Financial review
Contents
|
Page
|
Presentation of
information
|
2
|
Description of
business
|
2
|
Performance
overview
|
3
|
Financial
statements
|
4
|
Notes to the
financial statements
|
11
|
Statement of
directors' responsibilities
|
22
|
Forward-looking
statements
|
23
|
Presentation of
information
National Westminster Bank Plc
('NWB Plc') is a wholly owned subsidiary of NatWest Holdings
Limited ('NWH Ltd' or 'the intermediate holding company'). The term
'NWB Group' or 'we' refers to NWB Plc and its subsidiary and
associated undertakings. The term 'NWH Group' refers to NWH Ltd and
its subsidiary and associated undertakings. NatWest Group plc is
'the ultimate holding company'. The term 'NatWest Group' refers to
NatWest Group plc and its subsidiaries.
NWB Plc publishes its financial
statements in pounds sterling ('£' or 'sterling'). The
abbreviations '£m' and '£bn' represent millions and thousands of
millions of pounds sterling ('GBP'), respectively, and references
to 'pence' represent pence where amounts are denominated in
sterling. Reference to 'dollars' or '$' are to United States of
America ('US') dollars. The abbreviations '$m' and '$bn' represent
millions and thousands of millions of dollars, respectively. The
abbreviation '€' represents the 'euro', and the abbreviations '€m'
and '€bn' represent millions and thousands of millions of euros,
respectively.
Description of business
National Westminster Bank Plc
('NWB Plc', which wholly owns Coutts & Company) is a principal
entity under NatWest Holdings Limited ('NWH Ltd'), together with
The Royal Bank of Scotland plc ('RBS plc'). The term 'NWB Group'
refers to NWB Plc and its subsidiary and associated
undertakings.
Principal activities and operating segments
NWB Group serves customers across
the UK with a range of retail and commercial banking products and
services. A wide range of personal products are offered including
current accounts, credit cards, personal loans, mortgages and
wealth management services. NWB Plc is the main provider of shared
services for NatWest Group.
The reportable operating segments
are as follows:
Retail Banking -
serves personal customers in the UK and includes
Ulster Bank customers in Northern Ireland.
Private Banking -
serves UK-connected, high net worth individuals
and their business interests.
Commercial & Institutional - consists of customer businesses
reported under Business Banking, Commercial Mid-market and
Corporate & Institutions, supporting our customers across the
full non-personal customer lifecycle, both domestically and
internationally.
Central items & other - includes corporate functions such
as treasury, finance, risk management, compliance, legal,
communications and human resources. NWB Plc is the main service
provider of shared services and treasury activities for NatWest
Group. The services are mainly provided to NWH Group, however, in
certain instances where permitted, services are also provided to
the wider NatWest Group including the non ring-fenced
business.
Financial review
continued
Performance overview
Strong financial performance
NWB Group profit for the year was
£3,425 million compared with £3,509 million in 2023.
Total income decreased by £113
million to £11,973 million, primarily reflecting
a gain on redemption of own debt in 2023 and a
decrease on gains from economic hedging
derivatives. This was partially offset by
increased net interest income, lending and financing fees and
investment income.
Operating expenses increased by
£170 million to £6,963 million, reflecting higher staff costs as a
result of planned restructuring costs and higher depreciation and
amortisation costs, mainly due to continued investment in
technology. This was offset in part by a reduction in conduct and
managed services costs.
Net impairment losses of £347
million reduced year on year reflecting good book releases, post
model adjustment releases and the IFRS 9 multiple economic scenario
(MES) updates partially offset by an increase in Stage 3 charges.
Total impairment provisions decreased by £0.1 billion to £2.7
billion in the year. Expected credit loss (ECL) coverage ratio
decreased from 0.88% to 0.81%.
Robust balance sheet with strong capital
levels
Total assets increased by £8.8
billion to £424.3 billion. This was primarily driven by an increase
in loans to customers and a £7.6 billion increase in other
financial assets, driven by liquidity risk management activities,
principally net bond activity. This was partially offset by a
reduction in cash and balances at central banks.
Loans to customers increased by
£13.5 billion to £332.0 billion primarily
driven by an increase in reverse repo activities, growth in the
Retail Banking business as a result of the acquisition of a Metro
Bank mortgage portfolio, and commercial term loan
facilities.
Customer deposits increased by
£4.5 billion to £318.3 billion driven by
growth in savings balances combined with a deposit mix shift as
customers move toward interest bearing accounts. This was partially
offset by a reduction in repo balances as a result of market
conditions.
The Common Equity Tier 1 (CET1)
ratio decreased 20 basis points to 11.4% due to a £2.8 billion
increase in risk-weighted assets (RWAs) partially offset by a £0.1
billion increase in CET1 capital. The CET1 capital increase was
primarily driven by attributable profit, partially offset by
interim and foreseeable dividends.
Total RWAs increased by £2.8
billion to £124.5 billion mainly reflecting:
-
an increase in credit risk RWAs of £1.2 billion,
primarily driven by a £0.9 billion Metro Bank mortgage portfolio
acquisition, increased lending and an uplift in internal ratings
based (IRB) temporary model adjustment in Retail Banking and an
increase driven by drawdowns and new facilities within Commercial
& Institutional. These increases were partially offset by
active RWA management and improved risk metrics.
