Credit Management October 2024

CREDIT MANAGEMENT
CM
OCTOBER 2024
THE CICM MAGAZINE FOR CONSUMER AND
COMMERCIAL CREDIT PROFESSIONALS
Sting in the tail
Prioritising consumer
welfare in BNPL
What does a new
digital pound mean
for business.
Page 20
How to combat
fraud in the
enforcement sector.
Page 42

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SEAN FEAST FCICM
MANAGING EDITOR
Editor’s column
WE NEED AN
ALTERNATIVE TO
ALTERNATIVE
IN the news this month, Charlotte Crosswell,
Chair of the Centre for Finance, Innovation
and Technology, says that the big banks are still
declining a huge number of loan applications.
She believes that the solution, in part at least, is
for them to embrace Open Banking to support
better lending decisions (see news page 28).
There will be many of you out there who don’t especially see
this as ‘news’ – or certainly she’s not telling us something
we don’t already know. As someone who has spent four
decades helping businesses communicate, I continue to
despair at the big banks’ abject failure in promoting their
work with small businesses.
I also despair at the lack of attention given to the concept
of Open Banking (or Open Finance) by all but a few, and
certainly not by the mainstream. Early myths have become
established as fact, and it seems like something that is
easier to park to one side for the moment, and let others
take the heat until it all settles down.
What irritated me though about the Charlotte Crosswell
story was what she went on to say, and the inference behind
it. She suggests that because the High Street Banks are
failing to provide the funds that small business are looking
for, those businesses are being pushed into the ‘alternative
finance sector’ – as though this was the equivalent of a
consumer failing to secure a loan from their bank and
having to visit a loan shark.
Now I may be overreacting, but I don’t think I am.
Why reference it if it wasn’t to be dismissive and
disparaging? And then it made me think about the
word ‘alternative’ and its connotations – i.e how it is
perceived.
When the likes of Ben Elton and co appeared on our
television screens, it was labelled as ‘alternative comedy’
principally because it wasn’t funny, much in the same
way a ‘alternative rock’ isn’t rock. Then came ‘alternative
medicine’ and ‘alternative healing’ which meant it was
for tree huggers and Yurt dwellers and didn’t really work.
‘Alternative lifestyle’ is for people who are odd anyway
and ‘alternative schools’ are for odd parents with odd
children.
Now I must stress, before my e-mail box is filled with
outrage and complaints, that these views are not my own;
it is how they are portrayed by those for whom anything
outside of the accepted mainstream cannot be trusted. And
that is the inference of Charlotte Crosswell’s comment.
So perhaps it’s time for a rebrand. Perhaps the simple
solution is for the ‘alternative finance’ sector, upon which so
many hundreds of thousands of businesses have built their
success, needs a make-over. Because while Governmentbacked
bodies like the Centre for Finance, Innovation and
Technology clearly perceive you as something not quite
to be trusted, you’re never really going to get the credit
you so rightfully deserve.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 3

contents
October 2024 issue
12 – BUY NOW REGULATE LATER
Will they or won't they regulate BNPL and
if so when?
16 – FALSE IMPRESSIONS
Contentious insolvency and recovering
diverted funds.
18 – DIGITAL CONVERSION
Unlocking efficiency with digital collections.
20 – POUND FOR POUND
What does a new digital pound mean for
business?
24 – STATE OF THE UNION
Credit Reference Agencies are looking forward
to a period of growth.
28 – OPEN SEASON
Opening up to Open Banking may deliver
significant opportunity.
32 – A PASSAGE TO INDIA
India is much more than its stereotypes.
38 – ON THE WIND UP
The enforcement of non UK judgements in
England and Wales is beset with complexity.
42 – MAINTAINING TRUST
IN JUSTICE
How to combat fraud in the enforcement
sector.
46 – SEX ON THE BREACH
Companies must take care not to fall foul of
new sexual harassment rules.
52 – SHAPING SUCCESS
Are credit professionals ready for AI?
54 – CERTAIN UNCERTAINTY
Economic uncertainty is leading to an upsurge
in credit insurance.
32
COUNTRY FOCUS
In
16
INSOLVENCY
Contentious insolvency,
and recovering diverted
funds.
42
ENFORCEMENT
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 4

dia
President:
54
CERTAIN
UNCERTAINTY
12
REGULATION
Will they or won’t
they regulate BNPL
and if so when?
CICM GOVERNANCE
Stephen Baister FCICM
Chief Executive: Sue Chapple FCICM
Executive Board: Chair Neil Jinks FCICM
Vice Chair: Allan Poole FCICM
Treasurer: Glen Bullivant FCICM
Larry Coltman FCICM
Peter Gent FCICM(Grad)
Paula Swain FCICM
Advisory Council: Laurie Beagle FCICM
Laura Brown MCICM(Grad) / Arvind Kumar MCICM(Grad)
Natalie Bunyer FCICM / Glen Bullivant FCICM
Alan Church FCICM(Grad) / Larry Coltman FCICM
Peter Gent FCICM(Grad) / Neil Jinks FCICM
Martin Kirby FCICM / Charles Mayhew FCICM
Joshua Mayhew MCICM / Hans Meijer FCICM
Debbie Nolan FCICM(Grad) / Amanda Phelan FCICM(Grad)
Allan Poole FCICM / Emma Reilly FCICM
Philip Roberts FCICM / Paula Swain FCICM
View our digital version online at www.cicm.com.
Log on to the Members’ area, and click on the
tab labelled ‘Credit Management magazine.’
Credit Management is distributed to the entire
UK and international CICM membership, as well
as additional subscribers
Publisher
Chartered Institute of Credit Management
1 Accent Park, Bakewell Road, Orton Southgate,
Peterborough PE2 6XS
Telephone: 01780 722900
Email: editorial@cicm.com
Website: www.cicm.com
CMM: www.creditmanagement.org.uk
Managing Editor: Sean Feast FCICM
Deputy Editor: Iona Yadallee
Art Editor: Andrew Morris
Telephone: 01780 722910
Email: andrew.morris@cicm.com
Editorial Team
Rob Howard, Milica Cosic
and Melanie York
Advertising
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Telephone: 01727 739 196
Email: paul.heitzman@cplone.co.uk
Printers
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Single copies: £14.00
ISSN 0265-2099
Reproduction in whole or part is forbidden without specific permission.
Opinions expressed in this magazine do not, unless stated, reflect those
of the Chartered Institute of Credit Management. The Editor reserves
the right to abbreviate letters if necessary. The Institute is registered as a
charity. The mark ‘Credit Management’ is a registered trade mark of the
Chartered Institute of Credit Management.
Any articles published relating to English law will differ from laws in Scotland and Wales.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 5

THE NEWS
CMNEWS
A round-up of news stories from the
world of consumer and commercial credit.
WRITTEN BY: SEAN FEAST FCICM
CSA report shows consumers
have an over-exaggerated
fear of litigation
PUBLIC perceptions of debt
enforcement are at odds with
reality, with anxieties about
talking to a debt collector
about arrears out of line with
the likelihood of enforcement proceedings.
A report from the Credit Services
Association, the trade body representing
the debt collection industry, has found
that customers’ reluctance to engage with
creditors or collections agencies about their
debt situation is often driven by feelings of
fear, shame or denial. The report explores
some of the attitudes and psychology
underlying each of these.
Report author and CSA Head of Policy
Daniel Spenceley says that education is
key: “Too many people who have fallen
behind on their credit repayments are
held back from picking up the phone and
having a conversation because of misplaced
fears, often stemming from a lack of
understanding and awareness, which is fed
More must be done
to better educate
and inform not
just disengaged
customers, but the
public at large, if we
are to eliminate these
misconceptions.
by myths and misinformation,” he explains.
“More must be done to better educate and
inform not just disengaged customers, but
the public at large, if we are to eliminate these
misconceptions and empower customers to
confront their financial circumstances.”
Daniel says that the frontline staff survey
suggests that 60 percent of staff in call centres
are finding that the typical customer lacks
awareness of the potential for forbearance
on debt, how to get time to seek debt
advice, or to agree repayment arrangements
that suit their personal circumstances: “The
average consumer, according to our polling,
perceives that 32 percent of debt held by
collections agencies will end up in court,” he
continues.
“Data from CSA member firms, however,
indicates that this figure is closer to seven
percent – and those are predominantly
cases where customers have persistently
failed to engage. When customers learn
that the chances of ending up in court are
far smaller than they expect, our research
suggests their fears are lessened and there is
a greater willingness to have a conversation
and engage in potential solutions and
forbearance.”
In other words, Daniel concludes, if
customers are better informed, they are
more likely to resolve problem debts: “Our
report therefore recommends new steps to
invest in financial education, and stronger
regulatory efforts to correct misconceptions
and misinformation.”
The report Tackling the Engagement Gap:
Addressing the reluctance of consumers to
discuss debt is available from the CSA.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 6

CREDIT MANAGEMENT
Female founder ambitions
held back by lack of finance
ACCESS to funding, as well as a lack of
financial skills and confidence, are some
of the major barriers holding female
entrepreneurs back, according to a new
report by Small Business Britain.
The report examines the challenges that
women business owners face and explores
how entrepreneurial growth and inclusion
can be boosted across the UK.
Despite significant ambition among
female entrepreneurs, nearly three in
five (57 percent) cite a lack of business
knowledge and confidence as barriers to
growth, with 39 percent saying securing
funding is a major challenge.
The ‘Female Entrepreneurship: Moving
Forward’ report – produced in partnership
with Square and Clearpay – found more
than half of female founders (58 percent)
have never taken out external finance, with
almost four in five women (79 percent) selffunding
their start-ups and 13 percent even
relying on personal credit cards.
The research – which consulted more
than 1,000 female entrepreneurs – revealed
that a desire for greater independence is
the biggest driver for women starting their
own businesses, cited as the primary reason
by 60 percent of women.
The report pinpoints the urge to ‘be your
own boss’ as a key motivator behind the
rise in the number of female entrepreneurs
across the UK during the last six years,
but also suggests the desire for financial
freedom may create a reluctance by female
founders to take on debt or outside finance.
Half of the women surveyed said they
did not understand enough about equity
investment and almost half do not like the
idea of an investor owning part of their
company.
“Encouraging and supporting female
entrepreneurship is essential for the UK’s
economic growth,” says Michelle Ovens
CBE, Founder, Small Business Britain.
“But with women accounting for just over
20 percent of the UK’s entrepreneurs their
numbers still lag behind that of maleled
businesses and we want to see this
representation rise to at least 30 percent in
the coming years.
“To do this we need to understand,
recognise, and directly address the distinct
challenges female founders face and the
reasons why they tend to start businesses
– notably a want for independence. This
drive can also put women off taking on
debt, and is often combined with a broader
lack of confidence around finance and
business skills among this group that can
be hard-wired from a young age.”
Despite the financial barriers that
women face, optimism about future growth
and ambition for technological adoption
is strongly reported among female
entrepreneurs, pointing to significant
economic opportunities for the UK that
could be expanded further.
Nearly two thirds of women (65
percent) expect their businesses to grow
in the coming year, with two fifths
anticipating a 20 percent rise in income.
To do this
we need to
understand,
recognise, and
directly address
the distinct
challenges female
founders face and
the reasons why
they tend to start
businesses.
Bright Spark
WILLIAM Peters, who studied accounting
and finance at the University of Plymouth,
has been named the Chartered Institute of
Credit Management’s Student of the Year
for achieving the highest grade for the credit
analysis assignment as part of the degree’s
credit management module. William is
putting the cash prize towards a Masters
in International Finance and Banking at
Exeter University.
Virgin territory
NATIONWIDE is set to finalise its £2.9bn
acquisition of Virgin Money this month
after receiving approval from the Financial
Conduct Authority and the Prudential
Regulation Authority. The deal, initially
agreed in March, was cleared by the
Competition and Markets Authority in
July. Virgin Money’s Sir Richard Branson
is expected to receive over £650m from the
deal, including a £250m exit fee and a £400m
valuation of his stake. The merger is due to
go live on 1 October.
Clear thinking
IN what it describes as ‘a UK first’, Lloyds
Bank is to use an AI technology from
Cleareye to streamline the processing and
compliance of trade finance documentation.
The system will utilise optical character
recognition, machine learning and natural
language processing to extract vital
information from various trade finance
documents, including letters of credit,
documentary collections, undertakings and
trade loans. Additionally, it will automate
compliance and money laundering checks
in accordance with International Chamber
of Commerce rules.
Body double
THE Body Shop has been rescued from
administration, with a consortium led by
the British cosmetics tycoon Mike Jatania
acquiring the beauty brand’s 113 remaining
UK stores. Jatania’s investment firm Auréa
Group, which will also gain control of the
Body Shop’s assets in Australia and North
America, said it has ‘no immediate plans’ to
shut any of the UK stores currently trading
which employ more than 1,300 staff. Private
equity firm Aurelius paid £207m for The
Body Shop in November 2023 but placed
the UK arm into administration in February
2024, owing more than £276m to creditors.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 7

THE NEWS
Mortgage data shows no
room for complacency
THE latest Mortgage Lending data from
the Bank of England and FCA shows
that the value of outstanding mortgage
balances with arrears is 32 percent higher
than a year earlier and the highest since
2014 Q2, reaching £21.9bn.
On a quarterly basis, the value of
outstanding mortgage balances with
arrears increased by 2.9 percent compared
to Q1 while the proportion of the total
loan balances with arrears increased on the
quarter from 1.29 percent to 1.32 percent,
the highest since 2016 Q2. In a more
positive sign, new arrears cases decreased
by 0.5pp from the previous quarter, to 11.0
percent of the total outstanding balances
with arrears, and was 5.3pp lower than a
year earlier.
Tom Cuppello, Director, Risk at leading
independent consultancy Broadstone, says
the impacts of the significant increases to
mortgage rates continue to reverberate
around the secured lending market: “As
more borrowers came off cheap fixed rates
over the past couple of years and faced
a significant increase in their mortgage
payments, it was inevitable that we would
see a rise in arrears flowing through the
system.
“Nearly two years on from the ill-fated
Mini Budget, we are likely to be nearing
the tail end of homeowners facing these
issues, especially given the length of time
to prepare and the recent decline in rates.
This is evidenced in the slowdown in
arrears volumes and falling numbers of
new arrears cases.
“Yet there is no room for complacency
among lenders who must continue to
ensure they are supporting the long-term
financial interests of their customers,
especially as the economic and fiscal
environment remains volatile. The
Government’s Mortgage Charter, the
advent of Consumer Duty and additional
FCA rules demonstrate that the legislative
direction of travel is towards protecting
borrowers in uncertain economic times.”
Banks still declining to help SMEs
HIGH street banks are keen to increase
lending to small businesses but face
significant challenges due to inadequate
data sharing, according to the head of a
Government-backed fintech hub.
Charlotte Crosswell, who chairs the
Centre for Finance, Innovation and
Technology, said that the big banks were
still declining a huge number of loan
applications and putting them into the
alternative finance sector.
“Data unlocking and sharing is probably
going to drive the next phase of financial
innovation, and that’s what the rest of
the world is looking at as well,” she said,
arguing that Open Banking could be a
key driver in supporting banks to make
better lending decisions (see article on
page 28).
“I feel that if nothing is done, the
complexity of our data history for SMEs
and consumers is going to get worse,”
she added. “We have to commit to open
finance, because there’s a stack of data
out there that at the moment is just flying
around and not really being utilised at all.”
Lending to UK SMEs has decreased by
20 percent over the past decade according
to a recent report, creating an estimated
funding gap of more than £22bn.
Top Service Appoints
Philip King as Non-
Exec Director
PHILIP King FCICM has joined Top
Service, the credit reference and debt
recovery agency for the construction
industry, as a Non-Executive Director.
Philip started his career in the
construction sector, later spending 14
years as Chief Executive of the Chartered
Institute of Credit Management, and 18
months as the interim UK Small Business
Commissioner.
Emma Reilly FCICM, CEO of Top
Service, is delighted to welcome Philip to
the team: “His expertise will be invaluable
as we focus on building our brand, raising
our profile, and growing our established
business to become the preferred supplier
of credit information and debt recovery
services for the UK construction industry.”
Philip King added: “I’ve been advocating
the importance of good credit management
throughout my career, and this is as true
today as it has ever been. I’m looking
forward to using my experience, and the
lessons I’ve learned over many years, to
help them enhance the profile they’ve
established over the past 30 years.”
Make and mend
RECENT figures for the S&P Global UK
manufacturing PMI survey indicated a
reading of 52.5 for August, marking the
highest level in 26 months and an increase
from 52.1 in July. Growth is attributed to
increased output, new orders, and improved
employment figures, with the investment
goods sector leading the way. Despite this
positive trend, concerns linger over export
orders, which have declined for almost three
years due to weaker demand in Europe and
a slowdown in mainland China.
Correction
IN an unusual occurrence, Gremlins managed to find their way into the production offices of Credit Management last month causing minor
disruption. This included publishing a photograph on page 39 that purported to show the team at EDF, when in fact it showed a happy team
at Ford. We are delighted to put that right with the correct photograph of EDF published (above) and apologise wholeheartedly for any
embarrassment caused. A hunt for the Gremlins is ongoing, but they are believed to have escaped and headed West to the coast.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 8 PAGE 8

CREDIT MANAGEMENT
UK Finance sets out five-point plan
to boost financial literacy
UK Finance has published a new report aimed
at boosting financial literacy in the UK for
children and young people, and identifying
the levels of investment required.
Financial Services is the biggest funder
of financial education by sector, voluntarily
contributing 80 percent of total funding
(£7.5 million). In 2023, the industry provided
financial education lessons to over 4.1 million
children and young people; focused support
to over 83,000 vulnerable children; and
engaged with over 25,000 schools.
However, UK Finance believes there is still
a significant amount of work needed to fully
achieve its goals in boosting financial literacy
in the UK. To this end the report sets out five
key recommendations: The integration of
financial education in the national curriculum
across all devolved nations; the creation of a
structured financial education curriculum
roadmap; mandating financial education in
all schools; practical mathematics education
until age 18; and enhanced support for
teachers.
Eric Leenders MCICM, Managing
Director of Personal Finance at UK Finance
says there needs to be a reset on how young
people are educated around money: “Good
financial literacy sets young people up with
the skills they need for their whole lives – like
budgeting, saving, and understanding debt,”
he explains. “We want young people to have
the knowledge that will give them financial
stability and independence for their future.
“The Financial Services industry voluntarily
delivers financial education to millions
across the UK, but to build the foundations
for lasting financial capability and inclusion
we need more substantial financial education
planning and funding from Government.
We are calling for the subject to be
fully integrated into the national curriculum
by making the lessons mandatory for all
schools.”
CICM Members’ Financial Support Fund is here
to support members of the CICM in times of need
The CICM Members' Financial Support Fund was
established to help members who are in conditions
of need, hardship or financial distress.
Some examples of how CICM has helped its
members are:
Any member, or former member, finding themselves
in difficult circumstances and requiring financial
assistance, please apply today – we are here to help.
Visit the Member Support page of the CICM
website, or email governance@cicm.com for more
information.
Financed the purchase of a mobility scooter for a
disabled member.
Helped finance the studies of the daughter of a
member who became unexpectedly ill.
Financed the purchase of computer equipment to
assist an unemployed member set up a business.
Contributed towards the purchase of an orthopedic
bed for one member whose condition was thereby
greatly eased.
Helped with payment for a drug, not available on
the NHS, for medical treatment of another member.
SCAN FOR FURTHER DETAILS...
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 9

