Hbce 2020 Annual Report en
Hbce 2020 Annual Report en
Hbce 2020 Annual Report en
1 Adjusted performance is computed by adjusting reported results for the effect of significant items as detailed on pages 12 to 15.
2 Net operating income before change in expected credit losses and other credit and other credit risk provisions is also referred to as revenue.
3 The return on average total shareholders’ equity is defined as profit attributable to shareholders of the parent company divided by the average
total shareholders’ equity.
4 Adjusted cost efficiency is defined as total operating expenses (adjusted) divided by net operating income before change in expected credit losses
and other credit and other credit risk provisions (adjusted).
5 While HQLA increased due to deposit growth, the LCR for HSBC Continental Europe declined, reflecting a reassessment of potential LCR
outflows, particularly with respect to committed facilities.
6 Computed in respect of CRR II guidelines. 2018 ratio was calculated based on interpretation of BCBS 295.
Performance highlights
HSBC Continental Europe’s performance in 2020 was impacted by exceptional items, including the impairment of tangible and intangible
assets and significant restructuring costs, and by the downturn of the global economy caused by the Covid-19 pandemic, which resulted
in an increase in expected credit losses and other credit impairment charges. Historically-low interest rates in Europe and the cut in US
rates in March 2020 dampened the net interest margin, in spite of higher average loan and deposit balances over 2020.
Notwithstanding that context, customer revenue remained resilient, and HSBC Continental Europe continued to support its customers
and the wider economy, including through the granting of new loans under the French Government guarantee scheme and HSBC
specific schemes for a full-year amount of EUR 6 billion. HSBC also improved its market share in debt capital markets and confirmed its
position as a leading bank in Europe, ranking 2nd in the ‘European Sovereign Bonds’ category (Source: Dealogic). Moreover, HSBC’s
expertise was underlined in 2020 as it was conferred ‘Western Europe Transaction Banking Award’ from The Banker.
Reported consolidated loss before tax was EUR 945 million, down from a loss of EUR 22 million in 2019, including the impairment
of tangible and intangible assets (EUR 500 million), significant restructuring costs (EUR 258 million), an unfavourable PVIF (Present Value
of In-Force long term insurance business) movement (EUR 123 million), higher operating expenses and an increased cost of risk
(EUR 289 million).
Reported net operating income before change in expected credit losses and other credit impairment charges was EUR
2,121 million, down from EUR 2,227 million in 2019. The decrease was driven by an unfavourable PVIF movement in Life Insurance of
EUR 123 million. In addition, Wealth and Personal Banking income was impacted by persistently low rates and a decrease in net fee
income as a consequence of adverse market conditions and lower customer activity in the context of the Covid-19 pandemic. This was
offset by growth in Markets and Securities Services, corporate lending to Global Banking clients and a resilient performance in
Commercial Banking.
Reported change in expected credit losses and other credit impairment charges was a charge of EUR 289 million, compared
with a charge of EUR 128 million in 2019. The increase in the cost of risk was a direct consequence of the effects of the Covid-19
pandemic and reflected the deterioration in the current economic environment and the forward outlook.
Reported operating expenses were EUR 2,777 million, up from EUR 2,121 million in 2019, including the impairment of tangible and
intangible assets for EUR 500 million, restructuring costs for EUR 258 million, and contributions to the Single Resolution Fund which
increased by EUR 49 million compared with prior year, partly offset by lower recurring expenses.
Reported loss attributable to shareholders of the parent company was EUR 1,022 million in 2020, compared with a loss of EUR
39 million in 2019.
1
Effective from the second quarter of 2020, Group HSBC’s matrix organisational structure has been simplified by merging GPB and
RBWM to form Wealth and Personal Banking (‘WPB’).
relationships, improving synergies across HSBC global businesses. Wealth Solutions, and bespoke lending for customers with more
GBM is underpinned by a focus on the highest standards of sophisticated and international requirements.
conduct and financial crime risk management. The strategic review of the retail operations is ongoing. No
In July 2020, a social plan was presented for the GBM business in decision has been made.
France. Its objective is to preserve the bank’s future
competitiveness on the large corporate and financial market
Supporting our stakeholders through Covid-19
segment, to focus on our strategic positioning, while reducing the The Covid-19 outbreak has created a great deal of uncertainty and
size of GBM business in France. disruption for the people, businesses and communities we serve
around the world. It is affecting everyone in different ways. We are
Commercial Banking (‘CMB’)
tailoring our response to the different circumstances and
HSBC Continental Europe’s Commercial Banking serves customers situations in which our stakeholders find themselves.
in 10 markets (France, Spain, Italy, Belgium, the Netherlands,
Ireland, Greece, the Czech Republic, Sweden and Poland), ranging
Customers
from small enterprises in France focused on their local market to The Covid-19 outbreak has posed significant challenges to our
corporates operating across borders. Whether it is an SME customers worldwide. Our immediate priority is to do what we can
banking at one of HSBC Continental Europe’s business centres in to provide them with support and flexibility. This has included
key cities in France, or one of the multinationals HSBC Continental offering payment relief, assisting our customers to restructure
Europe helps support across the region, CMB provides the tools their balance sheets and providing access to local government
and expertise that European businesses need to thrive. lending schemes.
Our network of relationship managers and product specialists We granted new loans under the French Government guarantee
work closely to meet customer needs, from term loans to region- scheme and HSBC specific schemes for a full-year amount of EUR
wide treasury and trade solutions. We are fully committed to 6 billion. In CMB, we provided EUR 2.2 billion of facilities through
helping European businesses navigate change and seize export market-wide schemes (5,100 requests approved), and helped them
opportunities as the European Union strikes new trade to navigate the current environment. CMB and GBM largely
agreements. With the importance of the United Kingdom and deployed electronic signature solutions, and Global Markets
European Union trade relations to our customers, we are also ensured a continuous coverage from its sales and traders. With
providing guidance and continuity to assist businesses in adapting customers doing more of their banking online, CMB and GBM
to changes brought by the United Kingdom’s exit from the have also extended their permanent remote services, including
European Union. video calls with business relationship managers. In WPB, we put
Commercial Banking is at the centre of creating revenue synergies in place approximately 3,900 payment holidays corresponding to a
within the Group. We work closely with our Global Banking and balance of circa EUR 700 million of home loans and professional
Markets colleagues to provide expertise in capital finance and loans. The business has also granted circa 640 loans guaranteed
advisory solutions to support our Commercial Banking clients. Our by the state (‘PGE’) corresponding to approximately EUR 37
trade teams within Commercial Banking also provide import and million outstanding loans. Business continuity and high service
export finance solutions to Global Banking and Markets clients. quality have been ensured throughout the period, with most of our
branches open (following strict health guidelines protecting
Leveraging major operations in France and full-service centres in customers and colleagues) and enhanced technology to enable
hubs such as Ireland and the Netherlands, we provide corporates them to interact with us through digital tools (e-signature, video
with the means to consolidate and simplify their European calls, webinars).
operations, enabling our customers to have greater visibility over
their liquidity position and unlock efficiencies in their treasury Employees
structures. Our customers expect us to be innovative, whether it is The Covid-19 outbreak tested our employees in many ways and
a receivables finance solution to optimise working capital or they adapted quickly to the fast-changing environment. We
support in pursuing the sustainability agenda. One way we are provided new and enhanced support to ensure the well-being of
helping customers in their sustainability efforts is through their employees and have encouraged a culture of looking out for each
supply chains, by developing green financing solutions that are other. Our priorities for our employees are mental health and
beneficial for buyer and seller alike. flexible working.
CMB will continue to focus on its return on capital employed by Regulators and governments
repositioning its business to focus on strategic activities and
We have proactively engaged with regulators and governments in
clients valuing our international franchise. In order to improve
Europe, regarding the policy changes issued in response to the
operational efficiency, simplify processes and better leveraging the
Covid-19 outbreak, to help our customers and to contribute to an
Group’s Centres of Excellence, HSBC Continental Europe is also
economic recovery.
reshaping its CMB activities through a collective voluntary
departure plan.
Wealth and Personal Banking (‘WPB’)
In France and Greece, WPB helps more than 0.9 million customers
with their financial needs through Retail Banking, Wealth
Management, Insurance, Asset Management and Private Banking.
HSBC Continental Europe offers a full range of products and
services to meet the personal banking and wealth management
needs of customers from personal banking to ultra-high net worth
individuals.
Our core retail proposition offers a full suite of products including
personal banking products, such as current and savings accounts,
mortgages and unsecured loans, credit cards (only applicable in
Greece), debit cards and local and international payment services.
Alongside this, WPB offers various propositions, including Jade,
Premier, and Advance, as well as wealth solutions, financial
planning and international services.
Our Private Banking proposition serves high net worth and ultra-
high net worth clients with investment management, Private
as well. The CRR2 will also implement the first tranche of changes reflect the activities it undertakes more accurately and its
to the EU’s legislation to reflect the Basel III Reforms, including the relationship to our Treasury function more broadly. This followed
changes to market risk (‘FRTB’) rules, revisions to the standardised realignments within our internal reporting and includes the
approach for measuring counterparty risk and the new leverage reallocation of Markets Treasury from Corporate Centre to the
ratio rules. The CRR2 rules will follow a phased implementation global businesses. Comparative data has been re-presented
with significant elements entering into force in 2021, in advance of accordingly and reflected in all the business performance
Basel’s timeline. commentary. The global business segmental results are presented
on an adjusted basis in accordance with IFRS 8 ‘Operating
The implementation of the remaining Basel III Reforms
Segments’, as detailed in ‘Basis of preparation’ in Note 1.1.(f):
The remaining elements of the Basel III Reforms will be Segmental Analysis. Reconciliation of reported and adjusted
implemented in the EU by a further set of amendments to the performance are presented on pages 14 to 15.
Capital Requirements Regulation. The EBA responded to the
Adjusted performance
European Commission’s request to update its previous advice on
the impact of the package, taking into account the effect of the Adjusted performance is computed by adjusting reported results
Covid-19 outbreak. Two scenarios have been considered. One for the year-on-year effects of significant items that distort year-
scenario entails implementing the reforms in EU legislation in full on-year comparisons. We use ‘significant items’ to describe
alignment with Basel’s standards and timeline i.e. 1 January 2023. collectively the group of individual adjustments excluded from
The second scenario entails the implementation of the reforms in reported results when arriving at adjusted performance. These
line with Basel’s timeline but with CVA exemptions, the SME and items are ones that management and investors would ordinarily
infrastructure factors, and the historical loss multipliers set to 1 for identify and consider separately when assessing performance to
operational risk. The subsequent EU implementation will be understand better the underlying trends in the business.We
subject to an extensive negotiation process with the EU Council consider adjusted performance provides useful information for
and Parliament. investors by aligning internal and external reporting, identifying
and quantifying items management believes to be significant and
The UK’s withdrawal from the EU
providing insight into how management assesses year-on-year
As a result of the decision of the referendum on 23 June 2016, the performance.
UK left the EU on 31 January 2020. In order to smooth the
transition, the UK remained subject to EU law during a transition
period, which ended on 31 December 2020.
The agreement reached between the UK and the EU on
24 December 2020 (‘EU-UK Trade and Cooperation Agreement’)
sets out preferential arrangements in various areas excluding
financial services and related equivalences. As a result, the UK will
be treated from 1 January 2021 onwards as a non-EU third
country, the treatment of which is subject to equivalence
assessments. In September 2020, the EU declared the UK CCP
framework as temporarily equivalent (until 30 June 2022).
The end of the transition period also triggers an additional MREL
requirement under CRR2 for HSBC Continental Europe as it
becomes a subsidiary of a third-country parent entity.
Other developments
In November 2020, the ECB published its final guide on climate-
related and environmental risks laying out its associated
supervisory expectations on risk management and disclosures and
will start the associated dialogue with banks from 2021.
Also in November 2020, the European Banking Authority (‘EBA’)
published a consultation to incorporate Environmental Social and
Governance (‘ESG’) risks into the governance, risk management
and supervision of credit institutions and investment firms. This
will inform the EBA’s report on management and supervision of
ESG risks and the EBA’s assessment of the need for a dedicated
prudential treatment.
Management report
Scope of the performance review
Use of non-GAAP financial measures
Our reported results are prepared in accordance with International
Financial Reporting Standards ('IFRS'), as detailed in the Financial
Statements starting on page 164. In measuring our performance,
the financial measures that we use include those derived from our
reported results in order to eliminate factors that distort year-on-
year comparisons. These are considered non-GAAP financial
measures. Non-GAAP financial measures are described and
reconciled to the closest reported financial measure when used.
Change in reportable segments since year end 2019
Effective from the second quarter in 2020, we simplified our
organisation structure by merging Global Private Banking (‘GPB’)
and Retail Banking and Wealth Management (‘RBWM’) to form
Wealth and Personal Banking (‘WPB’). We also renamed our
Balance Sheet Management function as Markets Treasury to
1 Total operating income and expenses include significant items as detailed on pages 12 to 15.
Net interest income was EUR 1,053 million in 2020, down from Net insurance premium income was EUR 1,367 million in
EUR 1,095 million in the previous year. Interest income decreased 2020, down from EUR 2,076 million in 2019. This decrease was
by EUR 90 million, from EUR 1,951 million to EUR 1,861 million. In mainly related to reduction in insurance inflows particularly on
an environment of persisting low and even negative interest rates, Eurofund contracts during the year, in a context of deteriorated
income on loans and interest income on bond portfolios of the life markets conditions due to Covid-19.
insurance subsidiary continued to be pressured downward. This Other operating income was EUR 84 million down from EUR
was partly offset by the favourable decrease in interest expense of 187 million the previous year, impacted by the adverse variation of
EUR 48 million to EUR -808 million compared with EUR -856 PVIF (‘Present Value of In-force insurance long-term business’)
million last year, reflecting lower funding costs. driven by adverse market conditions and lower interest rates.The
Net fee income was EUR 858 million in 2020, up from EUR 778 variation of the accounting PVIF was a decrease of EUR 123
million in 2019. The increase was mainly due to higher fees from million in 2020 compared to an increase of EUR 113 million in
GBM with a good volume of transactions in the Capital Markets 2019. This was partly offset by a EUR 100 million exceptional
businesses and favourable fees from Equity activities. This was revenue booked in Corporate Centre and the reclassification of
partly offset by a decrease in fee income on Wealth & Personal some intragroup recoveries from operating expenses to other
Banking driven by lower levels of customer activity and assets operating income.
under management reflecting the impact of the Covid-19 Net insurance claims incurred, benefits paid and movement
pandemic. in liabilities to policyholders were EUR -1,571 million in 2020,
Net income from financial instruments held for trading or up from EUR -3,380 million in 2019. This increase is mainly driven
managed on a fair value basis was EUR 72 million in 2020, up by the change in the market value of assets recognised at fair
from EUR 30 million in 2019. This increase was mainly driven by value by the insurance subsidiary for both unit-linked and
the favourable market variation of options instruments held by the Eurofund contracts, and in relation with lower net insurance
insurance company and the increase in Markets & Securities premiums.
Services activities partly offset by an operational loss in the first Reported net operating income before change in expected
half of year. credit losses and other credit impairment charges was EUR
Net income from assets and liabilities of insurance 2,121 million, down from EUR 2,227 million in 2019. This decrease
measured at fair value through profit and loss was EUR 161 is mainly due to the adverse impact of the persistent low interest
million down from EUR 1,277 million in 2019. The reduction environment on net interest income, and the unfavourable
reflected the change in the market value of assets held by the variation of PVIF driven by both interest rates and markets
insurance company on behalf of its customers with respect to conditions.
both unit-linked policies and Eurofund contracts. The counterpart
of this decrease was the change in liabilities to policyholders.
Changes in fair value of other financial instruments
mandatorily measured at fair value through profit and loss
totalled EUR 87 million in 2020, compared to EUR 153 million in
2019. Compared to prior year, the decrease was mainly due to
unfavourable movements in the insurance portfolio.
Gains less losses from financial investments were broadly
unchanged at EUR 14 million compared to EUR 12 million in 2019.
Change in expected credit losses and other credit perimeter effect related to both the integration of EEA branches
impairment charges ('ECL') was EUR 289 million up from EUR last year and the transfer of Structured Equity Derivatives activities
128 million in 2019. ECL increased in all Global Businesses, mainly from HSBC Bank plc to HSBC Continental Europe this year.
driven by stage 3 provisions and from charges relating to the Loss before tax was EUR 945 million, sharply down from a EUR
global impact of the Covid-19 outbreak on the deteriorated 22 million loss in 2019, and included impairments of tangible and
forward economic outlook. intangible assets, restructuring costs, an adverse PVIF movement
Operating expenses amounted to EUR 2,777 million in 2020 up and a incremental ECL charges.
from EUR 2,121 million in 2019. This cost increase was mainly Loss attributable to shareholders of the parent company in
driven by the impairment of tangible and intangible assets for EUR 2020 was EUR 1,022 million, down from EUR 39 million in the
500 million, restructuring costs for EUR 258 million, Single previous year.
Resolution Fund contribution for EUR 106 million (increasing by
EUR 49 million compared with 2019) and the unfavourable
1 In 2020, significant items include EUR 31 million revenue loss related to GBM RWA reduction initiatives, EUR 100 million exceptional revenue
recognised in other operating income and a negative EUR 1 million fair value movement on non qualifying hedges. In 2019, they included
EUR 1 million debit valuation adjustment in GBM and EUR 1 million fair value movement on non qualifying hedges.
2 A change in reportable segments was made during 2020. Comparative data have been re-presented accordingly.
1 A change in reportable segments was made during 2020. Comparative data have been re-presented accordingly.
1 A change in reportable segments was made during 2020. Comparative data have been re-presented accordingly.
1 A change in reportable segments was made during 2020. Comparative data have been re-presented accordingly.
Adjusted loss before tax in 2020 stood at EUR -331 million, Adjusted operating expenses were EUR 2,095 million in 2020,
compared to a profit of EUR 240 million in 2019. This evolution up from EUR 1,861 million in 2019. The variation was mainly
was mainly driven by the impairment on tangible assets, the driven by the impairment of tangible assets for EUR 133 million,
increase in expected credit losses and other credit impairment the increase by EUR 49 million of the contribution to the Single
charges, the unfavourable PVIF movement and the higher Resolution Fund and the unfavourable perimeter effect related to
contribution to the Single Resolution Fund and the impairment on the transfer to HSBC Continental Europe of the European branches
tangible assets. during 2019 and of the Structured Equity Derivatives activity in
2020.
Adjusted net operating income before change in expected
credit losses and other credit impairment charges was EUR
2,053 million in 2020, down from EUR 2,229 million in 2019. This
was mainly driven by the unfavourable insurance PVIF variation,
with a decrease of EUR 123 million in 2020 down from an increase
of EUR 113 million in 2019, by the effect of persisting low and
negative interest rates on the net interest margin and by the
repercussions of the deteriorated economic and markets
conditions particularly on wealth activities. This was partly offset
by growing GBM revenues with an improved performance of
Markets & Securities Services activities, along with favourable
perimeter effect related to the transfer to HSBC Continental
Europe of the European branches during 2019 and of the
Structured Equity Derivatives activity in 2020.
Adjusted change in expected credit losses and other credit
impairment charges was EUR 289 million up from EUR 128
million in 2019. ECL increased in all Global Businesses, mainly
driven by stage 3 provisions and from charges relating to the
global impact of the Covid-19 outbreak on the deteriorated
forward economic outlook.
Wealth and Personal Banking and Euroclearing businesses, all benefiting from the broader scope
of European clients served and increased activity.
Adjusted loss before tax at EUR 280 million was EUR 333 million
below the 2019 profit reflecting a fall in net operating income Adjusted change in expected credit losses and other credit
before change in expected credit losses mainly explained by the impairment charges remained high at EUR 77 million, with EUR 18
adverse variation of PVIF, an increase in expected credit losses million unfavourable variation vs prior year mainly driven by Stage
reflecting the impact of the Covid-19 outbreak and an increase in 2 provision, while Stage 3 remained high in the context of the
operating expenses primarily due to the impairment of tangible Covid-19 crisis.
assets. Adjusted operating expenses amounted to EUR -691 million, up
Adjusted net operating income before expected credit losses and EUR 138 million compared to prior year, due to a significant
other credit impairment charges was EUR 622 million down from increase in the contribution to the European Single Resolution
EUR 885 million in December 2019. This was mainly the result of Fund, higher IT costs and unfavourable impact of perimeter
the adverse market impact in life insurance manufacturing change related to the transfer of Structured Equity Derivatives
(change in the PVIF movement of EUR -237 million). Interest activity headcount from HSBC Bank plc Paris Branch to HSBC
income was below prior year with lower and negative interest Continental Europe.
rates pressuring the income on assets downward despite Loans and Advances to Customers decreased by EUR 0.9 billion in
increased loans volumes and lower funding costs. Net fee income comparison with end of 2019 as lower business activity in certain
was also below prior year with negative impact of Covid-19 lending products more than offset the increased corporate lending
restrictions on customer activity penalising banking fees and in response to Covid-19. GBM supported its clients through the
wealth management fees. Covid-19 crisis, notably participating in significant state backed
Change in Expected Credit Losses and other credit impairment facilities with more than EUR 2 billion of lending provided.
charges increased by EUR 22 million mainly from deterioration in Customer Deposits decreased by EUR 0.9 billion in comparison
the forward economic outlook due to the Covid-19 pandemic. with end of 2019, predominantly driven by lower term deposits.
Adjusted Operating Expenses increased by EUR 48million to EUR Corporate Centre
880 million primarily due to the impairment of tangible assets in
part offset by productivity gains and cost management measures. Adjusted loss before tax was EUR 41 million in 2020 compared to
EUR 29 million loss in 2019.
Loans and advances to customers, at EUR 24 billion in December
2020, increased by 1.8 per cent compared to December 2019 Adjusted net operating income before expected credit losses and
driven by new home loans business in spite of lower customer other credit impairment charge was EUR 36 million in 2020 versus
activity. EUR 15 million in 2019. The increase reflected higher recharges to
other entities in HSBC Group.
Total Assets under Management from customers were EUR 53
billion in December 2020, broadly stable compared to December Adjusted operating expenses were EUR 77 million in 2020
2019. The growth was mainly driven by increased customer compared with EUR 44 million in 2019, driven by the impairment
deposits, with customer deposits at EUR 21 billion growing by 6 of tangible assets.
per cent compared to December 2019.This increase was partly
offset by lower assets under management caused by the adverse
equity market evolution since the beginning of the year.
Commercial Banking
Adjusted profit before tax was EUR 63 million down from EUR 188
million in 2019.
Adjusted net operating income before expected credit losses and
other credit impairment charges amounted to EUR 700 million,
increasing by EUR 11 million compared to 2019 on income from
lending partly offset by the unfavourable impact of historically low
interest rates.
Adjusted change in expected credit losses and other credit
impairment charges was EUR 190 million, up from from EUR 69
million in 2019 as the Covid-19 pandemic impacted customers.
Adjusted operating expenses rose by EUR 15 million to EUR 447
million, mainly due to higher IT, Risk and Compliance costs.
In 2020, loans and advances to customers remained broadly
unchanged. Loan balances of EUR 18.1 billion included EUR 2.2
billion of new loans under the French Government guarantee
scheme. The slight decrease was mainly driven by short term
loans and lower drawings on revolving credit facilities.
Deposits grew 14 per cent to EUR 27 billion, with significant
inflows linked to the Covid-19 pandemic.
Total assets were EUR 237 billion at 31 December 2020, broadly mainly driven by the growing deposits from WPB and CMB
stable compared to 31 December 2019. customers in France.
Assets Repo securities, at EUR 11 billion, decreased by EUR 9 billion due
to reduced positions on banks and customers.
HSBC Continental Europe’s deposits at the central banks grew by
EUR 10 billion to EUR 29.5 billion in 2020 following an increase of Derivatives, at EUR 55.7 billion, increased by EUR 10.6 billion, due
customer deposits and the issuance of TLTRO III funding. to the interest rate decrease.
The trading portfolio was reduced by EUR 2 billion to EUR 13 Equity
billion. Financial assets mandatorily measured at fair value through Shareholders’ equity stood at EUR 7.4 billion, down from EUR 8.4
profit and loss remained stable at EUR 12 billion. billion in 2019.
Derivative instruments were EUR 10.7 billion higher at EUR 56.5 The CET1 (Common Equity Tier 1) ratio was 12.6 per cent at 31
billion resulting from lower interest rate. December 2020 and a total capital ratio was 17.3 per cent.
Loans and advances to customers remained broadly steady at
Liquidity and funding
EUR 56 billion.
Outstanding medium- and long-term funding and the bank’s main
Reverse repurchase agreements – non trading – stood at EUR 22
financing transactions in 2020 are presented in the liquidity and
billion in 2020 compared to EUR 46 billion in 2019, due to reduced
financing management section on pages 132 to 135.
positions with banks and customers.
The short-term ratio (liquidity coverage ratio or LCR) was 143 per
Liabilities cent and the long-term ratio (net stable funding ratio or NSFR) was
Deposits by banks increased by EUR 5 billion to EUR 17.2 billion, 136 per cent.
mainly driven by the issuance of TLTRO III and repayment of
TLTRO II.
Customer deposits rose from EUR 57.6 billion to EUR 61.4 billion,
At 31 Dec 2019 1
Loans and advances to customers 23,773 18,378 15,411 (606) 56,956
Customers accounts 19,887 23,655 14,986 (978) 57,550
1 A change in reportable segments was made during 2020. Comparative data have been re-presented accordingly.
At 31 Dec.20191
France 51 (63) (77) (65) (154)
Belgium — — 1 — 1
Czech Rep — 27 1 (1) 27
Greece (7) (2) 17 (4) 4
Ireland — 16 9 — 25
Italy — 3 8 (1) 10
Luxembourg — — 8 — 8
Netherlands — 26 4 (1) 29
Poland — (8) 8 (4) (4)
Spain — 15 22 (1) 36
Sweden — — (1) — (1)
United Kingdom — — (4) — (4)
Others 1 — 1 (1) 1
Profit/(loss) before tax 45 14 (3) (78) (22)
1 A change in reportable segments was made during 2020. Comparative data have been re-presented accordingly.
1 Net interest margin is net interest income expressed as an annualised percentage of average interest-earning assets.
1 Yield has been calculated taking into account negative interest on assets recognised as interest expense in the income statement. 2019 yield have
been re-presented accordingly.
2 Interest income arising from trading assets is included within 'Net trading income' in the income statement.
1 Cost has been calculated taking into account negative interest on liabilities recognised as interest income in the income statement. 2019 cost have
been re-presented accordingly.
2 Interest expense arising from trading liabilities is included within 'Net trading income' in the income statement.
1 Capital ratios from 2018 are reported under fully loaded and no longer under transitional.
2 The cost efficiency ratio in 2016 does not include the depreciation of goodwill.
3 The increase in 2019 is due to acquisition of seven branches: Madrid branch, Milan branch, Ireland branch, Netherlands branch Belgium branch,
Prague branch with effect from 1 February 2019 and Luxembourg branch from 1 March 2019.
Article D.441 – II: Received invoices by HSBC Continental Europe S.A.1 subject to late payment delays during the year
0 day (for Total (1 day and
information) 1 to 30 days 31 to 60 days 61 to 90 days over 91 days more)
(A) Late payment buckets
Number of invoices 31,716 5,942
Amount of invoices including VAT
(in €k) 742,730 83,438 24,140 8,367 27,359 143,303
Percentage of total purchasing in the
year 84% 9% 3% 1% 3% 16%
(B) Invoices excluded from (A) in respect of litigations or not accounted
Number of invoices excluded 2,566
Amount of excluded invoices
including VAT (in €k) 61,541
(C) Suppliers' payment terms (contractual or legal terms)
Payment terms used to assess the late
payments Contractual terms: 45 days
Article D.441 – I: Issued invoices by HSBC Continental Europe S.A.1 subject to late payment delays at year-end
0 day (for Total (1 day and
information) 1 to 30 days 31 to 60 days 61 to 90 days over 91 days more)
(A) Late payment buckets
Number of invoices 93 695
Amount of invoices excluding VAT
(in €k) 27,109 18,157 6,348 263 4,708 29,476
Percentage of total revenue of the
year 1.88% 1.25% 0.44% 0.02% 0.33% 2.04%
(B) Invoices excluded from (A) in respect of litigations or not accounted
Number of invoices excluded —
Amount of excluded invoices
excluding VAT (in €k) —
(C) Clients' payment terms (contractual or legal terms)
Payment terms used to assess the
late payments Contractual terms: 30 to 45 days
This information does not include banking transactions and certain related transactions as HSBC Continental Europe considers that they
do not fall within the scope of the information to be produced.
Under article L. 225-37 of the French Commercial Code, the Board This report was submitted to the Board Committees at their
of Directors presents a report on Corporate Governance attached meetings held on 29 January, 9 February and 10 February 2021.
Remuneration
u Risk Committee
Committee
General Management
p p p
Asset & Liability Committee
Businesses' Risk
Financial Crime
Committees & Main ad hoc Businesses'
Operational Risks Financial Risks Compliance
international Committees Committees
Governance Structure
locations
Board composition is detailed and commented on pages 23 and In particular regarding the information flow on risk, the HSBC
following of this Corporate Governance report. Continental Europe Risk Management Meeting, which is chaired
by the Chief Risk Officer and includes the Chief Executive Officer,
Membership, duties and work of the Board Committees are
the Deputy Chief Executive Officers and other members of the
presented in relevant sections of this Corporate Governance report
Executive Committee, is the overarching Committee overseeing
(see pages 33 to 37).
risk management and permanent control. Next to it, the
General Management and Executive Committee membership is committee in charge of overseeing more specifically the Financial
detailed on page 37 and following of this Corporate Governance Crime Risk, Sanctions Risk and Fraud Risk, is the Financial Crime
report. Risk Management Committee.
Risks, issues or other matters requiring attention from the Relevant information, in particular on risk, is shared on a quarterly
management body may be escalated through line management, or basis with the Board and its Audit and Risk Committees by the
through the committee structure described above. bank’s senior management.
2
As far as their direstorship at HSBC Continental Europe is concerned, the address of HSBC Continental Europe's Directors and Senior Executives
is the company's registered office, 38 avenue Kléber, 75116 Paris, France.
3
Listed company.
The Board membership complies with the policies the Board had He was appointed Co-Head of Corporate Investment Banking and
implemented on the assessment of the suitability of members of Markets, mainly in charge of Corporate and Investment Banking in
the management body and key function holders and on diversity. 2004. In 2005, he was appointed Senior Corporate Vice-President.
In 2007, he was appointed Head of Global Banking and Markets of
Changes occurred in the Board composition during
HSBC Continental Europe. In 2010, he was appointed Deputy CEO,
2020 and early 2021
in addition to his role as Head of Global Banking and Markets
At its meeting on 6 February 2020, the Board took note of the France. The same year, he was appointed Head of Global Banking,
resignation of Jacques Veyrat from his directorship. Continental Europe, HSBC Group. His direct responsibilities within
The Nomination Committee reviewed the position of the Directors Global Banking and Markets ended in 2019. Since January 2012,
whose term of office expired at the Annual General Meeting on he has been CEO of HSBC Continental Europe.
13 March 2020: Jean Beunardeau and Lucile Ribot. Further to the 2019 Directorships in the HSBC Group:
reassessment of their suitability and upon recommendation of the Director and CEO: HSBC Continental Europe. Chairman of
Board, the Board decided to propose their renewal. the Board: HSBC Global Asset Management (France),
At the Annual General Meeting held on 13 March 2020, HSBC Assurances Vie (France). Director: Valeurs
shareholders re-elected those Directors. Mobilières Elysées. Chairman: Fondation HSBC pour
l'Education.
Further to James Emmett's resignation from his directorship,
Directorships outside of the HSBC Group:
the Board co-opted Nuno Matos as a Director at its meeting
Director: Institut de la Gestion Déléguée. Member of the
on 30 April 2020. The Shareholders' General Meeting on
Supervisory Board: Société Anonyme des Galeries
12 November 2020 ratified this co-optation.
Lafayette, Fonds de garantie des dépôts et de résolution
On 23 October 2020, the Board took note of the death of Philippe (permanent representative of HSBC Continental Europe).
Purdy, a Director elected by employees, on 9 September 2020. Chairman: Académie France-Chine. Director, Fondation de
At its meeting on 12 February 2021, the Board took note of the France (permanent representative of HSBC Continental
resignation of Laurence Rogier from her directorship. Europe). Treasurer: Association du Golf de Saint-Cloud.
Further to Nuno Matos's resignation from his directorship, 2018 Directorships in the HSBC Group:
the Board co-opted Stephen O'Connor as a Director at its meeting Director and CEO: HSBC Continental Europe. Chairman of
on 12 February 2021. This co-optation will be submitted to the the Board: HSBC Global Asset Management (France),
ratification of the Annual General Meeting to be held on 11 March HSBC Assurances Vie (France). Director: Valeurs
2021. Mobilières Elysées. Chairman: Fondation HSBC pour
l'Education.
Presentation of the Directors as of 13 February 2021 Directorships outside of the HSBC Group:
Director: Institut de la Gestion Déléguée. Member of the
Jean Beunardeau Supervisory Board: Société Anonyme des Galeries
Director and Chief Executive Officer Lafayette, Fonds de garantie des dépôts et de résolution
(permanent representative of HSBC Continental Europe).
First elected: 2008. Last re-elected: 2020. Term ends: 2023 Chairman: Académie France-Chine. Director, Fondation de
Principal position: Chief Executive Officer, HSBC Continental France (permanent representative of HSBC Continental
Europe. Group General Manager, HSBC Group4. Europe). Treasurer: Association du Golf de Saint-Cloud.
Other directorships in the HSBC Group: Chairman of the 2017 Directorships in the HSBC Group:
Board, HSBC Global Asset Management (France). Director, HSBC Director and CEO: HSBC Continental Europe. Chairman of
Assurances Vie (France). Director, Valeurs Mobilières Elysées. the Board: HSBC Global Asset Management (France),
Chairman, Fondation HSBC pour l'Education. Directorship expired HSBC Assurances Vie (France). Director: Valeurs
in 2020: Chairman of the Board, HSBC Assurances Vie (France). Mobilières Elysées. Chairman: Fondation HSBC pour
l'Education.
Other directorships outside of the HSBC Group: Member of Directorships outside of the HSBC Group:
the Supervisory Board, Société Anonyme des Galeries Lafayette. Director: Institut de la Gestion Déléguée. Member of the
Chairman Académie France-Chine. Director, Fondation de France Supervisory Board: Société Anonyme des Galeries
(permanent representative of HSBC Continental Europe). Lafayette, Fonds de garantie des dépôts et de résolution
Treasurer, Association du Golf de Saint-Cloud. Member of the Great (permanent representative of HSBC Continental Europe).
Council, Cercle de l'Union Interalliée. Directorship expired Chairman: Académie France-Chine.Director, Fondation de
in 2020: Member of the Supervisory Board, Fonds de garantie France (permanent representative of HSBC Continental
des dépôts et de résolution (permanent representative of Europe).
HSBC Continental Europe).
.
Number of positions held within the meaning of L. 511-52 of the
French Monetary and Financial Code: one directorship as
executive and one directorship as member of a Board of Directors
or a Supervisory Board.
Skills and experience: Born in 1962. Graduated from Ecole
Polytechnique, Telecom Engineer and Master of Economics, he
began his career at the Ministry of Finance, at the Forecasting
Department then at the Treasury. He became Technical Advisor to
the Prime Minister in 1995. He joined HSBC Continental Europe in
1997 in Corporate Finance and became Managing Director in
2000.
4
Listed company.
Member of the Risk Committee Chairman of the Risk Committee and Member of the Audit
Committee
First elected: 2017. Last re-elected: 2019. Term ends: 2022
First elected: 2013. Last re-elected: 2019. Term ends: 2022
Other directorships: Director, CA Indosuez Wealth Management
(Europe). Member of the Supervisory Board, Damartex5. Member Other directorship in the HSBC Group: Director, HSBC Bank
of the Supervisory Board, Somfy5. Bermuda Limited.
Number of positions held within the meaning of L. 511-52 of the Other directorships outside of the HSBC Group: Governor
French Monetary and Financial Code: four directorships as and Co-Founder, C.H.I.L.D. Foundation. Director, Export
member of a Board of Directors or a Supervisory Board. Development Canada. Directorship expired in 2020: Chancellor,
University of British Columbia.
Skills and experience: Born in 1955. Graduated from the Ecole
Supérieure de Commerce de Paris (‘ESCP’ Europe). Degree in Number of positions held within the meaning of L. 511-52 of the
International Law from the University Paris II-Assas and Corporate French Monetary and Financial Code: one directorship as member
Director Certificate from the French Institute of Directors, issued of a Board of Directors or a Supervisory Board.
by the Institut d'Etudes Politiques de Paris. After having held Skills and experience: Born in 1952. British and Canadian
various operational responsibilities within Investment Banking and nationality. Graduate of an M.B.A. in Finance and International
Markets activities at Banque Indosuez, The Chase Manhattan Bank Business at the Sauder School of Business of the University of
and then at Crédit Agricole group, she was Head of the central British Colombia and BA in Economics from the University of
team of Calyon’s Inspection Générale between 2000 and 2005, British Colombia. He joined HSBC Bank Canada in 1987 and has
Chief Executive Officer of Gestion Privée Indosuez between 2006 served in various roles in Toronto and Vancouver including Senior
and 2009, and subsequently Global Head of Compliance for Crédit Executive Vice-President, Chief Credit Officer, Senior Vice-
Agricole Corporate & Investment Bank until 2013, when she President and Head of Special Credit, and Vice-President at
retired. Since 2013, she has been holding several directorships in Commercial Banking in Toronto. He was appointed Chief
boards and board committees. Operating Officer in 1999 then President and Chief Executive
2019 Directorship in the HSBC Group: Officer from 2003 to 2013, date of his retirement.
Independent Director: HSBC Continental Europe. 2019 Directorships in the HSBC Group:
Directorships outside of the HSBC Group: Independent Director: HSBC Continental Europe. Director:
Director: CA Indosuez Wealth Management (Europe). HSBC Bank Bermuda Limited.
Member of the Supervisory Board: Damartex, Somfy. Directorships outside of the HSBC Group:
2018 Directorship in the HSBC Group: Chancellor: University of British Columbia. Governor and
Independent Director: HSBC Continental Europe. Co-Founder: C.H.I.L.D. Foundation. Director: Export
Directorships outside of the HSBC Group: Development Canada.
Director: CA Indosuez Wealth Management (Europe).
Member of the Supervisory Board: Damartex, Somfy.
2017 Directorship in the HSBC Group:
Independent Director: HSBC Continental Europe.
Directorships outside of the HSBC Group:
Chairman: Klefi Conseil. Director: CA Indosuez Wealth
Management (Europe). Member of the Supervisory Board:
Damartex, Somfy.
2016 –
Christine D'Amore
Director elected by employees
5
Listed company
2018 Directorships in the HSBC Group: 2019 Directorship in the HSBC Group:
Independent Director: HSBC Continental Europe. Director: Independent Director: HSBC Continental Europe.
HSBC Bank Bermuda Limited. Directorships outside of the HSBC Group:
Directorships outside of the HSBC Group: Chairman of the Management Board: Galeries Lafayette
Chancellor: University of British Columbia. Governor and Group. Deputy Chairman and Chief Executive Officer:
Co-Founder: C.H.I.L.D. Foundation. Director: Clear Seas Motier. Chairman: Motier Domaines, Guérin Joaillerie.
Centre for Responsible Marine Shipping, Export Lead Director: Carrefour. Director: Lafayette Anticipation-
Development Canada, Canadian Institute for Advanced Fondation d’entreprise Galeries Lafayette (Founders
Research. College), INSEAD, Institut Français de la Mode. Chairman
2017 Directorships in the HSBC Group: of the Supervisory Board: La Redoute. Member of the
Independent Director: HSBC Continental Europe. Director: Steering Committee: Union du Grand Commerce de
HSBC Bank Bermuda Limited. Centre-Ville (‘UCV’). Elected member: Chambre de
Directorships outside of the HSBC Group: Commerce et d’Industrie de la région Paris Ile-de-France.
Chancellor: University of British Columbia. Governor and Member of the Supervisory Committee: BHV Exploitation.
Co-Founder: C.H.I.L.D. Foundation. Director: Clear Seas Chairman of the France Council: INSEAD. Chairman of the
Centre for Responsible Marine Shipping, Export Board of the consular higher education institution, ESCP.
Development Canada, Canadian Institute for Advanced Deputy Chairman: Association Alliance 46.2 Entreprendre
Research. en France pour le Tourisme. Member of the Great Council:
Cercle de l'Union Interalliée.
2016 Directorship in the HSBC Group:
Independent Director: HSBC Continental Europe. Director: 2018 Directorship in the HSBC Group:
HSBC Bank Bermuda Limited. Independent Director: HSBC Continental Europe.
Directorships outside of the HSBC Group: Directorships outside of the HSBC Group:
Chancellor: University of British Columbia. Governor and Chairman of the Management Board: Galeries Lafayette
Co-Founder: C.H.I.L.D. Foundation. Director: Clear Seas Group. Deputy Chairman and Chief Executive Officer:
Centre for Responsible Marine Shipping, Export Motier. Chairman: Motier Domaines, Guérin Joaillerie.
Development Canada, Canadian Institute for Advanced Lead Director: Carrefour. Director: Lafayette Anticipation-
Research. Fondation d’entreprise Galeries Lafayette (Founders
College), INSEAD, Institut Français de la Mode. Chairman
of the Supervisory Board: La Redoute. Member of the
Philippe Houzé Steering Committee: Union du Grand Commerce de
Independent Director Centre-Ville (‘UCV’). Elected member: Chambre de
Commerce et d’Industrie de la région Paris Ile-de-France.
Chairman of the Nomination Committee and of the Remuneration Member of the Supervisory Committee: BHV Exploitation.
Committee Chairman of the France Council: INSEAD. Deputy
First elected: 1999. Last re-elected: 2019. Term ends: 2022 Chairman: Association Alliance 46.2 Entreprendre en
France pour le Tourisme. Chairman of the Board of the
Principal position: Chairman of the Management Board, Galeries consular higher education institution, ESCP. Member of
Lafayette Group. the Great Council, Cercle de l'Union Interalliée.
Other directorships: Deputy Chairman, Chief Executive Officer 2017 Directorship in the HSBC Group:
and member of the Supervisory Board, Motier. Chairman of the Independent Director: HSBC Continental Europe.
Supervisory Board, La Redoute. Lead Director then Deputy Directorships outside of the HSBC Group:
Chairman (since April 2020), Carrefour6. Director, Lafayette Chairman of the Management Board: Galeries Lafayette
Anticipation – Fondation d’entreprise Galeries Lafayette (Founders Group. Deputy Chairman and Chief Executive Officer:
College). Member of the Board, INSEAD. Member of the Steering Motier. Chairman: Motier Domaines, Guérin Joaillerie.
Committee, Union du Grand Commerce de Centre-Ville (‘UCV’). Lead Director: Carrefour. Director: Lafayette Anticipation-
Elected Member, Chambre de Commerce et d’Industrie de la région Fondation d’entreprise Galeries Lafayette (Founders
Paris Ile-de-France. Member of the Great Council, Cercle de l'Union College), INSEAD, Expofrance 2025, EESC ESCP, Institut
Interalliée. Chairman of the France Council, INSEAD. Chairman of Français de la Mode. Member of the Steering Committee:
the Board of the consular higher education institution, ESCP. Union du Grand Commerce de Centre-Ville (‘UCV’). Elected
Deputy Chairman, Association Alliance 46.2 Entreprendre en member: Chambre de Commerce et d’Industrie de la
France pour le Tourisme. Directorships expired in 2020: Member of région Paris Ile-de-France. Member of the Supervisory
the Supervisory Committee, BHV Exploitation. Chairman, Motier Committee: BHV Exploitation. Deputy Chairman:
Domaines. Association Alliance 46.2 Entreprendre en France pour le
Number of positions held within the meaning of L. 511-52 of the Tourisme. Chairman of the France Council: INSEAD.
French Monetary and Financial Code: one directorship as Chairman of the France Board of Governors, ESCP Europe.
executive and one directorship as member of a Board of Directors Chairman of the Governing Board: Novancia Business
or a Supervisory Board. School. Member of the Great Council, Cercle de l'Union
Interalliée.
Skills and experience: Born in 1947. Graduate of a Bachelor
degree in Political Science and of an M.B.A. from the Institut
Européen d'Administration des Affaires (‘INSEAD‘). Director of
Galeries Lafayette since 1974 and Chairman of the Management
Board since 2003.
6
Listed company
7
Company owned by the Fimalac group.
8
Listed company.
9
Listed Company
10
Director standing for re-election at the Annual General Meeting to be held on 11 March 2021
11
Listed Company
The profiles of the Directors are diverse and complementary and the role of directors, as well as the latest Registration Document
cover the spectrum of business lines and risks associated with the and minutes of Board meetings for the past 12 months. In
activities of HSBC Continental Europe. According to the Articles of addition, the Company Secretary organises, to the new Director’s
Association, the Board of Directors has four members elected by intent and depending on his/her needs and priorities, a programme
the employees. of training sessions with HSBC Continental Europe’s main
executives in the business lines and functions. It is also offered to
The Board includes four different nationalities and nearly two-
Directors in office to attend these sessions.
thirds of Directors have international experience. On 31 December
2020, the average age of the Directors in office is 60.6 and their In 2020, training sessions on the role and functioning of the
average seniority in the function is nearly seven years. Regulatory Affairs Department and Internal Audit were facilitated
by their respective Heads. In addition, Directors were invited to
Excluding Directors elected by employees, the Board comprises
attend to webinars organised by HSBC for the European week of
five women and seven men, i.e. 42 per cent of women and
sustainability and for the cyber awareness month. Furthermore,
58 per cent of men.
Directors took training in the form of e-learning on risk
Independent Directors management at HSBC, heath, safety and wellbeing, data privacy
and cybersecurity, financial crime risk, conduct and harassment at
With respect to the criteria on independence defined in the
work.
guidelines on the assessment of the suitability of members of the
management body issued by the European Banking Authority Meetings of the Board of Directors and of the Board’s Committees
(‘EBA’) and the European Securities and Markets Authority are also used as an opportunity to provide Directors with
(‘ESMA’) and by the HSBC Group, the Board of Directors information that is essential for them to carry out their duties, and
determines, on appointment and annually thereafter, whether each to update their knowledge.
non-executive Director may be considered as independent. To do Furthermore, a forum was organised for Audit and Risk
this, it examines whether there are relationships or circumstances Committees Chairs of the principal European entities of the HSBC
which are likely to affect, or could appear to affect, the Director’s Group.
judgement.
The Board should record its reasons if it determines that a Director
Directors’ remuneration
is independent notwithstanding the existence of relationships or The maximum total remuneration payable each year to Directors
circumstances which may appear relevant to its determination. was fixed at EUR 700,000, as decided by the Annual General
Meeting of 15 May 2017.
Based on the Nomination Committee’s report, the Board of
Directors reviewed the situation of each of its members as at This remuneration is allocated according to the following rules,
31 December 2020 in the light of these criteria. It considered that decided by the Board of Directors at its meeting on 6 February
eight Directors can be deemed independent. Nonetheless, two 2016 then modified on 8 February 2019:
Directors have served on the Board for more than 12 years. • each Director is allocated an annual flat fee of EUR 35,000, paid
Nevertheless, the Board of Directors found that this criterion alone at the conclusion of the Annual General Meeting;
did not call into question their independence vis-à-vis the
company. • the additional annual flat fee paid to Board Committees
members amounts to:
53.3 per cent of the Directors are independent; a higher proportion
than a third (excluding the Chairman of the Board), as – EUR 25,000 for the Chairmen of the Audit Committee and of
recommended by the Code. the Risk Committee;
Board evaluation – EUR 15,000 for the members of the Audit Committee and of
the Risk Committee;
Pursuant to the Code’s recommendations, a Board assessment
was conducted internally in July 2020, under the responsibility of – EUR 7,000 for the Chairmen of the Nomination Committee
the Nomination Committee and on the basis of a questionnaire and of the Remuneration Committee;
covering the following themes and covering the Board and the – EUR 6,000 for the members of the Nomination Committee
Board Committees: Strategy; risk and financial performance; and of the Remuneration Committee.
composition and structure; Executive oversight, talent and
Furthermore, within the HSBC Group, it is customary for Directors
succession; corporate culture and conduct; meeting process and
performing other executive duties in the Group and Executive
role of the Chair; role of the Company Secretary; self-assessment,
Directors to renounce their remuneration in respect of their
training and succession of Directors; behaviours; culture and
directorships held in HSBC Group companies. This
efficiency. Results of this evaluation and the update on main
recommendation has been implemented by the Directors and
actions implemented further to the evaluation conducted the year
Executive Directors of HSBC Continental Europe and its
before were discussed by the Nomination Committee and then by
subsidiaries.
the Board of Directors at its meeting of 24 July 2020.
In 2020, in respect of 2019, Jean Beunardeau, James Emmett,
The overall opinion regarding the Board and its Committees as
Laurence Rogier, Carola von Schmettow and Andrew Wild
well as their operations remains broadly positive. Proposals were
renounced the payment of their remuneration in respect of their
discussed by the Nomination Committee and the Board, which
directorship in HSBC Continental Europe. It has to be noted that,
decided to implement certain changes, including the lengthening
according to this rule, Samir Assaf, Chairman of the Board of
of the quarterly Board meetings.
HSBC Continental Europe, does not receive any remuneration from
Directors’ training and information HSBC Continental Europe for his office.
As required by the Board’s internal rules, Directors receive the
information they need to fulfil their duties and may ask to receive
any documents they deem useful. In particular, the Board and the
Board Committees may ask for a presentation on a particular
subject or issue at a future meeting.
Upon recommendation of the Nomination Committee, the Board
updated the policy on training of the management body's
members.
According to this policy, new Directors, when taking up duty,
receive an information pack on HSBC Continental Europe,
including, among others, legal information about the company and
Remunerations paid to Non-Executive Directors by HSBC Continental Europe, the companies it controls and the companies which
control it (the HSBC Group)
Remuneration in Remuneration in
respect of the respect of the
directorship directorship Other
paid in 2019 paid in 2020 in Other compensation compensation
in respect of 2018 respect of 2019 paid in 20191 paid in 20201
Directors performing their principal position in another entity of the
HSBC Group
James Emmett2,3,4 — — GBP 1,839,695 GBP 276,890
Nuno Matos3,5 — — — GBP 1,236,953
Carola von Schmettow6 — — — —
Directors elected by the employees
Ibtissam Bara7, 8 EUR 28,980 EUR 21,735 — —
Ludovic Bénard7,8 EUR 33,948 EUR 25,461 — —
Xavier Bertrand7,8 EUR 28,980 EUR 21,735 — —
Christine D'Amore8, 9 — EUR 7,245 — —
Laurent Lagueny8, 9 — EUR 7,245 — —
Philippe Purdy8,10 EUR 28,980 EUR 28,980 — —
Lucie Thalamas Dit Barathe8, 9 — EUR 7,245 — —
Directors not performing executive duties within the HSBC Group11
Paule Cellard EUR 45,500 EUR 41,125 — —
Lindsay Gordon EUR 63,200 EUR 65,400 — —
Philippe Houzé EUR 34,300 EUR 34,300 — —
Anne Méaux12 EUR 24,500 EUR 2,042 — —
Thierry Moulonguet EUR 50,750 EUR 52,500 — —
Dominique Perrier13 EUR 20,417 EUR 28,875 — —
Arnaud Poupart-Lafarge EUR 24,500 EUR 28,875 — —
Lucile Ribot EUR 45,500 EUR 41,125 — —
Brigitte Taittinger EUR 24,500 EUR 24,500 — —
Jacques Veyrat14 EUR 32,900 EUR 32,900 — —
1 Fixed and other fixed remuneration, variable remuneration and benefits in kind.
2 Co-optation on 26 October 2018.
3 Compensation shown are paid by other HSBC Group companies in respect of his/her executive functions within the Group.
4 Resignation from his directorship on 16 March 2020.
5 Co-optation on 30 April 2020.
6 Does not receive remuneration from controlled companies by HSBC Continental Europe nor from companies which control HSBC Continental
Europe.
7 End of Directorship on 26 September 2019.
8 Renounced remuneration to the benefit of a trade union organisation, net of social contributions.
9 Election by employees on 26 September 2019.
10 Died on 9 September 2020.
11 Amounts paid net of social contributions, income tax prepayment, and, where applicable, withholding tax.
12 Resignation from her directorship on 23 January 2019.
13 Co-optation on 20 February 2018.
14 Resignation from his directorship on 6 February 2020.
Duties and procedures of the Board of Directors Impacts of the Covid-19 pandemic on the Board's work
The Board internal rules govern Board’s functioning and include In 2020, the Board stepped up its work and concentrated on the
the main duties under Board’s responsibility. The Board's close monitoring of the evolution of the impacts and risks
functioning takes into account HSBC Continental Europe’s associated to the Covid-19 pandemic in particular in terms of
position, 99.9 per cent held by the HSBC Group: operational resilience, capital and liquidity, credit, market, fraud
and people risks. In total, it met ten times during the year, by
• it constructively challenges the strategy and determines
teleconference from March 2020, which did not have a negative
strategic orientations, on the basis of the strategy formulated
impact on its ability to carry out its work and to discharge its usual
by General Management and oversees and monitors their
responsibilities. Between these Board meetings, the Chief
implementation. It approves strategic investments/divestments
Executive Officer very regularly kept the Directors informed of
and all transactions liable to impact earnings significantly;
developments in the situation.
• it oversees and monitors management decision-making and
Businesses and strategy
actions and provides effective oversight of the effective
managers and constructively challenges and critically reviews At each meeting, the Board was informed of developments in
proposals and information provided by the effective managers, business activity, the group’s position, the important stakes for
as well as their decisions; each of its businesses, and transformation projects.
• it oversees and monitors that HSBC Continental Europe’s In the meeting held on 6 July 2020, the Board of Directors
strategic objectives, organisational structure and risk strategy, approved the company’s strategic directions. It took note of the
including its risk appetite and risk management framework, as opinions issued by the Social and Economic Council on the
well as other policies (e.g. remuneration policy) and the company’s economic and financial situation and on strategic
disclosure framework are implemented consistently. directions respectively at its meeting on 24 July and 23 October
2020.
• it monitors and supervises major risks and reviews regular risk
management reports, setting out the risks involved in the HSBC As part of the implementation of the strategy, the Board reviewed
Continental Europe’s business and results; and approved the repositioning projects of Global Banking and
Markets and Commercial Banking and of certain central functions
• it monitors that the risk culture is implemented consistently;
and the associated departure plans respectively at its meetings on
• it sets HSBC Continental Europe’s values and principles and 6 July and 4 December 2020. The transformation project for the
oversees the implementation and maintenance of a code of HSBC Continental Europe branches was presented to the Board at
conduct or similar and effective policies to identify, manage its meeting on 23 October 2020.
and mitigate actual and potential conflicts of interest;
The Board was kept regularly informed of the progress of the
• it oversees the integrity of financial information and reporting, strategic review of the retail banking activities.
and the internal control framework, including an effective and
After having approved the principle respectively at its meetings on
sound risk management framework;
16 October 2019 and 29 May 2020, the Board, at its meeting on
• it ensures that the heads of internal control functions, namely 23 October 2020, formally approved the change of the head office
the Chief Risk Officer, the Head of Regulatory Compliance, the and of the corporate name of the company from 1 December
Head of Financial Crime Compliance and the Head of Internal 2020. The change of corporate name was also approved by the
Audit, are able to act independently and, regardless the shareholders' general meeting held on 12 November 2020.
responsibility to report to other internal bodies, business lines
In 2020, The Board of Directors also continued its work on the
or units, can raise concerns and warn the Board where
impacts ot the United Kingdom's exit from the European Union,
necessary when adverse risk developments affect or may affect
which focused in particular on the booking models and the update
the institution;
of the outsourcing policy.
• it deliberates on all questions pertaining to its legal and
The Board regularly benefited from the comments and insight of
regulatory obligations and those stemming from its articles of
the Chairman of the Board, who is also Chairman of Corporate and
association;
Investment Banking of the HSBC Group, and Nuno Matos, who is
• it cares about HSBC Group's reputation in France. also Chief Executive Officer of the Europe region for the HSBC
In the week prior to the meeting, the Directors receive the meeting Group, on the HSBC Group’s development, results, strategy, latest
file, including the agenda, the draft minutes of the previous Board news, as well as trends in the world economic and regulatory
meeting and supporting papers to the agenda items to be environment. The Independent Directors, for their part, shared
discussed at the meeting. In the case of highly confidential with the Board their view of the economic situation and economic
matters, which cannot be disclosed in advance, the information is conditions in their business sector.
provided during the meeting itself. Furthermore, Directors are Finance
regularly advised of significant events affecting the company and
In 2020, the Board of Directors reviewed the quarterly, half-yearly
receive the relevant documents.
and annual financial statements and signed off the half-yearly and
Board of Directors’ work annual financial statements. At each of its meetings, the Board
reviewed HSBC Continental Europe’s revenue, costs, results and
The Board of Directors met ten times during 2020. The average
balance sheet. For each period reviewed, the Board heard the
attendance rate was 88 per cent, compared to 80 per cent in 2019:
conclusions of the Statutory Auditors, who were invited to attend
• 6 February 2020 (attendance rate: 94 per cent); all Board meetings.
• 18 February 2020 (attendance rate: 76 per cent);
• 30 March 2020 (attendance rate: 88 per cent);
• 30 April 2020 (attendance rate: 100 per cent);
• 29 May 2020 (attendance rate: 100 per cent);
• 6 July 2020 (attendance rate: 76 per cent);
• 24 July 2020 (attendance rate: 94 per cent);
• 31 July 2020 (attendance rate: 71 per cent);
• 23 October 2020 (attendance rate: 100 per cent);
• 4 December 2020 (attendance rate: 81 per cent).
Audit Committee’s duties letter and the aspects subject to particular attention at the time of
preparing the 2019 financial statements. The Committee discussed
The Audit Committee is accountable to the Board and has non-
the Statutory Auditors’ audit programme and independence,
executive responsibility for oversight of and advice to the Board on
approved the fees paid in 2019 by the HSBC Continental Europe
matters relating to the budget, financial reporting, internal control
group to the Statutory Auditors. The Committee reviewed and
of financial information, capital and liquidity ratios to support the
authorised as necessary the non-audit services rendered by the
Risk Committee, the dividend policy and capital allocation,
statutory auditors.
management of the Finance function and Internal Audit.
Statutory Auditors presented their diligences on the financial
The Committee in particular reviews:
statements at 31 March 2020, 30 June 2020 and 30 September
• the integrity of the financial statements, Pillar 3 disclosures, 2020 (meetings on 27 April, 17 July and 20 October 2020), as well
formal announcements and disclosures relating to financial as their annual audit plan (meeting on 17 July 2020).
performance;
The Committee was also informed of the results of controls
• the effectiveness of Internal Audit and the external audit conducted on financial statements, in particular regarding the
process; deficiencies identified by these controls and progress in action
• the effectiveness of internal financial control systems. plans. Within this framework, it reviewed the work carried out as
part of the application of Sarbanes-Oxley and reviewed the points
The Committee meets the Statutory Auditors and the Head of raised in the account controls certificates and by accounting
Internal Audit in private at least once per year to ensure that there assurance reviews, as well as implementation of the
are no unresolved issues or concerns. In carrying out these duties recommendations raised in the Statutory Auditors’ management
and responsibilities, the Committee may consult any adviser or letters.
expert as it deems appropriate.
In terms of data management, the Committee was kept regularly
To give itself sufficient time to review the accounts before they are informed of the progress of the development of the framework
reviewed by the Board, the Audit Committee meets a few days and action plans, in particular, in relation with BCBS 239
before the Board insofar as possible. application and reviewed the proposals relating to the introduction
Lastly, at the request of the HSBC Bank plc’s Audit Committee, the of indicators in the risk appetite monitoring dashboard.
HSBC Continental Europe’s Audit Committee Chairman provides a At its meeting on 20 October 2020, the Committee examined the
half-yearly certificate to the Audit Committee Chairman of HSBC list of the related-party agreements authorised previously by the
Bank plc, HSBC Continental Europe’s direct shareholder, Board and still in force and made recommendations to the Board
confirming, in particular, that the accounts were reviewed by the regarding the list update.
Committee and that the internal control system of financial At its meeting on 17 July 2020, the Committee was given a
reporting appears to be appropriate. presentation on the framework in place regarding whistleblowing
Audit Committee’s work in 2020 and its results.
The Audit Committee met four times in 2020, with an attendance The third aspect of the Committee work concerned the detailed
rate of 100 per cent, as in 2019: review, at each meeting, of Internal Audit work. It reviewed the
findings of the main audit duties, particularly those calling
• 4 February 2020; particular attention. The Committee remained extremely attentive
• 27 April 2020; to the proper implementation of the audit recommendations. It has
also approved the update of the audit charter and the 2020 annual
• 17 July 2020;
audit plan (meeting on 4 February 2020) and regularly discussed
• 20 October 2020. on Human Resources of Internal Audit.
