CRR Case Summaries and Entity-specific Press Notices
The FRC publishes, on a quarterly basis, summaries of its findings from recently closed reviews that resulted in a substantive question to a company (‘Case Summaries’). In addition, it publishes the names of companies whose reviews were closed in the previous quarter without the need for a substantive question. No Case Summary is prepared for such reviews.
Case Summaries, which are available for cases closed in the quarter ending March 2021 onwards, are included in the table below. As, currently, the FRC is subject to existing legal restrictions on disclosing confidential information received from a company, the Case Summaries can only be disclosed with the company's consent. Where consent has been withheld by the company, that fact is disclosed in the table.
From March 2018 until March 2021, the FRC published the names of companies whose reviews were closed in the previous quarter but did not prepare Case Summaries. However, on an exceptional basis, specific cases may be publicised through entity-specific Press Notices, which can also be found in the table below.
The FRC’s reviews are based solely on the company’s annual report and accounts (or interim reports) and do not benefit from detailed knowledge of the company’s business or an understanding of the underlying transactions entered into. They are, however, conducted by staff of the FRC who have an understanding of the relevant legal and accounting framework. The FRC’s correspondence with the company provides no assurance that the annual report and accounts (or interim reports) are correct in all material respects; the FRC’s role is not to verify the information provided but to consider compliance with reporting requirements. The FRC’s correspondence is written on the basis that the FRC (which includes the FRC’s officers, employees and agents) accepts no liability for reliance on its letters or Case Summaries by the company or any third party, including but not limited to investors and shareholders.
Key
- Only a certain number of CRR’s reviews result in substantive questioning of the Board. Matters raised may cover questions of recognition, measurement and/or disclosure.
- CRR’s routine reviews of companies’ annual reports and accounts generally cover all parts over which the FRC has statutory powers (that is, strategic reports, directors’ reports and financial statements). Similarly, CRR’s routine reviews of companies’ interim reports will generally cover all information in that document. Limited scope reviews arise for a number of reasons, including those conducted when a company’s annual report and accounts or interim report are selected for thematic review or reviews that have been prompted by a complaint. In accordance with the FRC's Operating Procedures, for Corporate Reporting Review, CRR does not identify those companies whose reviews were prompted by a complaint.
- The FRC may ask a company to refer to its exchanges with CRR when the company makes a change to a significant aspect of its annual report and accounts or interim report in response to a review.
- Case closed after 1 January 2021 but performed under operating procedures that did not allow for the publication of Case Summaries.
- From the quarter ended June 2023, the FRC started identifying the auditor of the annual report and accounts, or the audit firm that issued a review report on the interim report, that was the subject of the CRR review. This information was also back-dated for closed cases publicised from the quarter ended September 2022. Cases marked N/A relate to those published prior to September 2022 or interim reviews that did not have a review opinion.’
Case Summaries
CRR Case Summaries and Entity-specific Press Notices (Excel version)
| Entity | Tessuti Ltd |
|---|---|
| Balance Sheet Date | 29 January 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Limited |
| Quarter Published | December 2023 |
| Auditor (5) | KPMG LLP |
| Case Summary / Press Notice | Consent withheld |
| Entity | TP ICAP Group Plc |
| Balance Sheet Date | 31 December 2022 |
| Exchange of Substantive Letters (1) | No |
| Scope of Review (2) | Full |
| Quarter Published | December 2023 |
| Auditor (5) | Deloitte LLP |
| Case Summary / Press Notice | N/A |
| Entity | Warpaint London PLC |
| Balance Sheet Date | 31 December 2022 |
| Exchange of Substantive Letters (1) | No |
| Scope of Review (2) | Full |
| Quarter Published | December 2023 |
| Auditor (5) | BDO LLP |
| Case Summary / Press Notice | N/A |
| Entity | WILLOUGHBY'S CONSOLIDATED PLC |
| Balance Sheet Date | 30 September 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Limited |
| Quarter Published | December 2023 |
| Auditor (5) | Lohur & Co Ltd |
| Case Summary / Press Notice | Consent withheld |
| Entity | Witan Investment Trust plc |
