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CM April 2025

THE CICM MAGAZINE FOR CONSUMER AND COMMERCIAL CREDIT PROFESSIONALS

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CREDIT MANAGEMENT

CM

APRIL ISSUE 2025

THE CICM MAGAZINE FOR CONSUMER AND

COMMERCIAL CREDIT PROFESSIONALS

Platform

Delays

Why do big banks

struggle with tech?

Guidance on the new

Failure to Prevent Fraud

offence. Page 16

Are we about to face a

new tsunami of debt?

Page 38



SEAN FEAST FCICM

MANAGING EDITOR

Editor’s column

IS THERE

SOMETHING YOU’RE

NOT TELLING ME?

IN our January/February magazine we

published a challenging and thoughtprovoking

piece about Short Firm Fraud

and asked whether Credit Reference

Agencies (CRAs) were doing enough

to address the issue. The author,

James Campbell, highlighted four

cases which in total had cost suppliers in excess of

£200,000.

In every case, he showed how there had been an

over-reliance on CRA recommendations and

concluded that CRAs are no nearer to being

able to spot a bogus account today than they

were five or so years ago, despite significant

advances in technology. He also suggested that

CRAs could do much more to warn their

subscribers of the potential shortcomings in their

recommendations, or in the dangers of relying on

their recommendations alone.

James supported his arguments with various

examples to prove his point and posed a series of

questions to the industry. In summary, he challenged

CRAs to demonstrate that they could spot bogus

accounts by way of a test, with the results published

in this magazine.

Having thrown out the challenge, I expected some

sort of response, even if only a gentle word in my

ear to back off or provide an off the record briefing.

But so far there has been radio silence. James contacted

the Business Information Providers Association

(BIPA) which includes Experian, Equifax, Creditsafe,

Dun & Bradstreet, Company Watch and Vistra for

an industry response, but also – so far – nothing.

The outgoing BIPA Chair, Patrick Walsh, has

forwarded James’ request to each of the members

for their ‘review and consideration’ so let’s see

what happens. I have every faith, not least because

BIPA’s purpose is to ‘facilitate communication

between the commercial CRAs, government and the

business community (editor’s italics) to create greater

awareness of the data held, how that data is used, and

how it benefits business decisions and responsible

lending’.

So here is an opportunity for it to ‘communicate’

the benefits of the data it holds and the reports its

members provide. Let us all hope that we don’t find

ourselves a month down the line with ‘but answer

came there none’ (with apologies to Lewis Carroll,

the Walrus and the carpenter!)

Pretty much every credit manager I know sees CRAs

as a critical part of the credit decisioning process, a

point that James goes on to stress. Pretty much every

item of news I have ever seen or articles I have read

from a CRA talks about the importance of their data

in promoting business growth, and I believe them.

So given that everyone is on the same side, let us hope

that we get engagement from BIPA and its members.

If we don’t, some might take it as the equivalent of a

‘no comment’. And when anyone says ‘no comment’,

it just means there might be things they don’t want

you to know.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 3


contents

APRIL 2025 issue

13 – PLATFORM DELAYS

How can the Finance industry up its game to

build a future in the technological world?

16 – TAKEN IN EVIDENCE

Guidance on the new Failure to Prevent

Fraud offence.

20 – GREEN FLASH

AI is causing havoc in relation to the

monitoring of greenwashing in advertising.

24 – CLOCKED OFF

Are we in danger of losing our way at work?

26 – ARTIFICIAL REALITY

Building and Integrating AI Models in the

Financial Services Sector.

32 – COUNTRY FOCUS

Turkey is at a crossroads in more ways

that none.

38 – FLOOD WARNING

Is there a debt tsunami coming?

42 – EDUCATION OR EXPERIENCE?

Here are the three factors that really matter.

44 – AGE OF PROHIBITION

Selling union lists and the practicalities of

re-engaging wayward staff.

59 – CONSTRUCTIVE PROGRESS

Better outcomes for Government and

regulators.

12

INSOLVENCY

Why should directors

be concerned?

16

TAKEN IN

EVIDENCE

Guidance on the new

Failure to Prevent

Fraud offence.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 4

Tu

32

COUNTRY FOCUS


CICM GOVERNANCE

13

PLATFORM

DELAYS

20

GREEN FLASH

President: 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

Jonathan Swan FCICM / Mark Taylor MCICM

Atul Vadher FCICM(Grad) / Dee Weston 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

rkey

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 5

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

Paul Heitzman

Telephone: 01727 739 196

Email: paul@centuryone.uk

Printers

Stephens & George Print Group

2025 subscriptions

UK: £138 per annum

International: £171 per annum

Single copies: £15.00

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.


THE NEWS

CMNEWS

A round-up of news stories from the

world of consumer and commercial credit.

WRITTEN BY: SEAN FEAST FCICM

Small businesses show

big appetite for personal

guarantee backed finance

SMALL businesses appear

to be increasing their

financial resilience in the

face of increasing costs,

according to new research.

A survey by Purbeck

Insurance Services suggests

that in the final quarter of 2024, there was a

25% increase in small businesses applying for

personal guarantee (PG) backed business

loans compared to the same quarter of 2023.

Indeed, for the whole of 2024 there was a

45% increase in small businesses taking on

PG backed finance. The insurer believes

this is proof of how personal guarantees

have become a standard requirement in

small business lending.

Underlining the increased level of

entrepreneurship in the UK, 50% more

start-ups (firms that have been established

for under two years) applied for funding

in Q4 2024 and the average loan to these

young businesses jumped from £100,399 in

Q4 2023 to £121,668 in Q4 2024 – this is a

21.28 % year-on-year increase.

In contrast, the average loan taken by a

firm over two years old rose marginally by

6% from £238,645 in Q4 2023 to £254,203

in Q4 2024. Across the board, the average

loan value was £174,627 in Q4 2024 up from

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 6


CREDIT MANAGEMENT

“The fact that

small businesses

are increasingly

using insurance

to mitigate some

of the risks

associated

with personal

guarantee

backed loans

shows they are

taking positive

steps to improve

their financial

resilience”

£159,664 in Q4 2023. Principal reasons for

requiring a loan were to provide working

capital (33% of applications) and for

investment in growth initiatives or business

acquisitions (22%).

Todd Davison, Managing Director of

Purbeck Personal Guarantee Insurance

believes there is a good deal of realism

and pragmatism amongst small businesses

in the face of increasing business costs

following the Budget in October 2024:

“Small firms know they need to adjust

to increased cost pressures and personal

guarantee backed finance can help them

through – whether that's via their bank, an

alternative businesses lender or through

initiatives such as the Growth Guarantee

Scheme.

“The fact that small businesses are

increasingly using insurance to mitigate

some of the risks associated with personal

guarantee backed loans shows they are

taking positive steps to improve their

financial resilience,” he adds.

“It remains vital, however, that firms

familiarise themselves with the risks of

personal guarantees, particularly those

that form part of the Growth Guarantee

Scheme. This scheme does not protect a

business owner from a personal guarantee,

it protects the lender. There should be no

misunderstandings over the guarantor’s

liability should be the business ultimately

fail.”

Outlook for SMEs hit

hard since Labour win

TAXES remain the biggest obstacle to

SME growth, and more SMEs are now

struggling to source finance since Labour

came to power than under the previous

Government.

New data from iwoca’s Q4 SME Expert

Index suggests that almost three-quarters

(70%) of commercial finance brokers

believe that conditions for SMEs have

worsened since the Labour Government

took office, and small business owners are

increasingly anxious about the future.

As such, lower taxes are finance brokers’

top choice to drive SME growth in 2025

(38%) — twice as many as the next most

popular measure of business rates reform

(19%).

Increased business running costs for

SMEs remain the biggest concern for

more than half of finance brokers (53%),

up 11-points on the previous quarter.

Concerns over inflation also remain

high — with two-thirds (67%) of finance

brokers believing inflation will be above

Charity calls for action

on issue of ‘coerced debt’

A small but possibly growing number

of UK adults have experienced coerced

debt, a form of economic abuse where the

perpetrator coerces a victim into debt,

making them take out credit against their

wishes.

New research by StepChange Debt

Charity reveals around 3% of UK adults,

equivalent to 1.6 million people, have

suffered in this way and that around one

in eight (12%) of its debt advice clients are

impacted by it.

StepChange says that patchy and

inconsistent support, legislative barriers,

and inflexibilities in credit reporting

prevent victim-survivors from rebuilding

their lives and regaining economic

stability. The charity is calling for the

Government to establish a taskforce

to ensure victim-survivors can achieve

economic justice through economic

safety and stability without having to pay

the price for an abuser’s behaviour.

Currently, victim-survivors face years

repaying coerced debt, extending the

impact of abuse and tying victims to

a perpetrator. Often victim-survivors

struggle to make ends meet due to

debt repayments, experience financial

exclusion due to negative impacts on

their credit report and, in some cases, are

the Bank of England’s 2% target by the end

of the year, with 32% predicting it will top

2.6%.

However, despite continued concerns

about barriers to growth, economic

optimism bounced back in the last quarter

of 2024, with almost half of SME finance

brokers (46%) reporting feeling optimistic

about SMEs’ future in 2025, compared to

36% in the previous quarter. Following a

sharp decline after the Budget, this signals

a glimmer of hope for the year ahead, as

pessimism has gone down.

Worries persist about a recession, as

more than half (51%) are concerned about

the possibility – a slight increase on last

quarter.

Colin Goldstein, Chief Commercial

Officer, UK at iwoca, says SMEs are

facing rising costs and tougher borrowing

conditions: “With high street banks

pulling back, businesses are turning to

alternative lenders to access the funding

they need.”

barred from working in certain jobs.

National YouGov polling commissioned

by StepChange for the report reveals low

public awareness of coerced debt and

economic abuse: almost seven in ten

(68%) people have never heard of the term

‘coerced debt’ and for those who have

fallen victim, the majority (58%) had not

sought advice or support.

Vikki Brownridge, CEO at StepChange

Debt Charity, believes that those who

have experienced coerced debt should not

pay the price for their abuser’s behaviour:

“Restoring a victim-survivor’s finances

can be a long and complex process,

particularly in the case of joint debts

and joint mortgages. The challenge of

dealing with debts that have been coerced

is compounded by the emotional and

mental health impacts of abuse.

“Our research highlights the urgent

need for Government leadership and a

collaborative approach from regulators,

financial services and advice agencies in

supporting victim-survivors to regain

financial control and ensure they do not

spend years paying back coerced debts. A

more consistent approach to debt-write

off and credit file restoration are two

key recommendations that would help to

achieve this.”

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 7

continues on page 8 >


THE NEWS

Young Britons struggling

with debt and budgeting

YOUNG adults in

the UK are facing

significant financial

struggles, with

many battling debt

and seeking help

with budgeting.

Research carried out by Opinium for

Christians Against Poverty (CAP) found

that 35% of young adults are struggling with

deficit budgets – spending more than they

earn – a far higher number than the 9% of

over-55s in the same situation. Some 13% of

18-24s say they have had to borrow just to

afford food compared to 8% of 35-54 yearolds,

3% of 55+ and 2% of 65+.

These financial pressures and the easy

availability of credit cards and Buy Now

Pay Later schemes have led many young

people into debt. Three in ten (30%) 18-34

year-olds report struggling to repay debt,

compared to 23% of those aged 35-54 and

just 7% of over-55s.

With borrowing increasingly normalised,

younger generations are more reliant on

credit for education, housing, and day-today

expenses than previous generations.

The rise of high-interest credit products

and the growing number of households

borrowing more and saving less are

ringing alarm bells about the long-term

financial vulnerability of many young

people. Over half (52%) of young adults -

equating to more than 7.8 million people –

say they need support with budgeting. CAP

is warning that without better financial

education and support, young Britons risk

becoming trapped in a cycle of debt.

Juliette Flach, Policy & Public Affairs

Manager, CAP, warns that young people

face a higher risk of being pulled into

financial difficulty and spiralling debt:

“Not only are they in lower-paid jobs at

the start of their careers, but they have

not yet had time to build up financial

savings and are less likely to receive family

inheritances. Poverty and debt have an

immediate impact, but they can also have

a long-term impact as poverty can persist

over someone’s lifetime.”

While measures to help safeguard

pensioners, such as the ‘triple lock’ have

gone some distance in reducing poverty for

people who are pension age, there isn’t an

equivalent for young people.

CAP is calling on the Government to

establish a protected minimum amount

of social security, known as an Essentials

Guarantee so that the basic rate of social

security always covers life’s essentials and

ensures support is never pulled below that

level. In addition, CAP wants employers to

ensure wages are sufficient to prevent any

worker from facing a deficit budget.

CSA appoints Desmond Hudson as new Chair

THE Credit Service Association (CSA), the

UK trade body for the debt collection and

purchase industry, has appointed Desmond

Hudson to succeed Tom Chandos as new

independent chair.

