Last checked at 3 Apr 2018 11:36
Balfour Beatty plc
LEI: CT4UIJ3TUKGYYHMENQ17
Balfour Beatty plc Annual Report and Accounts 2017, Notice of 2018 Annual General Meeting and Class Meeting of Preference Shareholders, Forms of Proxy and Notice of availability of documents
Copies of the following documents, which are being posted to shareholders today, have been submitted to the UK Listing Authority ("the UKLA"), and will shortly be available for inspection at the UKLA's Document Viewing Facility, via the National Storage Mechanism, which is located at www.morningstar.co.uk/uk/NSM:
· The Company's Annual Report and Accounts for the year ended 31 December 2017 ("Annual Report 2017");
· The Notice of 2018 Annual General Meeting ("AGM") and Class Meeting of Preference Shareholders ("Class Meeting");
· Forms of Proxy for AGM and Class Meeting (versions for shareholders who have elected to continue to receive paper copies of the Company's Annual Report and Accounts, and either request a paper proxy form or have elected to continue to receive one);
· Forms of Proxy for AGM and Class Meeting (versions for shareholders who have not elected to continue to receive paper copies of the Company's Annual Report and Accounts, and either request a paper proxy form or have elected to continue to receive one); and
· Notice of availability of the Annual Report 2017 and the Notice of AGM and Class Meeting.
Copies of the Annual Report 2017 and Notice of AGM and Class Meeting will also shortly be available to view on the Company's website, www.balfourbeatty.com.
The Independent Auditor's Report on the financial statements of the Company for the year ended 31 December 2017, which comprise the Group Income Statement, Group Statement of Comprehensive Income, Group Statement of Changes in Equity, Company Statement of Changes in Equity, Group and Company Balance Sheets, Group Statement of Cash Flows, and the related Notes 1 to 41, is set out in full on page 88 of the Annual Report 2017.
A condensed set of financial statements were appended to the Company's full year results announcement issued on 14 March 2018, which included an indication of important events that occurred during the year. That information, together with the information set out below regarding a description of the principal risks and uncertainties, related party transactions and a responsibility statement, which is extracted from the Annual Report 2017, constitute regulated information, which is to be communicated to the media in full unedited text through a Regulatory Information Service in accordance with Rule 6.3.5R of the Financial Conduct Authority's Disclosure Guidance and Transparency Rules.
Page and note references in the text below refer to page numbers in the Annual Report 2017.
This material should be read in conjunction with, and is not a substitute for, the full Annual Report 2017.
Principal risks
Understanding our risk profile
Understanding Balfour Beatty's risk profile and establishing the most effective way to manage, accept or transfer risk is central to the Group's decision-making process. As such, the Board has made a robust assessment of the principal risks which the Group faces, the controls in place to remove or mitigate these risks and also whether these risks represent new, increased or decreased threats.
The Group recognises that its risk profile comprises interlinked and discrete risks. The principal risks as set out below should therefore be considered alongside the viability statement on page 57 and the discussion on financial risk factors and going concern on page 47.