Each meeting was also attended by the Statutory Auditors, the The Committee carried out the annual review of its terms of
Chief Financial Officer, the Chief Accounting Officer, the Head of reference (meeting on 4 February 2020).
Audit and the Chief Risk Officer. The Chief Executive Officer and
The Chairman of the Audit Committee reported on the key points
one of the two Deputy Chief Executive Officers also attended
discussed during Audit Committee meetings at the Board
Committee meetings to answer any questions. HSBC Continental
meetings held on 6 February, 30 April, 24 July and 23 October
Europe executives also attend Committee meetings covering any
2020.
subjects falling under their responsibility. The Committee
Chairman also met with the Statutory Auditors in private sessions Risk Committee
during the year.
Composition of the Risk Committee
The first aspect of the Committee’s work involved an in-depth
review of the annual, half-yearly and quarterly financial statements Chairman
prior to their presentation to the Board. The Audit Committee Lindsay Gordon (independent) Appointed in 2015
reviewed the parent-company and consolidated accounts. The (Member from 2013 to 2015)
Committee was informed by the Finance Department of the main Members
accounting and tax points of attention and discussed the choices Paule Cellard (independent) Appointed in 2017
made by the company in drawing up its financial statements and Thierry Moulonguet (independent) Appointed in 2009
verified the adequacy of provisions for identified risks. The (Chairman from 2010 to 2015)
Committee's work concentrated, in particular, on the impacts of Arnaud Poupart-Lafarge (independent) Appointed in 2019 – Resignation in
the Covid-19 pandemic on the accounting valuation of assets. October 2020
The Committee examined the budget for 2020 financial year The Committee members are highly qualified in the banking,
(meeting on 4 February 2020) and then the update of performance financial, risk and internal control areas, as they serve or have in
forecast at year-end. Once throughout the year, it paid careful the past served in the capacity of Chairman or Chief Executive
attention to monitoring the cost base and on recharges processes Officer of a bank, with operational responsibilities within a Global
in place in the HSBC Group. Banking activities or as Head of internal audit and compliance of a
At each meeting, the Committee was informed of the situation in bank, Risk Committee member, Chief Operating Officer or Chief
terms of solvability and capital of HSBC Assurances Vie (France) Financial Officer.
and of the changes in the models used to compute the Present
Value of In-Force (‘PVIF’) as well as their impact on the P&L.
The second area of the Committee’s work concerned controls. To
this end, the Statutory Auditors commented on their management
In the area of financial crime compliance, the Committee Nomination Committee’s work in 2020
continued in 2020 to monitor carefully the developments in works,
The Nomination Committee met four times in 2020, with an
organisation, tools and implementation of recommendations made
attendance rate of 100 per cent as in 2019. Its main work
by the various control bodies concerning anti-money laundering,
concerned:
international sanctions and anti-bribery and corruption, as well as
staffing changes, engagement with control and supervisory • the monitoring of the individual and collective suitability of the
authorities and duties performed by these authorities on these management body pursuant to the suitability assessment policy
matters. and assessments and reassessments required by the criteria
defined in this policy;
In the area of regulatory compliance, the Committee took note of
the quarterly reports, which set out the main new matters and • reflections, and recommendations to the Board, on the
updates on those already detailed in the course of previous membership of the management body in its supervisory
meetings. It also examined the progress made in action plans function – including that of the Board Committees – and
implemented under the HSBC Group’s Conduct programme as management function, based on the suitability assessment and
well as the Ombudsman’s annual report (meeting on 21 October diversity policies, following, in particular the resignations of
2020). James Emmett, Laurence Rogier and Jacques Veyrat, and the
death of Philippe Purdy, leading the Committee to propose to
The Committee approved the annual reports to the Autorité de
the Board the co-optation of a new Director: Nuno Matos;
contrôle prudentiel et de résolution on internal control and on the
organisation of the financial crime compliance framework • proposals to the Board on renewing Directors’ term of office at
(meeting on 28 April 2020) and took note of other reports intended the Annual General Meeting to be held in 2021 (meeting on
for the supervisory authorities. 9 December 2020);
The Committee was informed of communications with supervisory • the training plan of the management body for 2021 (meeting on
bodies and of the conclusions of various audits and reviews 9 December 2020);
carried out by supervisory and control bodies, such as the Autorité • the review of the results of the Board evaluation and proposal
des Marchés Financiers, the European Central Bank, the Autorité to the Board of actions to implement (meeting on 15 July
de Contrôle Prudentiel et de Résolution, the Prudential Regulation 2020);
Authority, or the Agence Française Anticorruption and received
reports and follow-up letters and replies to them in relation to • the review and proposal to the Board to approve the updated
these assignments, as well as action plans initiated to implement register of potential situations of conflict of interest (meeting on
their recommendations. 30 January 2020);
The Committee was informed of the works performed by HSBC • the review of the first part of the new report on corporate
Continental Europe regarding recovery and resolution and carried governance (meeting on 30 January 2020);
out as part of the HSBC Group's obligations towards the • the review and proposals to the Board for updating the Board
Prudential Regulation Authority or of its own ones towards the internal rules and the Board policies regarding assessment of
Single Resolution Committee. the suitability of the management body's members and key
Again in 2020, the Committee remained attentive to developments function holders, and diversity of the management body.
in the regulatory and supervisory environment in which HSBC The Chairman of the Nomination Committee reported to the Board
Continental Europe operates and to their impacts. on its work at the Board meetings on 6 February, 30 April and 24
In relation to other governance matters, the Committee reviewed July 2020. All of the Committee’s work was submitted to the
the remuneration policy and carried out the annual review of its Board for approval.
terms of reference (meeting on 4 February 2020). Remuneration Committee
The Chairman of the Risk Committee reported on the key points
discussed during Risk Committee meetings at the Board meetings Composition of the Remuneration Committee
held on 6 February, 30 April, 24 July and 23 October 2020. Chairman
. Philippe Houzé (independent) Appointed in 2009
Nomination Committee (Member from 1999 to 2009)
Members
Composition of the Nomination Committee Samir Assaf Appointed in 2012
Chairman Laurent Lagueny (elected by employees) Appointed in 2020
Philippe Houzé (independent) Appointed in 2009 Arnaud Poupart-Lafarge (independent) Appointed in 2020
(Member from 1999 to 2009)
Members
In accordance with the Governance Code for the companies of the
Samir Assaf Appointed in 2012
HSBC Group, at least two members of the Remuneration
Arnaud Poupart-Lafarge (independent) Appointed in 2020
Committee are independent non-executive Directors.
At its meeting on 6 February 2020 and upon recommendation
In accordance with the Governance Code for the companies of the from the Nomination Committee, the Board of Directors decided
HSBC Group, at least half of the Nomination Committee’s to appoint Laurent Lagueny and Arnaud Poupart-Lafarge as
membership are independent non-executive, non-employee members of the Remuneration Committee, replacing Ludovic
Directors. Bénard and Jacques Veyrat.
At its meeting on 6 February 2020 and upon recommendation
from the Nomination Committee, the Board of Directors decided
to appoint Arnaud Poupart-Lafarge as a member of the
Nomination Committee, replacing Jacques Veyrat.
Nomination Committee’s duties
The Nomination Committee reports to the Board and is
responsible for leading the process for Board and Board
Committees appointments and for identifying and nominating for
the approval of the Board, candidates for appointment to the
Board and its Committees.
In carrying out these duties and responsibilities, the Committee
may consult any adviser or expert as it deems appropriate.
General Management
Since 2007, HSBC Continental Europe’s Board of Directors has
chosen to separate the functions of Chairman of the Board and
Chief Executive Officer. This choice has been maintained since
then and is furthermore in compliance with obligations for credit
institutions.
Organisation of the General Management
General Management leads the Company and acts as its
representative vis-a-vis third parties. General Management
12
Tables numbers refer to table models provided by the Autorité des marchés financiers in its 10 December 2009, as amended lastly on 13 April
2015, recommendation 2009-16 concerning the guide for compiling registration documents.
Performance shares which became available for each Executive Director in 2020 (Table 7)
Number of shares
which became
available during
Date of award the year Vesting conditions
None
HSBC Holdings plc shares vested for each Executive Director in 2020 (Table 8)
Vesting conditions (in
Date of award Number of shares vested1 case of special conditions)
Jean Beunardeau 2/3/2015 18,676 Performance shares
Jean Beunardeau 27/2/2017 11,409 —
Jean Beunardeau 28/3/2018 11,503 —
Jean Beunardeau 26/3/2019 12,249 —
Jean Beunardeau 24/2/2020 35,533 —
Andrew Wild 27/2/2017 1,932 —
Andrew Wild 28/3/2018 2,155 —
Andrew Wild 26/3/2019 2,933 —
Andrew Wild 24/2/2020 20,978 —
Chris Davies 27/2/2017 3,657 —
Chris Davies 26/2/2018 3,017 —
Chris Davies 26/3/2019 3,519 —
Chris Davies 24/2/2020 25,760 —
1 The shares awarded under the UK plan in 2017, 2018 , 2019 and 2020 are available six or twelve months after the vesting.
The shares awarded in 2017 were vested for 20 per cent in 2020.
The shares awarded in 2018 were vested for 20 per cent in 2020.
The shares granted in 2019 were vested for 20 per cent in 2020.
The shares awarded in 2020 were vested for 100 per cent in 2020.
HSBC Holdings plc free shares, without performance conditions, awarded in 2020 in respect of 2019, to the 10 employees whose
number of awarded shares is the highest (Table 10)
Number of
shares
Date of award awarded Value of the shares at grant Vesting date1 Date of availability1
Total value of the 10 highest awards of March 2022 for 66 % and 6 or 12 months after the
shares (employees or former employees) 24/2/2020 ND EUR 3,336,365 March 2023 for 34 % award
1 Part of the free shares awarded to employees considered as Material Risk Takers (cf. page 39 vests immediately and is available for sale after six
months of vesting.
HSBC Holdings plc free shares, without performance conditions, awarded in 2020 in respect of 2019, to the 10 employees whose
number of awarded shares is the highest
Number of
shares
Date of award awarded Value of the shares at grant Vesting date1 Date of availability1
March 2021 or March 2023
for 66% and March 2024 for
34% or March 2022 to 2026
Total value of the 10 highest awards of for 20% per year or March 6 or 12 months after the
shares (employees or former employees) 24/2/2021 ND EUR 2,823,199 2022, 2023, 2024 per tiers award
1 Part of the free shares awarded to employees considered as Material Risk Takers (cf. page 39) vests immediately and is available for sale six
months or a year after the vesting.
HSBC Holdings plc free shares, without performance conditions, vested in 2020, for the 10 employees whose number of awarded
shares is the highest
Number of shares
vested1 Vesting dates
Total value of the 10 highest awards of shares, vested in 2020 (employees or former employees) 612,913
– of which award 2017 80,903 12.03.2020
– of which award 2018 99,472 11.03.2020
– of which award 2019 90,634 10.03.2020
– of which award 2020 341,904 24.02.2020
1 The shares awarded in 2017 and 2018 are available for sale six months after the vesting; those granted in 2019 are available 12 months after the
vesting and those granted in 2020 under the UK plan are available for sale six or 12 months after the vesting.
Compensation policy for employees whose professional maintain an appropriate financial capacity in the Covid 19 crisis
activities have a significant impact on the risk profile of context (SSM-2020-0315 of 28 July 2020 and SSM-2020-0763 of
the business 15 December 2020).
The following information is published in accordance with article Two committees – the People Committee, in its limited perimeter,
266 of the order of 3 November 2014 on internal control of and the Remuneration Committee – play a predominant role in the
banking sector companies, based on articles L. 511-64, L. 511-71 overall process of implementing this policy.
and L. 511-72 of the French Monetary and Financial Code and In accordance with the article L 511-74 of the Code Monétaire et
article 450 of (‘UE’) regulation 575/2013. Financier, the compensation policy is submitted to an independent
Decision-making process implemented to define the audit, once a year, performed by the Internal Audit department.
company’s compensation policy The compensation policy is also approved by the local Regulatory
Compliance department.
As HSBC Continental Europe is part of an international banking
group, its compensation policy is defined at the level of the parent The People Committee, in its limited perimeter, made up of the
company. As part of a delegation by the HSBC Group’s Board of main Senior Executives of HSBC Continental Europe (the Chief
Directors, the HSBC Group’s Remuneration Committee is Executive Officer, the Deputy Chief Executive Officer in charge of
responsible for approving the compensation policy for the HSBC the Commercial Banking, the Chief Risk Officer, the Head of
Group as a whole. Human Resources ), reviews the main aspects of the
compensation policy proposed by HR function for France and
The compensation policy in place in France falls within the
framework of this global policy, while also ensuring that local
regulations, in particular those arisen from European Directive
CRD III of July 2010 repealed by the Directive CRD IV of June
2013, since 1 January 2015 from AIFM Directive, since 1 January
2016 from Solvency II Directive and since 1 January 2017 from
UCITS Directive are observed.
Especially in 2020, remuneration policy included ECB
recommendations on the need to moderate the variable pay pools,
in particular those awarded to Material Risk Takers, aiming to
Finally, it reviews the remuneration of any Executive Directors, of All targets are formally documented at the beginning of the year,
Head of Risk and Head of Regulatory Compliance and submit its in annual employee target sheets (performance scorecards).
proposals to the Board. In compliance with the rules under CRD III and CRD IV directives,
Main characteristics of the compensation policy some employee categories are subject to specific rules regarding
variable compensation award. These employees, considered to
At HSBC Group level, the compensation policy defined takes into have an impact on the entity’s risk profile (‘Material Risk Takers’),
account, on one hand, the sustainable financial performance and were identified on the basis of qualitative and quantitative criteria
the commercial competitiveness of the company as a whole and defined by the European Banking Authority in March 2014.
each of its businesses and, on the other hand, the overall Pursuant to these criteria, the HSBC Group, which is itself
performance regarding risk management, and finally the submitted to this regulation, identified at HSBC Continental Europe
company’s capacity to fund this policy on its own profit. level a list of 65 employees coming under this Material Risk Takers
The main performance indicator used by the HSBC Group, to set category.
variable compensation budgets, is the profit before tax before As these new criteria have to be applied both at a consolidated
variable compensation and excluding the change in value of own and an individual basis, an additional list of 67 employees who
debt due to credit spread and capital gains or losses on can have a significant impact on the company’s risk profile at a
businesses’ and subsidiaries’ disposals. local level was added to this list of Material Risk Takers identified
On the other hand, it includes model and credit risk provisions. at HSBC Group level.
Variable compensation budgets on a global basis and by This whole list of 132 employees includes mainly the executive
businesses are reviewed and approved by the Group Chief Risk directors, the heads of business lines, the heads of risk functions
Officer, the Group CEO, the Group Chief Financial Officer and the and the market operators who have an impact on the company’s
Group Remuneration Committee. Once these variable risk profile.
compensation budgets are approved, they are divided, for each
business/segment/product/function by regions and countries
depending on their respective performance. Local performances
are measured on one hand through financial metrics such as
evolution of Profit Before Tax, growth in revenue on strategic
For this population, variable remuneration are limited to twice the • Executive Directors: Chief Executive Officer and deputy Chief
fixed remuneration, according to the decision made by HSBC Executive Officer;
Continental Europe shareholders’ general meeting held on 23 May • Key functions: Heads of Risk functions, Head of Compliance,
2014. In order to maintain the competitiveness of Material Risk Head of Actuarial, Head of Audit;
Takers remuneration, Group has modified the remuneration of
several of them by allocating a monthly fixed pay allowance linked • Head of Finance: Board committee member of HSBC
to their function. In addition their variable remuneration is deferred Assurances Vie (France) and under his strategic function in the
by 40 per cent and even by 60 per cent for the highest variable. company.
Finally, variable remuneration granted in the form of shares
* except two members who have the status of external ‘non executive’
accounts for 50 per cent of variable remuneration granted; this 50
Director.
per cent applies to both the deferred component and to its
immediately paid fraction. In 2020, 17 employees have been identified as risk takers under
It should be noted that if the variable remuneration amount is Solvency II.
lower than 33 per cent of total remuneration and lower than Impact on the variable remuneration
EUR 100,000, the variable remuneration is granted in cash
immediately paid and deferred shares according to HSBC Group For this population, a part of their variable remuneration is
standard deferred rules. deferred. This deferred part comprises shares that totally vest after
a three years vesting period and that is applied under specific
For this population as a whole, 42 per cent of variable conditions described below:
remuneration is deferred, and variable remuneration represents
37 per cent of total remuneration. For French employees, the • 60 per cent of the variable remuneration is deferred when its
deferred share-based portion is not vested by the employee until total amount is equal or above GBP 500,000;
after either a period of two years for 66 per cent and after three • 40 per cent of the variable remuneration is deferred when its
years for the remaining 34 per cent or a period of two years for 40 total amount is under GBP 500,000.
per cent, three years for 20 per cent, four years for 20 per cent and
However, risk takers whose variable remuneration is lower than
five years for the remaining 20 per cent. This is furthermore
GBP 500,000 (or an equivalent amount in local currency) and
subject to a six-month or one-year retention period starting from
whose variable remuneration is under 33 per cent of their total
vesting, and there is a prohibition on hedging it.
compensation, are considered as ‘de minimis’. On this basis, they
For impatriates or employees working in European branches, are subject to Group deferral standard rules.
deferred shares vest over three years (33 per cent, 33 per cent, 34
It should be noted that beyond this Material Risk Takers
per cent).
population, the great majority of the company’s senior managers
With effect from 1 January 2017, management companies under are affected by the minimum deferred compensation rules laid
certain conditions are governed by the UCITS Directive in addition down by the HSBC Group which, for 2020, provide for deferred
to the Alternative Investment Funds Management (‘AIFM’) compensation in the form of shares of between 10 per cent and
Directive already in place since 1 January 2015. In accordance 50 per cent of variable compensation, and to which the above
with these Directives, categories of employees of HSBC Global rules on vesting apply. Nevertheless, deferred shares are no longer
Asset Management (France) and HSBC REIM (France) are subject subject to any retention period.
to specific rules in term of variable remuneration. The employees
Lastly, since disclosure of ‘Loi Pacte’, a ‘Malus’ system now
concerned, are those whose professional activity has a significant
applies to all employees receiving deferred bonuses. This allows
impact on the risk profile of the management company or its
the HSBC Group’s Remuneration Committee to cancel, reduce or
alternative investment funds. The list of these risk takers mainly
amend all or part of bonuses awarded on the basis of the
comprises Executive Directors, Heads of Risk functions, Finance
employee’s behaviour or factors justifying such action.
function and Legal function, Heads of Sales, Heads of Funds
Management and Head of Branches. In 2020, a total of 46 risk To be also noted that all vested awards are subject to the Group
takers have been identified. For this population, subject to having ‘Clawback’ policy.
a variable remuneration of more than EUR 200,000 and
representing more than 30 per cent of fixed pay, variable
remuneration is 40 per cent deferred if it is lower than GBP
500,000 and 60 per cent deferred for variable remuneration of
more or equal to GBP 500,000. For risk takers with a variable
remuneration deferred at 40 per cent, the variable remuneration is
composed as follows:
50 per cent in immediate cash,10 per cent in cash variable indexed
on the funds’ performance, 40 per cent in cash variable deferred
one-third over three years and indexed on the funds performance.
For risk takers with a variable remuneration deferred at 60 per
cent, the variable remuneration is composed as follows: 40 per
cent in immediate cash,10 per cent in deferred cash that vest in
three annual tranches, 50 per cent in cash variable deferred one-
third over three years and indexed on the fund's performance. Risk
takers who do not meet the conditions above are subject to Group
deferral standard rules.
Finally, with effect from 1 January 2016, HSBC Assurance Vie
employees identified as risk takers under Solvency II Directive are
bound by the remuneration requirements set out in this directive.
Eligible employees
In accordance with this Directive, categories of employees of
HSBC Assurances Vie (France) identified as risk takers are subject
to specific rules in term of variable remuneration. The employees
concerned are:
• Board of Directors members*;
Remuneration awarded to Executive members and professionals whose roles have a significant impact
on risk profile of the company
Total remuneration: distribution between fixed pay and variable pay
Total remuneration
Number of people 2020 Total fixed pay Total variable pay
concerned € € €
Executive members 3 4,029,581 2,305,044 1,724,537
Global Banking and Markets 38 26,205,719 16,633,864 9,571,855
Retail Banking 14 7,158,458 4,127,302 3,031,156
Private Banking 5 1,987,202 1,133,000 854,202
Commercial Banking 10 3,119,179 2,065,000 1,054,179
Global Functions and Other 39 9,321,641 6,927,403 2,394,238
Total (France perimeter) 109 51,821,780 33,191,613 18,630,167
Total (international perimeter) 23 10,823,132 6,565,096 4,258,036
Total (France and International perimeter) 132 62,644,912 39,756,709 22,888,203
Total variable pay: distribution between payments in cash and payments in shares
Payments in Payments in Total variable
cash shares pay
€ € €
Executive members 862,269 862,269 1,724,537
Global Banking and Markets 4,818,927 4,752,927 9,571,855
Retail Banking 1,571,378 1,459,778 3,031,156
Private Banking 454,101 400,101 854,202
Commercial Banking 527,090 527,090 1,054,179
Global Functions and Other 1,636,548 757,691 2,394,238
Total (France perimeter) 9,870,312 8,759,855 18,630,167
Total (international perimeter) 2,216,176 2,041,860 4,258,036
Total (France and International perimeter) 12,086,488 10,801,715 22,888,203
Total variable pay: distribution between non deferred and deferred amount
Non-deferred
amount Deferred amount Total variable pay
€ € €
Executive members 848,215 876,322 1,724,537
Global Banking and Markets 5,239,530 4,332,325 9,571,855
Retail Banking 1,697,758 1,333,398 3,031,156
Private Banking 534,121 320,081 854,202
Commercial Banking 632,507 421,672 1,054,179
Global Functions and Other 1,781,953 612,285 2,394,238
Total (France perimeter) 10,734,084 7,896,083 18,630,167
Total (international perimeter) 2,624,548 1,633,488 4,258,036
Total (France and International perimeter) 13,358,632 9,529,571 22,888,203
Total deferred variable pay: distribution between payments in cash and payments in shares
Payments in Payments in Total deferred
cash shares variable pay
€ € €
Executive members 438,161 438,161 876,322
Global Banking and Markets 2,162,662 2,169,662 4,332,325
Retail Banking 320,436 1,012,962 1,333,398
Private Banking 160,040 160,040 320,081
Commercial Banking 210,836 210,836 421,672
Global Functions and Other 290,810 321,475 612,285
Total (France perimeter) 3,582,946 4,313,137 7,896,083
Total (international perimeter) 816,744 816,744 1,633,488
Total (France and International perimeter) 4,399,690 5,129,881 9,529,571
This table shows outstanding deferred variable pay corresponding ‘malus’ mechanism or early departure. Shares and equivalent
to total unvested deferred remuneration before the 31 December instruments are valued on the share value as at 31 December
2020, i.e. variable pay that has been awarded but not yet paid 2020. Outstanding vested variable pay in respect of prior year can
(cash) or delivered (shares) and which is still subject to a future be impacted by departures from the company.
The first column corresponds to all sums paid on termination of the employment contract (severance payment), which include
redundancy compensation and contractual indemnities.
Number of Contribution to
people defined benefit plan
concerned €
Executive members 1 549,794
Global Banking and Markets — —
Retail Banking and Private Banking — —
Commercial Banking — —
Global Functions and Other — —
Total (France perimeter) 1 549,794
Total (international perimeter) — —
Total (France and International perimeter) 1 549,794
Total remuneration
Number of
Material Risk
Takers
Between 1 million and 1.5 million excluded 4
Between 1.5 million and 2 million excluded 1
Between 2 million and 2.5million excluded 2
Total 7
1 Including 4 Executive managers who are already in the CRD IV material risk takers.
1 Including 11 Executive managers who are already in the CRD IV material risk takers.
(Annual General Meeting for the approval of the financial statements for the year ended 31 December 2020)
HSBC has set itself the task of bringing together people and The HSBC Group remains committed to listening to customers,
opportunities. The goal creates for us a duty of care to our whose feedback has helped us improve our products and services.
customers, to society in the broad sense of the term and to the We also have clear policies, frameworks and governance in place
integrity of the financial system. to protect our customers. These cover the way we behave, design
products and services, train and incentivise employees, and
Non Financial risks
interact with clients.
HSBC uses a variety of tools to identify and manage its non-
The Bank will keep on working to simplify processes and optimise
financial risks, including its appetite for risk, risk mapping, a list of
the customer experience, particularly in terms of being
top and emerging risks and stress testing. It also relies on surveys
contactable, having pro-active relationship managers and
involving employees and customers, dialogue with customers and
improving the customer pathway.
investors, and the annual ESG survey carried out among investors.
To guide this work, we measure and report on customer
In 2020, HSBC Continental Europe reviewed the environmental,
satisfaction data for all of our business lines within our Strategy
social and governance risk map that it had prepared in 2019. This
Report.
analysis of the most material ESG risks over the short, medium
and long term identifies nine ESG themes that present a material
risk for HSBC Continental Europe, along with three themes
required by the 19 July 2017 order relating to the publication of
non-financial information:
• Four risks relating to banking activity:
– Risk of customer disappointment (theme 1)
– Risk relating to the non-alignment of emissions financed
with a net zero pathway (theme 2)
– Risk relating to the non-alignment of the bank’s operational
carbon footprint with a net zero pathway (theme 3)
Monitoring customer recommendation and satisfaction rates Monitoring of customer satisfaction in Private banking
in Private Banking and Wealth Management in France HSBC Private Banking in France pays particular attention to the
In France, HSBC aims to be the first-choice wealth manager for its opinions and suggestions of its clients so to improve its range of
customers, and strives for excellence in the service and customer products and services, in which it aims to achieve excellence.
experience it provides. HSBC's customers lie at the heart of its Every year, HSBC Private Banking in France invites its customers
approach. to take part in a survey to gain feedback on their experiences and
Customer satisfaction in retail banking in France identify areas for improvement, with two main themes:
2020 saw a change in the methodology used to measure the • level of satisfaction in the offering of products and services and
Customer Experience. Since January, in each area, customers are the advice provided;
asked to give a recommendation score for HSBC with reference to • level of confidence in HSBC Private Banking in France and its
the banking relationship with their adviser or the interaction they staff.
have had (Customer Relations Centre, On-line Banking, Branch). A
Net Promoter Score (‘NPS’) is calculated from their responses as The 2020 survey showed that customer satisfaction with HSBC
the difference between the proportion of promoters (customers Private Banking in France remained identical to its level in 2019
giving a score of 9 or 10) and detractors (customers awarding (rated 8.2/10 in 2020). Customer satisfaction with their key
between 0 and 6). contacts also scored highly this year. Customers scored their
relationship with their Private Banker at 8.7/10 and their
In 2020, more than 47,000 individual customers were surveyed, relationship with other members of the advisory teams
with positive results in a difficult public health situation that reflect (investment, credit, wealth management) and product specialists
the commitment of our teams to providing effective support to at 8.5/10.
their customers.
There was also an increase (+23 per cent) in customer satisfaction
Although the banking relationship with key contacts has suffered with the quality of advice and recommendations provided and
from these conditions (due to branch closures and remote followed up by teams from HSBC Private Banking in France (80
working), HSBC demonstrated its ability to respond effectively to per cent satisfaction in 2020).
customers across all channels. As a result, the NPS scores
measured for remote access channels were strong: +50 on 93 per cent of customers surveyed reported that they achieved
average over the year for the Customer Relations Centre, with their financial goals in 2020 thanks to a clear and effective
continuous gains over the year (more than 60 per cent of financial strategy (96 per cent of customers surveyed) with
customers gave a score of 9 or 10) and +31 for users of the secure excellent value for money (89 per cent of customers surveyed).
on-line space (nearly 55 per cent giving 9 and 10 scores). The The general level of confidence increased over the year (63 per
scores obtained in the final four months of the year for branch cent of clients said they had confidence in HSBC Private Banking
visits (this channel having been closed between April and August) in France in 2020, from 59 per cent in 2019), as did the percentage
also reflected the quality of service provided by staff (NPS of +47 of clients saying they would recommend our services (47 per cent
per cent of customers from 31 per cent in 2019). of customers from 31 per cent in 2019).
Having won a number of awards in the Trophées de la Banque in Monitoring of customer satisfaction in Commercial Banking
2019, the retail bank of HSBC Continental Europe was named best
2020’s health crisis has transformed the banking relationship and,
traditional bank for students for the second year running in 2020,
more broadly, the way companies have organised themselves.
thanks to its banking package, charges and interest rates (Prix
Commercial Banking adapted to ensure continuity of operations
Sélectra – comparing 124 offerings).
during lockdown periods by accelerating the digitalisation of our
Monitoring of retail customer complaint main processes, transactions and subscriptions to new products
In 2020, the number of customer complaints decreased by 13 per and services, making more widespread use of electronic
cent compared with 2019. It should be noted that overall, the signatures, and implementing government measures such as
Covid-19 effect has not generated a significant increase in payment deferrals and government-guaranteed loans. As part of
complaints. Over the year, that's nearly 10,000 fewer claims the annual HSBC Customer Relationship 360 satisfaction survey
entered compared to 2019. This demonstrates the adaptability that 94 per cent of customers surveyed* agreed with the following
the network and head office teams have shown to support statement: ”the continuity of my operations management has
customers and contain dissatisfaction due to pandemic-linked been ensured”. Communication campaigns via the website and
disturbances. social media, coupled with a proactive approach from commercial
teams, helped maintain close links with our business customers
The quality and speed with which complaints are handled remain (31 per cent of customers* were contacted several times per
at the heart of the priorities and continued to be closely monitored. month by their account managers).
Despite the context of the health crisis and the impacts on the
organisation, especially on complex complaints requiring back Meanwhile, within the framework of the quality plan, particular
office intervention, response times remained good: 63 per cent of attention was paid to transparency on pricing, with simplified
complaints (vs 68 per cent in 2019) were processed on the same billing for certain transactions (such as international transfers) and
day or the following day; and 77 per cent (versus 80 per cent in simpler, clearer and more regular communication on standard or
2019) were processed within five working days. specific terms applicable to transactions.
The main causes of complaints among retail customers in 2020 Commercial Banking customer satisfaction levels are monitored as
were as follows: part of an annual survey covering the entire relationship as well as
by a monthly survey, part of an HSBC Group programme, on key
• complaints about pricing: 23 per cent of complaints (mainly moments in the relationship such as opening an account or
about charges dispute/explanation); requesting credit.
• customer service and support: 13 per cent of complaints mainly In 2020, the annual HSBC Relation Clients 360° survey, conducted
linked to the lack of visibility of pending requests ; by Kantar, took place in November. A sample of 1,000 customers,
• complaints about delays with closing accounts: 13 per cent of drawn from Commercial Banking’s three segments – SME, MME
complaints mainly about delays in processing; and Large Corporate – were interviewed by telephone. On a scale
• complaints in bank and life insurance succession, 8 per cent of
complaints mostly about delays in processing.
The number of complaints involving the ombudsman fell by 24 per
cent versus 2019.
Against a fast-moving economic, political and technological HSBC Private Banking in France also offers its customers regular
background, it is more important than ever to manage risks, webinars presented by internal and external experts on current
achieve operational excellence and seize growth opportunities. themes (investment, markets, philanthropy, sustainable finance,
The shift to digital technology, the challenges of the circular etc.).
economy and new value chains mean that we have to rethink and HSBC Private Banking won Best Global Private Bank for Digital
reinvent the bank–customer relationship. The HSBC Group is fully Customer Experience and Best Global Private Bank for Portfolio
aware of these issues and is investing heavily in solutions that will Management Technology by Professional Wealth Management,
make our services ever more simple, fluid, transparent and a Financial Times publication, at their 2020 Wealth Tech Awards
immediate for our customers. 2020.
More than ever, our Private Banking and Wealth Management Risk of customer disappointment performance indicators
business in France must become more efficient and get to know (theme 1)
its customers better in order to maintain and improve its value
proposition and service quality in a difficult market context. For 2020 2019 2018
individual clients, the main initiatives in 2020 were: Commercial banking customer overall
satisfaction rating (out of 10) 6.8 6.8 NA
• The deployment of tools and practices that allow staff teams to Share of commercial banking
be reached even when working from home (Jabber), provide customer complaints processed within
customers with video-conferencing facilities (Zoom), and 5 business days 43% 45% NA
improve and accelerate the response rate for emails; .
Financing the low carbon economy to manage the risk The sectors identified as priorities, and for which an internal policy
relating to the non-alignment of emissions financed has been developed, are forestry and its derivative products,
with a net zero pathway (theme 2) agricultural commodities, mining and metals, chemicals, energy,
defence, world heritage sites and Ramsar wetlands.
More than ever, we need to support the transition of our
customers to a low-carbon economy, including the innovation and To improve its risk management, the HSBC Group regularly
low-carbon solutions required to ensure economic resilience. For reviews its internal sector policies. In April 2020, HSBC
HSBC, these are the key elements of sustainable growth that it strengthened its Energy Sector policy by undertaking not to
can influence. consider financing any new coal-fired power plants anywhere in
the world. In fact, the Group has not provided any project finance
The Bank's network covers the world's largest and fastest-growing for any new coal-fired power plants since the announcement of its
trade corridors and economic zones. This enables the Group to energy policy in 2018.
play a strategic role in promoting sustainable growth at the heart
of the global economy. The HSBC Group's business dealings in these sensitive sectors
always involve dialogue with the client, to help it comply with
HSBC's commitment to sustainable finance international standards as well as our policies. However, as a last
HSBC supports the Paris Agreement and, in October 2020, resort, the Group reserves the right to cease all relations with a
announced new commitments to tackling the environmental and client that does not meet its requirements or which has not made
climate crisis: significant progress.
• Reducing its emissions financed – the emissions produced by These proactive policies, which form the basis of a restrictive and
its financing portfolio – with a view to be aligned with a carbon transparent approach to financing carbon-intensive or potentially
neutral trajectory by 2050; environmentally damaging sectors, have enabled the HSBC Group
and HSBC Continental Europe more specifically to avoid financing
• Being carbon neutral for operations, including the supply chain,
new thermal coal mines and coal-fired thermal power stations
by 2030;
since the energy sector policy was revised in mid-2018. In 2020,
• Supporting customers in the transition to a sustainable model coal’s share of the energy mix financed by HSBC Continental
by providing between USD 750 billion and USD 1,000 billion in Europe represented less than 0.16 per cent of its lending to
financing and investment over the next ten years; business; that proportion resulted from the energy mix of certain
• Becoming one of the major managers of natural capital customers, not from our direct financing of coal-related activities,
globally; in line with our internal policy.
• Contributing to the transformation of sustainable infrastructure For more details, visit the Group website: http://www.hsbc.com/
into a global asset class and generating a bankable project our-approach/risk-and responsibility/sustainability-risk.
pipeline. Assessment of HSBC Continental Europe's exposure to
For more information on progress towards these commitments physical and transition risks related to climate change
please see https://www.hsbc.com/our-approach/our-climate- Under the provisions of Article 173 of act no. 2015-992 of
strategy. 17 August 2015 on energy transition and green growth, HSBC
Managing the environmental risks related to banking activity Continental Europe has assessed its risks relating to climate
change with reference to regulatory requirements.
The HSBC Group has undertaken to follow the recommendations
of the Task Force on Climate-related Financial Disclosures ('TCFD') HSBC Continental Europe aims to refine its understanding of its
since they were published in 2017, and reports its progress in its exposure to transition risks in order to maintain the alignment of
annual Strategy Report available on the Group website. Prior to its financing in the energy sector with the projections of the 2°C
this, in 2003 it became a signatory to the Equator Principles, which scenario of the IEA for Europe.
form a voluntary framework to be used by financial institutions in HSBC Continental Europe has worked with Carbone 4, a
assessing and managing the social and environmental impact of consultancy advising on energy transition and climate adaptation,
infrastructure projects. This is revised regularly; the latest updates to carry out top-down analyses of its loan book's exposure to
were published in October 2020. HSBC has voluntarily extended climate risks. We started with the most exposed sectors: Energy &
the Equator Principles to company loans, export financing and Transport in 2016 and Real Estate & Industry in 2017, representing
other project financing tools. one-third of the loan book. In 2018, Commercial Banking analysed
In addition, for over 15 years, HSBC has developed a risk its entire loan book and confirmed that real estate and transport
management framework based on an approach to working with industries, along with producers of equipment for carbon-intensive
business customers that uses formal processes and trained and industries, represent challenges for HSBC in France. In 2019,
responsible employees to understand and manage environmental HSBC Continental Europe again assessed its loan book in the
and social issues in relation to sensitive sectors and themes. energy sector to see how it had changed since 2016. The study
showed that the proportion of the loan book relating to fossil fuels
As a result, an assessment of the environmental and social impact (oil and gas) had fallen and that the proportion relating to
of financing granted to the bank's customers has been embedded electricity had risen, better aligning the energy mix financed by
in the Group's risk management procedures. To ensure global HSBC Continental Europe with the requirements arising from the
consistency in analysis and approval procedures, a system of
environmental and social risk assessment has been established to
record and monitor client companies operating in sensitive sectors
throughout the world, and to obtain more precise information on
the Group's exposure in the management of sustainability risk.
The potential environmental and social impacts caused by
customers conducting business in any of the sectors concerned by
HSBC's policies are assessed by account managers from Global
Banking and Markets and Commercial Banking and by HSBC's
designated Sustainability Risk Managers from the Credit
Department, whether for risky project finance or lending
transactions. Since 2020, regional Reputational Risk Managers
have also had responsibility for supervising management of
sustainable development risks.
Commercial Banking contribution This multi-partnership has the particular aim of supporting small
and medium-sized companies, which do not always have the
The whole Commercial Banking team has been mobilised in order
human and financial resources to manage their ESG risks. Partners
to direct financing and lending to companies that are on a
provide, scientific, technical, methodological and regulatory
pathway compatible with the Paris Agreement targets.
support and through this one-stop approach create unique
A Head of Sustainable Finance has been appointed for conditions for providing tailored support to HSBC customers.
Commercial Banking, responsible, alongside a dedicated team, for:
https://www.business.hsbc.fr/fr-fr/articles/finance-durable
• developing sustainable solutions and financing for Commercial
Sustainable Governance
Banking customers of HSBC in France, by ensuring good
understanding of ESG issues by all stakeholders within the In 2020, Commercial Banking introduced a Sustainable Finance
bank; Forum, a body that aims to validate sustainable financing
transactions from an ESG point of view and to tackle underlying
• working with a dedicated origination team to structure
risks such as the risk of ‘greenwashing’ or ‘ESG-washing’,
sustainable finance transactions with Commercial Banking
reputational risk, corruption risk and legal risks.
customers to direct the bank’s portfolio on a pathway
compatible with the Paris Agreement targets. Growth of responsible investment within Private bank and
Commercial Banking has thus put in place a number of strategic Wealth Management
initiatives to support managers, the risk function and customers The integration of Environmental, Social and Governance criteria
themselves, as presented below. has been a prerequisite that the bank has incorporated in its
Development of sustainable financing products management processes since 2007 as a complement to financial
criteria. Today, 100 per cent of our asset management products
Commercial Banking has put in place: factor in ESG criteria when investment decisions are made.
• a financing allocation of EUR 500 million, backed by a In a continuation of the process it has adopted since launching its
European Investment Bank resource, including at least EUR 100 first SRI equity fund in 2001, HSBC Continental Europe offers a
million dedicated to financing green projects and assets for broad range of Socially Responsible Investment (‘SRI’) products
SMEs and mid-sized companies. Through this allocation, within a French registered SICAV, the HSBC Responsible
customers benefit from a 12.5 basis point reduction in their Investment Fund (‘HSBC RIF’)*. This covers seven SRI-labelled
financing rate. funds across all asset classes and also a new range of profiled
• green lending, where funds are released only to green projects funds. These solutions – HSBC RIF- SRI Moderate, HSBC RIF-SRI
and assets, in accordance with the Green Loan Principles Balanced and HSBC RIF-SRI Dynamic by increasing level of risk -
produced by the Loan Market Association (‘LMA’); are mainly invested directly in securities in the eurozone. This
diversified SRI range combines an SRI investment process with
• impact lending, that is to say loans whose margin is linked to multi-asset investment expertise; the SRI approach is overseen by
environmental, social or governance (‘ESG’) criteria, in order to managers and analysts who use proprietary tools and a
support mid-sized customers on their sustainability pathway, in comprehensive ESG research platform ensuring the consistency of
accordance with the Sustainability-Linked Loan Principles investment decisions. This full product range allows customers to
produced by the LMA. HSBC customers are supported by a invest in the theme of sustainable finance according to their risk
dedicated team in the provision of this type of loan with appetite.
Ethifinance.
The fund also features an SRI-energy transition subfund called
Implementation of a sustainable multi-partnership HSBC RIF-Europe Equity Green Transition, which has three
This system has been developed with experts in energy transition, recognised European labels: the French government's SRI label,
and reflects the need for vigilance and ESG strategy in order to the Greenfin-France Finance Verte label, and the Belgian ‘towards
support Commercial Banking customers on their sustainability sustainability’ label created by Febelfin and awarded by the
pathway: Belgian finance industry federation in November 2019.
• Energy Economy offers small and medium-sized businesses, via Since 2017, HSBC Continental has also offered 'lower-carbon'
the Up to Green platform, a suite of four complementary energy funds aiming to achieve both capital growth and income over the
efficiency services, with support ranging from the identification long term. The fund invests at least 90 per cent of its assets in the
of priority works to their financing, via assistance in finding equity of companies of all sizes, and seeks to have a smaller
sources of support such as Energy Savings Certificates. carbon footprint than its benchmark index.
• EcoVadis offers companies an assessment of their ESG The resilience of the SRI range, combined with the collective
performance, rating of improvement processes, peer commitment of the bank and investors, have produced total new
comparison and communication on good practice to customers money of more than EUR 262 million since the beginning of the
and commercial partners. EcoVadis also offers larger year (to 31 October 2020) at a time when there was a net outflow
companies support in laws relating to oversight of the analysis from non-SRI UCITS. Money invested in the SRI range currently
of their supply chains. represents around 19 per cent of assets under management by the
bank’s teams.
• EcoAct supports mid-sized and large companies in their low-
carbon strategies, from an initial diagnosis through to the Strengthened by these factors, HSBC is seeking to position itself
implementation of a decarbonisation action plan, including the as a driver of growth and a key player in this source of support for
definition of an emissions reduction pathway compatible with sustainable development. This is why it is continuing to develop
the estimated carbon budget from GIEC with a view to limiting sustainable products and also to educate its network of advisers
global warming to between 1.5°C and 2°C, life cycle analysis through regular training and communication on subjects relating
and carbon offsetting.
• EY, a longstanding partner of HSBC Continental Europe in the
Prix de l’Entrepreneur, offers large companies a range of
services related to their ESG challenges. EY supports them in
regulatory compliance and the definition, implementation and
value proposition of their strategies.
• EthiFinance, a European ratings agency specialising in extra-
financial ratings for mid-sized companies, has expanded
HSBC’s sustainable finance offering thanks to its expertise in
impact lending.
(2) www.carbon4finance.com/communique-hsbc/
Systematic evaluation of environmental, social and governance along with themed ESG research and specific reports relating to
issues and climate risk in asset management fixed income investment on a global scale.
The HSBC Group is more convinced than ever of the need to (5) www.assetmanagement.hsbc.fr/-/media/files/attachments/common/
incorporate environmental, social and governance (’ESG‘) factors news-and-articles/impact-esg-integration-fixed-income-portfolios-
in its investment decisions to protect the value created for its performance.pdf
clients and support the transition to a sustainable economy and
society. Engagement in protecting biodiversity
As one of the first signatories to the Principles for Responsible Building on collective undertakings to tackle climate change
Investment (‘PRI’) in 2006, HSBC Global Asset Management (Climate Action 100+, IIGC, One Planet Asset Managers, etc.),
committed at that time to integrating ESG factors in its investment HSBC Global Asset Management joined the Finance for
decisions. Alongside traditional criteria such as profitability, credit Biodiversity Pledge initiative in September 2020. This seeks to
quality, valuation and financial solidity, ESG analysis gives a true protect and restore biodiversity through financing and investment.
360° view of the financial instruments in which to invest. HSBC We have undertaken to bring our expertise and global reach to
Global Asset Management does not operate an overarching bear in a collegiate approach towards identifying more sustainable
hierarchy between environmental, social and governance factors: investments in agriculture, forestry, land use and other nature-
they contribute equally to informing its investment decisions with related areas. Lastly, the Pollination partnership helps cement
a view to obtaining positive financial results for its customers and, HSBC’s ambition to become the biggest manager of ‘natural
more precisely, the best returns adjusted for long-term risk. ESG capital’ funds worldwide. The HSBC Pollination Climate Asset
integration consists of integrating environmental, social and Management joint venture intends to establish and market funds
governance factors in investment analysis. Understanding the investing in a diverse range of activities that preserve, protect and
risks and opportunities facing issuers strengthens a ’citizen‘ enhance nature over the long term and address climate change.
approach by helping understand the most urgent challenges faced Measuring biodiversity
by today’s economies. This investment approach, the products
offered and the role adopted to make the financial system more In addition, HSBC Global Asset Management (France) has, since
sustainable all contribute to this approach. September 2020, been part of the ‘B4B+’ working group set up by
CDC Biodiversité. In order to create a method suited to the needs
ESG integration process and constraints of financial companies and institutions, the B4B+
HSBC Global Asset Management is certain that ESG issues can Club intends to jointly construct and test a Global Biodiversity
have major repercussions on companies’ performance. Challenges Score in close cooperation with its members. The aim of the B4B+
such as climate change, water scarcity and availability, Club is to act as an incubator for this indicator, the Global
deforestation, health and safety and the remuneration of directors Biodiversity Score (’GBS™‘), and the associated biodiversity
create risks and opportunities for companies that financial markets footprint method.
may not have valued accurately. This is why ESG criteria are Voting and shareholder engagement
integrated into the analysis of financial securities, alongside
financial fundamentals. This analysis varies from sector to sector Engagement is an integral part of the fundamental research
in order to take account of the specific features and industrial process and long-term investment approach at HSBC Global Asset
reality of each. The associated risks and opportunities thus Management. Equity and credit analysts from the active
identified help produce better informed investment decisions. At management teams, together with portfolio managers, are in
31 December 2020, more than 16,000 issuers around the world direct contact with issuers throughout the investment process,
were covered by an ESG analysis accessible to all analysts and from before to after the investment period, and follow up ESG
fund managers at HSBC. issues as part of their research and their discussions. Engagement
initiatives are determined as a function of the size of holdings, the
Principles for Responsible Investment (’PRI‘) issues identified and overall exposure, expectations in terms of
The consistency and robustness of HSBC Global Asset change and the ability to achieve the expected results. Thanks to
Management's approach to integrating ESG factors has once this approach, at each stage of the investment cycle the main ESG
again been underlined by the latest annual PRI assessment, which issues are integrated in analysis and the decision-making process,
ranks and rates the signatories on the quality of the in order to reduce risk and optimise performance.
implementation of the six principles for responsible investment In As a first step, HSBC Global Asset Management might notify the
2020, HSBC Global Asset Management once again received an A+ Chairman and non-executives of its concerns or vote in such a
score in the main areas assessed – including strategic governance, way as to express its concerns over a company’s lack of action. If
equity management and bond management – putting it in the top these measures do not produce results, we can join forces with
decile of a group of more than 500 asset managers in each other investors or bring the problem to the notice of a broader
category, including for ABS – Asset Backed Securities, an asset audience through statements, letters to the press or participation
class that is rarely assessed from an ESG standpoint. This latest in shareholder meetings, with the submission of shareholder
annual PRI evaluation, which rates and ranks signatories by the resolutions.
quality of their implementation of the six principles for responsible
investment, underscores the quality of our approach to ESG Over the past three years, this shareholder engagement has
criteria. increased significantly in the wake of the integration and improved
understanding of the effect that ESG issues can have on the
Focus on ESG research for bond assets performance of companies. In 2020, HSBC Global Asset
In 2020, quantitative research by HSBC Global Asset Management Management addressed ESG themes with more than 2,300 issuers
confirmed that the integration of ESG factors had a positive impact in 78 markets. Its interactions with companies increased by +11
on bond management strategies during the Covid-19 crisis. per cent during the lockdown period, from 1,504 in the second
Nevertheless, because analysis carried out under unprecedented quarter of 2019 to 1,682 in the second quarter of 2020 – reflecting
conditions should not be the sole driver of long-term fixed income
allocations, these results were put in context by a detailed review
over the longer period from 2007 to June 2020, the main results of
which were published in a research paper, ‘The impact of ESG
integration in fixed income portfolios’ performance’ (5).
Within the Global Credit Research team, the appointment of a
Head of Fixed Income ESG and Green Research, in August 2020,
confirmed the desire to offer sustainable investments to increase
the resilience of client portfolios. The purpose of this new role is to
provide ESG expertise to all fixed income management teams,
To help fulfil HSBC's strategy, HSBC Continental Europe focuses Circular economy
its attention on four objectives:
HSBC Continental Europe continues to seek to reduce waste
• improving energy efficiency; production in general and a reduction in non-recycled waste in
• reducing CO2 emissions, notably those related to business particular. Waste production fell from 849 tonnes in 2019 to 591
travel; tonnes in 2020, a fall of more than 30 per cent which is explained
by a methodological alignment with the Group which excludes site
• reducing paper consumption; waste from its scope and above all a drop in activity in buildings
• reducing production of non-recycled waste linked to lockdown. It represented on average 75 kg per employee
per year in 2020 versus 96 kg in 2019.
Reducing CO2 emissions
Electronic waste
In 2020, the main areas of action involved the on-going policy of
building renovation, actively seeking to reduce energy consumed At the start of 2020, a project to replace office telephones with
in the management of HSBC sites, and promoting remote working more up-to-date models was rapidly changed as a consequence of
and reducing business travel. the health crisis and the widespread uptake of remote working.
With the vast majority of staff working remotely and using new
Carrying on from the HQE certification it obtained for Coeur on-line communication tools (notably Jabber and Zoom), decision
Défense (46,000m² of office space) in 2011 and the ‘NFHQE™ was taken not to replace fixed-line telephones. At year end 2020,
Bâtiments Tertiaires en Exploitation’ energy efficiency certification, HSBC Continental Europe decommissioned and recycled more
under which it achieved an ‘Excellent’ rating in 2018, in 2020, than 5,800 telephones notably at the time of moving headquarters
HSBC Continental Europe maintained the ‘Exceptional’ rating from avenue des Champs Élysées. This represents a total of 9.7
achieved in 2019. tonnes of products which will be collected and recycled by Cisco.
On December 1, 2020, HSBC moved its headquarters to 38 avenue Regarding mobile phones, in February 2020, 478 mobiles were
Kleber, Paris (16). This 16,350m² building has been fully collected from HSBC Continental Europe staff and passed to
modernised and was chosen for its eco-responsible qualities, Recommerce Solutions for recycling or reconditioning, thus
having received BREEAM and BBC Effinergie certification. In contributing to sustainable development and solidarity
addition, its builder received an Exceptional HQE rating. employment in France:
Transport • 2,619kg of CO2 saved thanks to the re-use of products;
The pandemic had a significant impact on business travel in 2020: • 60,677.3MJ of primary electricity use avoided thanks to
total kilometers travelled dropped by 60 per cent compared to product recycling;
2019. Even though 2019 had already seen a sharp reduction in
international travel, due to a suspension of trips to Hong Kong • 60 hours of reintegration employment created for product
initially, due to political developments, and then to China, when processing.
the emergence of the Covid-19 virus was first reported, since Paper
March 2020 international travel has come to a virtual halt in
Having already been reduced in prior years, the reduction in paper
France and around the world. Although domestic travel was less
use gathered pace significantly in 2020, with the widespread use
tightly restricted, it was complicated in the early part of 2020 by a
of remote working favouring increased adoption of digital
strike on the SNCF rail network and major social unrest. As a
documents. The result was a fall of more than 33 per cent
result, CO2 emissions were down by 59 per cent.
between 2019 and 2020.
In 2020, HSBC also changed its relationship with its main taxi
Food issues
booking service (G7), with a default preference for ’green’ badged
taxis for all its subscriptions (apart from Club Affaires). Despite their importance on an environmental and social level,
food waste, the fight against food poverty, equitable, sustainable
In all, CO2 emissions from transport were 0.17 tonnes eq. CO2 per
member of staff per year, down 60 per cent on 2019. and responsible food and the respect for animal welfare are not
material matters within the framework of the bank's business.
In accordance with French decree no. 2011-829 of 11 July 2011 on
For more detailed information on HSBC Continental Europe’s
greenhouse gas emission footprints and the local climate energy
undertakings under its environmental policy visit hsbc.fr or
plan, HSBC Continental Europe has compiled and published its
hsbc.com
carbon report for 2019, showing a slight increase in tonnes of CO2
equivalent produced. Information on the company's 2020 Awareness-raising measures
greenhouse gas emission footprint will be available on http://
Throughout 2020, the Sustainability Department organised
www. about.hsbc.fr/fr-fr/hsbc-in-france/ community from January
awareness-building campaigns on the environmental footprint,
2021.
and more particularly the digital footprint and good practice to
Mobility plan adopt in the light of increased remote working and use of digital
The French energy transition act (act no. 2015-992 of 17 August solutions. Conference calls were organised during Sustainable
2015) requires companies with more than 100 employees on a Development weeks in September, and Waste Reduction weeks in
single site located in an 'urban travel plan' area to prepare a November, and there were also regular articles in the
mobility plan. In 2018, HSBC Continental Europe carried out an Department’s monthly Newsletter.
initial analysis for the La Défense (Courbevoie) site, which is our
largest site in terms of the number of people working there,
examining site accessibility and employee practice and
expectations regarding their commute to work. The study led to
the signature, in early 2020, of the 'Charter of reciprocal
undertakings to reduce rush hour travel' promoted by Ile-de-
France Mobilités and Paris La Défense, the aim of which is to
improve travel conditions on public transport for staff travelling at
peak times. HSBC Continental Europe, as part of its effort to
increase quality of life at work, has adopted a proactive remote
working policy, allowing an increasing proportion of employees to
work in this way. In 2020, in the face of the coronavirus health
crisis, remote working was extended to all staff. This process saw
the creation of 3,200 new access tokens within just a few days,
after the first lockdown was announced in March.
source of stress. Anxiety amongst staff was further increased by members, while helping them to give their best to the Bank.
the health crisis (hospitalisations, deaths, etc.), the deterioration of In an environment where potential expresses itself in many
the economic outlook, and the personal and professional different ways, HSBC is convinced that employees' differences
difficulties created by the crisis (isolation, increased domestic and represent a source of wealth. It places a particular emphasis on
family responsibilities, health problems and so on). Lastly, with diversity, so that it may be fully expressed in all its aspects,
banks having special responsibility during the crisis and given the particularly regarding gender, age, skin colour, background,
role they have played in supporting companies and individuals, religion, disability, sexual orientation, appearance and opinions. All
employees faced periods of intense activity. employees should be able to be themselves, in an organisation
The ‘psychosocial’ risk (work-related stress, anxiety, depression) that places value on a diversity of profiles and opinions. Make this
was thus addressed by a specific action plan that was closely diversity an asset is a major stake for the bank.
monitored by the company:
Managing the risk of inability to ensure the
• Regular and targeted communication campaigns from the employability of our employees given the
Human Resources division (practical details on health matters transformation of the banking sector, by developing
and the organisation of work); talent in all its guises and strengthening employability
• Adjustments to the management of leave, to ensure that (theme 5)
adequate leave could be taken without imposing requirements; Employability is a major theme in ensuring that people can adapt
• Real time monitoring of Covid-19 cases and contact tracing, to organisational and technological changes, and more broadly
with the appointment of a contact person at the heart of the changes in the labour market, particularly in the context of
system backed by the Workplace Health Team; uncertainty and change such as was seen in 2020. To help prepare
employees, it is necessary to support them in developing the skills
• Regular dialogue with the bodies representing staff;
that the business will require in the future.
• Enhanced support for managers;
Accordingly, HSBC provides the resources each employee needs
• A virtual support programme (#Résilience) for employees and to develop and take control of their career. Support is provided
management (webinars, co-development, coaching, etc.); through an efficient training ecosystem (innovative content,
• Surveys (Snapshot Survey) and direct dialogue with employees tailored formats and individualised training) that facilitates
(‘Boost Your Bank’ workshops). A survey in June allowed us to continuous learning, internally and externally, and helps increase
establish the perceived well-being of employees (65 per cent employees’ adaptability, agility and multi-disciplinary talents.
favorable responses) and identify the main obstacles to well- In 2020, the HSBC Group rolled out an ambitious upskilling
being (family and domestic responsibilities for 30 per cent, programme, ‘Future Skills’, which was backed in France by
technological problems for 29 per cent). Overall, 87 per cent conferences, training sessions, and self-training materials, with
reported that they felt well-informed, and 81 per cent that they 1,600 employees taking part. Its aim is to develop the core skills of
were well supported by their manager. tomorrow such as curiosity, creativity, teamwork, communication
Supporting the on-going transformation of HSBC and resilience.
Continental Europe The goal is to make employees their own players of their career
and to support them to become agile in our changing
Within the framework of its strategy implementation process,
environment.
HSBC Continental Europe undertook numerous restructuring
projects in 2020 both in France and in other Continental European This aim runs alongside sustainability. More information on the
countries (Poland, Italy, Spain, Czech Republic, etc.). This followed HSBC Group's initiatives is available at https://www.hsbc.com/our-
an information and consultation process with employee approach/building-a-sustainable- future/ employability-and-
representative bodies at a European level (EWC) and in the financial-capability.
countries concerned. With this goal in mind, we believe that one of our missions is to
Within this framework, a collective redundancy plan was adopted promote our development programmes, that are open to all, and
in the autumn covering the Global Banking and Markets Division to encourage employee uptake. To this end, we have set ourselves
and resulting in the elimination of 235 positions in France. The a target of 55 per cent of employees to have taken at least one
terms of this plan received unanimous collective agreement with module of our programmes each year. In 2020, the take-up rate
representative union bodies, guaranteeing a programme of was 48 % (see table below). 2020 was the first year of our French
support to employees that was equitable and adapted to their #resilience programmes and the first year of the Future Skills
circumstances. development programmes. Having almost one employee out of
two who attended one of our session is really a good participation
A contractual termination agreement relating to employees in
level. And as all of our training sessions have been recorded, all
Commercial Banking, support functions and at the head office has
staff can have access to those contents in replay.
been negotiated with union bodies and approved on 1 February
2021 . Promoting a range of learning methods
In both France and other European countries, these plans are Because personal development is based not only on training but
based mainly on voluntary redundancies. Support measures, also on experience and feedback, HSBC Continental Europe offers
which in most cases are subject to negotiation and discussion the broadest possible range of resources to help develop new
with employee representatives in the countries concerned, will skills.
allow the departure of employees to take place, as usual, in a HSBC Continental Europe is continuing its efforts to encourage
respectful, humane and responsible manner. uptake and recognition by managers and employees of a 70/20/10
Responsible and inclusive HR policy model, which combines three complementary training
approaches:
As a leading global employer, HSBC's main aim is to develop an
HR policy that helps to develop the employability of staff • 70 per cent from experience-based learning. By seeking
solutions through their professional practice, employees
In a rapidly changing banking industry (digitalisation accelerated Recruitment of young people is an important challenge for
by the health crisis, economic crisis, tighter regulatory HSBC Continental Europe
requirements), HSBC aims to respond to the shift in employment In 2020, and despite the difficulties created by the health crisis,
patterns by attracting, recruiting and integrating the best talent. HSBC continued to recruit young people through its four preferred
To support its development and the creation of the Continental channels: 173 apprentices, 267 interns, nine VIE graduates and
Europe platform, HSBC recruits staff from a variety of eight graduates were recruited in France over the course of 2020.
backgrounds and outlooks to contribute to the Bank’s various Induction processes were adjusted to allow remote induction
business lines and functions in France and in the other countries where no other alternative was available. Mentors also adopted
of Continental Europe. remote contact to enable young recruits to enjoy a successful
professional experience.
Two of our programmes have proved particularly popular with
students:
• The Volontariat International en Entreprises ('VIE') or
international professional assignment programme: young
graduates undertake assignments of between six and 24
months, mainly in London, New York and Hong Kong, in areas
such as Global Market Operations, IT, Risk and Finance.
• Global Graduate: an HSBC Group programme for young
graduates with a carousel of placements at the beginning of
their contract in Global Banking and Markets and Commercial
Banking. This programme encourages graduates to discover
various roles within each division whilst acquiring cutting-edge
skills.
The theme of mental health was a particular focus of awareness distributed via DRH Info, with Q&A packs provided to managers.
raising programmes in 2020. Dedicated manager training, a This communication helped raise awareness of approaches to help
conference and discussions all addressed this theme. structure work during lockdown, good practice to avoid overwork,
preventing isolation and strengthening team spirit.
