Standard Life ISSUED. 17 February 2017

Transcription

1 ISSUED 17 February 2017

2 Introduction Background AKG's Platform Profile & Financial Strength Reports are designed to meet the information needs of advisers in assessing the relative strengths of Platform Providers. Two different styles of report are published by AKG - FULL reports and SHORT reports. A FULL report is produced for each of the leading provider companies in the market, which participate in the production of the reports. For each remaining provider company which is covered, a SHORT report is produced. This is a FULL report. Each report collates relevant information from a range of sources such as a company s regulatory returns, its Report & Accounts and material provided by the companies themselves, and incorporates expert independent assessment. For FULL report companies the process is augmented by regular meetings and other communications with AKG. PLEASE NOTE: This report should be read in conjunction with the supporting explanatory information which is available online at About AKG AKG is an independent organisation. Originally established as an actuarial consultancy AKG has, for over 20 years, specialised in the provision of assessment, ratings, information and market assistance to the financial services industry. As the market has evolved over this period, the range of entities considered by AKG has expanded. Consequently AKG has brought additional skill sets into its operations. This has meant the inclusion of accounting, corporate finance, IT and market intelligence experience, alongside actuarial resources, to deliver an expanded professional capability. Today AKG s core purpose is in the provision of financial analysis and review services and in the delivery of key value added financial information to support the wider financial services sector and its customers. Regular Reports AKG publishes the following additional reports to assist Providers and Intermediaries: AKG Company Profile & Financial Strength Reports - covering onshore UK life companies, friendly societies and similar providers. AKG Offshore Profile & Financial Strength Reports - covering offshore life companies. AKG DFM Profile & Financial Strength Reports - covering discretionary fund managers. AKG UK Life Office With Profits Reports - providing further depth in the assessment of with profits funds. For further details, please contact AKG: Tel: +44 (0) or akg@akg.co.uk AKG Financial Analytics Ltd (AKG) 2017 This report is issued as at a certain date, and it remains AKG's current assessment with current ratings until it is superseded by a subsequently issued report or subsequently issued ratings (at which point the newly issued report or ratings should be used), or until AKG ceases to make such a report or ratings available. The report contains assessment based on available information at the date as shown on the report s cover and in its page footer. This includes prior regulatory data which may have an earlier date associated with it, but the report also takes into account all relevant events and information, available to and considered by AKG, which have occurred prior to this stated cover and footer date. Events and information subsequent to this date are not covered within it, but AKG continually monitors and reviews such events and information and where individually or in aggregate such events or information give rise to rating revision an updated report under an updated date is issued as soon as possible. All rights reserved. This report is protected by copyright. This report and the data/information contained herein is provided on a single site multi user basis. It may therefore be utilised by a number of individuals within a location. If provided in paper form this may be as part of a physical library arrangement, but copying is prohibited under copyright. If provided in electronic form, this may be by means of a shared server environment, but copying or installation onto more than one computer is prohibited under copyright. Printing from electronic form is permitted for own (single location) use only and multiple printing for onward distribution is prohibited under copyright. Further distribution and uses of the report, either in its entirety or part thereof, may be permitted by separate agreement, under licence. Please contact AKG in this regard or with any questions: akg@akg.co.uk, Tel +44 (0) AKG has made every effort to ensure the accuracy of the content of this report and to ensure that the information contained is as current as possible at the date of issue, but AKG (inclusive of its directors, officers, staff and shareholders and any affiliated third parties) cannot accept any liability to any party in respect of, or resulting from, errors or omissions. AKG information, comments and opinion, as expressed in the form of its analysis and ratings, do not establish or seek to establish suitability in any individual regard and AKG does not provide, explicitly or implicitly, through this report and its content, or any other assessment, rating or commentary, any form of investment advice or fiduciary service. AKG Financial Analytics Ltd 17 February 2017