-
an increase in operational risk RWAs of £1.6
billion following the annual recalculation
Financial review
continued
Summary consolidated income statement for the year
ended 31 December 2024
|
|
|
|
|
|
|
|
Retail
|
Private
|
Commercial
&
|
Central
items
|
|
|
|
Banking
|
Banking
|
Institutional
|
&
other
|
|
2024
|
2023
|
Variance
|
|
£m
|
£m
|
£m
|
£m
|
|
£m
|
£m
|
£m
|
%
|
Net interest income
|
4,472
|
619
|
3,342
|
(225)
|
|
8,208
|
8,023
|
185
|
2
|
Non-interest income
|
412
|
319
|
1,446
|
1,588
|
|
3,765
|
4,063
|
(298)
|
(7)
|
Total income
|
4,884
|
938
|
4,788
|
1,363
|
|
11,973
|
12,086
|
(113)
|
(1)
|
Operating expenses
|
(2,445)
|
(700)
|
(2,346)
|
(1,472)
|
|
(6,963)
|
(6,793)
|
(170)
|
3
|
Profit/(loss) before impairment
losses/releases
|
2,439
|
238
|
2,442
|
(109)
|
|
5,010
|
5,293
|
(283)
|
(5)
|
Impairment
(losses)/releases
|
(250)
|
11
|
(117)
|
9
|
|
(347)
|
(504)
|
157
|
(31)
|
Operating profit/(loss) before
tax
|
2,189
|
249
|
2,325
|
(100)
|
|
4,663
|
4,789
|
(126)
|
(3)
|
Tax charge
|
|
|
(1,238)
|
(1,280)
|
42
|
(3)
|
Profit for the year
|
|
|
3,425
|
3,509
|
(84)
|
(2)
|
Key metrics and ratios
|
|
|
|
|
|
2024
|
2023
|
Cost:income
ratio (1)
|
|
|
|
|
|
58.2%
|
56.2%
|
Loan impairment
rate (2)
|
|
|
|
|
|
10bps
|
15bps
|
CET1 ratio (3)
|
|
11.4%
|
11.6%
|
Leverage ratio (4)
|
|
4.4%
|
4.5%
|
Risk-weighted assets
(RWAs)
|
|
£124.5bn
|
£121.7bn
|
Loan:deposit
ratio (5)
|
|
98%
|
97%
|
(1)
Cost:income ratio is total operating expenses divided by total
income.
(2) Loan
impairment rate is the loan impairment charge divided by gross
customer loans.
(3) CET1
ratio is CET1 capital divided by RWAs.
(4)
Leverage ratio is Tier 1 capital divided by total
exposure.
(5)
Loan:deposit ratio is total loans divided by total
deposits.
NWB Group reported a profit
of £3,425 million
compared with £3,509 million in 2023. This was driven by increased
operating expenses of £170 million and a £113 million decrease in
total income, partially offset by a decrease in net impairment
losses of £157 million.
Total income decreased by
£113 million, or 1%, to £11,973 million, primarily reflecting a
decrease in non-interest income.
Net interest income increased
by £185 million, or 2%, to £8,208 million primarily reflecting
lending growth, the higher rate environment and an increase in net bond
activity. This was partially offset by increased interest payable
on customer deposits, due to balance growth combined with a mix
shift from non-interest bearing to interest bearing
products.
Non-interest income decreased
by £298 million, or 7%, to £3,765 million, primarily driven by
other operating income, partially offset by an increase in net fees
and commissions.
Net fees and commissions increased by £65 million, or 4%, to £1,734 million, driven by
increased commercial lending and financing fees, and higher Assets
Under Management and Administration (AUMA) balances driving an
increase in investment income.
Other operating income reduced by £363 million, or 15%, to £2,031 million primarily
reflecting:
-
£234 million decrease primarily due to a gain on
redemption of own debt in 2023;
-
£184 million decrease on gains from economic
hedging derivatives, combined with a £44 million decrease on gains
from hedge ineffectiveness;
-
£64 million lower intercompany income due from
fellow NatWest subsidiaries, partially offset by;
-
£101 million increase due to gains on the sale of
assets, primarily due to a loss on disposal of property during
2023.
Operating expenses increased
by £170 million, or 3%, to £6,963 million reflecting:
-
an increase in staff costs of £192 million
primarily as a result of planned restructuring costs, including the
closure of operations in Poland and staff share scheme awards,
partially offset by a reduction in temporary staff
costs;
-
an increase in depreciation and amortisation
costs of £110 million mainly due to continued investment in
technology;
-
an increase in premises and equipment costs of
£60 million due to an increase in technology contract costs and
property provisions, partially offset by lower utility costs and a
smaller property footprint, partially offset by;
-
a decrease in other administrative costs of £192
million, primarily driven by a reduction in conduct costs, managed
services costs and a lower profit share arrangement with fellow
NatWest Group subsidiaries, partially offset by the new Bank of
England Levy.
Net impairment losses of £347
million reduced year on year reflecting good book releases, post
model adjustment releases and the MES update. Total impairment
provisions decreased by £0.1 billion to £2.7 billion in the year.
ECL coverage ratio decreased from 0.88% to 0.81%.
Financial review
continued
Summary consolidated balance sheet
as at 31 December 2024
|
2024
|
2023
|
Variance
|
£m
|
£m
|
£m
|
%
|
Assets
|
|
|
Cash and balances at central
banks
|
35,095
|
48,259
|
(13,164)
|
(27)
|
Derivatives
|
2,874
|
3,184
|
(310)
|
(10)
|
Loans to banks - amortised
cost
|
3,426
|
3,355
|
71
|
2
|
Loans to customers - amortised
cost
|
332,013
|
318,466
|
13,547
|
4
|
Amounts due from holding companies
and fellow subsidiaries
|
3,736
|
2,311
|
1,425
|
62
|
Other financial assets
|
39,571
|
31,944
|
7,627
|
24
|
Other assets
|
7,594
|
7,949
|
(355)
|
(4)
|
Total assets
|
424,309
|
415,468
|
8,841
|
2
|
|
|
|
|
Liabilities
|
|
|
|
Bank deposits
|
24,780
|
18,052
|
6,728
|
37
|
Customer deposits
|
318,290
|
313,752
|
4,538
|
1
|
Amounts due to holding companies
and fellow subsidiaries
|
47,724
|
47,252
|
472
|
1
|
Derivatives
|
1,177
|
1,718
|
(541)
|
(31)
|
Other financial
liabilities
|
4,999
|
9,011
|
(4,012)
|
(45)
|
Subordinated
liabilities
|
122
|
122
|
-
|
-
|
Notes in circulation
|
935
|
806
|
129
|
16
|
Other liabilities
|
3,164
|
3,325
|
(161)
|
(5)
|
Total liabilities
|
401,191
|
394,038
|
7,153
|
2
|
Total equity
|
23,118
|
21,430
|
1,688
|
8
|
Total liabilities and equity
|
424,309
|
415,468
|
8,841
|
2
|
Total assets increased by £8.8 billion to £424.3 billion as at 31 December
2024.
Cash and balances at central banks decreased by £13.2 billion to £35.1 billion, primarily
reflecting outflows as a result of net bond activity as part of
liquidity risk management.
Loans to banks - amortised cost remained broadly stable at £3.4 billion, primarily reflecting
increases in reverse repos offset by the reclassification of the
cash ratio deposit to cash and balances at central
banks.