Health and safety | Risk: Increased Owner: Safety and Sustainability Committee Build to Last pillar: Safe |
Risk description The Group works on significant, complex and potentially hazardous projects which require continuous monitoring and management of health and safety risks. Causes Some common themes where health and safety risks could arise are recognised and communicated, including: risk identification/assessment processes that fail to deliver risk elimination or mitigation failure in safety leadership management of subcontractors not briefing people properly before setting them to work failure to follow procedures ongoing change programme and performance pressures, which may have an effect on people and their ability to remain focused on health and safety risks. | What impact it might have Failure to manage these risks gives the potential for significant harm to, or even the death of, employees, subcontractor staff or members of the public, as well as the potential for criminal prosecutions, significant fines, debarment and reputational damage. How it is mitigated Balfour Beatty has detailed health and safety policies, procedures and initiatives to minimise such risks. These are reviewed and monitored by management and external verification bodies. Each business has experienced health and safety professionals in place who provide advice and support and undertake regular reviews. The Safety and Sustainability Committee of the Board, as well as business-level Health and Safety executive leadership teams, meet regularly throughout the year to develop a consistent approach to health and safety best practice. Training programmes (including behavioural) are in place. Zero Harm action plans continue to be implemented and monitored. Risk movement Lagging performance indicators continue to improve however the upper limits for fines and scope for prosecution have increased. |
Work winning | Risk: No change Owner: Group Tender and Investment Committee Build to Last pillar: Trusted |
Risk description Failure to identify, price, and execute the right volume and quality of bids and investment opportunities to maintain a profitable, sustainable order book and deliver value to stakeholders. Causes Inaccuracy in: assumptions behind investment decisions costs versus scope and time calculations project programme and task duration estimates design and specifications not fully developed or understood assessment of the impact of inflation and exchange rates contract management negotiation of terms and conditions assessment of customers' liquidity/creditworthiness assessment of joint venture partners or supply chain. | What impact it might have Failure to estimate accurately the risks, costs versus scope, time to complete, impact of inflation and exchange rates, and failure to understand specification changes and contractual terms and how best to manage them could cause financial losses. In the event of disagreement with, failure of, or poor delivery performance by a joint venture partner, the Group could face financial and reputational risks. If any of the assumptions behind investment decisions prove incorrect, the profitability of those investments could be reduced. How it is mitigated Consistent and shared policies and minimum commercial expectations including acceptable margins. A wide and ongoing range of training initiatives across all disciplines within the Group including Cash is our Compass and High Value Selling to drive increased commercial awareness and an understanding of expectations on margins and cost. All bids are subject to rigorous estimating and tendering processes as part of the gateway review process. Commercial/contractual reviews are conducted by key commercial and legal staff. Defined delegated authority levels are in place for approving all tenders and infrastructure investments. Reviews are conducted following all tenders to ensure lessons are learnt, captured and applied to future tenders. Before entering into a joint venture agreement, the Group reviews the relevant skills, experience, resources and values of joint venture partners to understand how they complement its own. Investment appraisals are performed and reviewed by experienced professionals. The Group analyses the risks associated with revenues and costs and, where appropriate, establishes contractual and other risk mitigations. |
Project execution | Risk: No change Owner: Group management Build to Last pillar: Trusted |
Risk description Failure to deliver projects at the required specification on time and on budget to meet the expectations of customers and minimise the risk of delay-related damages and defect liabilities. Causes Failure to implement, maintain and challenge operational and commercial controls (as detailed within checklists at Gate reviews (4-6)) allowing: unrealistic programming targets non-availability of specialist resource unrealistic progress assessments and cost to complete judgements overly-optimistic claim recovery assumptions incomplete visibility and appreciation of scale of commercial judgements inaccurate and/or incomplete cost and value data or failure to analyse and report correctly, which could arise due to poor training, lack of supervision, lack of accountability or fear of reporting bad news failings in administering the contract terms to safeguard or protect future claims, change and extensions of time (EOTs). | What impact it might have Failure to manage or deliver against contracted customer requirements on time, on budget and to an appropriate quality could result in issues such as contract disputes, rejected claims, design issues, liquidated damages, cost overruns, failure to achieve customer savings and costs to rectify defective work - which in turn harm Balfour Beatty's profitability and reputation. The Group may also be exposed to long-term obligations including litigation and costs to rectify defective or unsafe work. Execution failure on a high-profile project could result in significant reputational damage and costs. How it is mitigated An increased focus on identifying and reporting risks, including the accuracy of cost and cash forecasting. Consistent application of strong commercial management