Desmond Hudson’s career spans several

high-profile positions, including Chief

Executive of the Law Society of England

& Wales and the Institute of Chartered

Accountants of Scotland. In both roles

he advanced regulatory frameworks and

enhanced professional standards.

Chris Leslie, CSA CEO, says that

Desmond’s appointment comes at an

important time for the Association:

“With the Government and regulators

now realising that economic growth must

be at the heart of new policies, we have

an opportunity to emphasise how credit

availability – for which a well-functioning

collections process is integral – must be

front and centre of their thinking. The CSA

represents our sector but also supports

member firms with services, networking

and new policy thinking. Des will be a great

asset in this endeavour.”

Desmond’s appointment was confirmed

at the CSA’s Annual General Meeting

which also saw something of a changing

of the guard of the CSA Board: Kathryn

Morgan, Managing Director of Lowell,

succeeded Nick Cherry of Phillips and

Cohen Associates (PCA) as Deputy Chair

and six other Board members were elected/

re-elected.

The six comprised: Frank Horvath,

Managing Director at Link Financial

Outsourcing; Claire Moore, Chief Risk

Officer at Azzurro Associates; Susan

Bain from Zinc Group; Sam Barnard,

Commercial Director at Lantern Group;

Stuart Webb, UK Site Director at PCA;

and the Chief Operating Officer at Cabot

Financial, Jaime Nuwar–Graham.

Commenting on the appointments, Chris

added: “Our CSA Board is drawn from

across the collections and debt purchase

sector, elected democratically at our AGM

from among our member firms, and they

will ensure the voice of the sector is heard

clearly and our work truly represents

the real-world issues in collections and

recoveries.

Chris also thanked the outgoing

executives for their contributions: “Tom

Chandos brought with him a wealth

of experience, impartiality, and proven

business acumen. His support for the

Association and the wider board over his

long tenure will be sorely missed.”

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 8


Gold Award winners

CICM Corporate Partner Top Service has

been awarded the Gold Award under the

new Fair Payment Code, introduced by the

Small Business Commissioner in January.

The award is said to recognise the company’s

commitment to ethical and fair payment

practices in the UK construction industry.

The Fair Payment Code replaces the

previous Prompt Payment Code, aiming to

tackle the widespread issue of late payments

that continue to challenge suppliers and

subcontractors. While the initiative is a

positive step forward, Top Service believes

that further measures, including statutory

backing, could significantly strengthen its

impact and bring about real, lasting change

for businesses operating in the construction

sector.

Emma Reilly FCICM, CEO of Top

Service says the true effectiveness of the

Code will depend on widespread adoption

and integration into risk assessments by

businesses and government departments

when evaluating tenders: “Making fair

payment a legal obligation could truly

transform the industry and protect the

smaller suppliers and subcontractors who

are often most affected by late payments,”

she says.

Sue Chapple FCICM, CEO of the CICM

is delighted to see one of the Institute’s

Corporate Partners in the vanguard

of best practice: “We are absolutely in

support of the FPC and the Small Business

Commissioner in her endeavours to further

improve payment practice,” she says, “and

agree that lasting change will require a firm

commitment from all.

“Enforcement will be the key to its

success, as will the ongoing support of the

Government and business organisations

who must continue to match words with

actions and not allow their support to waver

at the first sign of difficulty.”

The FPC is designed to reward businesses

for their payment performance with an

award of Gold, Silver or Bronze. The Gold

Award is for those firms paying at least

95 percent of all invoices within 30 days;

the Silver Award for those paying at least

95 percent of all invoices within 60 days,

including at least 95 percent of invoices

to small businesses within 30 days; and

the Bronze Award will be given to those

paying at least 95 percent of all invoices

within 60 days.

THE NEWS

Boost for women

WOMEN who start their own businesses

report a significant boost in confidence,

resilience, and self-belief despite many

feeling the stress of ‘entrepreneurial load',

according to new research from Small

Business Britain and Starling Bank. The

research, gathered from 1,000 female

entrepreneurs for International Women’s

Day last month, found four in five (80%)

feel more confident in their abilities

after launching their business, with 87%

feeling happier. However, respondents

acknowledged the demands on their time,

with 60% struggling to switch off from work

and 39% reporting stress and exhaustion.

Everyday rebrand

EVERYDAY Loans has rebranded as Evlo

and appointed consumer credit expert

Deborah Green as Chief Operating Officer

to help drive the company’s next stage of

growth. Evlo says the rebrand embodies

the company’s focus on financial inclusion,

transparency, simplicity and customercentricity.

The company also says it signals

a renewed emphasis on helping customers

improve their credit scores and gain access to

mainstream financial products, as opposed

to just offering short-term lending solutions.

Credit Information and

Debt Recovery Services for

the Construction Industry!

Up to the minute trading experiences & payment data

specifically for the construction industry

Company & Director monitoring

Debt Recovery solutions to suit you, your business

and customer relationships

A team of credit experts that really understand credit

management in the construction industry

Contact us to discuss how we can support you and

your business to minimise debt and maximise cash

Supporting the

construction

industry for over

30 years

01527 503990 membership@top-service.co.uk www.top-service.co.uk

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 9

continues on next page >


CICMQ NEWS

Royal Mail receives fourth Accreditation

ROYAL Mail’s Receivables Team has once

again demonstrated its commitment to excellence,

securing CICMQ Accreditation

for the fourth time since its initial recognition

in 2015. This achievement highlights

the team's industry-leading credit management

practices and operational expertise.

Maintaining this prestigious accreditation

reflects Royal Mail’s ability to uphold

best-in-class credit operations that enhance

financial stability and efficiency.

The latest assessment reaffirmed by Luke

Sculthorp FCICM, Head of Strategic Relationships,

who served as the Assessor for

this accreditation, ensuring rigorous evaluation

and validation of best practices. Areas

particularly noted include the team’s strong

credit policy and governance, effective risk

management, and collaboration across

sales, finance, and leadership, its proactive

approach to dispute resolution alongside

a commitment to continuous professional

development.

The accreditation is a testament to

the team’s essential role within Royal

Mail. Glenys Hayward, Head of Finance

Shared Services, praised the team’s impact:

“The Accounts Receivable team is absolutely

essential to our business. The

team is recognised across the stakeholder

ommunity as a critical function with a fundamental

impact on cashflow and working

capital. Stakeholders commended the

team’s transparency, professionalism, and

problem-solving capabilities, reinforcing

its reputation as a critical function within

the organisation. Colin Robinson and Sam

Nuttal MCICM, were also instrumental in

this success, contributing their expertise

and dedication to strengthening credit

operations and driving efficiency. Their efforts,

alongside the wider team, have been

pivotal in securing this accreditation.”

While this reaccreditation is a significant

achievement, the team remains committed

to continuous improvement. Future

priorities include process improvement,

enhancing collaboration with the

Sales team, increasing direct customer

engagement, and leveraging the benefits

of key system transformations currently

underway. With a forward-thinking

approach, Royal Mail’s Receivables Team

continues to set the benchmark for credit

management excellence.

The Credit Industry Credit Management

Quality team have also been busy assessing

other teams, and re-accreditations have

been achieved by Impellam Group, Tarmac

Trading, Wesco Anixter MEA in recent

weeks. Presentations are being arranged to

celebrate their success.

Vulnerable under pressure

as consumer optimism falls

ONE in five (20%) UK adults – the

equivalent of 11 million people – now

consider themselves financially vulnerable

and consumer optimism is dropping

rapidly, especially among middle income

families.

According to the Financial Conduct

Authority, financially vulnerable consumers

are susceptible to harm, due to

their personal circumstances, including

poor health, life changes like new caring

responsibilities, or difficulty handling financial

or emotional stress.

Data from TransUnion shows the impact

of money worries on mental wellbeing,

with nearly seven in 10 (68%) financially

vulnerable people feeling stressed when

dealing with their finances.

The cost of living remains high; more

than a quarter (26%) of UK adults are

relying on credit cards to meet shortfalls

in their monthly finances, while 16% dip

into their overdrafts. Meanwhile, 15% of

UK adults borrow money from friends

and family in order to be able to afford

their monthly expenses, whilst over one

in 10 (12%) turn to Buy Now, Pay Later

(BNPL) services. Overall, one in 10 (10%)

adults report that they wouldn’t be able

to maintain their current lifestyle without

credit or financing options. Indeed, this

reality was reflected in TransUnion’s Q4

2024 Consumer Pulse data that suggests

consumer optimism has dropped by a

significant 9% among middle income

families (those earning between £30,000

and £79,999), falling from 57% who

were optimistic about their household

finances over the next 12 months to 48%.

Lower income families (those earning

under £30,000 annually) remain the least

optimistic, with only 37% stating they are

optimistic about their household finances

over the next 12 months, highlighting

the continued strain on more financially

vulnerable households.

However, many more struggle to

consistently access credit, with 9%

indicating having been turned down

within the last 12 months. 35-44-year-olds

(18%) were the most likely age demographic

to have a credit application rejected. The

most common reason people said they

were turned down for when looking to

borrow money, is a low credit score (33%)

– a demonstration of the importance of

understanding and regularly monitoring

your credit report.

OBITUARIES

Mike Wykes FCICM

CREDIT Management is sad to report

the death of Mike Wykes FCICM, past

Chairman of the London Branch of the

CICM. Mike, who started his career in

credit as a despatch rider for Coopers

and Lybrand, rose to become an Associate

Director of Smith & Williamson prior to

launching his own consultancy. An obituary

to Mike will follow in a future issue. In the

meantime, the team would like to express

their condolences to Mike’s family.

Colin Hingston FCICM

CREDIT Management has also learned of the

sudden passing of Colin Hingston from a

suspected heart attack. Colin was a longtime

member and supporter of the Institute

and former European Credit Manager at

Instron, the international manufacturing

business. The team would like to express

their condolences to Mike’s daughter and

family. An obituary will similarly follow

in a future issue.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 10



INSOLVENCY

TRADING ON

WHILST INSOLVENT

Why should directors be concerned?

BY GIUSEPPE PARLA

DIRECTORS have a fiduciary duty to

promote the success of the business

for the benefit of its shareholders.

However, when a company begins

to head towards insolvency, the

directors’ primary duty should shift

to protecting the creditors’ position

from worsening further.

Where a director ought to have known that the company

was insolvent and should have therefore ceased trading at

an earlier point, a director can be personally liable for the

resultant loss to the company and its creditors.

As an example, if an insolvent company had an amount

owed to its creditors in the region of £2m but then trades

on for a further three months where the losses increase

further to £2.5m, then the directors can be personally liable

for £500,000. The reason for this, is that they should have

been taking steps to wind down the business and cease

trading at a much earlier time to avoid those increased

losses.

A liquidator or an administrator can bring a wrongful

trading claim against an offending director.

Whilst all directors are expected to have a certain level

of competence, and ignorance is no defence, those with

a higher level of qualification will be held to a higher

standard. So, a qualified accountant acting as a director

of a company, will be expected to have known about

the insolvency at an earlier stage and therefore, the

repercussions for them could be more severe.

Directors need to tread carefully when they begin to have

cashflow problems and they should make sure that if the

position is expected to worsen in the short term, then it

should really only continue trading in anticipation that

in the long term, the company will return to a solvent

position.

It would be wise for Directors to seek independent advice

from an Insolvency Practitioner at an early stage and

consider having Directors & Officers insurance in place.

What changed in 2022?

The Supreme Court’s judgement in BTI 2014 LLC v

Sequana caused a major shift in the way that the insolvency

profession considers potential action in respect of

wrongful trading claims.

Before 2022, it was always felt there was a clearcut moment

in time when insolvency commenced, and creditors’

interests prevailed. However, in Sequana the Court found

that there was no one point in time at which a real risk

of insolvency could be placed, but that instead there

was a sliding scale during which the risk of insolvency

becomes more acute. As a result, the obligations of the

directors ‘shifts’ as the likelihood of insolvency goes from

being ‘remote’ to one that is ‘inevitable’, ‘irreversible’, or

‘unavoidable’.

As a result of this interesting judgement, Insolvency

Practitioners look a little more closely into the events

leading up to an insolvency and whether the directors

ought to have taken appropriate steps to make sure that

the position did not deteriorate further.

What are the implications

When you start to have difficulties in recovering a debt,

find out why and make a log of the communications.

Consider also whether you want to continue providing

credit to the company. If you are a supplier, consider

insisting on cash on delivery for future supplies.

Events leading up to an insolvency are key and your

communication log could prove pivotal if desiring to bring

a claim against an individual or demonstrate at what point

a director should have known the company was heading

towards insolvency.

Author: Giuseppe Parla is a Business

Recovery Directorand Licensed Insolvency

Practitioner at Menzies LLP.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 12


TECHNOLOGY

PLATFORM

DELAYS

How can the Finance industry up its game to build

a future in the technological world?