THE NEWS
Ombudsman reports
fraud complaints at a
record high
THE Financial Ombudsman Service
(FOS) has reported a significant increase
in fraud and scam complaints, with
approximately 500 cases being received
and resolved weekly.
In the first quarter of the financial year,
8,734 complaints were recorded, marking
the highest level since tracking began in
2018. The rise in complaints is attributed
to various factors, including multiple
claims involving different firms and an
increase in consumers inadvertently
using cards to pay fraudsters. Crimes are
becoming more complex and convincing
– with some frauds involving multiple
banks.
Many financial providers have now
signed up to the voluntary Contingent
Reimbursement Model (CRM) code
which provides additional protection
for consumers, and means they are
reimbursed unless there are exceptional
circumstances. If a bank has not signed
up, consumers can have less recourse for
reimbursement.
Whether a bank has signed up to the
CRM code or not can affect the outcome
of a consumer’s case. Of the 4,752
Authorised Push Payment (APP) scam
cases the FOS received in the first three
months of this financial year, 2,734 were
not covered by the code. This is reflected
in the uphold rate – with 49 percent of
cases that fall under the code upheld,
compared to 36 percent that do not.
Pat Hurley, Ombudsman Director for
Banking, says that fraudsters’ methods are
always evolving, and they continue to see
that reflected in the complaints brought
to the service: “We are currently receiving
– and resolving – around 500 fraud and
scam complaints a week. In all the cases
we receive, we’ll look at the individual
circumstances and investigate whether a
business did everything it was required to
do.
“When we do uphold complaints, we
expect firms to learn from our findings
and apply them to any future interactions
with their customers.”
Elsewhere, almost £60 million has been
reported stolen through card fraud over
the past three years in the UK according
to new research from Trustly, the open
banking payments provider. Credit card
fraud is the most costly and common
type of card fraud, according to Trustly’s
research. Over £33 million was reported
stolen through credit card fraud between
2021 and 2023. This compares to just over
£24 million reported stolen through debit
card fraud.
The research also reveals that nearly
11,000 people were victims of card fraud
in the past three years, including 3,543
people in 2023 alone. This equates to
almost 300 victims per month last year.
Reports of credit card fraud specifically
peaked in 2023 with 2,171 victims – up
from 1,997 victims in 2022.
The figures were obtained via a freedom
of information request sent to the
National Fraud Intelligence Bureau run
by City of London Police.
Fintech squares
the profit circle
FUNDING Circle, the SME lender, has
reported a pretax profit of £0.5m for the
first half of 2024, a significant turnaround
from a £7.4m loss in the same period last
year.
The London-listed fintech has upgraded
its full-year guidance, now targeting
profitability for the entire year rather
than just the second half. Total income
rose by 32 percent year on year to £78.9m,
with revenue increasing to £79.1m.
Lisa Jacobs, Funding Circle CEO, says
that the company is delivering on the plan
she laid out in March to be simpler, leaner
and profitable whilst continuing to show
strong growth: “In May, we simplified and
streamlined the business to deliver £15m
annualised savings in 2025 and in July we
completed the sale of our US business for
a gain of £10m,” she explains.
“The first half was stronger than our
expectations with annual revenue growth
of over 30 percent; 12 percent up on H2
2023. We were profitable a half earlier
than we set out in our guidance in March
and are today upgrading our guidance to
be profitable for the full year (versus prior
guidance of H2 profitable).”
Lisa says she is now reaffirming the
lender’s medium-term guidance of 15-20
percent revenue growth and PBT margins
of more than 15 percent: “We continue to
be excited about the long-term growth
and profitability of the business as we
execute against our plan,” she concludes.
Doubling down
REVOLUT is intensifying its focus on
business-to-business (B2B) services, with
global revenues from business accounts
exceeding £380m this summer.
The platform, launched in 2017, caters
to a wide range of businesses, offering
tools for spending control and payment
acceptance to customers from sole traders
to large businesses. Currently, it serves over
a quarter of a million businesses monthly,
contributing 15-25 percent to Revolut’s
overall revenues. It claims to be onboarding
more than 20,000 businesses each month.
James Gibson, Head of Revolut Business,
stated: “With the support of a significant
and growing number of customers behind
us, we’re aggressively doubling down on
business-to-business.”
The company has invested over £100m in
marketing and growth initiatives, and is set
to launch BillPay, an automated payment
solution which it says will accelerate the bill
paying process for its customers to suppliers
around the world.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 10

THURSDAY 6 FEBRUARY 2025
THE ROYAL LANCASTER, LONDON
2025
JUDGES
ANNOUNCED
ALAN J SMITH
Chair
High Court
Enforcement Officers
Association
ATUL VADHER
SEFE
BRYONY CROSSLAND
Anixter
DAVID SHERIDAN
ARC
DEBBIE NOLAN
EPF
EMMA REILLY
Top Service
JASON BRAIDWOOD
Credit Safe
JAYNE GARDNER
Shakespeare
Martineau
JOHN KANE
KAREN YOUNG
Hays
MARTIN ROSEWEIR
Senior Vice President
Bill Gosling
Outsourcing
NATALIE BUNYER
Global Credit
Recoveries
PHIL ROBERTS
Clarke Willmott
PHILIP KING
SEAN FEAST
Director/
Co-Founder
Gravity Global
SIMON HOWELL
Tarmac
STEVE ALLINSON
Allinson Law
YVETTE GRAY
Atradius
Headline
Sponsor:
Brave | | Curious | | Resilient / www.cicm.com / October 2024 / PAGE 11
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REGULATION
Will they or won’t they regulate BNPL and if so when?
BY PETER FINCH
AND DOMINIQUE LOGAN
BUY Now, Pay Later (BNPL) has
seen a meteoric rise across all major
credit markets, including the UK.
Companies such as Klarna have now
become household names and have
valuations to match.
Take up has been driven by a number of factors, but
it’s clear that both the pandemic and the exponential
growth in online shopping have pushed the use of BNPL
to levels few expected in such a short period of time. As
both mainstream lenders and new providers have joined
the rush to provide BNPL, coupled with embedded
finance permeating new markets (such as in the travel
and fashion sectors), it’s easy to observe the speed at
which the rise of BNPL has occurred.
What is BNPL?
BNPL allows consumers to delay payment for a purchase
until a later date. A BNPL provider will step in and pay
the retailer, and the customer will agree to pay back the
BNPL provider over a period of time (typically between
30 days and two months after the point of purchase). The
repayment will generally be interest and fee-free as long
as customers make their repayments on time. Under
most BNPL models the provider usually makes its money
by taking a cut from anything they help a retailer to sell.
From a regulatory point of view, BNPL loan agreements
will generally fall outside of regulation. In practice, this
means the consumer protections such as affordability
checks are limited compared to standard loan and credit
products, and BNPL providers are not required to be
authorised by the Financial Conduct Authority (FCA).
Therefore, they avoid the stringent application process
of becoming authorised and the ongoing compliance
costs this brings with it.
There has been no overarching standard when it comes
to interest and credit guidelines across the UK BNPL
sector. This regulatory factor, alongside the huge growth
in the use of BNPL by younger users and media hype
around its potential negative impacts, has led to strong
political pressure from campaigners to bring BNPL
within the regulatory framework.
Regulatory developments
The UK Government first set out plans to regulate the
BNPL sector in February 2021. This culminated in the
Woolard Review (see boxed out section on page 14) setting
out its recommendation that the FCA and Treasury
work together to ensure that all BNPL products are
brought within the regulatory perimeter ‘as a matter of
urgency’.
Following the Woolard review, HM Treasury (HMT)
published a consultation seeking industry feedback, and
in turn a response in 2023. As a result of this consultation,
HMT’s key points were:
Creditworthiness assessments to be introduced
Lenders would need to undertake affordability checks.
While many BNPL lenders already undertake credit
checks they'll need to think carefully how to integrate
affordability assessments that will meet regulatory
expectations, given that speed and ease of application
at checkout has been key for the sector, enabling rapid
growth.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 12

CREDIT MANAGEMENT
Adverts and promotions to fall under financial
promotions regime
Financial promotions will have to be approved by an
authorised person. Rather than a merchant undertaking this,
HMT expect BNPL lenders to provide merchants with preapproved
materials.
Right to complain to the Financial Ombudsman
HMT confirmed that BNPL consumers would be able to
complain to the Financial Ombudsman Service (FOS).
Requirement to report to credit reference agencies
BNPL lenders will have to undertake ‘clear, consistent and
timely’ reporting to the credit reference agencies (CRAs), to
enable a customer’s BNPL loans to be visible on their credit
file.
Treatment of customers in financial difficulty
BNPL lenders will be subject to rules within the Consumer
Credit Act 1974 (CCA) on treatment of customers in financial
difficulty. Many BNPL firms already have processes in place to
identify and support customers in financial difficulty but will
need to ensure that these are consistent with potentially more
stringent regulatory requirements.
TRANSPARENCY
AIMS TO ENSURE
THAT THESE
SERVICES REMAIN
BENEFICIAL
WITHOUT
JEOPARDISING
THE CONSUMER'S
FINANCIAL
HEALTH.
To comply with the CCA, lenders will have to ensure that any
action they take towards the creditor doesn’t constitute an
‘unfair relationship’, which is detrimental to the consumer, and
can risk agreements being deemed unenforceable on account of
fairness at a later date. ‘Unfair relationship’ claims continue to
have a wide potential application in the context of consumer
claims. Lenders must also ensure that their procedures to
identify financial difficulty, and to monitor this on an ongoing
basis, meet all regulatory expectations.
Complying with the Consumer Duty
BNPL lenders will need to comply with the Consumer Duty
rules and frameworks. This raises the regulatory bar further for
BNPL lenders as they need to ensure ‘good outcomes’ for their
customers, in addition to complying with broad Consumer
Duty rules such as appointing Consumer Duty Champions,
conducting Fair Value Assessments, and additional protections
for vulnerable customers.
They are also required to make sure that BNPL products are
fully understood by customers, meet their needs, provide fair
value and help customers achieve their financial objectives.
Practical implications
HMT’s proposal would require retailers and BNPL providers to
adjust their practices to comply with the proposed regulations.
The need to comply with the CCA could have a significant
impact on customer journeys and point-of-sale processes. This
means reviewing marketing strategies, ensuring customer
support teams are well-informed, and implementing systems
for thorough affordability assessments.
For consumers, HMT’s proposal would offer enhanced
protection and clearer insights into the financial obligations
of using BNPL services. This transparency aims to ensure
that these services remain beneficial without jeopardising the
consumer’s financial health.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 13
continues on page 14 >

REGULATION
Where to from here?
Whilst the previous Government stated an ambition to bring final
legislation before Parliament prior to 2024, plans to move the
regulation forward were postponed after the second consultation.
Progress on the regulation of BNPL was then stalled for various
reasons such as economic and political instability, and of course
the 2024 election.
The on and off proposals for the regulation of BNPL has resulted
in uncertainty for both providers of BNPL products and users of
the products as to how and when these products will be regulated
in the UK.
However, the recently elected Labour Government has indicated
an intention to propose regulation of the UK BNPL sector.
Tulip Siddiq, Economic Secretary to UK Treasury, stated in July
2024 that the Government would proceed with regulatory plans
‘shortly’ and that the Government is ‘looking to work closely with
all interested stakeholders’.
We do not yet know whether the Labour Government will pick
up HMT’s proposals. We do, however, have some indication from
a letter in November 2023 from Siddiq to the then Economic
Secretary to the Treasury, Andrew Griffith. In this letter, the five
principles Labour proposes are that:
1. BNPL products must deliver good outcomes for consumers, by
ensuring customers have access to clear information.
2. Consumers must have protection if something goes wrong.
3. Bad actors must raise their standards or be denied access to the
market, to ensure vulnerable consumers are protected.
4. Regulation must be proportionate to support innovation in
the sector, in order to ensure that consumers are able to access
BNPL products.
5. Regulation must be introduced urgently, in a way that works
both for the sector and consumers.
A recurring theme of these five principles is the Consumer Duty
– a focus on good outcomes for the consumer, balanced with the
need to support innovation and development in the BNPL sector.
This somewhat reflects HMT’s 2023 proposal.
The Woolard Review
In September 2020, the FCA asked Christopher Woolard,
former Interim Chief Executive to review change and
innovation in the unsecured credit market.
The review was to consider how regulation could better
support a healthy unsecured lending market. The review
was tasked to look at the impact of the pandemic on
employment security and credit scores, changes in
business models and new developments in unsecured
lending, including the growth of unregulated products in
retail and the workplace.
It sought the views of consumers, firms and their
representatives.
The terms of reference for the review were:
• To examine the current state of the unsecured credit
market in the UK including the component parts,
recent changes in size and scale, whether in regulated or
in adjacent unregulated products.
• To examine changes in regulation, noting those areas
that have been subject to regulatory oversight in recent
years from a variety of bodies including the FCA, and
comparing likely harms or dynamic effects seen in those
areas.
• To examine the immediate effect of the pandemic on
demand for unsecured credit and on the role of credit
information.
• To report on possible trends and potential future
pressures.
• To identify areas of growth in demand from consumers
for credit including from non-traditional providers of
credit.
• To present an assessment of the benefits and harms
evident in the market and those that may be expected as
the market develops.
• To compare international approaches to these issues
where relevant.
• To make conclusions and recommendations to the FCA
Board on management of harms in this sector; gaps in
understanding or data; potential changes in regulation
for the FCA to consider; advice on potential changes
to the overall system the FCA may wish to consider
with other authorities or the Government; and possible
innovations to support a sustainable market.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 14

CREDIT MANAGEMENT
BNPL PRODUCTS
MUST DELIVER
GOOD OUTCOMES
FOR CONSUMERS,
BY ENSURING
CUSTOMERS HAVE
ACCESS TO CLEAR
INFORMATION.
The five principles also acknowledge the innovation
and convenience BNPL services bring to consumers
and retailers alike but stresses the necessity of
safeguards to protect the consumer. Interestingly,
in the letter Siddiq criticised the CCA, providing
that it is complicated and overly prescriptive. So it is
unclear whether Labour seeks to pick up all of HMT’s
proposals, noting that one of HMT’s proposals was to
bring BNPL within the scope of the CCA, or perhaps
whether Labour will also propose to simplify the CCA.
This move by the Government represents a big step
towards recognising BNPL as a significant component
of the financial services landscape that warrants
appropriate regulatory measures.
The UK is not the only jurisdiction that has been
exploring the regulation of BNPL for a number of
years. With so many global players in the BNPL sector
now, looking to other jurisdictions may be a helpful
‘temperature check’ to get a sense of how the UK may
seek to regulate BNPL.
International perspectives
In the US, the Federal Consumer Financial Protection
Bureau (CFPB) in May 2024 issued an interpretative
rule that imposes some rules that apply to credit card
providers to BNPL providers. This rule is limited
to digital user accounts used to access credit and is
designed to facilitate better consumer protection by
imposing regulation on billing disputes, refunds and
certain disclosures.
Outside the Federal system, some states have taken
steps to regulate BNPL. California has incorporated
BNPL products under its California Financing Law,
and New York recently proposed the regulation
of BNPL through draft legislation (which was not
successfully passed).
As at the date of this article, Australia is the only
comparable jurisdiction to the UK that has introduced
draft legislation designed to completely regulate
the BNPL sector. Whilst a voluntary industry code
of conduct has been in place for a number of years,
the draft legislation is a reflection of how embedded
BNPL is in Australia, and the rapid evolution of BNPL
in Australia since providers such as Afterpay were
established in the market over a decade ago.
The draft legislation introduced in March 2023 will
see BNPL brought within the scope of Australia’s
equivalent of the CCA, with BNPL being considered
a newly coined ‘low cost credit contract’. If passed
in its current form, the draft legislation will require
providers of low cost credit contracts to:
• be authorised with an Australian Credit Licence
(similar to FCA authorisation);
• comply with enhanced consumer protections; and
• implement appropriate responsible lending
frameworks, commensurate with their products.
The draft legislation will also impose maximum fees
and charges on BNPL products.
Adapting to the environment
Whilst the regulation of the BNPL sector in the UK
remains unknown, the move to regulate underscores
the importance of protecting consumers while
fostering innovation in financial services. As these
regulatory updates develop, businesses and consumers
alike must stay informed and agile, ensuring that they
can continue to benefit from the flexibility BNPL
provides, while safeguarding against potential risks.
These changes mark a significant step towards a
balanced BNPL ecosystem that prioritises consumer
welfare and responsible lending practices. Some
stakeholders in the BNPL industry argue that overregulation
could stifle innovation and place undue
burdens on service providers, potentially reducing
consumer choice. However, it appears that Labour’s
proposal to regulate the BNPL sector seeks to deal
with the complex balancing act between fostering
financial innovation and ensuring the protection of
consumers.
As the Government seeks to implement these
regulations, ongoing dialogue with stakeholders across
the spectrum will be crucial to striking an equilibrium
that benefits both consumers and the burgeoning
BNPL industry.
Authors: Peter Finch is a Partner, and Dominique Logan
an Associate, at Fox Williams LLP.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 15

INSOLVENCY
FALSE
IMPRESSIONS
Contentious insolvency, and recovering diverted funds.
BY RACHEL LAI
IN some scenarios, either before or after the
start of a formal insolvency procedure, the
debtor may give the impression of not having
any assets. They may use this approach to
encourage creditors to write off debt rather
than pursuing insolvency proceedings
against them. It is often true that there
are no obvious assets available. Assets may have been
pledged to secured creditors and any money in
the debtor’s bank account may be long since gone.
However, there may be opportunities for an insolvency
practitioner to recover funds which have been diverted
elsewhere, and this is where contentious insolvency
comes in.
The Insolvency Act 1986 provides a number of different
routes to make recoveries in formal insolvency
procedures. The general aim is to restore the position for
creditors of the debtor company or individual to what
it would have been, had assets not been diverted. The
statute allows insolvency practitioners to take a claim
through the courts, which may end as a formal trial in
front of a judge. However, in reality, most cases settle
before they reach this stage, reducing cost and risk on
both sides.
Transaction at undervalue
One of the most common types of claim is a transaction
at undervalue. This happens when a gift is made prior
to the commencement of an insolvency procedure, or
a transaction occurs whereby the debtor gives away
significantly more than is received in return. Examples
could include the transfer of the business to another
party without consideration or entering into a deed
of trust which shifts rights or assets away from the
debtor.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 16