3 Index Main Company Page Savings Ltd 2 General Information Distribution Service Assets under Administration Annual Review Page Group Overview is a UK based financial services group focused on providing long-term savings and investment solutions on a global basis. It sold both its banking operation and its healthcare operation in It operates in the UK, Europe, North America, Asia and Australia through its, Investments, Wealth, Savings and joint venture brands. It has around 4.5m customers worldwide, and a further 25m through its joint ventures in China (Heng An ) and India (HDFC ). entered the offshore market with the launch of its Dublin based subsidiary, International Ltd in January In July 2005 it acquired a shareholding in Tenet. It has also taken stakes in the intermediary service providers SimplyBiz (October 2006) and ThreeSixty (25% in June increased to 100% in March 2010). September 2010 saw the company sell its stakes in 2plan, a branded distribution group, and the wealth management arm of RSM Bentley Jennison. The acquisitions of Vebnet ( employee benefits solutions), Aida Capital ( alternative investments) and Focus Solutions ( software provider) were aimed at strengthening the group's capabilities in its chosen markets. In May 2015 acquired Pearson Jones from Skipton Building Society. This was then rebranded as 1825 and now operates as a restricted national advice service. has subsequently announced the acquisitions of regional financial planning businesses The Munro Partnership, Baigrie Davies and Jones Sheridan to further bolster the 1825 proposition. Following the demutualisation of The Assurance Company (SLAC) and the flotation of plc on the London Stock Exchange on 10 July 2006, Assurance Ltd (SLAL) operates in the UK alongside its now considerably smaller subsidiary, Pension Funds Ltd (SLPF). The Wrap is provided by Savings Ltd (SLSL). Other key businesses in the wider group, increasingly used within the broader strategic rationale, are Investments, the group's fund management arm, which also acquired Ignis Asset Management from Phoenix in July 2014, and Wealth Ltd, the discretionary fund manager, which acquired the private client business of Newton Management Ltd (NML) in September 's Canadian business was sold to Manulife for 2.2bn in January 2015, enabling a 1.75bn return to shareholders, together with a share consolidation (9 for 11 shares). AXA Portfolio Services Ltd, provider of the Elevate Platform, was acquired in November Group capital surplus was 2.2bn on a Solvency II basis on 30 June 2016, representing 154% solvency cover [1 January 2016: 2.1bn and 162% respectively]. Worldwide, the group had assets under administration of 328bn at 30 June Corporate Structure (simplified) plc Employee Services Ltd Investments (Holdings) Ltd Assurance Ltd Heng An Standard Life Insurance Co (China JV 50%) HDFC Insurance Co Ltd (India JV 35%) Wealth Ltd Investments Ltd International Ltd Savings Ltd Pension Funds Ltd AXA Portfolio Services Ltd Savings Nominees Ltd Ratings Company Platform Financial Strength Rating Service Supporting Ratings Image & Strategy Annual Review Savings Ltd B+ AKG Financial Analytics Ltd Page 1 17 February 2017

