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CAPITAL REQUIREMENTS DIRECTIVE Pillar 3 Disclosure Document 2015
(As at 28th February 2015)
R. Raphael & Sons plc Pillar 3 Disclosures 2015
Contents 1. Introduction ............................................................................................................................................. 1
2. Risk management objectives and policies ............................................................................................... 2
2.1 Principal risks and uncertainties ........................................................................................................ 2
2.2 Credit risk ........................................................................................................................................... 2
2.3 Operational risk ................................................................................................................................. 3
2.4 Liquidity risk ....................................................................................................................................... 3
2.5 Interest rate risk ................................................................................................................................ 3
2.6 Foreign exchange risk ........................................................................................................................ 4
2.7 Regulatory risk ................................................................................................................................... 4
3. Board and Committee structure.............................................................................................................. 4
4. Capital resources ..................................................................................................................................... 6
4.1 Adequacy of capital ............................................................................................................................ 7
4.2 Capital adequacy assessment process ............................................................................................... 7
4.3 Leverage Ratio .................................................................................................................................... 7
5. Risk weighted exposure amounts & minimum capital requirement ...................................................... 8
5.1 Credit risk and provisions ................................................................................................................... 9
5.2 Operational risk ................................................................................................................................ 11
5.3 Interest rate risk ............................................................................................................................... 12
6. Remuneration policy and practices ....................................................................................................... 12
7. Article 89 disclosure .............................................................................................................................. 14
R. Raphael & Sons plc Pillar 3 Disclosures 2015
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1. Introduction
Purpose
This document provides background information on the approach used by R. Raphael & Sons Plc (‘the
Bank’) to manage risk and maintain its capital resources. As such, it includes details of:
• the approach to risk management, its policies and objectives;
• the governance structure of the Bank, including Board and Committees;
• asset information and capital resources; and
• compliance with the EU Capital Requirements Regulation.
Disclosures are for the Bank at the Accounting Reference Date (ARD) 28th February 2015. The document
is updated at least annually and will be published as soon as practicable after the ARD.
Legislative framework
The Capital Requirements Directive IV (CRD IV, 2013/36/EU) and the Capital Requirements Regulation
(CRR, 575/2013/EU), usually jointly referred to as CRD IV, came into force on 1 January 2014 and set out
the capital requirements for banks, building societies and related institutions across Europe. It is the
European implementation of Basel III, which sets out global standards for capital and liquidity adequacy,
and is now overseen by the Prudential Regulatory Authority (PRA) for banks and building societies in the
UK.
The Bank aims to ensure that it protects depositors’ funds by having sufficient capital even during a
significant economic downturn.
As well as setting out capital requirements, the CRD IV framework also requires various disclosures to be
made covering key aspects of the Bank’s risk management policies and procedures, including the main
risks faced by the Bank and the governance thereof.
CRD IV is split into 3 parts, known as Pillars:
Pillar 1 - Minimum capital requirements, on a risk based approach
Pillar 2 - Assessment of capital requirements by the Bank and the PRA
Pillar 3 - Disclosure
This disclosure document deals with the requirements laid down in Pillar 3 and the information provided
is in accordance with the rules laid out in the Part 8 of CRR.
R. Raphael & Sons approach
Under Pillar 1 the Bank has followed the Standardised Approach when calculating its minimum capital
requirements. This uses prescribed formulae for calculating the amount of capital to be held in respect
of credit, operational and market risks.
As required by Pillar 2, the Bank’s Board has performed a detailed assessment of the risks facing the
Bank and has calculated the amount of capital that it considers necessary to cover these risks. This
includes detailed stress tests of risks and financial forecasts to determine whether additional capital is
required to mitigate these risks, including in a severe economic downturn.
R. Raphael & Sons plc Pillar 3 Disclosures 2015
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The process of determining the total capital requirements is called the Internal Capital Adequacy
Assessment Process (ICAAP) and this is reviewed by the PRA through a Supervisory Review and
Evaluation Process (SREP). See section 4 for further details.
Verification
The Pillar 3 disclosures are subject to internal review procedures broadly consistent with those
undertaken for unaudited information published in the Bank’s Annual Report. The information
contained in this document therefore has not been audited by the Bank’s external auditors, except to
the extent it is deemed to be equivalent to those made under accounting requirements.
