Notes: 1. Includes Direct Line, Churchill, Privilege, Darwin and partner brands: RBS, NatWest, © Ipsos MORI Financial
Brexit We prepared for the possibility of a disruptive Brexit. As is well known, following the Government winning a significant House of Commons majority in the December 2019 general election, the UK left the EU on 31 January (“Brexit”) with “a deal”, so that essentially there have been no substantive changes in practice to the trading and other arrangements between the UK and the EU, at least during the “implementation period” which is due to last until 31 December 2020, unless extended. Nonetheless, the terms, if any, of any future trading relationship between the UK and the EU, and between the UK and other key countries, are not yet known and there remains uncertainty and at least the possibility of a disruptive end to the implementation period.
Note: 1. See glossary on pages 222 to 224 for definitions and appendix A – Alternative performance measures on pages 225 to 228 for reconciliation to financial statement line items.
2. In-force policies, including direct own brands, as at 31 December 2018 have been restated to included 41,000 policies omitted from the previously reported amounts.
3. A reduction in the ratio represents an improvement as a proportion of net earned premium, while an increase in the ratio represents a deterioration. See glossary on pages 222 to 224 for definitions.
2. Results for the period ended 31 December 2018 have been restated to reflect the fully retrospective adoption of IFRS 16 ‘Leases’. See note 44 to the consolidated financial statements.
Instalment income 114.0 119.9 Other operating income: Revenue from vehicle recovery and repair services1 7 28.3 25.1 Vehicle referral income 7 19.1 17.2 Legal services income 7 11.3 11.2
Other operating income 7 66.2 72.1 Total instalment and other operating income 180.2 192.0
Staff costs2 261.5 269.9 IT and other operating expenses2,3 158.0 167.6
Restructuring and one-off costs (11.2) – Operating profit after restructuring and one-off costs 535.7 –
Return on tangible equity decreased to 20.8% (2018 restated: 21.6%) due primarily to a £46.9 million decrease in adjusted2 profit after tax to £408.5 million (2018 restated: £455.4 million). Profit after tax in 2019 was adjusted for restructuring and one-off costs. Profit after tax in both 2019 and 2018 was adjusted for coupon payments in respect of Tier 1 notes. Notes: 1. Results for the period ended 31 December 2018 have been restated to reflect the fully retrospective adoption of IFRS 16 ‘Leases’. See note 44 to the consolidated financial statements.
Basic earnings per share decreased by 11.4% to 29.5 pence (2018 restated: 33.3 pence). Diluted earnings per share decreased by 11.2% to 29.2 pence (2018 restated: 32.9 pence) mainly reflecting the reduction in profit after tax. Note: 1. Results for the period ended 31 December 2018 have been restated to reflect the fully retrospective adoption of IFRS 16 ‘Leases’. See note 44 to the consolidated financial statements.
In 2019, the Group generated £0.66 billion of Solvency II capital offset by £0.19 billion of capital expenditure and capital distribution of £0.45 billion for the 2019 dividend and share buyback. The increased capital expenditure
Financial debt – subordinated debt 259.0 259.5 Total capital employed 3,249.1 3,164.2 Financial-leverage ratio2 18.6% 19.2%
– New motor insurance platform launched for Privilege new business across all distribution channels including price comparison websites. We also became the first major insurer to partner with Starling Bank, using their accessible marketplace to offer Churchill home insurance.
Home’s combined operating ratio improvement was by 13.2 percentage points to 80.3% (2018 restated: 93.5%). This was driven primarily by a 9.2 percentage point improvement in claims relating to severe weather events, as 2019 had relatively benign weather and a 2.3 percentage point increase in prior-year releases due to favourable development on escape of water claims. Normalised for weather, the combined operating ratio was 4.7 percentage points better than 2018 at 86.9%2 (2018 restated: 91.6%). Notes: 1. Average incepted written premium excluding IPT for Home own brands for year ended 31 December 2019.
A – Alternative performance measures on pages 225 to 228 for reconciliation.
Loss ratio 66.9% 66.8% Commission ratio 6.4% 4.6% Expense ratio 22.1% 23.6% Combined operating ratio 95.4% 95.0% Operating profit £39.1m £44.0m
36% of claims are for cancellation of a journey which can often be a stressful situation. We want to make it quick and painless by enabling customers to register their cancellation claim on the portal and easily upload any documents. We’ll be able to tell them via email about the progress of their claim and pay them through BACS simply and efficiently.