CREDIT MANAGEMENT
MANY START-
UP BUSINESSES
BEGIN LIFE
WITH MORE
DEBTS THAN
ASSETS, BUT
CAN GROW INTO
SUCCESSFUL
PROFITABLE
AND HIGHLY
SOLVENT
ENTITIES.
It will always fall on the insolvency practitioner to prove
the claim, but where the beneficiary is a family member
or other associate of the debtor, the proof required
may be reduced. The period over which the insolvency
practitioner can look back at transactions varies
depending on whether the debtor is incorporated or an
individual, and on the purpose of the transaction.
Preference
Another frequent occurrence is a preference, whereby
something is done to put a creditor, surety or guarantor
in a better position than they would have been in, had
that thing not been done. Put simply, this could be the
payment of a debt or repayment of a loan to a particular
creditor, leaving other creditors unpaid.
Wrongful and fraudulent
trading
Trading whilst insolvent is often cited when creditors
are feeling aggrieved about being left unpaid. In itself,
trading whilst a company is insolvent is not prohibited.
Many start-up businesses begin life with more debts than
assets, but can grow into successful profitable and highly
solvent entities.
Wrongful trading happens where a director knew or
ought to have known that the company would not be able
to avoid insolvent liquidation or administration, and did
not take every step to minimise the loss to creditors. A
claim could be made against the director personally.
Fraudulent trading has a wide definition but involves
the company having been operated for some fraudulent
purpose and can be pursued against anyone who was
knowingly a party to the fraud.
Directors’ breach of duties
Directors have duties under the Companies Act 2006 and
also general fiduciary duties as stewards of the company’s
assets. If they have failed in these duties, which may
involve engaging in some of the conduct mentioned
above, they may find themselves being pursued by an
insolvency practitioner, even if they did not directly
benefit.
The role of creditors in the
process
Creditors can provide valuable information and assistance
to insolvency practitioners who are investigating
whether there is anything that should be pursued further.
If documentary evidence is available this can be hugely
helpful. In some cases, insolvency practitioners may look
to creditors for funding to pursue claims, such as to
obtain legal advice or to cover court fees.
All insolvencies are different and if readers suspect that
any of the things mentioned in this article have been done
by an insolvent debtor, they should contact an insolvency
practitioner for advice on their specific situation.
Author: Rachel Lai is a
Partner and Head of Contentious
Insolvency at Menzies LLP
An important part of making out a preference claim
is that the debtor has to be influenced by a desire to
prefer. As a general rule, this can exclude a decision
made for genuine commercial reasons. However, where
the person who has received the benefit of the preference
is connected to the debtor, there is a presumption that
there was such a desire and it would be for the beneficiary
to prove otherwise.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 17

CONSUMER
DIGITAL
CONVERSION
Unlocking efficiency with digital collections.
BY CRAIG TEBBUTT
THE debt landscape isn’t
just changing – it’s already
changed. Artificial intelligence
(AI) technology has evolved,
regulatory requirements have
evolved and how customers want
to engage has evolved.
Creditors today are facing a perfect storm of
challenges which impact their recovery capacity, from
tightening regulations and cost constraints to tougher
cost of living pressures facing their customers.
Meanwhile customer behaviours have shifted. A clear
preference for digital-first interactions has emerged
as more of us opt to manage debt resolution journeys
entirely online.
In this new reality, a data-led and customer-centric
approach aimed at achieving better customer
outcomes is no longer optional but imperative, and
personalised digital collection pathways are emerging
as a clear solution.
This is not just about digitising existing processes.
It represents a fundamental shift in how creditors
interact with customers, offering a path to overcome
challenges and enhance the overall customer
experience all in line with the new Consumer Duty
standards.
Evolving behaviour
Changing behaviours have elevated digital channels as
the favoured choice for customers. The world we live in
is becoming increasingly digital-first and the presence
of AI is more widespread by the day. Consumers have
integrated technology into every aspect of their lives -
the way they shop, bank and pay bills – and the same
is true when it comes to managing personal debt.
The statistics speak for themselves. One in three of
us prefer to deal with debt online, and 60 percent
say they prefer digital self-service tools for customer
support, such as an online knowledge base, app or
chatbot.
At Equifax, we’ve seen web chat engagement increase
by 50 percent and web portal usage up by 200 percent
for customer debt resolution journeys. Meanwhile the
number one complaint in collections is consumers
being wrongly contacted.
Flexible self-service options and digital pathways are
putting customers back where they should be, right at
the centre of the debt resolution process. Digital
collections empower customers to manage and engage
in debt resolution on their own terms – at their preferred
time and place. They can make payments, explore
affordable payment plans with the optional use of
Open Banking to reduce friction, access support
resources, and track their progress – all at their own
convenience.
Inevitably this is leading to better outcomes as well.
The added benefit of a digital recovery process is AIdriven
data intelligence. This can radically transform
collections operations, for instance by uncovering
behaviour patterns and adjusting to individual
circumstances based on whether or not there are signs
of financial stress.
It’s true the current economic landscape presents
widespread affordability challenges for UK
households and undisputedly there is an urgent
need to recognise nuance when resolving consumer
debt. But digitisation is enhancing, not hindering,
this process by providing personalised resolution
pathways.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 18

CREDIT MANAGEMENT
Business efficiency
But digital collections is not just improving customer
outcomes – it also has transformative potential for creditors
themselves.
Lenders are contending with heightened regulations such
as Consumer Duty, while staff shortages put a strain on
resources and cost constraints limit operational flexibility.
Digital recovery solutions can address these challenges all
while enhancing the overall customer experience.
Firstly, it has the potential to increase efficiency. The
shift towards self-service reduces operational costs and
streamlines the debt resolution process. The traditional
model of call-centre-driven collections still has a place –
but digital solutions offer a better route for resource-poor
centres by automating certain elements of the process and
freeing up experts to engage in more complex cases or
with customers who still prefer a human interaction. By
connecting digital channels and call centres, a consumer
can digitally flag when they need to speak to an agent, and
vice versa can be transferred back into a digital journey at
the right moment.
CONSUMERS
HAVE
INTEGRATED
TECHNOLOGY
INTO EVERY
ASPECT OF
THEIR LIVES -
THE WAY THEY
SHOP, BANK AND
PAY BILLS.
Meanwhile, digital processes are helping to reduce risk
through inherent compliance. Navigating the complex
web of regulatory requirements is a constant challenge for
creditors, particularly when it comes to managing financial
difficulty and protecting vulnerable customers. To add to
this, consumer debt profiles are changing, with an increased
proportion now holding a mortgage or on higher incomes
independent of wage growth. This poses new dimensions to
compliance needs.
Digital solutions can be designed with compliance in
mind, incorporating built-in guardrails to help ensure
adherence to evolving standards. This reduces the risk of
errors, protects consumers and gives creditors engaging in
recoveries more peace of mind.
A new era
In a world where the high cost of living has increased the
strain on household finances, debt management encounters
new challenges. The affordability landscape has changed,
creditors face growing pressures on all fronts, and today’s
consumer demands digital journeys that match their daily
routines.
Ultimately, digital customer engagement in collections
can unlock new efficiencies for creditors and offer better
outcomes for consumers, improving business recovery rates
and helping more customers get out of debt quicker and live
their financial best.
Craig Tebbutt is Chief Strategy & Innovation Officer
at Equifax UK.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 19

FINANCE
POUND
FOR POUND
What does a new digital pound mean
for business? Part one.
BY MARDI MACGREGOR
AND ANDREW MARRA
BANK of England (BoE) and HM
Treasury (HMT) papers have
examined how a hypothetical blockchain-backed
central bank digital
currency (CBDC) could impact
financial stability, innovation, and
the payments landscape. So what
is being proposed and what are its implications on
business?
In February 2023, the Bank of England (BoE) released
two documents regarding CBDC, a prospective
Government-backed digital form of UK currency also
known as the ‘digital pound’.
The consultative document – The digital pound: A new
form of money for households and businesses? – jointly
released with HMT, described the Government’s
emerging vision of the digital pound, including its
functionality and financial stability implications. The
accompanying technology working paper – The digital
pound: Technology Working Paper – provided an overview
of technical design considerations.
Both documents invited responses from the public. The
BoE and HM Treasury received over 50,000 comments
in response to the consultation and published a reply in
January 2024, entitled Response to the Bank of England
and HM Treasury Consultation Paper − The digital
pound: A new form of money for households and businesses?
The consultation and technology paper signalled that a
digital pound appears inevitable. If necessary approvals
are received, the UK may launch a digital pound in the
next several years.
Consultation overview
The report suggested that the digital pound would
likely take the form of a retail CBDC, issued by the
BoE, used by businesses and households alike for
everyday transactions.
The BoE stressed that a digital pound would not
replace cash, but exist alongside physical currency,
as an additional form of card or touchless payment
methods accessible through a smartphone. The digital
pound would be a direct claim on the BoE (as issuer)
and would always have the same value interchangeable
with a banknote. In this respect, the digital pound
would closely resemble current ‘private money’ or bank
accounts, but with the additional protection offered by
a central bank ledger (i.e., blockchain).
The digital pound would involve a central
infrastructure, or ‘core ledger.’ The BoE proposed the
adoption of a so-called ‘platform model’, analogous
to the ‘two-tier’ model favoured by the US Treasury,
where public access to the central, Governmentoperated
ledger would be intermediated by regulated
private entities, such as banks, Fintech companies,
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 20

CREDIT MANAGEMENT
and other approved non-bank private businesses.
These approved intermediaries would have exclusive
access to an intermediate layer between the central
ledger and the user-interface (or the Application
Programming Interface – API), through which they
would be permitted to build out applications and
mechanisms for storage of the digital pound through
‘pass-through wallets’.
These digital wallets (accessible via a smartphone or
smart card) would be provided by private businesses
(e.g. banks or approved non-bank firms), and would
record user’s holdings anonymously (as a means to
safeguard user privacy). The wallet would effectively
pass instructions from the user to the core ledger. The
end-user would interface with their wallet, not with
the BoE, and would be able to execute transactions by
instructing payments and transfers.
The BoE proposed strict regulation of companies
who are permitted to provide interface services for
the central bank ledger, ensuring that digital pound
payments are reliable and interoperable. The proposed
digital pound would be subject to rigorous privacy
standards, ensuring that private companies safekeep
users’ personal information and monitor transactions
for illicit financing, money laundering, and terrorism.
In the same way that banks and other financial service
providers are tasked with ensuring compliance with
anti-money laundering regulations, as well as antiterrorism
or illicit financing requirements, banks
and other private sector intermediaries between
the central ledger and users would be tasked with
maintaining similar compliance measures. According
to the BoE, this would render the digital pound ‘at
least as private as current forms of digital money, such
as bank accounts’, because the identity of users would
only be known to the private company that provides
interface services, and neither the government nor the
BoE would have access to the financial or personal
information of users unless such access was required
by law, the standards for which would be the same as
those currently in place with respect to other digital
payments and bank accounts generally.
The case for a digital pound
The BoE stated that the digital pound will likely
become necessary to preserve the role and public
access to money issued by the UK central bank; and
promote innovation, choice, and efficiency. Other
grounds identified by the BoE included supporting
inclusivity, payments resiliency, and the improvement
of cross-border payments.
Consultation questions asked
The digital pound: A new form of money for households and
businesses? consultation asked questions of two groups –
consumers (30 questions), SMEs (15 questions).
Of the consumer grouping, the consultation wanted to
understand matters such as how individuals currently
accessed day-to-day money, in which products they saved
money, whether they’ve switched provider, what features
of the new account was key when choosing a different
provider, whether they paid fees for non-standard
product features, and how ‘spare’ money was used.
Other topics asked about included payment methods used
for purchases, the last time a new method was used, how
payment methods could be improved, how often cash is
used, and the value placed on the ability to use banknotes.
In terms of SMEs, the consultation asked questions
such as payment methods currently accepted, preferred
method of payment, the most commonly used method,
how products used to accept payment, how payment
processes could be improved, how staff and other bills are
paid and what influences the choice of method, and the
last time a switch was made.
Preserving the role of the pound
The consultation noted changes to how people use
money and render payment as the basis for why a
digital form of central bank currency is likely to
be necessary in the future. The BoE noted that the
majority of payments in the UK are now made through
card or contactless methods, a form of ‘private’ money.
Such money is private because it is held by private
commercial banks in the form of deposits.
Roughly 95 percent of the funds held by people in the
UK are private money, the bulk of which is transferred
by electronic means. The BoE added that nearly a
third of retail shopping is done online, purchases for
which ‘public’ money – i.e. cash – is not accepted.
Given the trend of increasing dominance by so-called
‘private’ money, the BoE foresees that the public’s
access to, or use of, public central bank money will
decline over time, which could pose a risk to monetary
and financial stability. A more proportional balance
between public and private money is critical, the BoE
stated, because private money poses greater risks than
public money. While money held in a private bank
account is subject to credit, market, and liquidity
risks largely outside of one’s control, the cash held
in one’s pocket is not. Therefore, according to BoE,
the introduction of a digital form of central bank
direct-issue currency is needed to ensure that citizens
continue to have convenient access to safe liquid assets
backed by the state.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 21 continues on page 22 >

FINANCE
Promoting innovation, choice, and efficiency
The BoE stated that innovations in financial and payments
technology – for example, contactless card payments, mobile
payment apps, payment facilitators - have benefitted UK citizens
and the economy-at-large. While there is still room for greater
efficiency, BoE noted that such innovation has increased market
concentration. The consultation suggested that the introduction
of a digital pound could mitigate the entrenched dominance of
a small number of prominent Fintech firms that limit consumer
choice and hinder market entry. Further, the digital pound would
be a public-private partnership designed to support innovation
and foster competition. By creating a trusted infrastructure
platform and settlement asset upon which private businesses can
build and interface with users, the BoE believes that the digital
pound would be a boon to innovation.
Financial stability
If and when a digital pound is introduced, the effect of retail
consumers transferring all or some of their money from a bank
account into a digital pound would be a loss of deposits at
commercial banks, that is bank disintermediation. While the BoE
stated that it would seek to limit the risks to monetary policy and
financial stability posed by this process, it also stated conclusively
that it does not ‘seek to preserve the status quo’ or protect the
business model of the commercial banking sector.
A loss of retail deposits would necessitate more bank reliance on
wholesale deposit funding. The increased expense of wholesale
deposit funding would likely pass increased costs onto consumers,
namely in the form of higher interest rates on loans as well as a
broader decrease in credit availability. The likely occurrence of
these negative effects, together with their severity, would depend,
however, on the speed and scale of adoption of the digital pound,
and is therefore uncertain.
As a means of addressing this concern, the BoE would seek to
place some limits on holdings of digital pounds, at least during its
introductory period. An individual limit of between £10,000 and
£20,000 was proposed (in contrast the European Central Bank’s
proposal of a €3,000 limit on consumer CBDC accounts).
Monetary Policy
The BoE contemplated the impact a digital pound could have
on the sensitivity of the real economy to monetary policy, the
equilibrium interest rate, and economic productivity. While the
BoE was optimistic that such impacts could be slight or mitigated,
it admitted that a multitude of contingencies rendered the exact
impact uncertain.
Authors: Mardi MacGregor is a Partner in financial services team, and
Andrew Marra is Senior Associate in regulatory and white-collar crime
team, at Fox Williams. They will conclude their article in the November
issue.
Overview of BoE
response comments
In the BoE’s published response to the consultation it
said, in overview, that ‘money is central to our daily lives
and the economy. Trust in money is essential’. It noted
the value of banknotes and coins combined with cards or
phones.
The response acknowledged that the economy is
becoming more digital, and people are using cash less. It
also recognised that ‘as cash is issued directly by the Bank
of England… you can rely on it... you can trust it’.
The document noted that new technologies invariably
preclude the use of cash. The bank, however, wants to
innovate in the area of everyday smaller ‘retail’ payments,
made by households and businesses, as well as larger
‘wholesale’ payments, made by banks and other financial
firms.
A digital pound would be a digital complement to our
existing banknotes, it said. It would not replace cash. It
would be issued directly by the Bank of England.
A stated goal of a digital pound would be to support
innovation and choice so that private companies, big
and small, could develop innovative ways for people
to pay. The aims is to make day-to-day payments more
convenient and reduce costs for businesses that accept
them.
Respondents did, however, raise concerns about
important issues such as privacy and freedom of choice.
The bank said it would take further steps to address
concerns and that parliament would have to legislate on a
digital pound.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 22

Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 23

CREDIT REFERENCE AGENCY
STATE OF
THE UNION
Credit Reference Agencies are looking forward
to a period of growth.
BY CELSO NOGUEIRA
AS inflation rates rise more
slowly than anticipated,
businesses and consumers may
finally be seeing a light at the
end of the tunnel after years of
uncertainty and cost-of-living
stresses. While the credit
reference agency (CRA) sector has not been immune
to these financial challenges, many businesses are now
looking for new ways to attract and support customers
while delivering safe growth.
Future-Proofing strategies
Following a period of stagnant growth and heightened
risk aversion, it’s now critical that CRAs look to
the future and invest in new growth areas, beyond
traditional credit markets.
Technology and digitisation will continue to be key
drivers of growth for the CRA sector. The financial
services industry has already made significant progress,
with the rise of digital banking, but there are still more
opportunities to innovate. Advancements in data
analytics and artificial intelligence (AI) will enable
businesses to gain deeper insights into consumer
behaviour and enhance decision-making processes.
By harnessing the latest tools and information,
providers can ensure they are getting a comprehensive
view of every consumer and are lending responsibly
at a time when the economic landscape is constantly
changing. It is vital to ensure that consumers do not
borrow beyond their means, otherwise they risk
taking on debts they cannot afford and falling behind.
Emerging technologies will also transform how
consumers apply for financial products, such as credit
cards and loans, by personalising credit offerings and
streamlining credit management processes.
As digitisation rises, so does the risk of fraud.
Fraudsters are increasingly exploiting loopholes in
digital journeys, and with more businesses moving
their operations online and adopting digital-first
strategies, first-party fraud is a growing risk for
financial institutions. TransUnion’s 2024 State of
the Omnichannel Fraud Report revealed that since
2019, the volume of risky transactions in the UK has
increased by more than 16 percent. Yet nearly half (45
percent) of consumers ranked personal data security as
the top reason to do business with an online company,
while 90 percent said confidence that their personal
data will not be compromised was the most important
factor when choosing with whom to transact online.
As fraud becomes more sophisticated, having a
robust fraud prevention strategy in place will be
key in attracting and supporting customers while
delivering safe growth. Businesses must invest in
solutions that help protect against financial crime and
ensure customer confidence. Only through concerted
action and mutual cooperation can we ensure trust,
protect our digital infrastructure and ensure a safer
environment for all.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 24

CREDIT MANAGEMENT
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 25 continues on page26 >