The disclosures have been prepared purely for explaining the basis on which the Bank has prepared and
disclosed certain capital requirements and information about the management of certain risks and for
no other purpose. They do not constitute any form of financial statement and must not be relied upon
in making any judgment on the Bank.
Media and location
This document will be published on the Bank’s website, www.raphaelsbank.com.
2. Risk management objectives and policies The Bank operates in an environment that exposes it to a wide range of risks. To mitigate these risks,
the Board has continued to develop and refine its Enterprise Risk Management (‘ERM’) framework over
the past year, which is used to identify the types and quantum of risks to which the Bank is prepared to
be exposed and how those risks are to be mitigated and managed.
Some of the key elements of the Bank’s ERM framework are:
The use of risk appetite and tolerance statements throughout the business;
The use of risk registers to identify key risks and ensure they are actively monitored and
managed;
The maintenance of up to date policies and procedures, including fully tested Business
Continuity Plans; and
The delegation to various committees of the oversight of how well the Bank manages risk. The
main committees in this respect are the Audit and Risk Committee, the Executive Committee
(EXCO) and the Asset & Liability Committee (ALCO).
Ultimate responsibility for the overall framework and the risk management strategy continues to reside
with the Board and all aspects of the ERM framework are reviewed, amended where appropriate and
approved at least annually by the Board to ensure they remain in line with best practice and are
consistent with the Bank’s strategic objectives.
2.1 Principal risks and uncertainties The principal risks to which the Bank is exposed and an outline of the primary means by which those
risks are managed are set out below.
2.2 Credit risk Credit risk is the risk that a loss will be incurred if a customer or counterparty fails to meet its
obligations.
R. Raphael & Sons plc Pillar 3 Disclosures 2015
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Credit risk arises principally from the Bank’s hire purchase facilities and other loans and advances to
customers and group companies, the investment of liquid assets with treasury counterparties or in
short-term securities, and amounts due to the Bank in the settlement of ATM disbursements. In the
case of sports season ticket loans, student support loans, medical loans, professional firms short-term
funding and credit cards, an important mitigant of the credit risk is the fact that the Bank has an
arrangement whereby a third party will buy back outstanding balances that are more than three months
in arrears. In the event of any failure of these third parties, the Bank would take over administration of
the loans directly. All activities that give rise to credit risk are undertaken in accordance with the
Board’s approved policies, and the risk is actively monitored by the EXCO and/or the ALCO.
2.3 Operational risk Operational risk is the risk of direct or indirect loss resulting from inadequate or failed internal
processes, people and systems or from external events arising from day-to-day operating activities.
The Bank seeks to mitigate this risk through a variety of measures including maintaining up-to-date
policies and procedures for all key internal processes, ensuring its staff receive ongoing training,
investing in appropriate systems, having documented and tested business continuity plans and,
wherever possible, ensuring that it has a diversified spread of counterparties, business partners and
suppliers. The EXCO is the Bank’s principal forum for monitoring operational risk which it does through
a variety of means including the use of risk registers, operational loss databases, control self
assessments and regular reviews of operational divisions and functional areas by Compliance and
Internal Audit.
The Bank recognises conduct risk as a specific sub-set of operational risk. Raphaels defines conduct risk
as ‘’the risk that, through Raphaels’ actions or inactions, one or more of its products and services fail to
deliver fair outcomes to its customers’’. The conduct risk governance framework mirrors other aspects
of the Bank’s ERM framework and is being actively managed at all levels within the Bank through
training, the establishment of risk appetite and tolerances and the use of appropriate Key Risk Indicators
(‘’KRI’’) and other management information.
2.4 Liquidity risk Liquidity risk is the risk that the Bank either does not have available cash or cannot obtain sufficient
financial resources to enable it to meet its obligations as they fall due, or only secure such resources at
an excessive cost.
The Bank’s policy is to maintain liquid assets at all times which are adequate, both as to amount and
quality, to ensure that there is no significant risk that its liabilities cannot be met as they fall due both in
business-as-usual and stressed scenarios. The Liquidity Policy details liquidity risk limits set by the Board
and day-to-day responsibility for ensuring these are adhered to rests with the ALCO. The Bank
completes an Individual Liquidity Adequacy Assessment (‘ILAA’) at least annually to assess its
compliance with the liquidity systems and controls requirements as detailed in the PRA Handbook. The
availability of funds to the Bank on the retail deposit market is supported by the Financial Services
Compensation Scheme’s coverage of the Bank’s deposit liabilities to retail customers and could be
jeopardised if this coverage was in question, but this risk is regarded by the Board as remote.