In addition, the Coronavirus outbreak (specifically the disease COVID-19) has the potential to impact the 2020 result of our Travel business. We have currently incurred claims of around £1 million, the majority for customer trips to regions where the Foreign & Commonwealth Office (“FCO”) advise against all but essential travel. We ask customers to seek refunds or amendments to their trip from their travel provider in the first instance in line with FCO guidance. We have Travel reinsurance protection to mitigate the cost of an event over a 28 day period to £1 million up to a limit of £10 million. The full coverage, if utilised, can be reinstated once on the same terms.
Overview The Commercial broker market continued to consolidate in 2019. Customers continued to seek cover in the direct market that was flexibly tailored to their individual needs and demonstrated knowledge of their trades. Against this backdrop, Commercial maintained underwriting discipline and grew its policy count. Commercial’s current-year attritional loss ratio improved by 1.2 percentage points supported by pricing and underwriting initiatives.
A key aspect of any effective Strategic Planning Process is to understand and manage those risks appropriately. To achieve this, the Risk Function works closely with the business to help it to identify and assess risks, which is done through setting and achieving targets as well as through its review and challenge of business plans in the Strategic Planning Process.
If there is a smooth end to the implementation period with an agreed future trading agreement between the UK and the EU (and other key countries), and accordingly without significant disruption to the UK economy and to business generally, then any adverse impact on the Group (if any) would also not be expected to be significant. If, however, trade discussions (or the failure of them) were to lead to significant disruption then the impact on the Group could correspondingly also be disruptive and potentially material.
– Our business depends on the strength of its brands and its reputation with customers and distributors. As consumers become more aware and educated about climate change and environmental issues, research shows that they are putting their faith in brands that take their corporate responsibility seriously.
In addition to the above risks, the impacts of potential physical, transition and liability risks arising in the wider economy can also have an indirect impact on the investment portfolio through their influence on the value of assets. Our largest asset portfolios are focused on corporate bonds. During 2018, we approved a significant new investment initiative which incorporates a greater focus on indices weighted by environmental, social and governance factors, which tilt the composition of the portfolio towards higher holdings and weightings of issuers with strong environmental, social and governance scores.
We sought views from the business as well as a range of external stakeholders including customers, suppliers, investors, commercial partners, non-governmental organisations and policymakers that the business interacts with. Using in-depth interviews and surveys, we asked a series of questions around perceptions of responsible business, expectations including the most strategically important sustainability issues for the Group and future trends.
Customers Earn our customers’ trust by demonstrating how we are acting in their best interests.
– All our products are regularly reviewed to ensure that we continue to deliver value to all customers.
“Our mental health first aider programme has made it acceptable to talk about personal issues and made such a difference culturally. Because it matters to the business our mental health first aiders prioritise giving people support.” – Alan Bint Conduct Regulatory Risk manager
We are always looking for new commercial opportunities where changing consumer trends and expectations are altering the way markets work.
The Board oversees all of the Group’s ESG activity. It has delegated particular aspects of this supervision to its Committees.
The Board endorses the UK Corporate Governance Code 2018 (the “Code”), which applied to our 2019 financial year, and the related Guidance on Board Effectiveness. We seek to ensure that our governance framework remains aligned with best practice, consistent with the Code. During the year, the Nomination Committee changed its name to the Nomination and Governance Committee and is now responsible for monitoring governance matters throughout the Group. You can find information on the work of the Nomination and Governance Committee on pages 100 and 101.
Biography Mike is Chairman of the Nomination and Governance Committee. The Board benefits from his extensive experience as a Director and Chairman in the insurance industry, which makes him well suited to the role of Chairman, enabling him to lead the Board and ensure its effectiveness.
Current external appointments Mike also serves as Chairman of Close Brothers Group plc and its regulated bank, Close Brothers Limited.
Current external appointments Mark is CEO of Merian Global Investors (UK) Limited.
Current external appointments Jane is a NED of William Hill plc and Chair of Reclaim Fund Ltd. She is an Independent Member of the Fairness Committee at ReAssure Ltd. Jane is the Honorary Treasurer and a Trustee of the Disasters Emergency Committee and has her own financial sector consulting business.