and contract administration processes. Targeted recruitment of key staff within project delivery teams and senior management, together with ongoing and focused training of staff via the Balfour Beatty Academy. Ongoing project resource reviews. Gateway process embedded within each business and held on the Business Management System to increase accuracy and consistency within work winning and project delivery. Site Mobilisation Hub in place to facilitate early and effective start-up on site. Use of innovative and cost effective engineering and technical solutions. Planning and programming is undertaken to mitigate unforeseen events and changes. Drive for defect-free delivery is being embedded at all levels. Professional indemnity cover in place to provide further financial safeguards. Balfour Beatty monitors the performance of joint ventures, joint venture partners, subcontractors and suppliers throughout the lifecycle of a project. |
Data governance and cyber security | Risk: Increased Owner: Group management Build to Last pillar: Trusted |
Risk description Breach of the Data Protection Act or the General Data Protection Regulation (GDPR) and/or key company data or other confidential information is lost, stolen or compromised. Causes Failure to correctly assess and prepare for: the new GDPR the ongoing threat of cybercrime malicious intent and/or targeted attack breakdown of key security software or management system. | What impact it might have Crystallisation of this risk has the potential for: the business facing legal proceedings, investigations or disputes resulting in business disruption, losses, fines and penalties and reputational damage a reduction or loss of competitive advantage (including loss of intellectual property) a negative impact on customer relationships, including loss of confidence exclusion from bidding opportunities. How it is mitigated Data Protection Officers embedded throughout the businesses to ensure breaches are reported promptly and risks are appropriately escalated to the Group Data Protection Officer for consideration and assessment. Data protection programme covering policies, procedures and approved access levels in place alongside a comprehensive training plan. The Group's exposure has been reduced via a significant reduction in approved suppliers. All data is stored in secure data centres with strengthened back-up procedures. Regular review and communication of the ever-changing cyber threats and how they manifest themselves in practical guidance that all employees and contractors understand. Use of up-to-date anti-viral software and increased patching of key software. All employees are trained in and must comply with information security management obligations. Risk movement The potential risk exposure has increased as a result of the higher level of fines which will be enforceable under The General Data Protection Regulation. |
Uncertainty within our economic environment | Risk: No change Owner: The Board Build to Last pillar: Expert |
Risk description The effects of national or market trends, political or regulatory change (including the UK's exit from the EU and the change of administration in the US), or new developments in infrastructure expenditure or procurement may cause customers to re‑evaluate existing or future projects. Causes Failure to plan for any potentially negative impacts, or to capture any opportunities that may be presented could lead to: customers postponing, reducing or changing expenditure plans wider than expected fluctuations in inflation increased competition (eg in the UK from foreign investors acquiring competitors) increased supply chain risks (eg solvency, people and materials) reduced revenue or pressure on margins. | What impact it might have Any significant changes in the level or timing of customer spending or investment plans could adversely impact the Group's strategy, business model, revenue or profitability in the short or medium term. Restrictions to the availability of skilled labour and competitively priced materials will lead to a loss of competitive advantage and a devaluation of the business. Financial failure of a customer, including any government or public sector body, could result in not collecting amounts owed. How it is mitigated The Group's strategy to focus on the more resilient and stable infrastructure markets and geographies will help mitigate this risk. The effect of spending changes in any one market is mitigated by the Group's broad exposure to infrastructure markets and the continued need for infrastructure spending. Balfour Beatty also mitigates the effects of such market conditions by continuing to adapt its business model. The Group is actively monitoring the potential impacts of the UK exiting the EU including potential market stimulation by the UK Government, freedom of movement, finance costs, exchange rates and commodity prices. A dedicated Group-wide forum is in place for this purpose and issues a Brexit position paper for external audiences which is updated every second month. The financial solvency and strength of counterparties is always considered before contracts are signed and such assessments are updated and reviewed whenever possible during the project lifecycle. The business also seeks to ensure that it is not over-reliant on any one counterparty. |
People | Risk: No change Owner: The Board Build to Last pillar: Expert |