2.5 Interest rate risk Interest rate risk is the risk of reductions in income arising from unfavourable movements in interest
rates and/or reductions in the fair value of financial instruments.
This risk is managed within approved limits set by the Board and is monitored by the ALCO.
R. Raphael & Sons plc Pillar 3 Disclosures 2015
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2.6 Foreign exchange risk Foreign exchange risk is the risk of loss arising from unfavourable movements in currency exchange
rates.
The principal area of the Bank’s business where foreign exchange risk arises is within the ATM Division,
where Euro and US Dollar notes are held in ATMs prior to them being dispensed. Additionally the Bank
is exposed to foreign exchange risk when ATM transactions are settled in a different currency to the
original transaction. This risk is managed within approved limits set by the Board and is monitored and
managed by the ALCO. While a large proportion of card services cardholder liabilities are in currencies
other than sterling, the equivalent bank balance or investment is held in the same currency to ensure a
matched position and to mitigate any foreign exchange risk.
2.7 Regulatory risk Regulatory risk is the risk that the Bank does not adhere to the changing regulatory environment in
which it operates thereby threatening the achievement of the firm’s goals and objectives, possibly
damaging its reputation and, in extreme cases, giving rise to it being censured or fined by a regulator.
The Bank seeks to mitigate such risks by ensuring there are a suitable level of expertise within each of its
operating divisions which is then supported by a strong central compliance team and the use of risk-
based compliance monitoring plans to monitor and ensure the Bank’s ongoing adherence to relevant
laws and regulations. Finally and reflecting the three lines of defence model employed by the Bank, at
least annually, Internal Audit also undertakes a review of the Bank’s overall management of regulatory
risk.
3. Board and Committee structure The Bank’s Board is ultimately responsible for the strategy of the Bank, its risk management and its
compliance with all laws and regulations. In particular this includes maintaining adequate levels of
capital and liquidity. The Board meets at least ten times a year and comprises five executive Directors
and four non-executive Directors.
The Board has delegated a range of activities to each of the EXCO, the ALCO, the Audit and Risk
Committee, the Remuneration Committee and the Performance Committee. The Board and each of the
committees have their own Terms of Reference which are reviewed and if necessary updated at least
annually.
R. Raphael & Sons plc Pillar 3 Disclosures 2015
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The committee structure is illustrated below.
Audit and Risk Committee
The Committee’s duties include, among other things:
reviewing the effectiveness of the Bank’s policies and procedures for the identification,
assessment and reporting of risks;
setting the terms of reference and activities of the internal audit function;
reviewing the relationship with the external auditors; and
reviewing consistency of accounting policies from year to year and across the Bank.
The Committee is made up of three Non-executive Directors. Permanent invitees to each meeting of
the Committee are the Bank’s Chairman, the Executive Directors and the Head of Internal Audit.
Periodically members of the central compliance team and other members of staff will be invited to
attend meetings. The Committee also has private meetings with both internal and external audit
without the Bank’s executive management being present.
Remuneration Committee
The Remuneration Committee is appointed by the Board. It reviews and sets the remuneration for all
Bank staff. It comprises the Bank Chairman, the Chairman of the Audit and Risk Committee and the
CEO.
Executive Committee
The Bank’s EXCO is chaired by the CEO. Its members comprise the Executive Directors, and the Heads of
each division as well as key support function heads. The Committee meets at least 10 times per annum
and its responsibilities include agreeing budgets and considering proposals for introducing new products
for the Bank to offer to clients.
Asset and Liability Committee
The ALCO acts as a sub-committee of the EXCO and is primarily responsible, under delegated authority
from the Board, for the day-to-day management of the Bank’s liquidity and for ensuring that it operates
within capital adequacy limits established by the Board.
Board
Remuneration Committee
EXCO
Asset and Liability
Committee
Performance Committee
Audit and Risk Committee
R. Raphael & Sons plc Pillar 3 Disclosures 2015
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The ALCO normally meets each week although generally no separate meeting of the Committee will take
place in weeks when there is a meeting of either the EXCO or the Board. The Committee is made up of
the Executive Directors.