Chairman Mike Biggs 9 of 9 – – – – 5 of 5 4 of 4 Senior Independent Director Richard Ward 8 of 92 – 5 of 5 – – 5 of 5 – Non-Executive Directors Danuta Gray 9 of 9 – – – – 5 of 5 4 of 4 Mark Gregory 9 of 9 5 of 5 – – 4 of 4 – 2 of 2 Jane Hanson 9 of 9 5 of 5 5 of 5 3 of 3 4 of 4 – – Sebastian James 9 of 9 – – 3 of 3 – – 4 of 4 Fiona McBain 5 of 5 3 of 3 1 of 1 – – – – Gregor Stewart 9 of 9 5 of 5 5 of 5 – – – – Clare Thompson 4 of 4 1 of 22 – – – – 2 of 2 Executive Directors Paul Geddes 4 of 4 – – 0 of 12 – – – Penny James 9 of 9 – – 2 of 2 4 of 4 – – Mike HollidayWilliams 5 of 5 – – – – – – Tim Harris 2 of 2 – – – – – – Executive Committee Member Simon Linares – – – 3 of 3 – – –
– Reviews and approves various formal reporting requirements and promotes a risk aware culture within the Group
Approach to diversity and inclusion The Board and executive management are committed to ensuring that diversity is promoted across all areas of the Group and that everyone is treated fairly, irrespective of their racial or ethnic origin, gender, age, disability, belief or sexual orientation, religion, or educational or professional background. There is a Board-approved diversity policy and progress has been made in embedding principles and practices to promote diversity across the Group and to champion the benefits of a diverse and inclusive workforce.
Our Planet We are aware that vital action is needed to address climate change. Our ‘Reduce, Reuse, Recycle’ strategy guides the Group in meeting our objectives to reduce the Group’s environmental impact.
Matters Reserved to the Board and Board Committees’ Terms of Reference
The Board Risk Committee approves the risk management framework and the policy risk appetite statements, following review by the Risk Management Committee (a committee comprised of executives).
The Board has delegated responsibility to the Audit Committee to oversee the management of the relationship with the Company’s External Auditor. You can find details of the Audit Committee’s role, activities and relationship with the External Auditor in the Committee report which starts on page 93.
The Committee reviewed the adoption of IFRS 16 ‘Leases’ in the Group’s Half Year Report and the Annual Report & Accounts. IFRS 16 has been adopted on a fully retrospective basis. The Committee reviewed and challenged the methodology adopted to recognise and value right-of-use assets and lease liabilities and the disclosure in the Group’s financial statements. The Committee was satisfied that the new accounting standard had been properly adopted and the effect of the transition on the Group’s financial statements had been disclosed in accordance with IAS 8 ‘Accounting Policies, Changes in Accounting Estimates and Errors’, where a new accounting policy has been applied retrospectively. The Committee also considered the impact of IFRS 16 on the Group’s Solvency II balance sheet.
Audit-related assurance services were in respect of the Group’s Solvency II reporting; other assurance services were for the review of the Half Year Report 2019; and non-audit services related to assurance activities on IT projects in relation to the development of new systems where Deloitte were chosen to provide the non-audit services because of their expertise and insight in this area. The Committee determined that the services provided would not impact the independence of the external auditor. Further information in respect of audit fees paid to Deloitte is disclosed in note 10 to the consolidated financial statements.
Compliance and regulatory risk During the year, the Committee considered the Group’s compliance with regulatory requirements including conduct and financial crime. The Committee approved the annual Compliance Plan which sets out the compliance activities which will be undertaken in the coming year with the objectives of: (i) ensuring compliance; (ii) maintaining an open and co-operative relationship with regulators; and (iii) ensuring the Board and colleagues understand their regulatory responsibilities. The Committee also reviewed and challenged the outputs from conduct and compliance assurance reviews, including in relation to Solvency II compliance.
The Committee reviewed and challenged the stress and scenario testing plan prioritising the importance of certain potential scenarios including in relation to the potential impacts of a hard Brexit and a change in government following a general election. The Committee also examined the outputs of the budget stress tests and the associated management actions, which where necessary, would be required to keep the Group within capital risk appetite.
The Committee received updates on the Group’s overall diversity and inclusion commitments and reviewed and challenged the diversity and inclusion priorities and targets for 2020 in respect of each function in the organisation. The Committee was delighted to see that the Group had achieved its target to increase female senior management to 30% by the end of 2019.