CREDIT REFERENCE AGENCY
Fraud risk is growing at a notable rate within the
gaming sector, which includes online gambling and
poker. In 2023, gaming saw the highest proportion
of potentially fraudulent transactions (7.3 percent)
compared to other UK sectors. As the sector continues
to grow and face new regulations, it will be essential
to have technology in place to facilitate trust between
consumers and providers.
Open Banking will also continue to expand in the UK
as financial institutions seek to better understand how
customers spend, save and invest while managing their
risk profiles. Open Banking platforms are expected to
continue to gain traction with both vendors offering
traditional lending and those wanting to innovate in
new use cases in different sectors, such as utilities or
debt advice. TransUnion was an early advocate of Open
Banking in the UK, viewing the technology as a tool
to improve customer acquisition, customer experience
and enable more informed and fairer lending decisions.
Regulatory Challenges
With continued macroeconomic turbulence, there’s
more pressure than ever for businesses to take greater
accountability in treating vulnerable customers fairly,
inclusively, and avoiding causing them foreseeable harm.
The Financial Conduct Authority’s (FCA) Consumer
Duty regulations remain an ongoing priority, requiring
financial services providers to prioritise customer
needs and empower them to make informed financial
decisions. Internal processes are being reassessed to
ensure financial institutions are ready for potential
reporting requirements, as well as to deliver greater
transparency and improved consumer outcomes.
Digital-native companies with a customer-centric
culture will be better positioned to quickly adapt to
regulatory demands as they are often more in tune
with consumer needs. This adaptability is not limited
to smaller, tech-savvy companies; larger firms have also
shown an ability to pivot rapidly.
However, not all businesses are equally prepared.
Companies with older, more rigid processes may
find it challenging to adjust to these new regulatory
expectations. For organisations that are not digitalfirst
or that have traditionally maintained a distance
from direct customer interaction, adapting to the new
landscape may require more significant changes and
investments.
In the face of regulatory scrutiny, there are practical
approaches for any financial institution to ensure
compliance today and for the long term. By obtaining
the most actionable understanding of their customers’
situations, including assessing affordability and
spotting signs of financial stress and vulnerability, and
driving credit education with customers, businesses
can stay ahead of regulatory changes.
Consumer Duty regulations require financial
institutions to support vulnerable customers
while treating all consumers fairly. For the FCA,
vulnerability is a spectrum, which customers can move
up and down depending on their health, life events,
resilience and capability. This sentiment is echoed by
other regulatory bodies, such as Ofcom, Ofgem, Ofwat,
which have provided vulnerable consumer guidance for
their members.
By harnessing financial and non-financial data,
lenders can develop a detailed and distinctive view of
consumers’ vulnerability profiles and tailor services
to their needs while also complying with Consumer
Duty requirements. This enables financial institutions
to foster trust with their consumers and enhance
outcomes while also making more informed lending
decisions.
Looking Ahead
As the CRA sector continues to evolve, businesses
should tap into new growth opportunities while
remaining agile in this challenging economic landscape.
Organisations that prioritise continuous innovation
through better data, analytics and technology will be
able to stay ahead in the market. At the crux of this
is enriched credit data and emerging technologies
which will enable financial institutions to not only
better understand shifting consumer behaviours and
vulnerabilities, but also enable them to comply with
new regulatory requirements.
Author: Celso Nogueira is Chief Strategy Officer,
TransUnion UK.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 26

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BANKING
OPEN
SEASON
Opening up to Open Banking may deliver
significant opportunity.
BY ANTHONY PERSSE FCICM
IN July 2024, Open Banking Limited (OBL)
announced that there are now 10 million
consumers and small businesses regularly
benefiting from using Open Banking
technology. The significant achievement was
described by OBL as ‘highlighting the positive
momentum and growing adoption of Open
Banking technologies as millions of consumers and small
businesses benefit from innovative financial management
and payment tools’.
Competition it said has been a key driver to growth.
OBL observed that when one company focuses on Open
Banking technology, their direct competitors soon follow.
The organisation also reported seeing existing providers
expand their offer to the market.
The recent growth in users has bucked trends from
previous years. The growth in payments initiation service
(PIS) users over the past 12 months has been spectacular
with a 61 percent year-on-year increase. Growth of
accounts information service AIS users has also steadily
accelerated in recent months.
Within the Invoice Finance sector, those who are working
with AIS providers are certainly at an advantage. It
is enabling them to work with a third party to access a
business customer’s bank account details as a single source
of truth. So why is this important and how is it being used?
In Invoice Finance, as with any form of lending,
understanding risk is key. Having a true and accurate
understanding of a company’s income and outgoings,
payments, direct debits etc enables us to better
understand their cashflow. Being able to see payments to
particular organisations, such as His Majesty’s Revenue
and Customs, similarly helps build confidence and trust
in the data we are presented with, and that there are no
looming liabilities.
Access to Open Banking data is also helping the Invoice
Finance sector to combat fraud. In the past, we might have
asked for copies of bank statements with which to assess
a company’s financial position and mitigate risk. Paper
statements were, and are, easily forged, however, and
fake bank statements were not uncommon. With Open
Banking, this isn’t possible, neither is it possible for a
company to hide when a payment has been made directly
to them, without being disclosed, rather than being paid
into a Trust Account, which is the way Invoice Finance
providers work.
Faster access to lending
Open Banking isn’t just a safeguard against the more
unsavoury side of business life. It also helps accelerate
the speed with which a new client can be assessed and
onboarded, without additional proof points being
required and questions asked, for the data doesn’t lie. Put
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 28

CREDIT MANAGEMENT
simply, it enables organisations like Optimum Finance
to arrive at a decision far quicker, to the benefit of all
concerned. And there is another significant benefit
that Open Banking can deliver. Having visibility of
data enables a trusted third party to monitor and track
spend and revenue data in real time, which in turn may
enable that third party to predict and alert a business
of an imminent cashflow crisis. Connecting the right
people at the right time might not only prevent a crisis,
but also enable the funder to proactively offer cash that
could help balance the books and secure the ongoing
financial health of the business.
In some cases, Open Banking providers can also access
historic data and accounts, enabling funders to look
back at past transactions and use them as a source of
funds report or an initial security check for the purpose
of reducing the risk of financial crime or bad debt.
Products like StreemAnalyse, for example, created by
Open Banking provider StreemConnect, can further
simplify this process, creating an automatic, direct
link from client bank accounts to lenders in a read-only
format. They can create a breakdown of transactions
by supplier, help to identify spending trends, and
produce data-driven insights that save businesses
both time and money, whilst keeping lenders safe
from potential fraudulent or undisclosed business
activity.
Hosting Open Banking information and integrating
it with a financier’s existing data sets can also open
up the opportunity for funders to partner with each
other, rather than increase competition and the need
for costly transaction fees, which could result in further
enhancements to product delivery. This helps businesses
to be more agile in a rapidly evolving and increasingly
digital financial environment.
Given the importance of Open Banking, it is perhaps
surprising that it is not more widespread in our industry.
I would estimate that on average, at least three out of
every four new clients we onboard grant us visibility of
their banking data. Any reluctance is usually borne out
of fear of losing control, or a misinformed belief that
their data is being shared beyond the eyes of those who
have requested it, which cannot be the case.
To summarise, Open Banking makes the delivery of
Invoice Finance far simpler. It can also make it quicker
and more convenient for the customer. By reducing the
risk of fraudulent statements, and reducing the potential
for bad debt, Invoice Finance providers can ultimately
offer clients a product at a much more competitive rate.
Ultimately it is a ‘win win’ for all those involved.
Author: Anthony Persse FCICM is Chief Executive of
Optimum Finance.
VISIBILITY OF DATA ENABLES
A TRUSTED THIRD PARTY TO
MONITOR AND TRACK SPEND AND
REVENUE DATA IN REAL TIME.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 29

Introducing our
CORPORATE PARTNERS
For further information and to discuss the opportunities of entering into a
Corporate Partnership with the CICM, please contact luke.sculthorp@cicm.com
My DSO Manager is an intelligent SaaS AR and
credit management solution for SMEs to international
enterprises, helping AR analysts manage risk,
maximize cash collection and streamline the credit-tocash
cycle, by a real-time insight to KPIs.
Due to its inventive in-house IT teams and their tight
collaboration with support staff, many of whom were
credit managers at large firms, it can quickly integrate
any ERP data and customize as needed.
T: +33 (0)458003676
E: contact@mydsomanager.com
W: www.mydsomanager.com
Quadient AR by YayPay makes it easy for B2B
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Integrating with your ERP, CRM, and billing
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E: marketing@yaypay.com
W: www.quadient.com/en-gb/ar-automation
Esker’s Accounts Receivable (AR) solution removes
the all-too-common obstacles preventing today’s
businesses from collecting receivables in a
timely manner. From credit management to cash
allocation, Esker automates each step of the orderto-cash
cycle. Esker’s automated AR system helps
companies modernise without replacing their
core billing and collections processes. By simply
automating what should be automated, customers
get the post-sale experience they deserve and your
team gets the tools they need.
T: +44 (0)1332 548176
E: sam.townsend@esker.co.uk
W: www.esker.co.uk
The UK’s No1 Insolvency Score, available as a
platform to help businesses manage risk and
achieve growth. The only independently owned
UK credit referencing agency for businesses. We
have modernised the way companies consume
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our customers are always the first to know. Enabling
them to deliver best in class sales, credit risk
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T: +44 (0)330 460 9877
E: sales@redflagalert.com
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Our Creditor Services team can advise on the best
way for you to protect your position when one of
your debtors enters, or is approaching, insolvency
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T: +44 (0)2073 875 868 - London
T: +44 (0)2920 495 444 - Cardiff
W: menzies.co.uk/creditor-services
HighRadius provides a cloud-based Integrated
Receivable Platform, powered by machine learning
and AI. Our Technology empowers enterprise
organisations to reduce cycle time in the order-tocash
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Genius provides solutions designed to enhance your
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Building on our mature and hugely successful
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E: info@credica.co.uk
W: www.credica.co.uk
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 30

Each of our Corporate Partners is carefully selected for
their commitment to the profession, best practice in the
Credit Industry and the quality of services they provide.
We are delighted to showcase them here.
They're waiting to talk to you...
Hays Credit Management is a national specialist
division dedicated exclusively to the recruitment of
credit management and receivables professionals,
at all levels, in the public and private sectors. As
the CICM’s only Premium Corporate Partner, we
are best placed to help all clients’ and candidates’
recruitment needs as well providing guidance on
CV writing, career advice, salary bench-marking,
marketing of vacancies, advertising and campaign
led recruitment, competency-based interviewing,
career and recruitment trends.
T: 07834 260029
E: karen.young@hays.com
W: www.hays.co.uk/creditcontrol
Court Enforcement Services is the market
leading and fastest growing High Court Enforcement
company. Since forming in 2014, we have managed
over 100,000 High Court Writs and recovered more
than £187 million for our clients, all debt fairly
collected. We help lawyers and creditors across all
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later. We achieve 39 percent early engagement
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T: 07759 122503
E: s.evans@courtenforcementservices.co.uk
W: www.courtenforcementservices.co.uk
TCN is an industry leader in call centre technology
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With over 45 years of experience in supporting
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driven communication solutions including Docmail
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Top Service Ltd. The only credit information and
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UK construction industry. Our payment experiences
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assess credit risk and make the best, most informed
credit decisions. Coupled with our range of effective
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Invevo is a cloud-based platform specialising
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TOP SERVICE
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Key IVR provide a suite of products to assist companies
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service gives the end-user the means to make a
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In a credit management environment, these services
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Shakespeare Martineau provides expert debt and
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Our 70+ experts offer cradle-to-grave B2B and B2C
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E: jayne.gardner@shma.co.uk,
W: www.shma.co.uk
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 31

COUNTRY FOCUS
on India
A passage
to India
India is much more than
its stereotypes.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 32

INDIA has previously been described by Indian-born
English author Rudyard Kipling through the voice
of one his characters, Kim, as ‘a fair land — a most
beautiful land is this of Hind — and the land of the
Five Rivers is fairer than all…’
However, in 2010 the University of Illinois wrote
that depending on which films, TV shows or magazines they're
viewing, Westerners may be left with contradictory impressions
of India – as a nation with a thriving information technology
industry, as a third-world nation overwhelmed by poverty and
famine, or as a spiritual mecca with an exotic, mystical culture
frozen in a more primitive time.
The reality is clearly more nuanced and by way of example, to
some Americans, every Brit knows the king personally and life
revolves around drinking tea. That may be true in some circles,
but not many.
And so it is that India has become known more for some things
than others. Obvious are the independence activist Mahatma
Gandhi; the Taj Mahal – the monumental memorial tomb in
Agra for the beloved wife of a Mughal emperor; the originator
of yoga some 5,000 years ago; the Statue of Unity near Kevadia
– the world’s largest statue at 182m; 3,000 or so tigers – the most
in any one country; and naturally, curry – which, as a word,
doesn’t exist in India officially. But India is much more than its
stereotypes.
Ancient history
Turning the clock back, the Asia Society believes that there’s
evidence of humans in South Asia some two million years
ago. Around 30,000 years ago, stone age hunters and gatherers
inhabited sites in the area. Between 5,000 and 2,000 BC, highly
organised settlements spread throughout what is now presentday
Pakistan and northern India.
By the first century AD, the Kushans, a group of nomadic warriors
from central Asia, conquered the Gandharan region of northern
India, Pakistan, and Afghanistan. Regional centres were brought
together under Gupta control in the fourth century and the next
few centuries saw invasions by Turkic and Central Asian rulers.
In 1526 came a Mughal empire was founded by Babur, a Turkish/
Central Asian chieftain.
From the start of the seventeenth century Europeans became
present in South Asia as traders, but it was not until the middle
of the eighteenth century that the British established rule in the
region. Mughal control waned in the eighteenth century, and
British power expanded. The Battle of Plassey in 1757 gave the
British control of the province of Bengal. And by 1857, the time
of the ‘Mutiny’ – or the First War of Indian Independence - the
British took control from Mughals but that still left nearly 40
percent of the region in the hands of quasi-independent rulers.
Post world war two saw independence - in 1947 – with Pakistan
(East and West) and India formed out of the British empire in
India. In 1971, East and West Pakistan went their separate ways
to become Bangladesh and Pakistan.
x Royal Enfield is an Indian
multinational motorcycle
manufacturing company,
headquartered in Chenna in
India. The Royal Enfield brand,
including its original English
heritage, is the oldest global
motorcycle brand in continuous
production.
THERE IS SO MUCH
GOING FOR INDIA
THAT BRITISH
EXPORTERS
WOULD BE FOOLS
TO IGNORE IT AS A
DESTINATION.
Brave Brave | Curious | Curious | | Resilient / / www.cicm.com / / October 2024 2024 / / PAGE 33 33 continues on page 34 >

COUNTRY FOCUS
Disputed geography
Officially known as the Republic of India, it’s
located in South Asia and sits on the coast with the
Arabian Sea to the west, Indian Ocean to the south
and Bay of Bengal to the east. It is bounded by
Pakistan to the west; China, Nepal, and Bhutan to
the north; and Bangladesh and Myanmar (Burma)
to the east.
Notably, the Indian Government regards
Afghanistan as a bordering country, as it considers
all of Kashmir to be part of India. However, this is
disputed, and the region bordering Afghanistan is
administered by Pakistan.
India is the world’s seventh largest country by area
with a total area of some 3.28m km 2 . It’s behind
Australia with 7.74m km 2 and the US and China
with 9.5m km 2 each. The UK is 78th with ‘just’
244,376 km 2 . The country has a land frontier of
15,200 km and a coastline of 7,516.6 km.
The northern border of India is mostly bounded by
the Himalayan mountains. The west – with Pakistan
– sits on the Western Himalayas, Punjab Plains,
Thar Desert and salt marshes. The eastern border
is made up of the Khasi and Mizo Hills. Notably,
India is the Indian tectonic plate; it’s movement
north led to the formation of the Himalayas when
the Indian tectonic plate collided with the Eurasian
Plate.
As for climate, given the size of India, it’s not very
surprising that its landmass features six distinct
regions – Himalayan mountains in the north,
Peninsular Deccan Plateau, the Indo-Gangetic
Plains, Thar Desert in the west, Coastal Plain, and
the Islands.
The Himalayas act as a barrier to winds from
Central Asia and China and enable India’s climate
to be warmer than other countries at similar
latitudes; the north is characterised by hot summers
and cold winters. The coastal regions see warmer
temperatures with little variation throughout the
year and frequent rainfall. To the west are arid
and semi-arid climates including the Thar desert
region. However, the Southwestern region of India
has a wet tropical climate with high annual rainfall.
The east coast of India also sees consistently
high temperatures and high precipitation rates.
The central regions experience greater seasonal
temperature variation.
Indian demographics
India’s population is huge and is now globally the
largest with some 1.43bn souls (2023, World Bank).
It’s population has trebled in just over sixty years
from 446m in 1960, 870.4m in 1990 to 1.4bn in 2020.
In comparison, the UK’s population has almost
flatlined with 52.4m in 1960, 57.2m in 1990 and 67m
in 2020.
INDIA IS ALSO THE
SECOND LARGEST
MANUFACTURER OF
MOBILE HANDSETS
IN THE WORLD AND
HAS BEEN ACTIVELY
COURTED BY THE
LIKES OF APPLE.
India
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 34

CREDIT MANAGEMENT
India is the world’s largest democracy but it’s also a
very ‘young’ country. According to the CIA World
Factbook (2022), the median age of an Indian was
28.7 years. In comparison, 38.4 in China, and 40.7 in
the UK (ONS data).
The age pyramid shows the same and the Indian
Express observed that over half of India’s population
is still under age 30. According to Statista, those aged
0-14 years made up 25.31 percent of the population,
15-64 year olds were 67.8 percent, and those aged 65
years or older comprised just 6.9 percent.
Looking at the population pyramid generated by
the US Census Bureau International Data Base, the
fertility rate has dropped. The base is much wider
with a very distinct male surplus until the mid-40s.
From age two to around 20, the base is expanding.
From then until 30 there’s a gentle tail off. But from
30 until 50 years of age the thinning out of the
population is marked while ever year there after the
population decline is rapid. Indeed, there are very
few people aged over 80 and almost none over 90.
Multiple languages
Being a large nation India is very diverse. There
are some 23 official languages of which 22 are
listed in the Eighth Schedule to the Constitution
of India plus there’s English. Further, the 2001
census recorded 30 languages spoken by more than
a million and 122 which were spoken by more than
10,000 people.
Of the peoples there is a list as long as one’s arm that
at a top level includes the Andamanese, Dravidian,
Indo-Aryan, Iranic, Semitic, Tai, Tibeto-Burman
and Turkic.
As to where the population lives, according to
the Office of the Registrar General & Census
Commissioner, India (2011), there were 48 cities with
a population of one million or more with Mumbai
top (12.4m) followed by Dehli (11m), Bangalore
(8.4m), Hyderabad (6.9m) and Ahmedabad (5.5m).
Similarly, there were another 252 cities with
between 100,000 and one million inhabitants.
Economic change
India’s economy has undergone huge change in
recent years. As the World Bank commented in
September 2023, India is one of the fastest growing
economies of the world and is poised to continue
on this path, with aspirations to reach high middleincome
status by 2047.
GDP has grown from $37.03bn in 1960 to $321bn in
1990 and $2.67tn in 2020. It’s estimated to be $3.5tn
in 2023. In comparison, the figures for the UK saw
$73.23bn in 1960, $1.09tn in 1990 and $2.69tn in 2022
and is estimated to be $3.3tn in 2023 (World Bank
data).
World Bank data puts the US in first place with
a GDP of $27.3tn, followed by China with $17.7tn,
Germany with $4.4tn, Japan with $4.2tn and India
in fifth place with $3.5tn.
Export opportunities
Given the size of India and it’s recent rate of growth
that it’s not surprising that there are quite a number
of sectors of interest for UK – and other – exporters.
What follows is not an exhaustive list.
Agriculture
India is described by the US Trade Department
as an agrarian economy with half of its workers
employed in agriculture-related sectors cultivating
more than 54 percent of the nation’s land. India
produces rice, wheat, cotton, sugar, horticultural
products and dairy and overall, related sectors
account for 20.2 percent of the country’s GDP.
The sector is moving from traditional farming to
horticulture and livestock production.
India’s food and grocery retail businesses are
estimated to be worth $570bn and are dominated
by neighbourhood shops. That said, there are in
excess of 8,000 modern retail outlets across India.
Invest India reckons that India has the highest
number of organic farmers in the world at 44.3m
using 59.1m hectares of land. They produce certified
organic products including all varieties of food
products such as oil seeds, fibre, sugar cane, cereals
and millets, cotton, pulses, aromatic and medicinal
plants, tea, coffee, fruits, spices, dry fruits,
vegetables, and processed foods.
Interestingly, India the highest producer of milk in
the world – 24.64 percent of global milk production
in 2021-22 with 230.58 tonnes in 2022-23.
Aerospace and defence
Growth in middle-income households combined
with the rise of low-cost carriers and investment in
airports has given the aviation sector a push.
Invest India states that the country has 157
operational airports of which 137 are airports, two
are water aerodromes and 13 are heliports. Some
33 are international, 133 are domestic, and 11 are
custom airports. Domestic passenger numbers
rose from 60m in 2014 to 143m in 2020 prior to
COVID-19. Similarly, international passengers
grew from 43m to 64m. And aircraft numbers
have swollen from 400 or so in 2014 to 723 in 2023.
The US Trade Department believes that India is
projected to have more than 500 million domestic
and international air travellers by 2030 and has the
potential to become the world’s leading aviation
market by 2047.
Brave | Curious | Resilient / www.cicm.com /October 2024 / PAGE 35 continues on page 36 >