Loans to customers - amortised cost
increased by £13.5 billion to £332.0 billion,
driven by a £6.2 billion increase in reverse repos, an increase in
commercial term loan facilities and a £3.6 billion increase in
Retail Banking mortgage portfolios, mainly driven by the £2.2
billion acquisition of a Metro Bank mortgage portfolio.
Amounts due from holding companies and fellow
subsidiaries increased by £1.4
billion to £3.7 billion primarily due to balances with fellow
subsidiaries of NWH Group.
Other financial assets increased by £7.6 billion to £39.6 billion, primarily
reflecting £38.1 billion of bond purchases, partially offset by
bond disposals and maturities of £31.5 billion.
Bank deposits increased by
£6.7 billion to £24.8 billion, driven primarily by an increase in
repo balances.
Customer deposits increased
by £4.5 billion to £318.3 billion, primarily due to a growth in
savings balances including a mix shift as customers move to
interest bearing products, partially offset by a £9.6 billion
reduction in repo balances.
Derivative liabilities decreased by £0.5 billion to £1.2 billion,
driven by favourable rate movements on interest rate
swaps.
Other financial liabilities decreased by £4.0 billion to £5.0 billion,
mainly driven by lower short-term funding, due to the current
market environment, and bond maturities.
Total equity increased by
£1.7 billion to £23.1 billion. The increase mainly reflects profit
for the year of £3.4 billion, a £0.8 billion increase in paid-in
equity and a £0.3 billion reduction in cash flow hedging reserves,
partially offset by £2.5 billion of ordinary dividends paid to
NatWest Group plc.
Notes to the financial statements
continued
3 Segmental analysis
Reportable operating segments
NWB Plc is organised into the
following reportable segments: Retail Banking, Private Banking,
Commercial & Institutional and Central items &
other.
Retail Banking serves
personal customers in the UK and includes Ulster Bank customers in
Northern Ireland.
Private Banking serves
UK-connected high-net-worth individuals and their business
interests.
Commercial & Institutional consists of customer businesses reported under Business
Banking, Commercial Mid-market and Corporate & Institutions,
supporting our customers across the full non-personal customer
lifecycle, both domestically and internationally.
Central items & other includes corporate functions such as
treasury, finance, risk management, compliance, legal,
communications and human resources. NWB Plc is the main service
provider of shared services and treasury activities for NatWest
Group. The services are mainly provided to NWH Group, however, in
certain instances where permitted, services are also provided to
the wider NatWest Group including the non ring-fenced
business.
|
|
|
|
Retail
|
Private
|
Commercial
&
|
Central
items
|
|
|
Banking
|
Banking
|
Institutional
|
&
other
|
Total
|
2024
|
|
|
|
£m
|
£m
|
£m
|
£m
|
£m
|
Net interest income
|
|
|
|
4,472
|
619
|
3,342
|
(225)
|
8,208
|
Net fees and
commissions
|
|
|
|
313
|
285
|
1,132
|
4
|
1,734
|
Other operating income
|
|
|
|
99
|
34
|
314
|
1,584
|
2,031
|
Total income
|
|
|
|
4,884
|
938
|
4,788
|
1,363
|
11,973
|
Depreciation and
amortisation
|
|
|
|
(1)
|
(1)
|
(117)
|
(868)
|
(987)
|
Other operating
expenses
|
|
|
|
(2,444)
|
(699)
|
(2,229)
|
(604)
|
(5,976)
|
Impairment
(losses)/releases
|
|
|
|
(250)
|
11
|
(117)
|
9
|
(347)
|
Operating profit/(loss)
|
|
|
|
2,189
|
249
|
2,325
|
(100)
|
4,663
|
2023
|
|
|
|
|
|
|
|
|
Net interest income
|
|
|
|
4,595
|
709
|
2,955
|
(236)
|
8,023
|
Net fees and
commissions
|
|
|
|
327
|
245
|
1,096
|
1
|
1,669
|
Other operating income
|
|
|
|
109
|
31
|
314
|
1,940
|
2,394
|
Total income
|
|
|
|
5,031
|
985
|
4,365
|
1,705
|
12,086
|
Depreciation and
amortisation
|
|
|
|
-
|
-
|
(124)
|
(753)
|
(877)
|
Other operating
expenses
|
|
|
|
(2,311)
|
(615)
|
(2,191)
|
(799)
|
(5,916)
|
Impairment
(losses)/releases
|
|
|
|
(410)
|
(13)
|
(82)
|
1
|
(504)
|
Operating profit
|
|
|
|
2,310
|
357
|
1,968
|
154
|
4,789
|
Total revenue (1)
|
|
Retail
|
Private
|
Commercial
&
|
Central
items
|
|
|
Banking
|
Banking
|
Institutional
|
&
other
|
Total
|
2024
|
£m
|
£m
|
£m
|
£m
|
£m
|
External
|
8,215
|
1,256
|
7,037
|
5,899
|
22,407
|
Inter-segment (2)
|
100
|
1,529
|
(1,369)
|
(260)
|
-
|
Total
|
8,315
|
2,785
|
5,668
|
5,639
|
22,407
|
|
2023
|
|
External
|
6,565
|
1,156
|
6,440
|
5,174
|
19,335
|
Inter-segment (2)
|
(187)
|
998
|
(1,558)
|
747
|
-
|
Total
|
6,378
|
2,154
|
4,882
|
5,921
|
19,335
|
Total income
|
|
Retail
|
Private
|
Commercial
&
|
Central
items
|
|
|
Banking
|
Banking
|
Institutional
|
&
other
|
Total
|
2024
|
£m
|
£m
|
£m
|
£m
|
£m
|
External
|
4,725
|
6
|
4,477
|
2,765
|
11,973
|
Inter-segment (2)
|
159
|
932
|
311
|
(1,402)
|
-
|
Total
|
4,884
|
938
|
4,788
|
1,363
|
11,973
|
|
2023
|
|
External
|
4,172
|
324
|
4,652
|
2,938
|
12,086
|
Inter-segment (2)
|
859
|
661
|
(287)
|
(1,233)
|
-
|
Total
|
5,031
|
985
|
4,365
|
1,705
|
12,086
|
(1) Total revenue comprises interest receivable, fees and
commissions receivable and other operating income.
(2) Revenue and income from transactions between segments of the
group are now reported as inter-segment in both the current and
comparative information.