To improve day-to-day living standards, in France more than 500
disabled employees or employees with a disabled close relative A guide to the correct use of digital tools was made available to all
received 'CESU' cheques (enabling them to pay for domestic help) HSBC staff and contains best practice for optimal use of digital
financed entirely by HSBC, while nearly 60 employees were tools that respects the work/life balance. This guide was
supported in measures to alleviate their disability and maintain incorporated into all communications available to employees on
their employment, through a range of support including the the dedicated Covid-19 intranet site.
financing of individual equipment or other adaptations. Strengthening the collective ability to manage change and
Improving quality of life at work to foster employee measuring employees' satisfaction and wellbeing
commitment Listening to employees is based on a range of approaches:
Ensuring a good quality of life at work results in a committed • The ‘Exchange’ groupware application, which for managers
workforce: accordingly, HSBC Continental Europe's senior consists of organising agenda-free consultation meetings, in
management focuses on this topic in order to increase employees' which managers take part without taking any hierarchical
sense of fairness and belonging, to foster cohesion and to protect stance. This innovative approach allows staff members to
employees' mental and physical health, which has taken on even discuss any subject freely. The resulting feedback is sent to the
greater importance in the health crisis. HSBC Group. Since the programme was launched in 2012, it
Increasing employees' commitment is a strategic aim for HSBC, has been clear that employees taking part in an Exchange
and employees' professional fulfilment is a key priority for the meeting had a more positive approach to their work and the
Bank. bank's strategy and a better understanding of the changes
affecting HSBC.
Awareness-building and training on quality of life at work
• Group engagement surveys: ‘Snapshot’ is a regular survey of
In addition to actions already in place – such as the ‘action for
employees around the world, which aims to assess
workplace well-being’ which focuses on developing high-quality
understanding of the bank's strategic priorities and measure
relationships (empathy, affirmation, caring), conflict prevention
perception of changes through various themes: strategy, Global
and resolution, the management of emotions at work, and
Standards, communication, customer experience, culture and
guidelines on managing ‘logging off’ outside work hours – HSBC
working methods.
committed to strengthening measures to support employees
during the pandemic. Frequent communication, with both • In the first half of 2020, a survey focusing on employee well-
employees and managers, and awareness building measures being in the context of the pandemic helped identify the fact
under the #résilience programme are all examples of additional that the biggest difficulty faced by staff was managing work/life
awareness building in 2020. balance. At the same time, the quality of support from HSBC
was highlighted by more than 80 per cent of respondents. This
Giving employees more flexibility
report allowed us to adjust the systems we had put in place.
HSBC Continental Europe is attentive to offering more flexible
• In the second half of 2020, a further Snapshot study showed
working arrangements to employees to help improve work-life
stable or slightly improved scores for HSBC Continental Europe
balance. By way of illustration, a group agreement on remote
relative to the first half of 2019.
working, which has been in place in France for two years,
expanded the options for working from home for salaried • Confidence in line managers, the ability to express oneself if
executive employees to allow occasional and flexible working from faced with unacceptable behavior and a feeling of professional
home. Home working on specific days is also in place. satisfaction all saw better scores compared to previous survey.
Against the background of the health crisis, HSBC Continental • The survey shows areas of improvements regarding ownership
Europe allowed more than 90 per cent of staff to work from home of the strategy by the employees.
from the early days of the crisis until the end of 2020. As existing • These Group initiatives are supplemented in France by a
measures to allow remote working had created a flexible work medical stress-monitoring system (since 2004) and a
culture, the transition to a more virtual organisation, across all framework for identifying and measuring work-related stress
Continental European countries, was a smooth process. Specific (since 2012). The most recent findings reflected employee
training programmes for managers were introduced to support concern over the difficulties facing the banking sector and the
them in more widespread remote working, and this was backed by worries about the deterioration of the economic climate. They
initiatives to encourage good use of digital tools such as ‘We also showed that the quality of working relationships with line
Innovation’. managers and between colleagues, work-life balance, the work
In addition, for some time now, considerable attention has been environment, and level of independence remained as positive
paid to maintaining social links within the company, equality of factors.
treatment of staff and respect for private life and the right to Results for 2020 are not yet known, and will reflect the highly
disconnect. In the context of the health crisis, employees were unusual context of a major health crisis. During this period, the
invited to use an existing facility to provide details of their location
(on site or at home) to allow managers to get a quick view of the
whereabouts of their teams.
Ensuring the correct use of digital tools
In a highly-connected environment, and given the massive uptake
of remote working, the correct use of professional communication
tools is a key challenge for the quality of life at work.
A charter drawn up by HSBC Continental Europe’s Executive
Committee establishes 10 major principles that aim to encourage
staff members to adopt day-to-day behaviors and rules that help to
reconcile their private and professional lives.
Throughout 2020, against the background of the health crisis and
the massive use of remote working, employees were reminded of
these guiding principles through regular communication
To achieve this, 10 remote workshops were run over Zoom, The salary of disabled workers was between 97.5 per cent and
bringing together 115 volunteer employees. 112.8 per cent of that of all workers. Personal service vouchers
Having identified the five main positives from lockdown, (CESU) financed in full by the company were introduced in 2015 to
participants proposed 90 recommendations in three priority areas: assist employees with disabilities and employees with a close
remote working, caring, and processes and tools. All these relative with disabilities.
proposals were submitted to the Executive Committee for
consideration, and some are already under review or being Ratio theoretical waged disabled employees / other employees
implemented. Convention 2018 2019 2020
Status Level % % %
An attractive and fair remuneration policy
C — — —
HSBC Continental Europe’s remuneration policy is designed to D — — —
attract, motivate and retain the best employees. It is a powerful Technician E 107.7 111.2 112.8
driver of staff commitment, and one that HSBC makes full use of. F 103.8 104.9 105.9
HSBC Continental Europe addresses this strategic priority with a G 101.4 102.5 102.7
remuneration policy that is both attractive and fair, in order for H 100.5 100.8 100.9
each employee to be treated fairly. I 97.5 97.3 97.5
Executive
J 98.7 98.9 98.0
The remuneration policy recognises and rewards the efforts made, K 98.6 100.3 99.4
engagement, involvement, contribution and the collective and
.
individual performance of each of our employees through an
Table of social performance indicators of HSBC Continental
annual budget for collective and/or selective wage adjustments,
Europe
individual variable remuneration and, based on results, collective
Change
remuneration in the form of bonuses and profit sharing.
Indicators 2020 2019 2018
It helps finance employees’ day-to-day lives through the payment 1 – Workforce split by status,
of various contributions, such as for child care, the new academic gender and contract of
year, holidays through holiday voucher top-ups or in the event of employment (FTE):
mobility within the company. Lastly, it provides guarantees that Total FTE – HBCE in France 7,238 7,472 7,586
will last throughout an employee’s career at HSBC and beyond: o/w unlimited term contracts 7,183 7,437 7,555
continuation of salary and health cover in the event of illness, – o/w women managers 2,926 2,997 2,982
provident services in the event of incapacity and the – o/w men managers 2,781 2,861 2,928
supplementary pension scheme that has been in place for many – o/w women clerical staff 1,130 1,205 1,257
years to help our employees boost their income in retirement. – o/w men clerical staff 346 373 389
This policy forms part of an approach that seeks to treat all of our o/w Impatriate contracts 15 15 14
employees fairly. This approach is best illustrated by a few – o/w women 5 4 4
examples.
For more than 10 years, the collective agreements that HSBC
France has entered into have included an automatic salary review
for people returning from maternity or adoption leave. Specific
fairness budgets over the last ten years (EUR 8.8 million) have
helped establish wage fairness in several areas. Women's pay,
– o/w men 10 11 10 the use of a system of appropriate checks and the implementation
o/w fixed-term contracts 40 20 17 of measures to evaluate these risks.
– o/w women managers 6 10 8 Risks of money laundering and financial crime:
– o/w men managers 3 4 8 preventing the risk (theme 8)
– o/w women clerical staff 22 3 2
– o/w men clerical staff 9 3 — HSBC has a responsibility to help protect the integrity of the global
Total female FTE 4,089 4,220 4,252 financial system. In order to fulfil this responsibility, we have
% women 56.5% 56.2% 56.1% made, and continue to make, significant investments in our ability
Total male FTE 3,149 3,253 3,334 to detect, deter, and prevent financial crime. Various programmes
% men 43.5% 43.3% 43.9% have been implemented and others are under way to improve
systems and day-to-day practices for managing risks relating to
Total FTE – International network 1,279 1,385 627
money laundering, tax fraud, compliance with sanctions and
Total female FTE 652 700 360
corruption. Within HSBC Continental Europe, every month, all
% women 51.0% 50.6% 57.4%
transactions – more than 28 million across 1.7 million accounts –
are analysed to detect signs of money laundering, tax avoidance
Total male FTE 627 685 267
and failure to comply with sanctions. In addition, 1.7 million
% men 49.0% 49.4% 42.6%
names are screened on an ongoing basis using various
surveillance lists. The Bank has cut links with customers, products,
Total FTE – HBCE in France +
International network 8,517 8,857 8,213 and countries where we deemed the financial crime risk too high
to manage. The HSBC Group is also working with governments
Total female FTE 4,741 4,920 4,612
and other banks to advance its collective interests in this area.
% women 55.7% 55.5% 56.2%
These steps are enabling us to reduce the risk of financial crime
Total male FTE 3,776 3,937 3,601
much more effectively.
% men 44.3% 44.5% 43.8%
In order to ensure the effectiveness of our policies, an annual
2 – Hires and dismissals (FTE) training course has been taken by over 98 per cent of HSBC
Recruitments (FTE) HBCE in France 380 851 787 Continental Europe employees, which is in line with the bank's
% recruitments 5.2% 11.3% 10.4% Risk Appetite of having at least a 98 per cent mandatory training
Dismissals (FTE) HBCE in France 93 100 98 completion rate (the Risk Tolerance is set at 97 per cent).
% dismissals 1.3% 1.3% 1.3% Performance indicator for risk of money laundering and
financial crime (theme 8)
Recruitments (FTE) International 47 106 55
% recruitments 3.6% 7.6% 8.8% 2020 2019 2018
Recruitments (FTE) HBCE in France For more details, see Risks, Regulatory Compliance Risk
+ International network 426 957 842 Management page 147.
% recruitments 5.0% 10.8% 10.3% More information about HSBC financial crime policies at https://
Dismissals (FTE) HBCE in France + 99 105 98 www.hsbc.com/our-approach/risk-and-responsibility/financial-
International network
crime-risk/financial-crime-risk-policies
% dismissals 1.2% 1.2% 1.2%
Risks of corruption*: preventing the risk (theme 9)
3 – Equality of treatment HSBC is committed to high standards of ethical behaviour and
% of women in management HBCE operates a zero tolerance approach to bribery and corruption. We
in France (FTE) 29.0% 30.0% 30.0% consider such activity to be unethical and contrary to good
% of women in management corporate governance and require compliance with all anti-bribery
International
% of women network (FTE) HBCE
in management 30.5% 28.6% 47.6% and corruption laws in all markets and jurisdictions in which we
in France + International network operate. We have a global Anti-Bribery & Corruption Policy which
(FTE) 29.3% 29.7% 31.0%
gives practical effect to global initiatives such as the Organisation
Number of persons with disabilities of Economic Cooperation and Development (‘OECD’) Convention
(only HBCE in France) 425 439 458
on Combating Bribery of Foreign Public Officials in International
% employees with disabilities (only Business Transactions and Principle 10 of the United Nations
HBCE in France) 5.3% 5.2% 5.3%
Global Compact
% of employees less than 30 years
old HBCE in France (FTE) 10.0% 11.2% 10.8% As regards combating corruption, HSBC Continental Europe is
% of employees over 50 years old committed to complying with France's Sapin 2 act and to adopting
HBCE in France (FTE) 32.6% 31.2% 30.4% a zero- tolerance attitude to corruption.
% of employees less than 30 years In 2018, France's anti-corruption agency AFA carried out 47 audits
old International network (FTE) 7.3% 8.9% 7.7%
in France, including one at HSBC Continental Europe. Certain
% of employees over 50 years old areas of concern were highlighted and efforts to resolve them are
International network (FTE) 18.1% 15.6% 10.2%
currently underway, to enable the Bank to comply with the Sapin 2
% of employees less than 30 years
Act's eight pillars such as risk mapping and internal control.
old HBCE in France + International
network (FTE) 9.6% 10.8% 10.5%
% of employees over 50 years old
HBCE in France + International
network (FTE) 30.4% 28.8% 28.9%
Certain clients of HSBC Continental Europe could seek to use its HSBC Continental Europe is fully aligned with these Group
services for tax evasion purposes, exposing the bank to commitments and policies. Thus, since March 2017, as part of the
accusations of complicity which, if confirmed, could lead to severe new contracts process and the renewal process of the contracts,
financial, legal and reputational consequences. suppliers are systematically asked to sign the code of ethical and
environmental conduct established by the Group. At the end of
HSBC has adopted the Code of Practice on Taxation for Banks 1 December 2020, 97 per cent of the suppliers concerned had
which was introduced in 2009 and manages tax risk in accordance responded positively, thus meeting the objective of a supplier
with a formal tax risk management framework. return rate close to 100 per cent.
We apply a number of tax initiatives which were introduced after HSBC Continental Europe operates a vigilance plan to meet the
the global financial crisis with the aim of increasing transparency. requirements of France's new Duty of Care act. Given the
These initiatives address the tax positions both of companies and legislative and regulatory framework, the scope of its businesses
of their customers. These include: and the procedures in force within the HSBC Group, risks relating
• The US Foreign Account Tax Compliance Act (‘FATCA’); to a failure to respect human rights are not material for HSBC
Continental Europe.
• The OECD Standard for Automatic Exchange of Financial
Account Information (the 'Common Reporting Standard'); For more details on the ‘Duty of Care’ act, see page 77.
• The Capital Requirements Directive IV (‘CRD IV’) Country by HSBC Confidential Internal whistleblowing system
Country Reporting 2; HSBC strives to create a working environment in which employees
• The OECD Base Erosion and Profit Shifting (’BEPS‘) initiative; feel free to share their concerns. Aware that certain circumstances
require special discretion, it simplified its whistleblowing system in
• The UK legislation on the corporate criminal offence (‘CCO’) of 2015, detailed in its duty of care plan on page 78
failing to prevent the facilitation of tax evasion.
Arrangements in place within HSBC Continental Europe in France
1 See the UK Government’s code of practice on taxation for banks. and figures
2 See hsbc.com for our approach to tax transparency.
In accordance with Law N° 2016-1691 of December 9, 2016
Performance indicator for risk of tax evasion (theme 10) relating to transparency, the fight against corruption and the
modernisation of economic life, this solution allows employees to
2020 2019 2018 report, as soon as the usual channels for raising concerns are
Share of staff members trained on unavailable or inappropriate, without fear of retaliation, concerns
theme 98% 98% 96% relating to the following matters:
For more details, see Risks, page 151. • a crime or an offense (e.g. corruption, fraud, embezzlement,
More information about HSBC anti-bribery and corruption policies harassment, discrimination ...), a serious and manifest violation
at https://www.hsbc.com/our-approach/risk-and-responsibility/ of an international standard, law or settlement or serious
financial-crime-risk/financial-crime-risk-policies violation of human rights and fundamental freedoms, human
health and safety and the environment,
Risks in the areas of cybersecurity and IT attacks:
preventing the risk (theme 11)
HSBC Continental Europe, in common with other organisations, is
subject to a growing number of increasingly sophisticated cyber-
attacks that can in some instances affect its operations, including
the availability of digital facilities for customers.
The Bank’s IT security system is crucial for the proper functioning
of its banking services, the protection of its customers and of the
HSBC brand. With the aim of maintaining it at its best possible
level, HSBC Continental Europe continues to strengthen its
technical resources, its monitoring systems and its governance to
prevent and withstand the growing threat from cyber-attacks.
The cyber threat is a top priority for the management team and is
the subject of regular communication and discussion in order to
ensure the appropriate visibility, governance and support for our
cyber-security programme. HSBC Continental Europe has not
reported any significant security incidents in the last 12 months,
thus meeting its objective.
People KPI
Risk of inability to ensure the employability of our employees given the transformation
of the banking sector (theme 5)
Take-up rates for development programmes open to all on a voluntary basis (annual target: 60%) 48% NA NA
Risk of failure to recruit and retain talent (theme 6)
Attrition of talent (annual target: 7%) 12% 3% NA
Risks related to lack of diversity among teams and psychosocial risks (theme 7)
Share of women in senior executives positions (2025 target : 35%) 29.3% 30% 31%
Governance KPI
Risks of money laundering and financial crime (theme 8)
Risks of corruption* (theme 9)
Risks relating to tax evasion* (theme 10)
Share of staff members trained on themes 8, 9 & 10 98% 98% 96%
Risks in the areas of cybersecurity and IT attacks (theme 11)
Number of significant security incidents over last 12 months 0 0 0
Risks in terms of non-compliance with Human Rights*
Share of suppliers who signed the Code of Conduct in the renewal process 98% 97% 39%
1 With the change in scope from HSBC France to HSBC Continental Europe, the indicator has been recalculated for 2019 and 2018 on the basis of
the 2020 scope.
2 CO2 emissions energy and transports.
3 Base: subject workforce.
Report by one of the Statutory Auditors, appointed as an independent third party, on the
consolidated non-financial statement included in the Group management report
For the year ended on the 31 of December of 2020
This is a free translation into English of the Statutory Auditor’s report issued in French and is provided solely for the convenience of English
speaking readers. This report should be read in conjunction with, and construed in accordance with, French law and professional standards
applicable in France.
To the HSBC Continental Europe annual general meeting,
In our capacity as Statutory Auditor of your HSBC Continental Europe, appointed as an independent third party and accredited by
Cofrac(accreditation Cofrac Inspection n°3-1060 whose scope is available at www.cofrac.fr), we hereby report to you on the non-financial
information statement for the year ended... (hereinafter the “Statement”), included in the management report pursuant to the legal and
regulatory provisions of articles L. 225‑102-1, R. 225-105 and R. 225-105-1 of the French Commercial Code (Code de commerce).
The entity’s responsibility
Pursuant to legal and regulatory requirements, the Board of Directors is responsible for preparing the Statement, including a presentation
of the business model, a description of the principal non‑financial risks, a presentation of the policies implemented considering those
risks and the outcomes of said policies, including key performance indicators.
The Statement has been prepared in accordance with the entity’s procedures (hereinafter the “Guidelines”), the main elements of which
are available on request from the Sustainable Finance Direction.
Independence and quality control
Our independence is defined by the provisions of article L. 822-11-3 of the French Commercial Code and the French Code of Ethics (Code
de déontologie) of our profession. In addition, we have implemented a system of quality control including documented policies and
procedures regarding compliance with the ethical requirements, French professional guidance and applicable legal and regulatory
requirements.
Responsibility of the Statutory Auditor, appointed as an independent third party
On the basis of our work, our responsibility is to provide a report expressing a limited assurance conclusion on:
• the compliance of the Statement with the provisions of article R. 225-105 of the French Commercial Code;
• the fairness of the information provided in accordance with article R. 225‑105 I, 3 and II of the French Commercial Code, i.e., the
outcomes, including key performance indicators, and the measures implemented considering the principal risks (hereinafter the
“Information”).
However, it is not our responsibility to comment on:
• The entity’s compliance with other applicable legal and regulatory provisions, in particular the French duty of care law and anti-
corruption and tax evasion legislation;
• The compliance of products and services with the applicable regulations.
Nature and scope of our work
The work described below was performed in accordance with the provisions of articles A. 225-1 et seq. of the French Commercial Code
determining the conditions in which the independent third party performs its engagement and with the professional
guidance of the French Institute of Statutory Auditors (“CNCC”) applicable to such engagements, as well as with ISAE 3000 – Assurance
engagements other than audits or reviews of historical financial information
Our procedures allowed us to assess the compliance of the Statement with regulatory provisions and the fairness of the Information:
• we obtained an understanding of all the consolidated entities’ activities, the description of the social and environmental risks
associated with their activities, as well as the resulting policies and their outcomes;
• we assessed the suitability of the Guidelines with respect to their relevance, completeness, reliability, objectivity and
understandability, with due consideration of industry best practices, where appropriate;
• we verified that the Statement includes each category of social and environmental information set out in article L. 225‑102‑1 III;
• we verified that the Statement includes an explanation for the absence of the information required under article L. 225-102-1 III, 2;
• we verified that the Statement presents the business model and the principal risks associated with all the consolidated entities’
activities, including where relevant and proportionate, the risks associated with their business relationships and products or services,
as well as its their policies, measures and the outcomes thereof, including key performance indicators;
• we verified, where relevant with respect to the principal risks or the policies presented, that the Statement provides the information
required under article R. 225-105 II;
• we assessed the process used to identify and confirm the principal risks;
• we asked what internal control and risk management procedures the entity has put in place;
• we assessed the consistency of the outcomes and the key performance indicators used with respect to the principal risks and the
policies presented;
• we verified that the Statement covers the scope of consolidation, i.e., all the companies included in the scope of consolidation in
accordance with article L. 233-16 within the limitations set out in the Statement;
• we assessed the data collection process implemented by the entity to ensure the completeness and fairness of the Information;
PricewaterhouseCoopers Audit
Agnès Hussherr Pascal Baranger
Partner Sustainable Development Director
Plan to prevent risks relating to the Bank’s communication and awareness initiatives for employees are
activities intended to encourage ‘Speak-up culture’ within HSBC.
Regarding the impact of bank financing on potential breaches of 32 alerts were received and accepted into the HSBC Confidential
human rights and environmental protection, the sustainability risk channel in France in 2020, down 41 per cent compared to 2019.
management policy adopted by HSBC for more than 15 years The main theme emerging from the admitted alerts was related to
provides a solid risk management framework. An annual review is human behaviour in the work environment.
carried out regarding Global Banking and Markets and Commercial Arrangements in place in the HSBC Continental Europe
Banking clients operating in sectors covered by the Group’s sector branches and figures
policies, and all transactions in these sectors are also reviewed.
Alerts sent by employees in HSBC Continental Europe branches
HSBC’s sector policies cover agricultural commodities, chemicals,
are received and fully processed by the Group (with the exception
defence, energy, forestry, mining and metals, World Heritage Sites
of the Polish branch which receives its alerts locally as France).
and Ramsar wetlands*. HSBC regularly reviews and refines these
The Whistleblowing oversight team in France within HSBC
policies, including through constructive dialogue with NGOs and
Continental Europe Compliance monitors activities relating to the
action groups, alongside which it regularly addresses matters of
whistleblowing arrangements in the HSBC Continental Europe
common interest. HSBC has applied the Equator Principles since
branches.
they were first developed in 2003, including the latest version
(‘EP3’) since 2014. In addition, regarding six particularly carbon- In HSBC Continental Europe branches, 6 alerts were received in
intensive sectors (oil and gas, energy, construction, chemicals, 2020. All of these alerts related to poor human behaviour in the
automotive, mining and metals), HSBC has developed a method to work environment (HR cases).
assess the climate strategies put in place by its business clients in
order to oversee the impact of its financing more effectively. * These statements and policies can be viewed on the ‘Our Approach/
ESG reporting and policies’ page of the Group website.
For more details, see the ‘Managing the environmental risks https://www.hsbc.com/our-approach/esg-information/esg-reporting-
related to banking activity’ section on page 56. and-policies
Internal Whistleblowing system
HSBC strives to create a working environment in which employees
feel free to share their concerns. Aware that certain circumstances
require special discretion, it simplified its whistleblowing system in
2015 by creating "HSBC Confidential". The arrangements are open
to all employees of HSBC and other stakeholders. The
arrangements can be used anonymously by the whistleblower and
are accessible, at any time. Enhancements to the channel in
December 2020 mean the majority of concerns are now raised
through an independent third party offering 24/7 hotlines and a
web portal in multiple languages, including French and English.
The arrangements are supervised by an independent team within
the Compliance function. It can be used to report, in particular,
facts or behaviour constituting a serious violation of human rights
and fundamental freedoms, the health and safety of persons as
well as the environment resulting from the activities of HSBC
Continental Europe as well as those of their subcontractors or
suppliers, in accordance with Law N° 2017-399 of 27 March 2017
relating to the duty of care of parent companies and ordering
companies. Investigations are conducted confidentially, in depth
and independently by investigators who are trained and made
aware of the legislation / regulations applicable to whistleblowing
arrangements.
Alerts received in France are fully managed in France (i.) while
alerts sent by employees in HSBC Continental Europe branches (ii.)
are received and fully processed by Group in accordance with the
processes put in place by Group (with the exception of the Polish
branch which receives its alerts locally, as France). As the French
alerts and the alerts from HSBC Continental Europe branches do
not follow the same process, the figures are therefore reported
separately in this report.
Arrangements in place within HSBC Continental Europe
in France and figures
In accordance with Law N° 2017-399 of March 27, 2017 on the
duty of care of parent companies and ordering companies, the
whistleblowing arrangements can be used to report facts or
behaviour constituting a serious violation towards human rights
and fundamental freedoms, human health and safety and the
environment resulting from the activities of HSBC Continental
Europe as well as those of their subcontractors or suppliers.
HSBC Confidential in France is placed under the supervision of the
Audit Committee. Investigations are conducted, in a confidential,
in-depth and independent manner by investigators from different
departments, mainly Compliance and Human Resources. Controls
are in place relating to maintaining confidentiality and to protect
whistleblowers from the risk of retaliation. Periodic
• No appetite for inappropriate market conduct by a member of As part of HSBC Group’s stress testing programme, a number of
staff or by any group business. internal macroeconomic and event-driven scenarios were
considered to assess HSBC Group’s planning with respect to the
Enterprise-wide application impact of the United Kingdom’s withdrawal from the European
HSBC Continental Europe’s risk appetite is set out in the Risk Union. The results confirmed that HSBC Group is well positioned
Appetite Statement, which describes the types and levels of risk in the event of potential shocks.
that HSBC Continental Europe is prepared to accept in executing This risk has diminished since 31 December 2019.
its strategy. The HSBC Continental Europe’s Risk Appetite
Statement covers the following key areas of risk, with detailed IBOR transition
measures for each category: Financial Crime Compliance, The Financial Stability Board has observed that the decline in
Regulatory Compliance, Operational Risk, Reputational Risk, interbank short-term unsecured funding poses structural risks for
Resilience Risk, Asset Management, Insurance, People Risk, Cost interest rate benchmarks that reference these markets.
of Risk, Risk Diversification, Market Risk, RWAs, Capital (including
In response, regulators and central banks in various jurisdictions
leverage ratio), Liquidity and Funding, Interest Rate Risk on the
have convened national working groups (‘NWGs’) to identify
banking book portfolio, Earnings and Costs. Quantitative
replacement rates for these interbank offer rates ('IBORs') and,
statements and qualitative metrics are assigned to the above risk
where appropriate, to facilitate an orderly transition to these rates.
categories. Measurement against the metrics:
• guides underlying business activity, ensuring it is aligned to risk
appetite statements;
• informs risk-adjusted return;
• enables the key underlying assumptions to be monitored and,
where necessary, adjusted through subsequent business
planning cycles; and
• promptly identifies business decisions needed to mitigate risk.
The Risk Appetite Statement is approved by the HSBC Continental
Europe Board following advice from the Risk Committee, and is a
key component of the risk management framework. It is central to
the annual planning process and seeks to be aligned with the
strategy.
The business performance against these risk appetite metrics is
reviewed on a monthly basis in the Risk Management Meeting and
quarterly in the Risk Committee and Board. Details of metrics that
Following the announcement by the UK’s Financial Conduct and industry initiatives such as the ISDA protocol are necessary to
Authority in July 2017 that it will no longer persuade or require enable a more ordered transition coupled with legislative
banks to submit rates for LIBOR after 2021, the NWGs for the approaches for the products which are structurally difficult to
affected currencies were tasked with facilitating an orderly transition (‘tough legacy’). Repapering and operational booking
transition of the relevant LIBORs to their chosen replacement will be coordinated and driven by the client’s willingness, with a
rates. The EUR NWG was also responsible for facilitating an defined commercial strategy in place for each global business.
orderly transition of the Euro Overnight Index Average (‘EONIA’) to Dedicated teams are in place to support the client engagement
the Euro Short-Term Rate (‘€STR’) as a result of the determination and facilitate the transition, and specific training helps to further
that EONIA could not, as it was computed before 2nd October mitigate the conduct risk potentially generated by the legacy book
2019, be made to comply with the European Benchmark transition.
Regulation (‘BMR’) and could therefore no longer be used beyond
2021.
Financial instruments impacted by IBOR reforms
HSBC established the IBOR transition programme with the Amendments to IFRSs issued in August 2020 (Interest Rate
objective of facilitating an orderly transition from LIBOR and Benchmark Reform Phase 2) represents the second phase of the
EONIA for HSBC and its clients. This global programme oversees IASB’s project on the effects of interest rate benchmark reform,
the transition effected by each of the global businesses and is led addressing issues affecting financial statements when changes are
by the Group Chief Risk Officer. made to contractual cash flows and hedging relationships as a
result of reform. Under these amendments, changes made to an
In HSBC Continental Europe, the programme is led by the HSBC amortised cost financial instrument that are economically
Continental Europe Chief Risk Officer. Substantial change has equivalent and required by interest rate benchmark reform do not
been undertaken to develop products that reference the result in the derecognition or a change in the carrying amount of
replacement rates and enable the transition of legacy EONIA/ the financial instrument, but instead require the effective interest
LIBOR contracts, which exposes HSBC to material financial and rate to be updated to reflect the change in the interest rate
non-financial risks. benchmark. In addition, hedge accounting will not be discontinued
Throughout 2020 the programme has continued to develop solely because of the replacement of the interest rate benchmark if
products that reference the replacement near Risk Free Rates the hedge meets other hedge accounting criteria.
(‘nRFR'), including the supporting processes and systems, and to These amendments apply from 1 January 2021 with early adoption
make them available to customers. This included meeting permitted. HSBC has adopted the amendments from 1 January
regulatory deadlines for loan product readiness and the transition 2020.
to nRFR discounting by clearing houses. A structured development
plan had to be designed given the widespread use of LIBOR and Financial instruments yet to transition to alternative benchmarks,
EONIA in a wide range of products, systems and processes across by main benchmark
each of the four global businesses. The associated operational risk Total gross
is closely monitored by the programme. Moreover, the material carrying value/
change in the interest computation methodology for loans when USD GBP notional
Eonia Libor Libor Others1 amount
moving from LIBORs to nRFRs and the interpretation of nRFR loan
€m €m €m €m €m
market conventions are a source of conduct risk, that HSBC
addresses through specific client communication processes. At 31 Dec 2020
Non-derivative
EONIA is now off sale for almost all products in HSBC Continental financial assets2 1 2,098 272 1 2,372
Europe and has also been removed from our internal funding Non-derivative
processes; only new EONIA swaps are still being traded, as the financial liabilities2 2 229 — — 231
liquidity of the €STR swaps market has not taken off yet. LIBOR Derivative notional
sales continue as long as the equivalent products in nRFR are not contract amount 192,127 332,644 45,180 45,827 615,778
available and/or the liquidity is not present in the market. Selling
such products referring indices that will be discontinued is also a 1 Comprises financial instruments referencing other significant
source of conduct risk that HSBC mitigates notably through benchmark rates yet to transition to alternative benchmarks (EUR
Libor, JPY Libor and CHF Libor).
specific client information processes and following the industry
2 Gross carrying amount excluding allowances for expected credit
groups’ guidance on the enhancement of the legal documentation.
losses.
It extends to the EURIBOR contracts; indeed, even if the EURIBOR
is not planned, for now, to be discontinued, the industry is The amounts in the above table relate to HSBC Continental
working on developing robust fallback clauses for this index as Europe's main operating entities1 and provide an indication of the
required by the European Benchmark Regulation, which will have extent of the group's exposure to the Ibor benchmarks which are
to be incorporated in EURIBOR new contracts and potentially also due to be replaced. Amounts are in respect of financial
in some legacy contracts. instruments that:
In addition to offering new alternative rate based products, the • contractually reference an interest rate benchmark that is
new product capabilities will also help enable the transition of planned to transition to an alternative benchmark;
outstanding LIBOR and EONIA products. HSBC has begun to
engage clients to determine their ability to transition in line with • have a contractual maturity date after 31 December 2021, the
the readiness of the alternative rate product availability. date by which Libor is expected to cease;
Covid-19 may have affected the ability of clients to transition early • are recognised on HSBC's consolidated balance sheet.
and could result in compressed timelines for IBOR transition. 1 Entities where we have material exposures impacted by Ibor reform
Therefore, development and use of appropriate migration tools, in countries including France, the Netherlands, Spain and Ireland.
The main risks identified during the crisis have been • Specific tool kit trainings on resilience, remotely management
actively monitored: to support managers and employees in the current difficult
context,
Operational Risk: The dependency on offshore locations, and our
IT infrastructure is clear. The response from our offshore locations • Awareness of HR teams and Contact center to answer
has been at the expected standards. In Q4-2020 we experienced a employees’ queries,
second wave of Covid-19 where no major issues had to be to be • Detailed daily reporting on Covid-19 cases in order to be
reported. Remote working is becoming more and more accepted informed on the situation evolution within the company.
by employees. As long as the Covid-19 situation remains we will
More specifically, at the end of lockdown, additional actions were
keep the IT infrastructure and our protocols in place to be able to
taken to support employee’s reluctance to return back to the
return to full home working if necessary.
office:
Control Environment: Covid-19 has led to some exceptions to
• Progressive return to workplace with a maximum employee
standard practices which have been validated by the relevant Risk
occupancy on site for each three phases associated with
stewards and recorded in a central register.
remote working maintained as much as possible and flexibility
Coming challenges: on arrival/departure hours,
Define and implement new ways of working following the new • Sanitary measures such as hydro-alcoholic gel available at
norm post Covid-19. This will involve a mix of main office working, entrance building/floor, enhanced daily desk cleaning, and
contingency site, and Working from Home (WFH). Return to masks provided to employees,
workplace plans keep being adapted to follow the latest • Social distancing organised through floor markings, lifts with
development of the pandemic and the government responses. limited occupancy, serving packed lunch in company
The HSBC Operations, Services and Technology teams have restaurant,
continued to work with all Global Businesses to ensure resiliency • Development workshops to get employees feedbacks on the
under a range of operating scenarios and are continuing to crisis and support from in-house Health Centre.
actively monitor other risk levels across the business, particularly
increased operational risk (staff capacity, largely mitigated by the Model Risk
rapid move to remote working), reputational risk, and fraud. The unprecedented character of the economic and financial
Further to our operational response to the pandemic, specific disruptions created by the Covid-19 crisis is a challenge to
attention is given to the impact of Covid-19 across our key modelling. Models, in the sense of quantitative methods that apply
regulatory change programmes. The wider implications of mathematical techniques and assumptions to process input data
potential material impacts are monitored, in order to ensure our into quantitative estimates, are used by the bank for a wide range
Regulatory Compliance Risk profile remains reflective and of purposes, including calculation of risk-weighted assets, loan
accurate. impairment charges, fair valuation of some financial instruments,
financial crime and fraud risk management, stress testing, and
All of our businesses and functions have focused on
credit approvals.
understanding what processes needed to change to accommodate
a working from home model and also to operate effectively in the All models are based on a fundamental assumption that there exist
‘new normal,’ which we anticipate will involve a mix of main office some stable relationships between various aspects of the
working, contingency site, and working from home. A Covid-19 modelled situation, or in other terms that the future will look like
Inventory is now in place to document all known exceptions to the past. Hence they cannot be trusted to provide wholly reliable
how teams are operating versus what had previously occurred in predictions in an unprecedented state of affairs such as the deep
business as usual. Such exceptional handling has been agreed recession caused by the current health crisis.
through formal governance arrangements. Amongst the main impacted models are the Credit Risk models
used for capital requirements and accounting provisions: they are
based on lagged data and on past patterns which may not reflect
If it were to materialise, it could have a material effect on the circumstances, and these will become permanent. Beside, the
Group’s long-term strategy, profitability and/or reputation. Existing bank has supported its customers through this difficult period, in
mitigation plans are likely to be minimal, reflecting the uncertain particular by granting loan repayment holidays depending on their
nature of these risks at this stage. individual situation and, for those eligible, by participating in the
support schemes organised by the French state. So far, the
During 2020, we made certain changes in the list of our top and
consequences of the crisis on the bank’s retail loan portfolio have
emerging risks, reflecting the evolution of the issues facing HSBC
been rather moderate. In parallel, the bank has carried on with its
Continental Europe. Our current top and emerging risks, as
assessment of the various strategic options available to it
assessed by us, are as follows:
regarding this business.
Externally Driven Regarding its Global Banking and Markets business, HSBC
Continental Europe has continued to on-board European
Macroeconomic risks companies, in particular those that were banking with its UK
The Covid-19 pandemic led this year, notably in Europe, to sudden parent, HSBC Bank plc, so that service continuity was ensured for
episodes of recessions, which have been unprecedented in all of them ahead of the end of the transition period. At the same
magnitude since World War II. During the second quarter of 2020, time, the bank is now focusing its organic growth on clients and
lockdowns of populations in many countries and the suspension of products that are meeting in full the strategic orientations of the
productive activities meant a historical trough for the concerned HSBC Group, which is to reinforce its position as a dominant
economies. However, from March, national fiscal authorities and international bank in Europe while reducing capital consumption
the ECB have taken strong measures to support firms and and costs there for redeployment within higher growth
employment, but also to ensure that the financing of the real geographies. Besides, in consideration of persistent imbalances in
economy did not face any issue. Extremely substantial public economic situations across countries in the EU and of the
spending has been engaged, pushing fiscal deficit and the public uncertainties generated by United Kingdom’s withdrawal from the
debt ratio to record levels in some cases, while the ECB enhanced European Union, HSBC Continental Europe continues to maintain
banks’ liquidity and funding conditions (‘TLTRO III’) and limited market risk positions in its trading book portfolio. These are
strengthened its quantitative easing policy through the creation of subject to frequent stress tests based on a number of different
a Pandemic Emergency Purchase Programme (‘PEPP’). scenarios which the bank modifies according to the observed
trends and possible evolutions of the economic environment. Also,
After an improvement in the health situation at the beginning of risk calculations and the limits set to the ‘front office’ teams take
the summer in 2020, contributing to a very large rebound in the into account the relative illiquidity of certain markets.
economic activity over the third quarter, the pandemic spread
accelerated during the autumn across Europe, where growing The Commercial Banking network has mobilised itself to support
restrictions limited people’s mobility. New lockdowns have been its clients exposed to the impacts of the crisis, both under
implemented from October 2020, weighing on the domestic government-driven schemes (State-Guaranteed loans in France or
economic activity, in spite of fiscal supports sometimes increased their equivalent in other European countries) and under loan
compared to the packages decided during the spring. moratoria agreed across the French banking industry (quasi-
systematic six month loan repayment deferrals granted to SMEs in
All in all, although the economic outlook in Asia but also in the US the second quarter), and also by granting new financing and/or
finally looks less deteriorated than initially expected, 2021 may additional flexibilitiy on a case by case basis. While doing so, it has
prove for Europe a year beginning with a lower than anticipated also adapted its organization and its resources to reinforce the
growth and with rising uncertainties about the recession-induced monitoring of its corporate clients’ situation and address problems
permanent scarring on medium term potential growth and on at an early stage.
public finances, which have been durably affected in several
countries. Indeed, despite a progressive recovery in global trade As concerns industry sector risks, HSBC Continental Europe has
and in spite of bond yields having touched historically low levels long established procedures and a control framework which
for some sovereign borrowers, the reported increase in the includes the review, in detail, of all significant exposures to
household saving ratio and a deteriorated labour market in Europe customers operating in a higher risk sector, the establishment of
have fueled fears that the level of activity reached at the end of sector ‘Caps’ and a programme of stress tests designed to
2019 may not be recorded again before 2022 on average. regularly evaluate the effect of an exceptional deterioration
Admittedly, any success to manage the pandemic better than occurring in certain sectors which the bank is particularly exposed
forecast thanks to vaccines would represent an upside risk to to. The lending guidelines are updated as necessary in the event of
economic growth in the near term. any material change observed in particular sectors as well as in
consideration of any conclusions that could be drawn from these
Mitigating actions ‘stress tests’. Bank wide stress tests are undertaken annually to
Faced with these challenges, HSBC Continental Europe has measure the impact of a major economic downturn on the bank’s
maintained its efforts to adapt itself to this new environment in results and its balance sheet.
order to offset its impact on its profitability and reinforce the In terms of life insurance activities, HSBC Continental Europe
sustainability of its economic model. continues to apply a long term management strategy of its assets
This adaptation requires maintaining a very strict cost control, and hedging which have the effect of mitigating the impact of the
while carrying-on with necessary modernisation efforts. decline in yields. It is worth noting in this respect that HSBC
Assurances Vie (France) is the only insurance company in France
In Retail banking, the transformation of the distribution model in that integrates in its profit and loss account the variations in
2018, with the specialisation of the salesforce, combined with an Present Value In Force (‘PVIF’), which is the net present value of
accelerating modernisation of internet banking services, turned the profits expected to be generated by its current portfolio of
out to be particularly relevant : lockdowns and travel restrictions investment assets. In order to preserve its solvency ratio, HSBC
have led an increasing proportion of customers to use them and to Assurances Vie (France) has also made various adjustments,
have recourse to the central teams in charge of client relationship including on the sharing of distribution fees with its distribution
under the remote banking model. channel, namely the HSBC Continental Europe branch network.
New processes for the secure exchange of documents have been
made available to help clients to cope with these exceptional
Mitigating actions all Lines of Business have taken full ownership of Conduct risk,
like the other risks.
The security of our information and technology infrastructure is
crucial for maintaining our banking applications, processes, Regulatory Compliance oversees and provides advice to the lines
protecting our customers and the HSBC brand. We continue to of Business in their action plans, with a focus on employee
strengthen and significantly invest in our ability to prevent, detect training, to address any concern or possible delay in the
and respond to the ever-increasing and sophisticated threat of application of the regulatory requirements. It engages with internal
cyber attacks. More specifically, many tests are conducted and external stakeholders, including Regulators, as part of its role
internally to raise the awareness of the HSBC employees of the as Risk Stewards in achieving HSBC’s strategic priorities.
risk of phishing. This risk has remained stable versus 31 December 2019.
Cyber risk is a top priority of the Board and is regularly reported to
Financial crime risks
ensure appropriate visibility, governance and executive support for
our ongoing cyber security programme. HSBC has no appetite to see its products being used to transform
the profits of crime and corruption into legitimate assets, to
This risk is stable versus 31 December 2019.
finance terrorism, transfer money to sanctioned countries or
Tax transparency risks individuals or facilitate tax evasion. The risk of financial crime
remains a top risk for HSBC which continuously reinforces its
In common with all companies, HSBC Continental Europe is
framework to detect and deter suspicious activities.
potentially exposed to the risk that tax rules could be
misinterpreted or incorrect application of the increasingly complex Mitigating actions
tax rules that apply. In particular, the tax authorities are The framework is built to observe the letter and spirit of all
increasingly attentive to the transfer pricing that apply between relevant laws, codes, rules, regulations and standards of good
member companies of large international groups such as HSBC. market practice. These include those relating to financial crime
HSBC Continental Europe runs the risk of a tax adjustment or compliance such as Anti-Money Laundering (‘AML’), Counter
penalties in the event that the bank does not respect these rules Terrorist and Proliferation Financing, Sanctions, Anti-Bribery and
and in particular the requirement to transact with its parent Corruption (‘AB&C’), Fraud Prevention and Tax Transparency with
company at normal commercial conditions. the following top priorities:
Moreover, certain clients of HSBC Continental Europe could use • A suitable Customer Due Diligence (‘CDD’) framework, which
some of its services with the objective of tax evasion which could incorporates Customer Identification and Verification (‘ID&V’)
expose the bank to charges of collusion and which, if confirmed, and Know Your Customer (‘KYC’) principles, as well as
could also lead to severe financial, legal and reputational risks. Enhanced Due Diligence (‘EDD’) on customers assessed as
higher risk, such as Politically Exposed Persons (‘PEPs’) in
Mitigating actions
senior positions, their relatives and close associates;
HSBC Continental Europe Tax department works closely with
• A good Financial Crime Risk culture, from top management to
other central Functions and the various Global Businesses as well
each staff member, with regular training of employees and
as with other Group entities to verify that the transactions
contractors;
undertaken for the bank’s own account or by our clients are
consistent with the spirit and letter of the tax laws (tax • A suitable Transaction Monitoring framework, designed to
transparency principles). Furthermore, it also monitors that the monitor customer transactions for the purpose of identifying
transfer pricing conditions applied by other Group entities is suspicious activity to be reported to Tracfin;
properly justified and documented. • The suitable screening of customers, third parties and
This risk has remained stable versus 31 December 2019. transactions globally against the sanctions lists, with the
associated investigations being conducted in a reasonable
Regulatory Compliance including Conduct timeframe;
The Industry continues to operate under an increasing focus of • Ensure prohibition of business activity that HSBC believes may
regulators on Conduct matters, such as the fair treatment of violate applicable sanctions laws or HSBC’s Global Sanctions
customers with specific attention paid on the protection of fragile Policy;
customers and compliance with conduct rules in financial markets
(including the market abuse framework). • A suitable ‘AB&C’ framework compliant with the HBSC Group
policy and the requirements of Sapin 2 and the Agence
The ACPR also mentioned it was paying particular attention to Francaise Anticorruption (‘AFA’);
digital initiatives, artificial intelligence, FinTech developments and
e-activities, reminding banks that these changes should aim at the • Appropriate Fraud prevention systems to deter and detect all
clients' interest and allow enhanced traceability and control. internal and external fraud attempts;
The green finance and crypto-currencies have also been • Robust policies designed to meet the obligations related to tax
mentioned as emerging issues. The French law on energy fraud and tax evasion in line with art L561-15-11 of the Code
transition and green finance will have to be reviewed following Monétaire et Financier as well as FATCA, CRS and DAC6
European initiatives, and preventing green-washing and pushing reporting requirements.
for a better harmonization of methodologies to define what green This risk is stable versus 31 December 2019.
really is have been a big stake for the AMF. Regarding crypto-
currencies, the French regulators are calling for a European Environmental risks
initiative. HSBC has recently set out its ambitions to be the leading bank
Mitigating actions within the Net Zero Economy. The Net Zero Economy will require
banks to think of return on investment not just in financial terms,
In line with Group initiatives and the Global Conduct Policy, HSBC but in terms of impact on the climate, society, and the natural
Continental Europe has implemented the Conduct framework: ecosystems upon which we depend.
HSBC is aware that those environmental threats including climate
change and transition to a low carbon economy will generate risks
in the short, medium and long term. HSBC Continental Europe
cost base. The current uncertain macroeconomic outlook adds relations and political leadership are now an increasing driving
pressure on revenues, loan impairment charges, and impacts force behind financial market volatility.
credit, capital, liquidity and people risks. The Group strategy US: The US elections were the main focus this year.
presented on 18 February 2020 aims to improve returns and
efficiency in Continental Europe by 2022, and to reduce Risk Middle East: Broadly the region was calm in 2020. The
Weighted Assets (‘RWAs’). Given these guidelines, Global agreements signed by Israel in 2020 establishing diplomatic
Businesses have reviewed their operating models, to build more relations with four Arab League countries, Bahrain, the United
streamlined and effective operations across Europe. HSBC Arab Emirates, Sudan and Morocco were positive for the region.
Continental Europe’s focus in 2021 is to continue to manage US tensions with Iran remained high however. It remains to be
Covid-19 impacts whilst moving forward with the transformation seen whether the new US administration will change existing US
of our activities: (i) the strategic review of the retail operations policy or not.
which is ongoing and no decision has been made; (ii) the Europe: The United Kingdom left the European Union on
repositioning of our Global Banking and Markets (‘GBM’) activities 31 January 2020 and entered a transition period until
for which a social plan has been approved by the French Ministry 31 December 2020, during which negotiations took place on the
of Labour – associated employee exits will take place in 2021; future relationship between the UK and the EU. The risk of a no
(iii) the reshaping of our Commercial Banking (‘CMB’) activities deal remained high throughout 2020.
and support functions through a voluntary redundancy plan; and
(iv) the transformation of the HSBC Continental Europe Mitigating actions
International/European Economic Area (‘EEA’) branches, which We continue to closely monitor the evolving political and
increases focus on client-related activities whilst better leveraging economic environments and portfolio quality to the sectors most
our Paris hub and the Group’s Centres of Excellence. The affected. In particular, exposure is reviewed regularly for ‘at risk’
adaptation of our operational model will enable a significant sectors or companies.
reduction of our cost base across Continental Europe. HSBC
The risk has remained stable versus 31 December 2019
France has changed its name to become HSBC Continental
notwithstanding the threat of a no deal throughout much of this
Europe. The new name better reflects the purpose and nature of
year.
its activities, namely an integrated Continental European bank
connecting our customers to HSBC’s global network, and
providing access to Continental Europe for HSBC’s customers Internally driven
around the world. IT risks & Operational resilience risks
Mitigating actions Apart from malicious activities, the bank’s IT systems are also
HSBC Continental Europe has identified a number of initiatives to exposed to malfunction or breakdown risk, which would affect
adapt its businesses and its cost structure to the current HSBC Continental Europe’s clients, operations or its ability to
environment. These are being tracked both at the country, comply with regulatory obligations.
European and Group level. Key projects such as the repositioning
Mitigating actions
of our Global Banking and Markets (‘GBM’), and Commercial
Banking (‘CMB’) activities, the adaptation of our operational model HSBC Continental Europe is implementing a regular data and
as well as for the preparedness of the United Kingdom’s departure software migration programme onto new servers. In some
from the European Union are being implemented to support instances, the Bank decided to outsource some IT services to third
market developments. The strategic review of our Retail party companies whenever it is safer and more efficient. The use
operations is still ongoing. No decision has been taken. of Cloud services allows us to increase our resilience while
maintaining control over our data, applications and architecture.
This risk has increased since 31 December 2019 given the
macroeconomic environment which has worsened due to the An evergreening plan is in place to updates the software being
sanitary crisis. used with the recent versions to ensure that vendor support will be
obtained if an incident occurs.
Reputational Risk
This risk is stable versus 31 December 2019.
The need to adapt HSBC Continental Europe’s business model to
the current operating environment has significantly increased the People risks
number of transformational projects. The intensity and the pace of A more challenging external environment, made worse by the
transformation is an area of concern for HSBC Continental Covid-19 crisis as well as the implementation of several
Europe’s reputation overall as well as for employees. restructuring projects in accordance with our ongoing strategic
Mitigating actions orientation at HSBC Continental Europe impact the bank’s staff
and create an environment that many employees feel as complex
These risks are closely monitored and mitigation actions have and more uncertain.
been implemented, including an enhanced communication plan.
Due to the low interest rates environment, an increasingly
The risk has increased since December 2019. competitive situation in market activities and the Covid-19
Geo-political Risk pandemic crisis, HSBC Continental Europe's financial results are
deteriorating compared to previous years and this situation could
Financial markets around the world remained impacted by therefore potentially lead to a decrease in staff engagement and
geopolitical dynamics. High levels of geopolitical risk has become increased sick leave. In addition, the current transformation and
the new normal, with uncertainty surrounding policy, international increasing complexity in the banking industry modify the skills and
expertise required in all Businesses and Functions. Staff have to
analytic developments and technologies, actively reaching out to • HSBC have also initiated efforts to modernise data architecture
new Artificial Intelligence-Machine Learning (‘AI-ML’) programs and infrastructure through adoption of big data, cloud, machine
which are in the process of being developed. The embedding of learning, advanced analytics and visualisation technologies. To
environment risks in modelling is still an emerging topic; the help our employees keep abreast of Data Management and
second line of defence is encouraging businesses to consider it in Data Privacy Laws and Regulations and continue to hold annual
their upcoming model developments. data symposiums and data privacy awareness training
highlighting our commitment to protect personal data for our
The risk has increased versus 31 December 2019.
customers, employees and stakeholders.
Data management risks The risk is stable versus 31 December 2019.
HSBC Continental Europe uses a large number of systems and
applications to support key business processes and operations. As
Third Party Risk
a result, we often need to reconcile multiple data sources, HSBC Continental Europe utilises third parties for the provision of
including customer data sources, to reduce the risk of error, and to a range of services, in common with other financial service
ensure an accurate, complete and up to date data in our systems. providers. Risks arising from the use of third-party service
HSBC, along with other organisations, also needs to meet providers may be less transparent and therefore more challenging
external/regulatory obligations such as the General Data Protection to manage or influence. It is critical that we ensure we have
Regulation (‘GDPR’), the Basel committee for Banking Supervision appropriate risk management policies, processes and practices.
(‘BCBS’ 239) principles and Basel III. These should include adequate control over the selection,
Mitigating actions governance and oversight of third parties, including Cloud,
particularly for key processes and controls that could affect
• We continue to improve data quality across the large number
operational resilience. Any deficiency in our management of risks
of systems that we use. Data management, aggregation and
arising from the use of third parties could affect our ability to meet
oversight continues to strengthen and enhance the
strategic, regulatory or client expectations.
effectiveness of internal systems and processes. We have
continuously enhanced our data controls in order to comply the Mitigating actions
increased regulatory requirements and to better meet customer We continued to embed our delivery model in the first line of
expectations. defence through several dedicated teams. Processes, controls and
• We have achieved our objectives in support of the Basel technology to asses third party service providers against key
Committee for Banking Supervision (‘BCBS’ 239) principles. criteria and associated control monitoring and assurance have
been developed.
• We continue to enhance and advance our data insights, data
aggregation, reporting and decisions. We carry out ongoing Oversight capabilities in the second line of defence has been
improvement and investments in data Governance, data enhanced to monitor and embed policy requirements and
Quality, data Architecture and data Privacy. performance against risk appetite. Within the second line of
defence, the Resilience Risk is in charge of defining the strategy
• Through the implementation of the Global Data Management
and the policy for an effective management of the Third Party
Framework, HSBC has made progress in increasing coverage of
Risk.
key business processes and associated critical data to monitor
which again HSBC Continental Europe is benefiting from. A Governance: Any outsourcing of a material service is formally
proactive monitoring and reporting on the quality of customer, approved by the Bank Risk Management Meeting prior to the
product, reference and transaction data is designed for identify, contract commencement date.
track remediation and resolve the associated data issues in a A dedicated Cloud Committee is implemented to review each
timely manner. project to outsource on a Cloud to ensure adherence to the Group
• Additional control monitoring developed Key Performance, Cloud strategy and to review data privacy, regulatory compliance,
Control and Risk Indicators that will be integrated in 2021 with Legal and IT aspects.
the current controls and reported to the appropriate data A quarterly Third Party Risk Forum is in place to ensure that third
governance forums. parties are managed in line with Group standards and regulatory
• HSBC is continuously improving the global Data Privacy expectations.
Framework that establishes data privacy practices, design The risk has increased versus 31 December 2019.
principles and guidelines that demonstrate compliance with
Data Privacy Laws and Regulations in the jurisdictions which
Risk factors
HSBC Continental Europe operates such as the GDPR in EU.
Streamlining on the implementation of data privacy processes We have identified a comprehensive list of risk factors that cover
with new tools to enhance compliance with data privacy the broad range of risks our businesses are exposed to. A number
regulation on Data Transfers and Privacy Impact Assessments. of the risk factors have the potential to have a material adverse
effect on our business, prospects, financial condition, capital
position, reputation, results of operations and/or our customers.
They may not necessarily be deemed as top or emerging risks;
however, they inform the ongoing assessment of our top and
emerging risks that may result in our risk appetite being revised.
For the risks linked to Covid-19 see ‘Areas of Special Interest’ on
pages 83 to 85.
Geopolitical risk The UK’s withdrawal from the European Union may pose operating challenges to HSBC Continental
Europe in its adaptation to the new economic and regulatory environment. Likely Medium
Macro-prudential, HSBC Continental Europe is exposed to the risks associated with the replacement of benchmark
regulatory and legal indices.
risks Likely High
Risks concerning borrower credit quality are inherent in our businesses. Likely Very High
The delivery of our strategic actions is subject to execution risk. Likely High
HSBC Continental Europe is exposed to a risk of attrition along with a skills retention risk. Likely High
We have significant exposure to counterparty risk. Likely High
We may not achieve any of the expected benefits of our strategic initiatives. Unlikely High
HSBC Continental Europe remain susceptible to a wide range of cyber-risks that impact and/or are
facilitated by technology. Unlikely High
HSBC Continental Europe’s operations are highly dependent on our information technology systems. Unlikely High
Risks related to our
business, business HSBC Continental Europe could incur losses or be required to hold additional capital as a result of
operations, model limitations or weaknesses. Unlikely High
governance and HSBC Continental Europe’s operations utilise third-party and intra group suppliers and service
internal control providers. Likely Medium
systems
HSBC Continental Europe’s data management policies and processes may not be sufficiently robust. Likely Medium
HSBC Continental Europe's reputational risk is highly linked to its current organisational evolution. Likely Medium
Market fluctuations may reduce our income or the value of our portfolios. Likely Medium
HSBC Continental Europe’s operations are subject to the threat of fraudulent activity. Likely Medium
HSBC Continental Europe’s financial statements are based in part on judgements, estimates and
assumptions that are subject to uncertainty. Unlikely Medium
Liquidity, or ready access to funds, is essential to our businesses. Unlikely Medium
Third parties may use us as a conduit for illegal activities without our knowledge. Unlikely Medium
Macroeconomic risks carrying on with the transformation of its businesses. The HSBC
Group has launched a restructuring of its businesses and central
Current economic and market conditions may adversely functions. The Group strategy presented in February 2020 aims to
affect HSBC Continental Europe’s results. Probability: Likely / improve returns and efficiency in Continental Europe by 2022, and
Impact: Very High. to reduce Risk Weighted Assets (‘RWAs’). Following these
The Covid-19 outbreak has had, and continues to have, a material announcements, the global business lines and the central
impact on businesses and on the economic environment in which functions have been working on designing new business and
HSBC Continental Europe operates. It has caused disruption to operating models in order to make the bank simpler and more
HSBC Continental Europe’s customers, suppliers and staff. In most agile across Europe. This has been undertaken alongside the
countries in which HSBC Continental Europe operates, notably in strategic review of the Retail operations which is ongoing and for
France, schemes have been initiated by national governments to which, at this point, no decision has been made.
provide financial and social support to the economic sectors most Loss before tax was EUR 945 million in 2020, sharply down from a
impacted by the Covid-19 outbreak. EUR 22 million loss in 2019, and included impairments of tangible
As the Covid-19 outbreak continued to disrupt the economic and intangible assets, restructuring costs, an adverse PVIF
activity in most countries in the word, including in Europe movement and incremental ECL charges.
throughout 2020, there could be adverse impacts on HSBC
Continental Europe’s income due to lower lending and transaction
Geopolitical risks
volumes and lower wealth and insurance manufacturing revenue, The United Kingdom’s withdrawal from the European
including the present value of in-force long-term insurance Union may pose operating challenges to HSBC Continental
business (‘PVIF’), due to bond and equity markets volatility and Europe in its adaptation to the new economic and
weakness. In addition, lower interest rates will negatively impact regulatory environment Probability: Likely / Impact: Medium
net interest income and extreme market movements could have a The United Kingdom left the European Union on 31 January 2020
negative impact on HSBC Continental Europe’s markets activities. at midnight following the withdrawal agreement ratification, and
The current uncertain macroeconomic outlook will add pressure entered a transition period until 31 December 2020. A Trade and
on revenues, weigh on loan impairment charges, and impact Cooperation Agreement between the European Union and the
credit risk, capital risk, liquidity risk and people risk. United Kingdom was agreed on 24 December 2020, and ratified by
HSBC Continental Europe’s priority in 2021 is to continue to the British Parliament on 30 December 2020. Prior to European
manage the consequences of the Covid-19 health crisis while Parliament ratification (expected in 2021), the Trade and
Cooperation Agreement provisionally comes into effect from • Pricing risks, such as changes to benchmark indexes could
1 January 2021 onwards. The European Union and United impact pricing mechanisms on some instruments.
Kingdom agreed through a joint declaration to establish structured See also section ‘IBOR transition’ in the Areas of Special Interest
regulatory cooperation on financial services, with the aim of on pages 81- 83.
establishing a durable and stable relationship between
autonomous jurisdictions. However, there remain risks, many of Risks related to our business, business
them linked to the absence of tangible agreement between the operations, governance and internal control
United Kingdom and the European Union on financial services. systems
While the United Kingdom and the European Union have made a
number of equivalence decisions before the end of the transition Risks concerning borrower credit quality are inherent in
period, both parties are expected to establish the framework of our businesses. Probability: Likely / Impact: Very High.
their future cooperation with the Memorandum of Understanding Risks arising from changes in credit quality and the recoverability
to be signed by 31 March 2021. The United Kingdom’s future of loans and amounts due from borrowers and counterparties in
relationship with the European Union will have implications for the derivative transactions are inherent in the businesses of HSBC
future business model for HSBC Group’s London-based European Continental Europe. Adverse changes in the credit quality of our
cross-border banking operations, which relies on unrestricted borrowers and counterparties arising from a general deterioration
access to the European financial services market (discontinuation in economic conditions or systemic risks in the financial systems
of the free movement of services and significant changes to the could reduce the recoverability and value of our assets, and
United Kingdom’s immigration policy). require an increase in our loan impairment charges. The risk is that
Similarly, HSBC Continental Europe may be restricted in accessing we fail to estimate accurately the effect of factors that we identify
UK based financial infrastructure. or fail to identify relevant factors. Further, the information; HSBC
Continental Europe use to assess the creditworthiness of our
As a result, meeting HSBC clients' needs after the United counterparties may be inaccurate or incorrect. Any failure by
Kingdom’s departure from the European Union required HSBC Continental Europe to accurately estimate the ability of our
adjustments to HSBC European cross-border banking operations, counterparties to meet their obligations may have a material
including the transfer to HSBC Continental Europe of several EEA- adverse effect on HSBC Continental Europe its prospects, financial
based HSBC entities to HSBC Continental Europe and the condition and results of operations. The level of any material
migration of impacted businesses and clients from the United adverse effect will depend of the number of borrowers involved,
Kingdom to its EEA subsidiaries, in particular HSBC Continental the size of the exposures and the level of any inaccuracy of our
Europe. The programme is now largely completed. HSBC estimations.