| Balance Sheet Date | 31 December 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | December 2023 |
| Auditor (5) | Grant Thornton UK LLP |
| Case Summary / Press Notice |
We asked the company to explain the basis on which it determined that the Strategic Report contained a fair review of its business, including a balanced and comprehensive analysis of its development and performance during the financial year and its position at the end of that year, as required by the Companies Act 2006. We asked for this explanation as we were unable to locate any IFRS measures in the Strategic Report. The company explained that, as a closed-end investment company, its users need information in addition to that provided by IFRS measures. It agreed to include references to relevant IFRS measures in future Strategic Reports. |
| Entity | AstraZeneca Plc |
| Balance Sheet Date | 31 December 2022 |
| Exchange of Substantive Letters (1) | No |
| Scope of Review (2) | Full |
| Quarter Published | September 2023 |
| Auditor (5) | PricewaterhouseCoopers LLP |
| Case Summary / Press Notice | N/A |
| Entity | Bakkavor Group plc |
| Balance Sheet Date | 31 December 2023 |
| Exchange of Substantive Letters (1) | No |
| Scope of Review (2) | Full |
| Quarter Published | September 2023 |
| Auditor (5) | PricewaterhouseCoopers LLP |
| Case Summary / Press Notice | N/A |
| Entity | Baltic Classifieds Group PLC (3) |
| Balance Sheet Date | 30 April 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2023 |
| Auditor (5) | KPMG LLP |
| Case Summary / Press Notice |
Income tax We asked the company to explain why the reversal of a temporary difference was included as a reconciling item in the reconciliation of pre-tax profit to the tax expense for the year. The company explained that it related to the reversal of a deferred tax liability which had been initially recognised in relation to upfront commission fees incurred on long term borrowings. The company reviewed the historical accounting of the deferred tax liability and acknowledged that it should have been released in 2021, rather than in 2022. The company agreed to restate opening reserves as of 1 May 2021, the comparative consolidated statement of profit and loss and other comprehensive income and the comparative tax rate reconciliation in its next annual report and accounts. As the change affected the primary statements, we asked the company to disclose the fact that the matter had come to its attention as a result of our enquiry. We questioned the basis on which the directors considered the standard UK tax rate to be the most meaningful rate to use in the tax rate reconciliation as the group’s business operates from the Baltic region. The company confirmed that it had reassessed the use of the standard UK rate and agreed to use a blended rate in future annual reports and accounts. |
| Entity | Carr's Group plc |
| Balance Sheet Date | 3 September 2022 |
| Exchange of Substantive Letters (1) | No |
| Scope of Review (2) | Full |
| Quarter Published | September 2023 |
| Auditor (5) | Grant Thornton UK LLP |
| Case Summary / Press Notice | N/A |
| Entity | CMS Cameron McKenna Nabarro Olswang LLP |
| Balance Sheet Date | 30 April 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2023 |
| Auditor (5) | PricewaterhouseCoopers LLP |
| Case Summary / Press Notice |
Provisions We asked the LLP to explain why costs associated with settling claims for alleged negligence that are considered likely to succeed are recognised net of the related insurance receivable. The LLP explained that, although this presentation did not comply with FRS 102, it considers insurance receivables to be immaterial currently and agreed to clarify its accounting policies and disclosures in this area. The LLP undertook to present insurance reimbursement assets separately should they become material. Retirement benefit asset We sought an explanation for the basis on which the recognised retirement benefit surplus was recoverable. The LLP provided a satisfactory explanation and agreed to disclose why the pension surplus is recoverable in its next annual accounts. Annuities We asked the LLP to clarify the accounting policy applied to annuities to current and former members. The LLP explained that annuities to former members should have been accounted for as financial liabilities rather than provisions but that they consider such balances to be immaterial. The LLP stated that there were no annuities payable to current members and agreed to clarify its accounting policies in this respect. |
| Entity | Crest Nicholson Holdings plc |
| Balance Sheet Date | 31 October 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2023 |
| Auditor (5) | PricewaterhouseCoopers LLP |
| Case Summary / Press Notice |