Additional ethical matters The Committee recognises that respecting human rights is self-evidently the right thing to do and is committed to ensuring that the Group conducts its business in a manner which is ethical and responsible.
Consistent with the regulations, as the performance period of the TSR elements run for three years from grant (whereas the RoTE performance period is aligned with the financial year-end), the TSR element of the 2017 awards, due to vest during 2020, will be reported separately next year. Accordingly, we have included an estimated value of the RoTE vesting outcomes for the 2017’s awards plus the TSR vestings from the 2016 awards in the single figure remuneration table for 2019 for the Executive Directors.
The Committee believes that the 2019 remuneration outcomes appropriately reflect the
AIP achievement This chart illustrates the actual amounts earned from the AIP and reflecting performance in 2019. 60% of the amount is payable in March 2020 and 40% will be deferred into shares for three years.
– Reviewed annually with any increases taking effect on 1 April
Introduction We have prepared this report in accordance with the requirements of the Companies Act 2006 and the Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations 2008 (as amended) (the “Regulations”). The report also meets the relevant requirements of the Listing Rules of the FCA and describes how the Board has complied with the principles and provisions of the Code relating to remuneration matters. Remuneration tables subject to audit in accordance with the relevant statutory requirements are contained in this report and stated to be audited. Unless otherwise stated, the information within the Directors’ Remuneration Report is unaudited.
The formulaic outcome from 2019 performance against the financial measure was 69%, giving a total of 38% out of 55% attributable to this element. A summary of the assessment is provided in the following table.
– We launched a number of other customer systems, for example: – Darwin motor; our first new personal lines brand in 25 years. Darwin is focused on the Price Comparison Website (“PCW”) market and utilises a new technology platform that combines customer serve functionality with a data-led pricing engine employing machine learning techniques. Darwin was launched on two PCW during the year.
Notes: 1. This information includes holdings of any connected persons, as defined in section 253 Companies Act 2006. 2. Clare Thompson stepped down from the Board on 9 May 2019 and this represents her holding at that date.
The UK employees included are those employed on 31 December 2019 and remuneration figures are determined with reference to the financial year ending on 31 December 2019.
3. For employees other than the CEO, this includes average amounts earned under the AIP, and other variable incentive schemes, including monthly and quarterly incentive schemes operated in certain parts of the Group.
2. The 2016 single figure and annual bonus payment reflect an adjustment, made in 2019, to the original award of 20% of maximum opportunity related to the Ogden discount rate change.
DAIP awards granted during 2019 (Audited) The table below shows the deferred share awards granted under the DAIP to Executive Directors on 29 March 2019 in respect of the 2018 AIP and the Ogden adjustment in respect of the 2016 AIP (as disclosed in the 2018 Directors’ Remuneration Report). Awards will vest after three years subject to continued service and were granted in the form of nil cost options.
– Awards of up to 300% of base salary are permitted in exceptional circumstances, relating to recruiting or retaining an employee, as determined by the Committee
– The Committee will determine the performance conditions for each award made under the LTIP, measuring performance over a period of at least three years with no provision to retest
As set out in the policy implementation table on page 111, different performance measures may apply for awards granted in future years.
– They do not participate in the Group’s bonus, employee share plans or pension arrangements, and do not receive any employee benefits
Termination policy It is appropriate for the Committee to retain discretion to consider the termination terms of any Executive Director, having regard to all the relevant facts and circumstances available to them at the time. A Director is deemed a ‘good’ leaver if the following circumstances are met: – AIP and LTIP – death, injury, disability, ill-health, redundancy, retirement, the sale of the individual’s employing company or business out of the Group, or in such other circumstances as the Committee determines
The table below sets out the general position. However, it should be noted that the Committee, consistent with most other companies, has reserved a broad discretion to determine whether an Executive Director should be categorised as a ‘good’ leaver, and that discretion forms part of the approved policy.
External directorships The Company encourages Executive Directors to accept, subject to the Chairman’s approval, an invitation to join the board of another company outside the Group in a non-executive capacity, recognising the value of such wider experience. In these circumstances, they are permitted to retain any remuneration from the non-executive appointment. Executive Directors are generally limited to accepting one external directorship but may accept more with the Chairman’s prior approval.