BY : STEVE KIELY

TECHNOLOGY – love it or loathe

it, the website, app, and chatbot

are, today, simply indispensable

parts of the Finance industry, just

as they are for society as a whole.

Entire generations have grown

up living in the online age, and, with Artificial

Intelligence on everyone’s agenda, there seems to be

no sign of things slowing down.

The problem, of course, is that you need to get it right

– in the ‘good old days’ maybe a customer might not

even notice if, for example, their local bank branch was

closed for the weekend. Now, if your app is offline for

a matter of minutes, your customer is up in arms, and

your organisation is facing a significant reputational

risk and potential financial penalty.

Unplanned outages

There have been all too many failures in recent times.

The reality was driven home, last month, when the

Treasury Select Committee revealed that nine of the

top banks and building societies operating in the

UK accumulated at least 803 hours – the equivalent

of more than 33 days – of unplanned technology and

systems outages in just the last two years.

At least 158 banking IT failure incidents affected

millions of customers’ ability to access and use services

between January 2023 and February 2025.

This does not even include the most recent outages

affecting Barclays customers between 31 January and 2

February and various banks on 28 February, disruption

which left many people distressed on payday and

prompted angry complaints from MPs. The Committee

warns that it will be requesting further information

from the organisations involved in those instances.

‘Severe degradation’

Despite not including the information in their

aggregated figures, Barclays confirmed that 56% of

online payments during the incident failed due to

‘severe degradation’ of its mainframe processing

performance. It expects to pay between £5m and £7.5m

in compensation to customers for ‘inconvenience or

distress’.

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TECHNOLOGY

In fact, the Committee estimates that Barclays might need

to pay out up to £12.5m – well ahead of the second highest

amount paid by a lender in the last two years: £350,000 by

the Bank of Ireland.

Common reasons given for the IT failures include problems

with third-party suppliers, disruption caused by a change

in systems, and internal software malfunctions.

Chair of the Treasury Select Committee, Dame Meg

Hillier MP, does not mince her words: “For families

and individuals living paycheque to paycheque, losing

access to banking services on payday can be a terrifying

experience. Even when rectified relatively quickly, it can

cause real panic, which is why we wanted to get a proper

understanding of why unplanned banking outages happen

and how banks and building societies respond. And we

know some can go on for several days.

“The reality is that this data shows even the most successful

banks and building societies hit technical glitches. What’s

critical is they react swiftly and ensure customers are kept

informed throughout.”

Flawed execution

Barclays are far from the only lender to face significant

difficulties. This time last year, Nuno Matos, then Chief

Executive of HSBC Global Wealth and Personal Banking,

said that the bank would ‘attack’ the worldwide retail

payments market with the launch of Zing.

Matos said at the time: “It’s a bold move for us. This is

HSBC playing outside of its traditional perimeter of

customers, and really attacking, if you want, of taking

advantage of a contingent, which is big, is growing, looks

like us, and it’s here for us.” Exactly 12 months later,

HSBC admitted defeat in what had become an expensive

failure to challenge the established fintech payments

giants.

Joanne Kumire, lead banking and payments analyst at

GlobalData, said: “The app’s concept may have been sound,

but its execution was flawed from the start. Existing

customers were forced to undergo re-KYC, an unnecessary

hurdle. The product itself was incomplete, failing to offer

meaningful differentiation from Wise or Revolut.

“Worst of all, HSBC spent over three years developing

Zing before engaging with real users, sinking more than

$150m before generating any revenue. In contrast, Wise

and Revolut had already captured the market by rapidly

iterating their platforms, expanding globally, and building

deep customer loyalty.”

Need for speed

Kumire hits on a key consideration when she finds that

the underlying problem was not HSBC’s lack of talent

or resources, rather it was the cultural and structural

challenges that plague many large banks. Innovation at

scale requires speed, adaptability, and a willingness to

experiment, traits that ‘traditional’ financial institutions

often struggle to embody.

SORRY, PAGE NOT FOUND

“FOR FAMILIES

AND INDIVIDUALS

LIVING PAYCHEQUE

TO PAYCHEQUE,

LOSING ACCESS TO

BANKING SERVICES

ON PAYDAY CAN

BE A TERRIFYING

EXPERIENCE.’’

She adds: “There are valuable lessons to be learned from

Zing’s failure that banks must internalise to succeed in

today’s hyper-competitive financial landscape. Banks need

to prioritise moving quickly and gathering user feedback

early in the process to guide development.

“Additionally, excessive spending should be avoided until

there is clear evidence of product-market fit, and in many

cases, partnering with experienced providers may be far

more effective than attempting to build everything inhouse.”

Unravelling growth

One difficulty, of course, is that lenders are being required

to make such major investments in new products and

technology just at a time when their own financial base is

starting to look a little shaky.

The UK’s Financial sector has contracted significantly

since 2020, with nearly 10,000 firms disappearing in just

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 14


CREDIT MANAGEMENT

four years, according to The Payments Group. The decline

signals a deeper structural shift within the industry,

extending beyond the economic fallout of Brexit and the

pandemic.

Its analysis, based on UK Office for National Statistics data

spanning 2010 to 2024, paints a stark picture: after years of

growth, the sector has entered a period of consolidation,

technological disruption, and business failures. Banking,

financial management, and auxiliary financial services are

among the hardest-hit segments.

“The simple truth is that UK finance is shrinking,” says

Chief Executive, Jens Bader. “We are seeing a shift in

the industry’s foundations – one that could have lasting

consequences for the broader economy.”

He suggests that a mix of factors is reshaping the landscape:

• The rise of non-UK financial technology firms, including

American giants such as Apple and Google, which are

tightening their grip on the UK payments ecosystem.

•Regulatory and compliance burdens, particularly in

areas like anti-money laundering and financial-crime

prevention, which have increased operational costs for

smaller firms.

• Market shifts away from traditional financial services,

with mortgage finance emerging as one of the few growth

areas, reflecting the impact of rising interest rates and

sustained housing demand.

Identity and security

But the fact remains: success in the Finance industry

will increasingly rely on getting technology right, and

this technology can help give better, and more reliable,

customer service.

Advisers Cognizant believe that lenders are well placed

for a significant shift in identity management and security

approaches. Biometric authentication will evolve beyond

fingerprints and facial recognition to include behavioural

biometrics – and become the industry standard.

Blockchain-based decentralised identity solutions will

give customers greater control over personal data and

AI-powered fraud detection will revolutionise security.

Danske Bank’s much-heralded use of Machine Learning

to reduce false positives in fraud detection by 50% is, it

believes, just the beginning.

Rise of the super-app

And lenders do not have to do it all alone. Rather than

providing isolated services, many analysts believe that

the trend will shift toward comprehensive financial

ecosystems. ‘Super apps’, like China’s WeChat, which

integrates banking, shopping, and messaging, could inspire

similar platforms in the West.

André Burger, Senior Partner at Synpulse, insists that

banks can partner with fintech companies to develop these

versatile platforms. This would enable customers to use one

centralised app for all financial, and often non-financial,

needs – from account management to investments and

loan services.

In this ‘platform banking’, banks would act as an interface,

integrating various third-party providers to deliver a range

of services, allowing customers to manage finances and

access services such as insurance, real estate, bookings, or

even healthcare within one application.

Imperatives for success

So, despite all the concerns and challenges of the present,

there are still real opportunities for organisations and

professionals who are bold enough to pick up the gauntlet.

And, interestingly, many of the keys for success are the

very same that the industry has relied on for so many

major projects in the past.

Looking at ways to adapt to these challenges, Akhil Babbar,

a knowledge expert at management consultant McKinsey

& Company, points to some very familiar factors:

• Reduce complexity and avoid surprises by budgeting the

necessary time and resources up front.

• Estimate your technical debt – how far you need to travel

- and ensure that the initial budget includes the cost to

remove it; otherwise, the debt will lead to delays and cost

increases.

• Over-invest in cultural shift, even if it might not be

directly related to technology.

• Attract the right talent and do not try to outsource the

transformation.

• Break down organisational silos and design an

organisation-wide transformation road-map - not just by

business area.

Above all: measure the change, with agile practices

and processes in place, such as quarterly business

reviews, to allow for effective prioritisation and value

tracking. Traditional oversight should be replaced by

cross-functional collaboration, cross-silo performance

management, and a new concept of joint accountability

across the entire business. Along the way, successful

projects can be highlighted to inspire the team and build

momentum.

Conclusion

A large-scale digital transformation is not easy, and it is

not surprising that most banks struggle to achieve their

business objectives on time and within budget.

But take heart: the fundamentals for a successful project

are as true today as they have always been. Industry

professionals can take steps to avoid the most common

mistakes by defining clear goals and metrics that reflect

not only the business change, but also the cultural and

technical changes required.

By doing so, you can increase their chances for success and

reap the full rewards of your digital transformations.

Author: Stephen Kiely is a freelance buisiness writer.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 15


FRAUD

TAKEN IN

EVIDENCE

Guidance on the new Failure to Prevent Fraud offence.

BY SEBASTIAN SAYER AND

GLORIA PALAZZI

IN November last year, the Home Office

published its long-anticipated guidance

for corporates in relation to the new

Failure to Prevent Fraud (FTPF) offence

under the Economic Crime and Corporate

Transparency Act 2023 (ECCTA).

The FTPF offence creates criminal liability for certain

companies which fail to prevent fraud. If found guilty,

companies face unlimited fines.

The guidance, which runs to 44 pages, sets out examples

of good practice which may enable corporates to

demonstrate that they had in place ‘reasonable fraud

prevention procedures’ which provide a complete

defence against prosecution for the FTPF offence;

this will absolve them of criminal liability.

The guidance clarifies that the FTPF offence will

come into force on 1 September 2025. However,

there will be a transitional period designed to give

organisations adequate time to understand and

assimilate the guidance into their policies, procedures,

and practices.

The offence

Section 199 of ECCTA states that a criminal offence

is committed where a ‘person associated’ with a

‘relevant body’ commits an ‘offence’ intended to

benefit, whether directly or indirectly the relevant

body; or any person to whom, or to whose subsidiary

undertaking, the associate provides services on behalf

of the relevant body.

So, what does this mean?

Relevant body

Whilst the FTPF offence applies across all sectors

of the economy, it can only be committed by

‘large organisations’. This includes companies, and

partnerships, meeting at least two of the following

criteria – they have more than 250 employees, have a

turnover greater than £36m, or have more than £18m

in total assets.

These criteria apply to the whole organisation,

including subsidiaries, regardless of where the

organisation is headquartered or where its subsidiaries

are located.

Persons associated

Broadly speaking, this includes employees, agents, or

subsidiary undertakings of a company, or any person

who otherwise performs services for or on behalf of

a relevant body. Whether an individual is actually

performing services for an organisation may be a

question of fact.

Companies in an organisation’s supply chain, and

franchisees are not associated persons unless they are

providing services for or on behalf of the relevant

body.

Qualifying offences

The Act covers a wide range of fraudulent activities by

persons associated with an organisation. These include

offences such as fraud by false representation (under

the Fraud Act 2006), false accounting (under the Theft

Act 1968), fraudulent trading (under the Companies

Act 2006), and cheating the public revenue (under the

common law). Money laundering offences under the UK

Proceeds of Crime Act 2002 are not qualifying offences.

The Act requires that the associated person

committing the fraud had the ‘intention of benefiting’

the organisation or its clients. This intention does not

have to be the sole or dominant motivation for the

fraud – their primary motivation may be to benefit

themselves. It is irrelevant whether the organisation

does in fact actually receive any benefit.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 16


CREDIT MANAGEMENT

Territoriality

The offence applies to relevant offences committed under

UK law. Generally, this means that the fraud requires a

direct UK connection, but non-UK companies can fall

within scope.

For example, a non-UK-based company could fall within the

scope of the FTPF offence if an employee of the organisation,

who is based in the UK, commits a relevant qualifying

offence in the UK, or an employee of the organisation, who

is not based in the UK, commits fraud targeting UK victims.

Strict liability

The FTPF offence is a ‘strict liability’ offence. This means

that if a relevant qualifying fraud offence is committed, by

a relevant ‘person associated’, with a ‘relevant body’ (that

it’s a large organisation), then the corporate body has on

the face of it committed the offence. Senior managers in an

organisation do not have to be aware of what the fraudster

has done for the corporate to be guilty of FTPF offence.

WHAT AMOUNTS

TO ‘REASONABLE’

WILL BE JUDGED

BASED ON THE

CONTEXT OF

EACH CASE.

Under ECCTA, an organisation will not be guilty of an

offence if it can prove, on the balance of probabilities, that it

had reasonable procedures in place to prevent fraud, or that

it was unreasonable to expect it to have such procedures. The

onus will be on the organisation to discharge this burden.