Continental Europe has addressed many challenges (legal,
regulatory, organisational, operational, IT-related, HR-related, In 2020, HSBC Continental Europe has been taking exceptional
financial) as part of its adaptation programme. These adaptations measures to protect itself and its clients and participate in the
are now largely implemented and HSBC Continental Europe is prevention of an economic collapse, in particular through a quasi-
now providing continuity of service to EEA customers previously systematic six month deferral of loan repayments for its smaller
banking with HSBC Bank Plc. CMB clients and its personal, professional and entrepreneur client
base within WPB, with limited exclusions or restrictions. For the
See also page 9 (Purpose and strategy – Impact of United corporate segments, deferral of repayments has been considered
Kingdom’s withdrawal from the European Union on HSBC on a case-by case basis. At the beginning of the crisis, new money
Continental Europe) and page 81 (Areas of Special Interest – The financing has been granted to our customers, either state-
United Kingdom’s withdrawal agreement from the European guaranteed or not (depending on the individual situation). New
Union) for further information. money financing have been approved for large corporates to
Macro-prudential, regulatory and legal risks to the strengthen their short to mid-term liquidity at the beginning of the
business model of HSBC Continental Europe crisis, usually to support their rating or as a simple bridge to a
refinancing in the debt market.
HSBC Continental Europe is exposed to the risks
associated with the replacement of IBORs (interbank The review of counterparties under potential stress has been
offered rates). Probability: Likely / Impact: High reinforced since the beginning of the Covid-19 crisis, with a focus
on the early identification of cases that showed signs of credit
The planned replacement of key IBOR rates (LIBOR / EONIA) with worthiness deterioration.
alternative benchmark rates introduces a number of risks for
HSBC Continental Europe, its clients, and the financial services Credit Risk RWAs have increased as a result of the deferral of
industry more widely. This includes, but is not limited to: repayments, approval of waiver requests, additional financing
requests, precautionary drawdown by companies of their revolving
• Execution/operational risks, due to the requirement to adapt IT credit facilities and the downgrading of clients’ risk rating. For
systems, infrastructure and operational processes, notably for details concerning Credit Risk RWAs as at 31 December 2020 see
the legacy book transition; table 9: ‘Credit risk exposure – summary’ on page 16 in the 2020
• Conduct risks, relating to potential negative outcomes for the HSBC Continental Europe Pillar 3 document. The geographic
clients resulting from the sales of new product, the continued breakdown of exposures of HSBC Continental Europe and the
sales of IBOR products and the transition of the legacy book; credit risk exposures by industry sectors can be found in tables 14
and 15 on pages 22, 23 and 24 respectively in the 2020 HSBC
• Legal risks, as changes required to documentation for new and Continental Europe Pillar 3 document.
existing transactions may be required;
Expected Credit Losses have increased significantly over the
• Financial risks, arising from any changes in the valuation of period, reflecting the deterioration of the overall credit worthiness
financial instruments linked to benchmark rates; of the portfolio, which consequently increases the ECL for Stage 1
& 2. Stage 3 impairments have also materially increased as some
companies entered into default either through bankruptcy or as
they engaged into financial restructuring. Change in expected
credit losses and other credit impairment charges ('ECL') was
and operations in order to implement a sustainable and profitable Universal registration document concerning Operational risk
operating model that would be able to best serve its clients in the losses: quantitative data starting from 2012 for full details.
future. Within this framework, our strategy in Europe is to become HSBC Continental Europe’s operations are highly
the leading international wholesale bank, complemented by a dependent on our information technology systems.
targeted wealth management business. The HSBC Group’s Probability: Unlikely / Impact: High.
international network and expertise along with HSBC Continental
Europe’s coverage and capabilities provide us with a strategic The reliability and security of our information and technology
advantage to help clients achieve their goals, whether it is growing infrastructure, and our customer databases are crucial to
heir businesses in the single market or breaking into international maintaining the service availability of banking applications and
markets. The development and implementation of HSBC processes and to protecting the HSBC brand. The proper
Continental Europe’s strategy requires difficult, subjective and functioning of our payment systems, financial control, risk
complex judgements, including forecasts of economic conditions management, credit analysis and reporting, accounting, customer
in Continental Europe but also in other parts of the world. HSBC service and other information technology systems, as well as the
Continental Europe may fail to correctly identify the trends it seeks communication networks between our branches and main data
to exploit and the relevant factors in making decisions as to capital processing centres, are critical to our operations. Critical system
deployment and cost reduction.Key to achieving HSBC Continental failure, any prolonged loss of service or data availability or any
Europe’s strategy is to increase the cross-business and cross- material breach of data integrity, could cause serious damage to
border synergies between HSBC Group’s different entities across our ability to service our clients, could breach regulations under
the globe, while ensuring an efficient operating model across our which we operate and cause long-term damage to our business
Continental European operations. and brand that could have a material adverse effect on our
business, prospects, financial condition and results of operations.
HSBC Continental Europe’s transformation is articulated around No noticeable incidents or disruptions were reported for HSBC
four pillars: (i) the strategic review of the retail operations which is Continental Europe in 2019 and 2020. In addition HSBC
ongoing and no decision has been made; (ii) the repositioning of Continental Europe management considered the financial control
our Global Banking and Markets (‘GBM’) activities for which a environment and reviewed action taken to enhance controls over
social plan has been approved by the French Ministry of Labour – IT access management.
associated employee exits will take place in 2021; (iii) the
reshaping of our Commercial Banking (‘CMB’) activities and Operational losses for combined Information, technology and
support functions through a voluntary redundancy plan; and (iv) cyber security risks were EUR 0.22 million in 2020 (of which zero
the transformation of the HSBC Continental Europe International/ related to cyber risks). See table on page 146 of the HSBC
European Economic Area (‘EEA’) branches, which increases focus Continental Europe Universal registration document concerning
on client-related activities whilst better leveraging our Paris hub Operational risk losses: quantitative data starting from 2012 for full
and the Group’s Centres of Excellence. The adaptation of our details.
operational model will enable a significant reduction of our cost HSBC Continental Europe could incur losses or be required
base across Continental Europe. HSBC Continental Europe’s ability to hold additional capital as a result of model limitations or
to execute its strategy may be limited by its operational capacity weaknesses. Probability: Unlikely / Impact: High .
and the increasing complexity of the regulatory environment in
which HSBC Continental Europe operates. HSBC Continental Europe uses models for a range of purposes in
managing its business, including calculation of risk-weighted
HSBC Continental Europe remains susceptible to a wide assets, loan impairment charges, fair valuation of some financial
range of cyber-risks that impact and/or are facilitated by instruments, financial crime and fraud risk management, stress
technology. Probability: Unlikely / Impact: High. testing, and credit approvals.
The threat from cyber-attacks remains a concern for our HSBC Continental Europe could in some cases face adverse
organisation, and failure to protect our operations from internet consequences as a result of decisions by management based on
crime or cyber-attacks may result in financial loss, business the use of models. This can happen when models have been
disruption and/or loss of customer services and data or other inadequately designed or implemented, when their outcome is
sensitive information that could undermine our reputation and our misunderstood or used beyond the model’s intended use case, or
ability to attract and keep customers. Ransomware and as a result of random events whose probability was neglected in
Distributed Denial of Service (‘DDOS’) attacks are an increasingly the model design. Such events are made more probable by the
dominant threat across the industry. In 2020, the bank was subject uncertain and unprecedented environment created by the
to a small number of DDOS attacks on our external facing Covid-19 crisis. Risks arising from the use of models could have a
websites across the Group. In 2020, the bank was not subject to material adverse effect on our business, prospects, financial
ransomware attacks although there were several attacks on condition, results of operations, minimum capital requirements
Third Parties & Customers. Although cyberattacks had a negligible and reputation. Regulatory scrutiny and supervisory concerns over
effect on our customers or services due to the increasing banks’ use of models is considerable, particularly the internal
sophistication of cyber-attacks potential future attacks could have models and assumptions used by banks in the calculation of risk
a material adverse effect on our business, prospects, our capital, weighted assets. In case of significant model deficiencies,
reputation and our profit. regulators may require model re-developments or impose capital
add-ons.
HSBC Continental Europe did not report any operational losses
related to Cyber risks in either 2018, 2019 or 2020. Operational For details concerning RWAs as at 31 December 2020 – see table:
losses for combined Information, technology and cyber security RWAs by risk types on page 132.
risks were EUR 0.22 million in 2020 (of which zero related to cyber Likewise, models are used to infer the fair value of some financial
risks). See table on page 146 of the HSBC Continental Europe instruments, such as over-the-counter derivatives, whose price
cannot be directly observed on trading platforms: models then
compute a fair value by leveraging the prices of similar observable
Despite the support to the economy, the financial markets have misrepresenting financial statements to secure additional lines of
been severally impacted by the crisis in the first half of the year. credit. There is significant fraud risk associated with the bail-out
schemes, with associated media coverage globally. To date, we
Stocks market dropped by 20-30 per cent across the globe in
are not aware of significant losses from Covid-19 related fraud in
March but rallied significantly in June backed by a renewal of
Europe.
optimism on the end of sanitary crisis and the amount of liquidity
brought by central banks. In response to Covid-19 lockdown measures, organisations
(including HSBC) have had to invoke business continuity
The announcement around vaccination readiness and efficiency
arrangements resulting in reduced face to face contact and
lead to a new rally on markets at year end.
increased adoption of digital methods to support the processing of
However, sanitary situation was still concerning with the winter client requests. Processes and controls have had to be adapted to
period on western countries and the lockdown measures still support these new working arrangements. Increased levels of staff
impacting economy despite less thought than in spring. Dedicated working remotely, reduced management supervision and visibility
coronavirus stress tests did not exhibit significant potential market of staff activity all contribute to the heightened risk of internal
risk losses on Trading portfolios. They show significant increase of fraud. To date, no evidence of increased internal fraud has been
the Counterparty Credit Risk exposure but concentrated on identified in Europe.
collateralised or investment grade counterparties.
HSBC Continental Europe’s financial statements are based
As at 31 December 2020, Market Risk RWAs were EUR 2.7 billion in part on judgements, estimates and assumptions that are
of which EUR 339 million were under standardised approach and subject to uncertainty. Probability: Unlikely / Impact: Medium.
EUR 2.3 billion under IMA. The standardised RWAs include EUR
The preparation of financial statements requires management to
146 million of Interest rate risk, EUR 100 million of Foreign
make judgements, estimates and assumptions that affect the
exchange risk and EUR 93 million of options. RWAs under IMA
reported amounts of assets, liabilities, income and expenses. Due
include EUR 444 million VaR RWAs, EUR 964 million Stressed VaR
to the inherent uncertainty in making estimates, particularly those
RWAs, EUR 350 million of Incremental risk charge RWAs and EUR
involving the use of complex models, actual results reported in
566 million re Others.
future periods may be based upon amounts which differ from
See tables: ‘Market risk under standardised approach’ and ‘Market those estimates. Estimates, judgements, assumptions and models
risk under IMA’ on page 140. are continually evaluated, and are based on historical experience
HSBC Continental Europe’s operations are subject to the and other factors, including expectations of future events that are
threat of fraudulent activity. Probability: Likely / Impact: believed to be reasonable under the circumstances. Revisions to
Medium. accounting estimates are recognised in the period in which the
estimate is revised and in any future periods affected. The
The risk of fraud has increased and been made more complex by accounting policies deemed critical to our results and financial
the digital transformations operated within HSBC, fraudsters may position, based upon materiality and significant judgements and
target any of our products, services and delivery channels estimates, include impairment of loans and advances, goodwill,
(especially the online on-boarding), including lending, internet intangible and tangible asset impairment, valuation of financial
banking, payments, bank accounts and cards, and cyber-attacks instruments, deferred tax assets, provisions and interests in
against the bank’s infrastructure are increasing in frequency and associates. The valuation of financial instruments measured at fair
force. This may result in financial loss to HSBC Continental value can be subjective, in particular where models are used that
Europe, an adverse customer experience, reputational damage include unobservable inputs. Given the uncertainty and
and potential regulatory action depending on the circumstances of subjectivity associated with valuing such instruments, future
the event, any of which could have a material adverse effect on outcomes may differ materially from those assumed using
our business, prospects, financial condition and results of information available at the reporting date. The effect of these
operations. There is consumer association pressure to make banks differences on the future results of operations and the future
liable for substantially more of consumer fraud losses in absence financial position of HSBC Continental Europe may be material. If
of comprehensive fraud prevention solutions and controls. In the judgement, estimates and assumptions HSBC Continental
addition, fraud related litigation against the bank is increasing, be Europe use in preparing its consolidated financial statements are
it where HSBC is banking the client or the fraudster. subsequently found to be materially different from those assumed
In 2020, Operational Risk losses totalled EUR 81.7 million of which using information available at the reporting date, this could affect
EUR 2.3 million were for external fraud compared to EUR 15.1 our business, prospects, financial condition and results of
million in total in 2019 of which EUR 2.5 million for external fraud. operations.
Internal fraud was negligible in 2019 and 2020. See table on page Liquidity, or ready access to funds, is essential to our
146 of the 2020 HSBC Continental Europe Universal Registration businesses. Probability: Unlikely / Impact: Medium.
Document concerning Operational risk losses: quantitative data
starting from 2012 for full details. Our ability to borrow on a secured or unsecured basis, and the
cost of doing so, can be affected by increases in interest rates or
The risk of external fraud remains high as the Covid-19 pandemic credit spreads, the availability of credit, regulatory requirements
continues to disrupt the lives of individuals and organisations, relating to liquidity or the market perceptions of risk relating to the
fraudsters continue to exploit the current state of uncertainty
through the use of scams designed to steal money by deception
(3rd party fraud), organisations have had to change business
models to survive and/or take advantage of government bail-out
schemes, and there is increased risk of 1st party fraud from clients
certain ID&V and KYC activities in accordance with our AML, • We continue to promote Risk Culture through dedicated
Sanctions, AB&C, Fraud Prevention and Tax Transparency sessions for First Line of Defence, Risk stewards and Senior
procedures. While permitted by regulation, such reliance may not management related to Non-financial risk framework and
be effective in preventing third parties from using us (and our through specific elearning for each stakeholders within the
relevant counterparties) as a conduit for money laundering, Three lines of Defence.
including illegal cash operations, without our knowledge (and that • We continued to promote and encourage good conduct
of our relevant counterparties) or for financing terrorism, sanctions through our people's behaviour and decision making to deliver
violation, corruption, fraud or tax fraud and tax evasion. Becoming fair outcomes for customers and preserve market integrity;
a party to money laundering, association with, or even accusations
of being associated with, money laundering, sanctions violation, • We continued to focus on simplifying and enhancing our
corruption fraud or tax fraud/evasion will damage our reputation approach to non-financial risk management. We drove more
and could make us subject to fines, sanctions and/or legal effective oversight and better end-to-end identification and
enforcement. Any one of these outcomes could have a material management of non-financial risks;
adverse effect on our business, prospects, financial condition and • A new risk management structure and governance redesign
results of operations. has been implemented since 1 December 2020 with the
Within HSBC Continental Europe, every month, all transactions – implementation of HSBC Continental Europe, comprising
more than 30 million across 1.7 million accounts – are analysed to France, its European branches (Spain, Italy, Luxembourg,
detect signs of money laundering, terrorism financing tax Netherlands, Belgium, Czech-Republic, Poland, Greece, Ireland
avoidance, bribery and corruption, fraud and failure to comply and Sweden).
with sanctions. In addition, 1.7 million names are screened on an
ongoing basis using various surveillance lists. In order to ensure Risk Management
the effectiveness of our policies, an annual training course has
We recognise that the primary role of risk management is to
been taken by over 98 per cent of HSBC Continental Europe
protect our customers, business, colleagues, shareholders and the
employees, which is in line with the bank's Risk Appetite of having
communities that we serve, while ensuring we are able to support
at least a 98 per cent mandatory training completion rate (the Risk
our strategy and provide sustainable growth. This is supported
Tolerance is set at 97 per cent).
through our three lines of defence model described on page 101.
ESG Risks – Environmental, Social and We are focused upon implementation of our business strategy, as
Governance part of which we are carrying out a major change programme, and
it is critical that we ensure we use active risk management to
Refer ‘Non-financial performance statement’ within manage the execution risks.
‘Sustainability’.
We will also perform periodic risk assessments, including against
Key developments and risk profile strategies, to help ensure retention of key personnel for our
continued safe operation.
Key developments in 2020 We use a comprehensive risk management framework across the
In 2020, we undertook a number of initiatives to enhance our organisation and across all risk types, underpinned by the Group’s
approach to the management of risk. These included: culture and values. This outlines the key principles, policies and
practices that we employ in managing material risks, both
• In line with the increasing threat landscape that the industry financial and non-financial.
faces within non financial risk, a new Operational & Resilience
Risk sub-function has been implemented. The sub-function The framework fosters continual monitoring, promotes risk
provides robust first line of defence oversight and risk steward awareness and encourages sound operational and strategic
oversight, supported by clear plans and evidenced by effective decision making. It also ensures a consistent approach to
and timely independent challenge; identifying, assessing, managing and reporting the risks we accept
and incur in our activities.
• HSBC Risk management framework has been simplified
through the combination of the Enterprise Risk Management Risk management framework
Framework (‘ERMF’) and the Operational Risk Management An established risk governance framework and ownership
Framework (‘ORMF’) that allows HSBC to manage more structure ensures oversight of, and accountability for, the effective
efficiently and easily its risks; management of risk within the group. HSBC's risk management
• The HSBC Group simplified its risk taxonomy through framework ('RMF') fosters the continuous monitoring of the risk
consolidating certain existing risks into broader categories, for environment and an integrated evaluation of risks and their
example Resilience Risk. We adopted this approach. These interactions. Integral to the RMF and risk appetite, stress testing
changes streamline risk reporting and promote common and the identification of emerging risks.
language in our risk management approach. Further The HSBC Continental Europe Risk Committee is aligned with the
simplification will continue during 2021; Bank approach focusing on risk governance and provides a
• We continued to focus on HSBC Third Party Risk Management forward-looking view of risks and their mitigation. The Risk
Framework and Cloud framework further to the implementation Committee is a committee of the Board and has responsibility for
of the EBA Guidelines on Outsourcing; oversight and advice to the Board on, amongst other things, the
bank’s risk appetite, tolerance and strategy, systems of risk
management, internal control and compliance. Additionally,
members of the Risk Committee attend meetings of the
The model underpins our approach to risk management by and decisions in order to deliver good customer outcomes and not
clarifying responsibility, encouraging collaboration and enabling to disturb the orderly and transparent operations of financial
efficient coordination of risk and control activities. markets. Speak up culture is encouraged in order to detect and
The three lines are summarised below: prevent risks but also to manage them promptly and appropriately.
• the first line of defence owns the risks and is responsible for Risk function
identifying, recording, reporting and managing them, and The Risk function is headed by the Chief Risk Officer, which is
ensuring that the right controls and assessments are in place to responsible for the risk management framework of HSBC
mitigate them; Continental Europe. This responsibility includes establishing risk
• the second line of defence is responsible for ensuring that all policy, monitoring risk profiles, and forward-looking risk
risks it oversees are effectively managed and provides advice, identification and management. Risk is made up of sub-functions
guidance and challenge to the first line of defence. This line has covering all risks of our activities. Risk function is part of the
been reinforced by Assurance teams, in particular within second line of defence. It is independent from commercial
Compliance, which are dedicated to reviews based on a activities.
comprehensive understanding of specific risk types.
Enterprise-wide risk management tools
• the third line of defence is the Internal Audit function, which
HSBC Continental Europe uses a range of tools to identify, monitor
provides independent and objective assurance of the adequacy
and manage risk. The key enterprise-wide risk management tools
of the design and operational effectiveness of the group’s risk
are as follows:
management framework and internal control governance
process. Risk appetite
• In 2020, our risk management practice has evolved by Our approach to identifying and monitoring risk appetite is
introduction of a new role into the Three Lines of Defence described on page 81.
model. The first line of defence has been reinforced with the
Risk map
Business Service Owner role, accountable for the delivery of
one of more end-to-end business key service offered to our The risk map provides a point-in-time view of the risk profile
customers. They are responsible for overseeing and managing across HSBC’s risk taxonomy based on the accountable Risk
each of HSBC’s material Business Services end-to-end, Stewards judgemental assessment of the First line of defence
including the risk, control effectiveness and resilience of that activities. It assesses the potential for these risks to have a
service. material impact on the Group’s financial results, reputation and
the sustainability of its business. Risk stewards assign ‘current’
Risk culture risk ratings, supported by commentary. Risks that have an ‘amber’
Our risk culture is reinforced by our values. It is instrumental in or ‘red’ risk rating require monitoring and mitigating action plans
aligning the behaviours of individuals with our attitude to to be either in place or initiated to manage the risk down to
assuming and managing risk, which helps to ensure that our risk acceptable levels.
profile remains in line with our risk appetite. Top and emerging risks
We use clear and consistent employee communication on risk to
Our approach to identifying and monitoring top and emerging
convey strategic messages and set the tone from senior
risks is described on page 85.
management and the Board. We also deploy mandatory training
on risk and compliance topics to embed skills and understanding Stress testing
in order to strengthen our risk culture and reinforce the attitude to
HSBC Continental Europe operates a comprehensive stress testing
risk in the behaviour expected of employees, as described in our
programme that supports our risk management and capital
risk policies.
planning. It includes execution of stress tests mandated by our
The risk culture is reinforced by HSBC Group’s policy on regulators. Our stress testing is supported by dedicated teams and
performance management and remuneration through both infrastructure, and is overseen at the most senior levels of the
financial and non financial annual objectives setting that are bank. Our stress testing programme assesses our capital strength
aligned to our risk appetite, our Group’ values and our global through a rigorous examination of our resilience to external
strategy, through reward of individual or collective initiatives shocks. It also helps us understand and mitigate risks and informs
targeted to improve our risk management and/or allowing our decisions about capital levels. As well as undertaking
identification and prevention of frauds, through identification of regulatory-driven stress tests, we conduct our own internal stress
breaches on our internal rules and practices. tests (e.g. concentration risk stress tests on specific portfolios,
Since 2016, the programme ‘Embedding FCC Culture’ allowed market risk stress tests and capital sensitivity analysis from several
HSBC Continental Europe to strengthen employees’ knowledge risk factors). Stress test impacts are measured on the profit and
and the effectiveness of the framework enabling the bank to better loss account, the risk-weighted assets and capital. The stress test
identify financial crime risks and to terrorism risks from the first outcomes are submitted to the HSBC Continental Europe Risk
line of defence and HSBC Operations, Services and Technology. Committee and Board.
The ‘Conduct Programme’, applicable to every HSBC employee, In 2020, HSBC Continental Europe performed a range of stress
aims to ensure that actions and decisions taken as part of our tests within the stress testing programme, examining both capital
activities are in compliance with Group’s objectives. Trainings and and liquidity adequacy in line with the assessed top and emerging
communications are regularly deployed in order to enhance risks. These included possible exit scenarios from the Covid-19
employees’ knowledge completing a global mandatory training for pandemic, including the potential of a U-shaped recovery or a
all employees called ‘Values, Conduct and Me’. Furthermore, a double dip. The results of these stress tests were reported to
conduct handbook has been issued, highlighting for employees, senior management and to the other governance committees of
the best ways to incorporate conduct outcomes in their actions the bank.
Our insurance manufacturing subsidiaries are regulated separately Our insurance operations are also subject to some of the same
from our banking operations. Risks in our insurance entities are risks as our banking operations, which are covered by the group’s
managed using methodologies and processes that are subject to risk management processes.
Group oversight.
Credit Risk industry, country and customer groups. These include portfolio
and counterparty limits, approval and review controls, and stress
Credit risk is the risk of financial loss if a customer or counterparty testing.
fails to meet a payment obligation under a contract. It arises
principally from direct lending, trade finance and leasing business, Large Credit Exposure Policy – ‘LCEP’
but also from off-balance sheet products such as guarantees and The LCEP sets out the policy of HSBC Continental Europe on
credit derivatives, and from the holding of debt securities. controlling large risks, and it also forms part of the policy of HSBC
Credit Risk Management Bank plc, HSBC Holdings plc and meets the requirements of the
French banking regulator, the Autorité de Contrôle Prudentiel et de
Of the risks in which we engage, credit risk generates the largest Résolution (‘ACPR’) and the European Central Bank (‘ECB’). The
regulatory capital requirements. purpose of the LCEP is to ensure that:
The principal objectives of our credit risk management are: • HSBC Continental Europe adhere to the French regulatory
• to maintain across the group a strong culture of responsible requirements on large lending commitments;
lending and a robust risk policy and control framework; • there is an appropriate framework procedure to monitor and
• to both partner and challenge Global Businesses in defining, control large commitments and concentrations of risk;
implementing, and continually re-evaluating our risk appetite • the commitments by a bank to one individual borrower, or to a
under actual and scenario conditions; and group of connected borrowers, should not become excessive in
• to ensure there is independent, expert scrutiny of credit risks, comparison to its capital base;
their costs and mitigation. • excessive concentration and/or the combining of major
Within the bank, the Credit Risk function is headed by the Chief exposures are excluded; and
Risk Officer who reports to the Chief Executive Officer, with a • commitments to geographical areas or specific business
functional reporting line to the Regional Chief Risk Officer. Its sectors are strictly monitored to ensure that risky assets are
responsibilities include: diversified.
• formulating the local credit policy aligned where possible with
Concentration risk by counterparty
group policies;
Risk exposure limits are classified into three categories:
• validating HSBC Continental Europe’s appetite for credit risk
exposure to specified market sectors, activities and banking • category A: all financing recognised on the balance sheet and
products and controlling exposures to certain higher-risk all commitments such as guarantees, documentary credits and
sectors; standby letters of credit;
• undertaking an independent review and objective assessment • category B: off-balance sheet market risks such as currency
of risk. Credit risk assesses each request except for the certain and interest rate swaps taken at their maximum expected risk
modest level proposals (for the Retail and Commercial bank) during the life of the exposure; and
where detailed credit approval delegations have been • category S (settlement risk): principally intraday settlement risk
established; on payment commitments and foreign exchange business with
• monitoring the performance and management of portfolios customers or for their account.
across HSBC Continental Europe; Commitments to a single counterparty or group of
• vetting and controlling exposure to sovereign entities, banks counterparties, excluding central governments/central banks
and other financial institutions, as well as debt securities which The approved commitments (total of category A and B limits on
are not held solely for the purpose of trading; one side and category S limits on the other) for any single
• setting HSBC Continental Europe’s policy on large credit counterparty or group of connected counterparties, after taking
exposures, ensuring that concentrations of exposure by into account any risk mitigation/deduction techniques permitted
counterparty, sector or geography do not become excessive in under the regulations may not exceed 25 per cent of the HSBC
relation to the HSBC Continental Europe’s capital base, and Continental Europe consolidated capital.
remain within internal and regulatory limits; It should be noted that all commitments, as defined above, which
• maintaining and developing HSBC Continental Europe’s risk exceed 10 per cent of the HSBC Continental Europe consolidated
rating framework and systems via the local Model Oversight capital require the approval by HSBC Bank plc independently of
Committees, which oversees the local risk rating model the credit approval authorities in place.
management for both wholesale and retail businesses; Furthermore, commitments (categories A and B) to financial
• reporting on retail and wholesale portfolio performance, high institutions with:
risk portfolios, risk concentrations, large impaired accounts, • exposures with a maturity of more than one year;
impairment allowances and stress testing results and
recommendations to HSBC Continental Europe’s Risk • exposures to subsidiaries of financial institutions that are not
Committee and the Board; and financial institutions themselves; should not exceed 10 per cent
of HSBC Continental Europe’s consolidated capital.
• acting on behalf of HSBC Continental Europe as the primary
interface, for credit-related issues, with the ACPR, the ECB and A quarterly report on all single counterparty or groups of
rating agencies. connected counterparties for which the HSBC Continental Europe
commitments (the total of categories A and B on one hand, and
Concentration of credit risk exposure category S on the other) exceed 10 per cent of its consolidated
Concentrations of credit risk arise when a number of capital are submitted to the Risk Management Meeting, to the
counterparties or exposures have comparable economic Risk Committee and to the Board of HSBC Continental Europe and
characteristics, or are engaged in similar activities, or operate in to the various Risk committees in HSBC bank plc.
the same geographical areas/industry sectors, so that their
collective ability to meet contractual obligations is uniformly
affected by changes in economic, political or other conditions.
The group uses a number of controls and measures to minimise
undue concentration of exposure in the group’s portfolios across
Guarantors are subject to the same credit risk assessment process For individually significant exposures, risk ratings are reviewed
as primary obligors. regularly and amendments are implemented promptly when
necessary. Within the HSBC Group’s retail portfolios, risk is
Guarantees could be granted by the borrower’s parent company or
assessed and managed using a wide range of risk and pricing
by other entities such as financial institutions. Hedging via credit
models.
derivatives, guarantees from public insurers for export financing or
private insurers are other examples of guarantees. This risk rating system is based on the probability of default and
loss estimates, in accordance with the internal rating methods
The consideration of a guarantee consists of determining the
required by the Basel II framework for calculating regulatory
average amount the Bank can expect to recover if a guarantee is
capital.
called in following the default of a borrower. It will depend on the
amount of the guarantee and on the enforceable nature of the The five credit quality classifications defined below encompass a
commitment. range of more granular, internal credit rating grades assigned to
wholesale and retail lending business, as well as the external
Optimising Credit Risk Mitigation via CDS
rating, attributed by external agencies to debt securities.
As part of its mandate of optimising credit risk management for
There is no direct correlation between the internal and external
Global Banking and Markets Portfolio Management (‘PM’) sets up
ratings at granular level. Insofar as both fall within one of the five
hedges using credit derivatives, and primarily credit default swaps
classifications.
(‘CDS’). These CDS are used as part of an active management
policy, the main aim being to hedge migration and concentration All distinct HSBC customers are rated using the PD scale, except
risks and manage significant exposures. The underlying assets are for those still under the Standard Basel II method.
loans made to large corporates provided by Global Banking and Each customer risk rating (‘CRR’) band is associated with an
Markets (Banking). external rating grade by reference to long-run default rates for that
Considered as guarantees and treated under the Internal Ratings grade, represented by the average of issuer-weighted historical
Based Approach, CDS hedges totalled EUR 199 million at default rates. This mapping between internal and external ratings
31 December 2020 and subject to eligibility, they have for effect of is indicative and may vary over time.
decreasing the risk-weighted assets of the bank. For debt securities and certain other financial instruments, external
ratings have been aligned to the five quality classifications.
Credit quality of financial instruments
The HSBC Group’s credit risk rating systems and processes
differentiate exposures in order to highlight those with greater risk
factors and higher potential severity of losses.
1 Of which EUR 16,827 million EUR guaranteed loans by Credit Logement as at 31 December 2020.
2 For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss
allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes
fair value gains and losses.
1 Of which EUR 15,678 million EUR guaranteed loans by Crédit Logement as at 31 December 2019 (Re-presented to include Individual
entrepreneurs balance of EUR 2,591 million).
2 For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss
allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes
fair value gains and losses.
1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
2 For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss
allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes
fair value gains and losses.
3 'POCI' Purchased or originated credit-impaired.
Distribution of financial instruments to which the impairment requirements in IFRS 9 are applied, by credit quality and stage
allocation (continued)
Gross carrying/notional amount
Sub- Credit Allowance
Strong Good Satisfactory standard impaired Total for ECL Net
€m €m €m €m €m €m €m €m
Loans and advances to customers at amortised cost 25,541 12,162 16,512 2,184 1,239 57,638 (682) 56,956
– stage 1 25,540 12,004 13,953 1,405 — 52,902 (43) 52,859
– stage 2 1 158 2,559 779 — 3,497 (50) 3,447
– stage 3 — — — — 1,195 1,195 (578) 617
– POCI3 — — — — 44 44 (11) 33
Loans and advances to banks at amortised cost 6,547 172 76 3 — 6,798 — 6,798
– stage 1 6,522 171 76 — — 6,769 — 6,769
– stage 2 25 1 — 3 — 29 — 29
– stage 3 — — — — — — — —
– POCI3 — — — — — — — —
Other financial assets measured at amortised cost 77,234 3,343 1,151 4 12 81,744 (1) 81,743
– stage 1 77,234 3,341 1,151 — — 81,726 — 81,726
– stage 2 — 2 — 4 — 6 — 6
– stage 3 — — — — 12 12 (1) 11
– POCI3 — — — — — — — —
Total on balance sheet excluding debt instrument at
FVOCI 109,322 15,677 17,739 2,191 1,251 146,180 (683) 145,497
Loan and other credit-related commitments 62,824 14,279 10,269 991 59 88,422 (23) 88,399
– stage 1 62,824 14,149 9,608 420 — 87,001 (6) 86,995
– stage 2 — 130 661 571 — 1,362 (3) 1,359
– stage 3 — — — — 59 59 (14) 45
– POCI3 — — — — — — — —
Financial guarantees1 640 188 257 115 9 1,209 (5) 1,204
– stage 1 640 188 218 75 — 1,121 (1) 1,120
– stage 2 — — 39 40 — 79 (4) 75
– stage 3 — — — — 6 6 — 6
– POCI3 — — — — 3 3 — 3
Total on balance sheet and off balance sheet
excluding debt instrument at FVOCI 172,786 30,144 28,265 3,297 1,319 235,811 (711) 235,100
Debt instruments at FVOCI2 12,762 1,863 621 — 1 15,247 (6) 15,241
– stage 1 12,707 1,853 588 — — 15,148 (5) 15,143
– stage 2 55 10 33 — — 98 (1) 97
– stage 3 — — — — — — — —
– POCI3 — — — — 1 1 — 1
At 31 Dec 2019 185,548 32,007 28,886 3,297 1,320 251,058 (717) 250,341
1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
2 For the purposes of this disclosure gross carrying value is defined as the amortised cost of a financial asset, before adjusting for any loss
allowance. As such the gross carrying value of debt instruments at FVOCI as presented above will not reconcile to the balance sheet as it excludes
fair value gains and losses.
3 'POCI' Purchased or originated credit-impaired.
Memorandum Memorandum
Fair allowance for Fair allowance for
value ECL7 value ECL7
€m €m €m €m
Debt instruments measured at Fair Value through Other Comprehensive Income
(‘FVOCI’) 19,139 (8) 16,967 (6)
1 The total ECL is recognised in the loss allowance for the financial asset unless the total ECL exceeds the gross carrying amount of the financial
asset, in which case the ECL is recognised as a provision.
2 Of which EUR 16,827 million guaranteed by Crédit Logement as at 31 December 2020 (2019: EUR 15,678 million, re-presented to include
individual entrepreneurs balance of EUR 2,591 million).
3 Includes only financial investments measured at amortised cost. ‘Financial investments’ as presented within the consolidated balance sheet on
page 167 includes financial assets measured at amortised cost and debt and equity instruments measured at fair value through other
comprehensive income.
4 Includes only those financial instruments which are subject to the impairment requirements of IFRS 9. ‘Prepayments, accrued income and other
assets’ as presented within the consolidated balance sheet on page 167 includes both financial and non-financial assets.
5 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
6 Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.
7 Debt instruments measured at FVOCI continue to be measured at fair value with the allowance for ECL as a memorandum item. Change in ECL is
recognised in ‘Change in expected credit losses and other credit impairment charges’ in the income statement.
Summary of credit risk (excluding debt instruments measured at FVOCI) by stage distribution and ECL coverage by industry sector
at 31 December 2020
Gross carrying/nominal amount1 Allowance for ECL ECL coverage %
Stage 1 Stage 2 Stage 3 POCI2 Total Stage 1 Stage 2 Stage 3 POCI2 Total Stage 1 Stage 2 Stage 3 POCI2 Total
€m €m €m €m €m €m €m €m €m €m % % % % %
Loans and advances
to customers at
amortised cost 48,183 7,470 1,350 42 57,045 (36) (111) (661) (12) (820) 0.1 1.5 49.0 28.6 1.4
– personal3 21,648 807 430 — 22,885 (9) (28) (156) — (193) — 3.5 36.3 — 0.8
– corporate and
commercial 23,521 6,529 895 42 30,987 (25) (82) (486) (12) (605) 0.1 1.3 54.3 28.6 2.0
– non-bank financial
institutions 3,014 134 25 — 3,173 (2) (1) (19) — (22) 0.1 0.7 76.0 — 0.7
Loans and advances
to banks at
amortised cost 6,740 42 — — 6,782 (1) — — — (1) — — — — —
Other financial
assets measured at
amortised cost 71,728 19 3 — 71,750 (1) — (1) — (2) — — 33.3 — —
Loan and other
credit-related
commitments 94,964 2,871 57 — 97,892 (5) (12) (4) — (21) — 0.4 7.0 — —
– personal 1,318 32 2 — 1,352 (1) — — — (1) 0.1 — — — 0.1
– corporate and
commercial 38,623 2,424 55 — 41,102 (3) (5) (4) — (12) — 0.2 7.3 — —
– financial 55,023 415 — — 55,438 (1) (7) — — (8) — 1.7 — — —
Financial
guarantees4 923 98 29 1 1,051 (2) (5) (2) — (9) 0.2 5.1 6.9 — 0.9
– personal 25 — 1 — 26 — — — — — — — — — —
– corporate and
commercial 448 54 28 1 531 (2) (5) (2) — (9) 0.4 9.3 7.1 — 1.7
– financial 450 44 — — 494 — — — — — — — — — —
At 31 Dec 2020 222,538 10,500 1,439 43 234,520 (45) (128) (668) (12) (853) — 1.2 46.4 27.9 0.4
1 Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.
2 Purchased or originated credit-impaired ('POCI').
3 Of which EUR 16,827 million guaranteed by Crédit Logement as at 31 December 2020.
4 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
Unless identified at an earlier stage, all financial assets are assets by those less than 30 and greater than 30 days past due
deemed to have suffered a significant increase in credit risk when and therefore presents those financial assets classified as stage 2
they are 30 days past due and are transferred from stage 1 to due to ageing (30 days past due) and those identified at an earlier
stage 2. stage (less than 30 days past due). Past due financial instruments
are those loans where customers have failed to make payments in
The disclosure below presents the ageing of stage 2 financial
accordance with the contractual terms of their facilities.
1 Days past due ('DPD'). Current accounts in stage 2 are not shown in amounts presented above.
1 Represents the maximum amount at risk should the contracts be fully drawn upon and clients default.
2 Purchased or originated credit-impaired ('POCI').
3 Of which EUR 15,678 million guaranteed by Crédit Logement as at 31 December 2019 (Re-presented to include individual entrepreneurs balance
of EUR 2,591 million).
4 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
1 Days past due ('DPD'). Current accounts in stage 2 are not shown in amounts presented above.
Maximum exposure to credit risk sheet, the exposure to credit risk equals their carrying amount. For
financial guarantees granted, the maximum exposure to credit risk
The following table presents the maximum exposure to credit risk
is the maximum amount that the group would have to pay if the
with respect to financial instruments, before taking account of any
guarantee were called upon. For loan commitments that are
collateral held or other credit enhancements, unless such credit
irrevocable over the life of the respective facilities, the maximum
enhancements meet offsetting requirements defined in the
exposure to credit risk is the maximum amount of the committed
accounting policies and principles. For financial assets recognised
facilities.
in the balance
1 Of which EUR 15,678 million guaranteed by Crédit Logement as at 31 December 2019, re-presented to include individual entrepreneurs balance
of EUR 2,591 million.
2 'Financial and other guarantees' represents 'Financial guarantees' and 'Performance and other guarantees' as disclosed in Note 30.
Measurement uncertainty and sensitivity analysis of Three of these scenarios are drawn from consensus. These include
ECL estimates a Central scenario, representing a most likely outcome, a
Downside and an Upside scenario that represent meaningfully
The recognition and measurement of ECL involves the use of
different outcomes from the Central. The Central scenario is
significant judgement and estimation. We form multiple economic
created using the average of a panel of external forecasters (‘the
scenarios based on economic forecasts, apply these assumptions
consensus’) while consensus Upside and Downside scenarios are
to credit risk models to estimate future credit losses, and
created with reference to distributions that capture forecasters
probability-weight the results to determine an unbiased ECL
views of the entire range of outcomes. Management has chosen
estimate. Management judgemental adjustments are used to
to use a fourth scenario to represent their view of severe downside
address late-breaking events, data and model limitations and
risks. The use of an additional scenario is in line with HSBC’s
model deficiencies.
Forward Economic Guidance (‘FEG’) methodology and has been
Methodology used over the course of 2020.
Four economic scenarios have been used to capture the
exceptional nature of the current economic environment and to
articulate management’s view of the range of potential outcomes.
before the pandemic. The key judgements are the length of We have internal governance in place to regularly monitor
time over which the economic effects of the pandemic will management judgemental adjustments and, where possible, to
occur, the speed and shape of recovery. The main factors reduce the reliance on these through model recalibration or
include the effectiveness of pandemic containment measures, redevelopment, as appropriate. During 2020 the composition of
the pace of roll-out and effectiveness of vaccines, and the modelled ECL and management judgemental adjustments
emergence of new variants of the virus, plus a range of changed significantly, reflecting the path of the pandemic,
geopolitical uncertainties, which together represent a very high containment efforts and government support measures, and this is
degree of estimation uncertainty, particularly in assessing expected to continue to be the case until economic conditions
Downside scenarios; improve. Wider-ranging model changes will take time to develop
and need more real data on which models can rely. Models will be
• estimating the economic effects of those scenarios on ECL,
revisited over time once the full impacts of Covid-19 are observed.
where there is no observable historical trend that can be
Therefore, we anticipate significant management judgemental
reflected in the models that will accurately represent the effects
adjustments for the foreseeable future.
of the economic changes of the severity and speed brought
about by the Covid-19 outbreak. Modelled assumptions and Please refer to the HSBC Bank plc Annual Report and Accounts
linkages between economic factors and credit losses may 2020 for more detail on management judgemental adjustments to
underestimate or overestimate ECL in these conditions, and ECL and sensitivity analysis.
there is significant uncertainty in the estimation of parameters
Reconciliation of changes in gross carrying/nominal
such as collateral values and loss severity; and
amount and allowances for loans and advances to
• the identification of customers who could represent significant banks and customers including loan commitments and
increases in credit risk and credit impairment, particularly financial guarantees
where those customers have accepted payment deferrals and
other reliefs designed to address short-term liquidity issues The following disclosure provides a reconciliation of the Group’s
given muted default experience to date. gross carrying/nominal amount and allowances for loans and
advances to banks and customers including loan commitments
Management judgemental adjustments and financial guarantees. The transfers of financial instruments
In the context of IFRS 9, management judgemental adjustments represents the impact of stage transfers upon the gross carrying/
are short-term increases or decreases to the ECL at either a nominal amount and associated allowance for ECL. The net
customer or portfolio level to account for late breaking events, remeasurement of ECL arising from stage transfers represents the
model and data limitations and deficiencies, and expert credit variation in ECL due to these transfers.
judgement applied following management review and challenge of
model outputs. The most severe projections at 31 December 2020
of macroeconomic variables are outside the historical observations
on which IFRS 9 models have been built and calibrated to operate.
Moreover, the complexities of country-specific governmental
support programmes, the impacts on customer behaviours and
the unpredictable pathways of the pandemic have never been
modelled. Consequently, the group's IFRS 9 models, in some
cases, generate outputs that appear overly sensitive when
compared with other economic and credit metrics. Governmental
support programmes and customer payment reliefs have
dislocated the correlation between economic conditions and
default rates on which models are based. Management
judgemental adjustments are required to ensure that an
appropriate amount of ECL impairment is recognised.
At 31 Dec 2020
Gross carrying/nominal amount Allowance for ECL ECL release/(charge)
€m €m €m
As above 115,792 (851) (270)
Other financial assets measured at amortised cost 71,750 (2) —
Non-trading reverse purchase agreement commitments 46,975 — —
Performance and other guarantees not considered for IFRS 9 (17)
Summary of financial instruments to which the impairment requirements in
IFRS 9 are applied/ Summary consolidated income statement 234,517 (853) (287)
Debt instruments measured at FVOCI 19,139 (8) (2)
Total allowance for ECL/total income statement ECL charge for the period 253,656 (861) (289)
1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
Reconciliation of changes in gross carrying/nominal amount and allowances for loans and advances to banks and customers including
loan commitments and financial guarantees1 (continued)
Non-credit impaired Credit impaired
Stage 1 Stage 2 Stage 3 POCI Total
At 31 Dec 2019
Gross carrying/ ECL release/
nominal amount Allowance for ECL (charge)
€m €m €m
As above 109,962 (710) (122)
Other financial assets measured at amortised cost 81,744 (1) —
Non-trading reverse purchase agreement commitments 44,105 — —
Performance and other guarantees not considered for IFRS 9 (6)
Summary of financial instruments to which the impairment requirements in IFRS 9 are applied/ Summary
consolidated income statement 235,811 (711) (128)
Debt instruments measured at FVOCI 16,967 (6) —
Total allowance for ECL/total income statement ECL charge for the period 252,778 (717) (128)
1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
2 Transfer-In includes amounts related to the acquisition of seven branches: Madrid branch, Milan branch, Ireland branch, Netherlands branch,
Belgium branch, Prague branch with effect from 1 February 2019 and Luxembourg branch from 1 March 2019.
Credit impaired loans are aligned as far as possible so that Stage 3 represents all loans
which are considered defaulted or otherwise credit-impaired.
HSBC determines that a financial instrument is credit-impaired and
in Stage 3 by considering relevant objective evidence, primarily Renegotiated loans and forbearance
whether: A range of forbearance strategies is employed in order to improve
• contractual payments of either principal or interest are past due the management of customer relationships by avoiding default, of
for more than 90 days; the customer where possible or the calling of guarantees obtained
whilst maximising the recoveries of the amounts due. They include
• there are other indications that the borrower is unlikely to pay
extended payment terms, a reduction in interest or principal
such as that a concession has been granted to the borrower for
repayments, approved external debt management plans, debt
economic or legal reasons relating to the borrower’s financial
consolidations, the deferral of foreclosures and other forms of loan
condition.
modifications and re-ageing.
The loan is otherwise considered to be in default. If such
unlikeliness to pay is not identified at an earlier stage, it is deemed
to occur when an exposure is 90 days past due, even where
regulatory rules permit default to be defined based on 180 days
past due. Therefore the definitions of credit-impaired and default
Renegotiated loans and advances to customers at amortised costs by stage allocation (continued)
Stage 1 Stage 2 Stage 3 POCI Total
€m €m €m €m €m
Gross carrying amount
Personal — — 51 — 51
– first lien residential mortgages — — 36 — 36
– other personal lending — — 15 — 15
Wholesale 134 48 103 43 328
– corporate and commercial 134 48 103 43 328
– non-bank financial institutions — — — — —
At 31 Dec 2019 134 48 154 43 379
Allowance for ECL
Personal — — (14) — (14)
– first lien residential mortgages — — (10) — (10)
– other personal lending — — (4) — (4)
Wholesale (2) — (46) (10) (58)
– corporate and commercial (2) — (46) (10) (58)
– non-bank financial institutions — — — — —
At 31 Dec 2019 (2) — (60) (10) (72)
Personal lending
HSBC
Continental
Europe Group France Others1
Market-wide schemes
Number of customers granted mortgage customer relief — — —
Drawn loan value of customers granted mortgage customer relief €m — — —
Number of customers granted other personal lending customer relief 512 512 —
Drawn loan value of customers granted other personal lending customer relief €m 43 43 —
HSBC-specific measures
Number of customers granted mortgage customer relief 21 — 21
Drawn loan value of customers granted mortgage customer relief €m 3 — 3
Number of customers granted other personal lending customer relief 315 315 —
Drawn loan value of customers granted other personal lending customer relief €m 95 95 —
Total personal lending to major markets under market-wide schemes and HSBC-specific
Number of customers granted mortgage customer relief 21 — 21
Drawn loan value of customers granted mortgage customer relief €m 3 — 3
Number of customers granted other personal lending customer relief 827 827 —
Drawn loan value of customers granted other personal lending customer relief €m 138 138 —
Market-wide schemes and HSBC-specific measures mortgage relief as a proportion of total % 0.1 — 0.8
Market-wide schemes and HSBC-specific measures other personal lending relief as a proportion
of total other personal lending loans and advances % 0.7 0.7 —
Wholesale lending
HSBC
Continental
Europe Group France Others1
Market-wide schemes
Number of customers under market-wide measures 4,943 4,933 10
Drawn loan value of customers under market-wide schemes €m 4,452 4,330 122
HSBC-specific schemes
Number of customers under bank-specific measures 333 329 4
Drawn loan value of customers under bank-specific measures €m 1,437 1,201 236
Total wholesale lending to major markets under market-wide schemes and bank-specific
Number of customers 5,276 5,262 14
Drawn loan value €m 5,889 5,531 358
Market-wide schemes and HSBC-specific measures as a proportion of total wholesale lending
loans and advances % 21.0 21.5 16.0
1 Others include HSBC Continental Europe Madrid Branch, Athens Branch, Poland Branch and HSBC Middle East Leasing partnership.
Total wholesale lending for loans and advances to banks and customers by stage distribution
Gross carrying amount Allowance for ECL
Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total
€m €m €m €m €m €m €m €m €m €m
Corporate and commercial 23,521 6,529 895 42 30,987 (25) (82) (486) (12) (605)
– Industrial 5,145 1,426 129 13 6,713 (5) (14) (79) (4) (102)
– Commercial, international trade 11,482 3,980 519 29 16,010 (10) (47) (321) (8) (386)
– Commercial real estate 4,251 876 55 — 5,182 (5) (14) (23) — (42)
– Other property-related 310 43 80 — 433 (1) (1) (35) — (37)
– Governments 1,106 — — — 1,106 (1) — — — (1)
– Others 1,227 204 112 — 1,543 (3) (6) (28) — (37)
Non-bank financial institutions 3,014 134 25 — 3,173 (2) (1) (19) — (22)
Loans and advances to banks 6,740 42 — — 6,782 (1) — — — (1)
At 31 Dec 2020 33,275 6,705 920 42 40,942 (28) (83) (505) (12) (628)
Corporate and commercial 27,518 2,331 668 44 30,561 (36) (28) (377) (11) (452)
– Industrial 6,479 550 88 42 7,159 (8) (6) (62) (9) (85)
– Commercial, international trade 13,138 947 437 2 14,524 (12) (13) (249) (1) (275)
– Commercial real estate 4,814 785 55 — 5,654 (10) (9) (20) (1) (40)
– Other property-related 423 20 76 — 519 (1) — (36) — (37)
– Governments 933 — — — 933 — — — — —
– Others 1,731 29 12 — 1,772 (5) — (10) — (15)
Non-bank financial institutions 4,615 54 55 — 4,724 (3) (1) (43) — (47)
Loans and advances to banks 6,769 29 — — 6,798 — — — — —
At 31 Dec 2019 38,902 2,414 723 44 42,083 (39) (29) (420) (11) (499)
Total wholesale lending for loans and other credit-related commitments and financial guarantees1 by stage distribution
Nominal amount Allowance for ECL
Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total
€m €m €m €m €m €m €m €m €m €m
Corporate and commercial 39,071 2,478 83 1 41,633 (5) (10) (6) — (21)
Financial 55,473 459 — — 55,932 (1) (7) — — (8)
At 31 Dec 2020 94,544 2,937 83 1 97,565 (6) (17) (6) — (29)
1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
Total wholesale lending for loans and other credit-related commitments and financial guarantees1 by stage distribution (continued)
Nominal amount Allowance for ECL
Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total
€m €m €m €m €m €m €m €m €m €m
Corporate and commercial 36,005 1,302 61 3 37,371 (6) (6) (14) — (26)
Financial 50,943 98 — — 51,041 (1) — — — (1)
At 31 Dec 2019 86,948 1,400 61 3 88,412 (7) (6) (14) — (27)
1 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
Wholesale lending: other corporate, commercial and financial (non-bank) loans and advances including loan commitments by level
of collateral by stage
31 Dec 2020 31 Dec 2019
Gross Gross carrying/
carrying/nominal ECL nominal ECL
amount coverage amount coverage
€m % €m %
Stage 1
Not collateralised 57,962 — 59,452 (0.1)
Fully collateralised 2,733 (0.1) 4,118 (0.1)
LTV ratio:
– less than 50% 815 (0.1) 940 —
– 51% to 75% 1,002 — 1,419 (0.1)
– 76% to 90% 515 — 888 (0.1)
– 91% to 100% 401 — 871 (0.1)
Partially collateralised (A): 3,759 (0.1) 2,265 (0.1)
– collateral value on A 3,112 1,786
Total 64,454 — 65,835 (0.1)
Stage 2
Not collateralised 4,673 (1.1) 2,698 (0.7)
Fully collateralised 707 (1.0) 173 (1.7)
LTV ratio:
– less than 50% 368 (0.8) 21 —
– 51% to 75% 50 (2.0) 54 —
– 76% to 90% 23 — 13 —
– 91% to 100% 266 (1.1) 85 (3.5)
Partially collateralised (B): 2,818 (0.6) 65 —
– collateral value on B 2,453 38
Total 8,198 (0.9) 2,936 (0.8)
Stage 3
Not collateralised 620 (63.4) 524 (67.6)
Fully collateralised 14 (64.3) 36 (27.8)
LTV ratio:
– less than 50% 7 (57.1) 11 (36.4)
– 51% to 75% 4 (75.0) 14 (28.6)
– 76% to 90% 2 (50.0) 9 (11.1)
– 91% to 100% 1 (84.0) 2 (50.0)
Partially collateralised (C): 214 (27.1) 92 (22.8)
– collateral value on C 152 11
Total 848 (54.2) 652 (59.0)
POCI
Not collateralised 39 (23.1) 39 (20.5)
Fully collateralised — — — —
LTV ratio:
– less than 50% — — — —
– 51% to 75% — — — —
– 76% to 90% — — — —
– 91% to 100% — — — —
Partially collateralised (D): 3 (100.0) 5 (40.0)
– collateral value on D 3 4
Total 42 (28.6) 44 (22.7)
At 31 Dec 73,542 (0.8) 69,467 (0.7)
Personal lending purchases such as residential property where the loans are
secured by Crédit Logement Guarantee or by the assets being
Total personal lending
acquired. We also offer consumer lending products such as
We provide a broad range of secured and unsecured personal overdrafts and personal loans which are mainly unsecured.
lending products to meet individual customer needs. Personal
lending includes advances to individual customers for asset
Total personal lending for loans and advances to customers at amortised costs by stage distribution
Gross carrying amount Allowance for ECL
Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total
€m €m €m €m €m €m €m €m €m €m
First lien residential mortgages 2,914 173 196 — 3,283 (1) (7) (75) — (83)
Other personal lending 18,734 634 234 — 19,602 (8) (21) (81) — (110)
– other1 18,469 614 219 — 19,302 (6) (18) (80) — (104)
– credit cards 265 20 15 — 300 (2) (3) (1) — (6)
– second lien residential mortgages — — — — — — — — — —
At 31 Dec 2020 21,648 807 430 — 22,885 (9) (28) (156) — (193)
Total personal lending for loans and advances to customers at amortised costs by stage distribution
Gross carrying amount Allowance for ECL
Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total
€m €m €m €m €m €m €m €m €m €m
First lien residential mortgages 3,033 265 196 — 3,494 (1) (6) (76) — (83)
Other personal lending 17,736 847 276 — 18,859 (3) (15) (82) — (100)
– other1 17,440 817 258 — 18,515 (2) (13) (82) — (97)
– credit cards 296 30 18 — 344 (1) (2) — — (3)
– second lien residential mortgages — — — — — — — — — —
At 31 Dec 2019 20,769 1,112 472 — 22,353 (4) (21) (158) — (183)
Total personal lending for loans and other credit-related commitments and financial guarantees2 by stage distribution
Gross carrying amount Allowance for ECL
Stage 1 Stage 2 Stage 3 POCI Total Stage 1 Stage 2 Stage 3 POCI Total
€m €m €m €m €m €m €m €m €m €m
Personal lending
At 31 Dec 2019 1,174 41 4 — 1,219 — — — — —
1 Of which EUR 15,678 million guaranteed by Crédit Logement as at 31 December 2019 (Re-presented to include individual entrepreneurs balance
of EUR 2,591 million).
2 Excludes performance guarantee contracts to which the impairment requirements in IFRS 9 are not applied.
Mortgage lending The tables below show residential mortgage lending including off-
balance sheet loan commitments by level of collateral. They
We offer a wide range of mortgage products designed to meet
provide a quantification of the value of fixed charges we hold over
customer needs, including capital repayment, bridge loans and
borrowers’ specific assets in the event of the borrower failing to
regulated loans. HSBC Continental Europe has specific LTV
meet its contractual obligations.
thresholds and debt-to-income ratios in place for this type of
lending, which are compliant with the overall Group policy, The LTV ratio is calculated as the gross on-balance sheet carrying
strategy and risk appetite. amount of the loan and any off-balance sheet loan commitment at
the balance sheet date divided by the value of collateral.
Collateral and other credit enhancements held
The value of mortgage collateral is updated on a monthly basis
The most common method of mitigating credit risk for personal
using the notary price index (‘INSEE’). In addition professional
lending is to take collateral. For HSBC Continental Europe Retail a
valuations are obtained for high value mortgage loans (>3m)
mortgage over the property is often taken to help secure claims.
annually. Valuations of financial collateral are updated on a daily
Another common form of security is guarantees provided by a
basis for those portfolios held by HSBC Continental Europe and on
third-party company; Crédit Logement (a Société de Financement
annual basis for those held externally. The collateral valuation
regulated by the French Regulator ACPR). Crédit Logement
excludes any cost adjustments linked to obtaining and selling the
guarantees 100 per cent of the amount of the residential real
collateral and, in particular, loans shown as not collateralised or
estate loan in case of default. Loans may also be made against a
partly collateralised may also benefit from other forms of credit
pledge of eligible marketable securities or cash.
mitigants.
Personal lending: residential mortgage loans including loan commitments by level of collateral
31 Dec 2020 31 Dec 2019
Gross carrying/ ECL Gross carrying/ ECL
nominal amount coverage nominal amount coverage
€m % €m %
Stage 1
Fully collateralised 2,825 — 2,918 —
LTV ratio:
– less than 50% 1,406 — 1,307 —
– 51% to 60% 597 — 622 —
– 61% to 70% 443 — 495 —
– 71% to 80% 266 — 340 —
– 81% to 90% 78 — 105 —
– 91% to 100% 35 — 49 —
Partially collateralised (A): 89 — 115 —
LTV ratio:
– 101% to 110% 23 — 32 —
– 111% to 120% 13 — 21 —
– greater than 120% 53 — 62 —
– collateral value on A 84 111
Total 2,914 — 3,033 —
Stage 2
Fully collateralised 161 (3.1) 250 (1.6)
LTV ratio:
– less than 50% 93 (2.2) 123 (0.8)
– 51% to 60% 29 (3.4) 41 (2.4)
– 61% to 70% 22 (4.5) 35 (2.9)
– 71% to 80% 13 (7.7) 37 (2.7)
– 81% to 90% 3 — 10 —
– 91% to 100% 1 — 4 —
Partially collateralised (B): 12 (25.0) 16 (6.3)
LTV ratio:
– 101% to 110% 4 (25.0) 6 (16.7)
– 111% to 120% 3 (33.3) 3 —
– greater than 120% 5 (20.0) 7 —
– collateral value on B 11 15
Total 173 (4.6) 266 (1.9)
Stage 3
Fully collateralised 124 (30.6) 123 (27.6)
LTV ratio:
– less than 50% 50 (24.0) 68 (30.9)
– 51% to 60% 22 (31.8) 20 (20.0)
– 61% to 70% 28 (28.6) 12 (25.0)
– 71% to 80% 14 (42.9) 12 (25.0)
– 81% to 90% 5 (60.0) 5 (20.0)
– 91% to 100% 5 (40.0) 6 (33.3)
Partially collateralised (C): 72 (50.0) 74 (56.8)
LTV ratio:
– 101% to 110% 11 (54.5) 32 (53.1)
– 111% to 120% 9 (66.7) 17 (64.7)
– greater than 120% 52 (46.2) 25 (56.0)
– collateral value on C 39 58
Total 196 (37.8) 197 (38.6)
At 31 Dec 3,283 (2.5) 3,496 (2.3)
Counterparty Credit Risk Apart from that, a small portion of OTC products, the most
complex ones, shall remain outside of the scope because of
Counterparty Credit Risk exposure modelling issues. The Mark-to-Market Method is then used.