Notes to the financial statements
continued
3 Segmental analysis
continued
Analysis of net fees and commissions
|
Retail
|
Private
|
Commercial
&
|
Central
items
|
|
|
Banking
|
Banking
|
Institutional
|
&
other
|
Total
|
2024
|
£m
|
£m
|
£m
|
£m
|
£m
|
Fees and commissions receivable
|
|
-
Payment services
|
261
|
37
|
538
|
-
|
836
|
-
Credit and debit card fees
|
327
|
13
|
199
|
4
|
543
|
-
Lending and financing
|
16
|
5
|
512
|
-
|
533
|
-
Brokerage
|
27
|
9
|
-
|
-
|
36
|
-
Investment management, trustee and fiduciary services
|
2
|
230
|
1
|
-
|
233
|
-
Underwriting fees
|
-
|
-
|
-
|
-
|
-
|
-
Other
|
8
|
11
|
70
|
6
|
95
|
Total
|
641
|
305
|
1,320
|
10
|
2,276
|
Fees and commissions payable
|
(328)
|
(20)
|
(188)
|
(6)
|
(542)
|
Net fees and commissions
|
313
|
285
|
1,132
|
4
|
1,734
|
|
2023
|
|
Fees and commissions receivable
|
|
-
Payment services
|
263
|
32
|
518
|
-
|
813
|
-
Credit and debit card fees
|
323
|
13
|
197
|
-
|
533
|
-
Lending and financing
|
12
|
5
|
489
|
-
|
506
|
-
Brokerage
|
27
|
6
|
-
|
-
|
33
|
-
Investment management, trustee and fiduciary services
|
2
|
205
|
-
|
-
|
207
|
-
Underwriting fees
|
-
|
-
|
1
|
-
|
1
|
-
Other
|
4
|
5
|
60
|
15
|
84
|
Total
|
631
|
266
|
1,265
|
15
|
2,177
|
Fees and commissions payable
|
(304)
|
(21)
|
(169)
|
(14)
|
(508)
|
Net fees and commissions
|
327
|
245
|
1,096
|
1
|
1,669
|
|
Retail
|
Private
|
Commercial
&
|
Central
items
|
|
|
Banking
|
Banking
|
Institutional
|
&
other
|
Total
|
2024
|
£m
|
£m
|
£m
|
£m
|
£m
|
Assets
|
199,579
|
18,916
|
92,653
|
113,161
|
424,309
|
Liabilities
|
159,989
|
42,603
|
127,878
|
70,721
|
401,191
|
|
2023
|
|
|
|
|
|
Assets
|
194,488
|
19,284
|
89,783
|
111,913
|
415,468
|
Liabilities
|
154,083
|
37,816
|
123,084
|
79,055
|
394,038
|
Notes to the financial statements
continued
4 Tax
|
2024
|
|
2023
|
|
£m
|
|
£m
|
Current tax
|
|
|
Charge for the year
|
(1,078)
|
|
(1,108)
|
Under provision in respect of
prior years
|
(117)
|
|
(63)
|
|
(1,195)
|
|
(1,171)
|
Deferred tax
|
|
|
Charge for the
year
|
(255)
|
|
(220)
|
Increase in the carrying value of
deferred tax assets in respect of UK losses
|
203
|
|
137
|
Over/(under) provision in respect
of prior years
|
9
|
|
(26)
|
Tax charge for the year
|
(1,238)
|
|
(1,280)
|
Current tax for the year ended 31
December 2024 is based on rates of 25% for the standard rate of UK
corporation tax and 3% for the UK banking surcharge.
The actual tax charge differs from
the expected tax charge, computed by applying the standard rate of
UK corporation tax of 25% (2023 - 23.5%), as follows:
|
2024
|
|
2023
|
|
£m
|
|
£m
|
Expected tax charge
|
(1,166)
|
|
(1,125)
|
Losses and temporary differences
in period where no deferred tax asset recognised
|
(2)
|
|
(1)
|
Foreign profits and losses taxed
at other rates
|
(5)
|
|
(8)
|
Items not allowed for
tax:
|
|
|
- losses on disposals and write-downs
|
(2)
|
|
-
|
- UK bank levy
|
(20)
|
|
(19)
|
- regulatory and legal actions
|
(16)
|
|
-
|
- other disallowable items
|
(36)
|
|
(32)
|
Non-taxable items
|
3
|
|
15
|
Taxable foreign exchange
movements
|
-
|
|
(1)
|
Increase in the carrying value of
deferred tax assets in respect of:
|
|
|
- UK losses (2)
|
203
|
|
137
|
Banking surcharge
|
(131)
|
|
(190)
|
Tax on paid in equity
dividends
|
42
|
|
33
|
Adjustments in respect of prior
years (1)
(2)
|
(108)
|
|
(89)
|
Actual tax charge
|
(1,238)
|
|
(1,280)
|
(1)
Prior year tax adjustments incorporate
refinements to tax computations made on submission and agreement
with the tax authorities and adjustments to provisions in respect
of uncertain tax positions.
(2)
Includes a net £61 million benefit from UK group
relief and loss relief claims at higher tax rates (refer to the
Deferred Tax section of the NatWest Bank Plc 2024 Annual Report and
Accounts for details of the recent changes in UK tax
rates).
Judgement: Tax contingencies
NWB Group's corporate income tax
charge and its provisions for corporate income taxes necessarily
involve a significant degree of estimation and judgement. The tax
treatment of some transactions is uncertain and tax computations
are yet to be agreed with the relevant tax authorities. NWB Group
recognises anticipated tax liabilities based on all available
evidence and, where appropriate, in the light of external advice.
Any difference between the final outcome and the amounts provided will affect current and deferred income
tax assets and charges in the period when the matter is
resolved.