What amounts to ‘reasonable’ will be judged based on

the context of each case, considering factors such as the

organisation’s size, nature, and complexity of its activities.

Making preparations

The guidance, which courts will use as a benchmark, sets

out that fraud prevention structures within an organisation

should be guided by six Principles. At a high level, these are:

Top-level commitment. This means ensuring that senior

management is actively involved in fraud prevention efforts.

It includes fostering a culture where fraud is not tolerated,

endorsing anti-fraud policies, allocating resources, adopting

speak-up policies, and leading by example.

Risk assessment. This means evaluating the nature and extent

of an organisation’s exposure to fraud risks, focusing on

employees, agents, and other associated persons. It includes

identifying specific roles and scenarios that present higher

risks and ensuring that the risk assessment is documented

and reviewed regularly.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 17

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FRAUD

Proportionate risk-based fraud prevention procedures.

This means developing and implementing fraud

prevention measures (that respond to the risk

assessment) that are relevant to the identified risks. This

may amount to an ‘anti-fraud policy’, which sets out the

policies and procedures of the organisation to mitigate

the risk of fraud. These procedures should cover various

operational areas, such as procurement, financial

reporting and contractual relationships.

Due diligence procedures. This means conducting

thorough, risk-based, due diligence on all associated

persons. This should include the use of appropriate

technology, such as third-party risk management tools,

reviewing contracts, and monitoring the well-being of

staff to identify those who may be more likely to commit

fraud because of stress, targets or workload.

Communication (and training). This means developing a

training programme to educate employees and other

associated persons on fraud risks, and prevention

measures (such as whistleblowing procedures). It

includes ensuring ongoing communication about the

organisation’s stance on fraud and the consequences of

fraudulent behaviour.

Monitor and review. This means establishing a system

for regular monitoring and review of fraud prevention

measures. It includes detecting attempted fraud,

investigating suspected fraud, and evaluating the

effectiveness of prevention procedures.

Detailed records of all risk assessments, prevention

measures, training programmes, and decisions related to

fraud prevention should be kept. This documentation will

assist in demonstrating compliance and reasonableness

in the event of a challenge of the effectiveness of the

measures put in place to prevent fraud.

The guidance makes clear that whilst existing policies

and procedures may be relevant such as an organisation’s

Bribery Act 2010 policies, or policies it has because it

is regulated by the Financial Conduct Authority, it

will not be a suitable defence to state that because the

organisation is regulated its compliance processes under

existing regulations would automatically qualify as

‘reasonable procedures’ under ECCTA.

Smaller companies

Whilst only ‘large’ organisations are within scope of the

FTPF offence, the guidance notes that the Principles

represent good practice and may therefore also be

helpful for smaller organisation.

It is of course also possible that a currently ‘non-large’

organisation will in future years grow (in number of

employees, turnover, or assets) and therefore qualify

as ‘large.’ Therefore, it is worth all organisations taking

note of changes.

Conclusion

The FTPF offence marks a major shift in corporate

accountability, emphasising the need for robust

fraud prevention measures in large organisations.

Organisations should ensure they thoroughly understand

and implement the principles outlined in the guidance.

To adequately prepare, organisations may wish to seek

legal advice to navigate areas of uncertainty.

As the offence is both new and far-reaching, organisations

should remain vigilant in maintaining and updating

their fraud prevention procedures, documentation, and

training programs.

Sebastian Sayer is a partner, and Gloria Palazzi is

a trainee solicitor, in the financial services team of

Fox Williams.

Background to the offence

As the Law Commission has previously detailed, the

general rule for attributing liability to companies in

English and Welsh criminal law is the ‘identification

principle’. This states that where a particular mental

state is required, only the acts of a senior person

representing the company’s “controlling mind and

will” can be attributed to the company. In practice,

this is limited to a small number of directors and

senior managers.

In recent years, concern has been expressed that

the identification principle does not adequately

deal with misconduct carried out by and on behalf

of companies (and other ‘non-natural persons’). In

particular, some have suggested that it has proved

disproportionately difficult to prosecute large

companies such as banks for economic crimes

committed in their names, by senior managers,

for the company’s benefit. In practice, it can be

much easier to hold a small company to account

for wrongdoing than a large business where

responsibility for decision-making is more diffuse.

In November 2020, the then Government asked the

Law Commission to examine the issue and publish a

paper providing an assessment of different options

for reform. Following a discussion paper, round

table events and a consultation the Law Commission

published a paper in June 2022 examining options

to improve the law to ensure that corporations are

effectively held to account for committing serious

crimes. The paper considered the creation of a new

offence of failure to prevent fraud. This offence was

subsequently created by the Economic Crime and

Corporate Transparency Act 2023.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 18


CREDIT MANAGEMENT

Example of fraud by abuse of position

The payroll department of company A is supposed

to ensure that the company contributes to the

employees’ pension funds every month. However, the

head of the payroll department arranges for some

of these payments to be diverted for other projects

within the company but continues to record them as

payments to the pension fund.

The base fraud is fraud by abuse of position (since

the head of the payroll department is entrusted

with making payments for the employees), and

the associated person is the head of the payroll

department. The intention is to benefit other projects

within the company. Company A could be liable for

the offence under section 199(1)(a) unless a court

decides that it had reasonable procedures in place to

prevent the fraud.

Example of aiding and abetting fraud

Company A is seeking bank lending to purchase new

equipment. Employee C of Company A encourages

one of Company A’s clients (Company B) to make

a statement about its intention to place a series of

orders with Company A if Company A obtains the

equipment. Employee C drafts a letter from Company

B to the bank and gives it to Company B to sign.

In fact, Company B is winding up its operations and

will not be making any such orders. Company B has

committed fraud by false representation (it has made

a statement it knows to be false in order to make a

gain for Company A and has exposed the bank to the

risk of loss). Employee C has encouraged and assisted

Company B to commit the offence. As Employee C

has committed the offence with intent to benefit

Company A, Company A could be liable for the

offence unless a court decides that it had reasonable

procedures in place to prevent the fraud.

ORGANISATIONS

SHOULD REMAIN

VIGILANT IN

MAINTAINING AND

UPDATING THEIR

FRAUD PREVENTION

PROCEDURES.

Example of intended benefits not realised

An investment fund provider promotes investment

in a ‘sustainable’ timber company, knowing that, in

fact, this company’s environmental credentials are

fabricated, and that the timber is harvested from

protected forest. Investors are deceived into placing

funds with the investment fund provider. The base

fraud is fraud by false representation. The intent is to

benefit the fund provider.

The associated person is the relevant member of staff

at the investment fund provider who knowingly

used the false information in the investment fund’s

brochures for clients. The investment fund provider

could be liable under section 199(1)(a) unless a court

determines that it had reasonable procedures in place

to prevent this fraud. The offence applies even if

investment is not actually secured – it is enough that

the fraud was intended to benefit the investment fund

provider.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 19


STANDARDS

“REDUCING THE CHOICE

THAT BUSINESSES HAVE BETWEEN

EITHER GREENWASHING OR

GREENHUSHING IS FAR TOO

SIMPLISTIC’’

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CREDIT MANAGEMENT

GREEN FLASH

AI is causing havoc in relation to the ASA’s ability

to monitor advertising for ‘greenwashing’.

BY JONATHAN RUSH

THE trouble with standards, regulations,

and law is that they need enforcement

and that, in the modern

world, can be difficult.

For a while now the Advertising

Standard Agency (ASA) has been

using AI-assisted collective advert monitoring. And it

appears to be working.

Over the period of 2022-23, the body saw a 30-fold increase

in the number of adverts it has been able to analyse. This,

along with the ASA's new strategy to proactively pursue

so-called ‘greenwashing’ claims, means that businesses

across many sectors are now falling foul of the regulator.

As a result, it’s important that organisations and

businesses understand the heightened risks they face

from increased scrutiny of green claims they make and

also, what they can to do to minimise their exposure. So

what can we expect from the ASA in the Environmental.

Social and Governance (ESG) space?

A new strategy

In April, the ASA published its 2023 Annual Report,

setting out its five-year strategy which relies on AIassisted

collective advert regulation to shift the ASA from

complaints-led investigations to proactive monitoring

and enforcement. This is a significant change, establishing

the ASA as a more visible and dynamic regulator in the

ESG arena.

The Annual Report makes clear that environmental

claims remain a top priority for the regulator.

James Best, Chair of the Committee of Advertising

Practice (CAP), says in the report that perhaps the most

important work in the long term has been concerned with

environmental claims, including work clarifying what

‘green claims’ mean and determining how climate change

and mitigating technologies should be communicated in

adverts.

This is evidenced by the ASA’s increased activity

regarding ESG. In 2023, it introduced new guidelines on

environmental claims in advertising, and in recent years

it has actively investigated and made findings in relation

to a significant number of misleading environmental – so

called ‘greenwashing’ – claims that are considered further

below.

The ASA and AI

In 2023, the ASA introduced its active AI monitoring

tool. The tool uses AI to proactively monitor online

advertising and identify adverts which are most likely to

be problematic for further review. By the end of 2023, the

tool was processing over 500,000 adverts a month and the

ASA says that it contributed to the majority of adverts

which were amended/withdrawn following ASA action

that year.

The tool is being used to pursue the ASA's focus on

environmental claims. The development of the system is

ongoing, so the system's impact will likely continue to

grow, both to enhance the ASA's activities in relation to

environmental claims and to allow it to conduct reviews

in other areas.

This is a significant shift for the ASA, which has previously

tended to focus more on responding to complaints from

consumers and in some cases, competitors. AI is clearly

helping the ASA to adopt a more proactive and strategic

approach, identifying potentially problematic adverts

which have not necessarily been the subject of complaints.

The ASA is not the only regulator rapidly developing its

AI capabilities. For example, the FCA and the Bank of

England are already using AI. The FCA is using tools to

detect, review and triage potential scam websites, and inhouse

synthetic data to assess firms' sanctions screening

systems. The Bank is using AI ‘to support and enhance

[its] capabilities’ including in predictive analytics, and

data analysis. And the PRA is using a cognitive search

tool to identify patterns in unstructured and complex

firm management information.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 21

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STANDARDS

The FCA and ASA often work closely together in targeting

misleading claims. The FCA recently published finalised

guidance on the anti-greenwashing rule which came into

effect on 31 May 2024 and applies to all FCA-authorised

firms. The rule requires that references made to the

sustainability characteristics of a product or service, are

(i) consistent with the sustainability characteristics of the

product or services and (ii) clear, fair and not misleading.

The ASA and ESG

In 2021 the ASA launched its Climate Change and the

Environment project to respond to the climate crisis and

to ensure that environmental claims made in advertising

were not misleading or irresponsible. Since then, the

ASA and CAP have issued substantive guidelines for

businesses on environmental advertising and the ASA has

significantly increased its activity in this area.

Consider its action in relation to major airlines as a

number of adverts were banned. They included a Virgin

Atlantic advert which stated: ‘Virgin Atlantic’s Flight

100 will … become the world’s first commercial airline to

fly transatlantic on 100% sustainable aviation fuel’. They

also included an Air France-KLM advert which included

the claim ‘…Air France is committed to protecting the

environment: travel better and sustainably’.

In overview, the ASA found that each advert gave a

misleading impression of the advertiser's environmental

impact, and that the advertisers either could not provide

any evidence to back up the claim, or had omitted material

information regarding the claim which would have been

required for the consumers to make an informed decision,

or for them to properly understand the claims being made.

Accordingly, the advertisers were required to retract the

adverts (or, in the case of Virgin Atlantic, ensure that

future adverts contained qualifying information which

explained the environmental impact to customers).

Further claims

While the airlines have been targeted the ASA has also

made similar findings relating to environmental claims

across a variety of other sectors such as fossil fuels,

financial services, and household goods.

And there are several examples including:

Fossil fuels: A paid-for online display advert for Repsol, a

global energy company, featured several images of leaves

with text that stated: ‘At Repsol, we are developing biofuels

and synthetic fuels to achieve net zero emissions’. The ASA

concluded that the advert omitted material information

and was misleading, failing to explain that it was part of a

wider plan to achieve net zero by 2050.

E-cigarettes: Adverts for the vaping company Elf Bar after

it used the slogan ‘recycling for a greener future’. The ASA

felt that this was misleading because of the environmental

damage of discarded vapes.

Food: Ads for plant-based milk brand Oatly, for making

claims, such as ‘Oatly generates 73% less CO2e vs. milk,

calculated from grower to grocer’. The ASA said the

advert was misleading because Oatly based the claim on

comparing one of its products, Oatly Barista Edition,

but consumers would understand the claim to include all

Oatly's products, which was inaccurate.

Cars: BMW ads claiming that its electric vehicles were

‘zero-emission’. The ASA disagreed, noting that the models

produced carbon emissions during their manufacture, as

well as when recharging using electricity generated from

fossil fuels.