COUNTRY FOCUS
It also notes India’s Vision 2040 strategy document that
is planning for a five-fold increase in the number of
airports needed to handle over a billion passenger trips
a year.
On defence, India has the third largest armed forces in
the world and plans to spend billions over the next several
years. India wants to reduce its reliance on imports; its
total 2023 defence budget is $72bn of which $20bn is for
the procurement of domestically manufactured weapons
and military platforms. Demand for innovative, nextgeneration
technologies remains.
Automotive
Invest India states that India is the world’s largest
manufacturer of two-wheeled vehicles, with over 21m
produced annually, the world’s largest manufacturer
of tractors, the world’s third largest heavy truck
manufacturer, and the fourth largest car manufacturer.
It also notes that 37m people are employed in the sector.
The British Council echoes this saying that the sector
contributes nearly 6.4 percent of GDP and 35 percent of
manufacturing GDP. It adds that there is strong backing
from government for developing India’s electric vehicle
industry.
Healthcare
Another sector of interest is healthcare, a sector that has
seen rapid growth and change in recent years. It helps,
of course, that the Indian population is growing at a
rate of 0.7 percent (World Bank, 2022) a year and now
has an elderly population of over 100m. This, along with
rapid economic growth, rising middle class incomes,
and increased market penetration of health insurance
providers has boosted the sector to be worth, according
to the US Trade Department, over $370bn in 2022.
Nexdigm thinks that it could be worth over $610bn by
2026. All of this was given an extra level of importance
following the impact the pandemic had on the country.
Information Technology
ICT, says the US Trade Department, contributes 13
percent to GDP as India aims to grow the ICT sector to
$1tn by 2025, or 20 percent of predicted GDP. The National
Association of Software and Services Companies expects
India’s technology industry to have become worth $245bn
in 2023. Notably, Invest India thinks that the sector is
worth just 7.5 percent of GDP. The sector features all
of the usual suspects including IT and business process
management, IT-enabled services, engineering research
and development, hardware, software products, and
e-commerce.
The Indian telecoms sector is the second largest in the
world by subscribers, with 1.2bn wireless and fixed-line
subscribers; mobile represents 98 percent of telephone
use. And Deloitte thinks that Indians will have one
billion smartphones in use by 2026. India is also the
second largest manufacturer of mobile handsets in the
world and has been actively courted by the likes of Apple.
vIndia is one of the largest tea producers in the world, although over 70
percent of its tea is consumed within India itself. A number of renowned teas,
such as Assam and Darjeeling, also grow exclusively in India. The Indian tea
industry has grown to own many global tea brands and has evolved into one of
the most technologically equipped tea industries in the world.
Invest India notes that the technology industry is
estimated to have 5.4m employees. It also believes that
more than 1,300 new tech startups emerged in 2022 and
over 280,000 employees were reskilled and made digital
skilled.
Travel
According to Invest India, the Government is aiming for
140m tourism jobs by 2030 through growth, especially
from cruises, ecotourism and adventure tourism, to aid
regional development.
By 2028, the sector is likely to generate revenue of over
$59bn. The objective, says Invest India, is to position
India as the foremost travel destination globally.
It’s worth highlighting, as the US Trade Department
comments, that growth of the large and increasingly
affluent middle class, along with their increasing amounts
of disposable income and the increased availability of
air transportation has driven an increase in outbound
international travel from India. Additional interest in
niche tourism sectors such as medical, wellness, and
adventure tourism has also contributed to growth.
Summary
There is so much going for India that British exporters
would be fools to ignore it as a destination. Population
growth shows no sign of slowing any time soon and as time
progresses, is getting wealthier and more demanding. It
is the pinnacle of emerging markets.
Author: Adam Bernstein is a freelance finance writer for
Credit Magazine magazine.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 36

DEBT RECOVERY
ON THE
WIND-UP
The Enforcement of non-UK Judgments in England
and Wales is beset with complexity.
BY PAULA SWAIN FCICM AND ANDREW TAYLOR
SINCE Brexit, the enforcement of EU
judgments in England and Wales has
become more complicated and is still
subject to change as we await proposed
amendments to the Civil Jurisdiction
and Judgments Act 1982. For other non-
UK judgments, creditors must rely on a
mixture of legislative and procedural rules for recognition
and enforcement. This can be time consuming and
expensive. This complexity means that creditors may wish
to consider insolvency proceedings in relation to their
unpaid non-UK judgment debts.
Post-Brexit Landscape
The legal landscape in England and Wales has undergone
significant changes following the departure of the UK
from the European Union, particularly in relation to the
enforcement of EU judgments.
Prior to Brexit, the enforcement of EU judgments was
relatively straightforward with a streamlined process
for recognising and enforcing judgments across member
states. However, since the UK’s departure from the EU,
this process has been disrupted, creating uncertainties
and challenges for creditors seeking to enforce judgments
in England and Wales.
One of the key issues arising from Brexit is the applicability
of EU regulations and the need for domestic legislation to
fill the gaps left by our departure. The Civil Jurisdiction
and Judgments Act 1982 is one such piece of legislation
that is expected to be amended to address these changes.
Until these amendments are finalised, the enforcement of
EU judgments remains in a state of flux, with creditors
needing to navigate a more complex and potentially
protracted process.
For holders of non-UK and non-EU judgment, they face
a reliance on elderly legislation and related common
law rules and procedures requiring them to have their
judgment recognised in England and Wales before they
can consider enforcement steps. Where there is legal
complexity, there is cost and time, and this can put off
some creditors from looking at assets based in England
or Wales.
Foreign Judgments
A foreign judgment for a sum of money is essentially a
debt. When there is no pending appeal or any other
contingency affecting its validity, it represents a liquidated
sum – a specific, determinable amount of money that is
owed. For creditors, this means that they can present a
winding-up petition against a debtor company based
in England or Wales in relation to that debt if they can
demonstrate that the debtor company is unable to pay its
debts as they fall due. Non-payment of a foreign judgment
is compelling evidence of this inability to pay.
In practical terms, this means that if a creditor has
obtained a judgment in their favour outside the UK,
and the debtor company in England and Wales has not
satisfied this judgment, the creditor has a strong basis for
arguing that the company is insolvent. This insolvency
can then be the foundation for presenting a winding-up
petition. Quoting a recent decision of Judge Jones in the
Business and Property Courts: ‘…an unrecognised foreign
judgment, incontrovertibly owed, is a liquidated sum not
subject to a contingency. It satisfies the requirements of
s267 Insolvency Act 1986…the judgment forms a debt
for the purposes of winding up without the need for
registration or recognition.
Winding-Up Petitions
A winding-up petition is a formal request to the court
to liquidate a company, typically on the grounds that it
is unable to pay its debts. For creditors dealing with the
complexities of enforcing non-UK judgments, this option
becomes particularly attractive. By pursuing a windingup
petition, creditors can bypass some of the procedural
hurdles associated with enforcing judgments through the
courts. If the petition leads to a winding-up order, and
the company is liquidated, then the Official Receiver or
appointed liquidator may be able to obtain a recovery
for the creditor – helping to part pay or fully repay the
judgment debt.
There are a number of tools available to liquidators, seeking
to claw back sums into the estate, where there have been
questionable transactions entered into by a company, in
the time leading up to it being wound up. These include
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 38

CREDIT MANAGEMENT
transactions at undervalue and preferences to connected and nonconnected
third parties. Directors’ conduct can also been looked at
and where there has been wrongful trading, they can be compelled
to make a contribution to the cash in the estate, for the benefit of
creditors. Finally, it’s worth remembering that transactions entered
into post presentation of a petition (if a winding up order is made)
are void and should be reversed for the benefit of creditors, under
Section 127 of the Insolvency Act.
Older Debts
The courts have recently clarified that, aside from a bar on accruing
interest after six years, there are no limitation issues for foreign
creditors seeking to present a winding-up petition. This means
that creditors are not precluded from pursuing older judgment
debts through insolvency proceedings. Quoting Judge Jones: ‘A
winding-up petition is neither designed to re-establish the liability
of the company nor a process of execution of the judgment. As a
consequence, section 24(1) Limitation Act 1980 does not apply in
insolvency proceedings.’
This decision is particularly important for creditors with judgments
that are more than six years old. In the case of winding-up petitions,
the absence of a strict time limit allows creditors to revisit older
judgments and consider insolvency proceedings as a viable option.
Strategic Considerations
Given the complexities and uncertainties surrounding the
enforcement of non-UK judgments in England and Wales, creditors
need to adopt a strategic approach to debt recovery. Winding-up
petitions offer a potentially effective route for creditors facing
difficulties with traditional enforcement methods and they could
lead to a recovery depending on the financial position of the debtor
company.
When considering a winding-up petition, creditors should:
1. Check for signs of insolvency, such as unpaid invoices, defaults
on loans, or other outstanding debts.
2. Collect any additional evidence, such as correspondence with the
debtor acknowledging the debt or failed payment promises. This
can be useful for building the case that the company is insolvent.
3. Consider obtaining expert legal or insolvency advice. Legal and
insolvency professionals specialising in cross-border insolvency
and debt recovery can provide guidance on the best course of
action and help to navigate the procedural complexities.
4. Keep up-to-date with any amendments to the Civil Jurisdiction
and Judgments Act 1982 or other relevant legislation. Changes in
the law could impact the strategy adopted.
Conclusion
The enforcement of non-UK judgments in England and Wales can
be complex, time consuming and expensive. A winding-up petition
might offer a practical and potentially effective alternative. It’s
worth considering with your advisers.
Authors: Paula Swain FCICM, Partner and Andrew Taylor, Partner
at Shakespeare Martineau.
A WINDING-UP
PETITION IS A
FORMAL REQUEST
TO THE COURT
TO LIQUIDATE
A COMPANY,
TYPICALLY ON
THE GROUNDS
THAT IT IS UNABLE
TO PAY ITS DEBTS.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 39

ACCOUNTING | FINANCE | BUSINESS
OUR SERVICES TO CREDITORS:
MAXIMISE YOUR RECOVERIES
When one of your debtors enters, or is approaching, insolvency proceedings, we can
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Reviewing and analysing all Insolvency Reports
and correspondence.
Fully explaining the process, your rights
and likely outcomes in user friendly terms.
Representing you at Creditor Meetings and on
Creditors’ Committees.
Completing and lodging your claim
forms, proxy forms and any other
necessary documentation.
Assisting you with any Retention of
Title Claims.
Monitoring dividend prospects.
CONTACT OUR AWARD WINNING TEAM!
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Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 41

ENFORCEMENT
MAINTAINING
TRUST IN JUSTICE
How to combat fraud in the enforcement sector.
BY MICHAEL JACKSON FCICM
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 42

CREDIT MANAGEMENT
FRAUD is a growing concern across
the economy, and enforcement
and legal sectors are not immune.
Fraudsters, posing as High Court
Enforcement Officers (HCEOs),
Certificated Enforcement Agents
(CEAs), or HMCTS County
Court Bailiffs, are attempting to exploit individuals
and businesses by demanding payments under false
pretences. This criminal activity not only harms
victims but also damages the reputation of the courts,
legitimate enforcement and legal businesses.
The impersonation of Enforcement Agents by
fraudsters has a hugely detrimental effect on genuine
businesses. These activities lead to a loss of trust in
enforcement processes, making it more challenging for
certificated officers to perform their duties.
Fraudsters often use sophisticated tactics, presenting
themselves convincingly by providing what appears
to be authentic documentation and using appropriate
legal terminology. This complexity makes it difficult
for individuals to distinguish between genuine
enforcement actions and fraudulent schemes, further
eroding trust in the system.
Tactics now extend to setting up convincing websites
copied from existing enforcement businesses, legal
practices, and financial institution (these can even
include hi-tech online payment portals) and producing
highly sophisticated ID cards to impersonate
Enforcement Agents.
Industry Measures
Financial institutions have implemented stringent
measures to combat fraud, including thorough identity
verification when opening accounts and ongoing
monitoring of transactions. Despite these efforts,
fraudsters continue to find ways to circumvent these
safeguards, often operating on an industrial scale.
Impersonation of Enforcement Agents is a serious
crime, punishable by fines and even incarceration.
However, identifying and convicting the individuals
responsible is becoming an increasingly difficult
challenge for the authorities.
Combating Fraud
Raising awareness about enforcement fraud is
crucial. Public education initiatives help individuals
recognise the signs of fraud and understand the
correct procedures for enforcement actions. Resources
such as the HCEOA and CIVEA websites and the
Government’s Stop! Think Fraud campaign provide
valuable information and support. Victims of fraud
should report the incident to the police and register
it with Action Fraud to ensure the crime is officially
recorded and investigated.
Professionals in the sector are also targeted for their
personal information to aid scammers in creating fake
ID cards and communication. Knowing the difference
between a genuine request and a suspicious one can
help protect your information and prevent fraudsters
from using your credentials.
Detecting and Responding
to Fraud
Individuals and businesses must be vigilant and
informed about enforcement processes to protect
themselves from fraud.
If you receive a request for your credentials from
someone you don’t know, or are not expecting contact
from, you should:
1. Not provide any personal or professional details,
including any copies of ID they may ask for.
2. Research the organisation they claim to be working
for online using an independent search engine
and contact them directly using verified details to
confirm whether the request is genuine.
3. Report the incident to the company you work for
to make sure others are aware in case they are also
targeted. Your manager or compliance team may also
be able to help determine whether it is a genuine
request.
4. Raise a case with the police at your local station and
Action Fraud at https://www.actionfraud.police.uk/
Enforcement fraud poses significant challenges to both
victims and legitimate businesses. By maintaining
rigorous verification processes, raising public
awareness, and adhering to professional guidelines,
the enforcement and legal sectors can help mitigate
the impact of fraud. Protecting the integrity of
enforcement processes is essential to maintaining trust
in the justice system.
Michael Jackson FCICM is Vice Chair of the High Court
Enforcement Officers Association (HCEOA).
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 43

STUDENT OF THE YEAR
FRONT RUNNER
From the Welsh valleys to Student of the Year.
BY MEL YORK
WILLIAM Peters grew up
in Swansea on the Welsh
coast, with a love of maths.
He was a diligent student
but always did especially
well in maths-related
subjects. He therefore
decided to play to his strengths and study accounting and
finance at the University of Plymouth. Whilst there, he
achieved a First Class honours degree and won the Chartered
Institute of Credit Management’s Student of the Year Award.
Although he admits to being a little surprised at the news, he
says: “I was very honoured; it’s a great privilege.”
As part of his degree, he studied a credit management
module. The lecturer told the students the CICM offered
a cash prize to the person who achieved the highest grade
for the credit analysis assignment. Fired up by the challenge,
William recalls: “I was very excited and thought, ‘Let’s go for
this.’ We had to analyse the performance, finances, and credit
status of a company and determine an appropriate credit
limit. Thankfully, all the work paid off.”
Proud of the certificate he received, William is putting the
cash prize towards a Master’s in International Finance and
Banking at Exeter University. Receiving the award was a
real confidence booster for him and opened his eyes to a
potential career in credit management. “I like the whole
analysis that’s involved with credit management. It’s very
interesting. It gives you a real view of how these companies
are working.” He thinks a career in credit management is a
definite possibility and remains open to exploring different
career options during his Master’s programme.
Family Fun
Whilst William says his three years at Plymouth have been
amazing, he is ready for a new challenge at Exeter. He says
he’s willing to try anything, a trait encouraged by his mum
and dad from a young age, and he may even return to his love
of running, which he was introduced to as a child.
to be joking!’ but William was immensely proud to say
she completed the challenge and now he thinks it’s his Dad’s
turn.
“Dad warned me never to buy a 10K race for his Christmas
present – but he didn’t say anything about birthdays,”
William jokes. The fun and support of his family have played
a significant part in his success so far. He has a younger
brother and sister. Amy is 10, funny, and full of life. His
brother James has just completed his GCSEs and, although
he lives with CHARGE syndrome, remains a typical cheeky
teenager. They are a close-knit family. William treasures
going home during the holidays and his family’s regular visits
from Wales.
Charity Challenge
William’s family have also helped and supported his charity
and fundraising activities. At 16 he went on a school trip to
India visiting an orphanage in the Delhi area and different
schools and farms up in the Himalayas. William then
organised a sponsored Tough Mudder Challenge which is the
hardest race William has ever run – a 10K course filled with
obstacles such as crawling through the Kiss of Mudd, climbing
up a slippery Everest slope and over a Mudderhorn, taking a
dunk in an ice pit, and a clamber through to the finish line
through Electric Shock Therapy.
He says whilst it was fun, it isn’t one to repeat: “At least in
other races, I wasn’t getting electrocuted or muddy. That’s
a real positive,” he laughs. William’s family took on the
challenge with him – he persuaded his uncles and cousin
to join in: “They even enjoyed it,” he claims. “For everyone
involved, it was a fun day out, a big family event.” He is keen
to do more volunteering in the future, just maybe not the
electrifying kind!
William’s parents started entering him into 1K runs when
he was six or seven years old ‘just for fun’. It sparked his
enthusiasm, and he has run ever since, including during his
GCSEs. Although he ran less during his time at Plymouth, he
still completed the Swansea 10K in 2022.
As a Christmas surprise, his mother entered him in the
Swansea half marathon: “I was like, thanks, mum, that’s a
great Christmas present,” he laughs. He got his own back
by entering her into the 10K race the following year. Not
a runner herself, her initial response was, ‘You’ve got
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 45