For accounting policy information
refer to Accounting policies 2.1 and 3.7 in the NatWest Bank Plc
2024 Annual Report and Accounts.
Notes to the financial statements
continued
5 Loan impairment
provisions
Loan exposure and impairment metrics
The table below summarises loans
and related credit impairment measures within the scope of ECL
framework.
|
NWB Group
|
|
NWB Plc
|
|
31
December
|
31
December
|
|
31
December
|
31
December
|
|
2024
|
2023
|
|
2024
|
2023
|
|
£m
|
£m
|
|
£m
|
£m
|
Loans - amortised cost
|
|
|
|
|
Stage 1
|
298,209
|
288,772
|
|
268,368
|
258,188
|
Stage 2
|
35,517
|
31,727
|
|
31,101
|
28,008
|
Stage 3
|
4,798
|
4,405
|
|
4,112
|
4,003
|
Inter-group (1)
|
3,130
|
1,809
|
|
34,942
|
32,200
|
Total
|
341,654
|
326,713
|
|
338,523
|
322,400
|
ECL provisions (2)
|
|
|
|
|
Stage 1
|
482
|
566
|
|
442
|
521
|
Stage 2
|
667
|
794
|
|
624
|
746
|
Stage 3
|
1,599
|
1,512
|
|
1,482
|
1,416
|
Inter-group
|
2
|
1
|
|
39
|
41
|
|
2,750
|
2,873
|
|
2,587
|
2,724
|
ECL provision coverage (3)
|
|
|
|
|
Stage 1 (%)
|
0.16
|
0.20
|
|
0.16
|
0.20
|
Stage 2 (%)
|
1.88
|
2.50
|
|
2.01
|
2.66
|
Stage 3 (%)
|
33.33
|
34.32
|
|
36.04
|
35.37
|
Inter-group (%)
|
0.07
|
0.06
|
|
0.11
|
0.13
|
|
0.81
|
0.88
|
|
0.84
|
0.92
|
Impairment (releases)/losses
|
|
|
|
|
ECL
(release)/charge (4)
|
|
|
|
|
Stage 1
|
(355)
|
(319)
|
|
(335)
|
(302)
|
Stage 2
|
325
|
529
|
|
316
|
516
|
Stage 3
|
376
|
297
|
|
356
|
276
|
Third party
|
346
|
507
|
|
337
|
490
|
Inter-group
|
1
|
(3)
|
|
(3)
|
(7)
|
|
347
|
504
|
|
334
|
483
|
|
|
|
|
|
Amounts
written-off
|
549
|
235
|
|
536
|
218
|
(1)
NWB Group's intercompany assets are classified in
Stage 1.
(2)
Includes £4 million (2023 - £8 million) related to
assets classified as FVOCI.
(3)
ECL provisions coverage is calculated as ECL
provisions divided by loans - amortised cost and FVOCI. It is
calculated on loans and total ECL provisions, including ECL for
other (non-loan) assets and unutilised exposure. Some segments with
a high proportion of debt securities or unutilised exposure may
result in a not meaningful coverage ratio.
(4)
Includes a £10 million release (2023 - £10 million
charge) related to other financial assets, of which a £4 million
release (2023 - £6 million charge) related to assets classified as
FVOCI, and includes a £3 million release (2023 - £2 million
release) related to contingent liabilities.
(5)
The table shows gross loans only and excludes
amounts that are outside the scope of the ECL framework. Refer to
Financial instruments within the scope of the IFRS 9 ECL framework
in the NatWest Bank Plc Annual report and Accounts for further
details. Other financial assets within the scope of the IFRS 9 ECL
framework were cash and balances at central banks totalling £34.6
billion (2023 - £47.8 billion) and debt securities of £39.1 billion
(2023 - £31.5 billion).
Notes to the financial statements
continued
5 Loan impairment provisions
continued
Credit risk enhancement and mitigation
For information on credit risk
enhancement and mitigation held as security, refer to Risk and
capital management - credit risk enhancement and mitigation section
of the NatWest Bank Plc 2024 Annual Report and Accounts.
Critical accounting policy: Loan impairment
provisions
Accounting policy 2.3 sets out how
the expected loss approach is applied. At 31 December 2024,
impairment provisions amounted to £2,750 million (2023 - £2,873
million). A loan is impaired when there is objective evidence that
the cash flows will not occur in the manner expected when the loan
was advanced. Such evidence includes changes in the credit rating
of a borrower, the failure to make payments in accordance with the
loan agreement, significant reduction in the value of any security,
breach of limits or covenants, and observable data about relevant
macroeconomic measures.
The impairment loss is the
difference between the carrying value of the loan and the present
value of estimated future cash flows at the loan's original
effective interest rate.
The measurement of credit
impairment under the IFRS expected loss model depends on
management's assessment of any potential deterioration in the
creditworthiness of the borrower, its modelling of expected
performance and the application of economic forecasts. All three
elements require judgements that are potentially significant to the
estimate of impairment losses. For further information and
sensitivity analysis, refer to Risk and capital management -
measurement uncertainty and ECL sensitivity analysis
section.
IFRS 9 ECL model design principles
Refer to Credit risk - IFRS 9 ECL
model design principles section of the NatWest Bank Plc 2024 Annual
Report and Accounts for further details.
Approach for multiple economic scenarios
(MES)
The base scenario plays a greater
part in the calculation of ECL than the approach to MES.
Refer to Credit risk - economic loss drivers -
probability weightings of scenarios section of the NatWest Bank Plc
2024 Annual Report and Accounts for further details.
Notes to the financial statements
continued
6 Provisions for liabilities and
charges
|
NWB Group
|
Provisions for liabilities and charges
|
|
|
Financial commitments and
guarantees
|
|
Total
|
Redress and other
litigation
|
|
|
Property
|
Other (1)
|
£m
|
£m
|
£m
|
£m
|
£m
|
At 1 January 2024
|
247
|
64
|
56
|
89
|
456
|
Expected credit losses impairment
release
|
-
|
-
|
(17)
|
-
|
(17)
|
Currency translation and other
movements
|
1
|
-
|
-
|
-
|
1
|
Charge to income
statement
|
117
|
36
|
-
|
256
|
409
|
Release to income
statement
|
(23)
|
(27)
|
-
|
(42)
|
(92)
|
Provisions utilised
|
(87)
|
(14)
|
-
|
(179)
|
(280)
|
At 31 December 2024
|
255
|
59
|
39
|
124
|
477
|
|
NWB Plc
|
Provisions for liabilities and charges
|
|
|
Financial commitments and
guarantees
|
|
Total
|
Redress and other
litigation
|
|
|
Property
|
Other (1)
|
£m
|
£m
|
£m
|
£m
|
£m
|
At 1 January 2024
|
241
|
63
|
54
|
66
|
424
|
Expected credit losses impairment
release
|
-
|
-
|
(16)
|
-
|
(16)
|
Currency translation and other
movements
|
2
|
-
|
-
|
-
|
2
|
Charge to income
statement
|
112
|
35
|
-
|
234
|
381
|
Release to income
statement
|
(21)
|
(27)
|
-
|
(39)
|
(87)
|
Provisions utilised
|
(85)
|
(14)
|
-
|
(162)
|
(261)
|
At 31 December 2024
|
249
|
57
|
38
|
99
|
443
|
(1)
Other materially comprises provisions relating to
restructuring costs.