Risks to businesses

As with any adverse finding, a ruling from the ASA can not

only have financial consequences for a business in terms of

wasted costs when an advert is required to be amended or

withdrawn but also cause reputational damage.

Falling foul of the ASA also puts businesses at risk of

coming within the crosshairs of the Competition and

Markets Authority (CMA).

Businesses should be aware that, from this month (April

2025), the CMA will have significant new powers to

investigate and enforce consumer protection laws pursuant

to the Digital Markets, Competition & Consumers

Act 2024 (DMCCA). Before the CMA had to initiate

lengthy court proceedings to just establish a breach, but

the DMCCA will allow the CMA to directly impose

fines of up to 10% of global annual turnover if it finds

consumer law has been infringed, including in respect

of deliberately misleading consumers about products or

services. Individuals associated with the breach could also

be sanctioned.

This marks an important shift from a primarily selfregulatory/judicial

system of enforcement to a full

administrative regime similar to the UK's existing

approach to competition law enforcement. Whereas

the CMA’s current limited consumer powers arguably

encourage it to accept voluntary settlements to resolve

concerns, it will now have the arsenal to more aggressively

pursue and sanction potential infringements.

Comparing like for like

Where the ASA might be characterised as adopting a ‘high

volume’ approach, scrutinising a large number of adverts

across a wide range of sectors, the CMA tends to be more

selective. Typically, it will focus on a smaller number of

high impact investigations, often with a view to setting

precedents which it hopes will influence the wider market.

That said, when deciding which cases to pursue, the CMA

will often look at areas where the ASA has already found a

significant level of non-compliance – hence the danger that

an adverse ASA ruling may ultimately draw the attention

of the CMA (or other regulators such as the FCA).

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 22


CREDIT MANAGEMENT

including possible mass consumer claims. Indeed, we have

already seen significant group litigation being brought

against vehicle manufacturers over the diesel emissions

scandal. Businesses must therefore give careful thought to

how to mitigate these risks.

Faced with these risks, some businesses may be tempted

to steer clear of any sort of green claim – an approach

which has been described as ‘greenhushing’. However, this

risks chilling the genuine and legitimate aspirations of

most businesses to pursue their sustainability ambitions.

Many have a good story to tell – and as the ASA itself has

noted, “reducing the choice that businesses have between

either greenwashing or greenhushing is far too simplistic.

Impactful and informative green claims benefit consumers

because they enable them to make more responsible

choices.’’

Checking claims

Stepping back, what regulators are asking business to do is

arguably no different in principle from what they expect

with regard to any type of marketing claim, namely that

it should be supported by adequate evidence; and not be

expressed in a way that gives a misleading impression,

particularly when it comes to the business' overall impact

on the environment.

A further contrast with the ASA is that while the latter

focusses on bringing infringing behaviours to an end,

the CMA's new consumer powers will allow it to impose

penalties for past conduct – thus substantially increasing

the risks to business from making green claims which are

later found to be misleading. Indeed, the CMA's latest

action in relation to the fast fashion sector – where it has

issued guidance on what it regards as misleading – seems

to be laying the groundwork for enforcement action under

its new powers if the relevant brands fail to respond.

Finally, it's also worth noting that the CMA has identified

sustainability as an important objective not only for its

consumer protection function but also in relation to its

remit in the areas of competition law, merger control and

market investigations, where it has enjoyed significant

enforcement powers for some time.

And in addition to regulatory risks in the UK, the EU

is pursuing a number of measures intended to combat

misleading environmental claims about products and

services aimed at consumers.

Protecting the organisation

There is also a clear risk to businesses that the ASA’s

(and the FCA's and CMA's) focus on the ESG space may

encourage costly and reputationally damaging litigation,

High carbon-emitting business may be particularly

concerned by this last point, but as the ASA has

acknowledged, it should not mean that green claims are

completely off the table; on the contrary, it notes that

some businesses have managed to strike the right balance

‘through the inclusion of straightforward, prominent copy

in ads that acknowledges the less-climate-positive aspects

of their activities, that indicates how early in their journey

they are, or that provides summary details of their future

planned activities. Such copy does not have to dominate

ads, but it must not be hidden away’.

All of this said, the current focus on greenwashing

means that it is essential to ensure that such claims are

thoroughly verified and that relevant individuals in the

business (including at the highest levels) are satisfied

with the accuracy of the claims. In particular, absolute

environmental claims (for example claims that a product

is ‘100% recyclable’ or ‘environmentally friendly’) must

be capable of substantiation or, alternatively, statements

should be expressed in appropriately qualified terms.

Summary

To conclude, it’s perfectly clear that while organisations

and businesses are entitled to advertise their goods and

services, they need to do so with compliance uppermost

in their minds. The regime of the past where enforcement

relied on reporting has gone. Now the threat of action

comes from the proactive use of technology to markedly

step up what regulators can do.

Jonathan Rush is Knowledge Counsel at Travers Smith.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 23


VIEW FROM THE SEA

CLOCKED

OFF

Are we in danger of losing our way at work?

BY DAVID ANDREWS

A

long road trip through France

and Belgium at the start of the

year saw me stopping off with old

friends in the Dordogne region.

Of a similar vintage, my chums

have retired to enjoy la vie

Francais, glug plenty of fine wine, and feast on the local

fromage. They have one of those epic, beautiful houses

with plenty of outhouses for gite letting, a gorgeous pool

and their own vineyard. All for £500,000, which is broadly

what you’d pay for a one-bedroom flat in a challenged part

of south London.

Winters are harsh but come the spring it’s a lovely part of

the world. The perfect spot for a game of tennis and a glass

or two of Kir Royale. Not bad, eh? But there is a fly in the

ointment. Or maybe that should be a bluebottle.

My friend’s son, now 26 and educated to a high standard,

lives in the UK with his partner and has never had a job.

And I mean never. It’s a cause of much concern, distress

even, to my old mates. The young man is able bodied.

Intelligent. With a good degree. But he has chosen, like

literally millions of others of his generation (Z) to eschew

work and instead live off benefits. Which as it happens

are not bad.

What does he tell his civil servant interrogators when he

has a ‘review’ as to whether he will continue to qualify for

the free handouts? Well, a range of ‘issues’. Readers will be

familiar with most of them as this scenario is so prevalent

in the media.

Jeewhizz. If I had a tenner for every time I’ve heard these

incredibly annoying cards being played, I’d be off to the

Dordogne and a lovely second home myself. It’s such a

wind up.

Labour shortages

Government statistics show that there were approximately

670,000 unemployed people aged between 16 and 24 in the

third quarter of last year (2024). That’s 98,000 more than

in 2023, or to give more perspective, the highest recorded

number since age group records started in 1992.

The thing is, there’s plenty of work out there. Employers

are crying out for young labour but struggling to attract

quality applicants. It’s not just our youngsters who are

work-shy. Older beneficiaries of our generous benefits

system are creaming it in. So out of a potential UK adult

workforce of 25 million, around nine million are stay at

homers. They are taking the benefits – not paying any tax

– and ergo not contributing materially to our society in

any meaningful way to keep the wheels turning.

And we can’t afford it. Simple as that.

When I was 16 I left school and for several years

worked a host of menial jobs until finally getting

A levels and going to university in my 20s. Up at

5-00 am to drive a dumper truck in 1973 on a sprawling

building site in High Wycombe, Bucks. Try turning a

frozen solid dumper truck starting handle (it was a long

time ago) on a freezing February morning. And then

loading it with wet cement and bricks. At 7-00 in the

morning in minus conditions.

I did all that. No claims for mental health issues and the

like. Just very, very cold. And I gave my mum a portion

of my wages for my keep every week. It’s how it was

back then. No obesity. An NHS which worked just fine.

Broadly full employment. And no playing of these bizarre

contemporary maladies.

On the road trip I got myself up to the east of Belgium,

into the Ardennes Forest near a town called Bastogne.

Older readers may recognise the name. It’s where some of

the most vicious fighting of WW11 took place during the

so called battle of the Bulge.

Last gamble

Hitler’s last throw of the dice in December 1944 was to

send many divisions of crack Panzer squads and hordes

of infantry through the Eiffel region and into Belgium in

the hope of breaking the Allied supremacy in post D-Day

France, Holland and Belgium. The fighting raged around

Bastogne until the end of February 1945. Many, many

young American GIs lost their lives in the dreadful cold

and bitter fighting that winter. Most were aged around 20

years old. Generation Z-ers if you like.

I stood in various foxholes in Bois Jacques, the woodland

area seven kilometres from Bastogne where Easy Company

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 24


*

CREDIT MANAGEMENT

MANY YOUNG AMERICAN GI’S LOST

THEIR LIVES IN THE COLD AND BITTER

FIGHTING THAT WINTER. MOST

WERE AGED AROUND 20 YEARS OLD.

GENERATION Z-ERS IF YOU LIKE.

of the 101st paratroopers held their part of the front line.

Shelled relentlessly and repelling endless advances by

enemy tanks and infantry, those young men fought and

died in their foxholes. They did their job.

I thought of this sacrifice, unquestioning, it’s what we’ve

been trained to do. Etc. And I thought of my old mate’s

26-year-old son who had never worked, on his cushy

benefits. And I thought of the sacrifice that long ago

generation had made. For us. And it does not seem fair.

Innocent times

I cannot quite believe it’s been 37 years since I pitched

up as a young business reporter for CM. In those days

the title was based in the sleepy Lincolnshire hamlet of

Easton on the Hill. I would motor up from my north

London flat in a battered Alfa Romeo and spend a few

nights in a Stamford b ‘n b. No Air BnB in those days of

course.

A fellow reporter, Anthony Levy, became a good friend.

We spent a fair bit of time in the many outstanding

Stamford hostelries. Our editor, Richard Smith, was

a fine and highly principled journalist who taught me

a heck of a lot. We had some great laughs in what now

seems a far more innocent time. The pre mobile/social

media/internet days, when the desk telephone was our

only hotline to the world.

And Sir Alan Sugar’s early Amstrad desk top PCs glowed

a Space Invaders green in our compact, smoke-filled

newsroom. Both of my colleagues have sadly long since

departed this world and I’m not getting any younger. But

I don’t do the ‘R’ word and continue to write and consult

for my modest PR business.

All things must pass, however, and new blood flows

through any organisation rightly recognising that the

new stage is for the young. Through my years on national

newspapers and then building a financial PR firm there

have been endless challenges – but I would never have

traded places with anyone else.

It’s a cliche I know… but hard work and application does

pay off. But you have to do the leg work.

Author: David Andrews is a freelance jounalist.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 25


FINANCE

ARTIFICIAL

REALITY

Building and Integrating AI Models in the

Financial Services Sector.

BY MARDI MACGREGOR AND ROMANS VIKIS

Brave | Curious | Resilient / www.cicm.com / April 2025 / PAGE 26


CREDIT MANAGEMENT

AS the digital landscape

continues to evolve, artificial

intelligence (AI) represents a

transformative force within

the financial services sector.

By automating routine and

tedious tasks, providing

predictive analytics, enabling algorithmic trading,

and facilitating more effective risk management, AI

has multiple potential applications in the industry.

In recent months, the Bank of England (BoE) and

Financial Conduct Authority (FCA) have continued

to focus on AI in financial services, with the BoE

stating that appropriate regulatory responses are

required to negate the potential implications of AI

on financial stability, and the FCA launching the AI

Input Zone to gather stakeholders' views on current

and future uses of AI in UK financial services, as well

as the financial services regulatory framework.

AI in financial services is firmly on the UK financial

services regulators’ agenda and accordingly, there are

key considerations that firms should take into account

when building and integrating AI models in the

financial services sector to ensure they realise the full

potential of AI while minimising the risks associated

with its adoption.

Key considerations

Whilst the development and utilisation of innovative

AI-powered technologies are an exciting prospect for

financial services firms, data scientists and machine

learning engineers alike, the utility (and therefore, the

monetary value) of AI is dependent on the extent to

which it can be lawfully used.

In a joint discussion paper (DP5/22) from the FCA,

BoE, and the Prudential Regulation Authority (PRA)

in October 2022, the primary drivers of AI risk in

financial services were identified as relating to three

key stages of the AI lifecycle – data, models, and

governance, each of which are considered below.

The importance of data use

From sourcing large amounts of data and creating

datasets for training, testing, and validating, through

to the continuous analysis of data once the AI system

is deployed, the safe and responsible AI adoption

in UK financial services is underpinned by the use

of high-quality data. Financial services firms must

therefore consider the quality of their data.

Data quality and assurance

Poor quality or inappropriate data can compromise

any process that relies on it. The way in which data is

sourced and aggregated can impact the overall quality

of the data, and the intended outcome of a model. The

UK’s current regulatory framework aims to address

these specific risk components of the data lifecycle.

