:

 
 Average 2019-2023 
                         Alternative    Alternative    Alternative 
                            Downside       Downside       Downside 
                            scenario       scenario       scenario 
                                   1              2              3 
 GDP growth rate 
  (%)                        0.5           (0.1)          (0.7) 
 Inflation (%)               2.2            2.4            2.7 
 Unemployment 
  (%)                        6.5            8.0            7.7 
 Short term interest 
  rate (%)                   0.4            2.5            2.5 
--------------------- 
 10-year treasury 
  bond yields (%)            1.8            4.0            4.0 
 House price growth 
  (%)                       (1.5)          (3.3)          (4.8) 
 Equity price 
  growth (%)                (0.9)          (2.3)          (7.5) 
 Probability (%)            30.0            5.0            5.0 
---------------------  ---------      ---------      --------- 
 

The conditions which resulted in departure from the consensus economic forecasts will be reviewed regularly as economic conditions change in future to determine whether this adjustment continues to be necessary.

How economic scenarios are reflected in the wholesale calculation of ECL

HSBC has developed a globally consistent methodology for the application of economic scenarios into the calculation of ECL by incorporating those scenarios into the estimation of the term structure of probability of default ('PD') and loss given default ('LGD'). For PDs, we consider the correlation of economic guidance to default rates for a particular industry in a country. For LGD calculations we consider the correlation of economic guidance to collateral values and realisation rates for a particular country and industry. PDs and LGDs are estimated for the entire term structure of each instrument.

For impaired loans, LGD estimates take into account independent recovery valuations provided by external consultants where available, or internal forecasts corresponding to anticipated economic conditions and individual company conditions. In estimating the ECL on impaired loans that are individually considered not to be significant, HSBC incorporates economic scenarios proportionate to the probability-weighted outcome and the central scenario outcome for non-stage 3 populations.

How economic scenarios are reflected in the retail calculation of ECL

HSBC has developed and implemented a globally consistent methodology for incorporating forecasts of economic conditions into ECL estimates. The impact of economic scenarios on PD is modelled at a portfolio level. Historical relationships between observed default rates and macroeconomic variables are integrated into IFRS 9 ECL estimates by leveraging economic response models. The impact of these scenarios on PD is modelled over a period equal to the remaining maturity of underlying asset or assets. The impact on LGD is modelled for mortgage portfolios by forecasting future loan-to-value ('LTV') profiles for the remaining maturity of the asset by leveraging national level forecasts of the house price index ('HPI') and applying the corresponding LGD expectation.

Impact of UK economic uncertainty on ECL

In light of UK economic uncertainty at 31 December 2018, management made an adjustment that increased ECL allowances in the UK by GBP64m, of which GBP62m was attributed to GB&M and GBP2m to CMB. The adjustment represents incremental ECL based on a probability-weighted distribution of the upside (10%), consensus (50%) and alternative downside scenarios (40% combined).

In its assessment of events after the balance sheet date, HSBC considered, among others, the events related to the process of the UK's withdrawal from the European Union that occurred between 31 December 2018 and the date when the financial statements were authorised for issue, and concluded that no adjustments to the financial statements were required.

Economic scenarios sensitivity analysis of ECL estimates

The ECL outcome is sensitive to judgement and estimations made with regards to the formulation and incorporation of multiple forward-looking economic forecasts described above. As a result, management assessed and considered the sensitivity of the ECL outcome against the forward-looking economic conditions as part of the ECL governance process by recalculating the ECL under each scenario described above for selected portfolios, applying a 100% weighting to each scenario in turn. The weighting is reflected in both the determination of significant increase in credit risk as well as the measurement of the resulting ECL. The ECL relating to Wholesale defaulted obligors reflects a combination of anticipated economic conditions, independent recovery valuations and factors specific to the defaulted corporate. For wholesale credit risk exposures, the sensitivity analysis excludes ECL and financial instruments related to defaulted obligors because the measurement of ECL is relatively more sensitive to credit factors specific to the obligor than future economic scenarios.

The economic scenarios are generated to capture HSBC's view of a range of possible forecast economic conditions that is sufficient for the calculation of unbiased and probability-weighted ECL. Therefore, the ECL calculated for each of the scenarios represent a range of possible outcomes that have been evaluated to estimate ECL. As a result, the ECL calculated for the Upside and Downside scenarios should not be taken to represent the upper and lower limits of possible actual ECL outcomes. There is a high degree of estimation uncertainty in numbers representing tail risk scenarios when assigned a 100% weighting, and an indicative range is provided for the UK tail risk sensitivity analysis. A wider range of possible ECL outcomes reflects uncertainty about the distribution of economic conditions and does not necessarily mean that credit risk on the associated loans is higher than for loans where the distribution of possible future economic conditions is narrower. The recalculated ECL for each of the scenarios should be read in the context of the sensitivity analysis as a whole and in conjunction with the narrative disclosures provided below.

ECL under each scenario is given in dollar terms and as a percentage of the gross carrying amount (and, for wholesale lending, the nominal amount for related loan commitments and financial guarantees).

Wholesale analysis

 
 IFRS 9 ECL sensitivity to future 
  economic conditions(1) 
                                       UK    France 
 ECL Coverage of Loans 
  and Advances to Customers 
  at 31 December 2018 
--------------------------------- 
 Reported ECL (GBPm)                  218        36 
                                           -------- 
 Gross carrying/nominal 
  amount (GBPm)                    98,450    49,725 
                                   ------  -------- 
 Reported ECL Coverage 
  (%)                                0.22    0.07 
                                   ------  ------ 
 Coverage Ratios by Scenario 
  (%): 
                                   ------ 
 Consensus central scenario          0.16    0.07 
                                   ------  ------ 
 Consensus upside scenario           0.14    0.07 
                                   ------  ------ 
 Consensus downside scenario         0.18     0.1 
                                   ------  ------ 
 Coverage ratios for alternative 
  scenarios 
 UK AD 1                             0.22 
---------------------------------  ------  -------- 
 UK AD 2                             0.39 
---------------------------------  ------  -------- 
 UK AD 3                             0.35 
---------------------------------  ------  -------- 
 
 Alternative scenarios 
  ECL 
---------------------------------  ------  -------- 
 AD1                                  213 
---------------------------------  ------  -------- 
 Tail risk scenarios (UK              384 
  AD 2-3)                           - 341 
---------------------------------  ------  -------- 
 

1 Excludes ECL and Drawn Amounts related to defaulted obligors

ECL coverage rates reflect the underlying observed credit defaults, the sensitivity to economic environment, extent of security and the effective maturity of the book. The additional scenarios for UK economic uncertainty could, if they occurred, increase ECL coverage by between 13 to 17 basis points compared with reported ECL for loans and advances to customers including loan commitments and financial guarantees, and represents the elasticity between macro economic factors such as gross domestic product and the risk of default.

Retail analysis

 
 IFRS 9 ECL sensitivity to future 
  economic conditions(1) 
                                  UK    France 
 ECL Coverage of Loans 
  and Advances to Customers 
  at 31 December 2018 
 Reported ECL (GBPm)               6     116 
 Drawn Amount (GBPm)           1,899    16,760 
 Reported ECL Coverage 
  (%)                           0.33    0.69 
                               -----  ------ 
 Coverage Ratios by scenario 
  (%): 
 Consensus central scenario     0.33    0.69 
                               -----  ------ 
 Consensus upside scenario      0.29    0.69 
                               -----  ------ 
 Consensus downside scenario    0.37     0.7 
-----------------------------  -----  ------ 
 
   1      ECL sensitivities exclude portfolios utilising less complex modelling approaches 

Under certain economic conditions, economic factors can influence ECL in counter-intuitive ways (for example an increase in GDP growth accompanied by rising interest rates resulting in an increase in PDs) and it may be necessary to apply management judgement to the output which, following management review of the calculated ECL sensitivities, may require modelled output adjustments. An example of this is in France, where the ECL sensitivity results have been adjusted to more accurately reflect management's views of ECL sensitivity under an upside and downside scenario by inverting the Upside and Downside ECL sensitivity.

For all the above sensitivity analyses, as the level of uncertainty, economic forecasts, historical economic variable correlations or credit quality changes, corresponding changes in the ECL sensitivity would occur.

Reconciliation of changes in gross carrying/nominal amount and allowances for loans and advances to banks and customers including loan commitments and financial guarantees

The following disclosure provides a reconciliation of the Group's gross carrying/nominal amount and allowances for loans and advances to banks and customers including loan commitments and financial guarantees.

The transfers of financial instruments represents the impact of stage transfers upon the gross carrying/nominal amount and associated allowance for ECL. The net remeasurement of ECL arising from stage transfers represents the increase or decrease due to these transfers, for example, moving from a 12-month (stage 1) to a lifetime (stage 2) ECL measurement basis. Net remeasurement excludes the underlying CRR/PD movements of the financial instruments transferring stage. This is captured, along with other credit quality movements in the 'changes in risk parameters - credit quality' line item.

The 'Net new and further lending/repayments' represent the gross carrying/nominal amount and associated allowance ECL impact from volume movements within the Group's lending portfolio.

 
 Reconciliation of changes in gross carrying/nominal amount and allowances 
  for loans and advances to banks and customers including 
  loan commitments and financial guarantees(1) 
 (Audited) 
                                        Non credit - impaired                                       Credit - impaired 
                                  Stage 1                        Stage 2                   Stage 3                      POCI                            Total 
                                                              Gross                     Gross                     Gross 
                                 Gross                    carrying/    Allowance    carrying/    Allowance    carrying/                               Gross 
                      carrying/nominal    Allowancefor      nominal          for      nominal          for      nominal    Allowancefor    carrying/nominal    Allowancefor 
                                amount             ECL       amount          ECL       amount          ECL       amount             ECL              amount             ECL 
                    ------------------  --------------  -----------  -----------  -----------  -----------  -----------  --------------  ------------------  -------------- 
 The group                        GBPm            GBPm         GBPm         GBPm         GBPm         GBPm         GBPm            GBPm                GBPm            GBPm 
------------------  ------------------  --------------  -----------  -----------  -----------  -----------  -----------  --------------  ------------------  -------------- 
 At 1 Jan 2018          408,167            (452)         18,702        (618)        5,342       (1,897)       463           (74)             432,674           (3,041) 
------------------  -----------  -----  -------   ----  -------      ------       -------      -------      -----  ----  ------   -----  -----------  -----  -------- --- 
 Transfers to HSBC 
  UK and its 
  subsidiaries         (216,026)            288          (9,502)        453        (2,711)         663          -             -             (228,239)           1,404 
------------------  -----------   ----  -------  -----  -------      ------  ---  -------      -------      -----  ----  ------  ------  -----------   ----  --------  ---- 
 Transfers of 
  financial 
  instruments:           (5,852)           (120)          4,637         176         1,215          (56)         -             -                    -                - 
------------------                      -------   ----  -------      ------  ---  -------      -------      -----  ----  ------  ------  -----------  -----  --------  ---- 
 - Transfers from 
  Stage 1 to Stage 
  2                     (15,141)             38          15,141         (38)            -            -          -             -                    -                - 
 - Transfers from 
  Stage 2 to Stage 
  1                       9,955            (154)         (9,955)        154             -            -          -             -                    -                - 
 - Transfers to 
  Stage 
  3                        (754)             11            (941)         79         1,695          (90)         -             -                    -                - 
 - Transfers from 
  Stage 3                    88             (15)            392         (19)         (480)          34          -             -                    -                - 
                    -----------  -----  -------   ----  -------      ------       -------      -------      -----  ----  ------  ------  -----------  -----  --------  ---- 
 Net remeasurement 
  of ECL arising 
  from 
  transfer of 
  stage                       -              99               -        (114)            -           (7)         -             -                    -              (22) 
------------------ 
 Net new and 
  further 
  lending / 
  (repayments)           19,080            (143)           (421)        239          (769)          76       (330)           11               17,560              183 
------------------ 
 Changes to risk 
  parameters 
  -credit 
  quality                                   138                        (324)                      (240)                     (22)                                 (448) 
                    ------------------  -------  -----  -----------  ------       -----------  -------      -----------  ------   -----  ------------------  -------- --- 
 Assets written 
  off                         -               -               -           -          (456)         456          -             -                 (456)             456 
 Foreign exchange           779              (2)             86           -            14           (8)        (1)            -                  878              (10) 
 Others                   1,597              38             772         (19)          (78)          24         (8)            7                2,283               50 
------------------ 
 At 31 Dec 2018         207,745            (154)         14,274        (207)        2,557         (989)       124           (78)             224,700           (1,428) 
------------------  -----------  -----  -------   ----  -------      ------       -------      -------      -----  ----  ------   -----  -----------  -----  -------- --- 
 ECL 
  release/(charge) 
  for the period                             94                        (199)                      (171)                     (11)                                 (287) 
 Recoveries                                                                                                                                                        71 
 Others                                                                                                                                                           (10) 
 Total change in 
  ECL for the 
  period                                                                                                                                                         (226) 
------------------  ------------------  --------------  -----------  -----------  -----------  -----------  -----------  --------------  ------------------  -------- --- 
 
 
                                                                                12 months 
                                                                                 ended 31 
                                                      At 31 Dec 2018             Dec 2018 
                                            Gross carrying/nominal  Allowance 
                                                            amount    for ECL    ECL charge 
                                                              GBPm       GBPm          GBPm 
                                            ----------------------  --------- 
 As above                                                  224,700    (1,428)      (226) 
------------------------------------------  ----------------------  --------   -------- 
 Other financial assets measured at 
  amortised cost                                           165,525        (2)         - 
                                            ----------------------  --------   -------- 
 Non-trading reverse purchase agreement 
  commitments                                               49,911         -          - 
------------------------------------------  ----------------------  --------   -------- 
 Summary of financial instruments to 
  which the impairment requirements in 
  IFRS 9 are applied/Summary consolidated 
  income statement                                         440,136    (1,430)      (226) 
------------------------------------------  ----------------------  --------   -------- 
 Debt instruments measured at FVOCI                         47,172       (45)        79 
------------------------------------------  ----------------------  --------   -------- 
 Total allowance for ECL/total income 
  statement ECL charge for the period                      487,308    (1,475)      (147) 
------------------------------------------  ----------------------  --------   -------- 
 

1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

Credit quality

Credit quality of financial instruments

(Audited)

We assess the credit quality of all financial instruments that are subject to credit risk. The credit quality of financial instruments is a point-in-time assessment of the probability of default of financial instruments, whereas IFRS 9 stages 1 and 2 are determined based on relative deterioration of credit quality since initial recognition. Accordingly, for non-credit-impaired financial instruments, there is no direct relationship between the credit quality assessment and IFRS 9 stages 1 and 2, though typically the lower credit quality bands exhibit a higher proportion in stage 2.

The five credit quality classifications each encompass a range of granular internal credit rating grades assigned to wholesale and personal lending businesses and the external ratings attributed by external agencies to debt securities, as shown in the table on page 27. Under IAS 39, personal lending credit quality was disclosed based on expected-loss percentages. Under IFRS 9, personal lending credit quality is now disclosed based on a 12-month point-in-time PD adjusted for multiple economic scenarios. The credit quality classifications for wholesale lending are unchanged and are based on internal credit risk ratings.

 
 Distribution of financial instruments by credit quality 
 (Audited) 
                                     Gross carrying/notional amount 
                                                          Sub-     Credit           Allowance 
                       Strong    Good  Satisfactory   standard   impaired    Total    for ECL        Net 
 The group               GBPm    GBPm          GBPm       GBPm       GBPm     GBPm       GBPm       GBPm 
                      -------  ------  ------------  ---------  ---------  -------  ---------  --------- 
 In-scope for IFRS 9 
 Loans and advances 
  to customers held 
  at 
  amortised cost       45,870  31,451        30,141      3,483      2,361  113,306    (1,342)  111,964 
                      ------- 
 - personal            15,579   5,266         2,346        185        527   23,903      (206)   23,697 
 - corporate and 
  commercial           20,868  23,016        25,342      3,072      1,760   74,058    (1,106)   72,952 
 - non-bank 
  financial 
  institutions          9,423   3,169         2,453        226         74   15,345       (30)   15,315 
                      -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 Loans and advances 
  to banks held at 
  amortised 
  cost                 11,735   1,536           355          5          -   13,631        (3)   13,628 
--------------------  -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 Cash and balances 
  at 
  central banks        51,965       -            35         14          -   52,014        (1)   52,013 
                      -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 Items in the course 
  of collection from 
  other banks             839       -             -          -          -      839         -       839 
--------------------  -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 Reverse repurchase 
  agreements - 
  non-trading          67,748   8,017         4,337          -          -   80,102         -    80,102 
--------------------  -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 Financial 
  investments               5       -             8          -          -       13         -        13 
--------------------  -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 Prepayments, 
  accrued 
  income and other 
  assets               31,885     486           444          7          5   32,827        (1)   32,826 
 - endorsements and 
  acceptances              93      14             7          -          1      115        (1)      114 
 - accrued income 
  and 
  other                31,792     472           437          7          4   32,712         -    32,712 
                      -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 Debt instruments 
  measured 
  at fair value 
  through 
  other 
  comprehensive 
  income(1)            42,363   2,084           606        597          9   45,659       (45)   45,614 
                      -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 Out-of-scope for 
 IFRS 
 9 
 Trading assets        42,274   9,924         7,088        876          -   60,162         -    60,162 
--------------------  -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 Other financial 
  assets 
  designated and 
  otherwise 
  mandatorily 
  measured 
  at fair value 
  through 
  profit or loss        2,633   1,362         4,136          2          -    8,133         -     8,133 
                      -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 Derivatives          122,695  17,115         4,229        451         32  144,522         -   144,522 
--------------------  -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 Total gross 
  carrying 
  amount on balance 
  sheet               420,012  71,975        51,379      5,435      2,407  551,208    (1,392)  549,816 
--------------------  -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 Percentage of total 
  credit quality          78%     15%            6%         1%          -     100% 
--------------------                                                       ------- 
 Loan and other 
  credit-related 
  commitments          96,522  31,393        12,821        630        254  141,620       (66)  141,554 
--------------------  -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 Financial 
  guarantees            3,390   1,456           948        194         66    6,054       (17)    6,037 
--------------------  -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 In-scope: 
  Irrevocable 
  loan commitments 
  and 
  financial 
  guarantees           99,912  32,849        13,769        824        320  147,674       (83)  147,591 
--------------------  -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 
 Loan and other 
  credit-related 
  commitments(2)        7,275       -             -          -          -    7,275         -     7,275 
 Performance and 
  other 
  guarantees            8,631   5,236         2,682        592        103   17,244       (37)   17,207 
 Out-of-scope: 
  Revocable 
  loan commitments 
  and 
  non-financial 
  guarantees           15,906   5,236         2,682        592        103   24,519       (37)   24,482 
--------------------  -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 

1 For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes fair value gains and losses.

2 Revocable loan and other commitments of GBP7.3bn which are out-of-scope of IFRS 9 are presented within the strong credit quality classification.

 
 Distribution of financial instruments by credit quality 
 (Audited) 
                                     Gross carrying/notional amount 
                                                          Sub-     Credit           Allowance 
                       Strong    Good  Satisfactory   standard   impaired    Total    for ECL        Net 
 The bank                GBPm    GBPm          GBPm       GBPm       GBPm     GBPm       GBPm       GBPm 
                      -------  ------  ------------  ---------  ---------  -------  ---------  --------- 
 In-scope for IFRS 9 
 Loans and advances 
  to customers held 
  at 
  amortised cost       23,923  17,828        15,123      1,586      1,067   59,527      (744)   58,783 
                      ------- 
 - personal             1,782     695           734         14         24    3,249        (9)    3,240 
 - corporate and 
  commercial            9,441  14,695        12,764      1,358        998   39,256      (685)   38,571 
 - non-bank 
  financial 
  institutions         12,700   2,438         1,625        214         45   17,022       (50)   16,972 
                      -------  ------  ------------  ---------  ---------  -------  --------   ------- 
Loans and advances 
 to banks held at 
 amortised 
 cost                  11,225   1,356           107          1          -   12,689        (3)   12,686 
                      -------  ------  ------------  ---------  ---------  -------  --------   ------- 
Cash and balances at 
 central banks         40,657       -             -          -          -   40,657          -   40,657 
                      -------  ------  ------------  ---------  ---------  -------  ---------  ------- 
Items in the course 
 of collection from 
 other banks              442       -             -          -          -      442          -      442 
                      -------  ------  ------------  ---------  ---------  -------             ------- 
Reverse repurchase 
 agreements - 
 non-trading           48,220   6,668         1,607          -          -   56,495          -   56,495 
                      -------  ------  ------------  ---------  ---------  -------  ---------  ------- 
Financial                   -       -             -          -          -        -          -        - 
investments 
                      -------  ------  ------------  ---------  ---------  -------  ---------  ------- 
Prepayments, accrued 
 income and other 
 assets                26,653     170           122          1          4   26,950        (1)   26,949 
 - endorsements and 
  acceptances              67      14             -          -          1       82        (1)       81 
- accrued income and 
 other                 26,586     156           122          1          3   26,868          -   26,868 
                      -------  ------  ------------  ---------  ---------  -------             ------- 
Debt instruments 
 measured 
 at fair value 
 through 
 other comprehensive 
 income(1)             26,272      40            12          2          3   26,329        (6)   26,323 
                      -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 Out-of-scope for 
 IFRS 
 9 
Trading assets         28,973   7,379         6,873        845          -   44,070          -   44,070 
                      -------  ------  ------------  ---------  ---------  -------             ------- 
Other financial 
 assets 
 designated and 
 otherwise 
 mandatorily 
 measured 
 at fair value 
 through 
 profit or loss           303     939         3,800          2          -    5,044          -    5,044 
                      -------  ------  ------------  ---------  ---------  -------             ------- 
Derivatives           120,848  14,240         3,684        427         30  139,229          -  139,229 
                      -------  ------  ------------  ---------  ---------  -------  ---------  ------- 
Total gross carrying 
 amount on balance 
 sheet                327,516  48,620        31,328      2,864      1,104  411,432      (754)  410,678 
                      -------  ------  ------------  ---------  ---------  -------  --------   ------- 
Percentage of total 
 credit quality           79%     12%            8%         1%          -     100% 
                                                                           ------- 
Loan and other 
 credit-related 
 commitments           37,245  14,927         8,499        379        146   61,196       (50)   61,146 
                      -------  ------  ------------  ---------  ---------  -------  --------   ------- 
Financial guarantees    4,448     598           383         96         53    5,578       (14)    5,564 
                      -------  ------  ------------  ---------  ---------  -------  --------   ------- 
In-scope: 
 Irrevocable 
 loan commitments 
 and 
 financial 
 guarantees            41,693  15,525         8,882        475        199   66,774       (64)   66,710 
                      -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 
 Loan and other 
  credit-related 
  commitments(2)        4,742       -             -          -          -    4,742         -     4,742 
 Performance and 
  other 
  guarantees            5,231   2,458         2,193        374         67   10,323       (27)   10,296 
Out-of-scope: 
 Revocable 
 loan commitments 
 and 
 non-financial 
 guarantees             9,973   2,458         2,193        374         67   15,065       (27)   15,038 
                      -------  ------  ------------  ---------  ---------  -------  --------   ------- 
 

1 For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes fair value gains and losses.

2 Revocable loan and other commitments of GBP4.7bn which are out-of-scope of IFRS 9 are presented within the strong credit quality classification.