Inventories The company disclosed that land options were written down on a straight-line basis over the life of the option. We sought an explanation for this treatment, as it would indicate that the expected future economic benefits resulting from the land options gradually diminish regardless of the expected outcome. The company explained that accounting for the land options at cost less impairment would not result in a material difference. On this basis, we did not consider it proportionate to pursue the matter further. We also questioned whether the company considered further disaggregation of the inventory balance to separately disclose the carrying value of land. The company agreed to provide such disaggregation. Due to the implementation of a new ERP system, the company expects this to be disclosed in its 2024 report and accounts with comparatives for 2023. |
| Entity | CRH plc |
| Balance Sheet Date | 31 December 2021 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Limited |
| Quarter Published | September 2023 |
| Auditor (5) | Deloitte Ireland LLP |
| Case Summary / Press Notice |
Impairment testing of goodwill We asked the company to explain certain aspects of its impairment testing methodology relating to the inclusion of forecast capital expenditure associated with achieving 2025 carbon reduction targets in its value in use calculations, and the basis for forecasting cash flows for a period exceeding five years. We also asked the company for an explanation of how climate change had been incorporated in the impairment testing methodology and assumptions. The company explained that forecast capital expenditure included in impairment testing relating to achieving 2025 carbon reduction targets did not represent enhancement expenditure, as it maintained current performance rather than increasing capacity, and that it was, therefore, appropriate to include this expenditure and the resulting cash flows in its value in use calculations. The company enhanced the disclosures in its 2022 annual report and accounts to make this clear. The company also explained the circumstances in which it may use a period of longer than five years for cash flow forecasting purposes in impairment testing, and that it had not made any adjustments to cash flows beyond the five year strategic plan horizon under this approach in 2021. It updated the disclosures associated with this policy. The company satisfactorily explained how climate-related risks, including the risk of increased future carbon costs, had been incorporated into the value in use assessments used in its impairment testing of goodwill. The company enhanced these disclosures in its 2022 annual report and accounts by disclosing the assumptions applied in respect of future carbon costs, including the anticipated ability to recover increased carbon costs through pricing, as well as the impact of applying carbon cost assumptions from a Paris-aligned global warming scenario on these value in use assessments. The company also included detailed considerations of climate risk in the context of its accounting for property, plant and equipment. We closed our enquiries on the basis of these helpful additional disclosures. |
| Entity | Croda International Plc |
| Balance Sheet Date | 31 December 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2023 |
| Auditor (5) | KPMG LLP |
| Case Summary / Press Notice |
UK defined benefit pension scheme asset We asked the company to clarify whether the UK defined benefit pension scheme was open to future accrual and how the company expects to recover the scheme surplus through reduced future contributions. The company confirmed that the UK scheme remains open to new members and future service accrual, clarifying that the surplus can be recovered through a reduction in future service contributions. The company agreed to update its disclosures to make it clearer that the UK scheme remains open to future accrual and to new members. |
| Entity | Deliveroo plc |
| Balance Sheet Date | 31 December 2022 |
| Exchange of Substantive Letters (1) | No |
| Scope of Review (2) | Full |
| Quarter Published | September 2023 |
| Auditor (5) | Deloitte LLP |
| Case Summary / Press Notice | N/A |
| Entity | Deloitte LLP |
| Balance Sheet Date | 31 May 2022 |
| Exchange of Substantive Letters (1) | Yes |
| Scope of Review (2) | Full |
| Quarter Published | September 2023 |
| Auditor (5) | BDO LLP |
| Case Summary / Press Notice |
Former and current members’ annuities We requested further information about the possible impact on the LLP’s future accounts of applying IFRS 17 to the accounting for former and current members’ annuities. The LLP explained that it is analysing the impact of adopting the standard and will disclose the possible impact in its May 2023 accounts. We queried whether the provision for member annuities is sensitive to changes in the mortality assumption. The LLP confirmed that it is not and that it will update the wording of the accounting policy for member annuities in its May 2023 accounts. |