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                                                                                                                                                                                                                                          Contents
                                                                                                                                                                                                                                          Contents

                                                                                                                                                                                                Environmental, social
                                                                                                                                                                             The Bank’s         and governance
                                                                                                                                                                             governance                                                   Strategic Report
                                                                                                                                                                             policies and
                                                                                                                                                                             processes          Introduction
                                                                                                                                                                             are set out
                                                                                                                                                                             in detail on       The environmental, social and governance
                                                                                                                                                                             pages 42 – 71      (ESG) agenda is a key focus for the Board,
                                                                                                                                                                                                with regular debate and reports received
                                                                                                                                                                                                from the Executive relating to environmental,
                                                                                                                                                                                                community, and wider industry issues. The
                                                                                                                                                                                                Bank’s governance policies and processes
                                                                                                                                                                                                are set out in detail on pages 42 - 71.
                                                                                                                                   The Bank is pleased to report                                The Board recognises the importance of    Corporate Governance Statement

                                                                                                                                   the successful extension                                     the tone from the top so that the Board
                                Decisions made during the year                                                                                                                                  culture to the Bank’s health and creates
                                The Board reaffirmed the Bank’s current     ∞ Liquidity costs, greater commoditisation,            of its carbon neutral status                                 delivers on its responsibilities to all its various
                                                                                                                                                                                                stakeholders, especially our customers.
                                strategy, business structure, dividend     and the continued rise in deposit brokers
                                policy and capital structure during 2021.   in both the retail and SME markets;                    from 2020 to 2021.                                           Reducing our environmental impact
                                The Bank’s strategy has remained broadly
                                unchanged since it started trading in 2012     ∞ Long term trends in technology                                                                                 Climate change is a significant challenge
                                and has resulted in a balance sheet with   investment including IT data security and                                                                            facing society, with a growing focus for
                                assets exceeding £1bn, with pre-tax profits   cyber security threats;                                                  Other non-financial disclosures          all stakeholders, and the Bank continues
                                in excess of £18m pa.                                                                                                                                           to maintain a proactive approach to its
                                                                           ∞ Operational Resilience including the                                      The Bank has a moral, legal, and regulatory   environmental responsibilities. In 2021, the
                                The Board has assessed the future          impact of Supplier/Outsourcing Risks;                                       duty to prevent, detect and deter financial   Bank collaborated with Lancaster University   Independent Auditor’s Report
                                operating environment for the business and                                                                             crime and maintains a financial crime    Management School (LUMS) to further
                                expects continued growth in profits, and     ∞ Geopolitical headwinds and post                                         framework. This framework is supported   advise how climate risk changes will impact
                                ongoing investment in people and systems.   Brexit financial services equivalence                                      and reinforced by the Bank’s systems and   the Bank’s customer base, the properties
                                The Bank’s strategic objectives remain     arrangements, trade negotiations, and                                       behaviours which put the customer at     on which it has lent money, and inform the
                                unchanged. The Bank plans to continue to   the effects on UK business confidence;                                      the heart of every interaction. The Bank   environmental focus in the evolution of the
                                grow and bring its products and services to   and                                                                      promotes an environment that protects its   Bank’s strategy.
                                a wider geographical footprint and expand                                                                              customers, employees, and communities
                                its lending activities into new asset classes     ∞ The increased focus on climate                                     from financial crime, and continues to   The Bank is currently focusing on
                                where the existing capacity and capability   change risk.                                                              invest in its Anti-Money Laundering (AML)   understanding the potential impact on
                                of the Bank can be brought to bear,                                                                                    and Know Your Customer (KYC) financial   its loan security values and customers’
                                realising niche opportunities in markets   The number of newly launched niche                                          control system enhancements. The Bank’s   investments from increased flooding as
                                that offer earnings at a level accretive to   challenger banks, together with an increase                              compliance with requirements of the      well as potential new legislation relating to   Financial Statements
                                those achieved in the core businesses.   in the non-banking participation in the                                       financial crime framework is monitored   minimum Energy Performance Certificate
                                                                         asset finance market, has over the past                                       through ongoing control testing, assurance,   gradings. The Bank’s initial analysis has
                                The Bank’s future plans have been        few years also had a significant effect                                       audit, and the provision of management   concluded that its exposure to properties
                                influenced by the following trends       on lending margins. This has inevitably                                       information at senior governance         in high flood risk areas in England is limited
                                and risks:                               continued to put pressure on the Bank’s                                       committees. The Bank’s Modern Slavery    to 13 properties. Properties financed by
                                                                         gross lending margins. We continue to                                         Statement (which is available on our     the Bank have a range of EPC gradings and
                                   ∞ Macroeconomic environment (bank     ensure that our customers enjoy rates that                                    website) sets out the policies we apply   the Bank is currently developing plans for
                                   base rate and property valuations) and   compare well with those that are currently                                 and actions we take to ensure that our   how it can work with customers to assist,
                                   the impact of Covid 19 and the Ukraine   on offer in the market. Margin compression                                 employees and customers are treated with   where required, in the upgrading of property
                                   conflict on the UK economy,           is expected to continue although we                                           dignity and respect. This includes raising   energy standards. The Bank achieved its
                                                                         remain confident that following the                                           awareness of issues that could put the   plans to be carbon neutral across its head
                                   ∞ Credit cycle impacts closely aligned   expansion of our geographic footprint                                      people the Bank comes into contact with at   office site in Leicester in 2019, and is pleased   Notes to the Financial Statements
                                   to the above and the risk of material   across the country, and investing in our                                    risks such as vulnerability and exploitation.   to report the successful extension of its
                                   property price erosion;               relationships with our broker introducers,                                    The statement also explains how we ensure   carbon neutral plus status from 2020 to
                                                                         we will meet our growth appetite at                                           that the Bank’s values are applied within our   2021 following inclusion of its two regional
                                   ∞ Changes in competition and          margins commensurate with the Board’s                                         supply chain including the due diligence we   offices, as independently verified by Carbon
                                   market demand;                        credit risk appetite.                                                         carry out on our suppliers.              Footprint Ltd.
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