 
 Distribution of financial instruments to which the impairment requirements 
  in IFRS 9 are applied, by credit quality and stage distribution 
 (Audited) 
                                     Gross carrying/notional amount 
                                                          Sub-     Credit           Allowance 
                       Strong    Good  Satisfactory   standard   impaired    Total    for ECL        Net 
The group                GBPm    GBPm          GBPm       GBPm       GBPm     GBPm       GBPm       GBPm 
Loans and advances 
 to 
 customers at 
 amortised 
 cost                  45,870  31,451        30,141      3,483      2,361  113,306    (1,342)  111,964 
- stage 1              45,858  29,662        24,835      1,774          -  102,129      (121)  102,008 
- stage 2                  12   1,789         5,306      1,709          -    8,816      (171)    8,645 
- stage 3                   -       -             -          -      2,244    2,244      (972)    1,272 
- POCI                      -       -             -          -        117      117       (78)       39 
                      ------- 
Loans and advances 
 to 
 banks at amortised 
 cost                  11,735   1,536           355          5          -   13,631        (3)   13,628 
- stage 1              11,727   1,483           350          5          -   13,565        (2)   13,563 
- stage 2                   8      53             5          -          -       66        (1)       65 
- stage 3                   -       -             -          -          -        -         -         - 
- POCI                      -       -             -          -          -        -         -         - 
                      ------- 
Other financial 
 assets 
 measured at 
 amortised 
 cost                 152,293   8,491         4,717         19          5  165,525        (2)  165,523 
                      -------                                              ------- 
- stage 1             152,293   8,477         4,710         16          -  165,496        (1)  165,495 
- stage 2                   -      14             7          3          -       24         -        24 
- stage 3                   -       -             -          -          5        5        (1)        4 
- POCI                      -       -             -          -          -        -         -         - 
                      ------- 
Loan and other 
 credit-related 
 commitments           96,522  31,393        12,821        630        254  141,620       (66)  141,554 
- stage 1              96,507  30,452         9,515         65          -  136,539       (27)  136,512 
- stage 2                  15     941         3,306        565          -    4,827       (26)    4,801 
- stage 3                   -       -             -          -        249      249       (13)      236 
- POCI                      -       -             -          -          5        5         -         5 
                      ------- 
Financial 
 guarantees(1)          3,390   1,456           948        194         66    6,054       (17)    6,037 
- stage 1               3,354   1,431           604         34          -    5,423        (4)    5,419 
- stage 2                  36      25           344        160          -      565        (9)      556 
- stage 3                   -       -             -          -         64       64        (4)       60 
- POCI                      -       -             -          -          2        2         -         2 
At 31 Dec 2018        309,810  74,327        48,982      4,331      2,686  440,136    (1,430)  438,706 
                      -------                                              ------- 
Debt instruments at 
FVOCI(2) 
- stage 1              42,356   2,008           329        331          -   45,024        (8)   45,016 
- stage 2                   7      76           277        266          -      626       (36)      590 
- stage 3                   -       -             -          -          6        6        (1)        5 
- POCI                      -       -             -          -          3        3         -         3 
At 31 Dec 2018         42,363   2,084           606        597          9   45,659       (45)   45,614 
                      -------                                              ------- 
 

1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

2 For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes fair value gains and losses.

Credit--impaired loans

(Audited)

The Group determines that a financial instrument is credit impaired and in stage 3 by considering relevant objective evidence, primarily whether:

   --    contractual payments of either principal or interest are past due for more than 90 days; 

-- there are other indications that the borrower is unlikely to pay such as that a concession has been granted to the borrower for economic or legal reasons relating to the borrower's financial condition; and

-- the loan is otherwise considered to be in default. If such unlikeliness to pay is not identified at an earlier stage, it is deemed to occur when an exposure is 90 days past due, even where regulatory rules permit default to be defined based on 180 days past due. Therefore the definitions of credit-impaired and default are aligned as far as possible so that stage 3 represents all loans which are considered defaulted or otherwise credit-impaired.

Renegotiated loans and forbearance

The following table shows the gross carrying amounts of the group's holdings of renegotiated loans and advances to customers by industry sector and by stages. Wholesale renegotiated loans are classified as stage 3 until there is sufficient evidence to demonstrate a significant reduction in the risk of non-payment of future cash flows, observed over a minimum one-year period, and there are no other indicators of impairment. Personal renegotiated loans are deemed to remain credit-impaired until repayment or derecognition.

 
 Renegotiated loans and advances to customers at amortised costs by 
  stage allocation 
                                              Stage     Stage  Stage 
                                                  1         2      3  POCI     Total 
The group                                      GBPm      GBPm   GBPm  GBPm      GBPm 
Gross carrying amount 
Personal                                      -         -        75     -      75 
- first lien residential mortgages            -         -        56     -      56 
- other personal lending                      -         -        19     -      19 
 
Wholesale                                   394       429       568   117   1,508 
- corporate and commercial                  394       429       567   117   1,507 
- non-bank financial institutions             -         -         1     -       1 
At 31 Dec 2018                              394       429       643   117   1,583 
 
Allowance for ECL 
Personal                                      -         -       (14)    -     (14) 
- first lien residential mortgages            -         -        (9)    -      (9) 
- other personal lending                      -         -        (5)    -      (5) 
 
Wholesale                                    (4)      (10)     (169)  (78)   (261) 
- corporate and commercial                   (4)      (10)     (169)  (78)   (261) 
- non-bank financial institutions             -         -         -     -       - 
 
At 31 Dec 2018                               (4)      (10)     (183)  (78)   (275) 
 
 

Wholesale lending

This section provides further details on the countries and industries comprising wholesale loans and advances to customers and banks. Industry granularity is also provided by stage with geographical data presented for loans and advances to customers and banks, loan and other credit-related commitments and financial guarantees.

 
 Total wholesale lending for loans and advances to banks and customers 
  by stage distribution 
                                                                Gross carrying amount                  Allowance for ECL 
                                                               Stage  Stage  Stage                 Stage  Stage  Stage 
                                                                   1      2      3  POCI    Total      1      2      3  POCI      Total 
 The group                                                      GBPm   GBPm   GBPm  GBPm     GBPm   GBPm   GBPm   GBPm  GBPm       GBPm 
Corporate and commercial                                      64,822  7,476  1,643   117   74,058   (99)  (132)  (797)  (78)  (1,106) 
                                                              ------  -----  -----  ----  -------  ----   ----   ----   ---   ------ 
 
  *    agriculture, forestry and fishing                         187      5     10     -      202     -      -     (4)    -       (4) 
 
  *    mining and quarrying                                    1,368    107     19     -    1,494    (4)    (3)    (2)    -       (9) 
 
   *    manufacture                                           12,364  1,379    245    53   14,041   (23)   (19)  (100)  (33)    (175) 
 
  *    electricity, gas, steam and air-conditioning supply     2,232    332      6    47    2,617    (3)   (19)    (2)  (43)     (67) 
 
  *    water supply, sewerage, waste management and 
       remediation                                               465      2      -     -      467     -      -      -     -        - 
- construction                                                 1,267    179    305     -    1,751    (2)   (18)  (141)    -     (161) 
 
  *    wholesale and retail trade, repair of motor vehicles 
       and motorcycles                                         9,331  2,654    291    11   12,287    (8)   (11)  (156)    -     (175) 
 
  *    transportation and storage                              5,232    563    148     -    5,943   (14)   (19)   (23)    -      (56) 
 
   *    accommodation and food                                 1,170     28     23     2    1,223    (1)    (1)   (12)   (1)     (15) 
 
  *    publishing, audiovisual and broadcasting                3,849    310     30     -    4,189    (8)    (4)    (8)    -      (20) 
- real estate                                                  7,274    410    398     1    8,083    (8)    (7)  (252)    -     (267) 
 
  *    professional, scientific and technical activities       5,570    175     38     -    5,783    (3)     -     (8)    -      (11) 
 
  *    administrative and support services                     7,757    703     86     3    8,549    (8)   (16)   (64)   (1)     (89) 
 
  *    public administration and defence, compulsory social 
       security                                                  562     21      -     -      583     -     (2)     -     -       (2) 
- education                                                      109      3      1     -      113    (2)     -     (1)    -       (3) 
 - health and care                                               425     29     10     -      464    (1)    (1)    (7)    -       (9) 
 
   *    arts, entertainment and recreation                     1,367    446     12     -    1,825    (2)    (1)    (8)    -      (11) 
 - other services                                              3,114     55     16     -    3,185   (12)    (1)    (8)    -      (21) 
 - activities of households                                        6      -      -     -        6     -      -      -     -        - 
 
  *    extra-territorial organisations and bodies activities      15      -      5     -       20     -      -     (1)    -       (1) 
- government                                                   1,157     63      -     -    1,220     -      -      -     -        - 
 - asset-backed securities                                         1     12      -     -       13     -    (10)     -     -      (10) 
                                                              ------ 
Non-bank financial 
 institutions                                                 15,137    134     74     -   15,345   (13)   (12)    (5)    -      (30) 
                                                                                                                              ------ 
Loans and advances 
 to banks                                                     13,565     66      -     -   13,631    (2)    (1)     -     -       (3) 
                                                              ------  -----  -----                                            ------ 
At 31 Dec 2018                                                93,524  7,676  1,717   117  103,034  (114)  (145)  (802)  (78)  (1,139) 
                                                              ------  -----  -----                                            ------ 
 By country 
UK                                                            54,481  4,776    716     6   59,979   (69)  (100)  (354)    -     (523) 
                                                              ------  -----  -----  ----  -------  ----   ----   ----   ---   ------ 
France                                                        26,555  1,549    408    10   28,522   (18)   (16)  (298)   (3)    (335) 
                                                              ------  -----  -----  ----  -------  ----   ----   ----   ---   ------ 
Germany                                                        9,071    472    220     -    9,763    (1)    (2)   (25)    -      (28) 
                                                              ------  -----  -----  ----  -------  ----   ----   ----   ---   ------ 
Other countries                                                3,417    879    373   101    4,770   (26)   (27)  (125)  (75)    (253) 
                                                              ------  -----  -----  ----  -------  ----   ----   ----   ---   ------ 
At 31 Dec 2018                                                93,524  7,676  1,717   117  103,034  (114)  (145)  (802)  (78)  (1,139) 
                                                              ------  -----  -----  ----  -------  ----   ----   ----   ---   ------ 
 
 
 Total wholesale lending for loans and other credit-related commitments 
  and financial guarantees(1) by stage distribution 
                                      Nominal amount                      Allowance for ECL 
                             Stage   Stage  Stage                 Stage  Stage  Stage 
                                 1       2      3  POCI    Total      1      2      3  POCI    Total 
The group                     GBPm    GBPm   GBPm  GBPm     GBPm   GBPm   GBPm   GBPm  GBPm     GBPm 
Corporate and commercial    68,294   4,940    307     7   73,548   (30)   (34)   (17)     -   (81) 
 
Financial                   71,621     398      2     -   72,021    (1)    (1)     -      -    (2) 
 
At 31 Dec 2018             139,915   5,338    309     7  145,569   (31)   (35)   (17)     -   (83) 
 
By geography 
Europe                     139,915   5,338    309     7  145,569   (31)   (35)   (17)     -   (83) 
 
of which: UK                46,682   2,715    175     -   49,572   (23)   (29)    (5)     -   (57) 
 
of which: France            76,550   1,018     33     -   77,601    (1)    (2)    (7)     -   (10) 
 
of which: Germany           14,772   1,019     78     -   15,869     -     (1)    (4)     -    (5) 
 
 

1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

Collateral and other credit enhancement held

(Audited)

It is the group's practice to lend on the basis of the customer's ability to meet their obligations out of their cash flow resources rather than rely on the value of security offered. Depending on the customer's standing and the type of product, facilities may be provided unsecured.For other lending a charge over collateral is obtained and considered in determining the credit decision and pricing. In the event of a default, the group may utilise the collateral as a source of repayment. Depending on its form, collateral can have a significant financial effect in mitigating exposure to credit risk.

Other corporate, commercial and financial (non-bank) loans and advances

Other corporate, commercial and financial (non-bank) loans are analysed separately in the following table, which focuses on the countries containing the majority of our loans and advances balances. For financing activities in other corporate and commercial lending, collateral value is not strongly correlated to principal repayment performance.

Collateral values are generally refreshed when an obligor's general credit performance deteriorates and we have to assess the likely performance of secondary sources of repayment should it prove necessary to rely on them.

 
Wholesale lending - corporate, commercial and financial (non-bank) 
 loans and advances including loan commitments by level of 
 collateral for key countries by stage (excluding commercial real estate) 
 (Audited) 
                                                                                              Of which: 
                              Total                             UK                             France                           Germany 
                              Gross                            Gross                            Gross                            Gross 
                   carrying/nominal          ECL    carrying/nominal          ECL    carrying/nominal          ECL    carrying/nominal          ECL 
                             amount     coverage              amount     coverage              amount     coverage              amount     coverage 
The group                      GBPm            %                GBPm            %                GBPm            %                GBPm            % 
                 ------------------  -----------  ------------------  -----------  ------------------  -----------  ------------------  ----------- 
 Stage 1 
 Not 
 collateralised           116,011          0.1              71,762          0.1              14,057          0.1              20,857            - 
 
 Fully 
 collateralised            48,699            -               9,890            -              38,582                                - 
                                                                                                       ----------- 
 LTV ratio: 
                                     -----------                      ----------- 
 - less than 
 50%                        2,184          0.1               1,236          0.1                 868          0.1                   -            - 
 
 - 51% to 75%              38,068            -               2,066            -              36,001            -                   -            - 
 
 - 76% to 90%               1,013          0.1                 387            -                 626            -                   -            - 
 
 - 91% to 100%              7,434            -               6,201            -               1,087          0.1                   -            - 
 
 Partially 
 collateralised 
 (A):                       1,834          0.1                 625            -               1,161          0.1                   -            - 
 
 - collateral 
 value 
 on A                         343                              295                               33                                - 
                                     -----------                      -----------                      ----------- 
Total Stage 1             166,544          0.1              82,277          0.1              53,800            -              20,857            - 
 
Stage 2 
 Not 
 collateralised             9,327          1.4               5,852          1.7               1,184          0.3               1,261          0.2 
 
 Fully 
 collateralised             2,429          0.9               1,280          0.9               1,082          0.6                   -            - 
 
 LTV ratio: 
                                     -----------                      ----------- 
 - less than 
 50%                          294          0.7                 240            -                  39          2.6                   -            - 
 
 - 51% to 75%               1,378          0.9                 426          2.8                 948          0.2                   -            - 
 
 - 76% to 90%                  19            -                  14            -                   5            -                   -            - 
 
 - 91% to 100%                738          0.7                 600            -                  90          2.2                   -            - 
 
 Partially 
 collateralised 
 (B):                         163          0.6                   8            -                 148          0.7                   -            - 
 
 - collateral 
 value 
 on B                          11                                1                                7                                - 
                                     -----------                      -----------                      ----------- 
Total Stage 2              11,919          1.3               7,140          1.5               2,414          0.5               1,261          0.2 
 
Stage 3 
 Not 
 collateralised             1,450         44.3                 664         48.6                 286         66.4                 252         11.5 
 
 Fully 
 collateralised               226         21.2                 124          6.5                  67         44.8                   -            - 
 
 LTV ratio: 
                                     -----------                      ----------- 
 - less than 
 50%                           54         42.6                  15         20.0                  10        100.0                   -            - 
 
 - 51% to 75%                  75         12.0                  25            -                  51         29.4                   -            - 
 
 - 76% to 90%                  37         16.2                  34          8.8                   3        100.0                   -            - 
 
 - 91% to 100%                 60         16.7                  50          6.0                   3        100.0                   -            - 
 
 Partially 
 collateralised 
 (C):                          83         42.2                  33          6.1                  33         72.7                   -            - 
 
- collateral 
value 
on C                           26                               21                                1                                - 
                                     -----------                      -----------                      ----------- 
Total Stage 3               1,759         41.3                 821         40.6                 386         63.2                 252         11.5 
 
POCI 
Not 
collateralised                102         72.5                   -            -                   -            -                   -            - 
 
 Fully 
 collateralised                13         23.1                   -            -                   9         33.3                   -            - 
 
LTV ratio: 
                                     -----------                      ----------- 
- less than 50%                 -            -                   -            -                   -            -                   -            - 
 
 - 51% to 75%                  13            -                   -            -                   9         33.3                   -            - 
 
 - 76% to 90%                   -            -                   -            -                   -            -                   -            - 
 
- 91% to 100%                   -            -                   -            -                   -            -                   -            - 
 
Partially 
collateralised 
(D):                            6            -                   6            -                   -            -                   -            - 
 
- collateral 
value 
on D                            3                                3                                -                                - 
                                     -----------                      -----------                      ----------- 
Total POCI                    121         63.6                   6            -                   9         33.3                   -            - 
 
At 31 Dec 2018            180,343          0.6              90,244          0.6              56,608          0.5              22,370          0.1 
 
 

Other credit risk exposures

In addition to collateralised lending, other credit enhancements are employed and methods used to mitigate credit risk arising from financial assets. These are described in more detail below:

-- Some securities issued by governments, banks and other financial institutions benefit from additional credit enhancement provided by government guarantees that cover the assets;

   --    Debt securities issued by corporates are primarily unsecured; 

-- Debt securities issued by banks and financial institutions include ABSs and similar instruments which are supported by underlying pools of financial assets. Credit risk associated with ABSs is reduced through the purchase of credit default swap ('CDS') protection;

-- Trading assets include loans and advances held with trading intent. These mainly consist of cash collateral posted to satisfy margin requirements on derivatives, settlement accounts, reverse repos and stock borrowing. There is limited credit risk on cash collateral posted since in the event of default of the counterparty these would be set off against the related liability. Reverse repos and stock borrowing are by their nature collateralised; and

-- The group's maximum exposure to credit risk includes financial guarantees and similar contracts granted as well as loan commitments that we are irrevocably committed to. Depending on the terms of the arrangement, we may have recourse to additional credit mitigation in the event that a guarantee is called upon or a loan commitment is drawn and subsequently defaults.

Derivatives

The group participates in transactions exposing it to counterparty credit risk. Counterparty credit risk is the risk of financial loss if the counterparty to a transaction defaults before completing the satisfactory settlement of the transaction, which varies in value by reference to a market factor such as interest rate, exchange rate or asset price. It arises principally from OTC derivatives and securities financing transactions ('SFTs') and is calculated in both the trading and non-trading books.

Transactions vary in value by reference to a market factor such as interest rate, exchange rate or asset price. The counterparty risk from derivative transactions is taken into account when reporting the fair value of derivative positions. The adjustment to the fair value is known as the credit value adjustment ('CVA').

The International Swaps and Derivatives Association ('ISDA') Master Agreement is the group's preferred agreement for documenting derivatives activity. It provides the contractual framework within which dealing activity across a full range of OTC products is conducted, and contractually binds both parties to apply close-out netting across all outstanding transactions covered by an agreement if either party defaults or other pre-agreed termination events occur. It is common, and the group's preferred practice, for the parties to execute a Credit Support Annex ('CSA') in conjunction with the ISDA Master Agreement. Under a CSA, collateral is passed between the parties to mitigate the market-contingent counterparty risk inherent in the outstanding positions.

We manage the counterparty exposure arising from market risk on our OTC derivative contracts by using collateral agreements with counterparties and netting agreements. Currently, we do not actively manage our general OTC derivative counterparty exposure in the credit markets, although we may manage individual exposures in certain circumstances.

HSBC has historically placed strict policy restrictions on collateral types and as a consequence the types of collateral received and pledged are, by value, highly liquid and of a strong quality, being predominantly cash.

Where a collateral type is required to be approved outside the collateral policy (which includes collateral that includes wrong-way risks), a submission to the Documentation Approval Committee ('DAC') for approval is required. The DAC requires the participation and sign-off of senior representatives from the Global Markets Chief Operating Officer, Legal and Risk.

The majority of the counterparties with whom we have a collateral agreement are European. The majority of the group's CSAs are with financial institutional clients.

Personal lending

This section provides further details on the countries and products comprising personal loans and advances to customers.

Further product granularity is also provided by stage, with geographical data presented for loans and advances to customers, loan and other credit-related commitments, and financial guarantees.