Risk description Inability to attract and retain required levels of skilled and competent staff to meet the Group's objectives. Causes Perceived limitations to internal career development Lack of recognition and reward Failure of businesses to promote good news stories Failure to maintain a culture of pride in the workplace Lack of a diverse workforce Restrictions in the availability of skilled labour. | What impact it might have Failure to recruit and retain appropriately skilled people could harm the Group's ability to win or perform specific contracts, grow its business and meet its strategic objectives. A high level of staff turnover or low employee engagement could result in a drop in confidence in the business within the market, customer relationships being lost and an inability to focus on business improvements. How it is mitigated The Balfour Beatty Academy has been established in the UK to provide professional development and knowledge sharing opportunities and to ensure employees feel valued and specialisms are recognised. Regular reviews of remuneration arrangements to ensure they are appropriate to help the Group attract, motivate and retain key employees. Strong employee communication channels are in place celebrating individual, business and Group-level successes. An annual Group-wide employee engagement survey is undertaken to measure engagement and appropriate actions are developed and communicated. Recruitment and retention rates are measured and regularly reviewed across all parts of the business. Affinity networks have been established to create a diverse and inclusive working environment. Emerging talent is supported via a range of graduate, apprenticeship, trainee and industrial placement/internship schemes including The 5% Club (see page 32). Competency frameworks within core job families identify and support the development of key knowledge, skills and expertise. The talent review process focuses on succession and the talent pipeline is supported by various development initiatives across the Group. |
Realising the transformation programme | Risk: No change Owner: The Board Build to Last pillar: All |
Risk description The momentum gained via the policies, process, and practices of Build to Last is not maintained and potential benefits are not realised. Causes To enable the transformation programme to succeed, a culture of adhering to the Build to Last principles must be continued and enhanced. Failing to grow this culture could result from: ineffective communication inadequate resourcing (financial, physical and people) complacency within core disciplines new systems and processes being used without appropriate controls being in place and/or tested. | What impact it might have Failure to capture fully the benefits of Build to Last could result in the Group's ability to deliver sustained profit being jeopardised. How it is mitigated Ensuring Build to Last continues to deliver the Group's standard operating procedures is a strategic priority for the Group and is being led by the Group Chief Executive. Controls include: continuing to embed the Build to Last culture within each business unit senior leadership communication across the businesses is clear and frequent new systems and processes are deployed with training plans and in agreed phases employee surveys form a key part of the programme leaders throughout the business frequently monitor the delivery and impacts of the programme senior leadership is well experienced in delivering business transformation successfully. |
Financial strength | Risk: No change Owner: The Board Build to Last pillar: Trusted |
Risk description Inability of the Group to maintain the financial strength required to operate its business and deliver its objectives. Causes Failure to manage financial risks, including forecasting material exposures, and the financial resources of the Group that underpin its ability to: meet ongoing liquidity obligations so that it remains a going concern meet financial covenants as set out in financing facility agreements maintain the confidence of customers and key markets and therefore continue to win long-term contracts. | What impact it might have Failure to deliver effectively the required financial strength will mean the Group: fails to meet financial covenant tests, as set out in its financing facility agreements, that would lead to an event of default if not remedied within a specific grace period fails to pass the required tests that allow it to continue to adopt the going concern basis of preparing the financial statements loses the ability to compete for key long-term contracts that are critical to the delivery of its long-term objectives and viability. How it is mitigated The Group operates with a centralised treasury function that is responsible for managing key financial risks, cash resources and the availability of liquidity and credit capacity. The Group maintains significant undrawn term committed bank facilities with a banking group of high credit-quality to underpin the liquidity requirements of the Group. The Group maintains significant bank and surety bonding facilities to deliver trade finance requirements of the Group on an ongoing basis. The Group operates standardised reporting, forecasting and budgeting financial processes. This allows monitoring of the impact of business decisions on financial performance over future time horizons. |
Supply chain | Risk: Decreased Owner: Group management Build to Last pillar: Lean |
Risk description Supply chain partners are not able to meet the Group's operational expectations and requirements including availability, financial stability, technical ability, quality, safety, environmental, social and ethical. Causes Supply chain failure risk, exacerbated during, and when emerging from, tough economic conditions Over-reliance on a limited number of suppliers Retention of subcontracted parties in buoyant markets Inadequate assessment of supply chain partner capabilities and process (including safety, ethics, quality, material stewardship, child labour, forced labour and modern slavery) Failure to accurately assess project resource requirements and key deliverables Unethical treatment of the supply chain. | What impact it might have Failure of a subcontractor or supplier would result in the Group having to find a replacement or undertaking the task itself. This could result in delays, additional costs or a reduction in quality owing to lack of expertise. Mistreatment of suppliers, subcontractors and their staff, or poor ethical standards in the supply chain, could lead to legal proceedings, investigations or disputes resulting in business disruption, losses, fines and penalties, reputational damage and debarment. How it is mitigated The Group aims to develop long-term relationships with key subcontractors, working closely with them to understand their operations and dependencies. Contingency plans in place to address subcontractor failure including