Provisions are liabilities of
uncertain timing or amount and are recognised when there is a
present obligation as a result of a past event, the outflow of
economic benefit is probable and the outflow can be estimated
reliably. Any difference between the final outcome and the amounts
provided will affect the reported results in the period when the
matter is resolved.
For accounting policy information
refer to Accounting policy Note 3.12 in the NatWest Bank Plc 2024
Annual Report and Accounts.
Notes to the financial statements
continued
7 Memorandum items
Contingent liabilities and commitments
The amounts shown in the table
below are intended only to provide an indication of the volume of
business outstanding at 31 December 2024. Although NWB Group is
exposed to credit risk in the event of non-performance of the
obligations undertaken by customers, the amounts shown do not, and
are not intended to, provide any indication of NWB Group's
expectation of future losses.
|
NWB Group
|
|
NWB Plc
|
|
2024
|
2023
|
|
2024
|
2023
|
|
£m
|
£m
|
|
£m
|
£m
|
Contingent liabilities and commitments
|
|
|
|
|
|
Guarantees
|
1,748
|
1,359
|
|
1,729
|
1,339
|
Other contingent
liabilities
|
1,142
|
1,173
|
|
1,097
|
1,127
|
Standby facilities, credit lines
and other commitments
|
93,758
|
85,304
|
|
82,965
|
75,333
|
Total
|
96,648
|
87,836
|
|
85,791
|
77,799
|
Trustee and other fiduciary
activities
In its capacity as trustee or
other fiduciary role, NWB Group may hold or place assets on behalf
of individuals, trusts, companies, pension schemes and others. The
assets and their income are not included in NWB Group's financial
statements. NWB Group earned fee income of £231 million (2023 -
£205 million) from these activities.
The Financial Services Compensation
Scheme
The Financial Services
Compensation Scheme (FSCS), the UK's statutory fund of last resort
for customers of authorised financial services firms, pays
compensation if a firm is unable to meet its obligations. The FSCS
funds compensation for customers by raising management expenses
levies and compensation levies on the industry. In relation to
protected deposits, each deposit-taking institution contributes
towards these levies in proportion to their share of total
protected deposits on 31 December of the year preceding the scheme
year (which runs from 1 April to 31 March), subject to annual
maxima set by the Prudential Regulation Authority. In addition, the
FSCS has the power to raise levies on a firm that has ceased to
participate in the scheme and is in the process of ceasing to be
authorised for the costs that it would have been liable to pay had
the FSCS made a levy in the financial year it ceased to be a
participant in the scheme.
Litigation and regulatory matters
NWB Plc and its subsidiary and
associated undertakings ('NWB Group') are party to various legal
proceedings and are involved in, or subject to, various regulatory
matters, including as the subject of investigations and other
regulatory and governmental action (Matters) in the United Kingdom
(UK), the United States (US), the European Union (EU) and other
jurisdictions.
NWB Group recognises a provision
for a liability in relation to these Matters when it is probable
that an outflow of economic benefits will be required to settle an
obligation resulting from past events, and a reliable estimate can
be made of the amount of the obligation.
In many of the Matters, it is not
possible to determine whether any loss is probable, or to estimate
reliably the amount of any loss, either as a direct consequence of
the relevant proceedings and regulatory matters or as a result of
adverse impacts or restrictions on NWB Group's reputation,
businesses and operations. Numerous legal and factual issues may
need to be resolved, including through potentially lengthy
discovery and document production exercises and determination of
important factual matters, and by addressing novel or unsettled
legal questions relevant to the proceedings in question, before the
probability of a liability, if any, arising can reasonably be
estimated in respect of any Matter. NWB Group cannot predict if,
how, or when such claims will be resolved or what the eventual
settlement, damages, fine, penalty or other relief, if any, may be,
particularly for Matters that are at an early stage in their
development or where claimants seek substantial or indeterminate
damages.
There are situations where NWB
Group may pursue an approach that in some instances leads to a
settlement agreement. This may occur in order to avoid the expense,
management distraction or reputational implications of continuing
to contest liability, or in order to take account of the risks
inherent in defending or contesting Matters, even for those for
which NWB Group believes it has credible defences and should
prevail on the merits. The uncertainties inherent in all Matters
affect the amount and timing of any potential economic outflows for
both Matters with respect to which provisions have been established
and other contingent liabilities in respect of any such
Matter.
It is not practicable to provide
an aggregate estimate of potential liability for our Matters as a
class of contingent liabilities.
The future economic outflow in
respect of any Matter may ultimately prove to be substantially
greater than, or less than, the aggregate provision, if any, that
NWB Group has recognised in respect of such Matter. Where a
reliable estimate of the economic outflow cannot be reasonably
made, no provision has been recognised. NWB Group expects that in
future periods, additional provisions and economic outflows
relating to Matters that may or may not be currently known by NWB
Group will be necessary, in amounts that are expected to be
substantial in some instances. Refer to
Note 21 of the NatWest Bank Plc 2024 Annual
Report and Accounts for information on
material provisions.
Matters which are, or could be,
material, either individually or in aggregate, having regard to NWB
Group, considered as a whole, in which NWB Group is currently
involved are set out below. We have provided information on the
procedural history of certain Matters, where we believe
appropriate, to aid the understanding of the Matter.
For a discussion of certain risks
associated with NWB Group's litigation and regulatory matters
(including the Matters), see the Risk Factor relating to legal,
regulatory and governmental actions and investigations set out on
page 186 of the NatWest Bank Plc 2024 Annual Report and
Accounts.
Notes to the financial statements
continued
7 Memorandum items
continued
Litigation
London Interbank Offered Rate (LIBOR) and other rates
litigation
In August 2020, a complaint was
filed in the United States District Court for the Northern District
of California by several United States retail borrowers against the
USD ICE LIBOR panel banks and their affiliates (including NatWest
Group plc, NatWest Markets Plc, NatWest Markets Securities Inc. and
NWB Plc), alleging (i) that the very process of setting USD ICE
LIBOR amounts to illegal price-fixing; and (ii) that banks in the
United States have illegally agreed to use LIBOR as a component of
price in variable retail loans. In September 2022, the district
court dismissed the complaint. In December 2024,
the United States Court of Appeals for the Ninth
Circuit affirmed the district court's decision.