 
 Total personal lending for loans and advances to customers at amortised 
  costs by stage distribution 
                                                      Gross carrying 
                                                          amount                       Allowance for ECL 
                                                    Stage  Stage  Stage            Stage  Stage  Stage 
                                                        1      2      3   Total        1      2      3    Total 
The group                                            GBPm   GBPm   GBPm    GBPm     GBPm   GBPm   GBPm     GBPm 
By portfolio 
First lien residential mortgages                    6,832    349    276   7,457   (4)       (8)   (81)   (93) 
 
  *    of which: interest only (including offset)   3,323    244    126   3,693    -        (3)   (32)   (35) 
- affordability including 
 ARMs                                                 290      -      -     290    -         -      -      - 
Other personal lending                             15,338    857    251  16,446   (5)      (19)   (89)  (113) 
- other                                            14,888    818    235  15,941   (4)      (15)   (88)  (107) 
- credit cards                                        334     39     16     389   (1)       (4)    (1)    (6) 
 
  *    second lien residential mortgages              116      -      -     116    -         -      -      - 
At 31 Dec 2018                                     22,170  1,206    527  23,903   (9)      (27)  (170)  (206) 
By geography 
UK(2)                                               3,133     92     24   3,249   (1)       (3)    (4)    (8) 
France                                             16,756    984    328  18,068   (3)      (17)  (102)  (122) 
Germany                                               186     40      -     226    -         -      -      - 
Other countries                                     2,095     90    175   2,360   (5)       (7)   (64)   (76) 
At 31 Dec 2018                                     22,170  1,206    527  23,903   (9)      (27)  (170)  (206) 
 
 
 Total personal lending for loans and other credit-related commitments 
  and financial guarantees(1) by stage distribution 
                                             Nominal amount                     Allowance for ECL 
                                        Stage  Stage  Stage                 Stage  Stage  Stage 
                                            1      2      3       Total         1      2      3    Total 
The group                                GBPm   GBPm   GBPm        GBPm      GBPm   GBPm   GBPm     GBPm 
                                  -----------  -----  -----  ----------  --------  -----  -----  ------- 
UK                                        305      3      -         308         -      -      -      - 
                                  -----------  -----  -----              --------  -----  -----  ----- 
France                                  1,022     31      3       1,056         -      -      -      - 
                                  -----------  -----  -----  ----------  --------  -----  -----  ----- 
Germany                                   181      5      -         186         -      -      -      - 
                                  -----------  -----  -----  ----------  --------  -----  -----  ----- 
Other countries                           539     15      1         555         -      -      -      - 
                                  -----------  -----  -----  ----------  --------  -----  -----  ----- 
At 31 Dec 2018                          2,047     54      4       2,105         -      -      -      - 
 
 

1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.

2 Includes primarily first lien residential mortgages in Channel Islands, Isle of Man, Jersey and Guernsey

Collateral on loans and advances

The following table provides a quantification of the value of fixed charges we hold over specific assets where we have a history of enforcing, and are able to enforce, collateral in satisfying a debt in the event of the borrower failing to meet its contractual obligations, and where the collateral is cash or can be realised by sale in an established market.

The collateral valuation excludes any adjustment for obtaining and selling the collateral and in particular loans shown as collateralised or partially collateralised may also benefit from other forms of credit mitigants.

 
 Personal lending: residential mortgage loans including loan commitments 
  by level of collateral for key countries 
 (Audited) 
                                                                                     Of which: 
                                                Total                       UK                      France 
                                             Gross          ECL        Gross          ECL        Gross          ECL 
                                          exposure     coverage     exposure     coverage     exposure     coverage 
 The group                                    GBPm            %         GBPm            %         GBPm            % 
 Stage 1 
 Fully collateralised                      6,875          0.1        2,473            -        2,278            - 
 LTV ratio: 
 - less than 50%                           3,029          0.1        1,004            -          884            - 
 - 51% to 60%                                963            -          271            -          452            - 
 - 61% to 70%                                896            -          227            -          436            - 
 - 71% to 80%                                823          0.1          208            -          317            - 
 - 81% to 90%                                422          0.2           92            -          128            - 
------------------------------------- 
 - 91% to 100%                               742            -          671            -           61            - 
                                       ---------                 ---------                 --------- 
 Partially collateralised (A):               323            -          179            -          100            - 
 LTV ratio: 
 - 101% to 110%                              222            -          176            -           23            - 
 - 111% to 120%                               26            -            1            -           16            - 
 - greater than 120%                          75            -            2            -           61            - 
                                       ---------                 ---------                 --------- 
 - collateral value on A                     305                       177                        99 
                                       ---------                 ---------                 --------- 
 Total                                     7,198          0.1        2,652            -        2,378            - 
-------------------------------------  ---------                 ---------                 --------- 
 Stage 2 
 Fully collateralised                        297          2.4           38            -          199          0.5 
 LTV ratio: 
 - less than 50%                             130          1.5           16            -           84          1.2 
 - 51% to 60%                                 46          2.2            4            -           33            - 
 - 61% to 70%                                 41          2.4            -            -           32            - 
 - 71% to 80%                                 40          5.0            -            -           30            - 
 - 81% to 90%                                 18          5.6            -            -           16            - 
 - 91% to 100%                                22            -           18            -            4            - 
                                       ---------                 ---------                 --------- 
 Partially collateralised (B):                52          3.8           34            -           10            - 
 LTV ratio: 
 - 101% to 110%                               39          2.6           34            -            2            - 
 - 111% to 120%                                4            -            -            -            2            - 
 - greater than 120%                           9         11.1            -            -            6            - 
 - collateral value on B                      52                        34                        10 
                                       ---------                 ---------                 --------- 
 Total                                       349            -           72            -          209            - 
-------------------------------------  ---------                 ---------                 --------- 
 Stage 3 
 Fully collateralised                        222         22.1           17         11.8           98         16.3 
 LTV ratio: 
 - less than 50%                             113         11.5           13          7.7           46         15.2 
 - 51% to 60%                                 27         18.5            -            -           15         13.3 
 - 61% to 70%                                 32         28.1            2            -           13         15.4 
 - 71% to 80%                                 20         35.0            1            -            8         25.0 
 - 81% to 90%                                  8         25.0            -            -            5         20.0 
 - 91% to 100%                                22         59.1            1        100.0           11         18.2 
 Partially collateralised (C):                57         71.9            1            -           20         70.0 
 LTV ratio: 
 - 101% to 110%                               11         36.4            1            -            4         25.0 
 - 111% to 120%                               12         50.0            -            -            4         25.0 
 - greater than 120%                          34         91.2            -            -           12        100.0 
 - collateral value on C                      47                         1                        20 
                                       ---------                 ---------                 --------- 
 Total                                       279         32.3           18         11.1          118         25.4 
-------------------------------------  ---------                 ---------                 --------- 
 At 31 Dec 2018                            7,826            -        2,742            -        2,705            - 
-------------------------------------  ---------                 ---------                 --------- 
 

Supplementary information

 
 Summary of financial instruments to which the impairment requirements 
  in IFRS 9 are applied - by global business 
                            Gross carrying/nominal amount                Allowance for ECL 
                           Stage   Stage  Stage                 Stage  Stage  Stage 
                               1       2      3  POCI    Total      1      2      3  POCI      Total 
The group                   GBPm    GBPm   GBPm  GBPm     GBPm   GBPm   GBPm   GBPm  GBPm       GBPm 
                                  ------                                                   --------- 
Loans and advances to 
 customers at 
 amortised 
 cost                    102,129   8,816  2,244   117  113,306  (121)  (171)  (972)  (78)  (1,342) 
- RBWM                    20,331   1,263    532     -   22,126   (10)   (18)  (174)    -     (202) 
- CMB                     26,307   2,377    867   114   29,665   (46)   (81)  (439)  (78)    (644) 
- GB&M                    51,279   4,870    785     2   56,936   (64)   (60)  (348)    -     (472) 
- GPB                      3,296     209     48     1    3,554    (1)    (1)   (11)    -      (13) 
- Corporate Centre           916      97     12     -    1,025     -    (11)     -     -      (11) 
                                                                                           ------ 
Loans and advances to 
 banks at amortised 
 cost                     13,565      66      -     -   13,631    (2)    (1)     -     -       (3) 
                        --------  ------                                                   ------ 
- RBWM                     2,418       4      -     -    2,422     -      -      -     -        - 
- CMB                        348       3      -     -      351     -      -      -     -        - 
- GB&M                     6,100      38      -     -    6,138    (2)    (1)     -     -       (3) 
- GPB                          5       -      -     -        5     -      -      -     -        - 
- Corporate Centre         4,694      21      -     -    4,715     -      -      -     -        - 
                                                                                           ------ 
Other financial assets 
 measured at amortised 
 cost                    165,496      24      5     -  165,525    (1)     -     (1)    -       (2) 
                        --------  ------                                                   ------ 
- RBWM                       681       2      -     -      683     -      -      -     -        - 
- CMB                        421       1      1     -      423     -      -      -     -        - 
- GB&M                   116,790      18      4     -  116,812     -      -     (1)    -       (1) 
- GPB                         72       -      -     -       72     -      -      -     -        - 
- Corporate Centre        47,532       3      -     -   47,535    (1)     -      -     -       (1) 
Total gross carrying 
 amount 
 on balance sheet at 
 31 
 Dec 2018                281,190   8,906  2,249   117  292,462  (124)  (172)  (973)  (78)  (1,347) 
                        -------- 
Loans and other 
 credit-related 
 commitments             136,539   4,827    249     5  141,620   (27)   (26)   (13)    -      (66) 
                        --------  ------                                                   ------ 
- RBWM                     1,725      50      3     -    1,778     -      -      -     -        - 
- CMB                     18,832   1,584    111     4   20,531    (4)    (4)   (11)    -      (19) 
- GB&M                   107,965   2,600    135     1  110,701   (23)   (22)    (2)    -      (47) 
- GPB                        475     593      -     -    1,068     -      -      -     -        - 
- Corporate Centre(1)      7,542       -      -     -    7,542     -      -      -     -        - 
Financial guarantees       5,423     565     64     2    6,054    (4)    (9)    (4)    -      (17) 
                        --------  ------                        ----   ----   ----   ---   ------ 
- RBWM                        13       -      -     -       13     -      -      -     -        - 
- CMB                      1,472     319     17     2    1,810    (1)    (3)    (1)    -       (5) 
- GB&M                     3,288     245     46     -    3,579    (3)    (6)    (3)    -      (12) 
- GPB                         43       1      -     -       44     -      -      -     -        - 
- Corporate Centre(1)        607       -      1     -      608     -      -      -     -        - 
Total nominal amount 
 off 
 balance sheet at 31 
 Dec 
 2018                    141,962   5,392    313     7  147,674   (31)   (35)   (17)    -      (83) 
                        -------- 
 
RBWM                      10,005     120      -     -   10,125    (5)     -      -     -       (5) 
CMB                            -       -      -     1        1     -      -      -     -        - 
GB&M                         548       -      -     -      548     -      -      -     -        - 
GPB                            -       -      -     -        -     -      -      -     -        - 
Corporate Centre          35,998     491      6     3   36,498    (3)   (36)    (1)    -      (40) 
Debt instruments 
 measured 
 at FVOCI at 
 31 Dec 2018              46,551     611      6     4   47,172    (8)   (36)    (1)    -      (45) 
                        -------- 
 

1 Corporate Centre includes GBP4,358m and GBP597m of inter-company balances for 'Loans and other-credit related commitments' and 'Financial guarantees' respectively.

Securitisation exposures and other structured products

This section contains information about our exposure to ABSs, some of which are held through consolidated structured entities ('SEs') and summarised in the table below.

Also included within this section is information on the GB&M legacy credit activities in respect of Solitaire and the securities investment conduits ('SICs'). For further information on structured entities please refer to Note 19.

 
 Carrying amount of the group's consolidated holdings of ABSs 
                                                                          Financial 
                                                                  assets designated 
                                                                      and otherwise 
                                                                        mandatorily 
                                                                        measured at                 Of which 
                                          Financial     Held at          fair value             held through 
                                        investments   amortised      through profit             consolidated 
                              Trading      at FVOCI        cost            and loss   Total              SEs 
The group                        GBPm          GBPm        GBPm                GBPm    GBPm             GBPm 
Mortgage-related 
 assets:                        1,182           360          14                  99   1,655            163 
 
- sub-prime residential             -           233           -                   -     233             39 
- US Alt-A residential              -            36           -                  73     109             33 
- other residential               723             8           3                   -     734              8 
- commercial property             459            83          11                  26     579             83 
 
Leveraged finance-related 
 assets                           162            31           -                  16     209            156 
Student loan-related 
 assets                            28         1,421           -                   1   1,450          1,410 
Other assets                      596           287           -                   5     888            160 
At 31 Dec 2018                  1,968         2,099          14                 121   4,202          1,889 
 
 

Included in the above table are securities with a carrying amount of GBP78m (2017: GBP884m) held through the SICs, excluding Solitaire, that are consolidated by the group. Although the group includes these assets in full on its balance sheet, significant first loss risks are borne by the third-party capital notes investors. The carrying amount of the capital notes liability at the year ended 31 December 2018 was GBP84m (2017: GBP182m).

The financial assets at FVOCI reserve movement in relation to these ABSs for the year was a decrease of GBP27m (2017: increase of GBP25m). The impairment write-back attributed to the group for the year was GBP37m (2017: write-back of GBP40m).

2017 credit disclosures

The below disclosures were included in the Interim Report 2017 and the Annual Report and Accounts 2017 and do not reflect the adoption of IFRS 9. As these tables are not directly comparable to the current 2018 credit risk tables which are disclosed on an IFRS 9 basis, the 2017 disclosures have been shown below and not adjacent to the 2018 tables.

 
 Total personal lending 
                                                      Continental 
                                                  UK       Europe     Total 
                                                                                     As a % 
                                                                                   of total 
                                                GBPm         GBPm      GBPm     gross loans 
First lien residential mortgages             88,653        4,171    92,824          31.28 
 
- of which: 
  interest-only (including endowment) 
   mortgages                                 24,773           14    24,787           8.35 
  affordability mortgages, including 
   adjustable rate mortgages                      -          303       303           0.10 
 
Other personal lending                       14,648       12,817    27,465           9.25 
- personal loans and overdrafts               7,430       12,386    19,816           6.68 
- credit cards                                7,218          358     7,576           2.55 
- second lien residential mortgages               -           73        73           0.02 
- motor vehicle finance                           -            -         -              - 
 
Total gross loans at 31 Dec 2017            103,301       16,988   120,289          40.53 
 
Impairment allowances on personal lending 
First lien residential mortgages               (108)         (86)     (194) 
 
Other personal lending                         (192)         (51)     (243) 
- personal loans and overdrafts                (110)         (51)     (161) 
- credit cards                                  (82)           -       (82) 
- second lien residential mortgages               -            -         - 
- motor vehicle finance                           -            -         - 
 
Total impairment allowances at 31 Dec 
 2017                                          (300)        (137)     (437) 
 
 
 
 Residential mortgage loans including loan commitments by level of collateral 
(Audited)                                                     The group      The bank 
                                                                   2017          2017 
                                                                   GBPm          GBPm 
Non-impaired loans and advances 
Fully collateralised                                           96,173        90,421 
 
LTV ratio: 
- Less than 50%                                                52,940        51,015 
- 51% to 60%                                                   15,989        14,954 
- 61% to 70%                                                   12,083        10,818 
- 71% to 80%                                                    9,517         8,585 
- 81% to 90%                                                    4,698         4,218 
- 91% to 100%                                                     946           831 
 
Partially collateralised: 
greater than 100% LTV (A)                                         228            91 
- 101% to 110%                                                     92            27 
- 111% to 120%                                                     34            15 
- greater than 120%                                               102            49 
 
Collateral value on A                                             190            59 
 
Impaired loans and advances 
Fully collateralised                                              917           725 
 
LTV ratio: 
- Less than 50%                                                   470           396 
- 51% to 60%                                                      175           136 
- 61% to 70%                                                      115            91 
- 71% to 80%                                                       86            56 
- 81% to 90%                                                       40            28 
- 91% to 100%                                                      31            18 
Partially collateralised: 
greater than 100% LTV (B)                                          64            19 
- 101% to 110%                                                     28             8 
- 111% to 120%                                                     10             6 
- greater than 120%                                                26             5 
Collateral value on B                                              49            18 
 
At 31 Dec                                                      97,382        91,256 
 
 
 
 Total wholesale lending 
                                                               2017 
 
                                                                      As a % 
                                                                          of 
                                                                       total 
                                                          GBPm   gross loans 
Corporate and commercial                               134,513         45.32 
- manufacturing                                         21,494          7.24 
- international trade and services                      47,837         16.12 
- commercial real estate                                18,849          6.35 
- other property-related                                 5,908          1.99 
- government                                             2,583          0.87 
- other commercial                                      37,842         12.75 
Financial                                               41,991         14.15 
- non-bank financial institutions                       27,842          9.38 
- banks                                                 14,149          4.77 
Gross loans at 31 Dec                                  176,504         59.47 
Impairment allowances on wholesale lending 
Corporate and commercial                               (1,671) 
- manufacturing                                          (226) 
- international trade and services                       (497) 
- commercial real estate                                 (268) 
- other property-related                                 (256) 
- government                                               (2) 
- other commercial                                       (422) 
Financial                                                (134) 
- non-bank financial institutions                        (134) 
- banks                                                      - 
Impairment allowances at 31 Dec                        (1,805) 
Impairment allowances % of impaired loans               41.41% 
 
 
 
 Maximum exposure to credit risk 
(Audited)                                                         2017 
                                                                              Exposure 
                                                     Maximum                 to credit 
                                                    exposure     Offset     risk (net) 
The group                                               GBPm       GBPm           GBPm 
Trading assets: loans and advances to banks           20,590       (97)       20,493 
Trading assets: loans and advances to customers       22,520      (222)       22,298 
Derivatives                                          143,335  (139,174)        4,161 
Loans and advances to banks                           14,149      (202)       13,947 
Loans and advances to customers                      280,402   (19,074)      261,328 
Reverse repurchase agreements - non-trading           45,808    (2,748)       43,060 
Total balance sheet exposure to credit risk          728,568  (161,517)      567,051 
 
Total off-balance sheet                              190,413         -       190,413 
 
- financial guarantees(1)                             15,642         -        15,642 
 
  *    loan commitments and other credit-related 
       commitments(1)                                174,771         -       174,771 
 
At 31 Dec                                            918,981  (161,517)      757,464 
 
 
 
The bank                                             GBPm       GBPm       GBPm 
Trading assets: loans and advances to banks        17,744       (97)   17,647 
Trading assets: loans and advances to customers    22,254      (222)   22,032 
Derivatives                                       135,236  (121,736)   13,500 
Loans and advances to banks                        15,160         -    15,160 
Loans and advances to customers                   220,450   (19,024)  201,426 
Reverse repurchase agreements - non-trading        36,627      (342)   36,285 
Total balance sheet exposure to credit risk       588,080  (141,421)  446,659 
Total off-balance sheet                           109,033         -   109,033 
 
- financial guarantees                              9,219         -     9,219 
- loan commitments and other credit-related 
 commitments                                       99,814         -    99,814 
 
At 31 Dec                                         697,113  (141,421)  555,692 
 
 

1 31 December 2017 balances have been restated to include GBP32.5bn of loan commitments (unsettled reverse repurchase agreements) and GBP2.3bn of performance and other guarantees not previously identified for disclosure.