4 Savings Ltd Corporate Data Ownership Year Established 2001 Head Office Website plc House 30 Lothian Road Edinburgh EH1 2DH Tel: Key Personnel Group Chief Executive Officer Group Chief Financial Officer UK & Europe Chief Executive Officer CEO Wealth Director of Propositions MD, Corporate, Retail & Wholesale MD, Customer Services Head of Adviser & Wealth Management Propositions Head of Business Decision Support Customer Operations Director Head of Asset Admin Business Centre Director of Distribution N K Skeoch L Savage P S Matthews R A Charnock E Reynolds F A O'Dwyer J G McGuigan D Tiller A Warner D Archibald C Rowley N Butwell Company Background Established in 2001, SLSL is now responsible for Standard Life s UK platform businesses; in May 2006 SLSL launched its platform proposition, and it also runs the Fundzone proposition (its fund supermarket). In addition, the company acts as a PEP and ISA manager. Now considered an established player in the market, SLSL has continued to show significant growth in terms of Assets under Administration (AuA), with on-platform assets increasing to 28.9bn as at 30 June The platform is positioned as very much an adviser led proposition and as at 30 June 2016 was supporting 1,493 adviser firms [December 2015: 1,463] and over 230,000 clients. Platform Financial Strength B+ The financial strength of the platform operation is closely linked to that of the wider group from which it draws its ongoing development capital and for which it provides a core integrated component. has shown that it is committed to platforms, by virtue of this significant financial resource allocation and management focus which has been consistent in recent years, together with the acquisition of Elevate. The platforms are stated as core to s present and future model of operations, and the group is committed to continue investing in the appropriate technology, wider infrastructure and capital, in line with the original business plan for the short to medium term. Indeed, as a demonstration of its ongoing commitment to the adviser market in the UK, has announced Accelerate, a 30m investment in platform developments for The programme will deliver a range of enhancements and support to ensure Wrap is optimised for Pension Freedoms. Proposition Overview and Governance The Wrap provides access to over 2,750 funds from over 150 fund managers, with 23 asset classes and many other investment options, including ETFs and structured products. Portfolio modelling is provided through its own portfolio planning tool (other off-the-shelf portfolios are available), and SLWL provides comprehensive DFM (or DIM - Discretionary Investment Manager) capability. Whitelabelling is available for those advisers who require this. Risk management is carried out within the Group's Enterprise Risk Management (ERM) framework with responsibilities allocated to individuals within the businesses. The platform sits within the UK business of Group. The structure within the UK business is channel focused (Adviser, Workplace and Customer) and so responsibility for the platform sits with the Corporate, Retail & Wholesale MD, providing a single point of responsibility and accountability within the platform, consistent with governance in other channels. The Asset Administration Business Centre (AABC) sits at the heart of its investment governance, providing the process delivery control model and oversight. Ownership (Parent) plc is a UK based financial services group with a primary focus on savings and investment products. Technology Provider(s) FNZ (UK) Ltd (FNZ) is the UK element of an international platform technology business, and was established in the UK in It has provided technology for the Wrap proposition for several years, and also acts as a provider for other UK platforms. maintains a strong relationship with FNZ and takes a strategic role with FNZ effectively providing the 'front-end' and utilising other expertise, such as that of IBM or its own IT company, Focus Solutions, to develop aspects of the propositions. The parent company (Kiwi Holdco Cayco, Ltd) and its ultimate owner (H.I.G. Europe - FNZ, Ltd) are based in the Cayman Islands. In February 2012 FNZ had attracted further private equity investment from General Atlantic LLC, now a minority equity holder alongside H.I.G. Capital and the management team. The UK operation is FCA regulated and reported an increased pre-tax profit of 11.8m in 2015 [2014: 4.9m] and reported regulatory capital of 39.2m [2014: 26.7m]. Wrapper Provider(s) Investment Account and ISAs: Savings Ltd Onshore bonds and SIPPs: Assurance Ltd Offshore bonds: International Ltd Custodian/Nominee(s) Nominees: FNZ (UK) Ltd / FNZ Nominees Ltd Custodians: Bank of New York Mellon Other Additional external tools are available such as: risk profiling (from ORRA - Oxford Risk Research Analysis); portfolio analysis / planning (Towers Watson); data feeds and fund factsheets (Financial Express); fund analysis (Morningstar); and news feeds / equity pricing (Reuters). AKG regards SLSL as an important component of a group whose capital position has remained relatively resilient to volatile market movements, maintaining a good level of overall surplus capital. The platform operation appears to have benefited from this and developed a significant 'trusted business partner' proposition for advisers operating post-rdr. AKG Financial Analytics Ltd Page 2 17 February 2017