For example, the Basel Committee on Banking

Supervision has published various principles (the PRA

expects banks to adhere to these principles) aimed

at strengthening prudential risk data aggregation

by ensuring the accuracy, integrity, completeness,

timeliness, and adaptability of data. The PRA’s current

rules also require insurers to have internal processes

and procedures in place to ensure the completeness,

accuracy, and appropriateness of the data used in the

calculation of their technical provision.

Data sourcing is a critical consideration not only

because it will fundamentally shape the AI system,

but also because of the potential liability that may

arise if that data was sourced through inappropriate

means. This means ensuring that any data sourced is

compliant with relevant data protection regulations

and intellectual property rights, as well as having the

necessary permission to use it, to avoid possible civil

litigation.

AI-POWERED

TECHNOLOGIES

ARE AN EXCITING

PROSPECT FOR

FINANCIAL SERVICES

FIRMS, DATA

SCIENTISTS AND

MACHINE LEARNING

ENGINEERS ALIKE

Data privacy and security

Ensuring data is protected from malicious threats

such as unauthorised access, theft, and corruption is

crucial, and firms must ensure that data privacy and

anti-money laundering / counter-terrorist financing

regulations are complied with when sourcing and

utilising data in the development of AI. The UK's

Information Commissioner’s Office has updated its

guidance on AI, focusing on data protection impact

assessments, transparency to data subjects, and

minimisation of data usage. Meeting the core principle

of the GDPR – that only the minimum amount of data

needed to fulfil the purpose of processing is utilised –

can often be at odds with the large volumes of data

required to train AI systems. In order to comply with

this obligation, the risk management function of the

AI project must implement practices that are designed

to ensure that data minimisation is considered from

the initial design phase. Where an entity outsources

the AI production to a third party, this consideration

should form part of the due diligence process.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 27

continues on next page >


FINANCE

Data architecture,

infrastructure, and resilience

Firms must have strong data architecture and risk

management infrastructure under the FCA and PRA’s

current rules and guidelines to ensure AI technologies

are resilient against operational disruptions and data

quality issues. This includes having processes to manage

data architecture and resilience effectively, ensuring that

even in times of data breaches or system failures, the AI

models remain functional and reliable.

Robust AI development

When developing AI models, the joint discussion

paper highlights that firms must ensure the models are

compliant with a number of requirements.

Robust

AI models need to be resilient to errors and adaptable to

unforeseen changes. Firms must consider the possibility

of model drift (i.e., where the model’s performance

deteriorates over time as the data distribution changes).

Models should be periodically retrained and validated to

maintain their performance.

Fair

AI models must be built to ensure that they are fair to

all groups of people, regardless of their gender, race, or

other characteristics. Firms should ensure that they do

not use biased data or introduce biases unintentionally

while building the models. They must also consider the

possibility of unintended consequences and monitor

the models’ performance to ensure that they are not

perpetuating existing biases.

Diversity and inclusion continues to be a top regulatory

priority with the PRA and FCA consulting on measures

to boost diversity and inclusion in the financial services

sector last year. Firms will need to ensure that AI models

comply with current and upcoming regulatory rules and

guidance in this area.

Firms must also ensure that they are delivering good

customer outcomes when developing and using AI,

for example by providing unbiased, clear, and accurate

information to customers, and safeguarding their interests

by generating decisions that are fair and justifiable.

Techniques such as algorithmic fairness, where the model

is continuously tested for unbiased decision-making, can

be employed to promote fair AI systems.

Explainable

AI models must be explainable to stakeholders. Firms

should ensure that transparent models are used and

provide clear explanations for the decisions made by the

models. This may be a challenge for firms, as AI models

(particularly generative AI models) may be difficult to

explain (both in terms of how it works and the reasons

for its outputs). However, techniques such as using whitebox

models or creating explainability frameworks that

outline how decisions are made by the AI system can help

in achieving transparency.

Model governance

The joint discussion paper also highlights that governance

is a critical factor in ensuring the safe and responsible

adoption of AI in the financial sector. A number of key

recommendations were provided in the paper for AI

governance.

Accountability

Firms should ensure that they have clear accountability

structures in place for the AI models they develop, and that

the roles and responsibilities of the stakeholders involved

in the AI lifecycle are clearly defined and communicated.

The PRA’s and FCA’s existing rules and guidance around

the Senior Managers and Certification Regime (SMCR)

emphasise senior management accountability and

responsibility and are relevant to the use of AI. At present,

there is no dedicated senior management function (SMF)

for AI, with technology systems currently being the

responsibility of the SMF24 (Chief Operations functions)

and the overall management of the risk controls of a

firm being the responsibility of the SMF4 (Chief Risk

function). Therefore, a key consideration for firms is who

should be responsible for the use of AI within the firm.

AI MODELS IN THE

FINANCIAL SECTOR

OFFER SIGNIFICANT

OPPORTUNITIES

FOR FINANCIAL

INSTITUTIONS TO

REDUCE COSTS

Risk management

Firms should have a robust risk management framework

in place for the AI models. They must ensure that they

identify and assess the risks associated with the models

and implement appropriate risk mitigation measures.

Whilst the joint discussion paper recognises that the use

of AI may, in some cases, be used to minimise risk and

increase stability for a firm, it may also have the effect of

amplifying many of the existing risks to financial stability

in the financial services sector more generally. For

example, the use of similar datasets and AI algorithms

may create uniformity across models and approaches

at multiple firms, which could amplify behaviour and

lead to herding in certain use cases, such as algorithmic

trading, or increase the potential for systemic risk and

market disruptions.

Board composition,

and engagement

Brave | Curious | Resilient / www.cicm.com / April 2025 / PAGE 28


CREDIT MANAGEMENT

There may be a lack of understanding of the

challenges and risks arising from the use of advanced

technologies at firms’ senior management and board

levels, both individually and collectively, leading to

a skills and engagement gap and a risk of ineffective

governance. There are requirements and expectations

on firms to address this skill gap, including the PRA’s

expectations that boards should have the diversity of

experience and capacity to provide effective challenge

across the full range of the firm’s business and boards

should pay close attention to the skills of its members;

and the FCA requirements for issuers to publish

information on board diversity policies in their

corporate governance statement.

Future regulation of AI

In October 2023, the FCA, PRA and BoE published

a feedback statement to their joint discussion paper.

Whilst this feedback statement summarised the

responses received in relation to the discussion paper,

it did not include policy proposals, nor did it signal

how the UK supervisory authorities are considering

clarifying, designing, and/or implementing current or

future regulatory proposals on this topic.

Nevertheless, there were a number of key points

made by respondents. It was noted that a regulatory

definition of AI was not seen as beneficial due to the

rapid evolution of AI technologies. Also, there was

a preference towards principles-based or risk-based

approaches rather than specific AI definitions.

Industry engagement was seen as crucial, with

initiatives like the AI Public Private Forum being

valuable. Similarly, coordination and alignment

between domestic and international regulators was

recommended to reduce complexity.

An emphasis on consumer outcomes, particularly

fairness and ethical considerations was valued while

concern was raised over the increasing use of thirdparty

AI models and the need for regulatory guidance.

This said, firm governance structures and frameworks

such as SMCR were deemed sufficient to handle AI

risks. In October 2024, Sarah Breeden, BoE Deputy

Governor for Financial Stability, delivered a speech

addressing the implications of AI on financial stability.

As noted in Breeden’s speech, the increasing power

and use of AI, particularly generative AI, poses

significant implications for financial stability,

requiring appropriate regulatory responses. She also

noted that generative AI models are distinct due to

their autonomous learning and evolving capabilities,

with outputs that are not always interpretable or

aligned with societal goals. AI is expected to bring

considerable benefits to productivity and growth.

However, regulators must develop frameworks to

manage associated financial stability risks.

The speech highlighted two main regulatory concerns.

At the microprudential level, technology-agnostic

frameworks are needed to mitigate risks as AI

adoption increases. And at the Macroprudential level,

it is necessary to be vigilant about systemic risks and

have evolving stress tested frameworks.

The Financial Policy Committee (FPC) is scheduled

to publish its assessment of AI's impact on financial

stability early in 2025. This assessment will include

strategies for monitoring the evolution of potential

risks associated with AI in financial services. The

FPC aims to understand and mitigate risks such as

interconnectedness and trading behaviours influenced

by AI.

FCA’s AI Input Zone

In November 2024, the FCA launched the AI Input

Zone to gather stakeholders' views on current and

future uses of AI in UK financial services, as well as the

financial services regulatory framework. This initiative

aims to support safe and responsible innovation,

promote sector growth and competitiveness, and gain

practical insights into AI usage. The AI Input Zone,

part of the FCA’s AI Lab, invites diverse market

participants to share their perspectives and participate

in shaping the FCA’s future regulatory approach.

The initiative is an evidence-gathering effort to

understand transformative AI use cases and identify

opportunities for innovation. Stakeholders were

encouraged to express their views about current and

future uses of AI in UK financial services by the end

of January (2025).

Conclusion

The development of AI models in the financial

sector offer significant opportunities for financial

institutions to reduce costs, increase efficiency, and

improve customer experiences. However, there are

risks associated with its adoption such as hallucinations

and unpredictable behaviour, opaqueness, and a

firm’s lack of control over the foundation models

used in Generative AI (such models typically being

built and trained by third parties). As the use of

generative models (such as ChatGBT, Llama, BERT

and RoBERTa) increases, it is likely that the UK

regulator’s scrutiny of this technology will too.

At a minimum, firms must ensure that they comply

with data protection regulations, have permission

with regards to the data being fed to the AI system,

build robust, fair, and explainable AI models, and

implement appropriate governance frameworks, and

should keep up to speed with further guidance released

by the regulators in this area. By doing so, firms

may be able to realise the full potential of AI while

minimising the risks associated with its adoption.

Author: Mardi MacGregor is a partner, and Romans Vikis

is an associate, at Fox Williams LLP.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 29


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T: +44 (0)2073 875 868 - London

T: +44 (0)2920 495 444 - Cardiff

W: Menzies LLP.co.uk/creditor-services

Bottomline Technologies (NASDAQ: EPAY) helps

businesses pay and get paid. Businesses and banks

rely on Bottomline for domestic and international

payments, effective cash management tools, automated

workflows for payment processing and bill review

and state of the art fraud detection, behavioural

analytics and regulatory compliance. Every day, we

help our customers by making complex business

payments simple, secure and seamless.

T: 0870 081 8250

E: emea-info@bottomline.com

W: www.bottomline.com/uk

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

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• Streamline Collections, Payments & Asset

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• Enhance customer engagement with our cloudbased

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E: sales@geniusssl.com

W: www.geniusssl.com

Transform your Accounts Receivable with

Corcentric’s Managed AR Solution. Our

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E: ahassan@corcentric.com

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Building on our mature and hugely successful

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re-imagining our risk awareness module in 2019 to

allow for hugely flexible automated worklists and

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integration with all credit scoring agencies (e.g.

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for analysis and automation. Impressive results

and ROI are inevitable for our customers that also

have an active input into our product development

and evolution.

T: 01235 856400

E: info@credica.co.uk

W: www.credica.co.uk

Brave | Curious | Resilient / www.cicm.com /April 2025 / 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...

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

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

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sectors to recover unpaid CCJ’s sooner rather than

later. We achieve 39 percent early engagement

resulting in market-leading recovery rates. Our

multi-award-winning technology provides real-time

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E: s.evans@courtenforcementservices.co.uk

W: www.courtenforcementservices.co.uk

TCN is an industry leader in call centre technology

with offices around the world including, the United

Kingdom, the United States, Romania, Canada,

India and Australia. TCN has met the global

communication needs of its diverse customers.

Utilising best-practice solutions and 24/7 technical

support, TCN empowers clients to drive consumer

interactions through omni-channel, inbound and

outbound communications. TCN’s call centre

platform is entirely web-based and available

on-demand with unlimited capacity.

T: +44 (0) 800-088-5089

E: spencer.taylor@tcn.com

W: www.tcn.com

With over 45 years of experience in supporting

organisations in the successful delivery of multichannel

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.

Top Service Ltd. 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 and make the best, most informed

credit decisions. Coupled with our range of effective

debt recovery solutions, quite simply our members

stay one step ahead and experience less debt and

more cash.

Dun & Bradstreet is a leading provider of

comprehensive global business data and

analytics. We help clients make smarter decisions

and drive resilience by bringing together millions

of data sources into a globally consistent view,

underpinned by our D-U-N-S number.

T: 01761 416311

E: info@cfh.com

W: www.cfh.com

T: +44 1527 503990

E: membership@top-service.co.uk

W: www.top-service.co.uk

TOP SERVICE

MINIMISE DEBT

MAXIMISE C ASH

T: +44 (0)808 239 7001

E: hello@dnb.com

W: www.dnb.co.uk

Key IVR provide a suite of products to assist

companies across Europe with credit management.