HR MATTERS
SEX ON THE
BREACH
Companies must take care not to fall foul of new
sexual harassment rules
BY GARETH EDWARDS
SEXUAL harassment in the workplace
has been an issue for some time with
countless cases being reported in the
media – cases that have involved some
high-profile individuals. But beyond the
famous, there are a multitude of cases
elsewhere.
Of course, many employers will have a tried-and-tested
approach to dealing with workplace sexual harassment.
This is likely to involve staff training, the maintenance
of up-to-date policy documentation, and an approach to
ensuring issues are dealt with robustly when they arise.
However, from 26 October, employers have a new duty
and will be required to take ‘reasonable steps’ to prevent
the sexual harassment of staff at work. Those that fail
to take such steps risk a compensation uplift of up to 25
percent in the event of a successful claim against them.
Given that compensation awards for harassment claims
are uncapped, there could be a high cost of failure to
comply with the new duty.
In anticipation of the new duty, employers will be
wondering whether their existing approach to the
management of workplace sexual harassment will be
sufficient to comply. The answer is that in many cases,
employers need to do more.
But determining what constitutes ‘reasonable steps’ for
an employer will depend on individual circumstances.
Factors such as the employer’s size, the sector in which
it operates, and the way it identifies and manages risks
are all likely to be material. To effectively prepare for the
new duty, employers should reflect on their current sexual
harassment strategy, and make improvements where
necessary. It is also sensible to make contemporaneous
records to explain an employer’s strategy and approach
over time. This ensures that appropriate evidence can be
presented to the Tribunal in the event of a future claim.
The background
To understand the practical impact of this new law on
employers, it is helpful first to reflect on recent legal and
policy developments in this area. Numerous high-profile
cases and campaigns have highlighted the need for enhanced
protection against sexual harassment at work. It was
against the backdrop of campaigns such as the #MeToo
movement that the Government consulted in 2019 on a
proposal to reform the law in this area. This consultation
prompted the Government to introduce a new duty for
employers to take '‘all reasonable steps’ to protect workers
from sexual harassment in the workplace, and express
protection for workers against third-party harassment
at work.
The original Bill, when it was introduced to Parliament,
set out to achieve both these things. However, as the Bill
progressed, it was amended, and the resulting Worker
Protection (Amendment of Equality Act 2010) Act
2023 introduces a mandatory duty to protect staff from
workplace sexual harassment. It contains no express
protection against harassment by third parties, although
this is not to say that employers should not consider any
particular risk posed to their staff by third parties at work.
New mandatory duty
The Act introduces a mandatory duty on employers to
take ‘reasonable steps’ to prevent sexual harassment
of employees in the course of their employment. The
original proposal for the duty to encompass a requirement
to take ‘all’ reasonable steps was removed by the House
of Lords. The rationale given at the time to explain this
amendment was that as the new law was to apply to thirdparty
harassment, it would require employers take an
‘almost infinite’ number of steps to comply. The concern
was that compliance with a new duty expressed in these
terms would place too high a burden on employers. For
this reason, the requirement to take ‘all’ reasonable steps
was watered down.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 46

CREDIT MANAGEMENT
Employers should nevertheless be wary of falling into
the trap of thinking that because of this amendment
to the Bill, nothing is changing in terms of their legal
obligations. The mandatory duty is a much broader duty
than any other obligation existing under existing antiharassment
law. The question of what will constitute
‘reasonable steps’ for any individual employer merits
careful consideration and will depend on factors such as
the type of organisation and the harassment risks that are
present at that workplace.
Changing defence
Employers and HR professionals might be aware that
under existing law, there is a potential defence available to
employers facing harassment claims, where the employer
can show they took ‘all reasonable steps’ to prevent the
employee from carrying out the harassment. Where the
reasonable steps defence succeeds, the employer will
escape liability, leaving the harasser potentially personally
liable if they have been named as a respondent in the
litigation.
The new mandatory duty is different from the existing
reasonable steps defence. The reasonable steps defence
applies in a much narrower context, i.e. in demonstrating
that an employer took necessary action to prevent
a particular employee from displaying a particular
behaviour. In contrast, the mandatory duty will apply on
an organisation-wide basis to all employees and is likely to
call into question the organisation's culture and approach
more generally.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 47
continues on page 48 >

HR MATTERS
Third-party harassment
Despite the comments made in the House of Lords when
the Bill was debated, the express provisions relating to
third-party harassment were also removed from the Bill
before it was passed as the Act. These provisions were
removed due to concerns over freedom of speech and the
practical burden that would be placed on employers with
respect to policing the behaviour of third parties such as
customers.
The removal of the third-party harassment provisions
from the Bill has caused discussion amongst commentators
in anticipation of the impact of the new law. Employers
should note that although the explicit third-party
harassment provisions were removed from the Act, the
new mandatory duty may still encompass a requirement to
manage the risk of third-party harassment where relevant.
Again, the requirements of any given organisation will
depend on the sector in which they operate, and the
particular risk of staff being exposed to third-party
harassment at work. Employers should therefore consider
the risk of third-party harassment as part of the general
requirement to comply with the mandatory duty.
Enforcement methods
There are two ways the new mandatory duty will be
enforced. Either the Employment Tribunal may apply a
compensation uplift of up to 25 percent for breach of the
mandatory duty in successful sexual harassment claims,
or the Equality and Human Rights Commission (EHRC)
will be able to take direct enforcement action against
employers who breach the mandatory duty. In terms of
the compensation uplift, to pursue an employer for breach
of the mandatory duty, an employee will need to bring a
successful harassment claim under the Equality Act. If that
claim succeeds, the Tribunal may apply the compensation
uplift at an appropriate percentage to reflect the extent
to which the employer has breached the mandatory duty.
The Tribunal may be likely to apply the compensation
uplift precisely because, for the claim to succeed in the
first place, the employer will either have failed to invoke
the reasonable steps defence or will have been unsuccessful
in doing so. If an employer has failed in the reasonable
steps defence, it is likely to also fail to show that it has
complied with the mandatory duty. In real terms, the
practical impact of the mandatory duty is likely to be a
compensation uplift of up to 25 percent in almost any
successful sexual harassment claim. Given that sexual
harassment is a claim for which the Tribunal has the
power to award unlimited compensation, a failure to
comply with the mandatory duty could prove very costly.
Third-party harassment
There is currently no explicit liability on an employer
for third-party harassment since the relevant provisions
of the Equality Act were repealed in 2013. The current
legal framework relates to the conduct of an employer or
individual employees only. This means that if the treatment
suffered by a worker is purely third-party harassment, it
will not be possible to bring a successful sexual harassment
claim in respect of which the compensation uplift can be
applied.
It would however be short-sighted of an employer to
disregard the issue of third-party harassment purely on
this basis. If an organisation fails to address the potential
for third-party harassment, it could significantly influence
the level of compensation uplift the Tribunal may award
in a successful sexual harassment claim involving employee
conduct.
CHANGE IS
COMING AND
EMPLOYERS
NEED TO TAKE
NOTICE AND
RECOGNISE
THEIR NEW
DUTY.
EHRC enforcement action
The EHRC has the power to investigate alleged noncompliance
with equality law. In the event of a breach,
the EHRC can issue notices to organisations in relation
to their unlawful acts. A notice would require the
organisation to prepare a draft action plan setting out
how it will remedy its breach. The EHRC may approve the
plan or require improvements to be made to it. The EHRC
takes enforcement action against individual employers
rarely but may do so in the event of serious breaches of
equality law.
The EHRC is the only entity able to bring standalone
enforcement action against an employer for failing to
comply with the mandatory duty. As employees will need
to first bring a successful sexual harassment claim before
accessing the compensation uplift, they will not be able to
enforce the mandatory duty without also having suffered
harassment.
Summary
Change is coming and employers need to take notice
and recognise their new duty. It is going to be enforced
and employers that ignore the law could find themselves
paying for expensive awards made against them.
Aurthor: Gareth Edwards is a partner in the employment
team at VWV.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 48

2000+ CLIENTS
87 COUNTRIES
Rexel, Veolia, Atlas Copco, Metso,
PROMAN, In Extenso, Assa Abloy,
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MY DSO MANAGER..
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China, have been invaluable. The
synergy between My DSO Manager’s
in-house IT team and dedicated credit
project managers, , along with close
collaboration and regular follow-ups
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Romy Tognon
Head of Group Treasury - REXEL
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 49
“ My DSO Manager has been a game-
changer for us. . It's easy to integrate,
fluid, works well and is great for daily
credit management.
It allows us to
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less tedious, and everyone knows
exactly what needs to be done.
We can clearly identify and codify
overdue receivables, which has
improved our efficiency significantly. “
Karine Deniau
Dunning Agent - METSO

LOOKING FOR
YOUR NEXT
CAREER MOVE?
ACCOUNTS RECEIVABLE MANAGER
Covent Garden, £45k-£60k
A fixed term contract opportunity to work for a well-established
and thriving business who are pioneers in the skincare industry.
Reporting to the Group Financial Controller, you will manage a
team of two credit controllers. They are looking for someone
with brilliant organisational skills as you will be managing
the full end-to-end AR process, including taking hands-on
responsibilities for high-profile clients/customers.
Ref: 4540727
Contact Raphaella James on 020 3465 0020
or raphaella.james@hays.com
CREDIT CONTROL SUPERVISOR
Fully remote, £38k
You will be responsible for overseeing the collections
process for the firm’s clients, this includes supervising a
team, monitoring collection activities, implementing effective
collection strategies, and ensuring compliance with legal and
regulatory requirements. The ideal candidate should have a
strong background in collections, and a minimum of three
years of supervisory experience in a high volume, fast paced
environment. Ref: 4597579
Contact Sejal Hampson on 07816 406959
or sejal.hampson@hays.com
ACCOUNTS RECEIVABLE SPECIALIST
London, Up to £32k
As an expert brand activation agency are looking for a skilled
Accounts Receivables Specialist to join their dynamic team.
The Accounts Receivable Specialist will be responsible for
managing incoming payments, tracking them accurately in the
system, and maintaining up-to-date bookkeeping records.
To be successful in this role you need to have experience
working within a credit team in the media industry, dealing with
high volumes of invoices. Ref: 5450323
Contact Katie Bohun on 020 3465 0020
or katie.bohun@hays.com
SENIOR CREDIT CONTROLLER
Trafford Park (Manchester)/Hybrid Working, £28k-£30k
A global business based in Trafford Park (Manchester) are
seeking an experienced Credit Controller due to company
expansion. Reporting to the Credit Manager you will work as
part of a small credit team alongside two Credit Controllers and
be tasked with managing your own b2b ledger, chasing overdue
monies via phone, portal, email, allocating cash & customer
query resolution. Proficiency SAP would be advantageous.
Hybrid — 3 days office, 2 work from home. Ref: 9265254
Contact Joanna Taylor-Coburn on 0161 926 8605
or joanna.taylor-coburn@hays.com
hays.co.uk/credit-control-jobs
© Copyright Hays plc 2024. The HAYS word, the H devices, HAYS WORKING FOR YOUR TOMORROW and Powering the world of work and associated logos and artwork are trademarks of Hays plc.
The H devices are original designs protected by registration in many Brave countries. | Curious All rights | Resilient are reserved. / www.cicm.com CM-00426 / October 2024 / PAGE 50

TEMPORARY CREDIT CONTROLLER /
BILLINGS (KEY ACCOUNTS)
Chertsey, £18 an hour + holiday pay
A skilled OTC candidate is required to join a leading Surrey
based business on a long-term temporary basis. Responsible for
your own ledger of key accounts, your varied duties will include
raising invoices, chasing payments, allocating cash and aged
debt reporting. Building solid working relationships (internally &
externally), query resolution and complex account reconciling
will also form part of this role. Ref: 4601451
Contact Natascha Whitehead on 07770 786433
or natascha.whitehead@hays.com
CREDIT CONTROLLER
Birmingham, £28k-£32k
Reporting to the Credit Manager, you will manage your own
ledger and will be responsible for maximising the collection
of debt and ensure remedial solutions are provided to ensure
overdue debt and collections are achieved in line with targets.
The role is hybrid, working in the office twice a week.
Ref: 4578382
Contact Henry Brook on 0300 010 7517
or henry.brook@hays.com
This is just a small selection of the many opportunities
we have available for credit professionals. To find out
more, visit our website or contact Natascha Whitehead,
Credit Management UK Lead at Hays on 07770 786433.
Discover new
opportunities today
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 51

CAREERS
SHAPING
SUCCESS
Are credit professionals ready for AI?
BY NATASCHA WHITEHEAD FCICM
WHILST only 16 percent of
finance professionals have used
Artificial Intelligence (AI)
tools in their current role so
far according to our research,
this is certainly set to rise as
AI technologies advance and
organisations implement plans to take advantage of these tools.
However, the question remains: are professionals well equipped
to respond to the growing presence of AI across the world of
work? As tech evolves at such a rapid pace, keeping up can be a
real challenge, but there are actions we can take to stay informed
and utilise AI to the best of our ability. Here are five ways credit
professionals can unlock the opportunities that AI has to offer to
enhance their roles and simultaneously remain indispensable to
their organisation:
1. DEFINE CLEAR GOALS
Like any new technology, software or way or working, it’s
important to reflect on your overarching objectives and how you
can continue to strive to achieve these ambitions. Strip it back to
why your role exists and what success looks like in your position.
Whether you want to process and analyse vast amount of data
more efficiently, improve accuracy, automate repetitive tasks
to save time for more creative, human-centric responsibilities,
increase productivity or improve fraud detection and prevention.
In other words, what challenges are you currently facing and how
can AI help you to overcome these and to meet your professional
goals? The same thought process can be applied to assessing the
wider mission of your organisation as a whole and deciding what
tools and technologies need to be in place to align with this.
2. FIND RELEVANT TOOLS
Once you have a clearer understanding of what you want to get
out of AI, you can research the tools that are out there to discover
the ones that will work best for you. Some organisations will
outline the AI tools and technologies that they allow or encourage
you to use, so it’s important to keep your employer in the loop
about the tools you’ve come across and plan on using to ensure
you’re sticking to any company regulation and policy. There is
a multitude of AI-powered credit risk management software for
instance, so set aside some time to learn about what each one
offers and whether they tick the right boxes to align with your
goals.
3. UPSKILL ACCORDINGLY
The ability to use new AI tools to support your role won’t come
overnight, but instead will be a process involving trial and error
and a commitment to learn and upskill. Enrolling in courses
set up by your employer or external programmes is an effective
way of developing the skills necessary to get to grips with and
eventually utilise unfamiliar AI tools. Attend relevant webinars
and events, read journals and articles to build an awareness
and practice using AI in different ways and in different scenarios
to lay the groundwork for successful AI adoption going forward.
4. ENHANCE YOUR SOFT SKILLS
Soft skills, also known as core skills, are vital for a fulfilling career,
but they are particularly valuable when it comes to navigating
technological change. To ensure the human workforce stays
capable, employable and resilient in the face of AI, skills such as
communication, adaptability, problem-solving, time management,
critical thinking and creativity are non-negotiable. These kinds
of soft skills are timeless and transferable and professionals who
continually invest in developing a strong skillset will always be
an asset to organisations. Despite fears that AI will threaten jobs
and take over, the powerful and irreplaceable human element will
prove essential for working alongside AI and is a constant amidst
the uncertain and ever-changing nature of technology.
5. PROCEED WITH CAUTION
Last but by no means least, it’s crucial to use AI tools responsibly
and to be aware of the risks associated with these rapidly
advancing technologies. Always question and double check the
outputs that AI tools deliver as there is no guarantee they are
100 percent factual - whilst AI tools can certainly enhance our
day-to-day working lives, there are an array of limitations that
we shouldn’t turn a blind eye to. Be mindful of sharing personal
or sensitive data on AI tools as this can pose real security risks
and dedicate some time to familiarise yourself with the privacy
settings built into each tool. Remember the importance of
human judgement and be prepared to make your own decisions
rather than relying on AI too heavily. If the systems go down or
you’re in a circumstance where you can’t use the AI tools you’ve
incorporated into your daily routine, you still want to be able
to stand on your own two feet and get the job done to a high
standard.
Ultimately, taking advantage of, and collaborating with, AI is a
journey not a destination, one that will require a willingness to
learn, adapt, overcome obstacles and harness your soft skills, as
well as a healthy balance of optimism and caution.
Author: Natascha Whitehead is Senior Business Director
at Hays specialising in Credit Management.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 52

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THE PENINSULA, VICTORIA PLACE, MANCHESTER M4 4FB Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 53

CREDIT INSURANCE
CERTAIN
UNCERTAINTY
Economic uncertainty is leading to an
upsurge in UK Trade Credit Insurance.
BY SIMON PHILPIN
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 54

CREDIT MANAGEMENT
TRADE Credit Insurance (TCI) is
a financial product that protects
businesses against the risk of non
payment by their buyers. This
insurance is crucial for companies
engaged in both domestic and
international trade, providing a
safety net against potential losses due to insolvency,
bankruptcy, or prolonged default by customers. The
UK trade credit insurance market has seen significant
developments in 2023 and is poised for further growth
in 2024.
Market Size and Growth
In 2023, the global trade credit insurance market was
valued at approximately USD 10.58 billion. The UK,
being a major hub for international trade, plays a
significant role in this market. The market is expected
to grow at a compound annual growth rate (CAGR)
of 11.2 percent from 2024 to 2030. This growth is driven
by the increasing need for businesses to mitigate
risks associated with trade, especially in the face of
economic uncertainties and geopolitical tensions.
Key Drivers
So what’s behind the predicted growth?
Economic Uncertainty: the ongoing economic
uncertainties, including the aftermath of Brexit and
the global economic slowdown, have heightened
the need for trade credit insurance. Businesses are
increasingly seeking protection against potential
payment defaults.
Technological Advancements: the integration of
advanced technologies such as artificial intelligence
(AI), machine learning (ML), and blockchain in trade
finance is revolutionising the TCI market. These
technologies enhance risk assessment, streamline
processes, and improve the accuracy of underwriting.
Global Trade Expansion: the expansion of global
trade, particularly in emerging markets, is boosting
the demand for trade credit insurance. Companies are
looking to safeguard their international transactions
against the risk of nonpayment.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 55
continues on page 56 >

CREDIT INSURANCE
Market Trends
Digital Transformation: the adoption of digital platforms
and APIs (Application Programming Interfaces) by insurers
is transforming the TCI landscape. For instance, Coface
launched a new API portal in 2023, offering 26 API’s in trade
credit insurance. This digital shift is making it easier for
businesses to access insurance services and data.
Increased Investment in Insurtech: there has been a
significant increase in investments in Insurtech, with
the UK being a prominent player. In 2022, the UK saw
35 insurtech deals, highlighting the growing interest in
leveraging technology to enhance insurance services.
Focus on Sustainability: insurers are increasingly focusing
on sustainability and ESG (Environmental, Social,
and Governance) criteria. This trend is influencing the
underwriting processes and the types of risks covered by
trade credit insurance.
Trade Credit Losses
The UK trade credit insurance market has faced notable
challenges due to increased trade credit losses in 2023 and
2024. Several factors have contributed to these losses:
Economic Downturn: the economic slowdown has led to
a rise in insolvencies and bankruptcies among businesses,
resulting in higher claims for trade credit insurers. The UK
saw a significant increase in company insolvencies in 2023,
which directly impacted the trade credit insurance sector.
Geopolitical Tensions: ongoing geopolitical issues, such as
the Russia-Ukraine conflict, have disrupted supply chains
and trade routes, leading to payment defaults and increased
claims.
Sector-Specific Risks: certain sectors, such as retail
and construction, have been particularly vulnerable to
economic fluctuations, resulting in higher default rates and
subsequent claims on trade credit insurance policies.
Despite these challenges, the market has shown resilience.
Insurers have been adapting their risk assessment models
and leveraging technology to better predict and manage
potential losses. The focus on digital transformation and
advanced analytics is helping insurers to mitigate risk more
effectively.
Future Outlook
The UK trade credit insurance market is expected to
continue its growth trajectory in 2024. The increasing
adoption of digital solutions, coupled with the expansion
of global trade, will drive this growth.
INSURERS
HAVE BEEN
ADAPTING
THEIR RISK
ASSESSMENT
MODELS AND
LEVERAGING
TECHNOLOGY
TO BETTER
PREDICT
AND MANAGE
POTENTIAL
LOSSES.
The UK trade credit insurance market is undergoing
significant transformation. While challenges such as
regulatory changes and geopolitical risks persist, the market
is well-positioned for growth in 2024 and beyond. Businesses
are increasingly recognising the importance of trade credit
insurance in safeguarding their financial health, making it
a vital component of their risk management strategies.
Author: Simon Philpin is Head of Trade Credit at Markel and a
member of the CICM Think Tank.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 56

Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 57

International Trade
Monthly round-up of the latest stories
in global trade by Andrea Kirkby.
BIG FAT INDIAN WEDDINGS
PRESENT BIG OPPORTUNITIES
A story in The Times shows that
ostentatious wealth is neither dead nor
bad for business.
As the paper noted, the business of
big fat weddings (in India) is getting
bigger and fatter, with the industry now
worth $130bn a year – double the size
of the market in the US. Indian couples
spend an average of $15,000 on their
nuptials, and this is expected to increase
in the world’s fastest-growing economy.
And leading the charge for opulence
were the Ambanis, India’s richest family,
who recently hosted a lavish wedding
party costing around £120m, where
celebrations were said to take excess
beyond excess.
Critics may argue that extravagant
spending by the super-rich is obscene
in a country with social inequalities and
widespread poverty, while others say
weddings are intrinsic to culture and
generate income for various sectors. The
jewellery industry gets over 10 percent of
its income from brides.
For British firms with an interest in the
wedding sector, it looks like there’s a big
market to target.
UK trade in peril as trade posts dwindle
THE Guardian recently highlighted a
story that ought to concern UK firms
trading with the US. It appears that
the former Conservative Government
took a decision before the election was
called to cut nearly a seventh of trade
posts within British consulates in the
US. The paper quoted Jules Ehrhardt, a
designer and investor, who said there
was outrage and disbelief in the British
business community at the decision.
Another furious British businessman
said it was as an act of arson. Overall,
24 trade positions were eliminated,
including 18 from 139 posts in the trade
department.
Initially, post-Brexit Britain aimed
to secure a comprehensive free trade
USE OF CE MARKS
INDEFINITELY
FOLLOWING the end of the UK-EU
transition period on 31 December
2020, the UK Government introduced
the UK conformity assessed regime,
and UKCA marking, to regulate
manufactured products to be placed
on the market in Great Britain. The
UKCA mark means that the product
has been assessed to meet safety,
health, and environmental protection
requirements.
The original intention was to
replace the EU’s CE marking regime
with the UKCA marking but, to allow
businesses time to adjust, the
Government introduced a transition
period to enable CE marked
goods that met EU product safety
requirements to continue to be
placed on the market in Great Britain.
That transition period, which had
already been extended, was due to
expire on 31 December 2024.
However, businesses will now be
able to continue to use either UKCA
or CE marks as they see fit, when
the Product Safety and Metrology
etc (Amendment) Regulations 2024
come into force on 1 October 2024.
deal with the US. However, that came
to nought so successive Conservative
Governments turned towards forging
closer ties with individual US states.
The civil servants responsible for
these state-level deals have now been
dismissed.
Ehrhardt highlighted the critical role
consulate directors played in connecting
British and American business leaders,
facilitating introductions, and providing
invaluable advice and expertise.
The British Chambers of Commerce
would rather see scaling up than cutting
back on trade teams, particularly with
the potential for critical mineral and
digital trade deals with the US federal
government on the horizon.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 58

CREDIT MANAGEMENT
New Chancellor
has different take
on China trade
THE new Labour Government seems to
have a different view on trade with China
compared to its predecessor.
In an interview with Bloomberg,
chancellor Rachel Reeves said that ‘we
are a small, open trading economy, and
we benefit from those trade links with
countries around the world, both for
exports and imports, but also for foreign
direct investment’.
She added: ‘Our approach is to trade
and cooperate where possible and to
challenge where necessary. However, we
do not want to close the UK economy to
imports and exports. We benefit from
those trade links globally, including with
China.’
This stance contrasts sharply with the
United States, which has imposed a 100
percent tariff on imported electric vehicles
from China, and the European Union,
which has similarly increased levies on
Chinese goods.
High LOW TREND
GBP.EUR 1.19027 1.17042 Up
GBP.USD 1.3261 1.29299 Up
GBP.CHF 1.12327 1.10312 Down
GBP.AUD 1.96987 1.92881 Up
GBP.CAD 1.79596 1.76977 Up
GBP.JPY 193.314 183.925 Down
UK officials fear port chaos
Economists warn that the rise in
protectionist trade policies could drive
inflation and stifle global economic growth.
The UK has become increasingly
dependent on services sector exports
to manage its growing trade deficit.
According to the Office for National
Statistics, services exports have surged
by around 60 percent in real terms since
2010, while goods exports have increased
by only seven percent they have fallen
by about six percent since the Brexit
referendum in 2016.
For the latest
exchange rates visit
www.currenciesdirect.com
or call 020 7874 9400
Currency Exchange Rates
This data was taken on 17
September and refers to the
month previous to/ leading up to
16 September 2024.
UNLESS there’s a last minute reprieve, from 10
November the European entry/exit system will
require all non-EU travellers to undergo biometric
checks. This new scheme, delayed several times
since its inception in 2017, could significantly impact
Brits travelling.
One of the major challenges is the readiness of an
app developed by the EU and Frontex, designed to
streamline the registration process. The app aims to
allow non-EU citizens to register their details before
travelling, avoiding delays at border crossings.
In essence, travellers will need to undergo
fingerprint checks and facial biometrics on their first
registration, with subsequent visits requiring only
a facial biometric check at automated gates. There
could be chaos at key border points.
While the UK does not oppose the biometric
scheme in principle and acknowledges the need for
its implementation, there is concern that a poorly
executed rollout would benefit no one.
In addition to this change from mid-2025, Non-
EU visitors to the Schengen area will need to apply
online for entry permission.
A LOST DECADE LOOMS
IN CHINA
ACCORDING to the American
Enterprise Institute (AEI), China’s
economy is in deep trouble. The credit
market and property crisis, weak
consumption and high unemployment
all mean that China is at risk of a
Japanese-style ‘lost economic decade’
without major reforms to boost
domestic consumption.
The root cause of its problems is the
unbalanced economic model of the last
30 years, which has been too reliant on
investment (housing), exports and a
steady supply of cheap labour. China is
now impaired by poor demographics,
crippling local Government debt, and
declining trade relations with the US.
The AEI thinks that China needs the
‘forceful implementation’ of reforms
that improve China’s social safety net
in order to raise consumption if it’s to
get out of the mire.
UK-AFRICA TRADE AND
INVESTMENT EVENTS
THE Government has published a guide
on gov.uk about forthcoming trade and
investment events to help exporters
gather information, make contacts and
expand their networks in Africa.
Many of the trade and investment
events allow for virtual attendance as
well as in person attendance.
While the Government says that
it does not endorse events listed,
some to note include AFSIC Investing
in Africa (7-9 October), the FT Africa
Summit (29-30 October), and
the Africa Investment Forum (4-6
December).
See gov.uk and UK-Africa trade and
investment events.
FARNBOROUGH AIRSHOW
DEALS FOR UK AEROSPACE
TRADE association ADS reckons that
the total value of deals signed at the
2024 Farnborough Airshow was in
the region of £81.5bn which it says
illustrates the sector’s confidence,
resilience, and buoyancy.
Of these deals, there were 260 firm
aircraft orders valued at £6.4bn for the
UK and 808 firm engine orders adding
another £1.2bn at current prices.
Saudi Arabia’s low-cost carrier
flynas signed a Memorandum of
Understanding for 75 A320neo family
aircraft and 15 A330-900s making
this 90-aircraft order the largest of the
trade show.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 59

THIS
EVENT IS
SELLING
OUT!
Doing what we do best
In conjunction with the Chartered Institute of Credit Management’s
Premium Partner, Hays, the professional body is on tour across the UK
to deliver thought-provoking insights on the hottest topics from industry
leaders across business sectors, exclusively for CICM Members.
We’re going to be doing what we do best, providing learning and
development opportunities for passionate credit professionals who
strive to be the best at what they do, with a multiple-day event.
Where will we see you?
We’re going to be all over the UK and Ireland, take a look
at the cities where you can join us:
8 October – Birmingham
9 October – London
7 November – Dublin
This won’t be one to miss
We will be on tour across the UK & Ireland to unite the
Credit Management and Debt Collections Community in best practice and
to discuss the topics that are all on our minds such as recruitment trends,
Fraud, AI, Credit Risk and more.

EXCLUSIVE PAYMENT TRENDS
TRADING
PLACES
Latest late payment data shows UK regions and sectors
improving with Ireland going backwards.
BY ROB HOWARD
ROLES are reversed in the latest
late payment statistics. Last
month, late payments were on
the up across both UK regions
and sectors, while across Ireland
there were a number of marked
improvements. This month, it’s
the UK in the ascendancy, with many moving in the right
direction across the board while late payment figures
rise across Ireland. Across UK regions and sectors, the
average Days Beyond Terms (DBT) reduced by 1.5 and
2.8 days respectively. The average DBT figure across
Irish counties and sectors increased by 0.9 and 0.7 days
respectively. Average DBT across the four provinces of
Ireland increased by 3.4 days.
Sector Spotlight
Across UK sectors, the overall picture is bright indeed,
with 17 of the 22 sectors making cuts to late payments.
The Financial and Insurance sector saw the biggest
improvement, reducing its DBT by 12.1 days to take its
overall DBT to 4.4 days and moving into the top five
prompter payers in the UK. The IT and Comms and
Public Administration sectors also made significant
strides forward, reducing their DBT by 11.6 and 11.3
days respectively. Elsewhere, the Business from Home
(-7.5 days) and Agriculture, Forestry and Fishing (-7.1
days) sectors also made gains and further improvement
(-2.4 days) for the International Bodies sector means it
remains the best performing sector with an overall DBT
of zero days. At the opposite end of the standings, of
the four sectors that saw increases to late payments, the
Real Estate sector took the biggest hit. An increase of
11.0 days means it is now the worst performing sector
with an overall DBT of 23.8 days.
In Ireland, more than half (11) of the 20 sectors saw
increases in late payments. The Mining and Quarrying
sector saw the biggest increase, with a rise of 16.0 days
meaning it drops to the bottom of the standings as the
worst performing sector in Ireland. Businesses in the
Agriculture, Forestry and Fishing sector are also now
amongst the poorest payers following an increase of 12.1
days to its DBT. Another sector on the up in the UK
but on the slide in Ireland is the Financial and Insurance
sector, with a rise of 9.6 days taken its overall DBT to 10.7
days. On a more positive, and another example of role
reversal, this time in Ireland’s favour, seven sectors did
make improvements to late payments including the Real
Estate sector, with a cut of 12.1 days taking its overall
DBT to zero days.
Regional Spotlight
As with the sector standings, the UK regional data is
full of positives, with eight of the 11 regions making
improvements to late payments. The top five promptest
payers are huddled together, all improving and separated
by just 0.5 days. East Anglia tops the standings following
a cut of 5.6 days, taking its overall DBT to 10.2 days.
The East Midlands (-3.7 days) and Scotland (-2.1 days)
are close behind, both with an overall DBT of 10.5 days,
followed by the South West (-2.4 days) on 10.6 days
overall and Wales (-3.3 days) on 10.7 days overall. The
West Midlands is now the worst performing region, with
an increase of 4.1 days taking its overall DBT to 17.1 days.
The regional standings over in Ireland are more even,
with 13 of the 26 counties seeing increases to DBT, 11
counties improving and the remaining two seeing no
change to DBT. Focusing on the positives, no county
made a bigger reduction to its DBT than Tipperary, with
a cut of 16.1 days taking its overall DBT to zero days.
The counties of Kilkenny (-12.9 days), Westmeath (-9.4
days) and Limerick (-8.5 days) also made important
moves in the right direction. Looking at the negatives,
some counties saw significant increases in late payments.
County Clare is now at the bottom of the standings
following a steep rise of 32.3 days taking its overall DBT
to 34.1 days. Donegal isn’t too far behind, now with an
overall DBT of 29.0 days following a rise of 16.6 days to
its DBT.
Across the four provinces of Ireland, it’s a 50:50 split.
Ulster remains a drift at the bottom of the standings with
an overall DBT of 22.7 days following a further jump of
12.5 days. Connacht has lost top spot following an increase
of 3.0 days to its DBT, while both Leinster (-1.1 days) and
Munster (-0.7 days) made minor improvements.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 61

*
STATISTICS
Data supplied by the Creditsafe Group
Top Five Prompter Payers
Region (UK) August 24 Changes from July 24
East Anglia 10.2 -5.6
East Midlands 10.5 -3.7
Scotland 10.5 -2.1
South West 10.6 -2.4
Wales 10.7 -3.3
Getting worse
Real Estate 11
Health and Social 4.9
Mining and Quarrying 1.2
Dormant 0.8
Bottom Five Poorest Payers
Region (UK) August 24 Changes from July 24
West Midlands 17.4 4.1
South East 14.6 4.1
Northern Ireland 14.4 3.9
Yorkshire and Humberside 13.6 -1.7
London 12.3 -4.7
Top Five Prompter Payers
Sector (UK) August 24 Changes from July 24
International Bodies 0 -2.4
Business from Home 4.4 -7.5
Financial and Insurance 4.4 -12.1
Agriculture, Forestry and Fishing 4.9 -7.1
Public Administration 6.1 -11.3
Bottom Five Poorest Payers
Sector (UK) August 24 Changes from July 24
Real Estate 23.8 11
Health and Social 18.1 4.9
Dormant 16.1 0.8
Mining and Quarrying 15.6 1.2
Manufacturing 14.8 -1.1
Getting better
Financial and Insurance -12.1
IT and Comms -11.6
Public Administration -11.3
Business from Home -7.5
Agriculture Forestry and Fishing -7.1
Other Service -5.9
Entertainment -5.5
Professional and Scientific -4.2
Business Admin & Support -3.2
Water & Waste -2.8
International Bodies -2.4
Construction -1.9
Transportation and Storage -1.4
Wholesale and retail trade; repair of
motor vehicles and motorcycles -1.4
SCOTLAND
-2.1 DBT
Manufacturing -1.1
Hospitality -0.8
Energy Supply -0.1
NORTHERN
IRELAND
3.9 DBT
SOUTH
WEST
-2.4 DBT
WALES
-3.3 DBT
NORTH
WEST
-5.5 DBT
WEST
MIDLANDS
4.1 DBT
YORKSHIRE &
HUMBERSIDE
-1.7 DBT
EAST
MIDLANDS
-3.7 DBT
LONDON
-4.7 DBT
SOUTH
EAST
4.1 DBT
EAST
ANGLIA
-5.6 DBT
Region
Getting Better – Getting Worse
-5.6
-5.5
-4.7
-3.7
-3.3
-2.4
-2.1
-1.7
4.1
4.1
3.9
East Anglia
North West
London
East Midlands
Wales
South West
Scotland
Yorkshire and Humberside
South East
West Midlands
Northern Ireland
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 62

EXCLUSIVE PAYMENT TRENDS
Getting worse
CONNACHT
3 DBT
DONEGAL
16.6 DBT
SLIGO
-0.1 DBT
MONAGHAN
1.7 DBT
LEINSTER
-1.1 DBT
ULSTER
12.5 DBT
CAVAN
8.2 DBT
Mining and Quarrying 16
Agriculture Forestry and Fishing 12.1
Financial and Insurance 9.7
Education 4.4
MUNSTER
-0.7 DBT
CLARE
32.3 DBT
TIPPERARY
-16.1 DBT
LIMERICK
-8.5 DBT
CARLOW
0 DBT
WATERFORD
12.1 DBT
WESTMEATH
-9.4 DBT
Professional and Scientific 2.7
Transportation and Storage 2.7
Health and Social 2.5
Manufacturing 1.7
Hospitality 1.1
Top Five Prompter Payers – Ireland
Region August 24 Changes from July 24
Limerick 0 -8.5
Tipperary 0 -16.1
Westmeath 0 -9.4
Sligo 0.2 -0.1
Monaghan 2.5 1.7
Bottom Five Poorest Payers – Ireland
Region August 24 Changes from July 24
Clare 34.1 32.3
Donegal 29 16.6
Carlow 28.3 0
Cavan 24.8 8.2
Waterford 16.6 12.1
Top Four Prompter Payers – Irish Provinces
Region August 24 Changes from July 24
Leinster 7.1 -1.1
Connacht 8.8 3
Munster 9.4 -0.7
Ulster 22.7 12.5
Wholesale and retail trade; repair of
motor vehicles and motorcycles 0.9
Business Admin & Support 0.5
Getting better
Real Estate -12.1
Entertainment -7.6
Energy Supply -6.9
Other Service -4.7
Public Administration -4.7
Construction -1.6
IT and Comms -1.4
Top Five Prompter Payers – Ireland
Sector August 24 Changes from July 24
International Bodies 0 -2.4
Business from Home 4.4 -7.5
Financial and Insurance 4.4 -12.1
Agriculture, Forestry and Fishing 4.9 -7.1
Public Administration 6.1 -11.3
Nothing changed
International Bodies 0
Water & Waste 0
Bottom Five Poorest Payers – Ireland
Sector August 24 Changes from July 24
Real Estate 23.8 11
Health and Social 18.1 4.9
Dormant 16.1 0.8
Mining and Quarrying 15.6 1.2
Manufacturing 14.8 -1.1
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 63