Counterparty credit risk (‘CCR’) means the risk that the Framework/Limits and Monitoring
counterparty to a transaction could default before the final
settlement of the transaction's cash flows. CCR management in HSBC Continental Europe is performed
through different levels:
The Calculation of the Counterparty Credit Risk
Exposure • Credit authority is held by Wholesale Credit Risk (‘WCR’) which
is part of the Wholesale Credit and Market Risk (‘WMR’) sub-
HSBC Continental Europe applies the Internal Model Method function, within the Risk function, either at local level or
(‘IMM’) of CRR Article 283 to determine the CCR exposures for regional level or even Group level.
OTC transactions.
SFTs are all excluded from the IMM, capital requirements for those
products shall remain under the Title II chapter 4 method as
allowed by CRR article 111(2).
Exchange Traded Derivatives (‘ETDs’) are also all excluded, the
Mark-to-Market Method of CRR Article 274 is then used.
HSBC’s aggregated credit appetite to the client is reflected in the • Current Exposure (‘CE’) limits
GCRC. The GCRC is set during the Global Annual Review (‘GAR’) CE is the sum of positive MtM net of collateral across all
process. It is comprised of two elements, (i) limits (Cat A, Cat B, counterparties.
Cat S) which are already approved or proposed for approval in the
CARM application; and (ii) the Unallocated Appetite (‘UA’) which
represents an ‘Indication of Appetite’ for pipeline transactions or
generic headroom that supports the Global Relationship Banker’s
(‘GRB’) business development strategy over the next 12 months.
• Category A (‘Cat A') limits
Cat A facilities are those for which a credit limit is typically
recorded at the full notional amount of the facility, the bank being
actually or potentially at risk for 100 per cent of the committed
amount.
• Specific Wrong Way Risk (‘SWWR’) limits That adjustment reflects the current market value of the credit risk
of the counterparty to the institution, but does not reflect the
SWWR transactions are self-referencing transactions where future
current market value of the credit risk of the institution to the
exposure is expected to be high when the counterparty’s
counterparty.
probability of default is also high i.e. future exposure is positively
and directly correlated with the counterparty probability of default Institutions that hold internal model method approvals both for the
and this relationship is driven by transaction(s) with the specific risk and the counterparty credit risk can calculate the CVA
counterparty. capital charge under the advanced approach otherwise a standard
approach have to be used.
• General Wrong Way Risk (‘GWWR’) limits
HSBC Continental Europe applies the following methods to
GWWR occurs when a counterparty's probability of default is
determine the CVA capital charge:
positively correlated with moves in general market risk factors
such as foreign exchange rates. For example, the default • The advanced approach on all eligible OTC derivatives.
probability of a counterparty may increase with a depreciation of • The standardised approach on all other transactions that are
the domestic currency if the depreciation affects their business not in the IMM scope.
model. Trading OTC contracts with such a counterparty which
become more valuable to the bank as the currency depreciates Credit Valuation Adjustment (‘CVA’) hedges
represents GWWR. The responsibility for hedging and/or mitigating credit exposure
• Default Fund (‘DF’) limits lies within the remit of the Counterparty Exposure Management
(‘CEM’) Desk. Since 2018, this desk trades CDS hedges which are
DF limits covers HSBC’s funded and unfunded DF contribution to
eligible for the mitigation of the CVA own funds requirements.
CCPs.
Only single name or index CDS' are used as hedging instruments.
• Initial Margin (‘IM’) limits The monitoring of eligible hedges is made on a daily basis by
IM limits covers HSBC’s IM contribution to CCPs. Traded Risk.
Credit Valuation Adjustment (‘CVA’) means an adjustment to the During the development of Covid-19 crisis, vulnerable clients,
mid-market valuation of the portfolio of transactions with a sectors and countries have been defined. The risk management
counterparty. strongly focused on the collateral disputes and the failed
payments. All noteworthy trades especially concerning the
vulnerable sectors were escalated.
Treasury risk
Capital
Key capital numbers
At
31 Dec
CRD IV
2020 2019
€m €m
Capital resources
CET1 5,818 6,464
Tier 1 Capital 6,568 7,214
Total Capital 7,974 8,120
Risk weighted assets
Credit Risk1 36,431 36,426
Counterparty Credit Risk 3,736 3,982
Market Risk 2,663 4,494
Operational Risk 3,283 3,149
Basel 1 floor impact —
Total risk weighted assets 46,113 48,051
Capital Ratios (%)
Common equity tier 1 12.6% 13.5%
Total tier 1 14.2% 15.0%
Total capital 17.3% 16.9%
1 ‘Credit Risk’, here and in all tables where the term is used, excludes counterparty credit risk.
The Basel III framework, like Basel II, is structured around three Holdings of Tier 2 capital of financial sector entities are deducted.
‘pillars’: minimum capital requirements, supervisory review
process and market discipline. Basel III also introduces a number Leverage Ratio
of capital buffers, including the Capital Conservation Buffer
(‘CCB’), Countercyclical Buffer (‘CCyB’), and other systemic buffers The leverage ratio was introduced into the Basel III framework as a
such as the Globally/Other Systematically Important Institutions non-risk-based metric, to supplement risk-based capital
(‘G-SII’/’O-SII’) buffer. CRR and CRD legislations implemented requirements. It aims to constrain the build-up of excessive
Basel III in the EU. leverage in the banking sector, introducing additional safeguards
against model risk and measurement errors. The Basel III leverage
The capital management framework defines regulatory capital and ratio is a volume-based measure calculated as Tier 1 capital
economic capital as the two primary measures for the divided by total on- and weighted off-balance sheet exposures,
management and control of capital. further netting possibilities on market instruments and certain
Capital measures: exposures exclusions including a temporary exclusion until
27 June 2021 of central bank exposures as supervisory authorities
• Regulatory capital is the capital which HSBC Continental
publicly declared exceptional circumstances. This ratio has been
Europe is required to hold in accordance with the rules
implemented in the EU for reporting and disclosure purposes but,
established by regulators; and
at this stage, has not been set as a binding requirement.
• Economic capital is the internally calculated capital requirement
to support risks to which HSBC Continental Europe is exposed Pillar 3 market discipline
and forms a core part of the internal capital adequacy
assessment process. Pillar 3 of the Basel regulatory framework is related to market
Regulatory Requirements discipline and aims to make financial services firms more
transparent by requiring publication of wide-ranging information
As a result of the annual Supervisory Review and Evaluation on their risks, capital and management. HSBC Continental
Process (‘SREP’), the European Central Bank (‘ECB’) has set to Europe’s Pillar 3 Disclosure at 31 December 2020 is published on
3.00 per cent the minimum capital requirement under Pillar 2 HSBC’s website, www.hsbc.com, under ‘Investors’ section.
(‘P2R’) for HSBC Continental Europe for the year 2021. Following
the ECB decision on 8 April 2020 amending the composition of the Minimum Requirement for own funds and
Pillar 2 additional own funds requirement in the Covid-19 context, Eligible Liabilities (‘MREL’) – Total Loss
the P2R shall be held in the form of 56.25 per cent of CET1 and
75 per cent of Tier 1, as a minimum.
Absorbing Capacity (‘TLAC’)
HSBC Continental Europe will be required to meet on a HSBC Continental Europe became subject to MREL requirements
consolidated basis a minimum total capital ratio of at least 13.52 for the first time on 30 March 2020 following reception of decision
per cent, from 1 January 2021. The Overall capital requirement from the Autorité de Contrôle Prudentiel et de Résolution (’ACPR’).
(‘OCR’) is composed of: the 8 per cent minimum capital in respect This decision applies until a new decision is received and imposes
of article 92.1 of the 575/2013 Regulation, the 2.50 per cent for the an MREL requirement as a percentage of the Total Liabilities and
Conservation buffer in respect of article 129 of the 2013/36 Own Funds (‘TLOF’).
Directive, the 3 per cent Pillar 2 requirement mentioned above and Following the end of the UK withdrawal from the European Union
a countercyclical buffer of 0.02 percent based on the estimated transition period, HSBC Continental Europe becomes from
current levels. 1 January 2021 a material subsidiary (CRR article 4.1.135) of a
The requirement in respect of Common equity tier 1 is 8.71 per third-country G-SII and therefore bound by new internal TLAC
cent, excluding Pillar 2 guidance (‘P2G’). requirements (CRR article 92b). In order to meet the internal TLAC
requirements, HSBC Continental Europe issued internal TLAC
Regulatory Capital eligible Senior Non-Preferred bonds in December 2020.
HSBC Continental Europe’s capital base is divided into three main
categories, namely Common Equity Tier 1, Additional Tier 1 and
Tier 2, depending on their characteristics.
Common Equity Tier 1 (‘CET 1’) capital is the highest quality form
of capital, comprising shareholders’ equity and related non-
controlling interests (subject to limits). Under CRD/CRR various
capital deductions and regulatory adjustments are made against
these items – these include deductions for goodwill and intangible
assets, deferred tax assets that rely on future profitability as well
as negative amounts resulting from the calculation of expected
loss amounts under IRB.
Additional Tier 1 capital comprises eligible non-common equity
capital securities such as Additional Tier 1 eligible subordinated
debt as per CRR, and any related share premium. Holdings of
additional Tier 1 securities of financial sector entities are deducted
from additional Tier 1 capital.
Tier 2 capital comprises eligible subordinated debt and any related
share premiums.
* The references identify the lines prescribed in the EBA template that are applicable and where there is a value.
1 Common equity tier 1 available to meet buffers after Pillar 1 capital requirements.
The main movements of the own funds are detailed on the Note 1 ‘significant events during the year’ of the HSBC Continental Europe's
Universal Registration Document 2020.
1 ‘Capital required’, here and in all tables where the term is used, represents the Pillar 1 capital charge at 8 per cent of RWAs.
2 ‘Credit Risk’, here and in all tables where the term is used, excludes counterparty credit risk.
RWA decreased by EUR 1,938 millions, mainly driven by business activity decrease in CMB and GBM and partially offset by model
updates and methodology changes on WPB business.
Tier 1 capital reduced by EUR 646 millions to EUR 6,568 millions during 2020. The Leverage exposure decreased by EUR 37,4 billions to
EUR 154,9 billions.
Liquidity and funding risk management (‘ILAAP’) used to validate risk tolerance and set risk appetite.
Liquidity and funding risk management framework The HSBC Group’s operating entities are predominantly defined on
a country basis to reflect the local management of liquidity and
Liquidity risk is the risk that HSBC Continental Europe does not funding. In this context, liquidity and funding risk is managed by
have sufficient financial resources to meet its obligations as they HSBC Continental Europe on a standalone basis with no implicit
fall due, or will have to access such resources at excessive cost. reliance assumed on any other Group entity unless pre-committed.
The risk arises from mismatches in the timing of cash flows or
when the funding needed for illiquid asset positions cannot be HSBC Continental Europe’s policy is it should be self-sufficient in
obtained at the expected terms as and when required. funding its own activities.
HSBC Group has an internal liquidity and funding risk The Liquidity coverage ratio (‘LCR’) and Net stable funding ratio
management framework which aims to allow it to withstand very (‘NSFR’) are key components of the Liquidity and Funding Risk
severe liquidity stresses. It is designed to be adaptable to Framework.
changing business models, markets and regulations. The Liquidity and funding risk profile
management of liquidity and funding is undertaken in France in
compliance with the Group’s framework and with practices and Liquidity coverage ratio
limits set through by the RMM and approved by the Board. The Liquidity Coverage Ratio (‘LCR’) aims to ensure that a bank
The elements of this framework are underpinned by a robust has sufficient unencumbered high-quality liquid assets (‘HQLA’) to
governance framework, the two major elements of which are: meet its liquidity needs in a 30-calendar-day liquidity stress
scenario. HQLA consists of cash or assets that can be converted
• Asset, liability and capital management committees (‘ALCOs’); into cash very quickly with little or no loss of value in markets.
and
• Annual individual liquidity adequacy assessment process
Net stable funding ratio Our primary sources of funding are customer current accounts,
repo and wholesale issuances and capital instruments.
At 31 Dec
2020 2019 The following ‘Funding sources and uses’ table provide a
% % consolidated view of how HSBC Continental Europe’ balance
HSBC Continental Europe 136 127 sheet is funded, and should be read in light of the liquidity and
funding risk framework.
On the basis of the Basel Committee’s BCBS 295 interpretation, the The following table analyses HSBC Continental Europe’s
NSFR is assessed at the level of 130 per cent at 31 December 2020. consolidated balance sheet according to the assets that primarily
Depositor concentration and term funding maturity arise from operating activities and the sources of funding primarily
concentration supporting these activities. Assets and liabilities that do not arise
from operating activities are presented as a net balancing source
The LCR and NSFR metrics assume a stressed outflow based on a or deployment of funds.
portfolio of depositors within each deposit segment. The validity of
these assumptions is undermined if the underlying depositors do Wholesale funding markets are accessed by issuing senior debt
not represent a large enough portfolio so that a depositor securities (publicly and privately) and borrowing from secured repo
concentration exists. markets against high-quality collateral, to align asset and liability
maturities, currency mismatches and to maintain a presence in
In addition to this, HSBC Continental Europe is exposed to term local wholesale markets.
re-financing concentration risk if the current maturity profile
results in future maturities being overly concentrated in any The main financing transactions in 2020 are presented in the
defined period. Significant events during the year section on page 182.
Contingent liquidity risk arising from committed lending scenario any additional outflow generated by the increased
facilities utilisation of these committed facilities will not give rise to liquidity
risk for HSBC Continental Europe.
HSBC Continental Europe provides committed facilities such as
standby facilities and committed backstop lines to its customers. The table below shows the HSBC Continental Europe’s contractual
All of the undrawn commitments provided to conduits or external exposures as at 31 December. The increase of EUR 7.8 billion is
customers are accounted for in the LCR and NSFR in line with the mainly due to the pass-on to the real economy of the market and
applicable regulations. This, along with the live monitoring of the Central Bank’s funding in the 2020 challenged European economic
concentration over these instruments ensures that under a stress situation.
HSBC Continental Europe's contractual exposures as at 31 Dec monitored under the contingent liquidity risk structure
At
31 Dec 2020 31 Dec 2019
€bn €bn
Commitments to customers
– Corporates 42,332 37,311
– Retail and SME 1,709 1,871
– Financials 4,174 3,069
– Others 4,352 2,467
Commitments to customers
– 5 largest1 4,308 3,689
1 Sum of the undrawn balance of the five largest facilities excluding conduits.
Asset encumbrance and collateral management The objective of this disclosure is to facilitate an understanding
of instantly available and unrestricted assets that could be used
An asset is defined as encumbered if it has been pledged as
to support potential future funding and collateral needs. The
collateral against an existing liability and, as a result, is no
disclosure is not designed to identify assets which would be
longer available to the bank to secure funding, satisfy collateral
available to meet the claims of creditors or to predict assets that
needs or be sold to reduce the funding requirement. Collateral is
would be available to creditors in the event of a resolution or
managed on an HSBC Continental Europe basis consistent with
bankruptcy.
the approach to managing liquidity and funding. Available loan
collateral held in HSBC Continental Europe is managed as a
single consistent collateral pool from which HSBC Continental
Europe will seek to optimise the use of the available collateral.
The Head of Traded Risk Europe, who reports directly to the Global • development and implementation of procedures complying
Head of Traded Risk and to the Head WMR Europe, supervises the with regulatory requirements and with best practices;
mandates review process within his geographic zone of • allocation of market risk limits within HSBC Continental Europe
responsibility. He submits them for review to Group WMR. He is compatible with its strategy and its risk appetite;
also functional head of the Head of Traded Risk France.
The MRM team prepares the annual limit review jointly with the The HSBC Continental Europe Valuation Committee
business heads and submits it for approval to the Head of WMR The Valuation Committees meet on a monthly basis and features
France, by delegation from the Chief Risk Officer, and to Group representation from Front Office, Product Control, Market Risk
WMR via the Head of Traded Risk Europe. Management and IMR.
Market Risk Control (‘MRC’) It notably reviews and approves of the results of the month-end
The Market Risk Control teams are responsible on a day-to-day IPV and FVA calculation process as well as the prudent valuation
basis for checking adherence to all of the various market risk calculations on a quarterly basis. Approximate bookings where
limits, regardless of the level of the market risk mandate and the systems do not adequately reflect the economics of a transaction
nature of the limit in question. They report any breaches of these are also considered during this meeting.
limits and also any consumption in excess of a warning threshold All fair value adjustment methodologies are reviewed and
set at 80 per cent of the limit. They are responsible for reporting approved by this forum at least annually.
weekly the stress tests. They also carry out the back-testing of the
Market risk in 2020
VaR.
The world has been dramatically hit by the coronavirus sanitary
They also produce and distribute HSBC Continental Europe’s
crisis. The confinement measures stopped the economic activity
consolidated market risk reports for Senior Management and for
abruptly and forced governments and central banks to react
the HSBC Group Consolidation. The team is also responsible for
vigorously to avoid a severe and lasting economic depression.
producing the various periodical summary statements required for
both internal needs (packs for the RMM, Risk Committee, the See also page 92 Risk Factors – Market fluctuations may reduce
Board, annual reports, etc.) and external needs, such as our income or the value of our portfolios.
supervisory authorities. The announcement around vaccination readiness and efficiency
Market Risk Control reports hierarchically to the Head of Traded lead to a new rally on markets at year end.
Risk France. However, sanitary situation was still concerning with the winter
Traded Credit Risk period on Western countries and the lockdown measures still
impacting economy despite less thought than in spring.
Two teams are responsible for the daily monitoring of the
counterparty risk exposures of HSBC Continental Europe. Dedicated Covid-19 stress tests did not exhibit significant potential
market risk losses on Trading portfolios. They show significant
A first one is focusing on the reporting of counterparty risk. It
increase of the Counterparty Credit Risk exposure but
ensures completion of the scope, performs daily controls and
concentrated on collateralized or investment grade counterparties.
produces daily risk report to the second one, the risk managers.
Market risk measures
On top of controlling adherence to the dedicated limits, the Traded
Credit Risk Managers provide detailed and ad hoc analysis to Market Risk monitoring system
senior management, ensure that risk measures are fit-for-purpose
The objective is to manage and control market risk exposures
and runs regular stress tests on the portfolio.
while maintaining a market profile consistent with our risk
Both teams locally report into the Head of Traded Risk France. appetite. HSBC uses a range of tools to monitor and limit market
risk exposures including sensitivity analysis, Value at Risk and
stress testing.
Local stress test scenarios defined in HSBC Continental Europe Trading portfolios
contemplates different scenarios on Eurozone (mixing different
Value at Risk of the trading portfolios
deformations of the yield curves of the sovereign issuers, including
serious tensions on these spreads) and are regularly recalibrated to Trading VaR remained within the risk appetite throughout the year
adjust to market conditions. Dedicated scenarios involving and remained limited on average.
deformation of the swap curve and the volatility surface are also The spike observed during the summer is actually technical and
applied to more exotic books in order to capture the convexity and linked to the IBOR transition programme: the change of indexes
the distortion of risks of these books. These results are presented for clearing houses collateral remuneration has been reflected with
on a monthly basis to the MRF. some delay in systems and VaR levels came back to spring levels
as soon as the change had been reflected.
12
10
-2
-4
Jan-20 Feb-20 Mar-20 Apr-20 May-20 Jun-20 Jul-20 Aug-20 Sep-20 Oct-20 Nov-20 Dec-20
Foreign
exchange (‘FX’) and Interest Equity Credit Portfolio
commodity rate (‘IR’) (‘EQ’) Spread (‘CS’) Diversification Total
€m €m €m €m €m €m
Balance at 31 Dec 2020 0.16 2.64 — 0.40 (0.73) 2.46
Average 0.24 3.44 — 0.45 (0.62) 3.51
Maximum 0.51 11.04 — 0.96 (1.43) 10.58
20
15
10
5
0
-5
-10
-15
-20
-25
Jan-18 Mar-18 Jun-18 Sep-18 Dec-18 Mar-19 May-19 Aug-19 Nov-19 Feb-20 May-20 Jul-20 Nov-20
Non-Trading portfolios
Value at Risk of the non-trading portfolio
The VaR of the non-trading portfolio slightly increased in absolute terms following the increase of outright exposure in the Asset Liquidity
Buffer.
10
-2
-4
-6
Jan-20 Feb-20 Mar-20 Apr-20 May-20 Jun-20 Jul-20 Aug-20 Sep-20 Oct-20 Nov-20 Dec-20
Total IR CS FX Diversification
Interest-rate risk of the banking book schedules, expected prepayments, contractual rate indices used
for re-pricing and interest rate reset dates are examples of
Overview elements transferred for risk management by Markets treasury.
Banking book interest rate risk is the risk of an adverse impact to The internal transfer pricing framework is governed by Asset,
earnings or capital due to changes in market interest rates. liability and capital management committee (‘ALCO’) whose
Interest rate risk in the banking book is generated by non-traded responsibility it is to define each operating entities transfer pricing
assets and liabilities and is monitored and controlled at Group level curve and review and approve the transfer pricing policy, including
by Group Treasury and at HSBC Continental Europe level by Asset, behaviouralisation assumptions used for products where there is
Liability and Capital Management. Group Treasury and ALCM either no defined maturity or customer optionality exists. HSBC
functions are supervised by RMM who approve risk limits used in Continental Europe ALCO is responsible for monitoring and
the management of interest rate risk. Banking book interest rate reviewing the bank's overall structural interest rate risk position.
risk is transferred to and managed by Markets treasury, who are Interest rate behaviouralisation policies have to be formulated in
overseen by Wholesale Market Risk and Product Control line with the Group’s behaviouralisation policies and approved at
functions. least annually by ALCO.
Governance Non-traded assets and liabilities are transferred to Markets
Group Treasury and ALCM monitor and control non-traded interest treasury based on their re-pricing and maturity characteristics. For
rate risk as well as reviewing and challenging the business prior to assets and liabilities with no defined maturity or re-pricing
the release of new products and proposed behavioural characteristics behaviouralisation is used to assess the interest
assumptions used for hedging activities. ALCM are also rate risk profile.
responsible for maintaining and updating the transfer pricing Markets treasury manages the banking book interest rate positions
framework, informing ALCO of the overall banking book interest transferred to it within the Markets Risk limits approved by RMM.
rate risk exposure and managing the balance sheet in conjunction Markets treasury will only receive non-trading assets and liabilities
with Markets treasury. as long as they can economically hedge the risk they receive.
The internal transfer pricing framework is constructed to ensure Hedging is generally managed through vanilla interest rate
that structural interest rate risk, arising due to differences in the derivatives or fixed rate government bonds. Any interest rate risk
re-pricing timing of assets and liabilities, is transferred to Markets which Markets treasury cannot economically hedge is not
treasury and business lines are correctly allocated income and transferred and will remain within the business line where the risk
expense based on the products they write, inclusive of activities to is originated.
mitigate this risk. Contractual principle repayments, payment
During the year 2020, in the context of the Covid-19 outbreak, Non Financial (or Operational) risks
HSBC Continental Europe has constantly monitored the interest
rate risk associated with the credit drawdowns and additional In accordance with the French Order of 3 November 2014 and the
customer deposits as well as a slowdown in home loans Operational Risk Functional Instructions Manual, operational risk is
prepayment and has adjusted its policy to better reflect the defined within HSBC Group as a risk that might be the result of:
exceptional circumstances. The historically low rates environment, • inadequacy, ineffectiveness or failure of internal processes,
should it last longer, would keep on burdening the banking book’s performed manually or automatically;
Net Interest Margin.
• external events.
Structural foreign exchange risk This risk includes notably external or internal fraud risk (article 324
Structural foreign exchange exposures represent the net of EU regulation No. 575/2013), non-authorised activities, errors
investments in subsidiaries, branches and associates, the and omissions including events characterised by a low probability
functional currencies of which are currencies other than euro. but with a high operational loss in case of occurrence, and risks
Unrealised gains or losses due to revaluations of structural foreign related to models.
exchange exposures are recognised in other comprehensive HSBC reviewed and, thus, simplified its Risk Taxonomy regrouping
income, whereas other unrealised gains or losses arising from its non-financial risks in seven level 1 categories (previously 16):
revaluations of foreign exchange positions are reflected in the Financial Reporting and Tax Risk, Financial Crime and Fraud Risk,
income statement. Regulatory Compliance Risk, Legal Risk, Resilience Risk, Model
HSBC Continental Europe's structural foreign exchange exposures Risk and People Risk.
are managed with the primary objective of ensuring, where
practical, that the group’s consolidated capital ratios and the
capital ratios of individual banking subsidiaries are largely
protected from the effect of changes in exchange rates. HSBC
hedge structural foreign exchange exposures only in limited
circumstances.
The Three Lines of Defence model is detailed earlier in the part Each of these methods is more complex than the other to
called ‘Risk Management’. determine the capital required to cover operational losses, leading
to more complexity in terms of operational risk management.
Operational Risk Functional Instruction Manual, which is used to
outline how specific risks are managed, has been reviewed in Each method is linked to specific requirements in terms of risk
2020 in order to enhance the role and responsibilities of the three management and external information on the framework of which
Lines of Defence stakeholders. implementation is a condition for the approach application.
In the first line of defence, risk owners are responsible of the risks Like HSBC Group, HSBC Continental Europe currently uses the
within their perimeters and are accountable for the execution of standardised approach in terms of operational risks.
operational controls for their risks. This approach is based on the application of different ratios
Control owners must ensure that all the processes, activities and (12 per cent, 15 per cent, 18 per cent) to the average gross income
systems within their perimeters are working properly. They work (over three years) of each one of the eight business lines defined
with risk owners in order to understand and manage risks. by the Basel II framework.
In 2020, the first line of defence has been reinforced with the It implies that a method has to be determined to divide the global
Business Service Owner role, accountable for the delivery of one gross income between business lines defined by the regulator.
of more end-to-end business key service offered to our customers. Among qualitative criteria used for this method, the
He is responsible for overseeing and managing each of HSBC’s implementation of an internal operational risk framework is
critical and material Business Services end-to-end, including the required and needs to include the following aspects:
risk, control effectiveness and resilience of that service.
• regular inventory of operational losses;
In the second line of defence, the Risk Stewards help overseeing
first line of defence activities playing the role of experts for a • potential operational risks identification for all entities;
specific risk. • implementation of risk management processes, by defining and
Operational Risk Function monitors this framework, supports implementing action plans to mitigate the risks and by
stakeholders already quoted and ensure the efficiency of the monitoring risk indicators;
framework composed by the first and second line of defence. • implementation of an independent structure to manage those
In 2020, in line with the increasing threat landscape that the risks;
industry faces within non-financial risk, we formed a new • regular communication of information about the evolution of
'Operational & Resilience Risk' sub-function, created from the these risks to the executive management.
merge between the former Operational risk team and the new
second-line of defense team: Resilience risks team. The sub- Quantitative aspects
function provides robust first line of defence oversight and risk The Finance department is in charge of calculating capital
steward oversight, supported by clear plans and evidenced by requirement related to operational risks and communicating it to
effective and timely independent challenge. The sub-function the Autorité de contrôle prudentiel et de résolution (‘ACPR’) and the
challenges the status quo ensuring that the first line of defence are European central bank (‘ECB’).
focusing firmly and priority tasks;
First, the Net Banking Income (‘NBI’) has to be divided between
Regulatory disposition the eight business lines defined by Basel II requirements to
Basel II regulatory dispositions require that banking institutions calculate the regulatory capital allocation. This task involves
take into account the operational risk management on three levels: splitting the NBI by entities.
• In terms of capital requirements to take into account all For operational losses, COREP (COmmon solvency ratio REPorting)
banking risks and their economic reality (Pillar I). statements are produced and communicated to the ACPR by the
Finance department on behalf of HSBC Continental Europe; the
• In terms of operational risk framework, meaning an Operational & Resilience Risk function with the support of the
implementation of an internal framework to manage risks Region contributes to the production of two of these three COREP
which should enhance the prudential supervision by the statements: Operational Risk Details and Operational Risk Large
national supervisors (Pillar II). Loss Details on the consolidated perimeter of HSBC Continental
• In terms of information and financial communication on the Europe, excluding its subsidiary HSBC SFH (France), 100 per cent
matter, intended to administrators, supervisory authorities, owned, which is specialised in the issuance of Covered Bonds and
shareholders, etc. (Pillar III). is monitored directly by the Finance department.
Beyond regulatory requirements, managing operational risks and COREP is a prudential reporting implemented by the European
the permanent evolution of the control framework depending on banking supervision committee. It has been created based on
changing activities and regulations to reduce losses from the Profit English words: COmmon solvency ratio REPorting. It relates to the
& Loss (‘P&L’) is a major strategic issue for HSBC Continental sovereign solvability ratio linked to Basel II agreement.
Europe and also improves customer experiences in our daily Using information recorded by Business Risk and Control
activities. Management (‘BRCM’)/Chief Control Officer (‘CCO’) in the
Operational Risk Management – Methodology defined operational risk management system, the Operational Risk
by the regulator function is in charge of the first level of controls of these
statements.
Regulators have defined three methods which are the following:
• Basic approach;
• Standardised approach;
• Advanced approach.
The permanent control is primarily based on controls carried out • Independent Model Review;
by the managers responsible for each activity. The purpose of • Global Risk Analytics – Models elaboration and follow-up;
these controls is to ascertain that the activity is conducted in
• the Chief Risk Officer (‘CRO’) relies also on other functions to
accordance with all internal, external and regulatory rules and is
ensure a complete and accurate risk oversight (Human
up to standard. The key responsibility for control falls to the
Resources, Finance function as regards with accounting,
managers of the various businesses, functions and HSBC
liquidity, structural interest rate, forex and tax risks, and HSBC
Operations, Services and Technology.
Operations, Services and Technology in particular for the
An independent control framework completes this first level of oversight of IT and outsourced services). Functions at which we
control. This comprises mainly: can add Compliance function including, Financial Crime
• Business Risk and Control Management (‘BRCM’) and Chief Compliance and Regulatory Compliance, which report directly
Control Officer (‘CCO’) teams, who monitor and manage risks to the Chief Executive Officer.
in their business/function; All risk reports presented to the HSBC Continental Europe RMM,
• Functions acting as second line of defence, particularly feed the HSBC Continental Europe’s Executive Committee, the
Compliance, responsible for non-compliance risk for HSBC Audit Committee, the Risk Committee and the Board of Directors
Continental Europe as a whole as defined in the article 10 p) of of HSBC Continental Europe.
the French Order of 3 November 2014;
• Operational & Resilience Risk (‘ORR’) function, in charge of
overseeing the non-financial risks management framework. The
function oversees the work carried out by Business Risk and
Control Management (‘BRCM’)/Chief Control Officer (‘CCO’)
teams on operational risks within the businesses, functions and
HSBC Operations, Services and Technology, teams who report
hierarchically to these businesses and functions heads. The
Operational & Resilience Risk function works closely
HSBC Continental Europe RMM includes bank’s European effective and timely independent challenge. The sub-function
branches and is thus supported by risk committees from each challenges the status quo ensuring that the first line of defence are
business. focused firmly on priority tasks.
HSBC Group Manuals The Operational & Resilience Risk Function provides direction,
insight and challenge on the management of non financial risks,
The Group's Global Principles set an overarching standard for all
along with an overall assessment of the non financial risk
other policies and procedures and are fundamental to the Group’s
exposure versus Board appetite. The Operational & Resilience Risk
risk management structure. They inform and connect our purpose,
function also monitor use and adoption of HSBC’s non financial
values, strategy and risk management principles, guiding us to do
risk approach and reports on this to the Non Financial Risk
the right thing and treat our customers and our colleagues fairly at
Management Board, a subcommittee of the Group Risk
all times.
Management Meeting.
All the HSBC Group’s business activities must be fully
The Operational & Resilience Risk function, supervised directly by
documented in manuals or compendia of procedures. Functional
the Chief Risk Officer, brings a holistic vision of risks. It has a
Instruction Manuals are used to outline how specific risks are
consolidation and harmonisation role and provides an overview of
managed. They define the minimum risk management and control
the main operational risks and permanent control to the executive
requirements that must be adopted throughout the organisation to
management, the Risk Committee and HSBC Group, collaborating
ensure consistency and appropriate management of each risk in
with Business Risk and Control Management (‘BRCM’)/Chief
the taxonomy. They contain detailed policies and procedures
Control Officer (‘CCO’) teams and functions acting in the second
relating to a specific business or function, product or activity,
line of defence on critical subjects, such as risk maps reviews, the
which must be adhered to throughout the HSBC Group, barring
design and monitoring of action plans, incident reporting, risk
dispensation granted by the Functional Instruction Manual’s
indicators and control plans.
owner for the HSBC Group.
The function is also in charge of the HSBC Continental Europe Risk
Internal circulars are the key vehicle for communicating internal
Management Meeting secretariat which allows to achieve a
standards and rules derived from French regulatory requirements
transverse vision of risks, both complete and prioritised and if
or HSBC Group standards that apply to several or all the HSBC
possible, prospective of the main operational risk issues of all
Group structures operating in France or within its branches. They
HSBC Continental Europe entities, including International locations
are readily available on the HSBC Continental Europe Intranet and
to the Chief Risk Officer, Chair of the Risk Management Meeting,
have been communicated to the new branches of HSBC
and to the other members of the HSBC Continental Europe senior
Continental Europe, if applicable to them. The drafting, circulation
management.
and storing of circulars are governed by precise rules (also
formally set out in a circular) and are regularly updated. Previously composed by 16 level 1 risks, HSBC Continental
Europe’s operational risks (or non financial risks) taxonomy has
Handbook and codes of conduct
been simplified and is now composed by seven risks, which
The Internal Rules covers ethical provisions applied to all staff synthesise main non financial risks that a bank faces:
relating to adherence with confidentiality, compliance with laws
• Financial Reporting and Tax Risk
and regulations and professional integrity. In addition to these
rules, each of the bank’s businesses or activities may have a • Resilience Risk
specific code of conduct and/or compliance manuals that collate • Financial Crime and Fraud Risk
operational application procedures relating to staff ethic and
compliance with laws and regulations. Staff members qualified as • People Risk
‘High Risk Role’ are also subject to specific requirements relating • Regulatory Compliance Risk
to personal transactions. A conduct handbook available for all
• Legal Risk
employees illustrates with examples to help staff making actions
and decisions in accordance with the standards included in the • Model Risk
‘Global Principles’ document, with a key focus on values and Operational risks may have consequences on reputational risk.
conduct approach, applicable to every HSBC employees. Any lapse by HSBC Continental Europe in standards of integrity,
In 2020, HSBC deployed a code of conduct Anti Bribery & compliance, customer service or operating efficiency represents a
Corruption for France and its European branches. It has been potential reputational risk which may impact its relationship with
attached to the Internal Rules, to guide daily actions from all its clients, counterparts, shareholders, stakeholders and
people attached to HSBC entities in France. regulators. Safeguarding and building upon the Group’s reputation
is the responsibility of each employee of HSBC Continental
The internal committees, forums and working groups
Europe.
Risks and internal control oversight are driven by a number of
Identification and Management of Non financial (Operational)
dedicated committees, forums and working groups which
facilitate management, communication and monitoring of
Risks
operational risk. Governance
Senior Management is kept regularly informed of the organisation The general organisation of the permanent control is supported by
and findings of permanent and periodic controls, in particular Operational & Resilience Risk function regarding non financial
through various dedicated committees and working groups that risks. As mentioned earlier, this function works in close
will be presented further in the part called ‘Governance’. partnership with permanent control teams from businesses,
functions, HSBC Operations, Services and Technology and with
Non financial (or Operational) Risk Management
other functions working in the second line of defence. A
Framework
collaboration has also been implemented as soon as 2018 with the
In 2020, we combined the second line of defence Operational Risk HSBC Bank plc International Chief Risk Officer and Chief Risk
and second line of defence Resilience Risk sub-functions. The sub- Officers from international locations who report to him in order to
function provides robust first line of defence oversight and risk
steward oversight, supported by clear plans and evidenced by
Operational losses from 2012 to end of 2020 per risk category (*) (in millions of EUR)
Building Informa-
unavail- tion, Security
ability Employ- Failure tech- of Finan- Breach
and ment in other nology, Trans- Regu- people Systems cial of
Acco work practices principal and action latory and and report- Finan Resilie fiduciar
unt- place and External risk cyber Internal pro- com- physical data ing -cial Model nce y
ing safety relations fraud pro- security fraud Legal cessin pliance assets integrity and tax Crime risk risk obliga-
risk event event event cessing risk risk risk g risk event event risk event *** *** tions Total
2012 1,1 — 0,7 10,5 2,1 0,1 0,5 (0,8) 7,5 5,1 0,1 1 0,3 — — — — 28,200
2013 0,3 — 1,6 12,1 2,6 0,2 0,2 0,1 3,2 0,4 — 2,2 (2,5) — — — — 20,400*
2014 — 0,1 1,3 6,4 0,6 — 0,1 0,3 5,3 (2,8) — (0,3) (0,1) — — — — 10,900
2015 0,1 — 1,1 4,8 1,8 — 0,1 0,6 4,6 3,4 — 0,5 — — — — — 17,000
2016 — — 0,6 11,1 (0,2) — — 0,1 (15,7) 36,2 — 0,3 — — — — — 32,400
2017 — 0,1 0,9 2,9 1,4 — 0,2 — 3,4 0,7 — 0,1 1 — — — — 10,700
2018 7,83 — (0,07) 2,4 0,68 — — 0,7 3,36 2 — 0,1 0,4 — — — — 17,400
2019 — 0,016 0,99 2,48 1,68 1,22 0,023 (0,04) 8,09 (1,19) — — 1,8 — — — 0,019 15,083
2020 — 0.035 0.27 2.31 1.35 0.22 0.006 0 54.32 2.7 — — 0.09 — 17.1 3.28 0.008 81.699
(*)
Figures Source: Operational risk system (Helios). Level 1/level 2 from the risk taxonomy to take into consideration the successive risks taxonomy
changes since 2012.
(**)
Excluding a one-off legacy internal event within GBM.
(***)
New risks created in 2020 as part of the changes operated in the risk taxonomy.
RWA and capital requirements related to operational risk to the As part of the Group NFRO (Non-Financial Risk Optimisation)
end of 2020 Programme, aiming to simplify and enhance non financial risks
approach, certain existing risks have been consolidated into
Capital
(in millions of euros) RWAs requirements broader categories, which is the case for Resilience risk. It
WPB 969 78
includes Cybersecurity, Systems and data, transaction processing,
CMB 1,085 87
business continuity, workplace safety and third party
GBM 1,115 89
management.
Corporate Centre 114 9 The Covid-19 outbreak, as a new systemic risk, is still a key point
Total 3,283 263 of attention within the Bank, requiring robust contingency plans in
a context where the Banks assume critical financial service roles.
The year’s highlights 2020 Operational & resilience risk function has been fully involved to
ensure appropriate management of non financial risks during the
In 2020, in line with the increasing threat landscape that the period. The crisis has been an opportunity to demonstrate the
industry faces within non-financial risk, we formed a new maturity of Conduct principles applied in all decisions and actions
Operational & Resilience Risk sub-function, created from the with a balanced exchange of value between the bank and
merge between the former Operational Risk team and the new customers and to strongly collaborate across Lines of Business to
second line of defence team: Resilience risk team. optimise best practices and processes to deliver good outcomes to
customers.
The RC risks relating to the activities of HSBC Continental Europe Compliance examination procedures and detection and
stem primarily from the following areas: customer protection, prevention tools
compliance with conduct rules relating to client interests, HSBC Continental Europe has specific compliance examination
complaint handling, the protection of the integrity and procedures, in accordance with the provisions of Articles 35 to 38
transparency of financial markets, the preservation of the
confidentiality of information, employees code of ethics, the
prevention of conflicts of interest and compliance with the
applicable rules in terms of marketing (both on a domestic and a
cross-border basis).
of the Order of 3 November 2014 relating to banks’ internal control • The oversight of conduct implemented by the business lines
systems, as well as tools for detecting and preventing RC risks. through achievement, initiatives and risks regarding customer
fair treatment and market integrity;
These procedures and tools are the subject of regular updates and
upgrades. • The findings of the controls carried out by the Compliance
Assurance team, the status of its recommendations and their
Control System
implementation by action owners in the first line of defence;
The Compliance function is considered to be first and foremost a
• Cross-business items of significance regarding Regulatory
Second Line of Defence player in the HSBC Group. This role is
Compliance, whether for information, for action and/or for
ensured:
decision by Senior Management.
• firstly, by implementing the policies or circulars, by advising
Furthermore, regarding the risks related to new products and
and training the operating staff in the businesses or functions;
services as well as material changes and withdrawal for existing
• secondly, by conducting cross-functional theme-based reviews products, the majority of the businesses have specific bodies for
carried out by the Compliance Assurance team. the examination of products and services. In HSBC in France, all
The reporting of issues and RC Risk Control Forums new products and material changes for existing products are
subject to the approval from the Product Approval Committee,
Monitoring of the functioning of the control compliance chaired by the Chief Executive Officer of HSBC Continental
framework relies in the first instance on existing reporting Europe, and whose secretariat is managed by RC.
procedures within the Compliance function, as well as on the
information made available through governance forums. To finish, in 2020, Compliance function organized on a quarterly
basis a Forum on Whistleblowing with the main investigative
Problems identified in the implementation of the compliance functions (Human Resources, Compliance and FCI) with the
obligations are the subject of an incident report that is drawn up following agenda:
and must be transmitted to the appropriate level within the
Compliance Function, followed by regular monitoring of the • Monitor the whistleblowing activities with KPIs and MIs;
actions implemented to rectify the situation, using a dedicated tool • Ensure a follow-up of cases, and especially the older ones;
called IRIS (Integrated Regulatory Information System).
• Develop any amendment to the governance arrangements in
The incidents identified as having a high risk are also monitored in place;
a specific tool (Helios) and constitute a trigger event to review the
• Share best practices; and
risk identified.
• Address any outstanding or common issues.
Supervision and recording of Regulatory Engagements
Financial Crime
Under the consolidated approach to non-compliance risks, the
Compliance Function ensures centralised monitoring of Regulatory System of control and identification of non-compliance risks
Engagements within entities of the HSBC Group regarding notably
The Financial Crime (‘FC’) function relies, in particular, on the local
FC and RC risks, mostly via the Regulatory Affairs team. Since
legal monitoring of the French Legal function in order to identify
February 2018, the HSBC Group records the Material Regulatory
the modifications of legislative and regulatory texts as well as
Engagements between HSBC and its regulators and supervision
jurisprudential developments having an impact on the activities of
authorities in a tool dedicated to the supervision.
HSBC Continental Europe.
RC Risk Control Forums The analysis of non-compliance risks is documented in maps
The functioning of the framework and the main RC risks identified recording the legislative, regulatory, professional provisions, as
are reviewed through dedicated control forums, consisting of both well as the provisions specific to the HSBC Group, applicable to
compliance representatives and operating managers. RC risks are each business or function, and the procedures and controls
also reviewed by governance risk management forums within implemented to ensure compliance with the said provisions.
business lines or functions. Noncompliance risk maps are regularly updated.
These forums either have a decision-making role, in terms of The non-FC risks relating to the activities of HSBC Continental
managing the regulatory compliance control system, or the role of Europe stem primarily from the following areas: Anti-Money
providing information to Senior Management on the functioning of Laundering, Counter Terrorism Financing, Anti-Bribery &
the system, identified issues, and the corrective measures Corruption, international financial sanctions respect, Fraud, and
undertaken. Tax-fraud.
RC risks are reviewed by the Risk Management Meeting (‘RMM’), Staff training and awareness
which is the governance forum within HSBC Continental Europe
Staff training relating to fight against financial crime principally
for risk management and permanent control. It has a decision-
includes:
making power regarding the organisation of the risk control and
management frameworks. • Mandatory e-learnings ensuring all employees having sufficient
Financial Crime Risks knowledge and their respective roles;
The quarterly Conduct & Regulatory Compliance Forum meets
under the chairmanship of the Chief Executive Officer, and • Certifying training classroom-based for the FCC Risks
includes Executive Committee members who are Business Heads. employees most exposed: new employees follow a training and
receive a certification within 90 days following their arrival in
To ensure the appropriate level of information of the Senior
HSBC;
Management of HSBC Continental Europe on the functioning of
the risk control framework, the main topics raised during the
Forum include:
The Legal Department operates as First and Second line of On 21 December 2017, the Paris Court of Appeal decided that the
Defence. A legal risks taxonomy has been defined to harmonise banks, including HSBC Continental Europe, did infringe
their identification and control. The Legal Department is deeply competition law. The amount of the fine against HSBC Continental
involved in the review and control of the legal risks assessed by Europe is unchanged.
the businesses and functions in their Risk and Control HSBC Continental Europe has appealed the 21 December 2017
Assessments. Paris Court of Appeal’s decision before the French Supreme court.
Litigation monitoring with regard to HSBC Continental On 29 January 2020, the Supreme Court decided to quash the
Europe entities 2017 appeal decision and to refer the case back to the Paris Court
of Appeals.
The situation of the risks arising from significant litigation in
progress against the HSBC Continental Europe is examined The Apollonia case
monthly by a committee run by Chief Accounting officer, chaired As was the case for around 20 other banks, HSBC worked during
by the Chief Financial Officer and the Chief Risk Officer and is a limited period of time (from early 2006 to April 2007), and mainly
made up notably of representatives of the Finance Department, in one branch, with a financial adviser and estate agent, known as
the Credit Department and the Legal Department. This committee Apollonia. The latter offered its clients (mainly independent
decides upon the amount of the litigation provision to be charged professionals) ‘turnkey’ tax efficient products of the Loueur
or written back. Meublé Professionnel (‘LMP’) (professional lessor of furnished
Cases in progress as at 31 December 2020 involving legal risks accommodations) type and for a small number of investors ‘Loi
likely to have a significant effect on the financial situation of the Robien’ type tax efficient products.
HSBC Continental Europe net assets are set out below. These Between April 2006 and April 2007, 184 property loan applications
cases have given rise to appropriate provisions, as necessary. were approved, for a total of EUR 29 million, bearing in mind that
Interbank commissions relating to electronic cheque different media have said the total amount of operations by
processing Apollonia with all banks purportedly reached around EUR 2 billion.
In 2002, a number of banks with retail networks, including HSBC At the end of September 2008, HSBC Continental Europe became
Continental Europe forming part of an inter-branch committee aware of the use of inappropriate marketing methods by
sponsored by the French Banking Federation, introduced a system Apollonia. Moreover, it appeared that most of the borrowers took
of interbank fees applying to the new electronic cheque out several loans through Apollonia from various banks without
processing termed Echange d’Images Chèques (‘EIC’), the cheque notifying HSBC Continental Europe.
image exchange system. HSBC Continental Europe is involved as a civil law party, giving it
In March 2008, the French Competition Authority sent notification access to the criminal file. From this, it has become apparent that
of a complaint to the 12 members of the committee – including a very large proportion of the official agency authorisations, signed
HSBC Continental Europe – for the introduction of interbank fees by the buyers giving authority to sign purchase and sales deeds,
when the EIC was set up. were not properly prepared.
On 20 September 2010, the French Competition Authority took an HSBC Continental Europe systematically files proceedings against
unfavourable decision as regards the scheme introduced in 2002. those investors with loan repayments due but the hearings are
In substance, it found that the EIC constituted an illegal scheme, often held in abeyance because of the criminal proceedings under
the purpose of which included effects on the cost of processing way. However, in order to settle the financial aspects of the
cheques causing an increase in costs charged on ‘major remitter’ matter, without waiting for the outcome of criminal proceedings,
customers. The banks involved in setting up this charging system out-of-court settlements have already been reached with some
were fined a total of EUR 384.9 million. HSBC Continental Europe borrowers and talks are continuing with other borrowers.
was ordered to pay a fine of EUR 9.05 million. HSBC Continental Proceedings have also been commenced against the notaries
Europe, together with the other banks that were fined, except the involved and their insurer MMA. These proceedings have also
Banque de France, decided to appeal this unfavourable decision. been adjourned for the time being.
The banks actually contest as much the anticompetitive purpose Adequate provisions have been recorded for the Apollonia case in
as the anticompetitive effect of the EIC-related commission and the light of information available to Senior Management.
argue that it has no significant effect on the costs of banking HSBC Bank Polska S.A.: ACTION Case
services. The banks, including HSBC Continental Europe, further
question the method used in calculating the fines imposed upon On 29 June 2018, HSBC Continental Europe acquired from HSBC
them. Bank plc 100 per cent of the shares of HSBC Bank Polska S.A.
Pursuant to the terms of the Sale and Purchase Agreement, HSBC
On 23 February 2012, the Paris Court of Appeal overturned the Continental Europe and/or its subsidiaries will be indemnified by
decision of the French Competition Authority, finding that the
Authority had failed to demonstrate a restriction by object. The HSBC Bank plc in respect of certain liabilities relating to the
Paris Court of Appeal cleared the banks of wrongdoing and activities of HSBC Bank Polska S.A. prior to the acquisition of
ordered the repayment of fines paid by the banks. HSBC Bank Polska S.A. HSBC Bank Polska S.A. is involved in the
proceeding as described below. In April 2017, ACTION brought an
The French Competition Authority appealed to the Supreme Court action against HSBC Bank Polska S.A. alleging, among other
against the decision. things, breach of a facility agreement and claiming damages and
On 14 April 2015, the French Supreme Court overturned the indemnification for lost profits. The proceeding is ongoing.
decision of the Paris Court of Appeal of 23 February 2012 solely on European interbank offered rates investigations and litigation
procedural grounds.
See Note 36 of the consolidated financial statements with regard
Consequently, the banks had to transfer back the sums to other significant legal proceedings and regulatory matters
reimbursed on the basis of the decision of the Paris Court of relating to HSBC Group entities generally, including HSBC
Appeal of 23 February 2012. Continental Europe.
The French Supreme Court referred the parties back to the Paris
Court of Appeal.
Control of accounting production to HSBC Holding, duly signed by the CEO, the CFO and the Head
of Internal Audit, attesting the effectiveness of internal financial
The financial control of the Bank is organised around three main
controls.
axes:
• The monthly accounting certification; Resilience risk
• The analytical review of the financial statements; Resilience risk is the risk that we are unable to provide critical
services to our customers, affiliates and counterparties, as a result
• The financial Internal Control Sarbanes-Oxley (‘SOX’). of sustained and significant operational disruption.
HSBC Continental Europe prepares, on a monthly basis, a Sustained and significant operational disruption means events that
certificate of accounting reconciliations which is addressed to the affect:
HSBC Group Europe Finance Department. This certificate, which is • the stability of the financial system;
an attestation of the full reconciliation and substantiation of
Balance Sheet and Off Balance Sheet, is signed off by the CFO, • the viability of the bank and our industry peers; or
based on a consolidation of certificates of accounting • the ability of our customers to access our services.
reconciliations transmitted by the heads of accounting and
We seek to understand the effects and outcomes of these events,
financial reporting of HSBC Continental Europe and its entities.
prioritising services which are both vulnerable to disturbance and
These certifications are formalised using the Group managed
critical to our customer service offering.
accounting certification tool AssureNET.
The monthly accounting certification reporting is based on the Information and cyber security risk
principle according to which each account of a general balance is Overview – Risk description
assigned to an owner, which is responsible for its reconciliation.
The anomalies detected lead to the determination of corrective The bank operates a three lines of defence model to manage its
actions for the teams and business concerned. The BRCM risks, the first line of defence (Cybersecurity) being responsible for
(Business Risk & Control Managers) of the entities of HSBC the day to day operation and management of the information
Continental Europe group, internal controllers of the First Line of security control environment; the second of line of defence
Defence, ensure these controls during their work programme on a (Resilience Risk) being the risk stewards responsible for
risk based approach. determining the information security risk appetite, policy
development and governance and oversight of the activity of
Balance sheet and profit and loss analytical reviews are performed Cybersecurity; and the 3rd line of defence being the (Internal
by operational accounting and Business Finance/Management Audit) team whole role is to provide Senior management and the
Reporting and Analysis teams on a monthly basis. These variance Board with an independent vision concerning risk management
analysis are performed against business plans, budgets, trends and internal control governance and processes.
comparisons vs prior month or year-on-year and all major
variations according to thresholds are investigated and explained. The threat from cyber-attacks remains a concern for our
These reports are sent to the HSBC Group Europe Finance, Heads organisation, and failure to protect our operations from internet
of businesses and functions, as well as CFO. Financial reporting is crime or cyber-attacks may result in financial loss, business
presented monthly by the CFO to the Executive Committee of disruption and/or loss of customer services and data or other
HSBC Continental Europe and quarterly to the Audit Committee, sensitive information that could undermine our reputation and our
the Risk Committee and the Board of HSBC Continental Europe. ability to attract and keep customers. Ransomware and
The Audit Committee and the Risk Committee examine quarterly, Distributed Denial of Service (‘DDoS’) attacks are an increasingly
half-yearly and annually the accounts submitted to the Board. dominant threat across the industry.
In order to comply with the requirements of American Law of Ransomware are mostly distributed via spear phishing and aim to
Sarbanes-Oxley (‘SOX’), enforced by the HSBC Group, HSBC extort money from the victim or used to issue fraudulent payments
Continental Europe thoroughly evaluates the controls in place within the internal bank systems.
while establishing the financial statements. The main processes Key Developments 2020
supporting the establishment of these statements are part of a
HSBC, through the Cybersecurity Maturity Improvement
detailed documentation and proper controls, and regularly
Programme, succeeded to implement key cyber controls such as:
supervised within periodic review framework. These detailed
analysis of operations flows till the accounts contribute to the • Secure Development & Vulnerability Remediation tools leading.
improvement of control of the audit trail. Defects identified during Such tools are divided in three categories:
this process must be corrected in the given period of time defined – Static Application Security Testing, allowing to scan source
by the owners of remediation action plans and should be quarterly code and to identify known vulnerabilities;
reviewed by the Finance SOX internal controller.
– Dynamic Application Security Testing, allowing to identify
The Internal Audit team takes actively part in the supervision of potential security vulnerabilities in the web application and
the correct implementation of SOX process, while performing their
periodic controls. The Finance SOX internal controller has access
via the Audit databases of HSBC Group (ARAMIS and AID – Audit
Issues Database), to the audit points raised by the different teams
of audit, which permits to follow-up SOX recommendations issued
by the periodic control team. In addition, the external statutory
auditors perform every year the review of the control organisation
on the behalf of HSBC Group and give their opinion on the
SOX 404 report prepared by the management of HSBC Holding
PLC.
Every quarter, the Audit Committee and Risk Committee of HSBC
Continental Europe are informed of the results of these controls
and the progress of main action plans in case of deficiencies. A
certificate is half-yearly sent by HSBC Continental Europe
HSBC is committed to maintaining and continually improving Each business and function across the first line of defence is in
information security to meet our responsibilities to our customers charge of monitoring the Third Parties under its perimeter to
and regulators and to reduce exposure to legal sanction, ensure that any service considered for outsourcing is adequately
operational loss or reputational damage. We are committed to risk-assessed, that appropriate due diligence and controls are
ensuring the confidentiality, integrity and availability of corporate, conducted, that the service is duly approved by the appropriate
client and customer information. level of Management prior to the contract commencement date
and that the service is adequately monitored all along the contract
HSBC has implemented a risk management framework across the lifecycle. Each business and Function is in charge of monitoring
lines of defence to identify, assess, report and manage risks adherence to the Third Party Policy through continuous control
across the organisation. Information security frameworks within monitoring and thematic reviews performed by the CCO (Chief
HSBC follow internationally recognised best practice standards. Control Officer) teams and to reflect the effectiveness of the
The governance of the Cyber and Information security risks control environment into the Group Risk Management tool, Helios.
includes the Cybersecurity & Vulnerability Steering, the Cyber Within the second line of defence, the Resilience Risk is in charge
Defence Forum, the HSBC Operations, Services and Technology of defining the strategy and the policy for an effective
Control Environment Management Meeting, the business risk and management of the Third Party Risk, Regulatory Compliance and
control oversight meetings and ultimately the Risk Management Operational Risk are systematically engaged to review and
Meeting. approve the materiality assessment proposed by the first line of
defence, Legal is engaged to review the contractual agreements
Key Management Process where predefined contract templates cannot be used or in case of
Security incidents: In 2020, the bank was the target of limited request from the provider to adjust the contract, and each Risk
number of DDoS attacks on our external facing websites across Steward is engaged to review the risk assessment undertaken by
the Group. Additionally, the bank did not suffer any ransomware the first line of defence within his area of expertise.
attacks. However, the bank has seen an increase of ransomware In addition to the above, the Regulatory Compliance Risk
attacks on some of its third parties although these had no impact Assurance team is in charge for conducting thematic reviews to
on HSBC data or availability of services. Although cyber-attacks in ensure that the policy is correctly implemented across the different
2020 had a negligible effect on our customers, services or firm, business lines and functions.
due to the increasing sophistication of cyber-attacks there is the
potential for future attacks to have a material adverse effect on our Governance
business, prospects, financial condition, reputation and results of Any outsourcing of a material service needs to be formally
operations. HSBC had not reported any significant security approved by the Bank Risk Management Meeting prior to the
incidents in the past 12 months. contract commencement date.
Training & awareness: HSBC has an ongoing security awareness A dedicated Cloud Committee is implemented to review each
programme employing various channels to engage staff including, project to outsource on a Cloud to ensure adherence to the Group
mandatory annual online training, intranet content, posters, Cloud strategy and to review data privacy, regulatory compliance,
emails, new employee education and monthly thematic awareness Legal and IT aspects.
power point packs. All HSBC staff has been covered by the
awareness training. High risk profiles such as Board of Directors A monthly Third Party Risk Forum is in place to ensure that third
also attended a dedicated Cyber and Information Security parties are managed in line with Group standards and regulatory
awareness training session. expectations.
In addition to this annual mandatory on line training, every staff is Security of People and Physical Assets
encouraged to registered to a Cyber shield Programme. The Overview – Risk description
programme consists of three hours training per month on Cyber to
enhance their awareness. Furthermore, the Cyber monthly Heightened global terror threat, organised crime, political and
awareness newsletters are sent to all Business Information Risk social unrest, activism and the results of sanitary crisis place a
Officers and communicated to all Global Business/Global greater emphasis on the need to ensure the physical protection of
our people, premises and property through careful analysis of resilience; third party and protective security risk, including
current and emerging security threats. Contingency Risk area.
Protective Security is in charge of managing physical risks, In the 2nd half of 2020, a transformation occurred to merge the
identifying them and preventing them. The department Operational Risk and Resilience Risk within one team called
implements physical, electronic and operational solutions to Operational and Resilience Risk (‘ORR’).
ensure the security of personnel, assets and information held by In parallel, the Business Continuity & Incident Management team
HSBC against any malicious or criminal action. now sits within the HSBC Operations, Services & Technology Chief
Key developments Operating Office Office function. The Business Continuity &
Incident Management team located in France is now part of the
After the previous yellow vests crisis of 2019, this year saw the
Europe Business Continuity & Incident Management team who
increase in the terrorist threat, the Covid-19 pandemic and the
has accountability for the oversight of all delivery aspects of
long lockdown periods that required daily adaptation to ensure the
Business Continuity Management and Incident Management for
necessary security staff presence, a permanent fitting of our
the countries within HSBC Europe.
procedures, and the continuity of the management and
maintenance of security and access control systems. Covid-19: From the beginning, it has been decided to coordinate
the contingency response across Europe, based on lesson learned
The Protective Security team has also been heavily involved in the
from the first wave in Asia where HBSC’s teams had to respond
change of Head Office from l’avenue des Champs Elysées, to
first. Thus, the massive usage of work from home was anticipated
l’avenue Kléber, particularly for Elysées strong rooms transfers
and related actions timely implemented, so no country suffered
and relocating customer safes; as well as in the design and
from partial/full lockdown impacts. In parallel, a global Covid-19
monitoring of the security systems implementation in the new
Working Group was setup to ensure coordination across the
headquarters on avenue Kléber.
regions, to share best practices, define procedures for accounting
Governance staff, and guidance for planning phased return to office after the
The Protective Security team drafts procedures and circulars event.
relating to security within the scope of HSBC Continental Europe, The global response to the Covid-19 resulted in a significant
based on Group standards and regulatory complaints. increase in business processes being undertaken remotely. This
As 1st line of defence, Protective Security implements the required put an increased focus on resilience risks including contingency
security controls in accordance with the instructions and risks at service providers as part of Third-Party Management risk
taxonomy issued at the global level. and raised specific attention towards data leakage for staff
working from home due to lack of management oversight.
The Protective Security team provides advice to business lines or
functions, and, because of its cross-functional role, is involved in Overall it was found that the bank responded swiftly and
crisis management committees. efficiently to the situation as it could leverage the legacy usage,
equipment and infrastructure of occasional remote working and
Contingency risk succeeded in rapidly putting in place a governance to manage the
business exceptions processes.