Performance Committee
The Performance Committee comprises the Executive Directors. It meets quarterly and its primary role
is to undertake detailed analysis of each of the Bank’s operating divisions including looking at actual
performance against budget, the adequacy of the resources available to each division and the likely
future performance taking in to account all relevant external and internal factors.
Board responsibility for risk management
A core objective for the Bank is the effective management of risk. The responsibility for identifying and
managing the principal risks ultimately rests with the Bank’s Board of Directors. The Board has ultimate
responsibility for setting the Bank’s strategy, risk appetite and control framework.
The Board considers that, at 28 February 2015, it had in place adequate systems and controls with
regard to the Bank’s profile and strategy.
4. Capital resources The Capital Resources of the Bank are calculated in accordance with Part 2 of CRR.
The capital resources at 28th February 2015 totalled £23,396k, made up of £23,346k tier 1 and £50k
tier 2. This is analysed as follows:
Capital resources
£k
Share capital 13,600
Share premium 900
Profit and loss account 9,210
23,710
Deductions:
Investments (227)
Deferred taxation (137)
Total tier 1 23,346
General provisions 50
Total tier 2 50
Total capital resources 23,396
R. Raphael & Sons plc Pillar 3 Disclosures 2015
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4.1 Adequacy of capital The Bank is required to maintain capital resources above the minimum required by the PRA, together
with a further internal buffer. In order to do this, the Bank needs to generate sufficient levels of profits
that will be retained and add to reserves.
4.2 Capital adequacy assessment process Complementing the Business Plan and as already referred to, the Bank undertakes an ICAAP, which aims
to ensure that the Bank’s capital resources are sufficient to deliver the Plan’s objectives, both in normal
and stressed conditions. The ICAAP is formally reviewed and updated at least annually.
This process involves reviewing all risks to which the Bank is exposed or potentially could be exposed
and making an assessment of capital required to mitigate the potential impact of those risks. Included
in this process is a detailed assessment of the results of the Bank’s stress models based on a number of
stressed economic scenarios. The key risk areas are detailed in section 2.
To help assess the ongoing adequacy of capital, the Bank has established an overall appetite for each of
the main risks to which it is exposed and established tolerances for each such risk, within which the
Bank is expected to operate. Furthermore each operating division of the Bank has its own more detailed
risk tolerances that are consistent with those established for the Bank overall. The use of divisional
tolerances is one of the important means by which risk is controlled throughout the Bank. The Bank’s
performance against these tolerances is monitored regularly at divisional level and reviewed at least
monthly by the EXCO and the Board.
4.3 Leverage Ratio The leverage ratio is defined as the ratio between the Tier 1 capital and the total on and off balance-
sheet exposure, without taking into account any risk weighting. Its objective is to reduce the risk of
excessive leverage.
The Bank calculates its Tier 1 Capital on the basis that will apply once CRD IV has been fully phased in. In
addition to the on-balance sheet assets, the leverage ratio also takes off balance-sheet exposure into
account. At 28 February 2015, the Bank reports a leverage ratio of 6.76%, as shown below.
£k
Capital:
Tier 1 Capital (fully phased in definition) 23,346
Exposure values:
Balance sheet assets 344,118
Off balance sheet assets 1,347
Regulatory adjustments – tier 1 fully phased in definition (364)
Total exposures 345,101
Leverage ratio 6.76%
R. Raphael & Sons plc Pillar 3 Disclosures 2015
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5. Risk weighted exposure amounts & minimum capital requirement The assets of the Bank are analysed by risk category and assigned weightings according to the level of
risk entailed. Credit risk weightings are determined by the ’Standardised Approach’ within the CRR with
the minimum capital required being 8% of the risk weighted amount. The following table shows the
minimum capital requirements at 28th February 2015.
Exposure
£k
Risk weight
%
Risk
weighted
assets
£k
Minimum
capital
required
£k
Government or central banks 114,544 0% 0 0
Other short-term securities 8,860 20% 1,772 142
Loans and advances to banks 133,074 20% 26,615 2,129
Loans and advances to customers 24,476 35%/75%/100% 18,326 1,466
Net amounts receivable under hire
purchase agreements and
finance leases
42,603 75% 31,952 2,556
- Exposures in default 57 100% 57 5
Fixed and other assets 20,504 0%/20%/100% 11,425 914
Off balance sheet exposures 1,347 100% 1,347 108
Total credit risk requirement 345,465 91,494 7,320
Operational risk capital requirement 1,855
Market risk capital requirement – foreign currency PRR 201
Total Pillar I capital requirement 9,376
R. Raphael & Sons plc Pillar 3 Disclosures 2015
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5.1 Credit risk and provisions The following table shows the residual maturities of all credit risk exposures at 28th February 2015.