5 Savings Ltd Key Financial Data (for y/e: 31/12/15) Shareholder Funds 's 000's 000's Shareholder Funds b/f Changes in share capital Retained profit/loss for year Other 66,922 59, ,601 5,000-7,801-2,520 5, Shareholder Funds c/f 59,121 56,601 66,914 Total assets 80,816 68,931 75,143 Current liabilities Long term liabilities Total assets less liabilities 21, ,121 12, ,601 8, ,914 Capital Resources 's 000's 000's Available capital resources CRR 51,872 12,075 49,804 13,657 66,891 14,326 Excess capital resources 39,797 36,147 52,565 CRR Coverage Ratio % % % CRR coverage ratio Profit & Loss 's 000's 000's Turnover/Revenue Expenses 68,694 72,832 69,364 78,944 76,674 63,977 PBIT (Profit/Loss before interest & tax) -10,250-3,842 5,387 Interest Paid PBT (Profit/Loss before tax) -10,378-4,092 5,313 Tax -2,577-1,572 0 PAT (Profit/Loss after tax) -7,801-2,520 5,313 Dividends Retained Profit/Loss -7,801-2,520 5,313 EBITDA -10,250-3,842 5,387 Financial Ratios Operating margin Pre-tax profit margin EBITDA margin Interest cover -14.9% -15.1% -14.9% -80.1x -5.3% -5.6% -5.3% -15.4x 7.8% 7.7% 7.8% 72.8x In November 2014, a portion of SLSL's business transferred to Investments Ltd. Whilst the transfer did not impact the company's net assets, the revenue and expenses related to the transferred business are no longer recognised in SLSL. As a consequence, revenue reduced by 4.8% to 69.4m [2014: 72.8m], despite a further increase in AuA from 21.7bn to 26.0bn. Total expenses reduced by 17% to 64.0m. There remains, however, a significant underlying base of costs, the key components of which are staff costs and 'other administration costs'. All staff are employed by Employee Services Ltd, and recharged to SLSL. There has been some volatility in the staff recharges over the past few years, with the average number of staff aligned to SLSL decreasing from 593 in 2011 to 349 in 2012, increasing back to 522 in 2013 and 564 in 2014, before reducing to 535 in Staff costs also therefore reduced, down to 31.7m [2014: 32.2m]. 'Other administration costs', a range of expenses including recharges and investment expenses, saw a large reduction to 30.0m [2014: 39.4m]. With revenue exceeding expenses for the first time in a number of years, SLSL reported a pre-tax profit in 2015 of 5.3m [2014: 4.1m loss]. No dividend was paid [2014: nil]. The financial profile represents significant investment directed into developing the platform propositions over several years now. Whilst no formal capital support from the parent company was required in 2012, 2013 or 2014, there was a capital injection of 5m in Historically, the losses (development expenditure) had been funded by a series of capital injections ( 54m, 40m, 25m, and 50m in years respectively); running losses as at December 2015 year end reduced to 192m [2014: 197m]. Total net assets (Shareholder's Funds) increased to 66.9m [2014: 56.6m], boosted by retained profits and the capital injection. For liquidity and other funding, the company had access to a revolving credit agreement of 30m with its immediate parent, Assurance Ltd (SLAL), which could be utilised for short term funding if required. This expired in September 2015 and was not renewed. Cash resources reduced from 39.9m to 9.8m although 40.4m was invested in Seabury Assets Fund plc (Ireland), a liquidity fund managed by Investments. The Capital Resources Requirement (CRR) for SLSL increased again in 2015 (this calculated on the Fixed Overhead Requirement basis). Available capital resources also increased benefitting from the profit made and the capital injection, leading to an increase in the CRR ratio from 364.7% to 466.9%. Common with other subsidiary companies there are internal CRR targets for SLSL, and the capital position is managed to comply with those targets and minimum regulatory requirements. Current ratio Gearing 3.1x 24.4% 4.8x 14.9% 3.4x 9.2% Across the group, including its platform proposition, assets under administration continue to grow, helped by improving markets and an overall and increased net inflow of 6.3bn [2014: 1.0bn]. New business volumes, in PVNBP terms, were down overall, although UK retail fee business saw an increase. Group pre-tax operating profits from continuing operations increased by 9% to 665m [2014: 608m], mainly due to strong fee revenue performance from growth channels. Group underlying cash generation increased by 7% to 447m [2014: 419m]. The Group's IGD capital surplus reduced from 2.9bn to 2.7bn in 2015, primarily due to the sale of the Canadian business. The Group also reported Group Solvency II capital of 5.5bn against a requirement of 3.4bn as at 1 January AKG Financial Analytics Ltd Page 3 17 February 2017