The service gives the end-user the means to make a

payment when and how they choose. Key IVR also

provides a state-of-the-art outbound platform

delivering automated messages by voice and SMS.

In a credit management environment, these services

are used to cost-effectively contact debtors and

connect them back into a contact centre or

automated payment line.

American Express® is a globally recognised

provider of business payment solutions, providing

flexible capabilities to help companies drive

growth. These solutions support buyers and

suppliers across the supply chain with working

capital and cashflow.

By creating an additional lever to help support

supplier/client relationships American Express is

proud to be an innovator in the business payments

space.

STA International is a leading credit management

provider, offering debt recovery, outsourced credit

control, address tracing, and legal debt recovery

services. We maximise cash flow and minimise

risk with tailored strategies for businesses of

all sizes. Acting as an extension of your team,

we ensure efficient, amicable collections and

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International to safeguard your financial health and

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T: +44 (0) 1302 513 000

E: partners@keyivr.com

W: www.keyivr.com

T: +44 (0)1273 696933

W: www.americanexpress.com

T: +44 (0) 1622 600 921

W: www.stainternational.com

Brave | Curious | Resilient / www.cicm.com / April 2025 / PAGE 31


COUNTRY FOCUS

on Turkey

Border Crossing

Turkey is at a crossroads in more ways that none.

THE FOUNDING FATHER OF

THE MODERN TURKISH STATE,

THERE’S PLENTY TO KEEP A

VISITOR INTERESTED.

Tu

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 32


CREDIT MANAGEMENT

rkey

member

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 33

WE could open and

close a country profile

on Türkiye, formerly

known as Turkey, very

quickly. It’s an emerging

country with an uppermiddle-income

that sits

at the crossroads of Europe, Asia and Africa with a history

that cannot be ignored.

Known for Istanbul and sights such as Grand Bazaar and the

Blue Mosque, ancient sites such as Pamukkale, Hierapolis

and Ephesus, tulips under the Ottomans (no, they didn’t

originate in Holland), carpets and rugs, a unique cuisine,

and Mustafa Kemal Atatürk – the founding father of

the modern Turkish state, there’s plenty to keep a visitor

interested.

Steeped in History

Türkiye’s history goes back several millennia to well before

the founding of the Turkish Republic in 1923. Originally

a nomadic people from Central Asia, Turkish peoples

established several empires such as the Seljuk and Ottoman

Empires. The former can be dated to between 1037 and

1194, and the latter to 1299 until 1922. The Ottomans took

Constantinople – now Istanbul – in 1453 to become a

dominant world power with lands encompassing Anatolia,

North Africa, southeastern Europe, parts of the Arabian

Peninsula and Persian Gulf, modern day Iraq, and portions

of the Caucasus.

With a religiously and ethnically diverse population it was

only a matter of time before the Ottomans lost territory

from the 17th century. And with numerous national groups

within the empire, slow economic and technological

progress, and an ill-fated alliance with Germany during

World War I, the empire eventually collapsed.

Indeed, it was Mustafa Kemal (Ataturk) who united

disparate Turkish forces against foreign occupation of

Turkish lands. On forming the Turkish Republic in 1923,

Ataturk instituted sweeping reforms that made society

along the lines of a westernised parliamentary democracy.

He ordered the conversion of the Turkish alphabet from

Arabic to Latin script, encouraged European dress, and

incorporated German, Swiss, and Italian law codes into

Turkish law.

It’s no surprise then that this Western orientation led to

Türkiye being a charter member of the United Nations, a

of NATO since 1952, and seeking EU membership.

continues on next page >


COUNTRY FOCUS

Country demographics

According to 2024 data from the Turkish Statistical

Institute, the population is currently around 85.6m.

Chart data from Statista shows a flattish population

with 9.77m in 1800 14.1m to in 1924. But from there on

the rise was and has been exponential with figures of

21.41m in 1950, 43.98m in 1980 and 72.33m in 2010 and

onwards to where it is now.

Data from the European Commission, updated

in November 2023, notes that 50.2% of the total

population is male, and 49.8% is female. In 2018, the

15-64 age group (working age) population increased

by 1.4% compared to the previous year to 67.8%. The

proportion of the 0-14 age group - the child age group -

declined to 23.4% , and those aged 65 and over increased

to 8.8%. Accordingly, the population pyramid for the

country looks very much like a tear drop – narrower

at the bottom, cylindrical to age 54 and tapering to

the top.

The CIA World Factbook reckons, using 2016 data,

that Türkiye is quite homogenous with 70-75% being

Turkish, 19% Kurdish, and 6% -11% being ‘other’. It

follows that Turkish is the official language while

Kurdish and other languages are also spoken.

The country

Officially the Republic of Türkiye, the country is

mainly sited in western Asia with a small part set in

southeastern Europe. The Republic of Turkey, in 2022,

via the UN, changed its spelling to Türkiye.

Sitting astride the Bosphorus Strait, a 19-mile

waterway that connects the Black Sea to, effectively,

the Mediterranean, Türkiye borders a number of

countries. There’s Georgia, Armenia, Azerbaijan,

and Iran to the east; Iraq and Syria to the south; and

Greece and Bulgaria to the west.

With a land area of 769,632 km2, Türkiye is placed

36th in the world, just behind Mozambique but above

Chile. As before, the UK is 78th with 242,741 km2.

It’s topography is variable with semi-arid plateau

and basins in Anatolia that see little rainfall, and

mountains; Black Sea forests with mountains, high

humidity and rain; and land and natural lakes along

the coastlines of the Mediterranean and Aegean that

see hot summers, mild and wet winters, and not

unsurprisingly, fertile soils.

As to where the population lives, the CIA says

that 77.5% of the population is urbanised with the

most densely populated area being found around

the Bosporus in the northwest where 20% live in

Istanbul. The CIA notes too that with the exception

of Ankara, urban centres remain small and scattered

throughout the interior of Anatolia; an overall pattern

of peripheral development exists, particularly along

the Aegean Sea coast in the west, and the Tigris and

Euphrates River systems in the southeast. In numbers,

15.84m live in Istanbul, 5.39m in Ankara – the capital,

3.08m in Izmir, 2.08m in Bursa, 1.83m in Adana, and

1.8m in Gaziantep.

Growing economy?

Türkiye’s economy is considered by the World Bank

and IMF to be the 17th largest in the world with a

GDP of $1.02tn in 2023. In 25 years, the economy has

grown somewhat – from $274.29bn in 2000, $776.97bn

in 2010, a drop to $720.34bn in 2020, to an estimated

$1.12bn in 2024.

But if we look at the World Bank’s chart for Türkiye’s

annual growth rate from 1961 to date, we see a

compressed ECG recording for a patient needing life

support. Just looking at the period from 1983 to 2023

we see a wild sawtooth set of peaks of up to 10%% and

troughs of up to negative 6%. The 2023 rate was 5.1%.

As for inflation, Türkiye cannot be classified as a low

inflation economy. The 1970s recorded rates between

7.92 and 63.54%, a peak of 94.26% in 1980, rates of

40-60% in the 1980s, 105.22% in 1994, a ‘rapid’ drop to

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 34


CREDIT MANAGEMENT

x The Grand Bazaar in Istanbul is one of the largest

and oldest covered markets in the world, with 61

covered streets and over 4,000 shops on a total area of

30,700 m², attracting between 250,000 and 400,000

visitors daily.

equally divided between the children’. Consequently,

nearly two-thirds of Turkish farms are less than

five hectares in size. It added that ‘97% of Turkish

farmers reported diminishing harvests and yields due

to climate change-related impacts’. This is partly a

function of open channel irrigation.

Even so, Türkiye is a major producer of wheat, sugar

beets, milk, poultry, cotton, tomatoes, and other fruits

and vegetables, and is the top producer in the world

for apricots and hazelnuts. It also produces cherries

and figs.

Automotive

In 2023 Türkiye produced some 1.4m vehicles which,

says the Turkish government, puts the country into

third place in terms of European production (first if

only commercial vehicles are counted). Of the 1.4m

units, the Daily Sabah reported in January 2024 that

953,000 were cars.

More than 30 of the top 100 global suppliers have

facilities in Türkiye including Pirelli, Continental,

Bosch and Denso.

Statista states that the Turkish automotive industry

has been the export champion of the country for nearly

the last two decades. After the industry recovered

from the pandemic, the country’s automobile exports

increased …and peaked at $35bn in 2023. Indeed, in 2023

it’s reckoned that around 663,000 units were exported.

8.6% in 2004, a ‘stable’ 6-10% from 2005 to 2017, and an

uptick to a peak 72.31% in 2022 when President Erdogan

lowered interest rates to attempt to reinvigorate the

economy.

Business sectors

Agriculture

The Turkish Government has stated that agriculture

employed almost 18% of the country’s working

population and accounted for 6.5% of the country’s

GDP ($58.5bn) in 2022.

The US International Trade Administration said, in

2024, that over half the country consists of agricultural

land. Statista clarifies the point and reckons that

the size of the total agricultural land did not show

significant changes in Türkiye from 2010 to 2023. After

peaking in 2010 at 24.4m hectares, figures decreased

slightly over the years and reached roughly 24m

hectares in 2023. However, Climate Scorecard has

warned that the average farm size in the country is

decreasing through inheritance law, ‘as land should be

However, there are headwinds as noted by AGBI.

com. It wrote in September 2024 that domestic

manufacturers are facing stiff competition from

imports and grappling with 'sky-high interest rates’.

Production of most commercial vehicle types fell by

between 40 and 51%, partly due to the economy and

private banks charging 55% or more interest on loans.

Overall, at the end of 2023, Türkiye's automotive sector

employed 60,619 workers according to data from the

Automotive Manufacturers Association.

Defence and aerospace

This is an important sector for Türkiye. Mordor

Intelligence detailed that in 2022 military spending

was $15.4bn. According to the Defence Industry

Manufacturers Association, in 2022 Türkiye’s defence

and aerospace industry sales reached $12.2bn along with

an increase in spending on research and development

to $2.1bn from $1.6bn from 2021.

The sector is, however, fragmented. Mordor states that

the country is to enhance its domestic manufacturing

capabilities, especially as it was kicked out of the USled

F-35 programme for buying a Russian made air

defence system.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 35 continues on next page >


COUNTRY FOCUS

Research and Markets, in its forecast to 2027, notes

that the sector and saw total revenues of some

$42.67bn in 2022 on production volumes of 145.8bn

metric tons. The sector has grown considerably

since 2010, according to ceicdata.com reporting

data from the Federal Ministry Republic of Austria.

Back then it produced some 98.7bn metric tons. But

by 2021 that had grown to 146.02bn metric tons.

The sector may grow further still given that, as

aa.com.tr reported in January 2024, that ‘Türkiye has

substantially increased its financial commitment to

the mining sector this year, elevating the budget by

34% to 106bn liras and marking a milestone for the

industry's growth’. It added: ‘Forty-seven miningrelated

projects projected are due to receive funding

in the current fiscal year’.

Cappadocia is a region in central Turkey, known

for its unique landscape of ``fairy chimneys'' and other

rock formations. The area is particularly famous for its

hot air balloon rides, which offer stunning views of the

region's towering rock formations, valleys, and caves.

As for military exports, defenceturkey.com says that

the Gulf and Middle East are crucial export markets

for the Turkish defence and aerospace sector. It

reported that in 2023, Türkiye exported 230 types

of defence and aerospace products to 185 countries.

This it said, is ‘due to its NATO-standard high-tech

product range, competitive pricing, and openness to

technology transfer’.

On the civilian side, the Government notes that there

were 668 civil aircraft that carried 214.2m passengers

in 2022 which produced a turnover of $35.8bn in 2022.

Considering that passengers numbered 34m and

turnover stood at $2.2bn in 2004 it’s easy to see that

tourism has expanded.

Mining and metals

The Turkish Government reports that mining and

metals is another key sector for the economy.

Türkiye has 70 different types of natural resources

and is actively involved in the international trade of

60 of these minerals (aa.com.tr). It has large deposits

of boron, marble, trona, feldspar, barite, gypsum,

and chromium. Valuable metals and minerals include

gold, silver, nickel, aluminium, iron, copper, lead, zinc

and antimony.

The Government claims that Türkiye has 73% of

global boron reserves, has 20.4bn tons of lignite, 40%

of global natural stone reserves, and produced 31 tons

of gold in 2022.

In April 2024, the Union of Chambers and Commodity

Exchanges of Türkiye Mining Council stated that the

sector has provided direct employment for an average

of 136,000 people in the preceding 15 years.

Tourism

The travel and tourism sector is huge too; the country

sees millions of tourist arrivals – around 57m in 2023

according to Statista.

The World Travel & Tourism Council wrote in June

2024 that the sector contributes 12% of GDP and

supports 3.2m jobs. It added that the sector is forecast

to continue breaking records in 2024, with GDP

contribution set to reach almost 12.5% of the country’s

economy… The outlook for the next 10 years forecasts

a decade of growth.