 
 Gross loans and advances to customers by industry sector 
                                                                   2017 
                                                                       Gross loans 
                                                                                by 
                                                                          industry 
                                                                            sector 
                                                                                as 
                                                        Gross loans         a % of 
                                                                and          total 
                                                           advances          gross 
                                                                 to       loans to 
                                                          customers      customers 
The group                                                      GBPm              % 
Personal                                                    120,289        42.56 
Corporate and commercial                                    134,513        47.59 
 
Financial                                                    27,842         9.85 
 
Total gross loans and advances to customers at 31 Dec       282,644       100.00 
 
 
 
 The bank 
Personal                                                 97,248   43.80 
Corporate and commercial                                 89,549   40.34 
 
Financial                                                35,214   15.86 
 
Total gross loans and advances to customers at 31 Dec   222,011  100.00 
 
 
 
 Distribution of financial instruments by credit quality 
(Audited)                                                  2017 
                          Neither past due nor 
                                 impaired 
 
                                                                Past 
                                                                 due              Total 
                                                                 not              gross  Impairment 
                Strong    Good  Satisfactory  Sub-standard  impaired  Impaired   amount  allowances    Total 
The group         GBPm    GBPm          GBPm          GBPm      GBPm      GBPm     GBPm        GBPm     GBPm 
Cash and 
 balances at 
 central 
 banks          97,601       -             -             -         -         -   97,601          -    97,601 
Items in the 
 course 
 of 
 collection 
 from other 
 banks           2,023       -             -             -         -         -    2,023          -     2,023 
Trading 
 assets         57,965  11,279        12,132         1,218         -         -   82,594          -    82,594 
- treasury 
 and other 
 eligible 
 bills             775     252           139           782         -         -    1,948          -     1,948 
- debt 
 securities     29,038   3,577         4,744           177         -         -   37,536          -    37,536 
- loans and 
 advances 
 to banks       12,980   4,207         3,385            18         -         -   20,590          -    20,590 
- loans and 
 advances 
 to customers   15,172   3,243         3,864           241         -         -   22,520          -    22,520 
 
Financial 
 assets 
 designated 
 at fair 
 value             898     118            24             -         -         -    1,040          -     1,040 
 
Derivatives    122,547  17,143         3,113           532         -         -  143,335          -   143,335 
Loans and 
 advances to 
 customers 
 held at 
 amortised 
 cost          157,147  56,744        57,092         4,871       973     5,817  282,644     (2,242)  280,402 
- personal     109,224   5,687         2,860           453       607     1,458  120,289       (437)  119,852 
- corporate 
 and 
 commercial     30,262  45,954        49,458         4,266       355     4,218  134,513     (1,671)  132,842 
- non-bank 
 financial 
 institutions   17,661   5,103         4,774           152        11       141   27,842       (134)   27,708 
 
Loans and 
 advances to 
 banks held 
 at amortised 
 cost           11,509   1,651           982             7         -         -   14,149          -    14,149 
Reverse 
 repurchase 
 agreements 
 - 
 non-trading    36,667   4,563         4,274           304         -         -   45,808          -    45,808 
 
Financial 
 investments    51,478   3,271         1,132           920         -       537   57,338          -    57,338 
 
Other assets     2,118     609         1,358           185         4         4    4,278          -     4,278 
 
At 31 Dec      539,953  95,378        80,107         8,037       977     6,358  730,810     (2,242)  728,568 
 
Percentage of 
 total 
 gross amount    73.8%   13.1%         11.0%          1.1%      0.1%      0.9%   100.0% 
 
 
                                                           2017 
                          Neither past due nor 
                                 impaired 
 
                                                                Past 
                                                                 due              Total 
                                                                 not              gross  Impairment 
                Strong    Good  Satisfactory  Sub-standard  impaired  Impaired   amount  allowances    Total 
The bank          GBPm    GBPm          GBPm          GBPm      GBPm      GBPm     GBPm        GBPm     GBPm 
Cash and 
 balances at 
 central 
 banks          81,358       -             -             -         -         -   81,358          -    81,358 
Items in the 
 course 
 of 
 collection 
 from other 
 banks           1,407       -             -             -         -         -    1,407          -     1,407 
Trading 
 assets         43,271   9,643         9,578         1,218         -         -   63,710          -    63,710 
- treasury 
 and other 
 eligible 
 bills             458       -           139           782         -         -    1,379          -     1,379 
- debt 
 securities     15,251   3,313         3,592           177         -         -   22,333          -    22,333 
- loans and 
 advances 
 to banks       12,493   3,208         2,025            18         -         -   17,744          -    17,744 
- loans and 
 advances 
 to customers   15,069   3,122         3,822           241         -         -   22,254          -    22,254 
 
Derivatives    116,791  15,017         2,915           513         -         -  135,236          -   135,236 
Loans and 
 advances to 
 customers 
 held at 
 amortised 
 cost          133,341  38,408        41,835         3,735       488     4,204  222,011     (1,561)  220,450 
- personal      91,589   2,688         1,175           390       451       955   97,248       (307)   96,941 
- corporate 
 and 
 commercial     15,126  31,551        36,528         3,199        37     3,108   89,549     (1,100)   88,449 
- non-bank 
 financial 
 institutions   26,626   4,169         4,132           146         -       141   35,214       (154)   35,060 
 
Loans and 
 advances to 
 banks held 
 at amortised 
 cost           13,273   1,204           682             1         -         -   15,160          -    15,160 
Reverse 
 repurchase 
 agreements 
 - 
 non-trading    30,807   2,914         2,605           301         -         -   36,627          -    36,627 
Financial 
 investments    29,607   1,034            42           291         -         1   30,975          -    30,975 
 
Other assets     2,146     581           426             4         -         -    3,157          -     3,157 
 
At 31 Dec      452,001  68,801        58,083         6,063       488     4,205  589,641     (1,561)  588,080 
 
                     %       %             %             %         %         %        % 
Percentage of 
 total 
 gross amount     76.6    11.7           9.9           1.0       0.1       0.7    100.0 
 
 
 
 Ageing analysis of days past due but not impaired gross financial instruments 
(Audited) 
                                                                                              Over 
                                                                Up to  30-59  60-89  90-179    180 
                                                              29 days   days   days    days   days    Total 
The group                                                        GBPm   GBPm   GBPm    GBPm   GBPm     GBPm 
                                                             --------  -----  -----  ------  -----  ------- 
Loans and advances held at amortised 
 cost                                                             726    161     86       -      -    973 
 
  *    personal                                                   426    116     65       -      -    607 
 
  *    corporate and commercial                                   291     43     21       -      -    355 
 
  *    financial                                                    9      2      -       -      -     11 
 
Other assets                                                        4      -      -       -      -      4 
 
                                             At 31 Dec 2017       730    161     86       -      -    977 
 
 
 
 The bank 
Loans and advances held at amortised 
 cost                                  340  93  55  --488 
 
  *    personal                        312  87  52  --451 
 
  *    corporate and commercial         28   6   3  -- 37 
 
  *    financial                         -   -   -  --  - 
 
Other assets                             -   -   -  --  - 
 
                       At 31 Dec 2017  340  93  55  --488 
 
 
 
Loan impairment charges and other credit risk provisions 
                                                                 2017 
                                                                 GBPm 
Net impairment charge on loans and advances                   (624) 
Release of impairment on available-for-sale debt securities    145 
Other credit risk provisions                                   (16) 
 
Total                                                         (495) 
 
 
 
 Impaired loans and advances to customers and banks by industry sector 
(Audited) 
                                                                   2017 
                                                  Individually  Collectively 
                                                      assessed      assessed       Total 
                                                          GBPm          GBPm        GBPm 
Banks                                                        -             -         - 
Customers                                                5,365           452     5,817 
- personal                                               1,061           397     1,458 
- corporate and commercial                               4,163            55     4,218 
- financial                                                141             -       141 
 
At 31 Dec                                                5,365           452     5,817 
 
 
 
 Renegotiated loans and advances to customers by industry sector 
                                                                           2017 
                                                              Other                        Non-bank 
                                             Residential   personal        Corporate      financial 
                                               mortgages    lending   and commercial   institutions     Total 
                                                    GBPm       GBPm             GBPm           GBPm      GBPm 
Neither past due nor impaired                        252         57            1,203              6  1,518 
Past due not impaired                                 33          6               42              -     81 
Impaired                                             211         71            2,165            136  2,583 
 
Renegotiated loans at 31 Dec                         496        134            3,410            142  4,182 
 
Impairment allowance on renegotiated 
 loans                                                                                                (684) 
                                             -----------  ---------  ---------------  ------------- 
 
 
 Loan impairment charge to the income statement by industry sector 
                                                                   2017 
                                                                   GBPm 
                                                                ------- 
Personal                                                         120 
- residential mortgages                                            7 
- other personal                                                 113 
 
Corporate and commercial                                         454 
 
  *    manufacturing and international trade and services        227 
 
  *    commercial real estate and other property-related         149 
 
  *    other commercial                                           78 
 
Financial                                                         50 
Total loan impairment charge for the year ended 31 Dec           624 
 
Individually assessed impairment allowances                      529 
 
  *    new allowances                                            919 
 
  *    release of allowances no longer required                 (366) 
 
  *    recoveries of amounts previously written off              (24) 
 
Collectively assessed impairment allowances                       95 
 
  *    new allowances net of allowance releases                  327 
 
  *    recoveries of amounts previously written off             (232) 
 
Total loan impairment charge for the year ended 31 Dec           624 
 
 
 
 Movement in impairment allowances on loans and advances to customers 
  and banks 
 (Audited)                                                Banks            Customers 
                                                   Individually    Individually    Collectively 
                                                       assessed        assessed        assessed     Total 
 The group                                                 GBPm            GBPm            GBPm      GBPm 
 At 1 Jan 2017                                                -      1,729              828      2,557 
 Amounts written off                                          -       (310)            (173)      (483) 
 Recoveries of loans and advances written 
  off in previous years                                       -         14               96        110 
 Loan impairment charge                                       -         10               31         41 
 Exchange and other movements                                 -        (53)            (236)      (289) 
------------------------------------------------- 
 At 30 June 2017                                              -      1,390              546      1,936 
-------------------------------------------------                           --- 
 As a percentage of gross loans and 
  advances(1)                                                 -           0.50%           0.20%     0.65% 
------------------------------------------------- 
 
 At 1 July 2017                                               -      1,390              546      1,936 
 Amounts written off                                          -       (243)            (185)      (428) 
 Recoveries of loans and advances written 
  off in previous years                                       -         10              136        146 
 Loan impairment charge                                       -        519               64        583 
 Exchange and other movements                                 -          1                4          5 
------------------------------------------------- 
 At 31 Dec 2017                                               -      1,677              565      2,242 
-------------------------------------------------                           --- 
 As a percentage of gross loans and 
  advances(1)                                                             0.59%           0.20%     0.76% 
------------------------------------------------- 
 
   1      Net of reverse repo transactions, settlement accounts and stock borrowings. 
 
                                                                    2017 
                                                  Banks            Customers 
                                           Individually    Individually    Collectively 
                                               assessed        assessed        assessed     Total 
The bank                                           GBPm            GBPm            GBPm      GBPm 
At 1 Jan                                              -       1,074             475      1,549 
Amounts written off                                   -        (345)           (308)      (653) 
Recoveries of loans and advances written 
 off in previous years                                -          20             201        221 
Loan impairment charge                                -         347              84        431 
Exchange and other movements                          -           1              12         13 
At 31 Dec                                             -       1,097             464      1,561 
 
as a percentage of gross loans and 
 advances(1)                                          -           0.49%           0.21%     0.66% 
 
 
   1      Net of reverse repo transactions, settlement accounts and stock borrowings. 
 
Carrying amount of consolidated holdings of ABS 
                                                                                Of which 
                                                                            held through 
                                     Available-     Loans and               consolidated 
                            Trading    for-sale   receivables  Total(1)              SEs 
                               GBPm        GBPm          GBPm      GBPm             GBPm 
Mortgage-related assets: 
- sub-prime residential           4         679            24       707            358 
- US Alt-A residential            -         778             -       778            771 
- other residential             603         134           816     1,553             56 
- commercial property           444         198            41       683            167 
Leveraged finance-related 
 assets                          38         276             -       314            209 
Student loan-related 
 assets                          29       1,627             -     1,656          1,597 
 
Other assets                    573         455             1     1,029            317 
            At 31 Dec 2017    1,691       4,147           882     6,720          3,475 
 

1 The asset-backed securities are primarily US Dollar ('USD') denominated. Principal carrying amounts are converted into sterling ('GBP') at the prevailing exchange rates at 31 December 2017: 1GBP : USD 1.351.

Liquidity and funding risk in 2018

Liquidity coverage ratio

The Liquidity Coverage Ratio ('LCR') aims to ensure that a bank has sufficient unencumbered high-quality liquid assets ('HQLA') to meet its liquidity needs in a 30-calendar-day liquidity stress scenario. HQLA consist of cash or assets that can be converted into cash at little or no loss of value in markets.

At 31 December 2018, all the group's principal operating entities were within the LCR risk tolerance level established by the Board and applicable under the LFRF.

The following table displays the individual LCR levels for HSBC Bank Plc's principal operating entities on an EC LCR Delegated Regulation basis.

 
Operating entities' LCRs 
                                    At 
                             31 Dec    31 Dec 
                               2018      2017 
                  Footnotes       %         % 
HSBC Bank Plc        1,2        147     139 
HSBC France                     128     149 
                             ------  ------ 
HSBC Trinkaus & 
 Burkhardt AG                   111     114 
                             ------  ------ 
 

1 2017 figures are for HSBC UK Liquidity Group which comprises: HSBC Bank plc (pre ring-fencing), Marks and Spencer Financial Services plc, HSBC Trust Company (UK) Limited and Private Bank (UK) Limited.

2 2018 LCR is higher than 2017, as we carry surplus liquidity in preparation for the UK's withdrawal from the EU.

Net stable funding ratio

The Net Stable Funding Ratio ('NSFR') requires institutions to maintain sufficient stable funding relative to required stable funding, and reflects a bank's long-term funding profile (funding with a term of more than a year). It is designed to complement the LCR.

At 31 December 2018, all the group's principal operating entities were within the NSFR risk tolerance level established by the Board and applicable under the LFRF.

The table below displays the NSFR levels for the principal operating entities on a BCBS 295 basis.

 
Operating entities' NSFRs 
                                    At 
                             31 Dec    31 Dec 
                               2018      2017 
                  Footnotes       %         % 
HSBC Bank Plc         1         113     108 
                             ------  ------ 
HSBC France                     113     116 
HSBC Trinkaus 
 & Burkhardt AG                 116     117 
                             ------  ------ 
 

1 In adopting the NSFR (BCBS 295) as a key internal risk management metric, the HSBC Group has, until such time that the NSFR becomes a binding regulatory requirement on HSBC Group or the operating entity locally, permitted entities to reduce the amount of Required Stable Funding Requirement (RSF) for listed equities where the valuation risk has been hedged through an exchange traded daily cash margined derivative, due to management's view as to the speed at which these assets could be monetised under stress and the mitigation of the valuation risk. HSBC Bank Plc is applying a lower RSF to such equities.

Depositor concentration and term funding maturity concentration

The LCR and NSFR metrics assume a stressed outflow based on a portfolio of depositors within each deposit segment. The validity of these assumptions is undermined if the underlying depositors do not represent a large enough portfolio so that a depositor concentration exists.

In addition to this, operating entities are exposed to term re-financing concentration risk if the current maturity profile results in future maturities being overly concentrated in any defined period.

Liquid assets of the group's principal operating entities

The table below shows the unweighted liquidity value of assets categorised as liquid, which is used for the purposes of calculating the LCR metric. This reflects the stock of unencumbered liquid assets at the reporting date, using the regulatory definition of liquid assets.

 
Operating entities' liquid 
 assets 
                             Estimated    At Estimated 
                             liquidity       liquidity 
                                 value           value 
                             At 31 Dec          31 Dec 
                                  2018            2017 
                                  GBPm            GBPm 
HSBC Bank Plc 
Level 1                         84,185       119,198 
Level 2a                         4,243         2,157 
Level 2b                         7,764        13,899 
HSBC France 
Level 1                         15,545        16,441 
Level 2a                           435           741 
Level 2b                            24             2 
HSBC Trinkaus & Burkhardt 
 AG 
Level 1                          5,605         6,237 
Level 2a                            60            50 
Level 2b                           520           590 
 
 

Sources of funding

Our primary sources of funding are customer current accounts, repo and wholesale securities.

The following 'Funding sources and uses' table provides a consolidated view of how our balance sheet is funded, and should be read in light of the LFRF, which requires operating entities to manage liquidity and funding risk on a stand-alone basis.

The table analyses our consolidated balance sheet according to the assets that primarily arise from operating activities and the sources of funding primarily supporting these activities. Assets and liabilities that do not arise from operating activities are presented as a net balancing source or deployment of funds.

In 2018, the level of customer accounts continued to exceed the level of loans and advances to customers. The positive funding gap was predominantly deployed in liquid assets, cash and balances with central banks and financial investments, as required by the LFRF.

 
 Funding sources and uses for the group 
                                 2018     2017                                            2018       2017 
                                 GBPm     GBPm                                            GBPm       GBPm 
                              -------  ------- 
Sources                                         Uses 
                              ------- 
                                                Loans and advances to 
Customer accounts             180,836  381,546   customers                     111,964          280,402 
 
                                                Loans and advances to 
Deposits by banks              24,532   29,349   banks                          13,628           14,149 
 
Repurchase agreements                           Reverse repurchase agreements 
 - non-trading                 46,583   37,775   - non-trading                  80,102           45,808 
                                                                               -------  ------ 
                                                Cash collateral, margin 
Debt securities in issue       22,721   13,286   and settlement accounts        28,870                N/A 
                                                                                        ------ 
Cash collateral, margin 
 and settlement accounts       35,561      N/A  Assets held for sale                37              461 
                                       -------                                          ------ 
Liabilities of disposal 
 groups held for sale               -      454  Trading assets                  95,420          145,725 
                                                                                        ------ 
Subordinated liabilities       13,770   16,494  - reverse repos                  6,141            5,987 
 
Financial liabilities 
 designated at fair value                       - stock borrowing                6,498            5,189 
                               36,922   18,249  - settlement accounts                      N/A    4,947 
 
Liabilities under insurance 
 contracts                     20,657   21,033  - other trading assets          82,781          129,602 
                                                                                        ------ 
Trading liabilities            49,514  106,496  Financial investments           47,272           58,000 
                                                                                        ------ 
 
  *    repos                    1,027    1,182 
                                                Cash and balances with 
- stock lending                 9,161   21,156   central banks                  52,013    97,601 
- settlement accounts             N/A    2,959 
- other trading liabilities    39,326   81,199 
 
                                                Net deployment in other 
                                                 balance sheet assets 
Total equity                   27,409   44,049   and liabilities                29,199    26,585 
 
At 31 Dec                     458,505  668,731  At 31 Dec                      458,505          668,731 
                                                                               -------  ------ 
 

Contingent liquidity risk arising from committed lending facilities

The group provides customers with committed facilities such as standby facilities to corporate customers and committed backstop lines to conduits sponsored by the group. All of the undrawn commitments provided to conduits or external customers are accounted for in the LCR and NSFR in line with the applicable regulations. This ensures that under a stress scenario any additional outflow generated by increased utilisation of these committed facilities by either customers or the group's sponsored conduits will not give rise to liquidity risk for the group.

Since the group controls the size of the portfolio of securities held by these conduits, no contingent liquidity risk exposure arises as a result of these undrawn committed lending facilities. In relation to commitments to customers, the table below shows the level of undrawn commitments outstanding in terms of the five largest single facilities and the largest market sector.

 
The group's contractual exposures at 31 December monitored under the 
 contingent liquidity risk limit structure 
                                                                   2018     2017 
                                                       Footnotes  GBPbn    GBPbn 
Commitments to conduits 
Consolidated multi-seller conduits                         1 
- total lines                                                       5.6    6.8 
- largest individual lines                                          0.3    0.6 
Consolidated securities investment conduits - total 
 lines                                                              3.4    3.4 
Commitments to customers 
- five largest                                             2        3.0    2.5 
- largest market sector                                    3        9.1   19.0 
 
 

1 Exposures relate to the Regency multi-seller conduit. This vehicle provides funding to group customers by issuing debt secured by a diversified pool of customer-originated assets.

2 Represents the undrawn balance for the five largest committed liquidity facilities provided to customers, other than those facilities to conduits.

3 Represents the undrawn balance for the total of all committed liquidity facilities provided to the largest market sector, other than those facilities to conduits.

Asset encumbrance and collateral management

An asset is defined as encumbered if it has been pledged as collateral against an existing liability and, as a result, is no longer available to the group to secure funding, satisfy collateral needs or be sold to reduce the funding requirement. Collateral is managed on an operating entity basis consistent with the approach to managing liquidity and funding. Available collateral held in an operating entity is managed as a single consistent collateral pool

from which each operating entity will seek to optimise the use of the available collateral. The objective of this disclosure is to facilitate an understanding of available and unrestricted assets that could be used to support potential future funding and collateral needs. The disclosure is not designed to identify assets which would be available to meet the claims of creditors or to predict assets that would be available to creditors in the event of a resolution or bankruptcy.

 
 Summary of assets available to support potential future funding and 
  collateral needs (on- and off-balance sheet) 
                                                                    2018         2017 
                                                                    GBPm         GBPm 
 Total on-balance sheet assets at 31 Dec                        604,958    818,868 
------------------------------------------------------------- 
 Less: 
 - reverse repo/stock borrowing receivables and derivative 
  assets                                                       (237,020)  (200,319) 
 - other assets that cannot be pledged as collateral            (56,982)   (79,306) 
 Total on-balance sheet assets that can support funding 
  and collateral needs at 31 Dec                                310,956    539,243 
------------------------------------------------------------- 
 Add: off-balance sheet assets 
 - fair value of collateral received in relation to 
  reverse repo/stock borrowing/derivatives that is available 
  to sell or repledge                                           250,277    173,386 
 Total assets that can support future funding and collateral 
  needs                                                         561,233    712,629 
------------------------------------------------------------- 
 Less: 
 - on-balance sheet assets pledged                              (89,123)   (88,768) 
 - re-pledging of off-balance sheet collateral received 
  in relation to reverse repo/stock borrowing/derivatives      (202,782)  (130,430) 
------------------------------------------------------------- 
 Assets available to support funding and collateral 
  needs at 31 Dec                                               269,328    493,431 
------------------------------------------------------------- 
 

Market risk in 2018

Market risk is the risk that movements in market factors, including foreign exchange rates and commodity prices, interest rates, credit spreads and equity prices will reduce the group's income or the value of its portfolios.

There were no material changes to our policies and practices for the management of market risk in 2018.

Exposure to market risk is separated into two portfolios.

Trading portfolios comprise positions arising from market-making and warehousing of customer-derived positions.

Non-trading portfolios including BSM comprise positions that primarily arise from the interest rate management of the group's retail and commercial banking assets and liabilities, financial investments designated as as held-to-collect-and-sale ('HTCS'), and exposures arising from the group's insurance operations.

Trading portfolios

Value at risk of the trading portfolios

(Audited)

Trading VaR predominantly resides within Global Markets where it was GBP39.5m at 31 December 2018 compared with GBP36.3m at 31 December 2017. The Total Trading VaR moderately increased during the first half of 2018 and suddenly decreased in May 2018 following a change of methodology in HBFR to assess the shocks to apply on credit spreads. Both the Total Trading VaR and Credit VaR remained relatively stable until the last quarter of 2018. In December 2018, the IR Trading VaR increased from GBP17m to GBP22m following a change of positions, which resulted in an increase of the total trading VaR. The change in Equity Trading VaR was from fluctuations in dividend and correlation exposures.

The ALCO-trading book has been included in this exercise, which was not the case last year.

The long protection position held in the book against a Sterling devaluation for a future capital injection into HBFR results in a decrease of the FX Trading VaR since November 2018. The daily levels of Total Trading VaR over the past year are set out in the graph below.

 
 Daily VaR (trading portfolios), 99% 1 day (GBPm) 
 
 
Trading 
 VaR 
 inc RNIV 
IR trading 
 inc RNIV 
Equity 
 Trading 
 inc RNIV 
CR Trading 
FX Trading 
Diversification 
 
 
 
 

The group's trading VaR for the year is shown in the table below.