Overview
Contingency Risk covers the risk that we are unable to provide
Governance and structure
critical services to our customers, affiliates and counterparties, as Business Continuity & Incident Management has established a
a result of a sustained and significant disruption due to various quarterly local committee, headed by the Chief Operating Office
kinds of events. Continetal Europe in which are presented the status of the
The management of this risk is performed by the first and second contingency risk controls and the management of any major
line of defence. Within the first line of defence, the Global incidents.
businesses and functions own the risk and implement adequate In this committee are also reviewed the issues and risk identified
controls. The Business Continuity & Incident Management with the risks Businesses or Global Functions. These elements
function support them and ensure control monitoring. The could also be presented and escalated to the HSBC Europe RCMM
stewardship role of this risk is discharged by the Resilience Risk (Risk and Control Management Meeting).
function from a second line of defence perspective.
Business Continuity & Incident Management also has an internal
The aim is to ensure that the group’s critical services, processes management and escalation structure implemented through
and functions have the resilience to maintain continuity in the face Regional/GSC and GBM Team Meetings (‘TM’) as well as the
of major disruptive events. Within this very large perimeter, Global Business Continuity & Incident Management Leadership
business continuity management covers the planning for recovery Team Meetings (‘LTM’) in order to ensure that noteworthy points
through Business Continuity plans, seeking to minimise the are escalated to the Regional/GSC/LOB and Global Business
adverse effects of major business disruption, either globally, Continuity & Incident Management Heads.
regionally or within country, against a range of actual or emerging
Key risk management processes
risks.
The resilience risk team oversees the identification, management
Key developments 2020
and control of contingency risks. The Risk Taxonomy & Control
In 2020, the Group has finalised the implementation of the Library (‘RTCL’) linked to contingency risk is beng reviewed as part
Resilience Risk function, linked to the revision of the Non-Financial of the Non Financial Risk Optimisation programme.
Risk simplified risk taxonomy. Resilience risk function sits in the
Global policy and procedures are also being re-written to align
second line of defence and is in charge to provide guidance and
with the changes in the organisation and the new role of Business
oversight to our businesses and global functions for: strategic
Continuity & Incident Management.
change and emerging threats, systems and cyber resilience,
information and data resilience, payments and processing Business Continuity & Incident Management will going forward
now assess the key operational controls and attest using
continuous monitoring to their effectiveness.
designed to encourage awareness of model risk within In accordance with article 27 of the French order of 3 November
businesses. 2014, the periodic control framework applies to the entire HSBC
Continental Europe company, including its European branches, as
• The required depth of scrutiny is made commensurate to the
well as to companies under exclusive or joint control.
materiality of model risk, allowing to allocate resources to key
models. Global Internal Audit (‘GBL INA’) is comprised of six global audit
teams whose role is to provide expert coverage of HSBC Group’s
• The role of Model Risk Management function is now well
businesses and functions:
defined, giving the Second Line the authority to stop or impose
conditions to use the models. • Wealth and Personal Banking (‘WPB’) Audit;
Governance and structure • Commercial Banking (‘CMB’) and Global Banking (‘GB’) Audit;
At the level of HSBC Group, Model Risk Management is headed by • Global Markets (‘GM’) Audit;
the Chief Model Risk Officer, and is structured as a global sub • Finance and Risk Audit;
function, with regional Model Risk Management teams which
support and advise each global business and global function. At • Compliance Audit; and
the level of HSBC Continental Europe, Model Risk Management is • HSBC Operations, Services and Technology Audit.
headed by its local head, reporting to the Chief Risk Officer, and
functionally to the EMEA Head of Model Risk Management. The GBL INA is also comprised of, four regional audit teams (United
HSBC Continental Europe head of Model Risk Management is Kingdom, Asia Pacific, United States and Rest of the World) that
supported by a team of independent model review and model risk include Country Audit Teams (‘CATs’). Global Internal Audit France
overnance staff based locally, and by teams in HSBC Centres of (‘INA FRA’) being one of the CATs, whose responsibility is to cover
Excellence in Poland and India. the risks within HSBC Continental Europe legal perimeter
(Belgium, Czech Republic, France, Greece, Ireland, Italy,
Key risk management processes Luxembourg, Netherlands, Poland, Spain and Sweden), supported
HSBC regularly reviews its model risk management policies and by local teams in Luxembourg and in Poland.
procedures, which require model owning/using businesses and HSBC Continental Europe periodic control is therefore covered
functions to demonstrate a set of comprehensive and effective conjointly by two GBL INA entities, functionally linked and
model risk controls. Model Risk Management report on model risk coordinated:
to senior management on a regular basis through use of the risk
• INA FRA, a general audit team based in France, in the main
map and top and emerging risks. It also reviews the effectiveness
historically auditing central functions, WPB, CMB, banking
of the model risk committee structure on a regular basis to ensure
operations, IT and strategically important projects. INA FRA
appropriate understanding and ownership of model risk is
budgeted headcount was 30 members in 2020, mainly split
embedded in the businesses and functions.
between business auditors and IT auditors; and
Periodic control • the global teams, specialised by business and/or function,
In accordance with French ministerial order of 3 November 2014 based principally in London and in Hong Kong.
concerning internal control within financial institutions, and Beyond the functional and regional organisation described above,
payment and investment service providers, the role of Internal GBL INA relies on local resources in numerous countries.
Audit is to provide Senior Management and HSBC Continental
Europe Audit and Risk Committees objective assurance on risk CATs form one of the pillars of GBL INA’s strategy. Country teams
management and the internal control system implemented by the have the detailed knowledge of local regulations and environment
bank. Periodic controls of HSBC Continental Europe aim to enabling coverage to be adapted as appropriate, and functionally
ascertain the compliance of operations, the levels of risk actually reporting to the global audit function strengthens their
incurred by the institution, due observance of the procedures and independence and ensures consistency between teams, all of
the effectiveness and appropriateness of the control frameworks, whom are held to the high standards defined and regularly
by means of independent investigations conducted centrally by updated in the Audit Instruction Manual (‘AIM’). That all teams
staff qualified for this purpose. share a reporting line into a global function helps collaboration and
the sharing of best practices.
As part of HSBC Group’s risk management framework, Internal
Audit (‘INA’) constitutes the Third Line of Defence, coming Periodic controls on HSBC Continental Europe in 2020 have thus
successively behind the businesses and functions’ own First Line been assured jointly by GBL INA directly, by INA FRA or by both
of Defence (Risk Owners, Control Owners and Chief Control actors in concert in accordance with the agreement signed on
Officers) and the Second Line of Defence teams (Operational Risk, 25 March 2011 and updated on 2 August 2019 which structures
Assurance Teams and Risk Stewards). Whilst the First and Second the roles, responsibilities and coverage model.
Lines of Defence are taken into account, INA has unlimited scope There are five members of the global GBM audit team that are
to define its own programme of work. This freedom is based on based in Paris. In addition, other members of global teams are also
the fact that Internal Audit is responsible for providing Senior located in Paris: one person for Model Risk Audit and one person
Management and the Audit Committee and Risk Committee of the for Insurance Audit.
bank, independent assurance on the risk exposure and level of
control by management. The scopes of local audit and global audit converge and are
consolidated in the HSBC Continental Europe audit plan. In all
As such, Internal Audit pays attention, in the first instance, to the cases, as defined in the aforementioned French ministerial order of
evaluation of the respect of national legislation applicable to the 3 November 2014, all audits on HSBC Continental Europe are
audited area, secondly, to the correct application of rules and
procedures in force within HSBC Group and finally, that audited
activities remain within the defined appetite for exposure to the
associated risks.
Group People Committee (‘GPC’), while taking into account local Individual awards
practices and regulatory constraints. After approval of the list, it reviews and approves the consistency
The main missions of the People Committee are: of remuneration of the ‘Material Risk Takers’ (except for the
members of the People Committee in its limited perimeter) before
• Follow up, on a transversal way at local level and within every
submitting them to the appropriate HSBC Continental Europe and
Global Business and Global Function, of the implementation of
HSBC Group decision-making bodies.
Group strategies in term of staff management, for instance
regarding diversity, international mobility, employees It reviews the businesses’ 20 highest earners (except the members
engagement score, recruitment, personal development; of the People Committee in its limited perimeter) in conjunction
with the HSBC Continental Europe and HSBC Group’s decision-
• Review of possible dispensations obtained towards GPC on
making bodies and the global businesses lines.
approaches adopted with regard to strategies implementation
and/or Group main policies in term of staff management; It reviews the list of individual breaches with respect to internal
rules in term of credit risk, compliance and reputation, information
• Follow up of main risks in term of staff management at local
security, and for specific employees, to mandates provided by
level (especially cases of breaches identified through
Volker and SRAB rules.
incentivizing compliance process, statistics on turnover, results
of Global People Survey (‘GPS’) and corresponding action The Human Resources department undertakes to submit a
plans); summary of the major focus and main changes of the
remuneration policy to the first Remuneration Committee of the
• Identification of local talented employee, in the context of the
Board of Directors following the People Committee in its limited
Inspire programme (leadership development in France), the
perimeter.
Group Program 'Explore' and the management of the annual
succession plan for the critical roles (Enterprise Critical Roles Role of the Remuneration Committee
and Business Critical Roles);
On the basis of the remuneration policy papers prepared by the
• Follow up of the appropriate application of the Group Strategy People Committee in its limited perimeter, the Remuneration
in term of performance management and assessment of Committee, chaired by an independent Director, gives his view on
talented employee; the bank’s remuneration policies and, practices ensuring they are
• Analysis of the evolution of organisational structures if any and consistent with the HSBC Group policy and that they comply with
corresponding decisions at local level (for example major applicable local standards. It also ensures that risk management
changes to Job Catalogue, to managers scope of and compliance issues are taken into account.
responsibilities); Its scope of responsibility covers all remuneration policies and
• Review of GCB 0-3 career movements; practices in place within the company, with a more in-depth
review of market professionals and Executive Directors.
• Approval of minutes and review of previous People Committee
actions plans. Role of the Risk and Compliance functions as regards
remuneration policies
In term of remuneration, the People Committee in its limited
perimeter performs different roles both in its global and individual The Risk and Compliance functions are, in accordance with the
aspects. HSBC Group rules – Functional Instruction Manual (‘FIM’) and
Global Standards Manual (‘GSM’) referred to for advice on laying
Remuneration policy down remuneration policies on introducing new variable
It examines the main thrust of the remuneration policy put forward remuneration systems and finally during the pay review process
by the Human Resources Department for France and approves it. when allocating individual discretionary variable.
It ensures that this policy fits in with the general principles of the To strengthen the Risk and Compliance functions, certain changes
remuneration policy set out by the HSBC Group for all of its were made in 2010 and significantly reinforced in 2015.
subsidiaries, in accordance with the specific directives set by the On a practical level, these functions are responsible, in their
global businesses lines. respective fields of operation, for:
It gives its opinion on whether this policy complies with local • identifying and listing, throughout the year, all instances of
industry standards and the recommendations of the French bank non-adherence to compliance rules and/or rules of internal
supervisory authorities (Autorité de Contrôle Prudentiel et de procedure and/or rules concerning risk or security information;
Résolution, European Central Bank, Autorité des Marchés
Financiers, Fédération Bancaire Française). • instructing cases of individual breach in coordination with
employee’s manager and, if appropriate, with Employee
Variable remuneration arrangements Relation team;
It checks that all variable remuneration arrangements in place in • presenting cases to the Operational Risk Committee of the
the bank’s various businesses are in line with the general business concerned in order to assess the gravity of the risk
principles set out in the remuneration policy for France, Group and and the level of severity of the individual breach taking into
the global businesses lines and comply with the requirements of account aggravating and mitigating factors. Finally, the
the supervisory authorities. Committee decides the disciplinary and/or managerial actions
It reviews the variable remuneration packages awarded by global to be implemented, any adjustment on performance rating and
businesses lines to local teams (in France or outside of France) on as a result on variable remuneration and last whether,
the basis of the overall performance of each business and of the regarding the severity of the breach, the ‘malus’ rule needs to
relative performance of teams, while taking risk and compliance be applied, cancelling some or all previously awarded and
into account. unvested shares;
It approves the structure of these packages, i.e. the split between • if necessary, providing feedback to management for possibly
cash and shares, between immediate remuneration and deferred making possible changes to internal procedures and to the
remuneration in application of the HSBC Group rules, and local ‘balanced scorecard’ of the employees involved in the
industry standards on the subject. breaches.
The Human Resources Department notifies the People Committee
and the Remuneration Committee of the list of decisions giving a
The local subsidiary sets its own control procedures in addition to • credit risk: risk of financial loss following the default of third
complying with guidelines issued by the HSBC Group Insurance. parties to meet their obligations; and
Country level oversight is exercised by the subsidiary’s local Risk • liquidity risk: risk of not being able to make payments to
Management Meeting. policyholders as they fall due as a result of insufficient assets
In addition, local subsidiary’s ALCO monitors and reviews the that can be realised as cash.
matching over time of the expected cash flows of insurance assets Regulatory requirements prescribe the type, quality and
and liabilities. concentration of assets that HSBC Assurances Vie (France) must
All insurance products, whether manufactured internally or by a maintain to meet insurance liabilities. These requirements
third party, are subjected to a product approval process prior to complement the HSBC Group-wide policies.
introduction. The following table analyses the assets held in HSBC Continental
Financial risks of insurance operations Europe’s insurance manufacturing company by type of contract,
and provides a view of the exposure to financial risk.
HSBC Continental Europe insurance businesses are exposed to a
range of financial risks which can be categorised into:
• market risk: risks arising from changes in the fair values of
financial assets or their future cash flows from fluctuations in
variables such as interest rates, foreign exchange rates and
equity prices;
Approximately 62 per cent of financial assets were invested in the subsidiary is exposed to market risk. In particular, when
debt securities at 31 December 2020, and 23 per cent invested in customers seek to surrender their policies when asset values are
equity securities. falling, assets may have to be sold at a loss to fund redemptions.
In life-linked insurance, the net premium is invested in a portfolio For unit-linked contracts, market risk is substantially borne by the
of assets. HSBC Assurances Vie (France) manages the financial policyholder, but market risk exposure typically remains as fees
risks of this product on behalf of the policyholders by holding earned for management are related to the market value of the
appropriate assets according to the type of contracts subscribed. linked assets.
Market risk of insurance operations Each insurance manufacturing subsidiary of the HSBC Group
manages market risk by using some or all of the following
Market risk arises when mismatches occur between product
techniques:
liabilities and the investment assets which back them. For
example, mismatches between asset and liability yields and • for products with DPF, adjusting bonus rates to manage the
maturities give rise to interest rate risk. liabilities to policyholders. The effect is that a significant portion
of the market risk is borne by the policyholder;
The main features of products manufactured by the Group’s
insurance manufacturing company which generate market risk, • structuring asset portfolios to support liability cash flows;
and the market risk to which these features expose the company, • using derivatives, to a limited extent, to protect against adverse
are discussed below. market movements or better match liability cash flows;
Long-term insurance or investment products may incorporate • periodically reviewing products identified as higher risk, which
benefits that are guaranteed. Interest rate risk arises to the extent contain investment guarantees and embedded optionality
that yields on the assets supporting guaranteed investment features linked to savings and investment products;
returns could be lower than the investment returns implied by the
guarantees payable to policyholders. • including features designed to mitigate market risk in new
products; and
The income from the insurance and investment contracts with
Discretionary Participation Features (‘DPF’) is primarily invested in • selling, to the extent possible, the investments whose risk is
bonds; a fraction is allocated to other asset classes in order to considered unacceptable.
provide customers with an enhanced potential yield. The The French insurance manufacturing company monitors market
subsidiaries holding such type of product portfolio are at risk of risks exposures against mandated limits regularly and reports
falling market prices when discretionary bonuses cannot be fully these quarterly to HSBC Group Insurance. Exposures are
taken into account. aggregated and reported on a quarterly basis to risk management
An increase in market volatility may also result in an increase in forums in HSBC Group Insurance.
the value of the guarantee granted to the insured.
Long-term insurance and investment products typically permit the
policyholder to surrender the policy at any time or to let it lapse.
When the surrender value is not linked to the value realised from
the sale of the associated supporting assets,
The variation of the PVIF sensitivity is mainly explained by the to the individual Country Chief Risk Officers to identity
evolution of the economic environment in 2020, namely the investments which may be at greater risk of future impairment.
decrease of the interest rates. The increase of the PVIF sensitivity
Credit quality
to Equity level is mainly due to the model evolutions, notably the
increase of the Equity risk premium. The following table presents an analysis of treasury bills, other
eligible bills and debt securities within the French insurance
Credit risk of insurance operations business by measures of credit quality. The five credit quality
Credit risk can give rise to losses through default and can lead to classifications are defined on page 108.
volatility in income statement and balance sheet figures through Only assets supporting liabilities under non-linked insurance,
movements in credit spreads. investment contracts and shareholders’ funds are included in the
Management of the French insurance manufacturing company is table, as financial risk on assets supporting linked liabilities is
responsible for the credit risk, quality and performance of their predominantly borne by the policyholder. 91 per cent of the assets
investment portfolios. The assessment of creditworthiness of included in the table are invested in investments rated as ‘Strong’
issuers and counterparties is based primarily upon the opinion of Treasury bills, other eligible bills and debt securities in the French
internationally recognised rating agencies and other publicly insurance manufacturing company.
available information.
Investment credit exposures are monitored against limits by the
local insurance manufacturing subsidiaries, and are aggregated
and reported to HSBC Group Insurance Credit Risk and HSBC
Group Credit Risk. Stress testing is performed by HSBC Group
Insurance on the investment credit exposures using credit spread
sensitivities and default probabilities.
A number of tools are used to manage and monitor credit risk.
These include a Credit Watch Report which contains a watch list
of investments with current credit concerns and is circulated
fortnightly to Senior Management in HSBC Group Insurance and
Treasury bills, other eligible bills and debt securities in the French insurance manufacturing company
31 Dec 2020
Strong Good/Satisfactory Total
€m €m €m
Financial assets designated at fair value 3,692 91 3,783
– treasury and other eligible bills — — —
– debt securities 3,692 91 3,783
Financial investments 10,398 1,333 11,731
– treasury and other eligible bills — — —
– debt securities 10,398 1,333 11,731
Total 14,090 1,424 15,514
Liquidity risk of insurance operations This is achieved, for example, by assuming new business or
renewals are lower, and surrenders or lapses are greater, than
Every quarter, HSBC Assurances Vie is required to complete and
expected.
submit liquidity risk reports to the HSBC Group Insurance for
collation and review. Liquidity risk is assessed in these reports by The following tables show the expected undiscounted cash flows
measuring changes in expected cumulative net cash flows under a for insurance contract liabilities. The remaining contractual
series of stress scenarios designed to determine the effect of maturity of investment contract liabilities is all undated as in most
reducing expected available liquidity and accelerating cash cases, policyholders have the option to terminate their contracts at
outflows. any time.
Insurance risk A principal risk faced by the HSBC French Insurance business is
that, over time, the costs of acquiring and administering a
Insurance risk is the risk, other than financial risk, of loss
contract, of claims and of benefits may exceed the aggregate
transferred from the holder of the insurance contract to the
amount of premiums received and investment income. The cost of
insurer. Insurance risk is principally measured in terms of liabilities
claims and benefits can be influenced by many factors, including
under the contracts.
mortality and morbidity experience, lapse and surrender rates.
The insurance risk profile of the HSBC French life insurance
manufacturing business has not changed materially during 2020
despite the increase in liabilities to policyholders on these
contracts to EUR 23.10 billion (2019: EUR 23.13 billion).
The following tables analyse the HSBC French insurance risk exposures by type of business.
1 Insurance contracts and investments contracts with discretionary participation features (‘DPF’) give policyholders the contractual right to receive,
as a supplement to their guaranteed benefits, additional benefits that are likely to be a significant portion of the total contractual benefits, but
whose amount or timing is contractually at the discretion of the Group. These additional benefits are contractually based on the performance of a
specific pool of contracts or assets, of the profit of the company issuing the contracts.
2 Non-linked insurance includes remaining non-life business.
3 Although investment contracts with DPF are financial investments, the Group continues to account for them as insurance contracts as permitted
by IFRS.
Consolidated financial
statements
Page
Consolidated income statement 165
Consolidated statement of comprehensive income 166
Consolidated balance sheet 167
Consolidated statement of cash flows 168
Consolidated statement of changes in equity 169
1 Included are the impact of EUR 500 million Non-Financial Assets impairment and EUR 4 million Goodwill impairment in 2020 (2019 : EUR 9
million Non-Financial Assets impairment and EUR 169 million Goodwill impairment).
2 At 31 December 2020 EUR 5.5 billion (2019: EUR 5.4 billion) was not available for use by HSBC Continental Europe and is related to mandatory
deposits at central banks.
Interest received was EUR 2,117 million (2019: EUR 2,281 million), interest paid was EUR 1,354 million (2019: EUR 1,347 million) and
dividends received EUR 2 million (2019: EUR 9 million).
Operating activities are representative of HSBC Continental Europe's product-generating activities.
Investment activities represent cash flows for the acquisition and disposal of interests in consolidated and non-consolidated businesses,
and property, plant and equipment and intangible assets.
Financing activities result from changes in financial structure transactions relating to equity and long-term borrowings.
Financial
assets at Merger
Called up Fair Value Cash reserve Total
share capital through flow Foreign and share- Non-
and share Other equity Retained OCI hedging exchange other holders’ controlling Total
premium instruments earnings reserve reserve reserve reserves equity interests equity
€m €m €m €m €m €m €m €m €m €m
At 1 Jan 2020 2,628 750 3,424 47 34 (27) 1,587 8,443 28 8,471
Profit/(loss) for the period — — (1,022) — — — — (1,022) (3) (1,025)
Other comprehensive income/(expense) (net
of tax) — — (11) 31 35 (20) — 35 — 35
– debt instruments at fair value through
other comprehensive income — — — 32 — — — 32 — 32
– equity instruments designated at fair
value through other comprehensive
income — — — (1) — — — (1) — (1)
– cash flow hedges — — — — 35 — — 35 — 35
– re-measurement of defined benefit asset/
liability — — (6) — — — — (6) — (6)
– changes in fair value of financial liabilities
designated at fair value due to movement
in own credit risk1 — — (5) — — — — (5) — (5)
– exchange differences — — — — — (20) — (20) — (20)
Total comprehensive income/(expense)
for the period — — (1,033) 31 35 (20) — (987) (3) (990)
– capital securities issued during the period — — — — — — — — — —
– dividends to shareholders2 — — (30) — — — — (30) — (30)
– net impact of equity-settled share-based
payments — — — — — — — — — —
– change in business combinations and
other movements — — 7 — — — 1 8 — 8
Total Other — — (23) — — — 1 (22) — (22)
At 31 Dec 2020 2,628 750 2,368 78 69 (47) 1,588 7,434 25 7,459
1 At 31 December 2020, the cumulative amount of change in fair value attributable to changes in own credit risk of financial liabilities designated at
fair value was a loss of EUR (62) million.
2 Dividends corresponds to coupon payment on other equity instrument (AT1 capital) amounting to EUR 30 million.
Financial
assets at Merger
Called up Fair Value Cash reserve Total
share capital through flow Foreign and share- Non-
and share Other equity Retained OCI hedging exchange other holders’ controlling Total
premium instruments earnings reserve reserve reserve reserves equity interests equity
€m €m €m €m €m €m €m €m €m €m
At 1 Jan 2019 842 500 3,647 29 (23) (27) 1,587 6,555 29 6,584
Profit/(loss) for the period (39) (39) — (39)
Other comprehensive income/(expense)
(net of tax) — — (129) 18 57 — — (54) — (54)
– debt instruments at fair value through
other comprehensive income — — — 18 — — — 18 — 18
– equity instruments designated at fair value
through other comprehensive income — — — — — — — —
– cash flow hedges — — — — 57 — — 57 — 57
– re-measurement of defined benefit asset/
liability — — (16) — — — — (16) — (16)
– changes in fair value of financial liabilities
designated at fair value due to movement
in own credit risk1 — — (113) — — — — (113) — (113)
– exchange differences and other — — — — — — — — — —
Total comprehensive income for the year — — (168) 18 57 — — (93) — (93)
– capital securities issued 1,786 250 — — — — — 2,036 — 2,036
– dividends to shareholders2 — — (21) — — — — (21) (1) (22)
– net impact of equity-settled share-based
payments — — 6 — — — — 6 — 6
– change in business combination and other
movements — — (40) — — — — (40) — (40)
Total Other 1,786 250 (55) — — — — 1,981 (1) 1,980
At 31 Dec 2019 2,628 750 3,424 47 34 (27) 1,587 8,443 28 8,471
1 At 31 December 2019, the cumulative amount of change in fair value attributable to changes in own credit risk of financial liabilities designated at
fair value was a loss of EUR (57) million.
2 Dividends corresponds to coupon payment on other equity instrument (AT1 capital) amounting to EUR 21 million.
The consolidated financial statements of HSBC Continental Europe are available upon request from the HSBC Continental Europe
registered office at 38 Avenue Kléber – 75116 Paris or on the websites www.hsbc.com and www.hsbc.fr.
These consolidated financial statements were approved by the Board of Directors on 23 February 2021.
1.1 Basis of preparation
(a) Compliance with International Financial Reporting Standards
The consolidated financial statements of HSBC Continental Europe have been prepared in accordance with International Financial
Reporting Standards ('IFRSs') as issued by the International Accounting Standards Board (‘IASB’), including interpretations issued by the
IFRS Interpretations Committee, and as endorsed by the European Union (‘EU’).
Standards adopted during the year ended 31 December 2020
Interest Rate Benchmark Reform – Phase 2: Amendments to IFRS 9, IAS 39, IFRS 7, IFRS 4 and IFRS 16 issued in August 2020 represents
the second phase of the IASB’s project on the effects of interest rate benchmark reform, addressing issues affecting financial statements
when changes are made to contractual cash flows and hedging relationships as a result of the reform.
Under these amendments, changes made to a financial instrument that are economically equivalent and required by interest rate
benchmark reform do not result in the derecognition or a change in the carrying amount of the financial instrument, but instead require
the effective interest rate to be updated to reflect the change in the interest rate benchmark. In addition, hedge accounting will not be
discontinued solely because of the replacement of the interest rate benchmark if the hedge meets other hedge accounting criteria.
These amendments apply from 1 January 2021 with early adoption permitted. HSBC has adopted the amendments from 1 January 2020
and has made the additional disclosures as required by the amendments. Further information is included in Note 14.
Other changes
In addition, HSBC has adopted a number of interpretations and amendments to standards, which have had an insignificant effect on the
consolidated financial statements of HSBC Continental Europe.
(b) Future accounting developments
Minor amendments to IFRSs
The IASB has not published any minor amendments effective from 1 January 2021 that are applicable to HSBC CE . However, the IASB
has published a number of minor amendments to IFRSs that are effective from 1 January 2022 and 1 January 2023. HSBC Continental
Europe expects they will have an insignificant effect, when adopted, on the consolidated financial statements.
New IFRS
IFRS 17 ‘Insurance Contracts’
IFRS 17 ‘Insurance Contracts’ was issued in May 2017, with amendments to the standard issued in June 2020. The standard sets out the
requirements that an entity should apply in accounting for insurance contracts it issues and reinsurance contracts it holds. Following the
amendments, IFRS 17 is effective from 1 January 2023. The Group is in the process of implementing IFRS 17. Industry practice and
interpretation of the standard are still developing. Therefore, the likely numerical impact of its implementation remains uncertain.
However, we have the following expectations as to the impact compared with the group’s current accounting policy for insurance
contracts, which is set out in policy 1.2(j) below:
• Under IFRS 17, there will be no PVIF asset recognised; rather the estimated future profit will be included in the measurement of the
Insurance contract liability as the contractual service margin (‘CSM’) and gradually recognised in revenue as services are provided
over the duration of the insurance contract. The PVIF asset will be eliminated to equity on transition, together with other adjustments
to assets and liabilities to reflect IFRS 17 measurement requirements and any consequential amendments to financial assets in the
scope of IFRS 9;
• IFRS 17 requires increased use of current market values in the measurement of insurance liabilities. Depending on the measurement
model, changes in market conditions for certain products (measured under the General Measurement Approach) are immediately
recognised in profit or loss, whilst for other products (measured under the Variable Fee Approach) they will be included in the
measurement of CSM;
• In accordance with IFRS 17, directly attributable costs will be included in the results of insurance services as profit is recognised over
the duration of insurance contracts and costs that are not directly attributable remain in operating expenses. This will result in a
reduction in operating expenses compared to the current accounting policy.
(c) Foreign currencies
The functional currency of HSBC Continental Europe is euros which is also the presentational currency of HSBC Continental Europe's
consolidated financial statements and, the presentational currency of the consolidated financial statements of the bank and the Group is
sterling.
Transactions in foreign currencies are recorded at the rate of exchange on the date of the transaction. Assets and liabilities denominated
in foreign currencies are translated at the rate of exchange at the balance sheet date except non-monetary assets and liabilities measured
at historical cost, which are translated using the rate of exchange at the initial transaction date. Exchange differences are included in
other comprehensive income or in the income statement depending on where the gain or loss on the underlying item is recognised.
In the consolidated financial statements, the assets and liabilities of branches, subsidiaries, joint ventures and associates whose
functional currency is not € are translated into the HSBC Continental Europe’s presentation currency at the rate of exchange at the
balance sheet date, while their results are translated into € at the average rates of exchange for the reporting period. Exchange
differences arising are recognised in other comprehensive income. On disposal of a foreign operation, exchange differences previously
recognised in other comprehensive income are reclassified to the income statement.
(d) Presentation of information
Certain disclosures required by IFRSs have been included in the audited sections of this Annual Report and Accounts 2020 as follows:
• disclosures concerning the nature and extent of risks relating to financial instruments and insurance contracts are included in the
‘Risk’ section on pages 80 to 163;
• the 'Own funds' disclosure included in the ‘Capital and leverage management’ section on page 131.
(e) Critical accounting estimates and judgements
The preparation of financial information requires the use of estimates and judgements about future conditions. In view of the inherent
uncertainties and the high level of subjectivity involved in the recognition or measurement of items highlighted, as the 'critical accounting
estimates and judgements' in section 1.2 below, it is possible that the outcomes in the next financial year could differ from those on
which management’s estimates are based. This could result in materially different estimates and judgements from those reached by
management for the purposes of these financial statements. Management’s selection of the group’s accounting policies that contain
critical estimates and judgements reflects the materiality of the items to which the policies are applied and the high degree of judgement
and estimation uncertainty involved.
(f) Segmental analysis
HSBC Continental Europe chief operating decision maker is the Chief Executive, supported by the Chief Executive deputies and the
Executive Committee. Operating segments are reported in a manner consistent with the internal reporting.
Measurement of segmental assets, liabilities, income and expenses is in accordance with HSBC Continental Europe’s accounting policies.
Segmental income and expenses include transfers between segments and these transfers are conducted on arm’s length. Shared costs
are included in segments on the basis of the actual recharges made.
(g) Going concern
The financial statements are prepared on a going concern basis, as the Directors are satisfied that HSBC Continental Europe and parent
company have the resources to continue in business for the foreseeable future. In making this assessment, the Directors have considered
a wide range of information relating to present and future conditions, including future projections of profitability, cash flows, capital
requirements and capital resources. These considerations include stressed scenarios that reflect the increasing uncertainty that the global
Covid-19 pandemic has had on HSBC Continental Europe’s operations, as well as considering potential impacts from other top and
emerging risks, and the related impact on profitability, capital and liquidity.
Goodwill
Goodwill is allocated to cash-generating units (‘CGUs’) for the purpose of impairment testing, which is undertaken at the lowest level at
which goodwill is monitored for internal management purposes. HSBC Continental Europe's CGUs are the global businesses within
principal operating entities. Impairment testing is performed once a year, or whenever there is an indication of impairment, by comparing
the recoverable amount of a CGU with its carrying amount.
Goodwill is included in a disposal group if the disposal group is a CGU to which goodwill has been allocated or it is an operation within
such a CGU.
Where HSBC Continental Europe offers a package of services that contains multiple non-distinct performance obligations, such as those
included in account service packages, the promised services are treated as a single performance obligation. If a package of services
contains distinct performance obligations, such as those including both account and insurance services, the corresponding transaction
price is allocated to each performance obligation based on the estimated stand-alone selling prices.
Dividend income is recognised when the right to receive payment is established. This is the ex-dividend date for listed equity securities,
and usually the date when shareholders approve the dividend for unlisted equity securities.
Net income/(expense) from financial instruments measured at fair value through profit or loss includes the following:
• ‘Net income from financial instruments held for trading or managed on a fair value basis’: This comprises net trading income, which
includes all gains and losses from changes in the fair value of financial assets and financial liabilities held for trading and other
financial instruments managed on a fair value basis, together with the related interest income, expense and dividends, excluding the
effect of changes in the credit risk of liabilities managed on a fair value basis. It also includes all gains and losses from changes in the
fair value of derivatives that are managed in conjunction with financial assets and liabilities measured at fair value through profit or
loss.
• ‘Net income/(expense) from assets and liabilities of insurance businesses, including related derivatives, measured at fair value through
profit or loss’. This includes interest income, interest expense and dividend income in respect of financial assets and liabilities
measured at fair value through profit or loss; and those derivatives managed in conjunction with the above which can be separately
identifiable from other trading derivatives.
• ‘Changes in fair value of designated debt instruments and related derivatives’: Interest paid on the debt instruments and interest cash
flows on related derivatives is presented in interest expense where doing so reduces an accounting mismatch.
• ‘Changes in fair value of other financial instruments mandatorily measured at fair value through profit or loss’. This includes interest
on instruments which fail the SPPI test. See (d) below.
The accounting policies for insurance premium income are disclosed in Note 4.
(c) Valuation of financial instruments
All financial instruments are initially recognised at fair value. Fair value is the price that would be received to sell an asset or paid to
transfer a liability in an orderly transaction between market participants at the measurement date. The fair value of a financial instrument
on initial recognition is generally its transaction price (that is, the fair value of the consideration given or received). However, if there is a
difference between the transaction price and the fair value of financial instruments whose fair value is based on a quoted price in an
active market or a valuation technique that uses only data from observable markets, HSBC Continental Europe recognises the difference
as a trading gain or loss at inception (a ‘day 1 gain or loss’). In all other cases, the entire day 1 gain or loss is deferred and recognised in
the income statement over the life of the transaction either until the transaction matures or is closed out or the valuation inputs become
observable.
The fair value of financial instruments is generally measured on an individual basis. However, in cases where HSBC Continental Europe
manages a group of financial assets and liabilities according to its net market or credit risk exposure, the fair value of the group of
financial instruments is measured on a net basis but the underlying financial assets and liabilities are presented separately in the financial
statements, unless they satisfy the IFRS offsetting criteria. Financial instruments are classified into one of three fair value hierarchy levels,
described in Note 11, ‘Fair values of financial instruments carried at fair value'.
Critical accounting estimates and judgements
The majority of valuation techniques employ only observable market data. However, certain financial instruments are classified on the basis of valuation
techniques that feature one or more significant market inputs that are unobservable, and for them, the measurement of fair value is more judgemental:
Judgements Estimates
• An instrument in its entirety is classified as valued using significant • Details on HSBC Continental Europe’s level 3 financial instruments and
unobservable inputs if, in the opinion of management, a significant the sensitivity of their valuation to the effect of applying reasonable
proportion of the instrument’s inception profit or greater than 5 per cent possible alternative assumptions in determining their fair value are set out
of the instrument’s valuation is driven by unobservable inputs. in Note 11.
• Unobservable’ in this context means that there is little or no current
market data available from which to determine the price at which an
arm’s length transaction would be likely to occur. It generally does not
mean that there is no data available at all upon which to base a
determination of fair value (consensus pricing data may, for example, be
used).
Hedge accounting
When derivatives are not part of fair value designated relationships, if held for risk management purposes they are designated in hedge
accounting relationships where the required criteria for documentation and hedge effectiveness are met. HSBC Continental Europe uses
these derivatives or, where allowed, other non-derivative hedging instruments in fair value hedges, cash flow hedges or hedges of net
investments in foreign operations as appropriate to the risk being hedged.
Fair value hedge
Fair value hedge accounting does not change the recording of gains and losses on derivatives and other hedging instruments, but results
in recognising changes in the fair value of the hedged assets or liabilities attributable to the hedged risk that would not otherwise be
recognised in the income statement. If a hedge relationship no longer meets the criteria for hedge accounting, hedge accounting is
discontinued; the cumulative adjustment to the carrying amount of the hedged item is amortised to the income statement on a
recalculated effective interest rate, unless the hedged item has been derecognised, in which case it is recognised in the income
statement immediately.
Cash flow hedge
The effective portion of gains and losses on hedging instruments is recognised in other comprehensive income; the ineffective portion of
the change in fair value of derivative hedging instruments that are part of a cash flow hedge relationship is recognised immediately in the
income statement within ‘Net trading income’. The accumulated gains and losses recognised in other comprehensive income are
reclassified to the income statement in the same periods in which the hedged item affects profit or loss. When a hedge relationship is
discontinued, or partially discontinued, any cumulative gain or loss recognised in other comprehensive income remains in equity until the
forecast transaction is recognised in the income statement. When a forecast transaction is no longer expected to occur, the cumulative
gain or loss previously recognised in other comprehensive income is immediately reclassified to the income statement.
Derivatives that do not qualify for hedge accounting
Non-qualifying hedges are derivatives entered into as economic hedges of assets and liabilities for which hedge accounting was not
applied.
(i) Impairment of amortised cost and FVOCI financial assets
Expected credit losses are recognised for loans and advances to banks and customers, non-trading reverse repurchase agreements, other
financial assets held at amortised cost, debt instruments measured at fair value through other comprehensive income, and certain loan
commitments and financial guarantee contracts. At initial recognition, allowance (or provision in the case of some loan commitments and
financial guarantees) is required for ECL resulting from default events that are possible within the next 12 months (or less, where the
remaining life is less than 12 months) (’12-month ECL’). In the event of a significant increase in credit risk, allowance (or provision) is
required for ECL resulting from all possible default events over the expected life of the financial instrument (‘lifetime ECL’). Financial
assets where 12-month ECL is recognised are considered to be ‘stage 1’; financial assets which are considered to have experienced a
significant increase in credit risk are in ‘stage 2’; and financial assets for which there is objective evidence of impairment so are
considered to be in default or otherwise credit-impaired are in ‘stage 3’. Purchased or originated credit-impaired financial assets ('POCI')
are treated differently as set out below.
Credit-impaired (stage 3)
HSBC Continental Europe determines that a financial instrument is credit-impaired and in stage 3 by considering relevant objective
evidence, primarily whether:
• contractual payments of either principal or interest are past due for more than 90 days;
• there are other indications that the borrower is unlikely to pay such as when a concession has been granted to the borrower for
economic or legal reasons relating to the borrower’s financial condition; and
• the loan is otherwise considered to be in default.
If such unlikeliness to pay is not identified at an earlier stage, it is deemed to occur when an exposure is 90 days past due, even where
regulatory rules permit default to be defined based on 180 days past due. Therefore the definitions of credit-impaired and default are
aligned as far as possible so that stage 3 represents all loans which are considered defaulted or otherwise credit-impaired.
For doubtful exposures, interest income is recognised by applying the effective interest rate to the amortised cost amount, i.e. gross
carrying amount less ECL allowance.
Write-off
Financial assets (and the related impairment allowances) are normally written off, either partially or in full, when there is no realistic
prospect of recovery. Where loans are secured, this is generally after receipt of any proceeds from the realisation of security. In
circumstances where the net realisable value of any collateral has been determined and there is no reasonable expectation of further
recovery, write-off may be earlier.
Renegotiation
Loans are identified as renegotiated and classified as credit-impaired when we modify the contractual payment terms due to significant
credit distress of the borrower. Renegotiated loans remain classified as credit-impaired until there is sufficient evidence to demonstrate a
significant reduction in the risk of non-payment of future cash flows and retain the designation of renegotiated until maturity or
derecognition.
A loan that is renegotiated is derecognised if the existing agreement is cancelled and a new agreement is made on substantially different
terms or if the terms of an existing agreement are modified such that the renegotiated loan is a substantially different financial
instrument. Any new loans that arise following derecognition events in these
For CRRs greater than 3.3 which are not impaired, a significant increase in credit risk is considered to have occurred when the origination
PD has doubled. The significance of changes in PD was informed by expert credit risk judgement, referenced to historical credit
migrations and to relative changes in external market rates.
For loans originated prior to the implementation of IFRS 9, the origination PD does not include adjustments to reflect expectations of
future macroeconomic conditions since these are not available without the use of hindsight. In the absence of this data, origination PD
must be approximated assuming through-the-cycle (‘TTC’) PDs and TTC migration probabilities, consistent with the instrument’s
underlying modelling approach and the CRR at origination. For these loans, the quantitative comparison is supplemented with additional
CRR deterioration based thresholds as set out in the table below:
Further information about the 23-grade scale used for CRR can be found on page 108.
For certain portfolios of debt securities where external market ratings are available and credit ratings are not used in credit risk
management, the debt securities will be in stage 2 if their credit risk increases to the extent they are no longer considered investment
grade. Investment grade is where the financial instrument has a low risk of incurring losses, the structure has a strong capacity to meet
its contractual cash flow obligations in the near term and adverse changes in economic and business conditions in the longer term may,
but will not necessarily, reduce the ability of the borrower to fulfil their contractual cash flow obligations.
For retail portfolios, default risk is assessed using a reporting date 12-month PD derived from credit scores which incorporate all available
information about the customer. This PD is adjusted for the effect of macroeconomic forecasts for periods longer than 12 months and is
considered to be a reasonable approximation of a lifetime PD measure. Retail exposures are first segmented into homogeneous
portfolios, generally by country, product and brand. Within each portfolio, the stage 2 accounts are defined as
accounts with an adjusted 12-month PD greater than the average 12-month PD of loans in that portfolio 12 months before they become
30 days past due. The expert credit risk judgement is that no prior increase in credit risk is significant. This portfolio-specific threshold
identifies loans with a PD higher than would be expected from loans that are performing as originally expected and higher than that
which would have been acceptable at origination. It therefore approximates a comparison of origination to reporting date PDs.
Unimpaired and without significant increase in credit risk – (stage 1)
ECL resulting from default events that are possible within the next 12 months (’12-month ECL’) are recognised for financial instruments
that remain in stage 1.
Purchased or originated credit-impaired
Financial assets that are purchased or originated at a deep discount that reflects the incurred credit losses are considered to be POCI.
This population includes the recognition of a new financial instrument following a renegotiation where concessions have been granted
for economic or contractual reasons relating to the borrower’s financial difficulty that otherwise would not have been considered. The
amount of change-in-lifetime ECL is recognised in profit or loss until the POCI is derecognised, even if the lifetime ECL are less than the
amount of ECL included in the estimated cash flows on initial recognition.
Movement between stages
Financial assets can be transferred between the different categories (other than POCI) depending on their relative increase in credit risk
since initial recognition. Financial instruments are transferred out of stage 2 if their credit risk is no longer considered to be significantly
increased since initial recognition based on the assessments described above. Except for renegotiated loans, financial instruments are
transferred out of stage 3 when they no longer exhibit any evidence of credit impairment as described above. Renegotiated loans that are
not POCI will continue to be in stage 3 until there is sufficient evidence to demonstrate a significant reduction in the risk of non-payment
of future cash flows, observed over a minimum one-year period and there are no other indicators of impairment. For loans that are
assessed for impairment on a portfolio basis, the evidence typically comprises a history of payment performance against the original or
revised terms, as appropriate to the circumstances. For loans that are assessed for impairment on an individual basis, all available
evidence is assessed on a case-by-case basis.
Measurement of ECL
The assessment of credit risk, and the estimation of ECL, are unbiased and probability-weighted, and incorporate all available information
which is relevant to the assessment including information about past events, current conditions and reasonable and supportable
forecasts of future events and economic conditions at the reporting date. In addition, the estimation of ECL should take into account the
time value of money.
In general, HSBC Continental Europe calculates ECL using three main components, a probability of default, a loss given default ('LGD")
and the exposure at default (‘EAD’).
The 12-month ECL is calculated by multiplying the 12-month PD, LGD and EAD. Lifetime ECL is calculated using the lifetime PD instead.
The 12-month and lifetime PDs represent the probability of default occurring over the next 12 months and the remaining maturity of the
instrument respectively.
The EAD represents the expected balance at default, taking into account the repayment of principal and interest from the balance sheet
date to the default event together with any expected drawdowns of committed facilities. The LGD represents expected losses on the EAD
given the event of default, taking into account, among other attributes, the mitigating effect of collateral value at the time it is expected
to be realised and the time value of money.
HSBC Continental Europe leverages the Basel II IRB framework where possible, with recalibration to meet the differing IFRS 9
requirements as follows.
Model Regulatory capital IFRS 9
PD • Through the cycle (represents long-run average PD throughout a • Point in time (based on current conditions, adjusted to take into
full economic cycle) account estimates of future conditions that will impact PD)
• The definition of default includes a backstop of 90+ days past • Default backstop of 90+ days past due for all portfolios
due, although this has been modified to 180+ days past due for
some portfolios, particularly UK and US mortgages
EAD • Cannot be lower than current balance • Amortisation captured for term products
LGD • Downturn LGD (consistent losses expected to be suffered during • Expected LGD (based on estimate of loss given default including
a severe but plausible economic downturn) the expected impact of future economic conditions such as
• Regulatory floors may apply to mitigate risk of underestimating changes in value of collateral)
downturn LGD due to lack of historical data • No floors
• Discounted using cost of capital • Discounted using the original effective interest rate of the loan
• All collection costs included • Only costs associated with obtaining/selling collateral included
Other • Discounted back from point of default to balance sheet date
While 12-month PDs are recalibrated from Basel models where possible, the lifetime PDs are determined by projecting the 12-month PD
using a term structure. For the wholesale methodology, the lifetime PD also takes into account credit migration, i.e. a customer migrating
through the CRR bands over its life.
The ECL for wholesale stage 3 is determined on an individual basis using a discounted cash flow (‘DCF’) methodology. The expected
future cash flows are based on the credit risk officer’s estimates as at the reporting date, reflecting reasonable and supportable
assumptions and projections of future recoveries and expected future receipts of interest. Collateral is taken into account if it is likely that
the recovery of the outstanding amount will include realisation of collateral based on its estimated fair value of collateral at the time of
expected realisation, less costs for obtaining and selling the collateral. The cash flows are discounted at a reasonable approximation of
the original effective interest rate. For significant cases, cash flows under four different scenarios are probability-weighted by reference to
the three economic scenarios applied more generally by the Group and the judgement of the credit risk officer in relation to the likelihood
of the workout strategy succeeding or receivership being required. For less significant cases, the effect of different economic scenarios
and work-out strategies is approximated and applied as an adjustment to the most likely outcome.
Non-financial assets are generally not used in isolation to generate cash flows that are independent from other assets. Therefore, the VIU
of the non-financial assets depends on the VIU of the CGUs in which they are recorded. In addition, some non-financial assets do not
have their own FVLCOD, such as software (including software under development). Therefore, they rely solely on the recoverable amount
of the CGU where they are recorded.
Capitalisation of new non-financial assets when the CGU is impaired
For tangible and intangible assets that do not have their own recoverable amount, the future economic benefits will flow to the entity
only through usage via the CGU. When the CGU is impaired, newly acquired tangible and intangible assets are recognised only if these
assets have a recoverable amount at the individual asset level. These assets will be recognised and impaired down to their respective
recoverable amount subsequent to initial recognition. When the CGU is no longer impaired on a future date, previously recognised
impairment could be reversed. When the CGU is impaired, new acquisition of tangible and intangible assets without recoverable amount
at the individual asset level will be expensed immediately.
(o) Government grants
Government grants are assistance by government in the form of transfers of resources to an entity in return for past or future compliance
with certain conditions relating to the operating activities of the entity. The benefit of a government loan at a below market rate of
interest is treated as a government grant. The benefit of the below-market rate of interest is measured as the difference between the
initial carrying value of the loan recognised and the proceeds received. When identifying the costs for which the benefit of the loan is
intended to compensate, the conditions and obligations that have been, or must be, met are considered. Government grants are
recognised when there is reasonable assurance that the conditions attached with them will be complied with and that the grants will be
received. Government grants are recognised in profit or loss on a systematic basis over the periods in which the entity recognise as
expense the related costs for which the grants are intended to compensate.
Critical accounting estimates and judgements
JUDGEMENTS
• Determining whether there is reasonable assurance that the conditions attached with government grants will be complied with and that the grants will
be received.
1 The line ‘Other’ includes mainly analytical reallocations amongst business lines, HSBC inter-company fees, some inter-bank fees and various other
fees.
2 A change in reportable segments was made during 2020. Comparative data have been re-presented accordingly.
Net fee income includes EUR 495 million of fees earned on financial assets that are not at fair value through profit or loss (other than
amounts included in determining the effective interest rate) (2019: EUR 533 million), EUR 121 million of fees payable on financial
liabilities that are not at fair value through profit of loss (other than amounts included in determining the effective interest rate)
(2019: EUR 168 million), EUR 215 million of fees earned on trust and other fiduciary activities (2019: EUR 215 million).
3 Net income/(expense) from financial instruments measured at fair value through profit or
loss
2020 2019
€m €m
Net income/(expense) arising on:
Net trading activities 283 554
Other instruments designated and mandatorily measured at fair value and related derivatives (211) (524)
Net income/(expense) from financial instruments held for trading or managed on a fair value basis 72 30
Financial assets held to meet liabilities under insurance and investment contracts 161 1,280
Liabilities to customers under investment contracts — (3)
Net income/(expense) from assets and liabilities of insurance businesses, including related derivatives, measured at
fair value through profit or loss 161 1,277
Derivatives managed in conjunction with HSBC Continental Europe’s issued debt securities 59 47
Other changes in fair value (63) (48)
Changes in fair value of designated debt and related derivatives (4) (1)
Changes in fair value of other financial instruments mandatorily measured at fair value through profit or loss 87 153
Year ended 31 Dec 316 1,459
4 Insurance business
Through its insurance subsidiary, HSBC Continental Europe issues contracts to customers that contain insurance risk, financial risk or a
combination thereof. A contract under which HSBC Continental Europe accepts significant insurance risk from another party by agreeing
to compensate that party on the occurrence of a specified uncertain future event is classified as an insurance contract. An insurance
contract may also transfer financial risk, but is accounted for as an insurance contract if the insurance risk is significant.
While investment contracts with discretionary participation features are financial instruments, they continue to be treated as insurance
contracts as permitted by IFRS 4.
Insurance contracts are accounted for as follows:
Insurance premiums
Premiums for life insurance contracts are accounted for when receivable, except in unit-linked insurance contracts where premiums are
accounted for when liabilities are established.
Reinsurance premiums are accounted for in the same accounting period as the premiums for the direct insurance contracts to which they
relate.
Net insurance claims and benefits paid and movement in liabilities to policyholders
Non-linked Linked-life Investment
insurance insurance contracts with DPF Total
€m €m €m €m
Gross claims and benefits paid incurred and movement in liabilities 15 1 1,555 1,571
– claims, benefits and surrenders paid 15 2 1,748 1,766
– movement in liabilities — (1) (193) (194)
Reinsurers’ share of claims incurred and benefits paid and movement in liabilities — — — —
– claims, benefits and surrenders paid — — — —
– movement in liabilities — — — —
Year ended 31 Dec 2020 15 1 1,555 1,571
Gross claims and benefits paid incurred and movement in liabilities 25 — 3,356 3,381
– claims, benefits and surrenders paid 19 2 1,698 1,719
– movement in liabilities 6 (2) 1,658 1,662
Reinsurers’ share of claims incurred and benefits paid and movement in liabilities (1) — — (1)
– claims, benefits and surrenders paid — — — —
– movement in liabilities (1) — — (1)
Year ended 31 Dec 2019 24 — 3,356 3,380
Gross liabilities under insurance contracts at 1 Jan 2019 121 33 21,181 21,335
Claims and benefits paid (19) (2) (1,698) (1,719)
Increase in liabilities to policyholders 25 — 3,356 3,381
Exchange differences and other movements1 (1) 3 293 295
Gross liabilities under insurance contracts at 31 Dec 2019 126 34 23,132 23,292
Reinsurers’ share of liabilities under insurance contracts (2) — — (2)
Net liabilities under insurance contracts at 31 Dec 2019 124 34 23,132 23,290
1 ‘Exchange differences and other movements’ includes movements in liabilities arising from net unrealised investment gains recognised in other
comprehensive income.
The key factors contributing to the movement in liabilities to policyholders included death claims, surrenders, lapses, liabilities to
policyholders created at the initial inception of the policies, the declaration of bonuses and other amounts attributable to policyholders.
1 Includes restructuring provision of EUR 278 million in 2020 (refer Note 1.3).
2 Includes reversal of pension indemnity provision of EUR 21 million in 2020 related to restructuring plans.
3 This amount includes re-invoicing of the staff costs to and from the HSBC Group.
Average number of persons employed by HSBC Continental Europe during the year by global business
2020 2019
Wealth and Personal Banking1 4,155 4,195
Commercial Banking 1,652 1,704
Global Banking and Markets 1,145 1,020
Corporate Centre 14 14
Support functions and others2 2,651 2,919
Year ended 31 Dec 3 9,617 9,852
1 A change in reportable segments was made during 2020. Comparative data have been re-presented accordingly.
2 Including pre-retirement (CFCS) and expatriates.
3 Permanent contracts (CDI) and fixed terms contracts (CDD) within HSBC Continental Europe (including the European branches) and its
subsidiaries HSBC Global Asset Management (France) and HSBC Assurances Vie (France).
Share-based payments
Share Group policy
In 2005, the HSBC Group significantly revised its employee share option and share policy.
The rules of share option and share plans were approved by its Annual General Meeting held in May 2005. These rules include a French
sub-plan (Schedule 3 of the general rule), which complies with the legal and tax regulations applicable in France. This regulation was
revised in 2011 firstly to take into account the regulatory changes impacting the plan and, secondly, to formalise the rules of the ‘Group
Performance Share Plan’, for the HSBC Group’s Senior Executives. In this context, the French sub-plan (Schedule 5 of the new rules) has
also been subjected to a review, to comply with local social and tax rules. Since 2006, the general policy of the HSBC Group is to award
shares instead of share options (except in the case of a country specific legal and tax regulation).
The shares can be:
• ‘Group Performance Shares’ subject to performance conditions;
• ‘Restricted Shares’ without performance conditions.
•
Movement on 'Group Performance Shares'
This category of shares is available, after a vesting period of five years, at the retirement date.
1 The weighted average fair value of shares granted during the year was EUR 6.73 (2019: EUR 7.15).
2 The weighted average share price at the date the shares were exercised was EUR 6.05 (2019: EUR 7.29).
3 Corresponds to the shares granted to Group employees who joined HSBC Continental Europe during previous years net of shares granted to
HSBC Continental Europe employees who joined other Group entities.
In 2020, EUR (9) million was charged to the income statement in respect of amortisation of the existing plans for HSBC in France (in
2019: EUR (11) million).
The vesting period for deferred share awards expected to be granted in 2020, in respect of the 2019 performance year, was determined
to have started on 1 January 2019.
Employee share offering
In 2020, HSBC Continental Europe did not proceed to any capital increase opened to current employees.
HSBC Continental Europe recognises actuarial gains and losses directly in equity, without being recognised in income. Past service costs
are immediately recognised. The current service costs and any past service costs, together with the expected return on scheme assets
less the unwinding of the discount on the scheme liabilities, are charged to operating expenses.
The net defined benefit liability recognised in the balance sheet related to post-employment benefits recognised represents the present
value of the defined benefit obligations reduced by the fair value of plan assets.
Payments to defined contribution plans and state-managed retirement benefit plans, where HSBC Continental Europe obligations under
the plans are equivalent to a defined contribution plan, are charged as an expense as they fall due.
Post-employment defined benefit plans’ principal actuarial assumptions
The principal actuarial financial assumptions used to calculate the defined benefit pension plans at 31 December 2020, and the 2020
periodic costs, were:
1 The rate of increase for pensions and deferred pensions is 0.40 per cent in 2021 and back to 1.50 per cent after 2021.
HSBC Continental Europe determines discount rates, in consultation with its actuary based upon the current average yield of high quality
(AA rated or equivalent) debt instruments, with maturities consistent with that of the defined benefit obligations.
Mortality tables and average life expectancy at age 60 for the principal plan
Net assets/(liabilities) recognised on the balance sheet in respect of defined benefit plans
Present value of Effect of
Fair value of defined benefit limit on plan
plan assets obligations surpluses Total
€m €m €m €m
Defined benefit pension plans 6 181 — 175
Defined benefit healthcare plans — — — —
At 31 Dec 2020 6 181 — 175
Total employee benefit liabilities (within ‘Accruals, deferred income and other liabilities’) 175
Total employee benefit assets (within ‘Prepayments, accrued income and other assets’) —
Actuarial gains and losses of the year are composed of EUR 5 millions due to actuarial assumptions' changes attributed to the decrease
of the discount rate from 0.65 per cent to 0.40 per cent, and to changes in life expectancy assumptions with an impact of EUR (1) million.
1 This amount corresponds to transfer of employees from HSBC Bank plc Paris Branch to HSBC Continental Europe.
2 This amount corresponds to changes in the perimeter during the year.
Benefits expected to be paid from the plans to retirees over each of the next five years, and in aggregate for the five years thereafter, are
as follows:
1 The duration of the defined benefit obligation is 13 years for the principal plan under the disclosure assumptions adopted (2019: 13 years) and
13 years for all other plans combined (2019: 13 years).
6 Auditors’ remuneration
1 This Note is prepared in compliance with ANC regulation 2016-08, 2016-09, 2016-10 and 2016-11 and includes only the fees paid to
PricewaterhouseCoopers Audit France and BDO Paris Audit & Advisory (2019 figures have been re-presented accordingly).
Services other than the account certification at 31 December 2020 for PricewaterhouseCoopers Audit France and BDO Paris Audit &
Advisory mainly concern comfort letters related to the programmes of issuances and interim dividends, legal or regulatory services and
also services related to internal control procedures (i.e. report ISAE 3402).
7 Tax
Tax expense
2020 2019
€m €m
Current tax 52 45
Deferred tax 28 (28)
Year ended 31 Dec 80 17
HSBC Continental Europe's profits are taxed at different rates depending on the country in which the profits arise. The key applicable
corporate tax rates concerns France.
The 2020 Finances Law (‘Loi de Finances’) has reviewed the gradual decrease of the corporate tax rate from 33 1/3 in 2019 to 25 per cent
in 2022.
The social contribution on profit (CSB at 3.3 per cent of the income tax) is maintained and is added to the income tax.
As a consequence, at French Tax group level, in 2020, France’s tax rate is 32.02 per cent (2019: 34.43 per cent).
Other overseas subsidiaries and branches provide for taxation at the appropriate rates in the countries in which they operate.
In application of the standard IAS 12, at each deferred tax basis, assumptions of date of recovery were taken to determine these deferred
tax rate to apply to take into account the French tax rate decrease from 33 1/3 to 25 per cent.
Considering the recent losses incurred and the wider context of uncertainty, it was judged that the net deferred tax asset (’DTA‘) should
be written off and no further net DTA should be recognised. Recognition will be reassessed at each balance sheet date.
The increase of the tax expense between 2019 and 2020 is mainly due to the write-off in 2020 of net deferred tax asset recognised in
December 2019.
Tax risks
In 2018, HSBC Leasing (France) incurred a tax audit for the years 2015 and 2016, the tax audit has continued in 2019 and 2020 for years
2017 and 2018. In the frame of these tax audits, the French tax authorities have reassessed the tax treatment of provisions related to
some aircraft leasing transactions.
HSBC Leasing (France) disputed the reassessments with the French tax authorities.
A provision corresponding to the best estimate of the risk has been recorded at 31 December 2018 and is periodically reassessed at each
balance sheet date.
The effective tax rate for 2020 of (8.4) per cent whereas French current tax rate is 32.02 per cent is explained mainly by non-recognition
of net deferred tax asset as of 31 December 2020 and permanent disallowables (of which the impact of the non-deductible Single
Resolution Fund contribution).
1 Deferred tax in 'Other' includes essentially deferred tax assets from Mark-to-Market on issuances of Covered Bonds and Derivatives and deferred
tax liabilities on PVIF. Non-recognised Deferred Tax Assets has been apportioned to the categories ‘retirement benefits’, ‘goodwill and intangibles’
and ‘others’.
2 After netting off balances within entities, the balances as disclosed in the accounts are as follows: deferred tax assets EUR 131 million
(2019: EUR 229 million); and deferred tax liabilities EUR (131) million (2019: EUR (175) million).
CVAE
Since 2010, the French Tax ‘taxe professionnelle’ was replaced by a new tax 'contribution économique territoriale' (‘CET’) composed of
the 'cotisation foncière des entreprises' (‘CFE’) based on the rental value of taxable property, and the ‘cotisation sur la valeur ajoutée des
entreprises' (‘CVAE’) corresponding to 1.54 per cent of added-value of the year.
HSBC Continental Europe has treated the CVAE as income tax, in application of IAS 12. Deferred CVAE contributions are accounted for
on the basis of temporary differences between the book value of assets and liabilities and their tax value from a CVAE standpoint.