Corporate governance statement The FCA’s Disclosure Guidance and Transparency Rules require a corporate governance statement in the Directors’ report to include certain information. You can find information that fulfils the corporate governance statement’s requirements in this Directors’ report; the Corporate Governance report; the Committee reports; and the Directors’ remuneration report, on pages 74 to 138, all of which is incorporated in the Directors’ report by reference.
You can find further details regarding dividends paid during 2018 and 2019; in the Finance review on page 29 and in note 14 to the consolidated financial statements on page 188. You can also find information on dividend and capital management, including the share buyback programme in the Finance review on pages 35 to 37.
2. Basis for opinion We conducted our audit in accordance with International Standards on Auditing (UK) (ISAs (UK)) and applicable law. Our responsibilities under those standards are further described in the auditor’s responsibilities for the audit of the financial statements section of our report.
AUDIT REPORT V5.2 WWW.DIRECTLINEGROUP.CO.UK 145 4. Conclusions relating to going concern, principal risk and viability statements 4.1 Going concern
liabilities; and – The consistency of the approach with that used in the 2018 year-end valuation and the appropriateness of maintaining that approach in light of the current economic climate and market benchmarking against industry peers.
Materiality was determined as approximately 5.3% (2018: 5.2%) of three-year average profit before tax, excluding the impact of the Ogden rate discount change on yearend results.
Consistent with the prior period, this resulted in two entities being subject to a full scope audit and a further two were subject to an audit of specified account balances where the extent of our testing was based on our assessment of the risks of material misstatement and of the materiality of the Group’s operations. All entities within scope of the Group audit are based in the UK.
Instalment income 114.0 119.9 Other operating income 7 66.2 72.1 Total income 3,299.7 3,436.1 Insurance claims (1,917.3) (1,966.2) Insurance claims recoverable from reinsurers 69.7 55.1 Net insurance claims 8 (1,847.6) (1,911.1)
IFRIC 23 ‘Uncertainty over Income Tax Treatments’ provides interpretation when there is uncertainty over income tax treatments under IAS 12 ‘Income Taxes’.
WWW.DIRECTLINEGROUP.CO.UK 165 1.20 Share-based payment The Group operates a number of share-based compensation plans under which it awards Ordinary Shares and share options to its employees. Such awards are generally subject to vesting conditions that vary the amount of cash or shares to which an employee is entitled.
When first published, Amendments to IFRS 4 required insurance entities to evaluate whether their activities were predominantly connected to insurance as at its annual reporting date immediately preceding 1 April 2016, providing an option to defer adoption of IFRS 9 if liabilities connected to insurance comprised a predominant proportion of its total liabilities as at that date. The Group concluded that it satisfied the criteria and there have been no significant changes in the Group’s activities since this assessment to require a reassessment of the criteria.
Accounting judgement Judgement is applied to determine whether there is indication of impairment to intangible assets. In making this judgement, the Group considers: the projection of the economic benefits associated with each asset; subsequent remeasurement of these benefits through the development cycle and into use; the projected ultimate cost of each asset at each point through the development cycle due to specification changes; and the likelihood of obsolescence of any component parts.
Sources of estimation uncertainty Sources of estimation uncertainty can arise where there are indicators of impairment of an intangible asset and an impairment provision is deemed appropriate. Factors such as whether the carrying amount of the asset is expected to be greater than the recoverable amount are assessed and in 2019, the Group recognised an impairment provision of £1.3 million (2018: £1.5 million) in relation to ongoing IT projects primarily relating to the development of new systems. The sensitivity from the assumptions made by the Group in respect of the testing for impairment of intangible assets are shown in note 17.
The market value of the Group’s financial investments with fixed coupons is affected by the movement of interest rates. For the majority of investments in US dollar and Euro corporate bonds, excluding £398.9 million of short duration high yield bonds (2018: £405.2 million) and £176.1 million of subordinated financial debt (2018: £167.6 million), the Group hedges the exposure of this portfolio to the US dollar and Euro interest rate risk using swaps.
Commercial real estate loans – 58.6 117.2 25.8 – – 201.6
The measurement and management of the Group’s liquidity risk is undertaken within the limits and other policy parameters of the Group’s liquidity risk appetite and is detailed in the liquidity risk minimum standard. As part of this process the Investment and Treasury team are required to put in place a liquidity plan which must consider expected and stressed scenarios for cash in-flows and out-flows that is reviewed at least annually by the Investment Risk Committee. Compliance is monitored in respect of both the minimum standard and the regulatory requirements of the PRA.
