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Auditors’ responsibilities for the audit of the country-by-country information
It is our responsibility to report on whether the country-by-country information has been properly prepared in accordance with the
relevant requirements of the Capital Requirements (Country-by-Country Reporting) Regulations 2013.
Our objectives are to obtain reasonable assurance about whether the country-by-country information as a whole is free from
material misstatement, whether due to fraud or error, and to issue an auditors’ report that includes our opinion. Reasonable
assurance is a high level of assurance, but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect
a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in
the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of this country-by-
country information.
Irregularities, including fraud, are instances of non-compliance with laws and regulations. We design procedures in line with our
responsibilities, outlined above, to detect material misstatements in respect of irregularities, including fraud. The extent to which
our procedures are capable of detecting irregularities, including fraud, is detailed below.
Based on our understanding of the company/industry, we identified that the principal risks of non-compliance with laws and
regulations related to breaches of UK regulatory principles, such as those governed by the Prudential Regulation Authority, and we
considered the extent to which non-compliance might have a material effect on the country-by-country information. We also
considered those laws and regulations that have a direct impact on the country-by-country information such as applicable tax
legislation and the Capital Requirements (Country-by-Country Reporting) Regulations 2013. We evaluated management’s incentives
and opportunities for fraudulent manipulation of the country-by-country information (including the risk of override of controls),
and determined that the principal risks were related to posting inappropriate journal entries to increase revenue or reduce
expenditure and management bias in accounting estimates. Audit procedures performed included:
• Review of internal audit and compliance monitoring findings throughout the year;
• Reading key correspondence with the Financial Conduct Authority and Prudential Regulation Authority;
• Incorporation of an element of unpredictability in our testing through altering the nature, timing and/or extent of work
performed;
• Challenging assumptions and judgements made by management in their significant accounting estimates;
• Identifying and testing journal entries, in particular any journal entries posted by senior management, posted with
descriptions indicating a higher level of risk, posted to unusual account combinations based on our understanding of usual
business operations, and material late adjustments.
There are inherent limitations in the audit procedures described above. We are less likely to become aware of instances of non-
compliance with laws and regulations that are not closely related to events and transactions reflected in the country-by-country
information. Also, the risk of not detecting a material misstatement due to fraud is higher than the risk of not detecting one resulting
from error, as fraud may involve deliberate concealment by, for example, forgery or intentional misrepresentations, or through
collusion.
A further description of our responsibilities for the audit of the country-by-country information is located on the FRC’s website at:
www.frc.org.uk/auditorsresponsibilities. This description forms part of our auditors’ report.
Use of this report
This report, including the opinion, has been prepared for and only for the company’s directors in accordance with the Capital
Requirements (Country-by-Country Reporting) Regulations 2013 and for no other purpose. We do not, in giving this opinion, accept
or assume responsibility for any other purpose or to any other person to whom this report is shown or into whose hands it may
come, save where expressly agreed by our prior consent in writing.
The engagement partner responsible for this audit is Chris Shepherd.
PricewaterhouseCoopers LLP
Chartered Accountants and Statutory Auditors
Birmingham
27 March 2025