Not more
than 3
months
£k
>3 months
and up to 1
year
£k
>1 year and
up to 5
years
£k
>5 years
£k
Total
£k
Government, central
banks, securities 81,606 41,798 - - 123,404
Loans and advances to
banks 133,074 - - - 133,074
Loans and advances to
customers 8,925 7,014 8,445 92 24,476
Net amounts receivable
under hire purchase
agreements and
finance leases
4,249 11,538 26,873 - 42,660
Other items 17,023 - 2,695 3,481 23,199
Total 244,877 60,350 38,013 3,573 346,813
Credit risk by geographical area is detailed below.
UK
£k
Other
£k
Total
£k
Government, central banks, securities 63,219 60,185 123,404
Loans and advances to banks 62,184 70,890 133,074
Loans and advances to customers 24,476 - 24,476
Net amounts receivable under hire purchase
agreements and finance leases 42,660 - 42,660
Other items 23,199 - 23,199
Total 215,738 131,075 346,813
R. Raphael & Sons plc Pillar 3 Disclosures 2015
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The table below provides analysis of the performing and past due loan exposures for loans and advances
to customers and net amounts receivable under hire purchase agreements and finance leases. Amounts
shown relate to the overall loan balance, not the amount of arrears.
Loans and
advances to
customers
£k
Hire purchase
agreements
and finance
leases
£k
Specific
provisions
£k
Performing loans 24,476 41,734 -
1 to 3 months past due - 1,142 274
3 to 6 months past due - 248 191
6 months + past due - 406 405
At 28 February 2015 24,476 43,530 870
Provisions
The Bank will make specific and general provisions for losses based on an appraisal of the expected
recoveries on loans and other advances. Specific provisions are made in respect of loans and other
assets that are in arrears, together with the Directors’ appraisal of individual loans where appropriate.
General provisions are made where it is considered that there is impairment in the value of assets at the
year-end that is not already covered by specific provisions.
Loans, advances and other receivables are written down to estimated realisable value when there is no
realistic prospect of recovery.
Amounts charged in the profit and loss account represent losses written off in the accounting year,
together with the net change in provisions. Interest in respect of all loans is credited to the income and
expenditure account as it becomes receivable. Irrecoverable interest is written off against interest
receivable.
Further details relating to the above can be found in the 2015 Annual Report and Financial Statements.
The table below summarises movements in provisions in the financial year.
General
£k
Specific
£k
Total
£k
At 28 February 2014 50 1,131 1,181
Charge for the period - 248 248
Utilised in the period - (509) (509)
At 28 February 2015 50 870 920
R. Raphael & Sons plc Pillar 3 Disclosures 2015
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Counterparty credit risk
The selection of counterparties and the approval of limits involve consideration of ratings assigned by
the major Credit Rating Agencies and any other background information or other market intelligence
available. The ALCO reviews counterparty limits quarterly and recommends changes to such limits as
necessary. At least annually, the Audit and Risk Committee review and approve the counterparty credit
limits. The overall Policy governing the limit structure for counterparties is set out in the Large Exposure
Policy and Liquidity Policy, both of which are reviewed and approved annually by the Board.
In order to qualify as an acceptable counterparty, the institution or sovereign risk must have a minimum
Tier 1 capital of £500 million (or equivalent in currency) and must have a rating from one or more of the
rating agencies listed below. Other unrated counterparties may be added if specific approval is granted
by ALCO.
Short-Term Rating Required
Moody’s P1, P2 or P3
Standard & Poors A1+, A1, A2 or A3
Fitch F1+, F1, F2 or F3
Limits may be temporarily suspended by ALCO in the event of adverse market intelligence. No
transactions can be undertaken with counterparties which do not have a pre-approved limit. Where
appropriate, exposure to counterparties is also monitored on a consolidated basis. The maximum
exposure to any individual counterparty is limited to the Bank’s total capital.
The table below shows the breakdown of counterparty exposures, credit assessments and risk weights
at 28th February 2015. Ratings quoted are according to Moody’s.