 
 Trading VaR, 99% 1 day 
 (Audited) 
                            Foreign 
                           exchange                       Credit 
                           (FX) and    Interest  Equity   Spread              Portfolio 
                          commodity   rate (IR)    (EQ)     (CS)     Diversification(1)    Total(2) 
                               GBPm        GBPm    GBPm     GBPm                   GBPm        GBPm 
Balance at 31 Dec 
 2018                           7.9        21.7    15.4     16.6             (22.0)          39.6 
 
Average                         5.2        18.4    14.1     13.9             (19.0)          32.6 
Maximum                        11.7        25.1    22.1     24.3                             44.0 
Minimum                         2.1        14.5     9.6      8.1                             24.1 
 
 
 Balance at 31 Dec 2017         2.1        17.1    21.4     16.2             (20.5)          36.3 
 
Average                         5.2        25.3    12.0      9.2             (19.1)          32.6 
Maximum                        15.3        52.3    21.4     17.4                             53.4 
Minimum                         0.9        17.1     7.5      3.4                             26.2 
 
 

1 Portfolio diversification is the market risk dispersion effect of holding a portfolio containing different risk types. It represents the reduction in unsystematic market risk that occurs when combining a number of different risk types, for example, interest rate, equity and foreign exchange, together in one portfolio. It is measured as the difference between the sum of the VaR by individual risk type and the combined total VaR. A negative number represents the benefit of portfolio diversification. As the maximum occurs on different days for different risk types, it is not meaningful to calculate a portfolio diversification benefit for this measure.

2 The total VaR is non-additive across risk types due to diversification effect and it includes VaR RNIV.

Back-testing

In 2018, the group experienced two back-testing exceptions, one against hypothetical loss and one against actual loss. There was no evidence of model failure or control error.

Non-trading portfolios

Value at risk of the non-trading portfolios

(Audited)

Following the go live of the ring-fenced bank HSBC UK on 1 July, the non-trading VaR of our London Balance Sheet Management (BSM) desk dropped by GBP19m. This is to reflect the legal transfer of certain positions into HSBC UK. These positions were made up of ALCM buy in for the management of the structural interest rate risk (50% of the risk transferred to the combined to the bank), the existing cash flow hedge (CFH) positions referencing transferred asset pools and the high quality liquid asset (HQLA) (and corresponding hedges) purchased to form part of the newly formed HSBC UK Liquid Asset Buffer (LAB).

Our non trading ALCO books have been included in the non trading VaR. They contain capital issuances for the group (including TLAC) and any corresponding hedges. This resulted in an average decrease of the non trading VaR by GBP6m.

The daily levels of total non-trading VaR over the last year are set out in the graph below.

 
 Daily VaR (non-trading portfolios), 99% 1 day (GBPm) 
 
 
Non-trading 
 VaR 
IR non-trading 
CS non-trading 
Diversification 
 
 
 
 
 
 
 

The group's non-trading VaR for the year is shown in the table below.

 
 Non-trading VaR, 99% 1 day 
 (Audited) 
                                       Credit 
                            Interest   spread           Portfolio 
                           rate (IR)     (CS)     diversification    Total 
                                GBPm     GBPm                GBPm     GBPm 
 Balance at 31 Dec 2018         19.4      5.7            (4.6)      20.5 
------------------------ 
 Average                        32.8     16.4           (13.7)      35.5 
 Maximum                        59.3     41.3                       64.6 
 Minimum                        17.4      4.9                       17.7 
------------------------ 
 
 Balance at 31 Dec 2017         45.8     22.1           (17.8)      50.1 
------------------------ 
 Average                        64.1     29.3           (23.6)      69.8 
 Maximum                        92.0     53.4                       91.2 
------------------------ 
 Minimum                        44.8      9.3                       47.7 
------------------------ 
 

Structural foreign exchange exposures

The group's structural foreign currency exposure is represented by the net asset value of its foreign currency equity and subordinated debt investments in subsidiary undertakings, branches, joint ventures and associates.

For our policies and procedures for managing structural foreign exchange exposures, see page 30 of the 'Risk management' section.

 
 Net structural foreign exchange 
  exposures 
                           2018      2017 
                           GBPm      GBPm 
Currency of structural 
 exposure 
Euro(1)                  12,866  11,896 
US Dollars(1)               805     648 
                         ------ 
South African rand(1)       357     349 
Russian rouble              197     225 
Others, each less than 
 GBP150m(1)                 433     404 
                         ------ 
At 31 Dec                14,658  13,522 
                         ------ 
 

1 The net structural exposure at 31 December 2017 has been restated by GBP946m to increase the Euro (GBP764m), US dollar (GBP133m), Armenian dram (GBP25m), South African rand (GBP23m), and Swiss franc (GBP1m) exposures. This is due to incorrect currency classification of dotation capital to branches, elimination of subsidiaries' shareholders' equity on date of acquisition, and Additional Tier 1 instruments held in the UK.

Operational risk in 2018

Operational risk is the risk to achieving our strategy or objectives as a result of inadequate or failed internal processes, people and systems or from external events.

Responsibility for minimising operational risk lies with HSBC's employees. They are required to manage the operational risks of the business and operational activities for which they are responsible.

A summary of our current policies and practices regarding the management of operational risk is set out on page 31.

Operational risk exposures

In 2018 we continued our ongoing work to strengthen those controls that manage our most material risks. Among other measures, we:

-- further enhanced our controls to help ensure that we know our customers, ask the right questions, monitor transactions and escalate concerns to detect, prevent and deter financial crime risk;

-- implemented a number of initiatives to raise our standards in relation to the conduct of our business as described on page 31 of the 'Regulatory compliance risk management' section;

-- increased monitoring and enhanced detective controls to manage fraud risks which arise from new technologies and new ways of banking;

   --    strengthened internal security controls to help prevent 

cyber-attacks;

   --    improved controls and security to protect customers when using digital channels; and 

-- enhanced our third-party risk management capability to help enable the consistent risk assessment of any third-party service.

Further information on the nature of these risks is provided in 'Top and emerging risks' on page 20 and in 'Risk management' from pages 23 to 24.

Operational risk losses

Operational risk losses in 2018 are higher than in 2017. Total losses in both years were reduced by the write-back of provisions for a large conduct-related event. For further details, see Note 32 on the Financial Statements and on conduct-related costs included in significant items on page 12.

Insurance manufacturing operations risk in 2018

Our insurance manufacturing operations are subject to insurance risk and financial risk, including market risk, credit risk and liquidity risk.

A summary of our current policies and practices regarding the management of insurance risk is set out on page 33.

The group's bancassurance model

We operate an integrated bancassurance model that provides insurance products principally for customers with whom we have a banking relationship.

The insurance contracts we sell relate to the underlying needs of our banking customers, which we can identify from our point-of-sale contacts and customer knowledge. The majority of sales are of savings and investment products and term and credit life contracts.

By focusing largely on personal and SME lines of business, we are able to optimise volumes and diversify individual insurance risks.

We choose to manufacture these insurance products in HSBC subsidiaries based on an assessment of operational scale and risk appetite. Manufacturing insurance allows us to retain the risks and rewards associated with writing insurance contracts by keeping part of the underwriting profit and investment income within the bank.

We have life insurance manufacturing subsidiaries in France, Malta and the UK. Where we do not have the risk appetite or operational scale to be an effective insurance manufacturer, we engage with a handful of leading external insurance companies in order to provide insurance products to our customers through our banking network and direct channels. These arrangements are generally structured with our exclusive strategic partners and earn the bank a combination of commissions, fees and a share of profits.

Insurance products are sold through all global businesses, but predominantly by RBWM, GPB and CMB through our branches and direct channels.

Measurement

(Audited)

The risk profile of our insurance manufacturing businesses is measured using an economic capital approach. Assets and liabilities are measured on a market value basis, and a capital requirement is defined to ensure that there is a less than one-in-200 chance of insolvency over a one-year time horizon, given the risks to which the businesses are exposed. The methodology for the economic capital calculation is largely aligned to the pan-European Solvency II insurance capital regulations. The economic capital coverage ratio (economic net asset value divided by the economic capital requirement) is a key risk appetite measure. The business has a current appetite to remain above 140% with a tolerance of 110%. In addition to economic capital, the regulatory solvency ratio is also a metric used to manage risk appetite on an entity basis.

The following table shows the composition of assets and liabilities by contract type.

 
Balance sheet of insurance manufacturing subsidiaries by type of contract 
 (Audited) 
                                                                                         Shareholder 
                                                      With    Unit-          Other            assets 
                                                       DPF   linked   contracts(1)   and liabilities     Total 
                                         Footnotes    GBPm     GBPm           GBPm              GBPm      GBPm 
Financial assets                                    18,619    1,602            253             1,872  22,346 
- financial assets designated and 
 otherwise mandatorily measured at 
 fair value through profit or loss                   7,850    1,548             87               809  10,294 
- derivatives                                           92        -              -                 3      95 
- financial investments - at amortised 
 cost                                                  182        -              -                 6     188 
- financial investments - at fair 
 value through other comprehensive 
 income                                              8,698        -            108               947   9,753 
- other financial assets                     2       1,797       54             58               107   2,016 
Reinsurance assets                                       -       50            145                 -     195 
PVIF                                        3            -        -              -               652     652 
Other assets and investment properties                 774        1              -                48     823 
Total assets at 31 Dec 2018                         19,393    1,653            398             2,572  24,016 
                                        ----------  ------  -------  -------------  ----------------  ------ 
Liabilities under investment contracts 
 designated at fair value                                -      611              -                 -     611 
 
Liabilities under insurance contracts               19,262    1,041            354                 -  20,657 
 
Deferred tax                                 4           -        1              -               162     163 
                                        ----------  ------           -------------                    ------ 
Other liabilities                                        -        -              -             1,294   1,294 
Total liabilities at 31 Dec 2018                    19,262    1,653            354             1,456  22,725 
Total equity at 31 Dec 2018                              -        -              -             1,291   1,291 
                                        ---------- 
Total liabilities and equity at 31 
 Dec 2018                                           19,262    1,653            354             2,747  24,016 
                                        ---------- 
 
 
Financial assets                             18,749  1,530  190  1,906  22,375 
- financial assets designated at 
 fair value                                   7,020  1,466   85    630   9,201 
- derivatives                                    95      -    -     30     125 
- financial investments - HTM                     -      -    -      -       - 
- financial investments - AFS                 9,918      -  104  1,188  11,210 
- other financial assets                  2   1,716     64    1     58   1,839 
Reinsurance assets                                -    188  159      -     347 
PVIF                                     3        -      -    -    572     572 
Other assets and investment properties          784      1    1    449   1,235 
Total assets at 31 Dec 2017                  19,533  1,719  350  2,927  24,529 
 
Liabilities under investment contracts 
 designated at fair value                         -    548    -      -     548 
Liabilities under insurance contracts        19,533  1,166  334      -  21,033 
Deferred tax                              4       -      5    -    156     161 
Other liabilities                                 -      -    -  1,561   1,561 
 
Total liabilities at 31 Dec 2017             19,533  1,719  334  1,717  23,303 
Total equity at 31 Dec 2017                       -      -    -  1,226   1,226 
 
Total liabilities and equity at 31 
 Dec 31 Dec 2017                             19,533  1,719  334  2,943  24,529 
 
 
   1      'Other contracts' includes term assurance and credit life insurance. 

2 Comprise mainly loans and advances to banks, cash and intercompany balances with other non-insurance legal entities.

   3      Present value of in-force long-term insurance business. 
   4      'Deferred tax' includes the deferred tax liabilities arising on recognition of PVIF. 

Key risk types

The key risks for the insurance operations are market risks (in particular interest rate and equity) and credit risks, followed by insurance underwriting risks and operational risks. Liquidity risk, whilst significant for the bank, is minor for our insurance operations.

Market risk

(Audited)

Description and exposure

Market risk is the risk of changes in market factors affecting the bank's capital or profit. Market factors include interest rates, equity and growth assets and foreign exchange rates.

Our exposure varies depending on the type of contract issued. Our most significant life insurance products are investment contracts with discretionary participating features ('DPF') issued in France. These products typically include some form of capital guarantee or guaranteed return on the sums invested by the policyholders, to which discretionary bonuses are added if allowed by the overall performance of the funds. These funds are primarily invested in bonds with a proportion allocated to other asset classes, to provide customers with the potential for enhanced returns.

DPF products expose the bank to the risk of variation in asset returns, which will impact our participation in the investment performance. In addition, in some scenarios the asset returns can become insufficient to cover the policyholders' financial guarantees, in which case the shortfall has to be met by the bank. Reserves are held against the cost of such guarantees, calculated by stochastic modelling.

Where local rules require, these reserves are held as part of liabilities under insurance contracts. Any remainder is accounted for as a deduction from the present value of in-force 'PVIF' long-term insurance contracts. The table below shows the total reserve held for the cost of guarantees, the range of investment returns on assets supporting these products and the implied investment return that would enable the business to meet the guarantees.

The financial guarantees offered on some portfolios exceeded the current yield on the assets that back them.

For unit-linked contracts, market risk is substantially borne by the policyholder, but some market risk exposure typically remains as fees earned are related to the market value of the linked assets.

 
 Financial return guarantees 
 (Audited) 
                                            2018                                        2017 
                                            Long-term                                  Long-term 
                             Investment    investment                   Investment    investment 
                                returns       returns          Cost        returns       returns 
                                implied   on relevant            of        implied   on relevant            Cost 
                           by guarantee    portfolios    guarantees   by guarantee    portfolios   of guarantees 
               Footnotes              %             %          GBPm              %             %            GBPm 
                          ------------- 
                                                1.5 - 
Capital                               -           2.7            73            0.0           3.2            67 
 
Nominal 
 annual 
 return        1                    2.6           2.7            73            2.6           3.2            80 
Nominal 
 annual 
 return                             4.5           2.7            45            4.5           3.2            44 
At 31 Dec                                                       191                                        191 
               ---------                               ------------ 
 

1 A block of contracts in France with guaranteed nominal annual returns in the range 1.25%-3.72% are reported in line with the average guaranteed return of 2.6% (2017: 2.6%) offered to policyholders on these contracts.

Sensitivities

The following table illustrates the effects of selected interest rate and equity price scenarios on our profit for the year and the total equity of our insurance manufacturing subsidiaries.

Where appropriate, the effects of the sensitivity tests on profit after tax and equity incorporate the impact of the stress on the PVIF. Due in part to the impact of the cost of guarantees and hedging strategies which may be in place, the relationship between the profit and total equity and the risk factors is non-linear. Therefore, the results disclosed should not be extrapolated to measure sensitivities to different levels of stress. For the same reason, the impact of the stress is not necessarily symmetrical on the upside and downside. The sensitivities are stated before allowance for management actions which may mitigate the effect of changes in the market environment. The sensitivities presented allow for adverse changes in policyholder behaviour that may arise in response to changes in market rates.

Changes in sensitivity compared to 2017 were primarily driven by the impact of increasing yields in France on the projected cost of options and guarantees.

 
 Sensitivity of the group's insurance manufacturing subsidiaries to 
  market risk factors 
 (Audited) 
                                                         2018                    2017 
                                                       Effect   Effect                   Effect 
                                                           on       on        Effect         on 
                                                       profit    total     on profit      total 
                                                    after tax   equity     after tax     equity 
                                                         GBPm     GBPm          GBPm       GBPm 
+100 basis point parallel shift 
 in yield curves                                       32          18         24           9 
 
-100 basis point parallel shift 
 in yield curves                                      (35)        (19)       (44)        (28) 
10% increase in equity prices                          23          23         20          20 
 
10% decrease in equity prices                         (21)        (21)       (19)        (19) 
 
 

Credit risk

(Audited)

Description and exposure

Credit risk arises in two main areas for our insurance manufacturers:

-- risk associated with credit spread volatility and default by debt security counterparties after investing premiums to generate a return for policyholders and shareholders; and

-- risk of default by reinsurance counterparties and non-reimbursement for claims made after ceding insurance risk.

The amounts outstanding at the balance sheet date in respect of these items are shown in the table on page 66.

The credit quality of the reinsurers' share of liabilities under insurance contracts is assessed as 'satisfactory' or higher as defined on page 27, with 100% of the exposure being neither past due nor impaired.

Credit risk on assets supporting unit-linked liabilities is predominantly borne by the policyholder; therefore our exposure is primarily related to liabilities under non-linked insurance and investment contracts and shareholders' funds. The credit quality of these financial assets is included in the table on page 46.

Liquidity risk

(Audited)

Description and exposure

Liquidity risk is the risk that an insurance operation, though solvent, either does not have sufficient financial resources available to meet its obligations when they fall due, or can secure them only at excessive cost.

The following table shows the expected undiscounted cash flows for insurance contract liabilities at 31 December 2018. The liquidity risk exposure is wholly borne by the policyholder in the case of unit-linked business and is shared with the policyholder for non-linked insurance.

The profile of the expected maturity of insurance contracts at

31 December 2018 remained comparable with 2017.

The remaining contractual maturity of investment contract liabilities is included in Note 27.

 
 Expected maturity of insurance contract liabilities 
 (Audited) 
                                        Expected cash flows (undiscounted) 
                                  Within                         Over 15 
                                  1 year  1-5 years  5-15 years    years      Total 
                                    GBPm       GBPm        GBPm     GBPm       GBPm 
Unit-linked                          177        362         472      433    1,444 
 
With DPF and Other contracts       1,445      6,735       6,606    4,787   19,573 
 
At 31 Dec 2018                     1,622      7,097       7,078    5,220   21,017 
 
 
Unit-linked                          289        323         436      440    1,488 
 
With DPF and Other contracts       1,460      6,665       6,625    5,212   19,962 
 
               At 31 Dec 2017      1,749      6,988       7,061    5,652   21,450 
 
 

Insurance risk

Description and exposure

Insurance risk is the risk of loss through adverse experience, in either timing or amount, of insurance underwriting parameters (non-economic assumptions). These parameters include mortality, morbidity, longevity, lapses and unit costs.

The principal risk we face is that, over time, the cost of the contract, including claims and benefits, may exceed the total amount of premiums and investment income received.

The table on page 66 analyses our insurance manufacturing exposures by type of contract.

The insurance risk profile and related exposures remain largely consistent with those observed at 31 December 2017.

Sensitivities

The table below shows the sensitivity of profit and total equity to reasonably possible changes in non-economic assumptions across all our insurance manufacturing subsidiaries.

Mortality and morbidity risk is typically associated with life insurance contracts. The effect on profit of an increase in mortality or morbidity depends on the type of business being written. Our largest exposure to mortality and morbidity risk exists in the UK.

Sensitivity to lapse rates depends on the type of contracts being written. For a portfolio of term assurance, an increase in lapse rates typically has a negative effect on profit due to the loss of future income on the lapsed policies. However, some contract lapses have a positive effect on profit due to the existence of policy surrender charges. We are most sensitive to a change in lapse rates in France.

Expense rate risk is the exposure to a change in the cost of administering insurance contracts. To the extent that increased expenses cannot be passed on to policyholders, an increase in expense rates will have a negative effect on our profits.

 
 Sensitivity analysis 
(Audited) 
                            2018    2017 
                            GBPm    GBPm 
Effect on profit after 
 tax and total equity 
 at 31 Dec 
10% increase in mortality 
 and/or morbidity rates     (19)  (18) 
10% decrease in mortality 
 and/or morbidity rates      19    18 
10% increase in lapse 
 rates                      (27)  (22) 
10% decrease in lapse 
 rates                       30    25 
 
10% increase in expense 
 rates                      (33)  (31) 
 
10% decrease in expense 
 rates                       34    31 
 
 
 
 Capital 
 
 
 Capital management 
 

Approach and policy

(Audited)

Our objective in managing the group's capital is to maintain appropriate levels of capital to support our business strategy and meet regulatory and stress testing related requirements.

We manage group capital to ensure that we exceed current and expected future requirements, and that we respect the payment priority of our capital providers. Throughout 2018, we complied with the Prudential Regulation Authority's ('PRA') regulatory capital adequacy requirements, including those relating to

stress testing.

Capital measurement

The PRA is the supervisor of the bank and lead supervisor of the group. The PRA sets capital requirements and receives information on the capital adequacy of the bank and the group.

Individual banking subsidiaries are directly regulated by their local banking supervisors, who set and monitor their capital adequacy requirements. Since 1 January 2014, our capital at group level is calculated under CRD IV and the PRA Rulebook.

Our policy and practice in capital measurement and allocation at the group level is underpinned by the CRD IV rules. In most jurisdictions, non-bank financial subsidiaries are also subject to the supervision and capital requirements of local regulatory authorities.

The Basel III framework, like Basel II, is structured around three 'pillars': minimum capital requirements, supervisory review process and market discipline. Basel III also introduces a number of capital buffers, including the Capital Conservation Buffer ('CCB'), Countercyclical Capital Buffer ('CCyB'), and other systemic buffers such as the Globally/Other Systemically Important Institutions ('G-SII'/'O-SII') buffer. CRD IV legislation implemented Basel III in the EU and the 'PRA Rulebook' for CRR Firms transposed the various national discretions under the CRD IV legislation into UK requirements.

Regulatory capital

Our capital base is divided into three main categories, namely common equity tier 1, additional tier 1 and tier 2, depending on their characteristics.

-- Common equity tier 1 ('CET 1') capital is the highest quality form of capital, comprising shareholders' equity and related non-controlling interests (subject to limits). Under CRD IV various capital deductions and regulatory adjustments are made against these items; these include deductions for goodwill and intangible assets, deferred tax assets that rely on future profitability, negative amounts resulting from the calculation of expected loss amounts under internal ratings based ('IRB') approach and surplus defined benefit pension fund assets.

-- Additional tier 1 capital comprises eligible non-common equity capital instruments and any related share premium; it also includes other qualifying instruments issued by subsidiaries subject to certain limits. Holdings of additional tier 1 instruments of financial sector entities are deducted from our additional tier 1 capital.

-- Tier 2 capital comprises eligible capital instruments and any related share premium and other qualifying tier 2 capital instruments issued by subsidiaries, subject to limits. Holdings of tier 2 capital instruments of financial sector entities are deducted from our tier 2 capital.