Since 2014, the CVAE contribution is included in ‘Income Tax’. In 2020, the impact of this accounting position was a classification of a
charge of EUR 12.3 million (2019: EUR 16.7 million) on the ‘Income Tax’ and the recognition of a deferred tax charge of EUR 0.3 million
(2019: profit EUR 3 million).
8 Dividends
1 Coupons paid on other equity instruments are not included in the calculation of the dividends per share.
1 Discretionary coupons are paid semi-annually on the perpetual subordinated capital instruments.
Basic earnings per ordinary share were calculated by dividing the basic earnings of EUR (1,022) million by the weighted average number
of ordinary shares outstanding during the year, excluding own shares held, of 98,231,196 (full year 2019: earnings of EUR (39) million and
92,571,906 weighted average number of shares).
Diluted earnings per share were calculated by dividing the basic earnings, which require no adjustment for the dilutive of potential
ordinary shares (including share options outstanding not yet exercised), by the weighted average number of ordinary shares outstanding,
excluding own shares held, plus the weighted average number of ordinary shares that would be issued on ordinary conversion of all the
potential dilutive ordinary shares of 98,231,196 (full year 2019: 92,571,906 shares). At 31 December 2020, no potentially dilutive ordinary
share had been issued.
2020 2019
€m €m
Treasury and other eligible bills 853 1,427
Debt securities 12,001 13,409
Equity securities — —
Trading securities 12,854 14,836
Loans and advances to banks 27 1
Loans and advances to customers 73 —
Year-ended 31 Dec 12,954 14,837
Control framework
Fair values are subject to a control framework designed to ensure that they are either determined, or validated, by a function independent
of the risk taker.
For all financial instruments where fair values are determined by reference to externally quoted prices or observable pricing inputs to
models, independent price determination or validation is utilised. In inactive markets, we source alternative market information to
validate the financial instrument’s fair value, with greater weight given to information that is considered to be more relevant and reliable.
The factors that are considered in this regard are, inter alia:
• the extent to which prices may be expected to represent genuine traded or tradeable prices;
• the degree of similarity between financial instruments;
• the degree of consistency between different sources;
• the process followed by the pricing provider to derive the data;
• the elapsed time between the date to which the market data relates and the balance sheet date;
• the manner in which the data was sourced.
For fair values determined using valuation models, the control framework may include, as applicable, development or validation by
independent support function of: (i) the logic within valuation models; (ii) the inputs to these models; (iii) any adjustments required
outside the valuation models; and (iv) where possible, model outputs.
Valuation models are subject to a process of due diligence and calibration before becoming operational and are calibrated against
external market data on an ongoing basis.
Financial liabilities measured at fair value
In certain circumstances, HSBC Continental Europe records its own debt in issue at fair value, based on quoted prices in an active market
for the specific instrument. When quoted market prices are unavailable, the own debt in issue is valued using valuation techniques, the
inputs for which are based either on quoted prices in an inactive market for the instrument or are estimated by comparison with quoted
prices in an active market for similar instruments. In both cases, the fair value includes the effect of applying the credit spread that is
appropriate to the HSBC Continental Europe's liabilities.
Structured notes issued and certain other hybrid instruments are included within trading liabilities and are measured at fair value.The
spread applied to these instruments is derived from the spreads at which HSBC Continental Europe issues structured notes.
Fair value hierarchy
Fair values of financial assets and liabilities are determined according to the following hierarchy:
• Level 1 – Valuation technique using quoted market price: financial instruments with quoted prices for identical instruments in active
markets that HSBC Continental Europe can access at the measurement date.
• Level 2 – Valuation technique using observable inputs: financial instruments with quoted prices for similar instruments in active
markets or quoted prices for identical or similar instruments in inactive markets and financial instruments valued using models where
all significant inputs are observable.
• Level 3 – Valuation technique with significant unobservable inputs: financial instruments valued using valuation techniques where one
or more significant inputs are unobservable.
Breakdown of financial instruments recorded at fair value by level of fair value measurement
Financial instruments carried at fair value and bases of valuation
Valuation Amount with
techniques HSBC entities
Level 3 –
with
Level 1 – Level 2 – significant
quoted using non- Amounts
market observable observable Third-party with HSBC Of which
price inputs inputs Total entities Level 3 Total
At 31 Dec 2020 €m €m €m €m €m €m €m
Assets
Trading assets 11,449 1,468 29 12,946 8 — 12,954
Financial assets designated and otherwise mandatorily measured
at fair value through profit or loss 2,891 6,227 2,279 11,397 251 — 11,648
Derivatives 35 35,911 109 36,055 20,420 491 56,475
Financial investments 11,570 6,331 815 18,716 445 127 19,161
Liabilities
Trading liabilities 17,809 19 — 17,828 — — 17,828
Financial liabilities designated at fair value — 16,340 552 16,892 — — 16,892
Derivatives 17 37,706 239 37,962 17,752 138 55,714
At 31 Dec 20191
Assets
Trading assets 13,461 1,373 2 14,836 1 — 14,837
Financial assets designated and otherwise mandatorily measured
at fair value through profit or loss 2,697 6,678 2,325 11,700 257 — 11,957
Derivatives 27 28,197 442 28,666 17,058 328 45,724
Financial investments 7,571 7,957 1,006 16,534 447 75 16,981
Liabilities
Trading liabilities 23,249 13 — 23,262 — — 23,262
Financial liabilities designated at fair value 7,531 11,115 307 18,953 — — 18,953
Derivatives 20 27,955 130 28,105 17,010 469 45,115
1 2019 balances have been re-presented following a refinement in application of the levelling methodology primarily for private debt and equity and
real-estate investments during the period. The result of this is a total of EUR 16.0 billion moving from Level 1, and EUR 13.4 billion and EUR 2.6
billion into Levels 2 and 3 respectively. The change has impacted financial investments and financial assets designated and otherwise mandatorily
measured at fair value.
Designated and
otherwise mandatorily
Financial Trading measured at fair value Trading Designated
Investments assets through profit or loss Derivatives Liabilities at fair value Derivatives
€m €m €m €m €m €m €m
At 31 Dec 2020
Transfers from Level 1 to Level 2 223 185 — — 18 6,609 —
Transfers from Level 2 to Level 1 1,766 188 80 — — — —
At 31 Dec 20191
Transfers from Level 1 to Level 2 2,411 1,046 — — — — —
Transfers from Level 2 to Level 1 615 35 — — — — —
1 2019 balances have been re-presented following a refinement in application of the levelling methodology. The result of this is an increase in
transfers from level 1 to level 2 and level 2 to level 1 of EUR 2.4 billion and EUR 0.6 billion respectively for financial investments and a decrease of
EUR 1.2 billion in transfers from Level 1 to Level 2 for Assets designated and otherwise mandatorily measured at fair value.
Transfers between levels of the fair value hierarchy are deemed to occur at the end of each quarterly reporting period. Transfers into and
out of levels of the fair value hierarchy are normally attributable to observability of valuation inputs and price transparency.
Fair value adjustments
Fair value adjustments are adopted when we determine there are additional factors considered by market participants that are not
incorporated within the valuation model.
Movements in the level of fair value adjustments do not necessarily result in the recognition of profits or losses within the income
statement, such as when models are enhanced and fair value adjustments may no longer be required.
Bid-offer
IFRS 13 'Fair value measurement' requires use of the price within the bid-offer spread that is most representative of fair value. Valuation
models will typically generate mid-market values. The bid-offer adjustment reflects the extent to which bid-offer costs would be incurred
if substantially all residual net portfolio market risks were closed using available hedging instruments or by disposing of or unwinding the
position.
Designated and
Financial otherwise mandatorily Designated
Invest- Trading measured at fair value Total Trading at fair Total
ments assets through profit or loss Derivatives Assets liabilities value Derivatives liabilities
€m €m €m €m €m €m €m €m €m
Private equity including strategic investments 21 — 1,974 — 1,995 — — — —
Asset-backed securities — — — — — — — — —
Structured notes — — — — — — 552 — 552
Derivatives — — — 109 109 — — 239 239
Other portfolios 794 29 305 — 1,128 — — — —
HSBC Group subsidiaries 127 — — 491 618 — — 138 138
Year ended 31 Dec 2020 942 29 2,279 600 3,850 — 552 377 929
1 2019 balances have been re-presented following a refinement in application of the levelling methodology. The result of this is an increase of EUR
2.6 billion of assets in Level 3; other portfolios increased by EUR 1.2 billion and private equity including strategic investments by EUR 1.4 billion.
The change has impacted financial investments and financial assets designated and otherwise mandatorily measured at fair value.
For more complex derivative products, there may be some divergence in market practice.
Inputs to valuation models are determined from observable market data wherever possible, including prices available from exchanges,
dealers, brokers or providers of consensus pricing. Certain inputs may not be observable in the market directly, but can be determined
from observable prices via model calibration procedures. Finally, some inputs are not observable, but can generally be estimated from
historic data or other sources.
Structured notes
For structured notes whose fair value is derived from a valuation technique, the fair value will be derived from the fair value of the
underlying debt security as described above, and the fair value of the embedded derivative will be determined as described in the section
above on derivatives. The notes are classified as Level 3 due to the unobservability of parameters such as long-dated equity volatilities
and correlations between equity prices, between equity prices and interest rates and between interest rates and foreign exchange rates.
1 2019 balances have been re-presented following a refinement in application of the levelling methodology. The result of this is an increase of
EUR 2.6 billion of assets in Level 3; financial investments increased by EUR 1.1 billion and financial assets designated and otherwise mandatorily
measured at fair value by EUR 1.5 billion.
1 Derivatives, trading assets and trading liabilities are presented as one category to reflect the manner in which these financial instruments are
risk-managed.
2 2019 balances have been re-presented following a refinement in application of the levelling methodology. The impact changes reflected through
OCI due to financial investments is EUR 53 million and EUR 77 million reflected in profit or loss due to financial assets designated and mandatorily
measured at fair value.
The following table shows the sensitivity of Level 3 fair values to reasonably possible alternative assumptions by instrument type.
Reflected in profit or loss Reflected in OCI
Favourable Unfavourable Favourable Unfavourable
changes changes changes changes
€m €m €m €m
2020
Private equity including strategic investments 102 (102) 1 (1)
Asset-backed securities — — — —
Structured notes 10 (10) — —
Derivatives 9 (9) — —
Other portfolios 9 (10) 42 (42)
HSBC Group subsidiaries 23 (23) 6 (6)
Year ended 31 Dec 153 (154) 49 (49)
20191
Private equity including strategic investments 116 (97) 1 (1)
Asset-backed securities — — — —
Structured notes 1 (1) — —
Derivatives 10 (10) — —
Other portfolios 10 (13) 53 (56)
HSBC Group subsidiaries 16 (16) — —
Year-ended 31 Dec 153 (137) 54 (57)
1 2019 balances have been re-presented following a refinement in application of the levelling methodology. The impact changes reflected through
OCI due to other portfolios is EUR 53 million and EUR 77 million reflected in profit or loss due to Private equity including strategic investments
(EUR 69 million) and other portfolios (EUR 8 million).
Favourable and unfavourable changes are determined on the basis of changes in the value of the instrument as a result of varying the
levels of the unobservable parameters using statistical techniques. When parameters are not amenable to statistical analysis,
quantification of uncertainty is judgemental.
When the fair value of a financial instrument is affected by more than one unobservable assumption, the above table reflects the most
favourable or most unfavourable change from varying the assumptions individually.
Key unobservable inputs to Level 3 financial instruments
The table above lists key unobservable inputs to Level 3 financial instruments, and provides the range of those inputs as at 31 December
2020. A further description of the categories of key unobservable inputs is given below.
At 31 Dec 20194
Private equity including strategic
investments 1,854 — See notes below See notes below N/A N/A N/A N/A
Asset-backed securities
– CLO/CDO 2 — — Market proxy Bid quotes — — — —
– other ABSs — —
Structured notes 2 307
– equity-linked notes — 224 Model – Option model Equity volatility — — — —
– fund-linked notes — — Model – Option model Fund volatility — — — —
– FX-linked notes — — Model – Option model FX volatility — — — —
– other 2 83
Derivatives 770 599
Interest rate derivatives 721 574
– securitisation swaps 139 1 Model – DCF 3 Prepayment rate 50 50 50 50
– long-dated swaptions 500 433 Model – Option model IR volatility 16 36 18 31
– other 82 140
Foreign exchange derivatives
– foreign exchange options — — Model – Option model FX volatility 9 11 9 11
Equity derivatives 49 25
– long-dated single stock options — — Model – Option model Equity volatility — — — —
– other 49 25
Credit derivatives
– other — —
Other portfolios 1,552 —
Total Level 3 4,178 906
Prepayment rates
Prepayment rates are a measure of the anticipated future speed at which a loan portfolio will be repaid in advance of the due date. They
vary according to the nature of the loan portfolio and expectations of future market conditions, and may be estimated using a variety of
evidence, such as prepayment rates implied from proxy observable security prices, current or historical prepayment rates and
macroeconomic modelling.
Market proxy
Market proxy pricing may be used for an instrument for which specific market pricing is not available, but evidence is available in respect
of instruments that have some characteristics in common. In some cases it might be possible to identify a specific proxy, but more
generally evidence across a wider range of instruments will be used to understand the factors that influence current market pricing and
the manner of that influence.
Volatility
Volatility is a measure of the anticipated future variability of a market price. It varies by underlying reference market price, and by strike
and maturity of the option.
Certain volatilities, typically those of a longer-dated nature, are unobservable. The unobservable volatility is then estimated from
observable data. For example, longer-dated volatilities may be extrapolated from shorter-dated volatilities.
Correlation
Correlation is a measure of the inter-relationship between two market prices. Correlation is a number between minus one and one. A
positive correlation implies that the two market prices tend to move in the same direction, with a correlation of one implying that they
always move in the same direction. A negative correlation implies that the two market prices tend to move in opposite directions, with a
correlation of minus one implying that the two market prices always move in opposite directions.
Correlation may be unobservable. Unobservable correlations may be estimated based upon a range of evidence, including consensus
pricing services, HSBC Continental Europe trade prices, proxy correlations and examination of historical price relationships.
Credit spread
Credit spread is the premium over a benchmark interest rate required by the market to accept a lower credit quality. In a discounted cash
flow model, the credit spread increases the discount factors applied to future cash flows, thereby reducing the value of an asset. Credit
spreads may be implied from market prices. Credit spreads may not be observable in more illiquid markets.
Inter-relationships between key unobservable inputs
Key unobservable inputs to Level 3 financial instruments may not be independent of each other. As described above, market variables
may be correlated. This correlation typically reflects the manner in which different markets tend to react to macroeconomic or other
events.
Other financial instruments not carried at fair value are typically short-term in nature and reprice to current market rates frequently.
Accordingly, their carrying amount is a reasonable approximation of fair value. They include cash and balances at central banks and
items in the course of collection from and transmission to other banks, all of which are measured at amortised cost.
Fair value of financial instruments not carried at fair value and basis of valuation
Fair value
Level 1 – Level 2 – Using Level 3 – Significant
Carrying Quoted observable unobservable
amount market price inputs inputs Total
€m €m €m €m €m
At 31 Dec 2020
Assets
Loans and advances to banks 6,781 — 6,782 — 6,782
Loans and advances to customers 56,225 — — 56,334 56,334
Reverse repurchase agreements – non-trading 21,522 — 21,522 — 21,522
Financial investments: debt securities at amortised cost 6 — — 6 6
Liabilities
Deposits by banks 17,204 — 17,145 — 17,145
Customer accounts 61,393 — 61,387 — 61,387
Repurchase agreements – non-trading 10,984 — 10,984 — 10,984
Debt securities in issue 3,605 — 3,605 — 3,605
Subordinated liabilities1 1,876 — 1,958 — 1,958
At 31 Dec 2019
Assets
Loans and advances to banks 6,798 — 6,800 — 6,800
Loans and advances to customers 56,956 — — 57,037 57,037
Reverse repurchase agreements – non-trading 45,973 — 45,973 — 45,973
Financial investments: debt securities at amortised cost 6 — — 6 6
Liabilities
Deposits by banks 12,113 — 12,113 — 12,113
Customer accounts 57,550 — 57,545 — 57,545
Repurchase agreements – non-trading 20,213 — 20,213 — 20,213
Debt securities in issue 9,782 — 9,782 — 9,782
Subordinated liabilities 1,376 — 1,429 — 1,429
1 During 2020, HSBC Continental Europe has issued a New Tier 2 Capital (Tier 2 instrument) subscribed by HSBC Bank plc for EUR 500 million with
a maturity of 10 years.
Valuation
The fair value measurement is HSBC Continental Europe's estimate of the price that would be received to sell an asset or paid to transfer
a liability in an orderly transaction between market participants at the measurement date. It does not reflect the economic benefits and
costs expected to flow from the instruments’ cash flows over their expected future lives. Other reporting entities may use different
valuation methodologies and assumptions in determining fair values for which no observable market prices are available.
Financial investments
The fair values of listed financial investments are determined using bid market prices. The fair values of unlisted financial investments are
determined using valuation techniques that incorporate the prices and future earnings streams of equivalent quoted securities.
Loans and advances to banks and customers
The fair value of loans and advances is based on observable market transactions, where available. In the absence of observable market
transactions, fair value is estimated using valuation models that incorporate a range of input assumptions. These assumptions may
include value estimates from third-party brokers which reflect over-the-counter trading activity; forward-looking discounted cash flow
models using assumptions which HSBC Continental Europe believes are consistent with those which would be used by market
participants in valuing such loans; and trading inputs from other market participants which includes observed primary and secondary
trades.
Loans are grouped, as far as possible, into homogeneous groups and stratified by loans with similar characteristics to improve the
accuracy of estimated valuation outputs. The stratification of a loan book considers all material factors, including vintage, origination
period, estimates of future interest rates, prepayment speeds, delinquency rates, loan-to-value ratios, the quality of collateral, default
probability, and internal credit risk ratings.
The fair value of a loan reflects both loan impairments at the balance sheet date and estimates of market participants’ expectations of
credit losses over the life of the loans, and the fair value impact of repricing between origination and the balance sheet date.
Deposits by banks and customer accounts
Fair values are estimated using discounted cash flows, applying current rates offered for deposits of similar remaining maturities. The fair
value of a deposit repayable on demand is approximated by its carrying value.
13 Financial assets designated and otherwise mandatorily measured at fair value through profit
or loss
2020 2019
Designated at fair value and Designated at fair value and
otherwise mandatorily measured at otherwise mandatorily measured at
fair value fair value
€m €m
Securities 11,507 11,639
– debt securities 2,796 2,896
– equity securities 8,711 8,743
Loans and advances to banks and customers 141 318
Other — —
Year ended 31 Dec 11,648 11,957
14 Derivatives
The table shows the fair value of derivatives by contract type:
Notional contract amounts and fair values of derivatives by product contract type held by HSBC Continental Europe
Notional contract amount Fair value – Assets Fair value – Liabilities
Trading Hedging Trading Hedging Total Trading Hedging Total
€m €m €m €m €m €m €m €m
Foreign exchange 555,346 261 9,138 18 9,156 8,723 — 8,723
Interest rate 3,758,436 15,277 53,856 — 53,856 53,571 55 53,626
Equities 23,562 — 528 — 528 400 — 400
Credit 6,065 — 58 — 58 87 — 87
Commodity and other 1,176 — 3 — 3 4 — 4
Gross total fair values 4,344,585 15,538 63,583 18 63,601 62,785 55 62,840
Offset (Note 28) (7,126) (7,126)
At 31 Dec 2020 4,344,585 15,538 63,583 18 56,475 62,785 55 55,714
The notional contract amounts of derivatives held for trading purposes and derivatives designated in hedge accounting relationships
indicate the nominal value of transactions outstanding at the balance sheet date; they do not represent amounts at risk.
Trading derivatives
Most of HSBC Continental Europe’s derivative transactions relate to sales and trading activities. Positions come from the activity with
clients, including as a result of reasonable expected short-term demand of clients and dynamic hedging of the positions.
Derivatives valued using models with unobservable inputs
The difference between the fair value at initial recognition (the transaction price) and the value that would have been derived had the
valuation techniques used for subsequent measurement been applied at initial recognition, less subsequent releases, is in the following
table:
Hedged Risk
Interest rate2 12,199 3 62 Derivatives (60)
At 31 Dec 2019 12,199 3 62 (60)
1 The notional contract amounts of derivatives designated in qualifying hedge accounting relationships indicate the nominal value of transactions
outstanding at the balance sheet date; they do not represent amounts at risk.
2 The hedged risk ‘interest rate’ includes inflation risk.
1 Used in effectiveness assessment; comprising amount attributable to the designated hedged risk that can be a risk component.
2 The hedged risk ‘interest rate’ includes inflation risk.
1 The notional contract amounts of derivatives designated in qualifying hedge accounting relationships indicate the nominal value of transactions
outstanding at the balance sheet date; they do not represent amounts at risk.
2 Used in effectiveness testing; comprising the full fair value change of the hedging instrument not excluding any component.
3 Used in effectiveness assessment; comprising amount attributable to the designated hedged risk that can be a risk component.
1 The notional contract amounts of derivatives designated in qualifying hedge accounting relationships indicate the nominal value of transactions
outstanding at balance sheet date; they do not represent amounts at risk.
The main event occurred during 2019 and in scope of Ibor reform was the change to the calculation of the Eonia to be calculated as the
Euro Short Term rate (‘€STR’) plus a fixed spread of 8.5 basis points. This event had no material impact to the valuation of components of
designated hedge accounting relationships and there were no discontinuations of existing designated relationships. The main market
events in scope of Ibor reform during 2020 were the changes applied by central clearing counterparties to remunerating EURO and US
dollar collateral. While there was a minimal valuation impact to the derivatives in scope which are used for hedge accounting, these
changes had no discontinuation impact to any of the designated relationships affected.
15 Financial investments
Assets pledged
Financial assets pledged as collateral are displayed as below:
The table above shows encumbered assets including those linked to TLTRO III and Covered bonds debt. The amount of assets pledged to
secure liabilities may be greater than the book value of assets utilised as collateral. For example, in the case of securitisations and
covered bonds, the amount of liabilities issued, plus mandatory over-collateralisation, is less than the book value of the pool of assets
available for use as collateral. This is also the case where assets are placed with a custodian or a settlement agent that has a floating
charge over all the assets placed to secure any liabilities under settlement accounts.
These transactions are conducted under terms that are usual and customary to collateralised transactions including, where relevant,
standard securities lending and borrowing, repurchase agreements and derivative margining.
Financial assets pledged as collateral that the counterparty has the right to sell or repledge
2020 2019
€m €m
Trading assets 10,983 9,882
Financial investments 360 28
At 31 Dec 11,343 9,910
Transferred financial assets not qualifying for full derecognition and associated financial liabilities
Carrying amount of:
Transferred Associated
assets liabilities
€m €m
Repurchase agreements 10,153 10,193
Securities lending agreements 1,190 —
At 31 Dec 2020 11,343 10,193
Associate
At 31 December 2020, HSBC Continental Europe consolidated under equity method three entities on which it exercises a joint control or
a significant influence. The impact on consolidated financial statements is not significant.
At 31 Dec 2020
Country of HSBC Continental
incorporation and Principal Europe’s interest
principal place of business activity %
HCM Holdings Ltd United Kingdom Asset Management 51
HSBC Global Asset Management (Switzerland) Switzerland Asset Management 50
Service Epargne Entreprise France Asset Management 14.2
Although HSBC Continental Europe owns more than 50 per cent of the equity capital of HCM Holdings Ltd, the agreement with the other
shareholder includes restrictions on the rights of HSBC Continental Europe as the majority shareholder and indicates joint control over
HCM Holdings Ltd by the two shareholders.
Regarding the entity Service Epargne Entreprise developed in partnership with other groups, HSBC Continental Europe participates in
strategic decisions of the associate through its representation in the executive bodies, influences operational management by providing
management systems or management staff or brings its technical cooperation to the company’s growth.
The share in the results of companies under equity method is not significant.
Partnerships
As of 31 December 2020, the contribution of HSBC Middle East Leasing Partnership (‘MELP’) to the consolidated total assets of HSBC
Continental Europe was EUR 480 million (2019: EUR 501 million) and EUR 10 million (2019: EUR 19 million) to the consolidated income
statement.
At 31 Dec 2019
HSBC Continental Europe 2,099 (22) (45) 28 — 9,472
– France 1,686 (154) (24) 26 — 8,085
– Belgium 9 1 — — — 26
– Czech Republic 41 27 (5) — — 94
– Greece 60 4 — — — 350
– Ireland 53 25 — — — 138
– Italy 44 10 (3) — — 120
– Luxembourg 60 8 (2) — — 271
– Netherlands 45 29 (7) — — 62
– Spain 70 36 — — — 151
– Sweden — (1) — — — 6
– United Kingdom — (4) — — — 2
– Poland 29 (4) (4) 2 — 167
– Others 2 1 — — — —
The list of subsidiaries by country detailing the names of entities, nature of activity and geographical location, is presented in the Note 35
on pages 227 to 230. The addresses of main locations abroad are presented on page 284.
HSBC
Conduits Securitisations managed funds Other Total
€m €m €m €m €m
At 31 Dec 2020 — 82 3,923 1,171 5,176
At 31 Dec 2019 — 100 4,923 1,398 6,421
General policy
A structured entity is an entity designed so that voting or similar rights are not the dominant factor in deciding who controls the entity,
for example when any voting rights relate to administrative tasks only, and key activities are directed by contractual arrangements. Thus,
these entities have a limited scope of activities and a well-defined purpose.
Structured entities are assessed for consolidation in accordance with the accounting policy set out in Note 1.
HSBC Continental Europe is involved directly or indirectly with structured entities mainly through securitisation of financial assets,
conduits and investment funds.
Group arrangements that involve structured entities are authorised centrally when they are established to ensure appropriate purpose and
governance. The activities of structured entities administered by HSBC Continental Europe are closely monitored by senior management.
HSBC Continental Europe has involvement with both consolidated and unconsolidated structured entities, which may be established by
the group or by a third party, detailed below.
Securitisations
HSBC Continental Europe has interests in unconsolidated securitisation vehicles through holding notes issued by these entities.
HSBC Continental Europe managed funds
HSBC Continental Europe has established a number of money market and non-money market funds in order to offer its customer
investment opportunities. When HSBC Continental Europe is deemed to be acting as principal rather than agent in its role as investment
manager, HSBC Continental Europe will control and hence consolidate these funds.
HSBC Continental Europe, as fund manager, may be entitled to receive management and performance fees based on the assets under
management. HSBC Continental Europe may also retain units in these funds.
Non-HSBC Continental Europe managed funds
HSBC Continental Europe purchases and holds units of third party managed funds in order to facilitate both business and customer
needs.
HSBC Continental Europe sponsored structured entities
The amount of assets transferred to and income received from such sponsored entities during 2020 and 2019 was not significant.
Others
HSBC Continental Europe also enters into a number of transactions in the normal course of business, including asset and structured
finance transactions where it has control of the structured entity.
Unconsolidated structured entities by HSBC Continental Europe
The term ‘unconsolidated structured entities’ refers to all structured entities that are not controlled by the group. It includes interests in
structured entities that are not consolidated. The group enters into transactions with unconsolidated structured entities in the normal
course of business to facilitate customer transactions and for specific investment opportunities.
The table below shows the total assets of unconsolidated structured entities in which the group has an interest at the reporting date, as
well as the group’s maximum exposure to loss in relation to those interests.
Nature and risks associated with HSBC Continental Europe interests in unconsolidated structured entities
Group Non-group
Securitisations managed funds managed funds Other Total
Total asset values of the entities (€m)
0 – 500 — 100 117 11 228
500 – 2,000 — 32 68 — 100
2,000 – 5,000 — 1 27 — 28
5,000 – 25,000 — — 21 — 21
25,000+ — — — — —
Number of entities at 31 Dec 2020 — 133 233 11 377
€m €m €m €m €m
Total assets in relation to HSBC Continental Europe's interests in the
unconsolidated structured entities — 2,408 2,221 40 4,669
– trading assets — — — — —
– financial assets designated and otherwise mandatorily measured at fair
value — 2,408 2,021 — 4,429
– loans and advances to customers — — — — —
– financial investments — — 200 11 211
– derivatives — — — 29 29
Total liabilities in relation to HSBC Continental Europe’s interests in
the unconsolidated structured entities — — — — —
Other off balance sheet commitments — — — (37) (37)
HSBC Continental Europe's maximum exposure at 31 Dec 2020 — 2,408 2,221 3 4,632
€m €m €m €m €m
Total assets in relation to HSBC Continental Europe's interests in the
unconsolidated structured entities — 3,443 2,185 29 5,657
– trading assets — — — — —
– financial assets designated and otherwise mandatorily measured at fair
value — 3,443 1,899 — 5,342
– loans and advances to customers — — — — —
– financial investments — — 286 26 312
– derivatives — — — 3 3
Total liabilities in relation to HSBC Continental Europe’s interests in the
unconsolidated structured entities — — — — —
Other off balance sheet commitments — — — — —
HSBC Continental Europe's maximum exposure at 31 Dec 2019 — 3,443 2,185 29 5,657
The maximum exposure to loss from HSBC Continental Europe’s interests in unconsolidated structured entities represents the maximum
loss it could occur as a result of its involvement with unconsolidated structured entities regardless of the probability of the loss being
incurred.
• For commitments and guarantees, and written credit default swaps, the maximum exposure of HSBC Continental Europe to loss is the
notional amount of potential future losses.
• For retained and purchased investments in and loans to unconsolidated structured entities, the maximum exposure of HSBC
Continental Europe loss is the carrying value of these interests at the balance sheet reporting date.
The maximum exposure to loss is stated gross of the effects of hedging and collateral arrangements entered into to mitigate HSBC
Continental Europe’s exposure to loss.
2020 2019
€m €m
Goodwill 66 66
Present value of in force long term insurance business ('PVIF') 490 613
Other intangible assets1 23 314
At 31 Dec 579 993
1 Other intangible assets is predominantly internally generated software in the EEA branches.
1 During the year 2019, the goodwill on Commercial Banking was impaired.
Impairment testing
During 2020, impairment testing was performed and no impairment was recognised to the Asset Management goodwill. Refer to '2020
Impairment Testing' section below for HSBC Continental Europe impairment testing in France and EEA branches.
Cost
At 1 Jan 2019 184 62 15 261
Additions 143 4 — 147
Disposals (2) — — (2)
Amount written off — — — —
Exchange differences — — — —
Other changes 19 5 — 24
At 31 Dec 2019 344 71 15 430
Accumulated amortisation and impairment
At 1 Jan 2019 (8) (54) (14) (76)
Amortisation charge for the year (23) (3) — (26)
Impairment charge for the year (7) — — (7)
Amount written off — — — —
Disposals — — — —
Exchange differences — — — —
Other changes (5) (2) — (7)
At 31 Dec 2019 (43) (59) (14) (116)
Net carrying amount at 31 December 2019 301 12 1 314
Movements in PVIF
2020 2019
€m €m
At 1 January 613 500
Change in PVIF of long-term insurance business (123) 113
– moving forward (65) (61)
– value of new business 24 29
– assumption changes and others 36 178
– market impact (134) (55)
– experience variances 16 22
At 31 December 490 613
The PVIF moved from EUR 613 million as of 31 December 2019 to EUR 490 million as of 31 December 2020. The negative movement of
EUR (123) million is mainly due to following items:
• a positive impact of current year new business of EUR 24 million which partially offsets the negative impact of the Moving forward of
EUR (65) million;
• a positive effect of changes in assumptions and models evolutions of EUR 36 million mainly due to the update of the prospective
non-economic assumptions of EUR 12 million and to the increase of the actuarial reserve linked to guaranteed rate payments of
EUR 24 million;
• a negative impact of the economic environment of EUR (134) million mainly explained by the decrease of the interest rate in the year
2020;
• a positive impact of experience variances of EUR 16 million.
1 For 2020, market value future profits’ discounted rate used for the PVIF is 1.34 per cent , to which a risk margin of EUR 175.3 million is added. In
2019, the market value future profits’ discounted rate was 1.27 per cent, to which a risk margin of EUR 115.6 million was added.
Due to certain characteristics of the contracts, the sensitivities may be non-linear and the results of the sensitivity-testing should not be
extrapolated to higher levels of stress. In calculating the scenario, the shift in the risk-free rate results in changes to investment returns,
risk discount rates and bonus rates which are incorporated. The sensitivities shown are at ultimate forward rate and before actions that
could be taken by management to mitigate impacts and before resultant changes in policyholder behavior.
The sensitivities on the ultimate forward (EIOPA) rate are presented below:
Impact on PVIF as at 31/12/20201 Impact on PVIF as at 31/12/20191
€m €m
+ 100 basis points of Ultimate Forward Rate (UFR) 27 44
- 100 basis points of Ultimate Forward Rate (UFR) (37) (30)
2020 2019
€m €m
Prepayments and accrued income 569 649
Settlement accounts 2,440 1,482
Cash collateral and margin receivables 15,948 12,304
Endorsements and acceptances 7 18
Reinsurers’ share of liabilities under insurance contracts (Note 4) 2 2
Employee benefit assets (Note 5) — —
Other accounts 1,607 1,190
Right-of-use-Assets1 270 200
Property, plant and equipment 892 975
At 31 Dec 21,735 16,820
1 The net value of the right of use breaks down into EUR 454 million as gross value and EUR (184) million as depreciation and provisions. ROU
assets amounting to EUR 72 million have been recognised where the contracts are enforceable beyond their contractual end date based on
management’s best estimate of lease duration.
Prepayments, accrued income and other assets include EUR 20,530 million (2019: EUR 15,608 million) of financial assets, the majority of
which are measured at amortised cost.
Property, plant and equipment
Land and buildings are stated at historical cost, or fair value at the date of transition to IFRS, less any impairment losses and depreciation
calculated as per below:
• freehold land is not depreciated;
• acquisition-related expenses on buildings are expensed in the year in which they occur, same as preliminary costs;
• depreciation of buildings is calculated over their estimated useful lives, which are generally between 25 to 75 years.
Equipment, fixtures and fittings (including equipment on operating leases where HSBC Continental Europe is the lessor) are stated at cost
less impairment losses and depreciation is calculated on a straight-line basis to write off the assets over their estimated useful lives,
which are generally between 5 to 25 years. HSBC Continental Europe holds certain properties as investments to earn rentals or for capital
appreciation, or both. Investment properties are included in the balance sheet at fair value with changes in fair value recognised in the
income statement in the period of change. Fair values are determined by independent professional valuers who apply recognised
valuation techniques. Property, plant and equipment is subject to review for impairment if there are events or changes in circumstances
that indicate that the carrying amount may not be recoverable.
1 It includes EUR 15 million of leasehold land and building for which the rights of use are considered sufficient to constitute control and for which
there are insignificant lease liabilities. They are therefore presented as owned assets.
Impairment testing
During 2020, we considered the pervasive macroeconomic deterioration caused by the outbreak of Covid-19, along with the impact on
forecast profitability, to be an indicator of impairment. Impairment testing was performed, identifying the value-in-use (recoverable
amount) of the CGUs to be below their net carrying value in France.
As a result, EUR 206 million of tangible asset impairments were impaired, primarily right-of-use assets for leased office, commercial and
retail branches and fixtures and fittings. The impairments reflect recent losses and deterioration in the future forecasts, substantially
relating to prior periods. Refer to Note 20 Goodwill and intangible assets and Note 1.2(n) Summary of significant accounting policies –
Impairment of non-financial assets.
22 Trading liabilities
2020 2019
€m €m
Deposits by banks — —
Customer accounts — —
Other debt securities in issue — —
Other liabilities – net short positions in securities 17,828 23,262
At 31 Dec 17,828 23,262
2020 2019
€m €m
Deposits by banks and customer accounts 76 86
Liabilities to customers under investment contracts 14 15
Debt securities in issue 16,802 18,852
Subordinated liabilities (Note 26) — —
Preferred securities — —
At 31 Dec 16,892 18,953
The difference between the carrying amount of financial liabilities designated at fair value and the contractual amount at maturity at
31 December 2020 was EUR 921 million for HSBC Continental Europe (at 31 December 2019: EUR 628 million).
At 31 December 2020, the accumulated amount of the change in fair value attributable to changes in credit risk for HSBC Continental
Europe was EUR 127 million (at 31 December 2019: EUR 136 million).
In 2020, HSBC Continental Europe recognised a negative variation of EUR (4) million in other comprehensive income in respect of HSBC
Continental Europe's own credit risk (at 31 December 2019 EUR (167) million).
2020 2019
€m €m
Accruals and deferred income 764 1,123
Settlement accounts 696 1,782
Cash collateral and margin payables 15,509 11,084
Endorsements and acceptances 7 18
Employee benefit liabilities (Note 5) 175 188
Lease liabilities 420 238
Other liabilities 2,546 2,323
At 31 Dec 20,117 16,756
25 Provisions
HSBC Continental Europe recognises a provision when the following three criteria are met:
• existence of a present obligation occurring from a past event;
• it is probable that an outflow of resources will be required to settle the obligation;
• a reliable estimate of the amount can be made.
1 Includes restructuring provision of EUR 278 million in 2020 (refer Note 1.3).
2 Includes amount transferred to Other Liabilities.
1 This amount corresponds to the amount transferred due to the acquisition of certain assets and liabilities of European branches on 1 February
2019 and on 1 March 2019 from HSBC Bank plc.
Further details of ‘Legal proceedings and regulatory matters’ regarding the HSBC Group are set out in Note 32.
26 Subordinated liabilities
Subordinated liabilities are initially measured at fair value, which is the consideration received net of directly attributable transaction costs
incurred. Subsequent measurement is at amortised cost, using the effective interest rate method to amortise the difference between
proceeds net of directly attributable transaction costs and the redemption amount over the expected life of the debt, unless the
instruments are designated at fair value.
2020 2019
€m €m
At amortised cost 1,876 1,376
Designated at fair value (Note 23) — —
Total at 31 Dec 1,876 1,376
Book value
2020 2019
Tier 2 instruments issued by HSBC Continental Europe €m €m
EUR 16 million Undated subordinated variable rate notes 16 16
EUR 300 million Floating rate notes maturing 2027 300 300
EUR 300 million Floating rate notes maturing 2028 300 300
EUR 400 million Floating rate notes maturing 2029 400 400
EUR 100 million Floating rate notes maturing 2029 100 100
EUR 260 million Floating rate notes maturing 2029 260 260
EUR 500 million Floating rate notes maturing 2030 500 —
At 31 Dec 1,876 1,376
Due over
1 month but
Due not more not over Due between Due between Due after
than 1 month 3 months 3 and 12 months 1 and 5 years 5 years Total
€m €m €m €m €m €m
Deposits by banks 6,049 3 17 10,796 215 17,080
Customer accounts 58,540 1,411 1,266 131 81 61,429
Repurchase Agreements – non–trading 10,177 803 4 — — 10,984
Trading liabilities 17,828 — — — — 17,828
Financial liabilities designated at fair value 126 49 2,350 9,171 6,005 17,701
Derivatives 55,660 2 — 43 20 55,725
Debt securities in issue 0 0 1,141 2,118 346 3,605
Subordinated liabilities — — — 1,886 17 1,903
Other financial liabilities 17,780 89 374 310 1,260 19,813
Sub Total 166,160 2,357 5,152 24,455 7,944 206,068
Loan and other credit-related commitments 99,557 — — — — 99,557
Financial guarantees 1,050 — — — — 1,050
Total at 31 Dec 2020 266,767 2,357 5,152 24,455 7,944 306,675
Proportion of cash flows payable in period 87% 1% 2% 8% 2%
2019
Deposits by banks 5,895 257 2,199 3,485 502 12,338
Customer accounts 54,280 1,513 1,734 132 89 57,748
Repurchase Agreements – non–trading 19,349 861 3 — — 20,213
Trading liabilities 23,262 — — — — 23,262
Financial liabilities designated at fair value 1,035 14 2,209 9,636 7,597 20,491
Derivatives 45,075 — — 45 17 45,137
Debt securities in issue 368 430 9,003 — — 9,801
Subordinated liabilities — — — 1,116 277 1,393
Other financial liabilities 14,081 41 648 119 1,295 16,184
Sub Total 163,345 3,116 15,796 14,533 9,777 206,567
Loan and other credit-related commitments 89,693 — — — — 89,693
Financial guarantees 1,209 — — — — 1,209
Total at 31 Dec 2019 254,247 3,116 15,796 14,533 9,777 297,469
Proportion of cash flows payable in period 86% 1% 5% 5% 3%
Financial liabilities
Deposits by banks 6,044 2 9 — 9 18 10,907 215 17,204
Customer accounts 58,534 1,411 664 235 367 67 58 57 61,393
– personal 20,554 36 37 29 42 65 55 29 20,847
– corporate and commercial 33,149 1,332 571 206 325 2 3 28 35,616
– financial 4,831 43 56 — — — — — 4,930
Repurchase agreements – non-trading 10,176 804 2 2 — — — — 10,984
Items in the course of transmission to other banks 198 — — — — — — — 198
Trading liabilities 17,828 — — — — — — — 17,828
Financial liabilities designated at fair value 126 49 145 2,049 155 2,040 6,876 5,452 16,892
– debt securities in issue: covered bonds — — — — — 1,011 2,380 — 3,391
– debt securities in issue: unsecured 112 49 136 2,049 155 1,029 4,496 5,385 13,411
– other 14 — 9 — — — — 67 90
Derivatives 55,659 — — — — — 38 17 55,714
Debt securities in issue — — 470 380 291 510 1,608 346 3,605
– covered bonds — — — — — — — — —
– unsecured — — 470 380 291 510 1,608 346 3,605
Accruals and other financial liabilities 17,554 104 291 16 90 75 270 1,390 19,790
Subordinated liabilities — — — — — 300 1,560 16 1,876
Total financial liabilities at 31 Dec 2020 166,119 2,370 1,581 2,682 912 3,010 21,317 7,493 205,484
Non-financial liabilities 24,156 24,156
Total liabilities at 31 Dec 2020 166,119 2,370 1,581 2,682 912 3,010 21,317 31,649 229,640
Off-balance sheet commitments given
Loan and other credit-related commitments 99,557 — — — — — — — 99,557
– personal 1,352 — — — — — — — 1,352
– corporate and commercial 42,767 — — — — — — — 42,767
– financial 55,438 — — — — — — — 55,438
Financial liabilities
Deposits by banks 5,834 257 1,532 2 543 611 2,832 502 12,113
Customer accounts 54,279 1,423 1,244 54 369 80 43 58 57,550
– personal 19,100 64 67 33 62 77 40 46 19,489
– corporate and commercial 30,314 1,151 1,125 21 307 3 3 12 32,936
– financial 4,865 208 52 — — — — — 5,125
Repurchase agreements – non-trading 19,349 861 1 — 2 — — — 20,213
Items in the course of transmission to other banks 396 — — — — — — — 396
Trading liabilities 23,262 — — — — — — — 23,262
Financial liabilities designated at fair value 1,025 14 346 250 1,609 2,283 7,084 6,342 18,953
– debt securities in issue: covered bonds — — — — 1,015 — 2,373 1,032 4,420
– debt securities in issue: unsecured 1,010 14 334 250 594 2,283 4,711 5,236 14,432
– subordinated liabilities and preferred securities — — — — — — — — —
– other 15 — 12 — — — — 74 101
Derivatives 45,053 — — — — — 45 17 45,115
Debt securities in issue 367 430 1,557 4,154 3,274 — — — 9,782
– covered bonds — — — — — — — — —
– unsecured 367 430 1,557 4,154 3,274 — — — 9,782
Accruals and other financial liabilities 14,015 30 545 5 98 49 62 1,295 16,099
Subordinated liabilities — — — — — — 1,100 276 1,376
Total financial liabilities at 31 Dec 2019 163,580 3,015 5,225 4,465 5,895 3,023 11,166 8,490 204,859
Non-financial liabilities 24,350 24,350
Total liabilities at 31 Dec 2019 163,580 3,015 5,225 4,465 5,895 3,023 11,166 32,840 229,209
Off-balance sheet commitments given
Loan and other credit-related commitments 89,693 — — — — — — — 89,693
– personal 1,189 — — — — — — — 1,189
– corporate and commercial 38,218 — — — — — — — 38,218
– financial 50,286 — — — — — — — 50,286
Further information regarding HSBC Continental Europe’s liquidity and funding management is available in the Risk Management section
pages 132 and following.
Derivatives (Note 14) 1 50,683 (5,053) 45,630 (35,172) (350) (10,065) 43 94 45,724
Reverse repos, stock borrowing and similar
agreements classified as: 100,547 (54,573) 45,974 (9,327) (36,472) (174) 1 20 45,994
– trading assets 1 — 1 — — — 1 — 1
– non-trading assets 100,546 (54,573) 45,973 (9,327) (36,472) (174) — 20 45,993
Loans and advances to customers 2 55 — 55 — — — 55 — 55
At 31 Dec 2019 151,285 (59,626) 91,659 (44,499) (36,822) (10,239) 99 114 91,773
Financial Liabilities
Derivatives (Note 14) 1 62,742 (7,126) 55,616 (40,873) (1,137) (13,557) 49 98 55,714
Repos, stock borrowing and similar
agreements classified as: 43,290 (32,306) 10,984 (2,638) (8,113) (232) 1 — 10,984
– trading liabilities — — — — — — — — —
– non-trading liabilities 43,290 (32,306) 10,984 (2,638) (8,113) (232) 1 — 10,984
Customer accounts excluding repos 3 — — — — — — — — —
At 31 Dec 2020 106,032 (39,432) 66,600 (43,511) (9,250) (13,789) 50 98 66,698
Derivatives (Note 14) 1 50,082 (5,053) 45,029 (35,172) (1,385) (8,436) 36 86 45,115
Repos, stock borrowing and similar
agreements classified as: 74,786 (54,573) 20,213 (9,327) (10,430) (455) 1 — 20,213
– trading liabilities — — — — — — — — —
– non-trading liabilities 74,786 (54,573) 20,213 (9,327) (10,430) (455) 1 — 20,213
Customer accounts excluding repos 3 — — — — — — — — —
At 31 Dec 2019 124,868 (59,626) 65,242 (44,499) (11,815) (8,891) 37 86 65,328
1 At 31 December 2020, the amount of cash margin received that had been offset against the gross derivatives assets was EUR 779 million
(2019: EUR 198 million). The amount of cash margin paid that had been offset against the gross derivatives liabilities was EUR 1,994 million
(2019: EUR 1,750 million).
2 At 31 December 2020, the total amount of ‘Loans and advances to customers’ was EUR 56,225 million (2019: EUR 56,956 million) of which
EUR 0 million (2019: EUR 55 million) was subject to offsetting.
3 At 31 December 2020, the total amount of ‘Customer accounts’ was EUR 61,393 million (2019: EUR 57,550 million).
HSBC Continental Europe ordinary shares of EUR 5 each, issued and fully paid
2020 2019
Number €m Number €m
At 1 Jan 98,231,196 491 73,316,988 367
Shares issued — — 24,914,208 124
At 31 Dec 98,231,196 491 98,231,196 491
HSBC Continental Europe’s additional tier 1 capital instruments in issue which are accounted for as equity
2020 2019
First call date €m €m
EUR 200 million Perpetural Subordinated additional Tier 1 instruments issued in 2017 26/05/2022 200 200
EUR 300 million Perpetural Subordinated additional Tier 1 instruments issued in 2018 28/03/2023 300 300
EUR 250 million Perpetural Subordinated additional Tier 1 instruments issued in 2019 18/12/2024 250 250
At 31 Dec 750 750
Contingent liabilities
(a) Contingent liabilities and commitments
2020 2019
Footnote €m €m
Guarantees and other contingent liabilities:
– financial guarantees 1,051 1,209
– performance and other guarantees 8,313 9,256
– other contingent liabilities 89 95
At 31 Dec 9,453 10,560
Commitments: 1
1 Includes EUR 97,892 million of commitments at 31 December 2020 (2019: EUR 88,422 million), to which the impairment requirements in IFRS 9
are applied where HSBC Continental Europe has become party to an irrevocable commitment.
The amounts disclosed in the above table reflect HSBC Continental Europe’s maximum exposure under a large number of individual
guarantee undertakings. The risks and exposures arising from guarantees are captured and managed in accordance with HSBC
Continental Europe’s overall credit risk management policies and procedures. Guarantees with terms of more than one year are subject
to HSBC Continental Europe’s annual credit review process. The total of the nominal principal amounts is not representative of future
liquidity needs.
Financial guarantees include undertakings to fulfil the obligations of customers or group entities, should the obligated party fail to do so.
The inter-company financial guarantees include a specific guarantee related to debt issued by the Group for the benefit of other entities of
the group and with respect to regulatory requirements. Financial guarantees also include stand-by letters of credit, which are financial
guarantees given irrevocable obligations on the part of HSBC Continental Europe to pay a third party when a customer fails to meet a
commitment.
Performance guarantees include performance bonds, direct credit substitutes ,stand-by letters of credit related to particular transactions
which are undertakings by which the requirement to make payment under the guarantee depends on the outcome of a future event
which is unconnected to the creditworthiness of the customer. Other guarantees includes bid bonds and another transaction-related
guarantees which are undertakings by which the requirement to make payment under the guarantee depends on the outcome of a future
event which is unconnected to the creditworthiness of the customer.
The amounts disclosed in the above table reflect HSBC Continental Europe’s maximum exposure under a large number of individual
guarantee undertakings. The risks and exposures arising from guarantees are captured and managed in accordance with our overall
credit risk management policies and procedures. Guarantees with terms of more than one year are subject to the annual credit review
process.
HSBC Continental Europe has no contingent liabilities or commitments in relation to joint ventures or associates, incurred jointly or
otherwise.
The majority of the above guarantees have a term of more than one year. Those guarantees are subject to HSBC Continental Europe’s
annual credit review process.
When HSBC Continental Europe gives a guarantee on behalf of a customer, it retains the right to recover from that customer amounts
paid under the guarantee.
HSBC Continental Europe leases a variety of assets to third parties under finance leases, including transport assets (such as aircraft),
property and general plant and machinery. At the end of lease terms, assets may be sold to third parties or leased for further terms.
Rentals are calculated to recover the cost of assets less their residual value, and earn finance income.
2020 2019
Total future Unearned Total future Unearned
minimum finance Present minimum finance Present
payments income Value payments income Value
€m €m €m €m €m €m
Lease receivables
– No later than one year 270 (18) 252 432 (21) 411
– Later than one year and no later than five years 876 (63) 813 918 (76) 842
– One to two years 205 (19) 186 209 (23) 186
– Two to three years 204 (17) 187 237 (20) 217
– Three to four years 340 (16) 324 328 (18) 310
– Four to five years 127 (11) 116 144 (15) 129
– Later than five years 670 (34) 636 789 (38) 751
Total at 31 Dec 1,816 (115) 1,701 2,139 (135) 2,004
32 Legal proceedings and regulatory matters relating to HSBC group entities generally
HSBC group entities, including HSBC Continental Europe entities, are party to various significant legal proceedings and regulatory
matters arising out of their normal business operations. Apart from the matters described below and in the section 2.19a Legal Risks and
Litigation management of the 2020 Registration Document, HSBC Continental Europe considers that none of these matters is significant.
HSBC Continental Europe recognises a provision for a liability in relation to these matters when it is probable that an outflow of economic
benefits will be required to settle an obligation which has arisen as a result of past events, and for which a reliable estimate can be made
of the amount of the obligation. Any provision recognised does not constitute an admission of wrongdoing or legal liability. While the
outcome of these matters is inherently uncertain, management believes that, based on the information available to it, appropriate
provisions, as necessary, have been made in respect of such legal proceedings as at 31 December 2020.
Anti-money laundering and sanctions-related matters
In December 2012, among other agreements, HSBC Holdings agreed to an undertaking with the UK Financial Services Authority which
was replaced by a Direction issued by the UK Financial Conduct Authority ('FCA') in 2013, and again in July 2020, and consented to a
cease-and-desist order with the Federal Reserve Board (‘FRB’), both of which contained certain forward-looking anti-money laundering
(‘AML’) and sanctions-related obligations. HSBC also agreed to retain an independent compliance monitor (who is, for FCA purposes, a
‘Skilled Person’ under section 166 of the Financial Services and Markets Act, and for FRB purposes, an ‘Independent Consultant’) to
produce periodic assessments of the Group’s AML and sanctions compliance programme (the ‘Skilled Person/Independent Consultant’).
In December 2012, HSBC Holdings, entered into an agreement with the office of Foreign Assets Control ('OFAC') regarding historical
transactions involving parties subject to OFAC sanctions.
HSBC’s engagement with the Skilled Person appointed pursuant to the 2013 Direction was terminated in February 2020 and a new
Skilled Person with a narrower mandate has been appointed to assess the remaining areas that require further work in order for HSBC to
transition fully to business-as-usual financial crime risk management. A new Independent Consultant is also being appointed to continue
to carry out an annual OFAC compliance review at the FRB’s discretion.
Bernard L. Madoff Investment Securities LLC
Bernard L. Madoff (‘Madoff’) was arrested in December 2008 in the United States and later pleaded guilty to running a Ponzi scheme. His
firm, Bernard L. Madoff Investment Securities LLC (‘Madoff Securities’), is being liquidated in the US by a trustee (the ‘Trustee’).
Various non-US HSBC companies provided custodial, administration and similar services to a number of funds incorporated outside the
US whose assets were invested with Madoff Securities.
Various HSBC companies have been named as defendants in lawsuits arising out of Madoff Securities' fraud, amongst which are HSBC
Institutional Trust Services (Ireland) DAC ('HTIE') and/or its subsidiary Somers Dublin DAC.
On 1 August 2018 HSBC Continental Europe acquired from HSBC Bank plc 100 per cent of the shares of HTIE. Pursuant to the terms of
the Sale and Purchase Agreement, HSBC Continental Europe and/or its subsidiaries will be indemnified by HSBC Bank plc in respect of
certain liabilities relating to the activities of HTIE and/or Somers Dublin DAC prior to the acquisition by HSBC Continental Europe of HTIE,
which has been integrated within HSBC Continental Europe in Ireland.
The Madoff-related proceedings that HTIE and/or Somers Dublin DAC are involved in are described below:
Defender case:
In November 2013, Defender Limited brought an action against HTIE and others, based on allegations of breach of contract and claiming
damages and indemnification for fund losses. The trial commenced in October 2018. In December 2018, the Irish Court issued a
judgement in HTIE’s favour on a preliminary issue, holding that Defender Limited had no effective claim against HTIE. This judgement
concluded the trial without further issues in dispute being heard. In February 2019, Defender Limited appealed the judgement. In July
2020, the Irish Supreme Court ruled in part in favour of Defender Limited and returned the case to the High Court for further proceedings,
which will resume in April 2021.
US litigation:
The Trustee has brought lawsuits against various HSBC companies and others in the US Bankruptcy Court for the Southern District of
New York (the ‘US Bankruptcy Court‘), seeking recovery of transfers from Madoff Securities to HSBC in an amount not yet pleaded or
determined. HSBC and other parties to the actions have moved to dismiss the Trustee’s claims. The US Bankruptcy Court granted
HSBC’s motion to dismiss with respect to certain of the Trustee’s claims in November 2016. In February 2019, the US Court of Appeals
for the Second Circuit (the ’Second Circuit Court of Appeals’) reversed that dismissal. Following the US Supreme Court’s denial of
certiorari in June 2020, the cases were remanded to the US Bankruptcy Court, where they are now pending.
European interbank offered rates investigations
Various regulators and competition and law enforcement authorities around the world including in the United Kingdom (UK), the United
States of America (’US‘), the European Union, Italy are conducting investigations and reviews related to certain past submissions made
by panel banks and the processes for making submissions in connection with the setting of European interbank offered rates (’Euribor’).
The ultimate parent company of the group is HSBC Holdings plc, which is incorporated in the United Kingdom.
Copies of the Group financial statements may be obtained from the following address:
HSBC Holdings plc
8 Canada Square
London
E14 5HQ
All transactions were made in the ordinary course of business and on substantially the same terms, including interest rates and security,
as for comparable transactions with persons of a similar standing or, where applicable, with other employees. The transactions did not
involve more than the normal risk of repayment or present other unfavourable features.
Key Management Personnel
The table below sets out transactions which fall under IAS 24 ‘Related Party Disclosures’ between HSBC Continental Europe and the Key
Management Personnel of HSBC Continental Europe and on one hand, their respective spouses and children living in the family home,
and on the other hand, controlled companies.
Transactions and balances during the year with Key Management Personnel
2020 2019
Highest amounts Highest amounts
Number of Balance at outstanding Number of Balance outstanding
persons 31 Dec2 during year2 persons at 31 Dec2 during year2
€k €k €k €k
Key Management Personnel 1
Advances and credits 21 26,215 44,237 25 34,074 62,996
Guarantees 21 2,275 3,495 25 3,006 3,006
Deposits 21 54,746 121,248 25 61,004 489,617
1 Includes Key Management Personnel, close family members of Key Management Personnel and entities which are controlled or jointly controlled
by Key Management Personnel or their close family members.
2 The highest balance during the year and the balance at 31 December are considered to be the most significant information to show the
transactions during the year.
Compensation to the Key Management Personnel of HSBC Continental Europe under IAS 24 is disclosed as follows:
The Corporate governance report also includes a detailed description of Directors’ remuneration (see page 40 and following).
Transactions with other related parties
There is no significant amount due to joint ventures and associates.
Transactions detailed below include amounts due to/from HSBC Continental Europe and fellow subsidiaries of the HSBC Group.
There was no material event subsequent to the reporting date that would require a correction or adjustment to the consolidated financial
statements as at 31 December 2020.
New products and services are offered to customers of the HSBC Group in Continental Europe on a regular basis. Information is available
on the Group’s websites, in particular in the press releases posted at www.hsbc.fr.
There has been no significant change affecting the financial or sales situation of HSBC Continental Europe or its subsidiaries since
31 December 2020 until the Board of Directors of 23 February 2021 which approves these financial statements.
HSBC Continental Europe classifies investments in entities which it controls as subsidiaries. HSBC Continental Europe consolidation
policy is described in Note 1.
Subsidiaries of HSBC Continental Europe
HSBC Continental Europe
interest (%)
Country of incorporation Consolidation
Consolidated companies Footnotes or registration method* Main line of business 2020 2019
Retail and Commercial Banking
HSBC Factoring (France) France FC Financial company 100.0 100.0
SAPC Ufipro Recouvrement France FC Service company 99.9 99.9
Asset Management
CCF & Partners Asset Management Ltd United Kingdom FC Financial company 100.0 100.0
HCM Holdings Ltd 5 United Kingdom EM Financial company 51.0 51.0
HSBC Epargne Entreprise (France) France FC Financial company 100.0 100.0
Services Epargne Entreprise France EM Service company 14.2 14.4
HSBC Global Asset Management (France) France FC Asset management 100.0 100.0
HSBC Global Asset Management (Switzerland) AG Switzerland EM Asset management 50.0 50.0
HSBC REIM (France) France FC Asset management 100.0 100.0
Insurance
HSBC Assurances Vie (France) France FC Insurance company 100.0 100.0
SCI HSBC Assurances Immo France FC Real estate company 100.0 100.0
ERISA Actions Grandes Valeurs France FC Financial company 100.0 100.0
OPCVM8 – Erisa Diversifié N2 FCP France FC Financial company 100.0 100.0
OPCVM9 – Erisa Opportunités FCP France FC Financial company 100.0 100.0
HSBC MIX DYNAMIQUE FCP3DEC France FC Financial company 59.7 61.5
HSBC MUL.ASS.ST.FACT.S FCP3DEC France FC Financial company 100.0 100.0
HSBC PTF WLD Select.4 A C.3DEC France FC Financial company 55.7 54.2
HSBC SELECT DYNAMIC A FCP 2DEC France FC Financial company 78.1 74.4
HSBC GIF EMERG.WEALTH A C.3DEC France FC Financial company 64.1 64.8
HSBC ACTIONS EUR.C FCP 3DEC France FC Financial company 57.3 71.7
HSBC SELECT EQUITY A FCP 4DEC France FC Financial company 76.7 70.7
HSBC EURO PROTECT 80 PLUS PART C France FC Financial company 73.0 71.1
HSBC PORT-WORLD SEL 5-AHEUR France FC Financial company 56.0 54.0
HSBC GLOBAL INVESTMENT FUNDS GEM EQUITY France FC Financial company 64.8 54.4
HSBC RESP INVESTMENT FUNDS SRI GLOBAL EQUITY France FC Financial company 59.3 53.5
HSBC RESP INVE FD-SRI DYNAMIC PART AC France FC Financial company 69.2 66.7
HSBC RESP INVES FUNDS-SRI BALANCED AC France FC Financial company 97.3 99.1
HSBC GB Inv -Economic Scale Japan Eq 3 France FC Financial company 64.7 —
HSBC GLB-US EQUITY IND-ACEUR 3 France FC Financial company 98.4 —
HSBC OBLIG INFLATION EURO AC 3 France FC Financial company 50.8 —
Others
Charterhouse Management Services Limited United Kingdom FC Investment company 100.0 100.0
Charterhouse Administrators Ltd United Kingdom FC Investment company 100.0 100.0
Keyser Ullmann Ltd United Kingdom FC Investment company 100.0 100.0
Société Française et Suisse France FC Investment company 100.0 100.0
Flandres Contentieux France FC Service company 100.0 100.0
Valeurs Mobilières Elysées France FC Investment company 100.0 100.0
Removals
Merger
Thasosfin1
Non-consolidated entities
HSBC Continental Europe interest
(%)
Non Consolidated Companies Country of incorporation or registration Reason of non-consolidation 2020 2019
SNCB/M6 2007 A France Not consolidated in accordance with IFRS 10 100.0 100.0
SNCB/M6 2007 B France Not consolidated in accordance with IFRS 10 100.0 100.0
SNCB/M6 2008 A France Not consolidated in accordance with IFRS 10 100.0 100.0
SAS CYATHEAS PASTEUR France Not consolidated in accordance with IFRS 10 — 94.9
SNC KEROUAN France Not consolidated in accordance with IFRS 10 — 99.99
SNC Les MERCURIALES France Not consolidated in accordance with IFRS 10 99.99 99.99
SNC MAKALA France Not consolidated in accordance with IFRS 10 99.99 99.99
SNC DORIQUE France Not consolidated in accordance with IFRS 10 99.99 99.99
GIE GNIFI France Not consolidated in accordance with IFRS 10 25.0 25.0
CCF Finance Moyen Orient SAL Lebanon In the course of liquidation since 2002 99.9 99.9
CCF Holding Liban SAL Lebanon In the course of liquidation since 2002 75.0 75.0
At 31 December 2020, PVIF amounted to EUR 490 million, versus EUR 613 million at 31 December 2019.