Offshoring VAT assessments
HMRC, as part of an industry-wide
review, issued protective tax assessments in 2018 against NatWest
Group plc totalling £143 million relating to unpaid VAT in respect
of the UK branches of two NatWest Group companies registered in
India for the period from 1 January 2014 until 31 December 2017
inclusive. NatWest Group formally requested reconsideration by HMRC
of their assessments, and this process was completed in November
2020. HMRC upheld their original decision and, as a result, NatWest
Group plc lodged an appeal with the Tax Tribunal and an application
for judicial review with the High Court of Justice of England and
Wales, both in December 2020. In order to lodge the appeal with the
Tax Tribunal, NatWest Group plc was required to pay amounts
totalling £153 million (including statutory interest) to HMRC in
December 2020 and May 2022. The appeal and the application for
judicial review have both been stayed pending further discussion
with HMRC in relation to a separate case involving another
bank. The
amount of £153 million continues to be recognised as an asset that
NatWest Group plc expects to recover. Since 1 January 2018, NatWest
Group plc has paid VAT on intra-group supplies from the
India-registered NatWest Group companies.
Regulatory matters
NWB Group's financial condition
can be affected by the actions of various governmental and
regulatory authorities in the UK, the US, the EU and elsewhere. NWB
Group and/or NatWest Group have engaged, and will continue to
engage, in discussions with relevant governmental and regulatory
authorities, including in the UK, the US, the EU and elsewhere, on
an ongoing and regular basis, and in response to informal and
formal inquiries or investigations, regarding operational, systems
and control evaluations and issues including those related to
compliance with applicable laws and regulations, including consumer
protection, investment advice, business conduct,
competition/anti-trust, VAT recovery, anti-bribery, anti-money
laundering and sanctions regimes.
NWB Group expects government and
regulatory intervention in financial services to be high for the
foreseeable future, including increased scrutiny from competition
and other regulators in the retail and SME business
sectors.
Any matters discussed or
identified during such discussions and inquiries may result in,
among other things, further inquiry or investigation, other action
being taken by governmental and regulatory authorities, increased
costs being incurred by NWB Group, remediation of systems and
controls, public or private censure, restriction of NWB Group's
business activities and/or fines. Any of the events or
circumstances mentioned in this paragraph or below could have a
material adverse effect on NWB Group, its business, authorisations
and licences, reputation, results of operations or the price of
securities issued by it, or lead to material additional provisions
being taken.
NWB Group is co-operating fully
with the matters described below.
Investment advice review
In October 2019, the FCA notified
NatWest Group of its intention to appoint a Skilled Person under
section 166 of the Financial Services and Markets Act 2000 to
conduct a review of whether NatWest Group's past business review of
investment advice provided during 2010 to 2015 was subject to
appropriate governance and accountability and led to appropriate
customer outcomes. The Skilled Person's review has concluded and,
after discussion with the FCA, NatWest Group is undertaking
additional review / remediation work.
Notes to the financial statements
continued
8 Related parties
UK Government
The UK Government's shareholding
in NatWest Group plc is managed by UK Government Investments
Limited, a company wholly owned by the UK Government. At 31
December 2024 HM Treasury's holding in NatWest Group plc's ordinary
shares was 9.99% (31 December 2023 - 37.97%). As a result, the UK
Government through HM Treasury is no longer the controlling
shareholder of NatWest Group plc as per UK listing rules. The UK
Government and UK Government-controlled bodies remain related
parties of the NatWest Group.
NWB Group enters into transactions
with many of these bodies. Transactions include the payment of:
taxes, principally UK corporation tax Note 4 and value added tax;
national insurance contributions; local authority rates; and
regulatory fees and levies; together with banking transactions such
as loans and deposits undertaken in the normal course of
banker-customer relationships.
Bank of England facilities
NWB Group may participate in a
number of schemes operated by the Bank of England in the normal
course of business.
In March 2024 Bank of England Levy
replaced the Cash Ratio Deposit scheme. Members of NatWest Group
that are UK authorised institutions are required to pay the levy
having eligible liabilities greater than £600 million. They also
have access to Bank of England reserve accounts: sterling current
accounts that earn interest at the Bank of England Base
rate.
NWB Plc guarantees certain
liabilities of NWH Group to the Bank of England.
Other related party
(a) In accordance with
IAS 24, transactions or balances between NWB Group entities that
have been eliminated on consolidation are not reported.
(b) The primary
financial statements include transactions and balances with its
subsidiaries which have been further disclosed in the relevant
parent company notes.
Associates, joint ventures and equity
investments
In their roles as providers of
finance, NWB Group companies provide development and other types of
capital support to businesses. These investments are made in the
normal course of business. To further strategic partnerships, NWB
Group may seek to invest in third parties or allow third parties to
hold a minority interest in a subsidiary of NatWest Group. We
disclose as related parties for associates and joint ventures and
where equity interest are over 10%. Ongoing business transactions
with these entities are on normal commercial terms.
At 31 December 2024 NWB Group held
investment in associates and joint ventures amounting to £1 million
(2023 - £4 million). For the year ended 31 December 2024 NWB
Group's share of losses of associates was £2 million (2023 - £3
million). At 31 December 2024 there were £1 million balances within
customer deposits (2023 - £2 million) relating to associates and
joint ventures.
Post employment benefits
NatWest Group recharges NatWest
Group Pension Fund with the cost of pension management services
incurred by it.
Holding companies and fellow subsidiaries
Transactions NWB Group enters with
its holding companies and fellow subsidiaries also meet the
definition of related party transactions. The table below discloses
transactions between NWB Group and subsidiaries of NatWest
Group.
|
2024
|
|
2023
|
|
Holding
|
Fellow
|
Total
|
|
Holding
|
Fellow
|
Total
|
|
company
|
subsidiaries
|
|
|
company
|
subsidiaries
|
|
|
£m
|
£m
|
£m
|
|
£m
|
£m
|
£m
|
Interest receivable
|
2
|
95
|
97
|
|
-
|
133
|
133
|
Interest payable
|
(713)
|
(1,768)
|
(2,481)
|
|
(674)
|
(1,588)
|
(2,262)
|
Fees and commissions
receivable
|
-
|
74
|
74
|
|
-
|
62
|
62
|
Fees and commissions
payable
|
-
|
(78)
|
(78)
|
|
-
|
(71)
|
(71)
|
Other operating
income (1)
|
37
|
1,441
|
1,478
|
|
11
|
1,532
|
1,543
|
Other administration
expenses (2)
|
-
|
(128)
|
(128)
|
|
-
|
(156)
|
(156)
|
Impairment
(losses)/releases
|
(1)
|
-
|
(1)
|
|
3
|
-
|
3
|
|
(675)
|
(364)
|
(1,039)
|
|
(660)
|
(88)
|
(748)
|
(1)
Includes internal service recharges of £1,478
million (2023 - £1,542 million).