replacement supplier list. Lessons are learnt from supply chain performance. All UK trade suppliers and subcontractors are assessed using the Constructionline service that collects, assesses and monitors standard company information through a question set aligned to PAS 91, the industry-standard pre-qualification questionnaire. The risk management framework and the gateway review process allow for early (Gates 1-4) and ongoing (Gate 6) assessment of the appropriateness of resource allocation and dependencies. My Contribution programme generates ideas for more effective procurement and resourcing. The Group obtains project retentions, bonds and/or letters of credit from subcontractors, where appropriate to mitigate the impact of any insolvency. Key supplier audits within projects to ensure they are in a position to deliver consistently against requirements. Group-wide Code of Conduct and Supplier Code of Conduct, and related policies and procedures in place. Risk movement Increased rigour in the pre-qualification processes, consolidation of the supply chain and improved monitoring of supplier performance. |
Business conduct/compliance | Risk: No change Owner: The Board Build to Last pillar: Trusted |
Risk description The Group operates in various markets that present business conduct-related risks involving fraud, bribery or corruption, whether by its own staff or via third parties such as agents, partners or subcontractors. Those risks are higher in some countries and sectors. Overall, the construction industry has a higher risk profile than other industries. Causes Corruption Bribery Fraud, deception, false claims or false accounting Unfair competition Human rights abuses, such as child and other labour standards generally, illegal workers, human trafficking and modern slavery Unethical treatment of and by the supply chain Risk of ethics and values being compromised as a result of commercial pressures Other emerging ethical risks. | What impact it might have Failure by the Group, or employees and third parties acting on its behalf or in partnership, to observe the highest standards of integrity and conduct could result in legal proceedings (including prosecution under the UK Bribery Act), investigations or disputes resulting in business disruption, losses, fines and penalties, reputational damage and debarment. How it is mitigated The Business Integrity function promotes, monitors, assesses awareness of and provides training on, the Code of Conduct. The function provides reports to the Audit and Risk Committee and has the full support of the Board. Each business unit, supported by the Business Integrity function, is responsible for embedding the Code of Conduct. The Group has a range of risk assessment, due diligence and procurement controls that are designed to identify and manage risks with third parties. Independent third-party whistleblowing hotline and dedicated email are in place and actively promoted. All in-scope complaints are independently investigated by the Business Integrity function and appropriate action is taken, where necessary. Balfour Beatty works with a limited number of agents, all of whom undergo a due diligence and approval process. |
Legal and regulatory | Risk: No change Owner: The Board Build to Last pillar: Trusted |
Risk description The Group does not comply with all legal, tax and regulatory requirements. Causes A failure to recognise or adapt to changes in applicable laws affecting the Group's businesses. Such changes may include: obligations as a result of government/regulatory enquiry and enforcement actions adverse changes of law, including changes to tax law local procurement laws exclusion from bidding or blacklisting. | What impact it might have The business could face legal proceedings, investigations or disputes resulting in business disruption, losses, fines and penalties, reputational damage and exclusion from bidding. Such action could also impact upon the valuation of assets within that territory. How it is mitigated The Group monitors and responds to tax, legal and regulatory developments and requirements in the territories in which it operates. Local legal and regulatory frameworks are considered as part of any decision to conduct business in a new country. Appropriate and responsive policies, procedures, training and risk management processes are in place throughout the business. |
Legacy pension liabilities | Risk: No change Owner: The Board Build to Last pillar: Lean |
Risk description The Group is exposed to significant defined benefit pension risks. Causes The Group is unable to ensure that the trustees of the pension funds react effectively to or manage: changes in interest rates inflation or life expectancy trends intervention by regulators or legislators investment performance of the funds' assets. | What impact it might have Failure to manage these risks adequately could lead to the Group being exposed to significant additional liabilities due to increased pension deficits. How it is mitigated The Group constructively engages with the trustees of the pension funds to ensure that they are taking appropriate advice and the funds' assets and liabilities are being managed appropriately. The Group's main UK fund has hedged in excess of 80% of its exposure to interest rate and inflation movements.
|
More generally and in addition to its principal risks Balfour Beatty faces significant risks and uncertainties that are common to many companies - including financial and treasury, communications and marketing, wider information security, business continuity and crisis management, and hazard risks.
"36 Related party transactions
Joint ventures and associates
The Group has contracted with, provided services to, and received management fees from, certain joint ventures and associates amounting to £279m (2016: £344m). These transactions occurred in the normal course of business at market rates and terms. In addition, the Group procured equipment and labour on behalf of certain joint ventures and associates which were recharged at cost with no mark-up. The amounts due from or to joint ventures and associates at the reporting date are disclosed in Notes 23 and 24 respectively.