Pillar 3 disclosure requirements

Pillar 3 of the Basel regulatory framework is related to market discipline and aims to increase market transparency by requiring firms to publish, at least annually, wide-ranging information on their risks and capital, and how these are managed. Our Pillar 3 Disclosures 2018 are published on HSBC's website, www.hsbc.com, under 'Investors'.

 
 Capital overview 
 
 
 Key capital numbers 
                                          At 31 Dec 
                           Footnotes     2018    2017(1) 
Available capital 
 (GBPm) 
Common equity tier 
 1 capital                             19,831   27,409 
 
Tier 1 capital                         23,079   32,243 
Total regulatory capital               37,671   39,288 
 
Risk-weighted assets 
 (GBPm) 
Credit risk                    2       88,822  164,767 
 
Counterparty credit 
 risk                                  24,669   24,018 
Market risk                            17,534   20,978 
 
Operational risk                       12,850   23,310 
Total risk-weighted 
 assets                               143,875  233,073 
 
Capital ratios (%) 
Common equity tier 
 1                                       13.8     11.8 
Total tier 1                             16.0     13.8 
 
Total capital                            26.2     16.9 
 
Leverage ratio 
Tier 1 capital (GBPm)                  22,213   31,165 
 
Total leverage ratio 
 exposure measure (GBPm)              570,001  787,220 
 
Leverage ratio (%)             3          3.9      4.0 
 
 
   1      All figures presented as reported under IAS 39 at 31 December 2017. 

2 'Credit risk' here, and in all tables where the term is used, excludes counterparty credit risk.

   3      Leverage ratio is calculated on a fully phased-in basis. 

Capital structure at 31 December

(Audited)

 
 Own funds disclosure 
                                                                                At 
                                                                          31 Dec      31 Dec 
Ref(1)                                                                      2018        2017 
                                                                            GBPm        GBPm 
        Common equity tier 1 ('CET1') capital: instruments 
         and reserves 
        Capital instruments and the related share premium 
1        accounts                                                         797         797 
        - ordinary shares                                                 797         797 
 
2       Retained earnings                                              30,668      32,601 
3       Accumulated other comprehensive income (and other 
         reserves)                                                      2,953       4,341 
5       Minority interests (amount allowed in consolidated 
         CET1)                                                            372         337 
5a      Independently reviewed interim net profits net of 
         any foreseeable charge or dividend                           (12,049)        217 
6       Common equity tier 1 capital before regulatory adjustments     22,741      38,293 
 
        Common equity tier 1 capital: regulatory adjustments 
7       Additional value adjustments                                     (623)       (587) 
8       Intangible assets (net of related deferred tax liability)      (1,970)     (5,337) 
10      Deferred tax assets that rely on future profitability 
         excluding those arising from temporary differences 
         (net of related tax liability)                                   (40)        (39) 
11      Fair value reserves related to gains or losses on 
         cash flow hedges                                                   7          41 
12      Negative amounts resulting from the calculation of 
         expected loss amounts                                           (183)       (864) 
14      Gains or losses on liabilities at fair value resulting 
         from changes in own credit standing                              (79)        452 
15      Defined-benefit pension fund assets                               (22)     (4,550) 
 
        Total regulatory adjustments to common equity tier 
28       1                                                             (2,910)    (10,884) 
 
29      Common equity tier 1 capital                                   19,831      27,409 
 
        Additional tier 1 ('AT1') capital: instruments 
30      Capital instruments and the related share premium 
         accounts                                                       2,403       3,781 
31      - classified as equity under IFRSs                              2,403       3,781 
33      Amount of qualifying items and the related share 
         premium accounts subject to phase out from AT1                   866       1,083 
34      Qualifying tier 1 capital included in consolidated 
         AT1 capital (including minority interests not included 
         in CET1) issued by subsidiaries and held by third 
         parties                                                           26          44 
 
36      Additional tier 1 capital before regulatory adjustments         3,295       4,908 
 
        Additional tier 1 capital: regulatory adjustments 
37      Direct and indirect holdings of own AT1 instruments               (47)        (45) 
41b     Residual amounts deducted from AT1 capital with regard                        (29) 
         to deduction from tier 2 ('T2') capital during the 
         transitional period                                                - 
 
          *    direct and indirect holdings by the institution of 
               the T2 instruments and subordinated loans of 
               financial sector entities where the institution has a 
               significant investment in those entities                     -         (29) 
 
        Total regulatory adjustments to additional tier 1 
43       capital                                                          (47)        (74) 
44      Additional tier 1 capital                                       3,248       4,834 
 
45      Tier 1 capital (T1 = CET1 + AT1)                               23,079      32,243 
 
        Tier 2 capital: instruments and provisions 
46      Capital instruments and the related share premium 
         accounts                                                      13,962       5,977 
47      Amount of qualifying items and the related share 
         premium accounts subject to phase out from T2                    881       1,194 
48      Qualifying own funds instruments included in consolidated 
         T2 capital (including minority interests and AT1 
         instruments not included in CET1 or AT1) issued by 
         subsidiaries and held by third parties                           152         169 
 
49      - of which: instruments issued by subsidiaries subject 
         to phase out                                                     107         146 
 
51      Tier 2 capital before regulatory adjustments                   14,995       7,340 
 
        Tier 2 capital: regulatory adjustments 
52      Direct and indirect holdings of own T2 instruments                (31)        (30) 
55      Direct and indirect holdings by the institution of 
         the T2 instruments and subordinated loans of financial 
         sector entities where the institution has a significant 
         investment in those entities (net of eligible short 
         positions)                                                      (372)       (265) 
 
57      Total regulatory adjustments to tier 2 capital                   (403)       (295) 
 
58      Tier 2 capital                                                 14,592       7,045 
 
59      Total capital (TC = T1 + T2)                                   37,671      39,288 
 
 

1 The references identify the lines prescribed in the EBA template, which are applicable and where there is a value.

CET1 capital decreased during the year by GBP7.6bn, mainly due to:

   --    GBP11.2bn reduction from implementing the ring-fencing transfer scheme; and 
   --    GBP0.1bn of capital reduction through profits, net of dividends; 

These decreases were partly offset by:

   --    GBP3.5bn capital contribution from HSBC Holdings plc and HSBC UK Holdings Ltd; and 
   --    GBP0.1bn of IFRS 9 day one transition impact. 

Risk-Weighted Assets ('RWAs')

 
 RWA movement by business by key driver 
                                                    Credit risk, counterparty credit 
                                                        risk and operational risk 
                                                                                    Corporate   Market       Total 
                                                RBWM       CMB     GB&M      GPB       Centre     risk        RWAs 
                                                GBPm      GBPm     GBPm     GBPm         GBPm     GBPm        GBPm 
                                            --------  --------  -------  -------  -----------  -------  ---------- 
RWAs at 31 Dec 2017                          26,676    85,448   76,790    3,540    19,641      20,978   233,073 
 
Asset size                                      248     6,177   (3,622)      (7)   (7,143)     (4,309)   (8,656) 
                                            -------   -------   ------   ------   -------      ------ 
Asset quality                                   (32)    1,206      370      116       (49)          -     1,611 
 
Model updates                                   332     1,300      328        -         -           -     1,960 
 
  *    portfolios moving onto IRB approach        -         -        -        -         -           -         - 
 
  *    new/updated models                       332     1,300      328        -         -           -     1,960 
 
Methodology and policy                          726     3,792   (4,185)     196      (324)       (219)      (14) 
 
  *    internal updates                         726     3,792   (4,185)     196      (635)       (219)     (325) 
 
  *    external updates - regulatory              -         -        -        -       311           -       311 
 
Acquisitions, disposals and 
 transfers                                  (20,982)  (66,241)   2,264   (1,848)     (811)        (38)  (87,656) 
 
Foreign exchange movement                        64       228    1,929       15       199       1,122     3,557 
 
Write-offs                                        -         -        -        -         -           -         - 
 
Total RWA movement                          (19,644)  (53,538)  (2,916)  (1,528)   (8,128)     (3,444)  (89,198) 
 
RWAs at 31 Dec 2018                           7,032    31,910   73,874    2,012    11,513      17,534   143,875 
 
 

RWAs fell by GBP89.2bn in the year, principally as a result of an GBP87.7bn reduction due to acquisitions, disposals and transfers. On 1 July the bank transferred business and assets worth GBP89.7bn to HSBC UK bank plc to complete the ring-fencing of its qualifying retail business. This transfer was partly offset by other movements, primarily the acquisition of HSBC Investment Bank Holdings and HSBC Specialist Investment Limited which added GBP2.6 bn RWAs.

Excluding these movements, and an increase of GBP3.6bn due to foreign currency translation differences, the bank's RWAs reduced by GBP5.1bn mainly as a result of an GBP8.7bn fall in asset size, less a GBP2.0bn increase due to model updates and a GBP1.6bn increase due to movements in asset quality.

The following comments describe RWA movements in 2018 excluding foreign currency translation differences and acquisitions and disposals.

Asset size

Asset size movements were mainly driven by management initiatives which reduced legacy securitisation assets in Corporate Centre and GB&M RWAs by GBP10.7bn. This was partly offset by GBP6.4bn of lending growth in CMB corporate book and in RBWM mortgages and credit card exposure. Market risk RWAs fell by GBP4.3bn due to management initiatives to lower exposures.

Asset quality

RWAs increased by GBP1.6bn mainly as a result of changes in portfolio mix across CMB and GB&M.

Methodology and policy

The GBP0.3bn decrease in RWAs from internal updates is principally the result of a fall of GBP4.2bn in GB&M RWAs and a GBP3.8bn increase in CMB. These movements include the transfer of GBP1.6bn of RWAs from GB&M to CMB as part of resegmentation activity prior to ring-fencing. Excluding this transfer:

-- GB&M RWAs fell by GBP2.6bn as a result of management initiatives and calculation refinements; and

   --    CMB RWAs rose by GBP2.1bn primarily as a result of calculation refinements following IFRS 9 implementation. 

This is offset by a GBP0.3bn increase in external updates as a result of IFRS 9 implementation.

Model updates

The GBP2.0bn increase in RWAs was largely due to updates to UK retail and corporate PD models and to the implementation of a German receivable finance model.

Leverage ratio

Our fully phased-in CRD IV leverage ratio was 3.9% at 31 December 2018, down from 4.0% at 31 December 2017. Fall in tier 1 capital was largely offset by a decrease in the leverage exposure measure, primarily due to a transfer of qualifying exposures to HSBC UK bank plc.

 
 Corporate Governance Report 
 

The statement of corporate governance practices set out on pages

72

to

77

and information incorporated by reference constitute the Corporate Governance Report of HSBC Bank plc.

The Directors serving at 31 December 2018 are set out below.

 
 Directors 
 

Stephen O'Connor

Chairman

Chairman of the Chairman's Nominations and Remuneration Committee

Appointed to the Board: May 2018. Chairman since August 2018

Stephen is Founder and Chairman of Quantile Technologies Limited, and a non-executive Director, Chairman of the Risk Committee and member of both the Audit and Nomination Committees of The London Stock Exchange Group plc. He has more than 25 years' investment banking experience in London and New York. Former appointments include: Chairman of the International Swaps and Derivatives Association and prior to that he was Managing Director and a member of the Fixed Income Management Committee at Morgan Stanley.

James Emmett

Executive Director and Chief Executive Officer

Chairman of the Executive Committee

Appointed to the Board and as Chief Executive Officer: September 2018

James joined HSBC in 1994 and has performed a variety of senior management roles. He is a Director of HSBC France and a member of the Supervisory Board of HSBC Trinkaus & Burkhardt AG. Former appointments include: Group General Manager and Chief Operating Officer of HSBC Bank plc, and Group General Manager and CEO of HSBC Bank A.S. (Turkey).

Jacques Fleurant

Executive Director and Chief Financial Officer

Member of the Executive Committee

Appointed to the Board and as Chief Financial Officer: August 2018

Jacques joined HSBC in 2000 in Toronto, and has held a variety of senior roles in finance and operations. Prior to joining HSBC he performed senior roles at Merrill Lynch and for the Canadian Revenue Agency.

Dame Mary Marsh

Independent non-executive Director

Member of the Risk Committee

Appointed to the Board: January 2009

Mary is the non-executive Chair of Trustees of the Royal College of Paediatrics and Child Health, a director of the London Symphony Orchestra, a member of the Governing Body of the London Business School and a Trustee of Teach First. Former appointments include: founding Director of the Clore Social Leadership Programme and Chief Executive of the National Society for the Prevention of Cruelty to Children.

Yukiko Omura

Independent non-executive Director

Member of the Risk Committee

Appointed to the Board: May 2018

Yukiko is a non-executive Director of The Private Infrastructure Development Group Limited ("PIDG"), as well as Chair of GuarantCo Limited, a subsidiary of PIDG. She also serves as a non-executive Director of Assured Guaranty Ltd, and on the Supervisory Board member of Nishimoto HD Co. Ltd. She has more than 35 years' international professional experience in both the public and private financial sector, performing senior roles for JP Morgan, Lehman Brothers, UBS and Dresdner Bank. Former appointments include: Under-Secretary General and COO/Vice President of the International Fund for Agricultural Development and, Executive Vice President and CEO of the Multilateral Investment Guarantee Agency of the World Bank Group.

Dr Eric Strutz

Independent non-executive Director

Chairman of the Risk Committee, Member of the Audit Committee and the Chairman's Nominations and Remuneration Committee

Appointed to the Board: October 2016

Eric is a member of the Supervisory Board and Chairman of the Risk and Audit Committees of HSBC Trinkaus & Burkhardt AG, Germany, member of the Board of Directors and Chairman of the Risk and Audit Committee of Partners Group Holding AG, Switzerland, a member of the Board of Directors and Chairman of the Audit Committee of Global Blue SA, and a member of the Advisory Board and Chairman of the Audit & Risk Committee of Luxembourg Investment Company 261 Sarl. Former appointments include: Chief Financial Officer of Commerzbank Group, Partner and Director of the Boston Consulting Group, as well as non-executive Director of Mediobanca Banca di Credito Finanziario SpA.

John Trueman

Deputy Chairman and independent non-executive Director

Member of the Audit Committee, the Risk Committee and the Chairman's Nominations and Remuneration Committee

Appointed to the Board: 2004. Deputy Chairman since December 2013

John is Chairman of HSBC Global Asset Management Limited and non-executive director of HSBC Private Bank (UK) Limited. Former appointments include: Deputy Chairman of S.G. Warburg & Co Ltd.

Andrew Wright

Independent non-executive Director

Chairman of the Audit Committee, Member of the Risk Committee and the Chairman's Nominations and Remuneration Committee

Appointed to the Board: May 2018

Andrew has been the Treasurer to the Prince of Wales and the Duchess of Cornwall since 2012. Former appointments include: Global Chief Financial Officer for the Investment Bank at UBS AG, Chief Financial Officer, Europe and the Middle East at Lehman Brothers and Chief Financial Officer for the Private Client and Asset Management Division at Deutsche Bank.

 
 Company Secretary 
 

Loren Wulfsohn was appointed Company Secretary of HSBC Bank plc with effect from 1 January 2018.

 
 Board of Directors 
 

The objective of the Board of Directors, led by the Chairman, is to deliver sustainable value to shareholders and internal and external stakeholders. Implementation of the strategy is delegated to the Bank's Executive Committee.

The Board meets regularly and Directors receive information between meetings about the activities of committees and developments in the bank's business. All Directors have full and timely access to all relevant information and may take independent professional advice if necessary.

All Directors are subject to annual re-election at the HSBC Bank plc Annual General Meeting.

Board Changes during 2018

The Board regularly reviews its composition and in 2018 a number of changes were made to the Board to ensure that the Board has the right mix of skills and experience.

In May 2018 Stephen O'Connor, Yukiko Omura and Andrew Wright were appointed to the Board as independent non-executive Directors.

The following Board changes took place:

In August 2018;

   --    Jonathan Symonds stepped down as Chairman of the Board; 
   --    Stephen O'Connor was appointed as Chairman of the Board; 

-- Jim Coyle, Dame Denise Holt and David Lister resigned, having each been appointed to the Board of HSBC UK Bank plc;

-- Eric Strutz and Andrew Wright were appointed as Chairman of the Risk and Audit Committees respectively; and

   --    Jacques Fleurant was appointed as Chief Financial Officer and Executive Director. 

In September 2018;

   --    Thierry Moulonguet resigned as a non-executive Director having served since July 2012; 

-- Antonio Simoes who served on the Board and as Chief Executive Officer since 2012 resigned; and

-- James Emmett, who had been appointed as acting Chief Executive Officer in March 2018, was appointed as Chief Executive Officer and to the Board.

 
 Directors' emoluments 
 

Details of the emoluments of the Directors of the bank for 2018, disclosed in accordance with the Companies Act, are shown in Note 6 'Employee compensation and benefits'.

Non-executive Directors do not have service contracts, but are bound by letters of appointment.

 
 Board committees 
 

The Board has established a number of committees to assist it in discharging its responsibilities. The Chairman of each non-executive Board committee reports to the Board on the activities of the committee since the previous Board meeting. All of the members of the Audit, Risk and Chairman's Nomination and Remuneration Committees are independent non-executive directors.

At the date of this report, the following are the principal committees of the Board:

Audit Committee

The Audit Committee is accountable to the Board and has non-executive responsibility for oversight of and advice to the Board on financial reporting related matters and internal controls over financial reporting.

The Committee meets regularly with the bank's senior financial and internal audit management and the external Auditors to consider, among other matters, the bank's financial reporting, the nature and scope of audit reviews, the effectiveness of the systems of internal control relating to financial reporting, the review of the financial underpinnings of structural reform projects and the monitoring of the finance function transformation program. The current members are Andrew Wright (Chairman), Eric Strutz and John Trueman.

 
 Significant accounting judgements and related matters considered by 
  the Audit Committee during 2018 included: 
 
Appropriateness           The HSBC Bank plc Audit Committee ('AC') received reports 
 of provisioning           from management on the recognition and measurement of 
 for legal proceedings     provisions and contingent liabilities for legal proceedings 
 and regulatory            and regulatory matters. Specific matters included accounting 
 matters                   judgements in relation to provisions and contingent 
                           liabilities arising from investigations by regulators 
                           and competition and law enforcement authorities around 
                           the world into trading on the foreign exchange market. 
IBOR transition           The AC considered the accounting implications of benchmark 
                           interest rate replacement for hedge accounting relationships 
                           at 31 December 2018, the longer term broader implications 
                           for financial instruments and other areas of accounting, 
                           and the related disclosures. The AC considered management's 
                           judgement that no change to hedge accounting is appropriate 
                           as at 31 December 2018 and that this position will be 
                           kept under review in the context of future market developments 
                           in the transition of interest rate benchmarks to new 
                           risk free rates. 
Interim and annual        The AC considered key judgements in relation to interim 
 reporting                 and annual reporting. 
Expected credit           The AC considered the key judgements related to IFRS 
 loss ('ECL') allowances   9 and the related disclosures, The AC considered ECL 
 and charges               allowances and charges for personal and wholesale lending. 
                           Specific attention was paid to credit risk in the UK 
                           and adjustment to ECL for UK economic uncertainty. 
Valuation of financial    The AC considered the key valuation metrics and judgements 
 instruments               involved in the determination of the fair value of financial 
                           instruments. 
Going concern             The AC considered a wide range of information relating 
                           to present and potential conditions, including projections 
                           for profitability, cash flows, liquidity and capital. 
                           Specific attention was paid to the effects of ring-fencing 
                           and the potential impact of the UK's withdrawal from 
                           the European Union. 
UK customer remediation   The AC considered the provisions for redress for mis-selling 
                           of payment protection insurance ('PPI') policies in 
                           the UK and the associated redress on PPI commissions 
                           earned under certain criteria, including management's 
                           judgements regarding the effect of the time-bar for 
                           claims ending August 2019. In addition, the AC monitored 
                           progress on the remediation of operational processes 
                           and associated customer redress. 
Goodwill impairment       The AC considered the results of the annual goodwill 
 testing                   impairment test and subsequent review for any impairment 
                           indicators. Whilst there were no indicators of impairment 
                           at 31 December 2018, the AC noted the sensitivity of 
                           Commercial Banking goodwill to reasonably possible changes 
                           in assumptions and the risk of impairment in the future 
                           should business performance or economic factors diverge 
                           from forecasts 
Controls                  The AC considered the financial control environment 
                           and reviewed action taken to enhance controls over IT 
                           access management, balance sheet substantiation, disclosure 
                           preparation and other areas. The AC reviewed the progress 
                           of ongoing action to enhance controls over general ledger 
                           reconciliation and substantiation, model governance, 
                           IFRS 9 data quality and control monitoring. 
Tax                       The AC considered key judgements in relation to tax, 
                           notably the contingent liability for retrospective VAT 
                           assessments issued by HMRC. 
Estimated impact          The AC considered the estimated impact of implementation 
 of IFRS 16, Leases        of IFRS 16 Leases on 1 January 2019 and the related 
                           disclosures. 
Ring-fenced bank          The AC considered the accounting in relation to the 
 ('RFB')                   creation of the RFB and the associated judgements, including 
                           those related to the disclosure of discontinued operations. 
 

Risk Committee

The Risk Committee is accountable to the Board and has non-executive responsibility for oversight of and advice to the Board on high-level risk related matters and risk governance.

The Committee meets regularly with the bank's senior financial, risk, internal audit and compliance management and the external Auditors to consider, among other matters, risk reports and internal audit reports and the effectiveness of compliance.

The current members are: Dr Eric Strutz (Chairman); Dame Mary Marsh; Yukiko Omura; John Trueman and Andrew Wright.

Post ring-fencing, the sub Committee of the Risk Committee for Global Banking and Markets ("GB&M") Risk Oversight was demised and its role assumed by the Risk Committee.

Operations and Technology Committee

Following implementation of ring-fencing in the UK, the Operations and Technology Committee was demised in July 2018. The Committee's responsibilities, which included the oversight of systems, operational resilience and the bank's IT infrastructure, were assigned to the Risk Committee which will be assisted in the discharge of its duties by the newly formed Operations and Technology Forum.