Exposure
£k
Credit
quality
assessment
step
Risk weight
for short
term
exposures
Government and central bank 114,544 1 0%
Short term securities 8,860 1 20%
Institutions (Aaa to Aa3) 30,385 1 20%
Institutions (A1 to A3) 90,785 2 20%
Institutions (Baa1 to Baa3) 11,904 3 20%
Total credit risk requirement 256,478
5.2 Operational risk Operational risk is calculated under the ‘Basic Indicator Approach’ as set out in the CRR and is therefore
calculated as 15% of the Bank’s average net income over the previous three years as detailed in the
table below.
R. Raphael & Sons plc Pillar 3 Disclosures 2015
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2013
£k
2014
£k
2015
£k
Interest receivable and similar income 5,169 7,074 8,789
Interest payable and similar charges (1,611) (1,759) (2,231)
Commissions and fees receivable 6,900 7,652 11,715
Commissions and fees payable (9,448) (11,253) (12,158)
Other operating income 8,498 9,405 10,360
Total 9,508 11,118 16,475
Basic Indicator (3 year average) 12,367
Capital Requirement (15%) 1,855
5.3 Interest rate risk The interest rate gap report covers all assets and liability interest rate mismatches, including a sensitivity
scenario showing the impact of a 2% parallel shift of interest rates on the net present value of the net
gap between asset and liability cash flows, as detailed below.
NPV
Change to
interest rate
Net gap 23,724
NPV sensitivity to + 2% interest rate shift 22,570 (1,154)
NPV sensitivity to - 2% interest rate shift 24,978 1,254
6. Remuneration policy and practices The policy and level of remuneration is determined by the Bank’s Remuneration Committee noted in
Section 3 above.
Non-executive Directors’ remuneration
The CEO recommends the level of remuneration paid to Non-executive Directors based on external data
from financial institutions of a similar size and complexity. Non-executive Directors are only entitled to
fees and do not receive salary, bonus incentives, pensions or other taxable benefits.
Executive Directors’ remuneration
The level of Executive Directors remuneration is comparable within the industry taking account of the
specific role performed. The remuneration is made up of basic salary, discretionary bonus, pension
contributions and private health care.
R. Raphael & Sons plc Pillar 3 Disclosures 2015
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Basic salary
The basic salary for Executive Directors takes into account market forces, responsibility and individual
performance.
Discretionary bonus All bonuses are paid on a discretionary basis and are subject to the approval of the Remuneration
Committee.
Pension benefit
A money purchase scheme is operated by the Bank and contributions are made for all qualifying staff.
There is also a death in service scheme which pays a lump sum equal to twice basic salary.
Other benefits
The Bank provided healthcare cover for Executive Directors and all managers during the year.
Contracts of employment
No Executive Director or member of the senior management team has an employment contract with a
notice period longer than one year in line with recommendations made in the UK Corporate Governance
Code.
Board diversity
The Bank is committed to diversity and works hard to ensure that all staff are offered equal
opportunities throughout their career with the Bank. The organisation is determined that nobody is
discriminated against, directly or indirectly, on the basis of age, ethnic or national origin, religion or
beliefs, sexual orientation, gender, marital status or disability. This commitment applies equally to
members of the Board. All Board appointments are made on merit, in the context of the skills,
experience, independence and knowledge which the Board as a whole requires to be effective.
Code staff
Code staff are defined by the Regulators as “staff that have a material impact on the firm’s risk profile”;
this includes staff that perform significant influence functions, senior managers and risk takers.
The table below sets out the aggregate quantitative remuneration for code staff in relation to their
services for the Bank for the year ended 28th February 2015:
Fixed
remuneration
£
Variable
remuneration
£
Total
remuneration
£
Deferred
variable
remuneration
£
Senior Management 884,203 445,640 1,329,843 322,430
Other Staff 160,847 20,000 180,847 -
Non-executive Directors 83,000 - 83,000 -
R. Raphael & Sons plc Pillar 3 Disclosures 2015
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7. Article 89 disclosure Article 89 of CRD IV requires credit institutions and investment firms in the EU to disclose annually,
specifying by Member State and by third country in which it has an establishment, the following
information for the year ended 28 February 2015:
R. Raphael & Sons Plc:
Type of Entity Nature of
activity Location
Turnover
(£k)
Profit or
loss before
tax (£k)
Corporation
tax paid (£k) Number of
employees
Credit
Institution
Financial
Services
United
Kingdom
22,552 2,039 299 100
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