See Notes 1.2 and 20 to the consolidated financial statements.
At 31 December 2020, instruments classified as level 3 in the fair value hierarchy represented EUR 3,850 million recognised under assets and
EUR 929 million recognised under liabilities.
See Notes 1.2 and 11 to the consolidated financial statements.
Application of IFRS 9 in the calculation of impairment of loans to HSBC Continental Europe business customers
Description of risk How our audit addressed this risk
The determination of expected credit losses (ECLs) requires Management has put in place controls designed to ensure the reliability of the
management’s judgement and the corresponding estimates are subject calculation of expected credit losses (ECLs). In this context, we tested the
to a high degree of uncertainty, which grew during the Covid-19 crisis. controls we deemed key to our audit, in order to assess the relevance of the
Management uses multiple assumptions to estimate ECLs. In the course impairment losses recorded, in particular:
of our audit, we focus on the following main assumptions: risk inputs, • the examination and comparative review of several economic scenarios and
the determination of forward-looking economic scenarios and their their probability by a group of experts and an internal governance committee;
probability, business customer risk ratings (CRRs) and the recoverability • the effectiveness of the credit committees set up to assess and approve the
of the loans. estimated impairment, particularly the judgement exercised by management
These assumptions are used in complex, tailor-made models that are to determine the adjustments to be applied;
developed using risk inputs based on historical data which, in the • the validation and monitoring of models;
current economic environment, generated an inappropriate level of
• the credit reviews used to determine customer risk ratings for business
estimated ECLs.
portfolios;
With regard to the determination of forward-looking economic
• the entering of critical data in the source systems, as well as the flow and
scenarios, the Covid-19 crisis triggered unprecedented economic
transformation of the data between the source systems and the engine for
conditions that vary depending on the country and business sector. The
calculating impairment losses;
support programmes introduced by governments together with the
action taken by regulators had an impact on economic factors such as • the calculation and approval of post-model adjustments and expected credit
GDP and the unemployment rate. These inputs therefore limited and losses based on the judgement of the Credit Risk department.
changed the extent and duration of customer defaults. These factors We called upon our experts to assess the reasonableness of the macro-economic
increased the uncertainty surrounding the estimates used to determine variables forecasts, particularly regarding the estimated probability of various
the severity and probability of the impacts of the crisis on scenarios. They examined the sensitivity of expected credit losses to these
macroeconomic variables (MEV) through the different economic assumptions.
scenarios used in the ECL models. We also assessed the relevance of the model methodologies that had not
Lastly, the customer risk ratings (CRRs) used to determine impairment changed during the year, notably taking into account Covid-19 and the need to
were adjusted based on quantitative data and qualitative criteria in order use post-model adjustments. Where expected credit losses were adjusted, we
to reflect the material increase in credit risk due to the Covid-19 crisis. assessed the impairment losses determined by management and the supporting
Accordingly, ECLs were significantly adjusted to take account of these analysis.
uncertainties. The type and scope of these adjustments, which may or In addition, we assessed the level of ECLs using a sample of business customer
may not be based on models and are determined based on the loans, and the relevance of management’s judgement, particularly post-model
judgement of the Credit Risk department, vary depending on the adjustments, the level of customer risk ratings and expert valuations.
business portfolio. We also assessed the information on credit risk provided in the consolidated
Given the Bank’s outstanding loan balances, the uncertainty of the financial statements for the year ended 31 December 2020.
assumptions used and the higher degree of judgement exercised by
management, within the context of the Covid-19 crisis, to estimate the
amount of ECLs, we deemed this to be a key audit matter.
Impairment of loans to Bank customers stood at EUR 904 million at 31 December 2020.
See Note 1.2 to the consolidated financial statements and page 106 of the management report.
Impairment of property, plant and equipment and intangible assets (excluding goodwill)
Description of risk How our audit addressed this risk
The Covid-19 crisis had a significant impact on the global economy and We called upon valuation (particularly real estate) and accounting standards
therefore on the economic performance of HSBC Continental Europe in experts in our network to verify the relevance and appropriateness of the
2020 and on its forecasts for 2021, which situation management methods used to calculate the recoverable amount of intangible assets and
considered to constitute an indication of potential impairment. property, plant and equipment.
Management therefore decided to carry out impairment tests on all We verified the calculations performed by management.
property, plant and equipment and intangible assets held by HBCE, With regard to the main assumptions used in the models, we:
mainly by comparing the carrying amount of the assets with their
• discussed the relevance of the budget prepared by management, in particular
recoverable amount.
given the economic environment;
Recoverable amount is estimated using a certain number of
• assessed, with the help of our valuation experts, the assumptions used by
assumptions, particularly:
management to determine the impairment to be recognised against property,
• an estimate of future cash flows, long-term growth rates and plant and equipment;
discount rates, mainly to determine the estimated value in use (VIU)
• assessed the sensitivity of the estimated value in use of intangible assets to
of other intangible assets;
the different assumptions used, particularly the discount rate.
• changes in the French real estate office market in the current
We also assessed the information on property, plant and equipment and
environment, particularly with more widespread remote working;
intangible assets provided in the consolidated financial statements for the year
• the type and location of rented real estate assets. ended 31 December 2020.
These different assumptions are subject to estimation uncertainty and
are mainly based on data from internal and external experts contracted
by management, market data and the judgement of management,
particularly with regard to the preparation of the budget for 2021-2025
and therefore the forecasts for income, cost savings, growth rates and
discount rates.
Following the impairment tests, management recognised an impairment
loss of EUR 294 million against intangible assets and EUR 206 million
against property, plant and equipment. At 31 December 2020, non-
impaired intangible (excluding goodwill) and property, plant and
equipment amounted to EUR 23 million and EUR 892 million
respectively. In light of the above, we deemed the impairment of
intangible assets and property, plant and equipment to be a key audit
matter for HSBC Continental Europe’s consolidated financial statements.
Specific verifications
As required by legal and regulatory provisions and in accordance with professional standards applicable in France, we have also verified
the information pertaining to the Group presented in the Board of Directors’ management report.
We have no matters to report as to its fair presentation and its consistency with the consolidated financial statements.
We attest that the Group management report includes the consolidated non-financial information statement required under article
L.225-102-1 of the French Commercial Code. However, in accordance with article L.823-10 of the French Commercial Code, we have not
verified the fair presentation and consistency with the consolidated financial statements of the information given in that statement, which
will be the subject of a report by an independent third party.
Our report to the Audit Committee includes the risks of material misstatement that, in our professional judgement, were the most
significant in the audit of the consolidated financial statements and which constitute the key audit matters that we are required to
describe in this report.
We also provide the Audit Committee with the declaration provided for in article 6 of Regulation (EU) No 537/2014, confirming our
independence within the meaning of the rules applicable in France, as defined in particular in articles L.822-10 to L.822-14 of the French
Commercial Code and in the French Code of Ethics for Statutory Auditors. Where appropriate, we discuss any risks to our independence
and the related safeguard measures with the Audit Committee.
Assets
(in millions of euros) Notes 31 Dec 2020 31 Dec 2019
Cash and amounts due from central banks and post office banks 4,970 4,683
Treasury bills and money-market instruments2 4 20,700 20,574
Loans and advances to banks3 2 42,138 96,318
Loans and advances to customers4 3 64,100 82,094
Bonds and other fixed income securities2 4 4,420 5,628
Equities and other variable income securities 4 158 244
Investments in subsidiaries and equity securities held for long term 5 85 86
Interests in affiliated parties 5 1,359 1,353
Finance leases 7 448 522
Intangible fixed assets 6 42 347
Tangible fixed assets 7 79 181
Other assets 9 33,261 26,201
Prepayments and accrued income 10 54,134 42,528
Total assets 225,894 280,759
Off-balance sheet items
Financing commitments given 21 47,223 40,093
Guarantees and endorsements given 21 9,695 10,398
Securities commitments (other commitments given) 47,328 51,881
Liabilities
(in millions of euros) Notes 31 Dec 2020 31 Dec 2019
Central bank and post office banks 13 39
Deposit due to credit institutions4 11 28,896 82,458
Customer accounts3 12 63,319 67,474
Debt securities in issue 13 17,319 24,805
Other liabilities2 15 53,455 54,089
Accruals and deferred income 16 53,704 42,493
Provisions for liabilities and charges 14 593 400
Subordinated liabilities 17 2,629 2,128
Share capital 18 491 491
Additional paid-in capital 19 2,155 2,158
Equity 19 1,041 1,041
Special tax-allowable reserves 19 — —
Retained earnings1 19 3,185 3,330
Net profit (loss) for the period 19 (906) (147)
Interim dividend 19 — —
Total liabilities 225,894 280,759
Off-balance sheet items
Financing commitments received 21 3,324 5,479
Guarantees and endorsements received 21 17,931 16,692
Securities commitments (other commitments received) 47,908 46,293
1 Number of shares outstanding at year end: 98,231,196 in 2020 and 98,231,196 in 2019.
2020 Highlights
Business review
Net banking operating income was EUR 1,736 million, down EUR 57 million compared to 2019. This decrease is due to the
degradation of economic and financial conditions, while the persistence of a low interest rates environment continued to impact the net
interest income.
General operating expenses were to EUR 2,007 million, up EUR 304 million compared to the previous year. This increase is mainly
driven by restructuring costs of for EUR 258 million and a EUR 49 million increase of the Single Resolution Fund contribution.
Depreciation, amortisation and impairment of tangible and intangible assets was EUR 486 million, up EUR 327 million
compared to 2019, reflecting recent losses and deterioriation in the future forecast.
Loan impairment charges were EUR 211 million up from EUR 133 million in 2019. This increase in all global businesses, is mainly
explained by incremental charges on non-performing loans linked to the global impact of the Covid-19 outbreak and on the deteriorated
forward economic outlook.
Gains on disposals of long-term investments were EUR 73 million compared to a loss of EUR 8 million in 2019, primarily due to the
sale of Visa shares.
Net loss for the period was EUR 906 million compared to a net loss of EUR 147 million in 2019.
At 31 December 2020, the total balance sheet of HSBC Continental Europe amounted to EUR 226 billion compared to EUR 281 billion
at 31 December 2019.
Change of name and new headquarters
On 1 December 2020, HSBC France has changed its name to become HSBC Continental Europe. The new name better reflects the
purpose and nature of its activities, namely an integrated Continental European bank connecting our customers to HSBC’s global
network, and providing access to Continental Europe for HSBC’s customers around the world. The new headquarters for HSBC
Continental Europe is located at 38 avenue Kléber, 75116 Paris, France.
Impairment and write-off of intangible and tangible assets
During 2020, the HSBC Group considered the pervasive macroeconomic deterioration caused by the outbreak of Covid-19, along with the
impact on forecast profitability, to be an indicator of impairment. As a result, an impairment test was performed which led to the
recognition of EUR 400 million in non-financial asset impairments, of which capitalised software impairments and write-offs of EUR 308
million and EUR 92 million in tangible asset impairments. This impairment reflected recent losses and deterioration in the future
forecasts, substantially relating to prior periods. Refer to Note 1.a for related accounting policies and judgments, Note 6 intangible assets
and Note 7 tangible assets.
Recognition of restructuring costs
In line with the Group's Business Update announced in February 2020, HSBC Continental Europe has initiated its own
transformation programme during the year. In July, a social plan (‘Plan de Sauvegarde pour l’Emploi’) was presented for the GBM
business in France. Its objective is to preserve the bank’s future competitiveness and to focus on our strategic positioning while
reducing the size of the GBM business in France.
In October, a plan was presented to the European Work Council (‘EWC’) focused on the European Economic Area (‘EEA’)
branches of HSBC Continental Europe. The plan foresees increasing client-focused activities within the branches and to deliver a
more efficient operating and booking model, better leveraging HSBC Continental Europe’s wider operating infrastructure and
balance sheet.
Implementation of the plan is undertaken in accordance with the respective legal and social frameworks in each of the countries.
In December, a plan for collective voluntary departure (’Rupture Conventionelle Collective’) was presented focused on the CMB
business and Global Functions and HSBC Operations, Services and Technology. This initiative will enable us to better serve
commercial banking clients while focusing on clients valuing our international network. It will also improve operational efficiency
and simplify processes.
During 2020, HSBC Continental Europe recognised EUR 258 million on termination benefits for restructuring costs relating to
these plans. Refer to Note 14 Provisions.
Derecognition of Deferred Tax Assets (‘DTAs')
Considering the recent losses incurred and the wider context of uncertainty, it was judged that the net deferred tax asset (’DTA‘) should
be written off and no further net DTA should be recognised. Recognition will be reassessed at each balance sheet date. Refer to Note 30
Tax expense and deferred tax.
Funding through Targeted Long-Term Refinancing Operation (‘TLTROs’)
In June 2020, HSBC Continental Europe repaid EUR 2.6 billion in TLTRO II funding and issued EUR 10.6 billion in TLTRO III funding.
Borrowing rates for TLTRO III are at below-market rates as they are issued at, or below, the deposit facility rate. Borrowing rates in these
operations can be as low as 50 basis points below the average interest rate on the deposit facility rate over the period 24 June 2020 to 23
June 2022, capped at -1 per cent, and as low as the interest rate on the deposit facility during the rest of the life of the respective TLTRO
III, if the entity’s benchmark lending is maintained at a prescribed level over specific periods. During 2020, HSBC Continental Europe
judged there to be reasonable assurance that the conditions attached to TLTRO III will be complied with and that the below market rate
foreseen in the first twelve months will be received.
HSBC Holding plc whose head office is located in London, is responsible for consolidated financial statements. HSBC Continental Europe
is part of it, and is responsible for consolidated financial statements in the France perimeter. The head office of HSBC Continental Europe
is located in Paris. These consolidated financial statements are available on the website ‘www.hsbc.fr’ or ‘www.hsbc.com’.
The financial statements of HSBC Continental Europe are prepared in accordance with Regulations 2014-03 and 2014-07.
Regulations and accounting policies adopted in 2020
On 22 December 2020, the National Standard Setter adopted Regulation n°2020-10 as an amendment to ‘Regulation n°2014-07 of
26 November 2014 relating to the accounts of companies in the banking sector’. Following these amendments, HSBC Continental Europe
has applied offsetting for securities borrowing and regulated saving accounts centralised at the Caisse des Dépôts et Consignations. In
addition, in 2020 HSBC Continental Europe adopted a voluntary change in accounting policy enabling offsetting to be applied where it
has been established that reciprocal obligations are settled on a net basis with the same counterparty, currency and maturity date, and
where agreements are in place for which the right of offset can be exercised.
(a) Initial recognition and subsequent measurement of tangible and intangible assets
HSBC Continental Europe applies the component approach in the recording and amortising of fixed assets.
HSBC Continental Europe complies with ANC Regulation 2014 03 and in particular with articles 214 1 to 214 27 for initial recognition,
amortisation and impairment of tangible assets.
Investment property and operational building
For operating and investment fixed assets, HSBC Continental Europe adopted the components approach with the following minimum cap
on the useful lives and methods of the corresponding components:
Components Periods and depreciation and amortisation methods
Infrastructure
Building 25 and 50 years on a straight-line basis
Civil engineering works 25 years on a straight-line basis
Technical installations
Air conditioning Ventilation Heating 10 years on a straight-line basis
Electrical installations 10 years on a straight-line basis
Telephone and electrical fittings 10 years on a straight-line basis
Security fittings 10 years on a straight-line basis
Fittings
Improvements and internal fittings 10 years on a straight-line basis
Goodwill
Acquired goodwill is subject to impairment on the basis of objective indicators.
Goodwill on merger
The goodwill is affected under the terms provided in accordance with the article 745-6 of regulation 2014-03 to the different concerned
assets, and recorded in the accounts under the rules set down in the article 745-7.
The goodwill is amortised or reported in the income statement, under the same rules and conditions as underlying assets to which it is
assigned. (See Note 6).
Loans and receivables are classified according to HSBC Continental Europe’s internal loan rating system. Performing loans have a rating
of between 1 and 8, non-performing loans have a rating of 9 and impaired loans, including doubtful loans not yet written off, have a
rating of 10.
The following are therefore classified as non-performing loans:
• receivables overdue for more than three months for all types of loans and equipment leases, more than six months for property loans
or leases and more than nine months for loans to local government bodies;
• receivables having risk criteria;
• receivables deriving from debt restructuring for which the debtor is again in default.
HSBC Continental Europe applies the provisions of articles 2221-2 of 2014-07 ANC regulation on identifying overdrafts at risk of default.
For overdrafts, the overdue period starts when:
• the debtor exceeds an authorised limit that has been notified to him by HSBC Continental Europe; or
• the debtor is notified that the amount outstanding exceeds a limit set up by HSBC Continental Europe under its internal control
system; or
• the debtor withdraws amounts without overdraft authorisation.
The downgrade to non-performing loans immediately leads to all amounts outstanding and commitments for that debtor that are in the
same category, according to contagion principle and, if applicable, the downgrade of counterparties belonging to the same group to non-
performing debtors, on a case-by-case assessment.
In application of the article 2221-8, 2231-3 of 2014-07 ANC regulation on accounting treatment at credit risk, HSBC Continental Europe
has introduced a specific system for dealing with restructured debt and impaired loan.
In application of the articles 2221-8 of 2014-07 ANC regulation, impaired loans are those for which the prospect of recovery is very
remote and for which a write-off is being considered. These include receivables which are long overdue or for which the contract has
been terminated in case of leasing, and also receivables that have been categorised as non-performing for more than one year, unless
final write-off is not being considered because of information on the prospects for recovery available at that stage. Interests on impaired
loans are not recognised through profit or loss until the date of actual payment.
Reclassification into performing loans
In application of the article 2221-5 of the 2014-07 ANC regulation, a loan that has been classified as non-performing may be reclassified
as performing when the original scheduled payments have been resumed without further incident.
In the case of restructured loans, the classification of doubtful exposure can be omitted, if the exposure complies firstly with the previous
condition, and, on the other hand, the counterparty risk is lifted.
Risk mitigation instruments
The bank uses the customary risk mitigation instruments including guarantees and collateral (which is re-measured at least annually
depending on its nature) and, to a minor extent, the purchase of credit default swaps (‘CDS’). In this latter case, the risk mitigation impact
is only recognised if the CDS meets the relevant regulatory conditions for recognition (term, currency, etc.).
Recognition of gains and losses
Charges for impairment against non-performing and impaired loans, included in the calculation of the banking result, are determined
annually on the basis of the non recovery risk assessment by analysing each loan individually. In application of the article 2231-1 of the
2014-07 ANC regulation, impairment of non-performing and impaired loans has been calculated on the basis of the difference between
the net present value of expected future recoveries and the carrying amount of the loan. Impairment may not be less than the amount of
unpaid, recognised interest on the loan.
In the income statement, charges and releases of provisions, losses on irrecoverable receivables and recoveries on amortised receivables
are recognised in the ‘Loan impairment charges’ line.
Loans assessed on a portfolio basis
Non-performing loans are not measured on a portfolio basis. Impairment is assessed individually.
Discount on restructured debt
In application of articles 2221-5 and 2231-3 of the 2014-07 ANC regulation, HSBC Continental Europe applies a specific system for
dealing with restructured debt.
On restructuring, any waived principal and interest, accrued or due, is written off.
Moreover, at the time of restructuring, a discount is provided for on the restructured debt for the difference between the present value of
initially anticipated contractual cash flows and the present value of future cash flows of principal and interest arising from the
restructuring plan. The discount rate used is the original effective interest rate for fixed interest loans, or the most recent effective rate
before the restructuring calculated in accordance with contractual terms for floating-rate loans.
This discount is recognised in the net cost of risk on restructuring and is then written back through net interest income over the
remaining period.
Application of the effective interest rate
All liabilities are recognised at amortised cost. These headings include repurchase transactions. Accrued interest on these liabilities is
recorded in the balance sheet in an accrued interest account.
1 Refer to Note 1. In 2019, EUR 2,182 million in loans and advances centralised at the Caisse des Dépôts et Consignation would have been
presented net against regulated savings accounts and EUR 49,739 million in reverse repurchase agreements would have been presented net.
1 Refer to Note 1. In 2019, EUR 4,852 million in reverse repurchase agreements would have been presented net.
2 This is explained by the decrease in the reverse repurchase activity.
1 Refer to Note 1. In 2019, EUR 3,115 million assets arising from securities borrowing transactions would have been deducted from corresponding
liabilities.
The financial investments portfolio is made up mainly of fixed income securities for which the interest-rate risk is usually hedged. The
portfolio valuation rules are given in Note 1b.
Additional information on the securities given in compliance with ANC 2014-07 regulation dated
26 November 2014
No held-to-maturity securities have been sold during the period.
The premium (Unamortised difference between the acquisition price and the redemption price of securities) of available-for-sale and held-
to-maturity securities amounted to EUR 76 million in 2020 and to EUR 36 million in 2019.
No security was transferred from one portfolio to another portfolio in 2020 or in 2019.
6 Intangible assets
Since 1 January 2016 and according to 2015-06 ANC new regulation of 23 November 2015 which modifies 2014-03 ANC regulation, the
goodwill is recognised in a specific account in the relevant asset category after its affectation (art 745-6). The amortisation method and
period are the same as those applied to amortised assets it is linked to (art 745-7).
Goodwill is impaired when the current value of one or more underlying assets, to which a portion of it was affected, is lower than the
carrying amount of the asset(s) plus the attributed goodwill. The current value is the higher of the market value and the value-in-use (see
articles 214-1 to 214-27 of 2015-06 ANC regulation).
Finance lease
31 Dec 2020 31 Dec 2019
€m €m
Assets under construction 3 3
Gross amount1 926 945
Amortisation (481) (427)
Accrued interests — 1
Total 448 522
1 Main assets in 2020: road assets for EUR 348 million, public building and construction for EUR 104 million, IT Office for EUR 175 million.
At 31 December 2020, the financial outstanding amounts to EUR 476 million (EUR 506 million in 2019) and the provision for negative
unearned finance income before deferred tax to EUR 33 million (EUR 52 million in 2019).
8 Loan impairment
Unused
Balance at Amounts amounts Other Balance at
1 Jan 2020 Additions utilised reversed movements 31 Dec 2020
€m €m €m €m €m €m
Impairment on interbank and customer non-performing loans
(excluding doubtful interest) 570 247 (50) (125) (4) 638
Impairment on securities — — — — — —
Provisions for loans commitments 38 36 — (19) (11) 44
Total of impairment and provisions
recognised in cost of risk 608 283 (50) (144) (15) 682
9 Other assets
1 Including mark-to-market on derivatives instruments for EUR 53,173 million in 2020, and 41,250 millions EUR in 2019.
11 Deposit by banks
Deposits by banks
31 Dec 2020 31 Dec 2019
€m €m
Total 28,896
Netting on repurchase agreements1 29,434 —
Total before netting 58,330 82,458
1 Refer to Note 1. In 2019, EUR 49,739 million in repurchase agreements would have been presented net.
12 Customer accounts
1 Refer to Note 1. In 2019, EUR 2,182 million in loans and advances centralised at the Caisse des Dépôts et Consignation would have been
presented net against regulated savings accounts and EUR 4,852 million in repurchase agreements would have been presented net.
Issuance premium to be amortised is EUR 9.8 million at 31 December 2020 compared to EUR 13 million at 31 December 2019.
14 Provisions
Unused
Balance at Amounts amounts Other Balance at
1
1 Jan 2020 Additions utilised reversed movements 31 Dec 2020
€m €m €m €m €m €m
Provisions for commitments by signature and disputes 76 36 (2) (20) (12) 78
Other provisions 324 298 (92) (17) 2 515
Total 400 334 (94) (37) (10) 593
Provision on PEL/CEL
31 Dec 2020
PEL
> 4 years and
≤ 4 years ≤ 10 years > 10 years Total CEL
€m €m €m €m €m
Amounts collected 19 277 390 686 88
Outstandings collected — — — — —
Provisions — — (6) (6) —
Allocation to provisions/reversal — — — — —
15 Other liabilities
1 Refer to Note 1. In 2019, EUR 3,115 million assets arising from securities borrowing transactions would have been deducted from corresponding
liabilities.
2 Of which deposits on derivatives received in 2020: EUR 16,283 million and EUR 11,610 million in 2019.
1 Including mark-to-market on derivatives instruments: EUR 52,474 million in 2020 and EUR 41,270 million in 2019.
17 Subordinated debt
Subordinated debts are dated or undated, loans or securities, for which repayment is subordinated to other creditors in case of
liquidation.
Accrued interest, if any, on these subordinated securities is recognised in the balance sheet in an accrued interest account with a
corresponding amount recognised in profit and loss.
31 Dec 2020 31 Dec 2019
€m €m
Subordinated notes — —
Undated subordinated notes 16 16
Subordinated debts 2,610 2,110
Accrued interest 2 2
Total 2,629 2,128
Participating securities are refunded at a price equal to the par only in the case of the liquidation of the company.
Subordinated debts
Date of Currency of 31 Dec 2020 31 Dec 2019
Date of issue maturity Interest type issue €m €m
Subordinated debts1 22.12.2014 22.12.2029 Floating rate EUR 260 260
Fixed rate as defined
Undated debts2 26.05.2017 perpetual on the contract EUR 200 200
Fixed rate as defined
28.03.2018 perpetual on the contract EUR 300 300
16.12.2019 perpetual Floating rate EUR 250 250
Subordinated debts3 26.05.2017 26.05.2027 Floating rate EUR 300 300
21.06.2018 21.06.2028 Floating rate EUR 300 300
29.01.2019 29.01.2029 Floating rate EUR 400 400
27.07.2019 27.06.2029 Floating rate EUR 100 100
22.05.2020 22.05.2030 Taux variable EUR 500 —
Accrued interest 2 2
Total for securities issued by HSBC Continental Europe (including accrued interest) 2,612 2,112
1 A total or a part refund will be possible from December 2024. The subordinated liabilities conversion in equity or in debt is not possible.
2 Tier 1: A total or a part refund (Additional Tier 1) will be possible, under certain conditions, from the 26th of May 2022. The conversion in capital of
these shares will be possible under certain conditions.
3 Tier 2: A total or a part refund (Tier 2) will be possible, under certain conditions, from the 26th of May 2022. The subordinated liabilities conversion
in equity or in debt is not possible.
Voting rights
At 31 December 2020, the total of voting rights stood at 98,231,196.
19 Equity
1 Before proposed appropriation submitted to HSBC Continental Europe Annual General Meeting's approval.
Legal reserve
This reserve is built up by appropriating at least one-twentieth of the year’s profit. This appropriation ceases to be mandatory once this
reserve reaches one-tenth of share capital. It is not distributable.
Net long-term gains reserve
Distributing this reserve would lead to an additional tax charge equal to the difference between standard tax rate and reduced tax rate.
Revaluation reserve (1976 revaluation)
This reserve could be incorporated into capital, but it cannot be distributed or used to offset losses.
Other reserves
Amounts put into reserves over five years ago would be subject to a levy if they were to be distributed.
For distributions paid on or after 1 January 2000, HSBC Continental Europe can charge the dividends against profits liable to corporate
income tax for accounting periods ended at most five years ago, starting with the oldest, in application of the decree of 21 December
1999.
1 Including defined benefits pension plans for Executive Board for EUR 5.1 million in 2020 and for EUR 4.9 million in 2019.
Rate of increase
for pensions in
payment and Rate of pay
(in %) Discount rate Inflation rate deferred pensions increase
At 31 Dec 2020 0.4 1.50 0.40 2.57
At 31 Dec 2019 0.65 1.50 1.50 2.61
HSBC Continental Europe determines discount rates in consultation with its actuaries based on the current average yield of high quality
(AA-rated) debt instruments, with maturities consistent with that of the defined benefit obligation.
Provision recognised
31 Dec 2020 31 Dec 2019
€m €m
Present value of benefit obligations 163 178
Fair value of plan assets (6) (7)
Net liability recognised 158 171
The components of the table below have been recognised in on profit & loss.
1 Includes curtailment effect of EUR (21) million in 2020 linked to restructuring plans and EUR 5 million due to the change in actualisation rate and
social charges rate.
1 Primarily new commitments for customers transferred from HSBC Bank plc to HSBC Continental Europe during 2020.
22 Derivatives
1 Interest rate swaps accounted for as micro-hedging are used to hedge interest and currency rate risk of an asset or a liability at the beginning of
the transaction.
2 Interest rate swaps accounted for as macro-hedging are used to hedge and to manage the global interest rate risk of portfolio of assets and
liabilities of the bank.
Modification made to the data published at the end of 2019 to correct the allocation of our credit risk equivalents on derivative products
linked to collateral posted to our counterparties. These credit risk equivalents are indeed part of contracts negotiated within the
framework agreement and benefit from a compensation effect (Section A). They were incorrectly reported under ‘Other contracts’ –
Heading B on the 2019 note.
1 Refer to Note 4.
1 Includes termination benefits arising from restructuring plans. Refer to '2020 Highlights'.
HSBC group entities, including HSBC Continental Europe entities, are party to various significant legal proceedings and regulatory
matters arising out of their normal business operations. Apart from the matters described below and in the section 2.19a Legal Risks and
Litigation management of the 2020 Registration Document, HSBC Continental Europe considers that none of these matters is significant.
HSBC Continental Europe recognises a provision for a liability in relation to these matters when it is probable that an outflow of economic
benefits will be required to settle an obligation which has arisen as a result of past events, and for which a reliable estimate can be made
of the amount of the obligation. Any provision recognised does not constitute an admission of wrongdoing or legal liability. While the
outcome of these matters is inherently uncertain, management believes that, based on the information available to it, appropriate
provisions, as necessary, have been made in respect of such legal proceedings as at 31 December 2020.
Anti-money laundering and sanctions-related matters
In December 2012, among other agreements, HSBC Holdings agreed to an undertaking with the UK Financial Services Authority which
was replaced by a Direction issued by the UK Financial Conduct Authority ('FCA') in 2013, and again in July 2020, and consented to a
cease-and-desist order with the Federal Reserve Board (‘FRB’), both of which contained certain forward-looking anti-money laundering
(‘AML’) and sanctions-related obligations. HSBC also agreed to retain an independent compliance monitor (who is, for FCA purposes, a
‘Skilled Person’ under section 166 of the Financial Services and Markets Act, and for FRB purposes, an ‘Independent Consultant’) to
produce periodic assessments of the Group’s AML and sanctions compliance programme (the ‘Skilled Person/ Independent Consultant’).
In December 2012, HSBC Holdings, entered into an agreement with the office of Foreign Assets Control ('OFAC') regarding historical
transactions involving parties subject to OFAC sanctions.
HSBC’s engagement with the Skilled Person appointed pursuant to the 2013 Direction was terminated in February 2020 and a new
Skilled Person with a narrower mandate has been appointed to assess the remaining areas that require further work in order for HSBC to
transition fully to business-as-usual financial crime risk management. A new Independent Consultant is also being appointed to continue
to carry out an annual OFAC compliance review at the FRB’s discretion.
Bernard L. Madoff Investment Securities LLC
Bernard L. Madoff (‘Madoff’) was arrested in December 2008 in the United States and later pleaded guilty to running a Ponzi scheme. His
firm, Bernard L. Madoff Investment Securities LLC (‘Madoff Securities’), is being liquidated in the US by a trustee (the ‘Trustee’).Various
non-US HSBC companies provided custodial, administration and similar services to a number of funds incorporated outside the US
whose assets were invested with Madoff Securities.
Various HSBC companies have been named as defendants in lawsuits arising out of Madoff Securities' fraud, amongst which are HSBC
Institutional Trust Services (Ireland) DAC and/or its subsidiary Somers Dublin DAC.
On 1 August 2018 HSBC Continental Europe acquired from HSBC Bank plc 100 per cent of the shares of HTIE. Pursuant to the terms of
the Sale and Purchase Agreement, HSBC Continental Europe and/or its subsidiaries will be indemnified by HSBC Bank plc in respect of
certain liabilities relating to the activities and/or Somers Dublin DAC prior to the acquisition of HTIE (newly HSBC Continental Europe
Dublin Branch).
The Madoff-related proceedings that HTIE and/or Somers Dublin DAC are involved in are described below:
Defender case:
In November 2013, Defender Limited brought an action against HTIE and others, based on allegations of breach of contract and claiming
damages and indemnification for fund losses. The trial commenced in October 2018. In December 2018, the Irish Court issued a
judgement in HTIE’s favour on a preliminary issue, holding that Defender Limited had no effective claim against HTIE. This judgement
concluded the trial without further issues in dispute being heard. In February 2019, Defender Limited appealed the judgement. In July
2020, the Irish Supreme Court ruled in part in favour of Defender Limited and returned the case to the High Court for further proceedings,
which will resume in April 2021.
US litigation:
The Trustee has brought lawsuits against various HSBC companies and others in the US Bankruptcy Court for the Southern District of
New York (the ‘US Bankruptcy Court‘), seeking recovery of transfers from Madoff Securities to HSBC in an amount not yet pleaded or
determined. HSBC and other parties to the actions have moved to dismiss the Trustee’s claims. The US Bankruptcy Court granted
HSBC’s motion to dismiss with respect to certain of the Trustee’s claims in November 2016. In February 2019, the US Court of Appeals
for the Second Circuit (the ’Second Circuit Court of Appeals’) reversed that dismissal. Following the US Supreme Court’s denial of
certiorari in June 2020, the cases were remanded to the US Bankruptcy Court, where they are now pending.
HSBC Continental Europe does not hold any direct or indirect presence in any non-cooperative States or territories in accordance with the
article 238-0 A of the General Tax Code.
There was no material event subsequent to the reporting date that would require a correction or adjustment to the statutory financial
statements as at 31 December 2020.
New products and services are offered to customers of the HSBC Group in Continental Europe on a regular basis. Information is available
on the Group’s websites, in particular in the press releases posted at www.hsbc.fr.
There has been no significant change affecting the financial or sales situation of HSBC Continental Europe or its subsidiaries since
31 December 2020 until the Board of Directors of 23 February 2021 which approves these financial statements.
B – Aggregate data concerning companies whose book value at cost does not exceed 1% of HSBC Continental Europe’s share capital
1 – Subsidiaries
a) French subsidiaries
(aggregated) — — — — — — — — — — —
b) Foreign subsidiaries
(aggregated) — — — — — — — — — — —
2 – Related party companies
a) French companies
(aggregated) — — — — 4 — — — — — —
b) Foreign companies
(aggregated) — — — — — — — — — — —
To the Shareholders,
Opinion
In compliance with the engagement entrusted to us by your Annual General Meeting, we have audited the accompanying financial
statements of HSBC Continental Europe for the year ended 31 December 2020.
In our opinion, the financial statements give a true and fair view of the assets and liabilities and of the financial position of the Company
at 31 December 2020 and of the results of its operations for the year then ended in accordance with French accounting principles.
The audit opinion expressed above is consistent with our report to the Audit Committee.
Basis for opinion
Audit framework
We conducted our audit in accordance with professional standards applicable in France. We believe that the audit evidence we have
obtained is sufficient and appropriate to provide a basis for our opinion.
Our responsibilities under these standards are further described in the “Responsibilities of the Statutory Auditors relating to the audit of
the financial statements” section of our report.
Independence
We conducted our audit engagement in compliance with the independence rules provided for in the French Commercial Code (Code de
commerce) and the French Code of Ethics (Code de déontologie) for Statutory Auditors, for the period from 1 January 2020 to the date of
our report, and, in particular, we did not provide any non-audit services prohibited by article 5(1) of Regulation (EU) No. 537/2014.
Emphasis of matter
Without qualifying our opinion, we draw your attention to Note 1 to the financial statements, which outlines changes in accounting
principles such as the adoption of Regulation 2020-10 of 22 December 2020 of the French accounting standard-setter (Autorité des
Normes Comptables – ANC) and the voluntary change in accounting method for the presentation of sale and repurchase agreements.
Justification of assessments – Key audit matters
Due to the global crisis related to the Covid-19 pandemic, the financial statements of this period have been prepared and audited under
specific conditions. Indeed, this crisis and the exceptional measures taken in the context of the state of sanitary emergency have had
numerous consequences for companies, particularly on their operations and their financing, and have led to greater uncertainties on their
future prospects. Those measures, such as travel restrictions and remote working, have also had an impact on the companies’ internal
organisation and the performance of the audits.
It is in this complex and evolving context that, in accordance with the requirements of articles L.823-9 and R.823-7 of the French
Commercial Code relating to the justification of our assessments, we inform you of the key audit matters relating to the risks of material
misstatement that, in our professional judgement, were the most significant in our audit of the financial statements, as well as how we
addressed those risks.
These matters were addressed as part of our audit of the financial statements as a whole, and therefore contributed to the opinion we
formed as expressed above. We do not provide a separate opinion on specific items of the financial statements.
Complex derivative financial instruments measured at fair value based on unobservable data
Description of risk How our audit addressed this risk
As part of its activities, HSBC Continental Europe holds complex derivative We tested the effectiveness of the controls we deemed key to our audit, put
financial instruments. in place by management to record, value and recognise these financial
Derivative financial instruments are financial assets or liabilities measured at instruments, and specifically those regarding:
fair value on the balance sheet. The offsetting entry for the remeasurement • the independent validation of valuation models by the Independent Model
of financial instruments at fair value at the reporting date is recognised in Review – Markets department;
profit or loss. The measurement of derivatives may require the use of
• the independent verification of prices and valuations by the Product
internally developed models using unobservable data such as long-term
Control department;
interest rates or volatilities for certain currencies. The measurement of more
complex instruments may require several unobservable inputs such as • the determination of fair value adjustments (“FVA”).
volatility surfaces, in whole or in part, for less commonly traded option We also sought the support of our experts in risk modelling to carry out, on a
products, and correlations between market factors such as foreign sample basis, an independent valuation of instruments measured based on
exchange rates, interest rates and equity prices. It also takes account of unobservable data, using their own models and market inputs in order to
adjustments for counterparty and liquidity risk. assess the valuations generated by HSBC Continental Europe’s internal
In view of the multiple inputs subject to management’s judgement, we models.
deemed the measurement of complex derivative financial instruments We examined the assumptions, methods and models used by the Bank to
whose fair value is based on unobservable data to be a key audit matter for estimate the main valuation adjustments (counterparty and liquidity risk) in
HSBC Continental Europe’s financial statements. order to assess their relevance.
At 31 December 2020, derivative instruments (including those whose fair value is measured based on unobservable data) represented EUR 53,173
million recognised under assets and EUR 52,474 million recognised under liabilities.
See Notes 10 and 16 to the financial statements.
Specific verifications
In accordance with professional standards applicable in France, we have also performed the specific verifications required by French
legal and regulatory provisions.
Information given in the management report and in the other documents provided to the shareholders with respect
to the Company’s financial position and the financial statements
We have no matters to report as to the fair presentation and the consistency with the financial statements of the information given in the
Board of Directors’ management report and in the other documents provided to the shareholders with respect to the Company’s financial
position and the financial statements, with the exception of the following matter.
Concerning the fair presentation and the consistency with the financial statements of the information about payment terms referred to in
article D.441-4 of the French Commercial Code, we have the following matter to report:
As indicated in the management report, this information does not include banking transactions and related transactions, as the Company
has decided that such transactions do not fall within the scope of the required information.
Report on corporate governance
We attest that the Board of Directors’ report on corporate governance sets out the information required by articles L.225-37-4 and
L.22-10-10 of the French Commercial Code.
Other verifications and information pursuant to legal and regulatory requirements
Presentation of the financial statements to be included in the annual financial report
Pursuant to paragraph III of article 222-3 of the AMF’s General Regulations, the Company’s management informed us of its decision to
postpone the application of the single electronic reporting format, as defined by European Delegated Regulation No. 2019/815 of 17
December 2018, to reporting periods beginning on or after 1 January 2021. Accordingly, this report does not contain a conclusion on the
compliance of the presentation of the financial statements to be included in the annual financial report referred to in paragraph I of article
L.451-1-2 of the French Monetary and Financial Code (Code monétaire et financier) with this format.
Appointment of the Statutory Auditors
We were appointed Statutory Auditors of HSBC Continental Europe by the Annual General Meetings held on 23 April 2015 for
PricewaterhouseCoopers Audit and on 10 May 2007 for BDO Paris Audit & Advisory.
At 31 December 2020, PricewaterhouseCoopers Audit and BDO Paris Audit & Advisory were in the sixth and thirteenth consecutive year
of their engagement, respectively.
Responsibilities of management and those charged with governance for the financial statements
Management is responsible for preparing financial statements giving a true and fair view in accordance with French accounting
principles, and for implementing the internal control procedures it deems necessary for the preparation of financial statements that are
free of material misstatement, whether due to fraud or error.
In preparing the financial statements, management is responsible for assessing the Company’s ability to continue as a going concern,
disclosing, as applicable, matters related to going concern, and using the going concern basis of accounting, unless it expects to
liquidate the Company or to cease operations.
The Audit Committee is responsible for monitoring the financial reporting process and the effectiveness of internal control and risk
management systems, as well as, where applicable, any internal audit systems relating to accounting and financial reporting procedures.
The financial statements were approved by the Board of Directors.
Responsibilities of the Statutory Auditors relating to the audit of the financial statements
Objective and audit approach
Our role is to issue a report on the financial statements. Our objective is to obtain reasonable assurance about whether the financial
statements as a whole are free of material misstatement. Reasonable assurance is a high level of assurance, but is not a guarantee that
an audit conducted in accordance with professional standards will always detect a material misstatement when it exists. Misstatements
can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to
influence the economic decisions taken by users on the basis of these financial statements.
As specified in article L.823-10-1 of the French Commercial Code, our audit does not include assurance on the viability or quality of the
Company’s management.
As part of an audit conducted in accordance with professional standards applicable in France, the Statutory Auditors exercise
professional judgement throughout the audit. They also:
• identify and assess the risks of material misstatement in the financial statements, whether due to fraud or error, design and perform
audit procedures in response to those risks, and obtain audit evidence considered to be sufficient and appropriate to provide a basis
for their opinion. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as
fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control;
• obtain an understanding of the internal control procedures relevant to the audit in order to design audit procedures that are
appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the internal control;
• evaluate the appropriateness of accounting policies used and the reasonableness of accounting estimates made by management and
the related disclosures in the notes to the financial statements;
Five-year highlights
(Articles R. 225-81 and R. 225-102 of the French Commercial Code)
2020 2019 2018 2017 2016
€m €m €m €m €m
Share capital at year end
Called up share capital 491 491 367 337 337
Number of issued shares 98,231,196 98,231,196 67,437,827 67,437,827 67,437,827
Nominal value of shares in euros 5 5 5 5 5
Results of operations for the year
Sales 3,285 3,560 3,043 2,869 2,847
Profit before tax, depreciation and provisions (455) (120) 59 238 292
Profit after tax, depreciation and provisions (906) (147) 78 172 117
Per share data (in euros)
Profit after tax, but before depreciation and provisions (5.8) (0.6) 1.3 3.3 4.5
Profit after tax, depreciation and provisions (9.2) (1.5) 1.1 2.5 1.7
Dividend paid per ordinary share, eligible as of 1 January — — — 1.66 4.00
Employees (France)
Number of employees1 8,835 9,314 8,377 8,080 8,382
Average number of employees (excluding employees available) 9,058 9,281 8,341 8,202 8,652
Salaries and wages 640 639 543 515 515
Employee benefits 248 247 249 249 249
Payroll and other taxes 58 53 64 61 63
Incentive schemes and/or employee profit-sharing scheme2 — 6 20 23 23
List of equity shares and debt securities held at 31 December 2020 (excluding trading securities)
Held-on maturity, available-for-sale and portfolio activity securities
31 Dec 2020
€m
A – Held-to-maturity securities 571
Debt securities 571
Treasury bills and other eligible bills —
Other public sector securities —
Money market instruments —
Negotiable certificates of deposit —
Negotiable medium-term notes —
Bonds and similar assets 570
Accrued interest 1
B – Available-for-sale and portfolio activity securities 7,434
Debt securities 7,276
Treasury bills and other eligible bills —
Other public sector securities 4,129
Money market instruments —
Commercial paper —
Negotiable certificates of deposit —
Negotiable medium-term notes —
Asset-backed securities —
Bonds and similar 3,130
Negotiable medium-term notes issued by banks —
Accrued interest 17
Equity shares 158
Equity shares and similar 158
Mutual fund units —
Total held-to-maturity, available-for-sale and portfolio activity securities 8,005
Asset Management
Insurance
Asset Management
(in thousands of euros)
HSBC Continental Europe
Total assets Shareholders’ funds Net profit group’s percentage
2020 2019 2020 2019 2020 2019 2020 2019
133,392 140,445 57,938 60,543 16,514 19,632 100 100
Profit before tax fell, reflecting lower fees mainly due the fall of equity market in March 2020 (Covid 19 crisis) and penalising the
year 2020. Assets managed and distributed amounted to EUR 86.5 billion compared with EUR 83.8 billion at end 2019. As in
HSBC Global Asset Management 2019, HSBC Global Asset Management (France) win some awards such as:
(France) • Multi-Asset (sur 1 an et 3 ans) pour le produits Multi-Asset Factors
• Obligations (‘ISR’), 2ème place (Les Globes de la Gestion)
• Obligations ‘ISR Government Bond’, Meilleur fonds Obligataire ISR (Etica -Italie)
• HSBC Continental Europe ‘Meilleur Gamme de Fonds Diversifiés’ (certificat Banques de Réseau)
74,022 57,047 31,796 21,252 (4 381) (4 455) 100 100
HSBC Epargne Entreprise (France) is an investment company, wholly-owned by HSBC Continental Europe, specialising in
HSBC Epargne Entreprise employee savings & pensions accounts administration for the HSBC Group in France. It has a clientele of 2,300 companies and
(France) manages 217,000 personal accounts. The employee savings funds it offers are managed by HSBC Global Asset Management
(France), with assets under management totaling EUR 3.8 billion as of 31 December 2020, making the Group the seventh-largest
employee savings manager in France. Its products are distributed via the HSBC Group distribution network in France, covering the
needs of companies of all sizes.
18,130 18,925 10,502 8,938 6,564 6,333 100 100
HSBC REIM (France) is the subsidiary of the Asset Management business specialising in real estate management on behalf of
third parties. As of 31 December 2020, the market value of assets under management was EUR 3.3 billion. The main fund
HSBC REIM (France) managed, Elysées Pierre is a Classic Real Estate Investment Placement Company which celebrated its 30th anniversary in 2016.
Its capitalisation of more than EUR 2.4 billion ranks it among the top 10 REITs on the market and the 126 component buildings of
its assets are mainly offices in Ile-de-France, one of the deepest and most liquid markets in Europe and in the world. This fund has
a return and valuation strategy that results in an internal rate of return (‘IRR’) over 10 years as at 31 December 2019 at 8.2 per
cent. The specialised press regularly praised the management qualities and the long-term performance of the SCPI.
Insurance
(in thousands of euros)
HSBC Continental Europe
Total assets Shareholders’ funds Net profit group’s percentage
2020 2019 2020 2019 2020 2019 2020 2019
23,301,030 23,451,308 891,769 822,326 63,927 58,870 100 100
HSBC Assurances Vie (France) manufactures a wide range of products and services to meet HSBC Group customer's needs
(individuals, professionals and companies) in terms of life insurance, pension and protection. In 2020, impacted by the sanitary
and economic crisis, insurance manufacturing gross written premium on saving stands at EUR 1,312 million (35 per cent down
HSBC Assurances Vie compared to 2019), including EUR 505 million on unit-linked contracts, which account for 39 per cent of new money compared to
(France) 25 per cent last year. The net new money was negative for HSBC Continental Europe Retails Network by EUR 175 million in 2020,
of which a positive net new money of EUR 268 million related to unit-linked contracts. The life insurance liabilities managed by
the insurance company now stand at EUR 23.2 billion compared to EUR 23.3 billion last year. Within these, unit-linked contracts
represent EUR 5.1 billion, increased by EUR 0.5 billion compared to 2019, due to the positive net new money and the favourable
variation of the fair value of contracts. The arbitrage movement towards unit-linked contracts amounts to + EUR 96 million on the
HSBC Continental Europe Retails Network.
Own investments
(in thousands of euros)
HSBC Continental Europe
Total assets Shareholders’ funds Net profit group’s percentage
2020 2019 2020 2019 2020 2019 2020 2019
9,496 9 502 9,492 9 496 (4) 5 100 100
Société Française et Suisse
(‘SFS’) Société Française et Suisse has yielded profit loss compared to 2019. The total balance sheet is mainly composed of free cash
flow.
49,830 56 668 49,517 54 804 (623) 4 658 100 100
Valeurs Mobilières Elysées is a subsidiary in which principal investments are booked under HSBC France. These investments
Valeurs Mobilières Elysées include listed midcaps and Private Equity funds. HSBC having decided in 2009 not invest any further in listed midcap shares,
Valeurs Mobilières Elysées manages a portfolio of gradually declining listed shares. No new Private Equity investments will be
booked under Valeurs Mobilières Elysées, therefore this portfolio will also decline gradually. Because of the pandemic, asset
valuation has taken a hit, therefore generating loss in 2020.
Voting under the quorum and majority conditions to transact Eighth resolution
ordinary business, the shareholders, having noted that the year
ended 31 December 2020 shows a net result of EUR Voting under the quorum and majority conditions to transact
- 906,098,899.83, hereby approve the proposed distribution of this special business, and having heard and considered the report of
net result made by the Board of Directors and resolve to the Directors, the shareholders hereby decide to amend Article 10
appropriate it as follows: of the Articles of Association, as follows:
Net result for the year EUR - 906,098,899.83 • The first sentence of the first indent becomes: "– the eight (8)
Plus retained profits EUR 3,184,897,620.24 members at the least and sixteen (16) at the most, appointed by
Total sum available for distribution EUR 2,278,798,720.41 the Ordinary General Meeting;"
The shareholders duly note that dividends paid in respect of the Ninth resolution
three previous financial years were as follows:
Voting under the quorum and majority conditions to transact
Year Net dividend per share
ordinary and special business, the shareholders hereby confer full
2017 EUR 1.66 powers on the bearer of an original, copy or abstract of the
2018 - minutes of this meeting for the purpose of completing any
2019 - formalities required by law.
Dividends paid in respect of the three previous years are eligible
for the tax deduction referred to in article 158 paragraph 3.2 of the
General Tax Code.
Third resolution
Voting under the quorum and majority conditions to transact
ordinary business, and having heard and considered the report of
the Directors and the report of the Statutory Auditors regarding
the consolidated statements for the year ended 31 December
2020, the shareholders hereby approve the consolidated financial
statements for that year as presented.
Fourth resolution
Voting under the quorum and majority conditions to transact
ordinary business, and having heard and considered the Statutory
Auditors’ report on regulated agreements governed by article L.
225-38 of the French Commercial Code, the shareholders hereby
approve successively the agreements described therein under the
conditions referred to in article L. 225-40 of said Code.
Fifth resolution
Voting under the quorum and majority conditions to transact
ordinary business, the Shareholders hereby ratify the co-optation
of Mr Stephen O’Connor decided by the Board on 12 February
2021 to replace Mr Nuno Matos, who resigned, for the remainder
of the term of office of his predecessor, that is until the conclusion
of the Annual General Meeting held to approve the financial
statements for the year ending 31 December 2021.
Information on the company HSBC Continental Europe – 38 avenue Kléber, 75116 Paris, France.
The Articles of Association of the Company can be found in the
Name ‘About HSBC’ section of the HSBC Continental Europe website
HSBC Continental Europe. New name of HSBC France since www.hsbc.fr.
1 December 2020. The information made available on hsbc.fr website are not part of
Commercial name the Universal Registration Document, unless the informations are
included by reference in the current Registration Document.
HSBC and, for the Private Banking business, HSBC Private
Banking. Financial year
Date of incorporation From 1 January to 31 December.
Approval will be given in the form of a notice, or will be deemed to In these cases, the rules governing approval and the buyback
have been given, in the absence of a reply within three months of conditions shall apply to the securities subscribed, and the time
the date of the request for approval. given to the Board of Directors to notify the third party subscriber
whether it accepts him as a shareholder shall be three months
The approval decision will be made by the Board of Directors, by a
from the date of final completion of the capital increase.
majority of the Directors present or represented. The transferor
shall be entitled to vote, if he is a Director. The decision will not be In the event of a buyback, the price shall be equal to the value of
justified, and in the event of a refusal, shall never give rise to any the new shares or negotiable securities giving access to the capital
claim. determined under the conditions provided by article 1843-4 of the
French Civil Code.
If the proposed transferee is approved, the transfer will be
completed in favour of the transferee upon presentation of the Custodian and financial service
supporting documents, which must be supplied within one month
of service of the decision of the Board of Directors, failing which a CACEIS Corporate Trust.
fresh approval will be required.
History of the company
If the company does not approve the proposed transferee, the
transferor will have a period of eight days from the date of service 1894: The Banque Suisse et Française (‘BSF’) is founded. It will
of the refusal to notify the Board whether or not he abandons his become the Crédit Commercial de France (‘CCF’).
proposal. 1987: CCF privatisation. Apart from its national network, CCF has
If the transferor does not expressly abandon his proposal under progressively created a group of regional banks operating under
the conditions set out above, the Board of Directors shall be their own brand.
obliged within a period of three months from the date of service of 1994: Centenary of CCF.
the refusal, to arrange for the purchase of the shares or negotiable
securities giving access to the capital, by a shareholder, a third 2000: CCF joins the HSBC Group and becomes the European
party, or, with the transferor’s consent, by the company, with a platform of the HSBC Group.
view to a reduction of the capital. 2002: Crédit Commercial de France changes its legal name to CCF.
In the event that the offered shares or negotiable securities giving 2005: CCF becomes HSBC France and certain of its subsidiaries
access to the capital are purchased by shareholders or third change their legal name and adopt the HSBC brand. HSBC France,
parties, the Board of Directors shall inform the transferor of the HSBC Hervet, HSBC de Baecque Beau, HSBC UBP and HSBC
names, forenames, profession and address of the purchasers, or of Picardie constitute the new HSBC network.
the company name and registered office in the case of a company.
The sale price shall be fixed by agreement between the purchasers 2008: Disposal by HSBC France of its regional banking
and the transferor. subsidiaries (Société Marseillaise de Crédit, Banque de Savoie,
Banque Chaix, Banque Marze, Banque Dupuy, de Parseval, Banque
In the event that the offered shares or negotiable securities giving Pelletier and Crédit Commercial du Sud-Ouest).
access to the capital are purchased by the company, the Board of
Directors must first ask for the transferor’s consent. The transferor 2008: Merger of HSBC Hervet, HSBC de Baecque Beau, HSBC
must give his answer within eight days of receiving this request. UBP and HSBC Picardie with HSBC France.
In the absence of agreement between the parties, the price of the 2011: Merger of HSBC Private Bank France with HSBC France.
shares and negotiable securities giving access to the capital shall 2013: HSBC France acquires HSBC Assurances Vie (France).
be determined by an expert valuation, under the conditions
2017-2018: Creation of branches in Greece, the United Kingdom,
provided by article 1843-4 of the French Civil Code.
Belgium, Luxembourg, Ireland, Italy, Poland, the Czech Republic,
If, upon the expiry of a period of three months, the purchase has the Netherlands and Spain.
not been completed, approval shall be deemed to have been
January 2018: Acquisition of certain assets and liabilities from the
given. However, this period may be extended by the courts on an
HSBC Bank plc branch in Greece and launch of the activities of the
application by the company.
HSBC France branch in Greece.
The transferor may, at any time, and at the latest within a period of
August 2018: Acquisition of HSBC Bank Polska S.A. and HSBC
eight days of determination of the price by the expert, abandon
Institutional Trust Services (Ireland) DAC.
the disposal of his shares or negotiable securities giving access to
the capital. February 2019: Acquisition of certain assets and liabilities from the
HSBC Bank plc branches in Belgium, Ireland, Italy, the Czech
Disposals to the purchaser or purchasers nominated by the Board
Republic, the Netherlands and Spain and launch of the activities of
of Directors shall be completed by means of a transfer order
the HSBC France branches in those countries.
signed by the Chairman of the Board of Directors, who shall serve
it to the transferor within eight days of its date, with an invitation March 2019: Acquisition of certain assets and liabilities from the
to attend the registered office to receive the sale price, which shall HSBC Bank plc branch in Luxembourg and launch of the activities
not bear interest. of the HSBC France branch in this country.
All notices, requests, answers, opinions, waivers, information and April 2019: Merger of HSBC Bank Polska S.A. and HSBC
consents provided for by this article shall be validly given if sent by Institutional Trust Services (Ireland) DAC with HSBC France.
extrajudicial instrument or by registered letter with proof of receipt May 2019: Creation of a branch in Sweden and launch of the
requested. activities in this branch in October 2019.
When an expert is used to determine the price of the shares or December 2020: HSBC France becomes HSBC Continental Europe
negotiable securities giving access to the share capital under the and transfers its registered office 38 avenue Kléber 75116 Paris.
conditions provided by article 1843-4 of the French Civil Code, the
expert’s fees shall be paid in equal shares by the assignor and
assignee.
This approval clause, which is the purpose of this article, also
applies to disposals of allocation rights in the event of capital
increases by way of incorporation of reserves, profits or issue
premiums, and disposals of subscription rights in respect of
capital increases in cash or individual waivers of subscription
rights in favour of named individuals.
1 Calculated on the weighted average number of shares outstanding after deducting own shares held.
2 Dividend paid as a percentage of reported earnings.
At the Annual General Meeting to be held on 11 March 2021, the Board will propose not to distribute a dividend in respect of year 2020.
Dividends which are not claimed within five years of the payment date lapse and become the property of the French Treasury.
Statutory Auditors’ fees paid in 2020 within the HSBC Continental Europe group are available in Note 6 to the consolidated financial
statements on page 190.
Cross-reference table
The following cross-reference table refers to the main headings required by the European regulation 2017/1129 (Annex I and Annex II)
implementing the directive known as ‘Prospectus’ and to the pages of the Universal Registration Document 2019 D.20-0071.
According to article 28 of the European Regulation 809/2004, are included by reference in this Registration Document:
• the consolidated financial statements for the year ended 31 December 2018 and the Statutory Auditors’ report on those consolidated
financial statements, presented on pages 146 to 219 and 220 to 224 of reference document D.19-0065 filed with the AMF on
20 February 2019; the information can be found here : https://www.hsbc.com/-/files/hsbc/investors/investing-in-hsbc/all-reporting/
subsidiaries/2018/annual-results/hsbc-france/190220-hbfr-ara-2018-fr.pdf
• the consolidated financial statements for the year ended 31 December 2019 and the Statutory Auditors’ report on those consolidated
financial statements, presented on pages 155 to 220 and 222 to 225 of reference document D.20-0071 filed with the AMF on
19 February 2020; the information can be found here : https://www.hsbc.com/-/files/hsbc/investors/investing-in-hsbc/all-reporting/
subsidiaries/2019/annual-results/hsbc-france/200219-hbfr-ara-2019-fr.pdf
These documents are available on the website www.hsbc.fr and on that of the Autorité des marchés financiers www.amf-france.org.
Anyone wishing to obtain additional information on the HSBC Continental Europe group can, without obligation, request the documents
by mail:
HSBC Continental Europe
38 Avenue Kléber
75116 Paris
France
This Registration Document includes the annual financial report: 2020
Parent company financial statements pages 237 to 264
Consolidated financial statements pages 164 to 230
Management report Refer to the Management report cross ref table Statement by person responsible pages 283 and 280
Statutory Auditors’ report pages 231 to 236 and 265 to 269
branch Bederstrasse 49
28020 Madrid
Telephone: +34 914 566 979
HSBC Continental Europe
branch
Plaza Pablo Ruiz Picasso, 1
Torre Picasso planta, 33
28020 Madrid
Telephone: +34 914 566 100