Before its demise, the Committee met regularly in 2018 with the bank's senior risk, operations, security and fraud risk and technology audit management to consider, among other matters, internal audit reports and reports on the risks associated with the bank's IT infrastructure and transformation projects, cybersecurity and data management.

The current members are Stephen O'Connor and Eric Strutz.

Chairman's Nominations and Remuneration Committee

The Chairman's Nominations and Remuneration Committee has responsibility for: (i) leading the process for Board appointments and for identifying and nominating, for the approval of the Board, candidates for appointment to the Board; (ii) the endorsement of the appointment of the chairman and any director to the Board of certain subsidiaries of the bank; and (iii) reviewing the implementation and appropriateness of HSBC Group's remuneration policy and the remuneration of the bank's senior executives.

The current members are: Stephen O'Connor (Chairman); Eric Strutz; John Trueman and Andrew Wright.

Executive Committee

The Executive Committee meets regularly and operates as a general management committee under the direct authority of the Board, exercising all of the powers, authorities and discretions of the Board in so far as they concern the management and day-to-day running of the bank, in accordance with such policies and directions as the Board may from time to time determine. The bank's Chief Executive Officer, James Emmett, chairs the Committee.

Regular Risk Management Meetings of the Executive Committee, chaired by the Chief Risk Officer, Europe, are held to establish, maintain and periodically review the policy and guidelines for the management of risk within the bank.

The following committees are sub-committees of the Executive Committee:

   --    International Executive Committee; and 
   --    International Risk Management Meeting. 

The International Executive Committee is responsible for monitoring and, where appropriate, implementing and driving execution of the group's strategy as it pertains to the portion of the group's operations designated as International.

The International Risk Management Committee is responsible for the oversight and management of all risks impacting the group's operations designated as International.

 
 Dividends 
 

Information about dividends is provided on page 15 of the Strategic Report.

 
 Internal control 
 

The Board is responsible for maintaining and reviewing the effectiveness of risk management and internal control systems and for determining the aggregate level and types of risks the bank is willing to take in achieving its strategic objectives.

The bank has procedures in place designed to safeguard assets against unauthorised use or disposal, maintain proper accounting records and ensure the reliability and usefulness of financial information whether used within the business or for publication.

These procedures can only provide reasonable assurance against material mis-statement, errors, losses or fraud. They are designed to provide effective internal control within the bank. The procedures have been in place throughout the year and up to the date of approval of the Annual Report and Accounts 2018.

In the case of companies acquired during the year, the risk management and internal controls in place are being reviewed against HSBC's benchmarks and integrated into HSBC's processes.

Key risk management and internal control procedures include the following:

-- Adherence to the Group's Global Standards Manual ('GSM'). The GSM outlines the core principles within which all members of the HSBC Group must operate wherever business is conducted. The GSM overlays all other policies and procedures throughout the HSBC Group. The requirements of the GSM are mandatory, apply to and must be observed by all businesses within the HSBC Group, regardless of the nature or location of their activities. In 2019, the GSM process will be replaced by a set of Global Principles.

-- Delegation of authority within limits set by the Board. Authority to manage the day-to-day running of the bank is delegated within limits set by the Board to the Chief Executive who has responsibility for overseeing the establishment and maintenance of systems of control appropriate to the business and who has the authority to delegate such duties and responsibilities as he sees fit. Appointments to the most senior positions require Board approval.

-- Risk identification and monitoring. Systems and procedures are in place to identify, control and report on the material risk types facing the group.

-- Changes in market conditions/practices. Processes are in place to identify new risks arising from changes in market conditions/practices or customer behaviours, which could expose the group to heightened risk of loss or reputational damage. The group employs a top and emerging risks framework at all levels of the organisation, which enables it to identify current and forward-looking risks and to take action which either prevents them materialising or limits their impact.

-- Responsibility for risk management. All employees are responsible for identifying and managing risk within the scope of their role as part of the three lines of defence model, which is an activity-based model to delineate management accountabilities and responsibilities for risk management and the control environment. The second line of defence sets the policy and guidelines for managing specific areas, provides advice and guidance in relation to the risk, and challenges the first line of defence (the risk owners) on effective risk management.

-- Strategic plans. Strategic plans are prepared for global businesses, global functions and geographical regions within the framework of the HSBC Group's overall strategy. The bank also prepares and adopts an Annual Operating Plan, which is informed by detailed analysis of risk appetite, describing the types and quantum of risk that the bank is prepared to take in executing its strategy and sets out the key business initiatives and the likely financial effects of those initiatives.

The key risk management and internal control procedures over financial reporting include the following:

-- Entity level controls: The primary mechanism through which comfort over risk management and internal control systems is achieved, is through assessments of the effectiveness of entity level controls ('ELC'), and the reporting of risk and control issues on a regular basis through the various risk management and risk governance forums. ELCs are internal controls that have a pervasive influence over the entity as a whole. They include controls related to the control environment, for example the Company's values and ethics, the promotion of effective risk management and the overarching governance exercised by the Board and its non-executive committees. The design and operational effectiveness of ELCs are assessed annually as part of the assessment of the effectiveness of internal controls over financial reporting.

-- Key process level controls that mitigate risk of financial misstatement are recorded in the Operation Risk system and monitored in accordance with the ORMF. Further details on the framework can be found on page 31.

-- Disclosure Forum. The Disclosure Forum reviews financial reporting disclosures made by the bank for any material errors, misstatements or omissions. The integrity of disclosures is underpinned by structures and processes within the group's Finance and Risk functions that support rigorous analytical review of financial reporting and the maintenance of proper accounting records.

-- Financial reporting. The bank's financial reporting process for preparing the consolidated Annual Report and Accounts 2018 is controlled using documented accounting policies and reporting formats, supported by detailed instructions and guidance on reporting requirements, issued to all reporting entities within the Group in advance of each reporting period end.

-- Subsidiary certifications. Full and half-yearly certifications are provided to the Audit Committee and the Risk Committee from audit and risk committees of principal subsidiary companies, confirming that their financial statements have been prepared in accordance with Group policies, present fairly the state of affairs of the relevant principal subsidiary and are prepared on a going concern basis.

In 2018, the acceleration of operational resilience and investment in technology controls were particular areas of focus for HSBC. The Group continued to embed the operational risk management framework and invest in the non-financial risk infrastructure. Work also continued to enhance the risk appetite framework for non-financial risks and improve the consistency of adoption of the end-to-end risk and control assessment process. Whilst there remains more to do, considerable progress has been made to strengthen HSBC's control environment and it will continue to be a priority for 2019.

During the year, the Audit and Risk Committees keep under review the effectiveness of this system of internal control and report regularly to the Board. In carrying out their reviews, the Audit and Risk Committees receive regular business and operational risk assessments; regular reports from the heads of key risk functions, which cover all internal controls, both financial and non-financial; internal audit reports; external audit reports; prudential reviews; and regulatory reports.

The Risk Committee monitors the status of principal risks and considers whether the mitigating actions put in place are appropriate. In addition, when unexpected losses have arisen or when incidents have occurred which indicate gaps in the control framework or in adherence to Group policies, the Risk and Audit Committees review special reports, prepared at the instigation of management, which analyse the cause of the issue, the lessons learned and the actions proposed by management to address

the issue.

 
 Employees 
 

Health and safety

The group is committed to providing a healthy and safe working environment for our employees, contractors, customers and visitors on HSBC premises and where impacted by our operations. We aim to be compliant with all applicable health and safety legal requirements, and that best practice health and safety management standards are implemented and maintained across the HSBC Group.

Everyone at HSBC has a responsibility for helping to create a healthy and safe working environment. Employees are expected to take ownership of their safety and are encouraged and empowered to report any concerns.

Chief Operating Officers have overall responsibility for ensuring that the correct policies, procedures and safeguards are put into practice. This includes making sure that everyone in HSBC has access to appropriate information, instruction, training and supervision.

Putting our commitment into practice, in 2018 the group delivered a health and safety education and information training programme to every one of our employees, and a range of programmes to help us understand and effectively manage the risks we face and improve the buildings in which we operate:

-- We developed and implemented a health and safety continuous improvement programme, focusing on education, engineering and enforcement/reward, to improve our health and safety culture and to implement the highest standards of control for managing health and safety.

-- We developed and implemented an improved health and safety training and awareness programme for all employees globally, ensuring roles and responsibilities were clear and understood; and processes for identifying and reporting hazards and incidents were clearly defined and communicated.

-- We implemented, through our global facilities management service provider, an electronic permit to work system to provide effective controls for all high risk work undertaken.

-- We developed and implemented a global earthquake risk management programme, to ensure all HSBC properties in earthquake zones were risk assessed and controls implemented to manage the risk.

-- We ensured all our properties had been assessed for fire and asbestos risk, with over 40,000 individual actions taken to improve standards.

 
 Employee health and safety 
                         Footnotes  2018  2017    2016 
Number of workplace 
 fatalities              1,2           -     -     - 
 
Number of major 
 injuries to employees   1,2           9    19      21 
 
All injury rate 
 per 100,000 employees   2           343   448     470 
 
 
   1      Fractures, dislocation, concussion. 
   2      Comparative data has been restated to show Europe figures. 

Diversity and inclusion

We are committed to enabling a thriving environment where people are valued, respected and supported to fulfil their potential; and where leveraging the extraordinary range of ideas, backgrounds, styles and perspectives of our employees means we can effectively meet the needs of our different stakeholder groups and drive better business outcomes for all. Our employees are expected to build positive and lasting relationships among the variety of people they interact with.

We focus on enhancing the diversity profile of our workforce so that it is more reflective of the communities we operate in and the customers we serve.

To support an inclusive environment, our policy is that each of us must treat colleagues with dignity and respect. We have zero tolerance for discrimination, bullying, harassment and victimisation on any ground, including age, race, ethnic or national origin, colour, mental or physical health conditions, disability, pregnancy, gender, gender expression, gender identity, sexual orientation, marital status or other domestic circumstances, employment status, working hours or other flexible working arrangements, or religion or belief. Such behaviour is considered a personal conduct matter and managed in accordance with applicable local policies and procedures and our consequence management framework.

Diversity and inclusion carries the highest level of executive support and is governed by the Group People Committee.

More information about our diversity and inclusion activity is available at https://www.hsbc.com/our-approach.

Key achievements

In 2018, the UK created and launched the 'Inclusion Hub', which holds an abundance of information and resources relating to Diversity & Inclusion ('D&I'). This effectively provides UK employees with a 'one stop shop' for all of their D&I questions and requirements. The Driving Inclusion Workshops were delivered to UK leaders, with the HR Leadership Team, UK Inclusion Board and the UK Executive Committee already having participated during 2018. The workshop has been designed to support our inclusion strategy underpinned by inclusive behaviours. To focus the agenda around the five areas of priority for the UK business; gender, LGBT+, ethnicity, flexible working, and disability, a framework has been designed to progress the agenda at pace. The framework provides for business led actions with clear UK Executive Committee accountability and ownership.

HSBC France launched its first Diversity & Inclusion week to raise awareness in partnership with its two Employee Resource Groups: 50 50 Partner of Balance and HSBC Pride Network France. HSBC France also continued to raise managers' awareness of diversity and unconscious bias via dedicated workshops.

HSBC Malta was accredited as an Equal Employer by the National Commission Promoting Equality. The company demonstrated commitment towards its equality and sexual harassment policy; taking measures to ensure equal opportunities in recruitment and employment practices, and in career and personal development opportunities; promoting family-friendly measures and work-life balance options for men and women with caring responsibilities. It is an affirmation that the company truly demonstrates its commitment towards gender equality and provides true equal opportunities without judgements based on stereotypes. Ultimately, this showcases a quality standard for job seekers to look out for and makes the company an employer of choice.

HSBC Germany continued to establish an integrated talent development and D&I approach by increasing talent development activities. These include initiatives such as progression and targeted development of female talents by implementing the Female Leadership Accelerator Programme and implementing individual development plans for female key talent. HSBC Germany also continued to focus on unconscious bias awareness by deploying Unconscious Bias workshops for leaders. The local Balance network continues to provide its members opportunities to have an open dialogue and share insights around career development within the firm. Typical activities include speeches by senior women, blind date lunches and quarterly newsletters. Additionally events are supported by external speakers who share best practices around gender balance. The local mentoring programme continues successfully. To date, 148 senior leaders offered their guidance for junior colleagues.

Diverse representation in Europe

Our focus on improving gender balance in senior leadership across Europe is on going.

Female representation by management level:

   --    All grades: 48% 
   --    Clerical grades: 68% 
   --    Junior management: 56% 
   --    Management: 39% 
   --    Senior management: 24% 
   --    Executive management: 12% 

Employment of people with a disability

We believe in providing equal opportunities for all employees. The employment of people with a disability is included in this commitment. The recruitment, training, career development and promotion of people with a disability are based on the aptitudes and abilities of the individual. Should employees become disabled during their employment with us, efforts are made to continue their employment and, if necessary, appropriate training and reasonable equipment and facilities are provided.

A number of countries have dedicated teams to ensure that barriers to work are removed for colleagues. HSBC France has taken actions to create a more inclusive environment for disabled people, for example HOST and Finance are ensuring disabilities are accommodated through assisted technologies. A deaf employee who benefits from interpreters and technological support was interviewed on French television (France 24) to explain how the support put in place and the commitment of his colleagues make his integration successful. HSBC France has worked with a non profit organisation to coach young disabled people on their CV and prepare them for interviews.

Learning and talent development

The development of our people is fundamental to the ongoing success of our organisation. We continue to develop and implement practices that build employee capability and identify, develop and deploy talented employees to ensure an appropriate supply of high calibre individuals with the right values, skills and experience for current and future senior management positions.

Since the launch of HSBC University in 2017 we have continued to add to the portfolio of world class leadership and professional programmes that provide opportunity for leaders and people managers to both develop and connect with each other across the group. In 2018 as part of our drive to use our own leaders to share experiences and the skill sets that they possess, we successfully launched a programme of development that enables our leaders to do just this. As a result we now have a growing number of HSBC leaders who actively help facilitate and bring our HSBC leadership development programmes to life.

As well as growing our learning and talent offering in traditional format, we also spent the year testing new technology platforms that make personal development accessible to all in HSBC. In addition we closed the year with the launch of our first digital learning curriculum covering the topic of personal leadership in HSBC. The target audience for this development is wide and includes HSBC front-line staff, meaning format and accessibility will be crucial to the overall success of the programme.

During 2018 a total of 75,000 formal days of training were received by 170,000 participants across Europe. Over 4,800 participants across Europe attended a flagship leadership programme in 2018 and all courses continue to receive positive feedback.

Employee relations

We consult with and, where appropriate, negotiate with employee representative bodies. It is our policy to maintain well-developed communications and consultation programmes with all employee representative bodies and there have been no material disruptions to our operations from labour disputes during the past five years.

 
 Auditor 
 

PricewaterhouseCoopers LLP ('PwC') is external Auditors to the bank. PwC has expressed its willingness to continue in office and the Board recommends that PwC be re-appointed as the bank's Auditors. A resolution proposing the re-appointment of PwC as the bank's Auditors and giving authority to the Audit Committee to determine its remuneration will be submitted to the forthcoming AGM.

 
 Articles of Association, Conflicts 
  of interest and indemnification 
  of Directors 
 

On 23 November 2018 the Articles of Association of HSBC Bank plc were amended to reflect the redesignation of the preferred ordinary share to an ordinary share as set out in Note 29 of the financial statements.

The Articles of Association of HSBC Bank plc gives the Board authority to approve Directors' conflicts and potential conflicts of interest. The Board has adopted a policy and procedures for the approval of Directors' conflicts or potential conflicts of interest. A review of situational conflicts which have been authorised, including the terms of authorisation, is undertaken by the Board annually.

The Articles of Association provide that Directors and directors of associated companies are entitled to be indemnified out of the assets of the company against claims from third parties in respect of certain liabilities arising in connection with the performance of their functions, in accordance with the provisions of the UK Companies Act 2006. Such indemnity provisions have been in place during the financial year but have not been utilised by the Directors. All Directors have the benefit of directors' and officers' liability insurance.

 
 Statement on going concern 
 

The Directors consider it appropriate to prepare the financial statements on the going concern basis. In making their going concern assessment, the Directors have considered a wide range of detailed information relating to present and potential conditions, including profitability, cash flows, capital requirements and capital resources.

Further information relevant to the assessment is provided in the Strategic Report and the Report of the Directors, in particular:

   --    a description of the group's strategic direction; 
   --    a summary of the group's financial performance and a review of performance by business; 
   --    the group's approach to capital management and its capital position; and 

-- the top and emerging risks facing the group, as appraised by the Directors, along with details of the group's approach to mitigating those risks and its approach to risk management in general.

In addition, the objectives, policies and processes for managing credit, liquidity and market risk are set out in the 'Report of the Directors: Risk'.

 
 Statement of directors' responsibilities in respect of the financial 
  statements 
 

The directors are responsible for preparing the Annual Report and the financial statements in accordance with applicable law and regulation.

Company law requires the directors to prepare financial statements for each financial year. Under that law the directors have prepared the group financial statements in accordance with International Financial Reporting Standards (IFRSs) as adopted by the European Union and company financial statements in accordance with International Financial Reporting Standards (IFRSs) as adopted by the European Union. Under company law the directors must not approve the financial statements unless they are satisfied that they give a true and fair view of the state of affairs of the group and company and of the profit or loss of the group and company for that period. In preparing the financial statements, the directors are required to:

   --    select suitable accounting policies and then apply them consistently; 

-- state whether applicable IFRSs as adopted by the European Union have been followed for the group financial statements and IFRSs as adopted by the European Union have been followed for the company financial statements, subject to any material departures disclosed and explained in the financial statements;

   --    make judgements and accounting estimates that are reasonable and prudent; and 

-- prepare the financial statements on the going concern basis unless it is inappropriate to presume that the group and company will continue in business.

The directors are also responsible for safeguarding the assets of the group and company and hence for taking reasonable steps for the prevention and detection of fraud and other irregularities.

The directors are responsible for keeping adequate accounting records that are sufficient to show and explain the group and company's transactions and disclose with reasonable accuracy at any time the financial position of the group and company and enable them to ensure that the financial statements comply with the Companies Act 2006 and, as regards the group financial statements, Article 4 of the IAS Regulation.

The directors of HSBC Holdings plc are responsible for the maintenance and integrity of the website on which the bank's financial results are located. Legislation in the United Kingdom governing the preparation and dissemination of financial statements may differ from legislation in other jurisdictions.

By order of the Board

Loren Wulfsohn

Company Secretary

HSBC Bank plc

19 February 2019

Registered number 14259

 
 Independent auditors' report to the member of HSBC Bank plc 
 
 
 Report on the audit of the financial statements 
 

Opinion

In our opinion, HSBC Bank plc's group financial statements and parent company financial statements (the "financial statements"):

-- give a true and fair view of the state of the group's and of the parent company's affairs as at 31 December 2018 and of the group's profit and the group's and the parent company's cash flows for the year then ended;

-- have been properly prepared in accordance with International Financial Reporting Standards (IFRSs) as adopted by the European Union and, as regards the parent company's financial statements, as applied in accordance with the provisions of the Companies Act 2006; and

-- have been prepared in accordance with the requirements of the Companies Act 2006 and, as regards the group financial statements, Article 4 of the IAS Regulation.

We have audited the financial statements, included within the Annual Report and Accounts 2018, which comprise:

   --     the consolidated and HSBC Bank plc balance sheets as at 31 December 2018; 

-- the consolidated income statement and consolidated statement of comprehensive income for the year then ended;

   --     the consolidated and HSBC Bank plc statements of cash flows for the year then ended; 

-- the consolidated and HSBC Bank plc statements of changes in equity for the year then ended; and

-- the notes to the financial statements, which include a description of the significant accounting policies.

Our opinion is consistent with our reporting to the Audit Committee.

Basis for opinion

We conducted our audit in accordance with International Standards on Auditing (UK) ("ISAs (UK)") and applicable law. Our responsibilities under ISAs (UK) are further described in the Auditors' responsibilities for the audit of the financial statements section of our report. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

Independence

We remained independent of the group in accordance with the ethical requirements that are relevant to our audit of the financial statements in the UK, which includes the FRC's Ethical Standard, as applicable to listed public interest entities, and we have fulfilled our other ethical responsibilities in accordance with these requirements.

To the best of our knowledge and belief, we declare that non-audit services prohibited by the FRC's Ethical Standard were not provided to the group or the parent company.

Other than those disclosed in Note 7 to the financial statements, we have provided no non-audit services to the group or the parent company in the period from 1 January 2018 to 31 December 2018.

Our audit approach

Overview

-- Overall group materiality: GBP282 million (2017: GBP183 million), based on 0.75% of Total Regulatory Capital.

-- Overall parent company materiality: GBP235 million (2017: GBP183 million), based on the lower of the group materiality or 0.75% of the parent's regulatory capital. 0.75% of the parent company's regulatory capital was lower and therefore was the benchmark used.

-- HSBC Bank plc (the 'Bank') is a member of the HSBC Holdings plc Group, the ultimate parent company of which is HSBC Holdings plc. HSBC Bank plc operates in 18 countries.

-- We performed audits of the complete financial information of two components, namely the UK business of the Bank (referred to as UK Operations) and HSBC France.

-- For five further reporting units, specific audit procedures were performed over selected significant account balances.

The following areas were identified as key audit matters. These are discussed in further detail in the Appendix:

   --     Application of IFRS 9 in the calculation of impairment of loans and advances; 

-- Execution of structural reform required by the UK Financial Services (Banking Reform) Act 2013;

   --     IT access management; and 
   --     Valuation of financial instruments. 

The scope of our audit

As part of designing our audit, we determined materiality and assessed the risks of material misstatement in the financial statements. In particular, we looked at where the directors made subjective judgements, for example in respect of significant accounting estimates that involved making assumptions and considering future events that are inherently uncertain.