6 Distribution Method The platform is provided under the brand to its core intermediary market. It benefits from the life company's established footprint in this respect, with significant longstanding relationships with intermediary firms and significant distribution capability to support growth via the platform. The company / platform is an integral part of 's UK Retail proposition and so leverages expertise from its position within the value chain and access to investment solutions. has stated that Elevate will currently continue as a distinct platform proposition. Key Relationships had arrangements with 1,493 adviser firms as at end Q2 2016, including all the major national distributors. 123 new firms were added to the platform in 2015 [2014: 104]. Image and Strategy has a long pedigree in the UK Long Term Savings market and is committed to its platform proposition, viewing its platform as key to growth in its UK retail business, given the ongoing demand and adoption for such infrastructure to sit at the core of adviser businesses and meet regulatory requirements effectively. Organic growth for the platform continues both in terms of adviser firms using the platform and AUA. However the acquisition of the Elevate platform from AXA adds significantly further scale to the overall platform footprint. The group believes that its brand and distribution reach will be key factors in its future success. In terms of scalability and capacity, suggests that its platform offering which now includes the Elevate component can support an unlimited number of clients and advisers, e.g. that it has been designed (and tested) with both horizontal and vertical capacity and scalability, built into the infrastructure. It has shown versatility, for instance, with the RBS partnership where powers RBS s non-advisory, direct-toconsumer online platform. The platform businesses remain firmly in the centre of 's broader proposition and are fundamentally, culturally and financially supported by their parent, which itself continues to perform strongly. The platform operation is maintaining a good reputation alongside other positive performers in the intermediary markets post-rdr, and is expected to continue to be a major presence. In addition, it sees adjacent opportunities in the Private Client (DFM/DIM accessible) and workplace (corporate) markets. has been recognised by the industry numerous times in recent years and it has a Defaqto 5 Star Platform Rating, Winner of Platform of the Year and Best Platform Provider (AUM over 12.5bn) 2014, 2015 and 2016, Best Platform for Adviser Service and Best use of Platform Technology at the Aberdeen UK Platform Awards The evolving integration and positioning of the Elevate platform will be the key element of operations strategy in the near term. Investments continues a strong association with the Ryder Cup golf competition, through its position as Worldwide Sponsor, partnering in both the UK and US. Service has invested significantly in its platform service capabilities, which are based on electronic self-service and maximising 'straight through processing' with a focus on the end customers. It acknowledges a commitment to sustainability and support over a 5-15 year client lifecycle. The AABC was established to deliver, over the asset life cycle, the investment processes that are not outsourced, and to have oversight control of those that are. Internal data confirms positive performance in most key areas. There are Platform Consultants to guide intermediaries and show them how to maximise platform functionality. Around 100 Platform Relationship Managers are out in the field in the UK, with 80% of them Level 5 qualified. has been recognised for its service in respect of the platform with a Defaqto Gold Service Rating in 2015 and Assets under Administration Assets under Administration Assets b/f Inflows Outflows 's 14,600,000 3,985,000 1,011, 's 17,000,000 4,495,000 1,241, 's 23,500,000 5,369,000 1,288,000 Assets c/f 17,000,000 23,500,000 26,500,000 Growth Rate 16.4% 38.2% 12.8% Expense Ratio (%) 0.5 % 0.4 % 0.3% Figures above are at December year end and relate to the total platform proposition, and had increased to 28.9bn by the end of June SLI manages around 22% of the AuA. The Elevate and deal creates one of the UK's largest and fastest growing adviser platform businesses with combined AuA of over 40bn, a total of 360,000 customers and combined new asset inflows of 5.1bn in the last 12 months. Annual Review The platform continued to grow in 2015, with AuA growing by 20% to 26bn and 123 adviser firms added, bringing the total to 1,463. It remains an integral part of the overall offering, embellished by the acquisition of Elevate. SLSL reported a pre-tax profit of 5.3m in 2015 [2014: 4.1m loss] after a number of loss making years. Group pre-tax operating profits increased by 9% to 665m [2014: 608m].The sale of the Canadian business has reduced the volatility of the group's earnings by greatly increasing the proportion of earnings coming from asset management and fee based business. This change lies at the core of the group's strategy. Investments, which started life as the investment department of an insurance company, is now firmly at the heart of its strategy providing investment solutions to clients globally. The Group's IGD capital surplus reduced from 2.9bn to 2.7bn in 2015, primarily due to the sale of the Canadian business. The Group also reported Group Solvency II capital of 5.5bn against a requirement of 3.4bn as at 1 January David Nish stood down as Group CEO in August 2015, succeeded by Keith Skeoch. AKG Financial Analytics Ltd Page 4 17 February 2017