Transactions with non-Group members
The Group also entered into transactions and had amounts outstanding with related parties which are not members of the Group as set out below. These companies were related parties as they are controlled or jointly controlled by a non-executive director of Balfour Beatty plc.
|
2017 £m |
2016 £m |
Anglian Water Group Ltd |
|
|
Sale of goods & services | 18 | 13 |
Amounts owed by related parties | 3 | - |
URENCO Ltd |
|
|
Sale of goods & services | 72 | 62 |
Amounts owed by related parties | - | 5 |
All transactions with these related parties were conducted on normal commercial terms, equivalent to those conducted with external parties. The amounts outstanding are unsecured and will be settled in cash. No guarantees have been given or received. No expense has been recognised in the period for bad or doubtful debts in respect of the amounts owed by related parties.
Compensation of key management personnel of the Company
|
2017 £m |
2016 £m |
Short-term benefits | 2.938 | 2.384 |
Share-based payments | 2.584 | 1.612 |
| 5.522 | 3.996 |
Key management personnel comprise the executive Directors who are directly responsible for the Group's activities and the non-executive Directors. The compensation included above is in respect of the period of the year during which the individuals were Directors. Further details of Directors' emoluments, post-employment benefits and interests are set out in the 2017 Remuneration report on pages 76 to 87."
"Statement of Directors' responsibilities
The Directors are responsible for preparing the Annual Report and the Group and Company financial statements in accordance with applicable law and regulations.
Company law requires the Directors to prepare Group and Company financial statements for each financial year. Under that law they are required to prepare the Group financial statements in accordance with International Financial Reporting Standards as adopted by the European Union (IFRSs as adopted by the EU) and applicable law and have elected to prepare the Company financial statements in accordance with UK accounting standards, including FRS 101 Reduced Disclosure Framework.
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 their profit or loss for that period. In preparing each of the Group and Company financial statements, the Directors are required to:
- select suitable accounting policies and then apply them consistently
- make judgements and estimates that are reasonable, relevant, reliable and prudent
- for the Group financial statements, state whether they have been prepared in accordance with IFRSs as adopted by the EU
- for the Company financial statements, state whether applicable UK accounting standards have been followed, subject to any material departures disclosed and explained in the Company financial statements
- assess the Group and the Company's ability to continue as a going concern, disclosing, as applicable, matters related to going concern
- use the going concern basis of accounting unless they either intend to liquidate the Group or the Company or to cease operations, or have no realistic alternative but to do so.
The Directors are responsible for keeping adequate accounting records that are sufficient to show and explain the Company's transactions and disclose with reasonable accuracy at any time the financial position of the Company and enable them to ensure that its financial statements comply with the Companies Act 2006. They are 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, and have general responsibility for taking such steps as are reasonably open to them to safeguard the assets of the Group and to prevent and detect fraud and other irregularities.
Under applicable law and regulations, the Directors are also responsible for preparing a Strategic Report, Directors' Report, Directors' Remuneration Report and Corporate Governance Statement 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. Legislation in the UK governing the preparation and dissemination of financial statements may differ from legislation in other jurisdictions.
The Directors confirm that to the best of their knowledge:
- the financial statements, prepared in accordance with the applicable set of accounting standards, give a true and fair view of the assets, liabilities, financial position and profit or loss of the Company and the undertakings included in the consolidation taken as a whole
- the Strategic Report includes a fair review of the development and performance of the business and the position of the Company and the undertakings included in the consolidation taken as a whole, together with a description of the principal risks and uncertainties that they face.
In light of the work undertaken by the Audit and Risk Committee reported in greater detail on pages 67 to 69 and the internal verification and approval process which has been followed this year, the Directors are able to state that the Annual Report and Accounts, taken as a whole, is fair, balanced and understandable and provides the information necessary for shareholders to assess the Company's position, performance, business model and strategy.
Statements of Directors as to disclosure of information to auditors
Each of the Directors at the date of approval of this report confirms that:
- so far as the Director is aware, there is no relevant audit information of which the Company's auditors are unaware
- the Director has taken all the steps that he or she ought to have taken as a Director to make himself or herself aware of any relevant audit information and to establish that the Company's auditors are aware of that information.
This confirmation is given and should be interpreted in accordance with the provisions of Section 418 of the Companies Act 2006.
By order of the Board
David Mercer
General Counsel and Company Secretary
13 March 2018
Registered Office:
5 Churchill Place, Canary Wharf
London E14 5HU
Registered in England Number 395826"