Capability of the audit in detecting irregularities, including fraud

We focused on laws and regulations that could give rise to a material misstatement in the financial statements, including, but not limited to, the Companies Act 2006, the Financial Conduct Authority's regulations, the Prudential Regulation Authority's regulations, UK Listing Rules, the UK tax legislation and equivalent local laws and regulations applicable to significant component teams. One identified risk related to the execution of structural reform required by the UK Financial Services (Banking Reform) Act 2013; our audit procedures are explained in the key audit matter in the Appendix. Further to this, our tests in relation to laws and regulations included, but were not limited to, review of the financial statement disclosures to underlying supporting documentation, review of correspondence with and reports to the regulators, review of correspondence with legal advisors, enquiries of management, enquiries of legal counsel, review of significant component auditors' work and review of internal audit reports in so far as they related to the financial statements. We also designed audit procedures at a group and significant component level to respond to the risk of fraud. This included identifying specific fraud criteria as part of our journals testing which were relevant to HSBC Bank plc and its business, for example unusual account combinations.

There are inherent limitations in the audit procedures described above and the further removed non-compliance with laws and regulations is from the events and transactions reflected in the financial statements, the less likely we would become aware of it. Also, the risk of not detecting a material misstatement due to fraud is higher than the risk of not detecting one resulting from error, as fraud may involve deliberate concealment by, for example, forgery or intentional misrepresentations, or through collusion.

Key audit matters

Key audit matters are those matters that, in the auditors' professional judgement, were of most significance in the audit of the financial statements of the current period and include the most significant assessed risks of material misstatement (whether or not due to fraud) identified by the auditors, including those which had the greatest effect on: the overall audit strategy; the allocation of resources in the audit; and directing the efforts of the engagement team. These matters, and any comments we make on the results of our procedures thereon, were addressed in the context of our audit of the financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate opinion on these matters. This is not a complete list of all risks identified by our audit. The key audit matters are discussed further in the Appendix.

How we tailored the audit scope

We tailored the scope of our audit to ensure that we performed enough work to be able to give an opinion on the financial statements as a whole, taking into account the structure of the group and the parent company, the accounting processes and controls, and the industry in which they operate.

HSBC Bank plc is structured into four divisions being Retail Banking and Wealth Management, Commercial Banking, Global Banking & Markets and Global Private Banking. The divisions operate across a number of operations, subsidiary entities and branches throughout Europe. Within the group's main consolidation and financial reporting system, the consolidated financial statements are an aggregation of the operations, subsidiary entities and branches ('reporting units'). Each reporting unit submits their financial information to the group in the form of a consolidation pack.

The ring-fencing requirements of the UK Financial Services (Banking Reform) Act 2013 and associated secondary legislation and regulatory rules, required UK deposit-taking banks with more than GBP25bn of 'core deposits' (broadly from individuals and small to medium-sized businesses) to separate their UK retail banking activities from their other wholesale and investment banking activities by 1 January 2019. As a result, on 1 July 2018, the UK Retail Banking and Wealth Management and the majority of the Commercial Banking divisions were transferred from HSBC Bank plc into a separately regulated legal entity, HSBC UK Bank plc (the 'ring-fenced bank'). This transaction had a significant impact on the audit of HSBC Bank plc and was considered as part of the scoping and execution of our testing.

In establishing the overall approach to the group and parent company audit, we scoped using the balances included in the consolidation pack. We determined the type of work that needed to be performed over the reporting units by us, as the group engagement team, or auditors within PwC UK and from other PwC network firms operating under our instruction ('component auditors').

As a result of our scoping, for the parent company we determined that an audit of the complete financial information of the UK Operations of the Bank was necessary, owing to its financial significance. For group purposes, we additionally performed an audit of the complete financial information of HSBC France. We instructed component auditors, PwC UK and PwC France, to perform the audits of these components. Our interactions with component auditors included regular communication throughout the audit, including visits to France, the issuance of instructions, a review of working papers relating to the key audit matters and formal clearance meetings. The group audit engagement partner was also the partner on the audit of the UK Operations significant component.

We then considered the significance of other reporting units in relation to primary statement account balances. In doing this we also considered the presence of any significant audit risks and other qualitative factors (including history of misstatements through fraud or error). For five reporting units, specific audit procedures were performed over selected significant account balances. For the remainder, the risk of material misstatement was mitigated through group audit procedures including testing of entity level controls and group and parent company level analytical review procedures.

Certain group-level account balances (including goodwill) were audited by the group engagement team.

Materiality

The scope of our audit was influenced by our application of materiality. We set certain quantitative thresholds for materiality. These, together with qualitative considerations, helped us to determine the scope of our audit and the nature, timing and extent of our audit procedures on the individual financial statement line items and disclosures and in evaluating the effect of misstatements, both individually and in aggregate on the financial statements as a whole.

Based on our professional judgement, we determined materiality for the financial statements as a whole as follows:

 
                         Group financial statements           Parent company financial 
                                                               statements 
Overall materiality      GBP282 million (2017: GBP183         GBP235 million (2017: GBP183 
                          million).                            million). 
How we determined        0.75% of Total Regulatory            0.75% of Total Regulatory 
 it                       Capital.                             Capital. 
Rationale for benchmark  Regulatory capital is used           Materiality is determined 
 applied                  as a benchmark as it is considered   as the lower of the group 
                          to be a key driver of HSBC's         materiality or 0.75% of the 
                          decision making process and          parent company's regulatory 
                          is a primary focus for regulators.   capital. 0.75% of the parent 
                                                               company's regulatory capital 
                                                               was lower. 
 

In the prior year an adjusted profit before tax benchmark was used to determine materiality. However, due to the change in the nature of the group's business activities following the separation of the ring-fenced bank, the basis for determining materiality was re-evaluated and a regulatory capital based benchmark for materiality was chosen instead.

For each component in the scope of our group audit, we allocated a materiality that is less than our overall group materiality. The range of materiality allocated across components was GBP10m to GBP168m. Certain components were audited to a local statutory audit materiality that was also less than our overall group materiality.

We agreed with the Audit Committee that we would report to them misstatements identified during our audit above GBP10 million (group audit and parent company audit) (2017: GBP9 million) as well as misstatements below those amounts that, in our view, warranted reporting for qualitative reasons.

Conclusions relating to going concern

ISAs (UK) require us to report to you when:

-- the directors' use of the going concern basis of accounting in the preparation of the financial statements is not appropriate; or

-- the directors have not disclosed in the financial statements any identified material uncertainties that may cast significant doubt about the group's and parent company's ability to continue to adopt the going concern basis of accounting for a period of at least twelve months from the date when the financial statements are authorised for issue.

We have nothing to report in respect of the above matters.

However, because not all future events or conditions can be predicted, this statement is not a guarantee as to the group's and parent company's ability to continue as a going concern.

Reporting on other information

The other information comprises all of the information in the Annual Report and Accounts 2018 other than the financial statements and our auditors' report thereon. The directors are responsible for the other information. Our opinion on the financial statements does not cover the other information and, accordingly, we do not express an audit opinion or, except to the extent otherwise explicitly stated in this report, any form of assurance thereon.

In connection with our audit of the financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the audit, or otherwise appears to be materially misstated. If we identify an apparent material inconsistency or material misstatement, we are required to perform procedures to conclude whether there is a material misstatement of the financial statements or a material misstatement of the other information. If, based on the work we have performed, we conclude that there is a material misstatement of this other information, we are required to report that fact. We have nothing to report based on these responsibilities.

With respect to the Strategic Report and Report of the Directors, we also considered whether the disclosures required by the UK Companies Act 2006 have been included.

Based on the responsibilities described above and our work undertaken in the course of the audit, ISAs (UK) require us also to report certain opinions and matters as described below.

Strategic Report and Report of the Directors

In our opinion, based on the work undertaken in the course of the audit, the information given in the Strategic Report and Report of the Directors for the year ended 31 December 2018 is consistent with the financial statements and has been prepared in accordance with applicable legal requirements.

In light of the knowledge and understanding of the group and parent company and their environment obtained in the course of the audit, we did not identify any material misstatements in the Strategic Report and Report of the Directors.

Responsibilities for the financial statements and the audit

Responsibilities of the directors for the financial statements

As explained more fully in the Statement of Directors' Responsibilities set out on page 78, the directors are responsible for the preparation of the financial statements in accordance with the applicable framework and for being satisfied that they give a true and fair view. The directors are also responsible for such internal control as they determine is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error.

In preparing the financial statements, the directors are responsible for assessing the group's and the parent company's ability to continue as a going concern, disclosing as applicable, matters related to going concern and using the going concern basis of accounting unless the directors either intend to liquidate the group or the parent company or to cease operations, or have no realistic alternative but to do so.

Auditors' responsibilities for the audit of the financial statements

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditors' report that includes our opinion. Reasonable assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.

A further description of our responsibilities for the audit of the financial statements is located on the FRC's website at: www.frc.org.uk/auditorsresponsibilities. This description forms part of our auditors' report.

Use of this report

This report, including the opinions, has been prepared for and only for the parent company's member as a body in accordance with Chapter 3 of Part 16 of the Companies Act 2006 and for no other purpose. We do not, in giving these opinions, accept or assume responsibility for any other purpose or to any other person to whom this report is shown or into whose hands it may come save where expressly agreed by our prior consent in writing.

 
 Other required reporting 
 

Companies Act 2006 exception reporting

Under the Companies Act 2006 we are required to report to you if, in our opinion:

   --     we have not received all the information and explanations we require for our audit; or 

-- adequate accounting records have not been kept by the parent company, or returns adequate for our audit have not been received from branches not visited by us; or

   --     certain disclosures of directors' remuneration specified by law are not made; or 

-- the parent company financial statements are not in agreement with the accounting records and returns.

We have no exceptions to report arising from this responsibility.

Appointment

Following the recommendation of the HSBC Bank plc Audit Committee, we were appointed by the directors on 31 March 2015 to audit the financial statements for the year ended 31 December 2015 and subsequent financial periods. The period of total uninterrupted engagement is 4 years, covering the years ended 31 December 2015 to 31 December 2018.

Simon Hunt

(Senior Statutory Auditor)

for and on behalf of PricewaterhouseCoopers LLP

Chartered Accountants and Statutory Auditors

London

19 February 2019

 
 Appendix: Key audit matters discussed with the Audit Committee ('AC') 
 

The key audit matters are discussed below together with an explanation of how the audit was tailored to address these specific areas.

All key audit matters are applicable to both the group and parent company.

 
 Application of IFRS 9 in the calculation of impairment of loans and 
  advances 
 
As this is the first year of adoption        At each Audit Committee and Risk 
 of IFRS 9, there is limited experience       Committee meeting there was a discussion 
 available to back-test the charge            on changes to risk factors and other 
 for expected credit losses ('ECL')           inputs within the models, geopolitical 
 with actual results. There is also           risks, such as Brexit, as well as 
 a significant increase in the number         discussions on individually significant 
 of data inputs required for the impairment   loan impairments. 
 calculation. The data is sourced 
 from a number of systems that have           The more judgemental interpretations 
 not been used previously for the             of IFRS 9 made by management continued 
 preparation of the accounting records.       to be discussed, in particular the 
 This increases risk around completeness      application of forward economic 
 and accuracy of certain data used            guidance, including the severity 
 to create assumptions and operate            and magnitude of modelled downside 
 the models.                                  scenarios; and associated considerations 
                                              of post model adjustments. 
 The credit environment has remained 
 benign for an extended period of             As the control environment for the 
 time, in part due to low interest            calculation of ECL under IFRS 9 
 rates and relative strength of the           continued to be strengthened following 
 European economy. However, there             initial adoption, we provided updates 
 are a number of headwinds to the             on the changes being made and the 
 regional economy as well as certain          results of our testing procedures. 
 country specific risks. As a result, 
 whilst the current levels of delinquencies 
 and defaults remains low, the risk 
 of impairment remains significant. 
 
  Controls were tested over: 
    *    Model performance monitoring, including periodic 
         policy and independent model reviews, back testing of 
         performance and approval of model changes. 
 
 
    *    Review and challenge of multiple economic scenarios 
         by an expert panel and internal governance committee. 
 
 
    *    Inputs of critical data into source systems, and the 
         flow and transformation of data between source 
         systems to the impairment calculation engine. 
 
 
    *    User acceptance testing over the automated 
         calculation of ECL to ensure it is performed in line 
         with business requirements. 
 
 
    *    Review and challenge forums to assess the ECL output 
         and approval of post model adjustments. 
 
 
    *    Approval of the key inputs, assumptions and 
         discounted cash-flows that support the significant 
         individual impairments. 
 
 
 
   Further substantive procedures included: 
    *    Risk based testing of models, including independent 
         rebuild of certain assumptions. 
 
 
    *    Testing the multiple economic scenarios and variables 
         using our economic experts to assess their 
         reasonableness. 
 
 
    *    Testing of the critical data used in the year end ECL 
         calculation. 
 
 
    *    Review of the SAS script codes for the impairment 
         engine against business requirements and our 
         expectations of how the calculation should operate. 
 
 
    *    Testing discounted cash flows for a sample of 
         individually assessed loans including, in specific 
         instances, using experts to assess the valuation of 
         collateral. 
 
Credit Risk Disclosures, page 35. 
 AC Report, page 74. 
 Note 34: Effects of reclassifications upon adoption of IFRS9, page 
 158. 
 
 
 Execution of structural reform required by the UK Financial Services 
  (Banking Reform) Act 2013 
 
            On 1 July 2018, the Retail Banking                        The application of predecessor accounting 
             and Wealth Management, Global Private                     and the method of allocation of 
             Banking, the majority of the Commercial                   goodwill to the ring-fenced bank 
             Banking and specific elements of                          was reviewed and discussed with 
             Global Banking and Markets divisions                      the Audit Committee. 
             of HSBC Bank plc were transferred 
             to HSBC UK Bank plc. The transfer                         In addition, we discussed the approach 
             was accounted for as a group reorganisation               taken by management to identify 
             and predecessor accounting values                         and allocate customer accounts defined 
             applied to the balances transferred.                      by regulation as core deposits, 
                                                                       Relevant Financial Institutions 
             The separation of most financial                          and complex products. We also discussed 
             statement line items was straightforward,                 the results of quality assurance 
             however, the allocation of certain                        procedures undertaken by management 
             intangible assets, certain provisions                     to test the appropriateness of the 
             and specific balances in other assets                     allocation process. 
             and other liabilities involved a 
             higher degree of management judgement,                    We discussed with the Audit Committee 
             specifically:                                             the appropriateness of allocations 
                                                                       involving a higher degree of judgement. 
              *    the allocation of intangible assets based on an     We also discussed the appropriateness 
                   historic apportionment of central costs;            of customer account allocations 
                                                                       to either HSBC Bank plc or HSBC 
                                                                       UK Bank plc. 
              *    the nature of underlying transactions relating to 
                   specific balances in other assets and other         We discussed the results of our 
                   liabilities;                                        controls and substantive testing, 
                                                                       which found no material errors. 
 
              *    the allocation of goodwill between the banks; and 
 
 
              *    whether the separation of certain provisions was 
                   appropriate and reasonable. 
 
 
 
             While not requiring substantial management 
             judgement, the allocation of customer 
             accounts was also a key driver for 
             assignment of multiple balances to 
             each bank and therefore also a key 
             area of audit focus. 
 
      Controls were tested over: 
        *    The quality assurance measures performed by 
             management over customer allocations. Evidence 
             corroborating the conclusions drawn by management was 
             also obtained and reviewed. 
 
 
        *    Internal governance over the separation of HSBC UK 
             Bank plc from HSBC Bank plc. 
 
 
 
       Further substantive procedures included: 
        *    We assessed the appropriateness of the accounting 
             treatment applied by management. 
 
 
        *    We tested the customers allocated to each entity and 
             assessed the nature of the customers and the 
             appropriateness of the sort-code applied. 
 
 
        *    We recalculated the allocation of goodwill between 
             the entities. 
 
 
        *    We obtained an understanding of management's approach 
             to judgemental allocations in relation to vacant 
             space provisions. We agreed the properties to the 
             entity fixed asset register together with the 
             associated vacant space provision. The allocation of 
             property to the entity fixed asset register was 
             tested. 
 
 
        *    For other assets and other liabilities not aligned to 
             a specific customer, samples were selected and 
             evidence obtained to validate the nature of the 
             underlying transactions and corroborate the 
             allocation. 
 
 
        *    In relation to intangible assets aligned to more than 
             one business line, the allocation percentage, based 
             on predefined rates upon which all central costs are 
             allocated, was recalculated. 
 
AC Report, page 74. 
 Economic background and outlook - Structural reform, page 18 
 
 
 IT Access Management 
 
The audit approach relies extensively        Over the past 4 years, management 
 on automated controls and therefore          implemented remediation activities 
 on the effectiveness of controls             that have contributed to reducing 
 over IT systems.                             the risk over access management 
                                              in the financial reporting process. 
 In previous years, we identified             The status of the remediation was 
 and reported that controls over access       discussed at several Audit Committee 
 to applications, operating systems           meetings. 
 and data in the financial reporting 
 process required improvements. Access 
 management controls are critical 
 to ensure that changes to applications 
 and underlying data are made in an 
 appropriate manner. Appropriate access 
 controls contribute to mitigating 
 the risk of potential fraud or errors 
 as a result of changes to application 
 and data. 
 
 However, issues related to privileged 
 access and business user access remained 
 unresolved on parts of the technology 
 infrastructure, requiring our audit 
 approach to respond to the risks 
 presented. 
 
   Access rights were tested over applications, operating systems and 
    databases relied upon for financial reporting. Specifically the audit 
    tested that: 
     *    New access requests for joiners were properly 
          reviewed and authorised. 
 
 
     *    User access rights were removed on a timely basis 
          when an individual left or moved role. 
 
 
     *    Access rights to applications, operating systems and 
          databases were periodically monitored for 
          appropriateness. 
 
 
     *    Highly privileged access was restricted to 
          appropriate personnel. 
 
 
 
    Other areas that were independently assessed included password policies, 
    security configurations, controls over changes to applications and 
    databases and that business users, developers and production support 
    did not have access to change applications, the operating system or 
    databases in the production environment. 
 
    As a consequence of the deficiencies identified, a range of other procedures 
    were performed: 
     *    Where inappropriate access was identified, we 
          understood the nature of the access, and, where 
          possible, obtained additional evidence on the 
          appropriateness of the activities performed. 
 
 
     *    Additional substantive testing was performed on 
          specific year-end reconciliations (i.e. custodian, 
          bank account and suspense account reconciliations) 
          and confirmations with external counterparties. 
 
 
     *    Testing was performed on other compensating controls 
          such as review controls undertaken by management. 
 
 
     *    Testing was performed over toxic combination 
          controls. 
 
 
     *    A list of users' access permissions was obtained and 
          manually compared to other access lists where 
          segregation of duties was deemed to be of higher risk, 
          for example users having access to both core banking 
          and payments systems. 
 
AC Report, page 74. 
 Effectiveness of internal controls, page 75. 
 
 
 Valuation of financial instruments 
 
The financial instruments held by           We discussed with the Audit Committee 
 HSBC range from those that are traded       our risk assessment with respect 
 daily on active markets with quoted         to valuation and the results of 
 prices, to more complex and bespoke         our controls testing. This included 
 positions. The valuation of these           a number of observations on how 
 complex financial instruments can           controls may be improved including 
 require the use of prices or inputs         controls over valuation models. 
 which are not readily observable 
 in the market.                              We also discussed the results of 
 Financial instruments classified            our substantive testing which included 
 as Level 3 (L3), per the IFRS 13            independent revaluation of a range 
 fair value hierarchy, are valued            of financial instruments, including 
 using some unobservable inputs. There       a sample of Level 3 positions. 
 is a risk that certain L3 portfolios 
 are not valued appropriately due 
 to the complexity of the trades and/or 
 unobservability of some inputs. 
 Valuation of the following L3 portfolios 
 was therefore classified as a significant 
 risk for the audit: asset-backed 
 securities and certain long-dated 
 interest rate derivatives. 
 
 
     *    We evaluated the design and tested the operating 
          effectiveness of the key controls supporting the 
          identification, measurement and oversight of the 
          valuation of financial instruments, including the 
          independent price verification process and governance 
          and reporting controls. This included review of the 
          year end independent price verification results by 
          the HSBC Bank plc Valuation Committee. 
 
 
     *    Methodology and underlying assumptions of key 
          valuation adjustments, including the Credit Valuation 
          Adjustment, Debt Valuation Adjustment and Funding 
          Fair Value Adjustment, were assessed, and compared 
          with our knowledge of current industry practice. 
          Controls over the calculation of these adjustments 
          were also tested. 
 
 
     *    We utilised our valuation specialists to perform 
          independent valuations to determine if management's 
          valuations fell within a reasonable range. The 
          revaluation covered a range of product classes and 
          was performed across Level 1, 2 and 3 of the group's 
          IFRS 13 fair value hierarchy. This testing 
          specifically included a sample of Level 3 positions 
          as at the balance sheet date. Where revaluation was 
          not possible, alternative testing procedures were 
          performed. 
 
 
     *    As a response to the control findings noted, we 
          increased the sample of independent revaluations 
          performed. 
 
AC Report, page 74. 
 Note 11: Fair values of financial instruments carried at fair value, 
 page 120. 
 

This information is provided by RNS, the news service of the London Stock Exchange. RNS is approved by the Financial Conduct Authority to act as a Primary Information Provider in the United Kingdom. Terms and conditions relating to the use and distribution of this information may apply. For further information, please contact rns@lseg.com or visit www.rns.com.

END

ACSTMMMTMBATBBL

(END) Dow Jones Newswires

February 20, 2019 06:54 ET (11:54 GMT)

Hsbc Bk 41 (LSE:63AS)
Historical Stock Chart
From Jun 2024 to Jul 2024 Click Here for more Hsbc Bk 41 Charts.
Hsbc Bk 41 (LSE:63AS)
Historical Stock Chart
From Jul 2023 to Jul 2024 Click Here for more Hsbc Bk 41 Charts.