7 AKG Financial Analytics Ltd 17 February 2017

8 Guide to AKG Ratings Financial Strength Ratings - Introduction AKG is an independent organisation which has provided detailed expert financial strength assessments (including ratings) and data to the UK financial services sector for over 20 years. AKG s analysis draws on publicly available information, supplemented by other detailed information made available to AKG directly by providers. Traditionally AKG s focus has been predominantly on life companies. However, in light of the growing impact of other entities Platforms and the transformation that this is bringing to the financial services market in the UK, there is an increasing demand from intermediaries in particular to widen the scope of entities that receive specialist AKG assessment. Overall, the aim of AKG s assessments is to provide independently evaluated information to assist in the choice of provider by the intermediary as well as to help in the understanding and appropriate development of the market. In line with its core focus, AKG s assessment is primarily focussed on financial strength. AKG considers that a major consideration for an intermediary in considering a Platform provider is the comfort and assurance that can be obtained from an independent, external assessment. It is an important component in seeking to avoid the operational complications and potential brand damage that would be incurred should a chosen Platform proposition encounter any financial difficulties, suffer a restriction on necessary investment to deliver required evolving functionality, or in some other way fail. AKG assesses financial strength using consistent methodology and objective measures wherever possible, and the detailed analysis of the company s particular strengths and weaknesses. The objectives and criteria for the Platform financial strength rating are summarised below. Platform Financial Strength Rating The objective is to provide a simple broad-brush indication of the financial strength of a Platform operator company. Platform operations are assessed in relative terms within a specific peer group of such entities. By design, and consistent with the very different nature of these entities, the rating is not comparable with other AKG ratings, such as those available for Life companies in AKG s Company Profile & Financial Strength Reports or Offshore Profile & Financial Strength Reports. Key to assessment is a company s ability to survive in its current form or an improved form for the long term to deliver on a user s reasonable expectations of experience. This will include expectations of service delivery and continued maintenance of appropriate infrastructure to deliver this. The following listing outlines primary elements (criteria) considered within this process, where relevant: Strategic appraisal Objectives Distribution Focus Process Competitive Position Company Structure and its fit with strategy Performance against stated strategy - Current and Past Risks and Risk Controls - Strategic, Market and Business Risks Financial appraisal Company Structure Capital Structure Use of Capital/Capital Availability Solvency Levels Expenses Business Mix Margins Customer Focus (TCF) Risk Tolerance Risks and Risk Controls A B+ B B- C D Superior Very strong Strong Satisfactory Weak Very Weak AKG Financial Analytics Ltd 17 February 2017

9 Guide to AKG Ratings (continued) Platform Financial Strength Rating (continued) Operational Appraisal Company Structure Management Servicing/Administration Management of/coordination with Independent Companies eg. Outsourcing Customer Focus Risk Control - Operational Risks, including Business Continuity Analysis of the Group and other entities Group Structure Where and how does the company fit in? Why? Is it core? Financial Support - Past, Present and in the Future Capital Availability to Company Relevant Other Entities - Collaborative, e.g. Technology providers Servicing/Administration providers Counterparties Process Distributors Note: Whilst account is taken of the relationship with Wrapper providers offered through any Platform, including issues of reputational risk, intermediaries and others should also look through to AKG s detailed work in respect of any of these. See: AKG Company Profile & Financial Strength Reports AKG Offshore Profile & Financial Strength Reports The Platform Financial Strength Rating should therefore not be taken as a proxy for any Life company rating in the context of Wrapper use, where separate consideration must apply. Supporting Ratings - Introduction Supporting ratings, assessed at the brand level, are provided only in full reports. AKG assesses three key supporting areas, using consistent methodology and objective measures wherever possible. The aim is to assist IFAs and others to consider the relative merits of the brands that they deal with. AKG's objectives and criteria for each of these ratings are summarised below: Service Rating The objective is to assess the quality of the organisation's service to the intermediary market in respect of the brand concerned. Criteria taken into account include: performance in surveys, awards and benchmarking exercises (external and internal), the organisation's philosophy, service charters, the extent of investments designed to improve service, and feedback from intermediaries. Image and Strategy Rating The objective is to assess the effectiveness of the means by which the organisation currently positions itself to distribute its products for the brand concerned and the plans it has to maintain and/or develop its position. Criteria taken into account include: overall trends in the company s market share position, brand visibility and reputation, feedback from intermediaries and industry commentators, and AKG s view of the company s general strategy. Annual Review Rating This is an end of year view for the last year for which Report and Accounts, Pillar III disclosure, etc., are available, together with comment on any significant post-balance sheet events. It is an assessment of how the brand has fared against its peers, and how it is perceived externally. Criteria taken into account include: increase/decrease in market shares, expense containment, publicity - good or bad, press or market commentary, regulatory fines, and competitive position. Excellent Very good Good Adequate Poor Not rated Excellent Very good Good Adequate Poor Not rated Excellent Very good Good Adequate Poor Not rated AKG Financial Analytics Ltd 17 February 2017

10 AKG Financial Analytics Ltd Anderton House, 92 South Street Dorking, Surrey RH4 2EW Tel No: +44 (0) Fax No: +44 (0) AKG is an independent organisation specialising in the provision of assessment, ratings, information and consultancy to the financial services industry AKG Financial Analytics Ltd 2017