(2)
Other operating expense relates to a new profit
share arrangement with a fellow NatWest Group subsidiary that
commenced in 2024. The profit share arrangement was introduced
during the year to reward NWM Group on an arm's length basis for
its contribution to the performance of the NatWest Group Commercial
& Institutional business segment, 2024 being the first full
year with the Commercial & Institutional segment in
place.
Notes to the financial statements
continued
9 Date of approval
The annual results for the year
ended 31 December 2024 were approved by the board of directors on
13 February 2025.
10 Post balance sheet
events
There have been no significant
events between 31 December 2024 and the date of approval of these
accounts which would require a change to or additional disclosure
in the accounts.
Statement of directors'
responsibilities
This statement should be read in
conjunction with the responsibilities of the auditor set out in
their report on pages 87 to 97 of the NatWest Bank Plc 2024 Annual
Report and Accounts.
The directors are responsible for
the preparation of the Annual Report and Accounts.
The directors are required to prepare Group
financial statements, and as permitted by the Companies Act 2006
have elected to prepare company financial statements, for each
financial year in accordance with UK adopted International
Accounting Standards. They are responsible
for preparing financial statements that present fairly the
financial position, financial performance and cash flows of NWB
Group and NWB Plc. In preparing those financial statements, the
directors are required to:
- select suitable accounting policies and then apply them
consistently;
- make judgements and estimates that are reasonable, relevant
and reliable; and
- state whether applicable accounting standards have been
followed, subject to any material departures disclosed and
explained in the financial statements;
- prepare the financial statements on a going concern basis
unless it is inappropriate to presume that the company and Group
will continue in business.
The directors are responsible for
keeping proper accounting records which disclose with reasonable
accuracy at any time the financial position of NWB Group and to
enable them to ensure that the Annual Report and Accounts complies
with the Companies Act 2006. They are also responsible for
safeguarding the assets of NWB Plc and NWB Group and hence for
taking reasonable steps for the prevention and detection of fraud
and other irregularities.
Under applicable law and
regulations, the directors are also responsible for preparing a
Strategic report and Directors' report, that comply with that law
and those regulations. The directors are responsible for the
maintenance and integrity of the corporate and financial
information included on the company's website.
The directors confirm that to the
best of their knowledge:
- the financial statements, prepared in accordance with UK
adopted International Accounting Standards, give a true and fair
view of the assets, liabilities, financial position and profit or
loss of the Bank and the undertakings included in the consolidation
taken as a whole; and
- the Strategic report and Directors' report (incorporating the
Financial review) includes a fair review of the development and
performance of the business and the position of the Bank and the
undertakings included in the consolidation taken as a whole,
together with a description of the principal risks and
uncertainties that they face.
By order of the Board
Richard Haythornthwaite
|
John-Paul Thwaite
|
Katie Murray
|
Chair
|
Chief Executive Officer
|
Chief Financial Officer
|
13 February 2025
Board of directors
Chair
|
Executive directors
|
Non-executive directors
|
Richard Haythornthwaite
|
John-Paul Thwaite
Katie Murray
|
Francesca Barnes
Ian Cormack
Roisin Donnelly
Patrick Flynn
Geeta Gopalan
Yasmin Jetha
Stuart Lewis
Mark Rennison
Mark Seligman
Gillian Whitehead
Lena Wilson
|
Forward-looking
statements
Cautionary statement regarding
forward-looking statements
This document may include
forward-looking statements within the meaning of the United States
Private Securities Litigation Reform Act of 1995, such as
statements with respect to NWB Group's financial condition, results
of operations and business, including its strategic priorities,
financial, investment and capital targets, and climate and
sustainability related targets, commitments and ambitions described
herein. Statements that are not historical facts, including
statements about NWB Group's beliefs and expectations, are
forward-looking statements. Words such as 'expect', 'estimate',
'project', 'anticipate', 'commit', 'believe', 'should', 'intend',
'will', 'plan', 'could', 'target', 'goal', 'objective', 'may',
'outlook', 'prospects' and similar expressions or variations on
these expressions are intended to identify forward-looking
statements. In particular, this document may include
forward-looking statements relating, but not limited to: NWB
Group's economic and political risks, its regulatory capital
position and related requirements, its financial position,
profitability and financial performance (including financial,
capital, cost savings and operational targets), the implementation
of NatWest Group's strategy, its climate and sustainability related
ambitions and targets, its access to adequate sources of liquidity
and funding, its ongoing compliance with the UK ring-fencing regime
and ensuring operational continuity in resolution, its impairment
losses and credit exposures under certain specified scenarios,
substantial regulation and oversight, ongoing legal, regulatory and
governmental actions and investigations. Forward-looking statements
are subject to a number of risks and uncertainties that might cause
actual results and performance to differ materially from any
expected future results or performance expressed or implied by the
forward-looking statements. Factors that could cause or contribute
to differences in current expectations include, but are not limited
to, future growth initiatives (including acquisitions, joint
ventures and strategic partnerships), the outcome of legal,
regulatory and governmental actions and investigations, the level
and extent of future impairments and write-downs, legislative,
political, fiscal and regulatory developments, accounting
standards, competitive conditions, technological developments,
interest and exchange rate fluctuations, and general economic and
political conditions, exposure to third party risk, operational
risk, compliance and conduct risk, cyber, data and IT risk,
financial crime risk, key person risk, credit rating risk, model
risk, reputational risk, and the impact of climate related risks
and the transitioning to a net zero economy. These and other
factors, risks and uncertainties that may impact any
forward-looking statement or the NWB Group's actual results are
discussed in the NWB Plc's 2024 Annual Report and Accounts. The
forward-looking statements contained in this document speak only as
of the date of this document and NWB Plc does not assume or
undertake any obligation or responsibility to update any of the
forward-looking statements contained in this document, whether as a
result of new information, future events or otherwise, except to
the extent legally required.
Legal Entity Identifier:
213800IBT39XQ9C4CP7