Cr£ditWho?
CICM Directory of Services
COLLECTIONS
Controlaccount
Compass House, Waterside, Hanbury Road, Bromsgrove,
Worcestershire B60 4FD
T: 01527 386 610
E: sales@controlaccount.com
W: www.controlaccount.com
Controlaccount has been providing efficient, effective, and
ethical pre-legal debt recovery for over forty years. We help
our clients to improve internal processes and increase cash
flow, whilst protecting customer relationships and established
reputations. We have long-standing partnerships with leading,
global brand names, SMEs and not for profits. We recover
over 40,000 overdue invoices each month, domestically
and internationally, on a no collect, no fee arrangement.
Other services include credit control and dunning services,
international and domestic trace and legal recoveries. All our
clients have full transparency on any accounts placed with us
through our market leading cloud-based management portal,
ClientWeb.
Guildways
T: +44 3333 409000
E: info@guildways.com
W: www.guildways.com
Guildways is a UK & International debt collection specialist with over
25 years experience. Guildways prides itself on operating to the
highest ethical standards and professional service levels. We are
experienced in collecting B2B and B2C debts. Our service includes:
• A complete No collection, No Fee commission based service
• 10% plus VAT commission for UK debts
• Commission from 22% plus VAT for International debts
• 24/7 online access to your cases through our CaseManager portal
• Direct online account-to-account payments, to speed up
collections and minimise costs
If you are unable to locate your customer, we also offer a no trace,
no fee, trace and collect service.
For more information, visit: www.guildways.com
MIL Collections Ltd.
Palace Building, Quay Street, Truro,TR1 2HE
M: 07961578739 E: GaryL@milcollections.co.uk
W: www.milai.co.uk
From our dedicated office in Truro, Cornwall, our team of over
50 staff work tirelessly to ensure our clients expectations are not
just met but exceeded.
We offer clients an experienced, dedicated and regulated
collection service. From small sundry invoices through to
complex property cases and overseas jurisdictions we can
help our clients recover what is due to them in a fair and timely
manner.
Added to the ISO certification, MIL is a pioneer bringing AI
to the collections world with a platform dedicated to ensure
customers are treated fairly and clients work is managed
effectively.
COLLECTIONS LEGAL
Lovetts Solicitors
Lovetts, Bramley House, The Guildway,
Old Portsmouth Road,
Guildford, Surrey, GU3 1LR
T: 01483 347001
E: info@lovetts.co.uk
W: www.lovetts.co.uk
With more than 25yrs experience in UK & international business
debt collection and recovery, Lovetts Solicitors collects £40m+
every year on behalf of our clients. Services include:
• Letters Before Action (LBA) from £1.50 + VAT (successful in
86% of cases)
• Advice and dispute resolution
• Legal proceedings and enforcement
• 24/7 access to your cases via our in-house software solution,
CaseManager
Don’t just take our word for it, here’s some recent customer
feedback: “All our service expectations have been exceeded.
The online system is particularly useful and extremely easy to
use. Lovetts has a recognisable brand that generates successful
results.”
CREDIT DATA AND ANALYTICS
CoCredo
Missenden Abbey, Great Missenden, Bucks, HP16 0BD
T: 01494 790600
E: customerservices@cocredo.com
W: www.cocredo.co.uk
For over 20 years, CoCredo has been a leading Credit Report
Agency in the UK, providing online company credit checks and
business credit score information to businesses and suppliers
in the UK and globally. Our services include competitively priced
data aggregation from top UK, Ireland, and overseas providers.
Our business credit report service provides financial data and
credit scores from companies in 240 countries/territories.
Additionally, we offer CRM integration, Dual Reports, Business
Credit Monitoring, and other essential business credit report
checking services. We have consistently been finalists or winners
in numerous Small Business and Credit Awards. Our clients love
how we actively engage in their customer journey, delivering an
impressive 99.4% customer retention rate. We consistently offer
value for money, excellent customer service, and ongoing product
innovation.
DataTrace UK
Compass House, Waterside, Hanbury Road, Bromsgrove,
Worcestershire B60 4FD
T: 01527 386 626
E: info@datatraceuk.com
W: www.datatraceuk.com
DataTrace is recognised as one of the leading trace agencies in
the UK. Our client portfolio includes leading debt collection and
enforcement firms, utilities companies, housing associations,
law practices and universities. Providers of volume electronic
trace services, enhanced desktop tracing, employment and
international tracing, propensity to pay reporting, address and
telephone appending, and pre-litigation reports. We can build
a bespoke workflow to meet your data needs. All our data is
validated and priced competitively.
CREDIT DATA AND ANALYTICS
TOP SERVICE
MINIMISE DEBT
Top Service Ltd
Top Service Ltd, 2&3 Regents Court, Far Moor Lane
Redditch, Worcestershire. B98 0SD
T: 01527 503990
E: membership@top-service.co.uk
W: www.top-service.co.uk
MAXIMISE C ASH
The only credit information and debt recovery service provider
specifically for the UK construction industry. Our payment
experiences are the most up to date credit information available
and enable construction businesses to confidently assess credit
risk & make the best, most informed credit decisions. Coupled
with our range of effective debt recovery solutions, quite simply
our members stay one step ahead & experience less debt &
more cash.
CREDIT MANAGEMENT SOFTWARE
Credica Ltd
Building 168, Maxell Avenue, Harwell Oxford, Oxon. OX11 0QT
T: 01235 856400E: info@credica.co.uk W: www.credica.co.uk
Our highly configurable and extremely cost effective Collections
and Query Management System has been designed with 3
goals in mind:
•To improve your cashflow • To reduce your cost to collect
• To provide meaningful analysis of your business
Evolving over 15 years and driven by the input of 1000s of
Credit Professionals across the UK and Europe, our system is
successfully providing significant and measurable benefits for
our diverse portfolio of clients.
We would love to hear from you if you feel you would benefit
from our ‘no nonsense’ and human approach to computer
software.
Corcentric
Information: Ali Hassan| 020 317 71713
ahassan@corcentric.com | corcentric.com
Social media links: https://www.linkedin.com/company/
corcentric/, https://x.com/corcentric?lang=en-GB
Membership can go to: Lee Allen lallen@corcentric.com
Jonathan BlackBurn jblackburn@corcentric.com
Ali Hassan ahassan@corcentric.com
About Corcentric: Corcentric is a leading global provider
of best-in-class procurement and finance solutions. We
offer a unique combination of technology and payment
solutions complemented by robust advisory and managed
services. Corcentric reduces stress and increases savings
for procurement and finance business leaders by forming a
strategic partnership to diagnose pain points and deliver tailormade
solutions for their unique challenges. For more than two
decades, we've been a trusted partner who delivers proven
results. To learn more, please visit www.corcentric.com.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 64

FOR ADVERTISING INFORMATION OPTIONS
AND PRICING CONTACT
paul.heitzman@cplone.co.uk – 01727 739 196
CREDIT MANAGEMENT SOFTWARE
CREDIT MANAGEMENT SOFTWARE
DEBT & ASSET RECOVERY SERVICE
ESKER
Sam Townsend Head of Marketing
Northern Europe Esker Ltd.
T: +44 (0)1332 548176 M: +44 (0)791 2772 302
W: www.esker.co.uk LinkedIn: Esker – Northern Europe
Twitter: @EskerNEurope blog.esker.co.uk
Esker’s Accounts Receivable (AR) solution removes the
all-too-common obstacles preventing today’s businesses
from collecting receivables in a timely manner. From credit
management to cash allocation, Esker automates each step of
the order-to-cash cycle. Esker’s automated AR system helps
companies modernise without replacing their core billing and
collections processes. By simply automating what should
be automated, customers get the post-sale experience they
deserve and your team gets the tools they need.
Genius Software Solutions
T: +44 (0) 141 280 0275
E: sales@geniusssl.com
W: www.geniusssl.com
Genius provides solutions designed to enhance your customer
engagement with compliance in full focus; our team have decades
of operational experience in the Debt & BPO space.
As a global outreach partner our technology drives compliance
and operational efficiency to help your business thrive.
• Streamline Collections, Payments & Asset Recovery, whether this
be in-house or within a BPO setting with our Adept platform.
• Enhance customer engagement with our cloud-based
omnichannel platform, Commpli.
We've helped businesses worldwide enhance efficiency, optimise
workflows, and respond to the dynamic needs of a changing
marketplace.
Cr£ditWho?
CICM Directory of Services
For advertising
information
options and
pricing contact
– 01727 739 196
My DSO Manager
22, Chemin du Vieux Chêne,
Bâtiment D, Meylan, FRANCE
T: +33 (0)458003676
E: contact@mydsomanager.com
W: www.mydsomanager.com
My DSO Manager is an all-in-one intelligent SaaS accounts
receivable and credit management system that provides
real-time insight and scalability from SMEs to international multientity
companies. It helps AR analysts, accounting or finance
managers, and any client-facing employee, manage risk and
maximize cash collection.
It can swiftly integrate any kind of data from any ERP and
implement any customization due to its creative, competent IT
teams that are headquartered inside the firm and collaborate
closely with support employees, many of whom were formerly
credit managers at big corporations.
The feature-rich functions, automated reminders, alerts, and
numerous services connected to the solution, such as EDM/
CRMs/insurance/e-payment/BI platforms etc., along with
a reasonable pricing system, have simplified the credit-tocash
cycle by monitoring daily KPIs like DSO, aging balance,
overdues/past-dues, customer behavior, and cash forecast.
My DSO Manager's worldwide clientele are its real
ambassadors, who assist the company in expanding on an
ongoing basis.
TCN
T: +44 (0) 800-088-5089
E : spencer.taylor@tcn.com
W: www.tcn.com
TCN is a leading provider of cloud-based call centre technology
for enterprises, contact centres, BPOs, and collection
agencies worldwide. Founded in 1999, TCN combines a deep
understanding of the needs of call centre users with a highly
affordable delivery model, ensuring immediate access to robust
call centre technology, such as SMS, email, predictive dialler,
IVR, call recording, and business analytics required to optimise
operations while adhering to callers’ requests.
Its “always-on” cloud-based delivery model provides customers
with immediate access to the latest version of the TCN solution,
as well as the ability to quickly and easily scale and adjust to
evolving business needs. TCN serves various Fortune 500
companies and enterprises in multiple industries, including
newspaper, collection, education, healthcare, automotive,
political, customer service, and marketing. For more information,
visit www.tcn.com or follow on Twitter @tcn.
Invevo
Daniel Gregory
T: 07843591646 E : daniel@invevo.com
W: www.invevo.com
Invevo is a fully integrated, cloud-based provider of credit
management and accounts receivable automation solutions,
offering dynamic features to optimise operational efficiency and
improve cash performance.
Our flexible platform empowers organisations to:
- Automate the manual and repetitive work allowing your team to
focus on the value-added activities
- Discover financial and operational insights through beautiful,
data-rich dashboards
- Test and adjust workflow strategies immediately through zerocost
configuration
- Mitigate customer global risk through integrated credit reporting
via credit agencies or open banking
Invevo integrates with your existing systems (ERP, CRM,
accounting, billing) to present the insights you need to make
strategic decisions through one system that acts as a single
source of truth. Access the undiscovered analytics and improve
performance across your portfolio through data-driven actions.
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 65
Shakespeare Martineau
E: jayne.gardner@shma.co.uk,
W: www.shma.co.uk
T 01789 416440
Shakespeare Martineau provides expert debt and asset
recovery services across various sectors, including energy,
manufacturing and government. Our team supports regulated
and unregulated debt, acting as an extension of internal
collections when needed. We prioritise keeping client costs low
while empathetically engaging with debtors. Our 70+ experts
offer cradle-to-grave B2B and B2C collections, transparent
fee plans, bespoke service, flexible case management, and
additional support like training, advice, litigation and mediation.
ENFORCEMENT
Court Enforcement Services
Samuel Evans – Director of Business Development
T: 07759 122503
E : s.evans@courtenforcementservices.co.uk
W: www.courtenforcementservices.co.uk
Court Enforcement Services is the market leading and fastest
growing High Court Enforcement company. Since forming in
2014, we have managed over 100,000 High Court Writs and
recovered more than £187 million for our clients, all debt fairly
collected. We help lawyers and creditors across all sectors to
recover unpaid CCJ’s sooner rather than later. We achieve 39%
early engagement resulting in market-leading recovery rates.
Our multi-award-winning technology provides real-time reporting
24/7. We work in close partnership to expertly resolve matters
with a fast, fair and personable approach. We work hard to
achieve the best results and protect your reputation.
High Court Enforcement Group Limited
Client Services, Helix, 1st Floor, Edmund St, Liverpool, L3 9NY
T: 08450 999 666
E: clientservices@hcegroup.co.uk
W: hcegroup.co.uk
Why choose us?
With over £400 million recovered for our clients, our track
record is second to none. We have enforced over 320,000 writs
of control and are committed to providing you with a unique
and personalised service. Our enforcement agents cover all of
England and Wales, are trained to the highest standards and
each holds strong local knowledge of the areas they cover.
Our clients rate our service extremely highly, with a 99%
satisfaction score in our most recent annual survey.
You can rely on us, the largest independent High Court
enforcement company in the UK, with the highest number of
HCEOs and a wealth of experience across all our teams.
ENGAGEMENT
CFH Docmail
T: 01761 416311
E: info@cfh.com
W: www.cfh.com
With over 45 years of experience in supporting organisations in
the successful delivery of multi-channel communications, CFH
are the innovative and trusted partner for driving engagement
and achieving measurable results.
Combining proven expertise, the right accreditations and
industry driven communication solutions including Docmail the
leading hybrid mail solution, CFH have the perfect blend of
solutions to help you engage offline, online or the perfect blend
of the two.
continues on page 66 >

Cr£ditWho?
CICM Directory of Services
FOR ADVERTISING INFORMATION
OPTIONS AND PRICING CONTACT
paul.heitzman@cplone.co.uk
FINANCIAL PR
INSOLVENCY
PAYMENT SOLUTIONS
Gravity Global
Floor 6/7, Gravity Global, 69 Wilson St, London, EC2A 2BB
T: +44(0)207 330 8888. E: sfeast@gravityglobal.com
W: www.gravityglobal.com
Gravity is an award winning full service PR and advertising
business that is regularly benchmarked as being one of the
best in its field. It has a particular expertise in the credit sector,
building long-term relationships with some of the industry’s
best-known brands working on often challenging briefs. As
the partner agency for the Credit Services Association (CSA)
for the past 22 years, and the Chartered Institute of Credit
Management since 2006, it understands the key issues
affecting the credit industry and what works and what doesn’t in
supporting its clients in the media and beyond.
INSOLVENCY
Red Flag Alert Technology Group Limited
49 Peter Street, Manchester, M2 3NG
T: 0330 460 9877
E: sales@redflagalert.com
W: www.redflagalert.com
The UK’s No1 Insolvency Score is available as platform
designed to help businesses manage risk and achieve growth
using real-time data. The only independently owned UK credit
referencing agency for businesses. We have modernised the
way companies consume data, via Graph QL API and apps for
many CRM / ERP systems to power businesses decisions with
the most important data taken in real-time feeds, ensuring our
customers are always the first to know.
Red Flag Alert has a powerful portfolio management tool
enabling you to monitor all your customers and suppliers so
you and your teams can receive email alerts on data events
i.e. CCJ, Petitions, Accounts, Directors, amongst 84 alerts
produced and tailored to your business.
Red Flag Alert works towards growing and protecting
businesses using advanced machine learning and AI
technology data to provide businesses with information
to deliver best in class sales, credit risk management and
compliance.
Menzies
T: +44 (0)2073 875 868 - London
T: +44 (0)2920 495 444 - Cardiff
W: menzies.co.uk/creditor-services
Our Creditor Services team can advise on the best way for you
to protect your position when one of your debtors enters, or
is approaching, insolvency proceedings. Our services include
assisting with retention of title claims, providing representation
at creditor meetings, forensic investigations, raising finance,
financial restructuring and removing the administrative burden
– this includes completing and lodging claim forms, monitoring
dividend prospects and analysing all Insolvency Reports and
correspondence.
For more information on how the Menzies Creditor Services
team can assist, please contact Bethan Evans, Licensed
Insolvency Practitioner, at bevans@menzies.co.uk or call
+44 (0)2920 447 512.
PAYMENT SOLUTIONS
American Express
76 Buckingham Palace Road,
London. SW1W 9TQ
T: +44 (0)1273 696933
W: www.americanexpress.com
American Express is working in partnership with the CICM
and is a globally recognised provider of payment solutions
to businesses. Specialising in providing flexible collection
capabilities to drive a number of company objectives including:
• Accelerate cashflow • Improved DSO • Reduce risk
• Offer extended terms to customers
• Provide an additional line of bank independent credit to
drive
growth • Create competitive advantage with your customers
As experts in the field of payments and with a global reach,
American Express is working with credit managers to drive
growth within businesses of all sectors. By creating an additional
lever to help support supplier/client relationships American
Express is proud to be an innovator in the business payments
space.
Quadient AR by YayPay
T: +44 20 8502 8476
E: r.harash@quadient.com
W: www.quadient.com/en-gb/ar-automation
Quadient AR by YayPay makes it easy for B2B finance teams
to stay ahead of accounts receivable and get paid faster – from
anywhere. Integrating with your existing ERP, CRM, accounting
and billing systems, YayPay organizes and presents real-time data
through meaningful, cloud-based dashboards. These increase
visibility across your AR portfolio and provide your team with a
single source of truth, so they can access the information they
need to work productively, no matter where they are based.
Automated capabilities improve team efficiency by 3X and
accelerate the collections process by making communications
customizable and consistent. This enables you to collect cash
up to 34 percent faster and removes the need to add additional
resources as your business grows.
Predictive analytics provide insight into future payer behavior to
improve cash flow management and a secure, online payment
portal enables customers to access their accounts and pay at any
time, from anywhere.
RECRUITMENT
Hays Credit Management
107 Cheapside, London, EC2V 6DN
T: 07834 260029
E: karen.young@hays.com
W: www.hays.co.uk/creditcontrol
Hays Credit Management is working in partnership with the
CICM and specialise in placing experts into credit control jobs
and credit management jobs. Hays understands the demands
of this challenging environment and the skills required to thrive
within it. Whatever your needs, we have temporary, permanent
and contract based opportunities to find your ideal role. Our
candidate registration process is unrivalled, including faceto-face
screening interviews and a credit control skills test
developed exclusively for Hays by the CICM. We offer CICM
members a priority service and can provide advice across a wide
spectrum of job search and recruitment issues.
Key IVR
T: +44 (0) 1302 513 000 E: sales@keyivr.com
W: www.keyivr.com
Key IVR are proud to have joined the Chartered Institute of
Credit Management’s Corporate partnership scheme. The
CICM is a recognised and trusted professional entity within
credit management and a perfect partner for Key IVR. We are
delighted to be providing our services to the CICM to assist
with their membership collection activities. Key IVR provides
a suite of products to assist companies across the globe with
credit management. Our service is based around giving the
end-user the means to make a payment when and how they
choose. Using automated collection methods, such as a secure
telephone payment line (IVR), web and SMS allows companies
to free up valuable staff time away from typical debt collection.
Cr£ditWho?
CICM Directory of Services
PORTFOLIO
CREDIT CONTROL
Portfolio Credit Control
1 Finsbury Square, London. EC2A 1AE
T: 0207 650 3199
E: recruitment@portfoliocreditcontrol.com
W: www.portfoliocreditcontrol.com
Portfolio Credit Control, a 5* Trustpilot rated agency, solely
specialises in the recruitment of Permanent, Temporary &
Contract Credit Control, Accounts Receivable and Collections
staff including remote workers. Part of The Portfolio Group,
an award-winning Recruiter, we speak to Credit Controllers
every day and understand their skills meaning we are perfectly
placed to provide your business with talented Credit Control
professionals. Offering a highly tailored approach to recruitment,
we use a hybrid of face-to-face and remote briefings, interviews
and feedback options. We provide both candidates & clients
with a commitment to deliver that will exceed your expectations
every single time.
For advertising information options and pricing contact
– 01727 739 196 paul.heitzman@cplone.co.uk
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 66

View our digital version online at www.cicm.com
Log on to the Members’ area, and click on the tab
labelled ‘Credit Management magazine’
Just another great reason to be a member
Credit Management is distributed to the entire UK and international
CICM membership, as well as additional subscribers
Brave | Curious | Resilient
www.cicm.com | +44 (0)1780 722900 | editorial@cicm.com
Brave | Curious | Resilient / www.cicm.com / October 2024 / PAGE 67