Notes: 1. Results for the year ended 31 December 2018 have been restated to reflect the fully retrospective adoption of IFRS 16 ‘Leases’, see note 44. 2. Restructuring and one-off costs of £11.2 million are included as follows: staff costs (£5.8 million) and other operating expenses (£5.4 million). 3. Staff costs and other operating expenses attributable to claims handling activities are allocated to the cost of insurance claims. 4. IT and other operating expenses include professional fees and property costs. 5. Insurance levies were previously reported in IT and other operating expenses. Comparative data for the year ended 31 December 2018 has been re-presented accordingly. 6. Depreciation and amortisation include a £1.3 million impairment charge for year ended 31 December 2019 (2018: £1.5 million), which relates to capitalised software development costs for ongoing IT projects primarily relating to development of new systems. 7. Includes depreciation on right-of-use assets of £14.2 million (31 December 2018: £14.1 million).
Amounts recognised as distributions to equity holders in the period: 2018 final dividend of 14.0 pence per share paid on 16 May 2019 191.8 – 2017 final dividend of 13.6 pence per share paid on 17 May 2018 – 186.1 2019 first interim dividend of 7.2 pence per share paid on 6 September 2019 98.6 – 2018 first interim dividend of 7.0 pence per share paid on 7 September 2018 – 95.8 2018 special dividend of 8.3 pence per share paid on 16 May 2019 113.7 – 2017 special dividend of 15.0 pence per share paid on 17 May 2018 – 205.3
The proposed final dividends for 2019 have not been included as a liability in these financial statements.
Note: 1. The cost included in the carrying value at 31 December 2019 is £222.9 million (2018: £252.5 million).
The investment properties are measured at fair value derived from valuation work carried out at the balance sheet date by independent property valuers.
WWW.DIRECTLINEGROUP.CO.UK 195 25. Prepayments, accrued income and other assets £m restated
Present value of defined benefit scheme obligations (90.3) (78.6) (87.3) (90.5) (72.0) Fair value of defined benefit scheme assets 100.0 95.6 101.7 102.5 85.1
Current estimate of cumulative claims 3,363.3 2,187.9 1,870.9 1,687.2 1,704.8 1,727.4 1,821.4 1,871.9 2,084.5 1,941.2
Cash paid for claims settled in the year1 (restated) (2,186.0) 31.1 (2,154.9) Increase / (decrease) in liabilities2: Arising from current-year claims1 (restated) 2,489.7 (174.2) 2,315.5 Arising from prior-year claims (523.5) 119.1 (404.4)
Assets held at fair value: Investment property (note 20) 322.1 – – 322.1 322.1
43. Related parties Transactions between the Group’s subsidiary undertakings, which are related parties, have been eliminated on consolidation and accordingly are not disclosed.
Impact on the consolidated balance sheet as at 31 December 2018
Net cash generated from operating activities before investment of insurance assets 4.2 19.3 23.5 Cash flows used in financing activities Finance costs (19.3) (6.8) (26.1) Principal elements of lease payments – (12.5) (12.5)
On 8 December 2017, the Company repurchased £250 million nominal value of subordinated guaranteed dated notes for a purchase price of £330.1 million including accrued interest of £2.7 million and associated transaction costs of £0.6 million.
Gross written premium The total premiums from contracts that were accepted during the period. Group Direct Line Insurance Group plc and its subsidiaries (“Direct Line Group” or the “Group”). Incremental borrowing rate (“IBR”)
Appendix A – Alternative performance measures The Group has identified Alternative Performance Measures (“APMs”) in accordance with the European Securities and Markets Authority’s published Guidelines. The Group uses APMs to improve comparability of information between reporting periods and reporting segments, by adjusting for either uncontrollable or one-off costs which impact the IFRS measures, to aid the user of the Annual Report & Accounts in understanding the activity taking place across the Group. These APMs are contained within the main narrative sections of this document, outside of the financial statements and notes, and may not necessarily have standardised meanings for ease of comparability across peer organisations.
Combined operating ratio normalised for weather and Ogden discount rate 86.9% 91.6% 99.2% 98.5% 93.5% 93.3%