This is backed up by comment from the Daily Sabah

which wrote that foreign arrivals are expected to

reach 60m in 2024 before hitting 90m in 2028… for

income, [the Government] said they see it rising to

$60bn [in 2024] and $100bn five years from now.

That compares well to Statista’s data which reckons

that the sector was worth nearly $56bn in 2023 and has

recovered well post-pandemic. Russians are one of the

largest groups of foreign visitors to Türkiye followed

by Germans and Britons.

Summary

From what has been written it should be patently

clear that Türkiye ought to be top of many a board’s

list of potential export markets. Sitting at the

crossroads of Europe, Asia and Middle East, it’s the

perfect springboard into other territories. But just

as no organisation should commit itself without

understanding what it’s getting into, so exporters

should be aware of the instability of the economy in

terms of, for example growth and inflation.

Author: Adam Bernstein is a freelance finance writer

for Credit Magazine magazine.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 36


As voted for at the 2025 CICM British Credit Awards


DEBT

FLOOD

WARNING

Is there a debt tsunami coming?

BY GARY BROWN MCICM

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 38


CREDIT MANAGEMENT

THIS LOOMING

REFINANCING WAVE COULD

TRIGGER RECESSIONARY

PRESSURES AND HEIGHTEN

CREDIT-DEFAULT RISKS,

MAKING CREDIT RATINGS

AND ACCESS TO LIQUIDITY

CRITICAL FOR BUSINESSES

OF ALL SIZES.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 39 continues on next page >


DEBT

Global Liquidity

Much of this debt is underpinned by global liquidity.

Refinancing such a large volume of obligations in a short

two to three-year window will demand coordinated efforts

among international lenders, policymakers, and central

banks. The potential credit risks will be global in nature,

affecting not just isolated markets but also interconnected

economies worldwide.

FIVE years on from COVID, a once-ina-generation

credit event has ushered

in an extraordinary five-to-sevenyear

business cycle, now nearing its

final stages. As with the pandemic, no

organisation – large or small – is entirely

immune. This raises the prospect of

heightened credit risk across the board as a massive wave

of pandemic-era debt nears its refinancing deadlines.

A Global Surge

The near-complete shutdown of economies worldwide in

2020 added roughly $30 trillion to global debt – an increase

the IMF has described as the largest surge since World War

II. The United States alone contributed about $7 trillion,

raising its federal obligations from $23 trillion to nearly

$30 trillion by early 2022.

Total global debt across Government, corporate, and

household sectors stood at a record $307 trillion as of mid-

2023, according to the Institute of International Finance

(IIF). Many analysts estimate that by 2025, global debt

could climb to $320–$340 trillion, driven by ongoing

Government deficits, robust corporate borrowing, and

household credit demand – even in the face of rising

interest rates.

As the current business cycle winds down, a significant

portion of this debt – often carrying loan maturities of

around 65 months (average) – will come up for refinancing

between mid-2025 and mid-2027. This looming refinancing

wave could trigger recessionary pressures and heighten

credit-default risks, making credit ratings and access to

liquidity critical for businesses of all sizes.

The signs, for those who choose not to ignore them, are

already there. One early indicator of credit stress is the

gradual lengthening of trade debt payment cycles and

abuse of extended payment terms. As finances become

more strained, some organisations delay settling invoices

or push for longer terms to manage cashflow, often

shifting the burden onto suppliers and creditors. CFOs,

credit managers, and stakeholders will need to be more

vigilant than ever for this behaviour, as it can herald wider

liquidity challenges within supply chains and the broader

market.

So who will feel the strain?

While many homeowners with 30-year mortgages at

2-3% interest may be relatively shielded, those reliant on

higher-interest financing (e.g., auto loans, credit cards)

face tougher terms as rates climb. Small businesses will

also be affected. SMEs with tighter cashflows and fewer

financing channels are especially vulnerable to rising costs

and stricter lending requirements. Even smaller debt loads

can create outsized stress if revenue streams weaken and

refinancing options narrow.

But the challenge of refinancing is not something that only

affects the smaller enterprises. Much larger corporations

may also feel the pressure. Whereas those with the strongest

balance sheets and easier access to corporate bond markets

may be cushioned from the full effects, larger firms aren’t

entirely insulated; supply-chain fragility and customer

defaults can pose indirect risks.

Government Debt

The challenge is not restricted to the business world.

Governments – having issued substantial short-term debt

to cover pandemic spending – could be among the first

to face elevated refinancing costs. A notable example is

the Trump administration’s evolving fiscal strategy under

Treasury Secretary Scott Bessent, who initially unveiled a

“3 3 3 plan” in the summer of 2024.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 40


CREDIT MANAGEMENT

Credit Risk Timings to Watch

• Mid-2025: Liquidity begins to tighten as governments

and corporations start rolling over shorter-dated debt

– five years on from the initial wave of pandemic-era

financing.

• Early 2026: If the 10-year U.S. Treasury yield climbs to

5% - 6%, it would signal heightened market demand

for refinancing and higher premiums, confirming tighter

lending conditions.

• Mid-2026: The refinancing wave likely peaks, with a

concentrated volume of loans reaching maturity.

• 2026–2027: In a worst-case scenario, excessive

refinancing demands and stringent credit requirements

could lead to widespread defaults, potentially eroding

robust labour markets and undermining GDP growth.

Stress indicators – such as rising corporate delinquencies

or lengthening payment terms – could surface in the

latter half of 2026.

The plan aimed to cut the federal budget deficit to 3% of

GDP by 2028 (the last year of President Trump’s second

term), boost GDP growth to 3% through deregulation and

pro-growth measures, and increase US energy production

by an additional three million barrels of oil per day.

However, as of early February, Bessent signalled a shift

toward keeping Treasury yields low via fiscal policy

– moving away from prior calls for Federal Reserve

benchmark rate cuts. The administration now views the

10-year Treasury yield as the critical lever for managing

borrowing costs, foreshadowing more direct interventions

in Government debt markets.

Better prepared

As with any global crisis, no organisation is fully shielded

from the aftershocks of a worldwide credit squeeze.

Preparation, cost optimisation, and forward planning can

make the difference between weathering the storm and

facing severe financial strain.

Best practices would include mapping out debt maturities,

identifying and anticipating refinancing obligations

well before they come due, thereby avoiding lastminute

scrambles, when credit conditions may be less

favourable. They would also include strengthening credit

risk frameworks by implementing robust policies and

analytical tools to gauge counterparty exposure, and stresstesting

multiple scenarios and interest-rate environments

to pinpoint vulnerabilities.

Early, honest dialogue helps ensure you’re near the front

of the queue if credit tightens, while proactive discussions

often yield better terms and more flexible covenants. On

that basis, maintaining transparent lender communications

is key, as is the need to optimise all budgets available

to you. In a tightening credit environment, companies

must do more with less, and leveraging automation and

AI technologies – like Debt Register – enables firms to

stretch existing budgets further, streamlining invoice

chasing, prioritising collections, and boosting cashflow

predictability.

Leveraging AI and other digital tools helps deliver datadriven

insights that in turn help to illuminate hidden risks

and streamline decision-making, maximising the impact

of every pound/euro/dollar spent. Automated analytics

can also detect warning signs – like payment delays – well

in advance of manual processes.

Getting the basics right is key. Keep a close eye on average

days sales outstanding (DSO) and invoice payment trends

and act quickly on any signs of extended payment terms,

which can be an early signal of liquidity strain for your

customers – or for you.

Conclusion

A confluence of high debt levels, rising interest rates, and

a compressed refinancing window points to a challenging

phase for both public and private sectors. As with any

global crisis, no business – large or small can be fully

shielded from the fallout.

The best defence lies in proactive planning and strategic

action – whether through robust credit frameworks,

AI-driven analytics, or platforms that ensure your

organisation’s debts and claims are front and centre. By

optimising existing budgets and being vigilant about

payment delays, organisations can move from merely

surviving the next financial storm to emerging from it in a

position of strength.

Author: Gary Brown MCICM is Founder of Debt Register.

Key Takeaways for CFOs

and Credit Professionals

1.Refinancing Readiness

• Anticipate the crunch between mid-2025 and mid-

2027; secure options early.

2. Build Financial Resilience

• Fortify balance sheets and maintain liquidity buffers.

It’s better to have a plan and not need it than to need

one and not have it.

3. Monitor Monetary, Fiscal, and Payment Trends

• Keep a close eye on central bank policies, Treasury

yields, fiscal changes, and emerging signs of delayed

payments that could reshape credit markets.

4. Adopt Cost-Efficient Strategies

• Use AI and digital tools to get more out of current

budgets, effectively doubling results without

doubling costs.

5. Practice Ongoing Scenario Planning

• Continuously update forecasts and run scenario

analyses, staying agile as conditions evolve.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 41


CAREERS

EDUCATION OR

EXPERIENCE?

The three factors that really matter

BY NATASCHA WHITEHEAD FCICM

RESILIENCE IS A CRUCIAL SKILL

FOR THRIVING ACROSS THE CREDIT

LANDSCAPE, AND ARGUABLY THIS IS A

SKILL MORE LIKELY TO BE DEVELOPED

OUTSIDE OF EDUCATION

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 42


CREDIT MANAGEMENT

THE debate between obtaining a

degree versus on-the-job experience

is one that continues to crop up

across the world of work, and

the credit sector is no exception.

Deciding on the most valuable way

to lay the foundations for a fulfilling

and successful career in credit is by no means black and

white as every individual has different learning styles and

preferences and will follow their own unique career path.

It goes without saying that having a degree won’t harm your

chances of a fulfilling and successful career in credit, and

it can certainly support your professional journey, but the

key thing to note is that a background in higher education

is not essential. Speaking from my own experience, the

majority of people I meet don’t initially set out to work

in credit and instead they stumble across the sector, quite

by accident, and then absolutely love it! In other words,

aspiring credit professionals shouldn’t be disheartened

or discouraged if they haven’t been to university and

employers alike ought to look at the bigger picture when

hiring rather than having strict degree requirements.

According to our research, attitudes towards the necessity

of a degree amongst finance employers are relatively split,

with just over half (53%) who say an applicant’s academic

background is important compared to 47% who believe

it is not make or break that a job applicant has a degree.

Although degrees and qualifications are impressive, it’s

the other key ingredients individuals develop along the

way that will future proof their career.

Let’s explore the three factors I believe are crucial for

credit professionals to flourish.

1. Attitude

Arguably everything comes down to a person’s attitude

– with a positive attitude, an individual is more likely to

achieve their goals, be more productive, build great working

relationships, secure vast opportunities, contribute to

a healthy working environment, overcome challenges,

minimise stress and the list goes on. A professional’s

attitude impacts how they express themselves, what they

are like to work with, how they react in different scenarios

and how treat they those around them. Ultimately, all this

comes from within, regardless of whether someone has a

degree or on the job experience or both.

Having an enthusiasm to learn, grow and broaden your

horizon is an essential element of a constructive attitude;

as our research reiterates, three quarters (75%) of finance

employers believe a person’s willingness to learn is more

important than their existing skills. Especially with the

continually evolving nature of credit, professionals who

are adaptable and open to constantly improve themselves

and to venture outside of their comfort zone will stand in

good stead to go far, degree or no degree.

2. Skills

Developing a strong skillset, including both soft and

technical skills, is paramount for any credit professional.

Many soft skills needed for being successful in credit,

such as communication and the confidence to have

difficult conversations with people, are developed outside

of further education, including in customer service

jobs, retail roles and through apprenticeship schemes.

Something like time management can be enhanced during

university level education, in order to plan ahead, manage

a heavy workload and various modules and to meet

deadlines, but this is also a skill that can come with onthe-job

training and experience. Resilience is a crucial skill

for thriving across the credit landscape, and arguably this

is a skill more likely to be developed outside of education,

in scenarios such as competitive sporting environments or

dealing with challenges at home and in personal life.

The opportunity to hone our skills is all around us, and

depends largely on the experiences you go through, rather

than whether you have a degree or a certain amount of

time at a particular organisation.

3. Credibility

The importance of being both trustworthy and

knowledgeable cannot be overstated and there are several

ways to develop a level of credibility. An undergraduate

degree in areas such as mathematics, finance, accounting,

business and economics can help give you a host of

knowledge, skills and importantly credibility, but so can

being formally recognised through reputable training

programmes as well as taking part in work experience

and racking up positive references. Notably, people often

move internally into a credit role if they demonstrate the

required traits to be good at it, and then study CICM to

develop and cement their practical experience with an

industry recognised qualification. Credibility is not only

portrayed through the achievements on a person’s CV,

but more importantly in the way they approach their

day-to-day role, responsibilities and interactions in the

workplace.

At the end of the day, the criteria for being successful in

credit is complex and the focus should be on fostering

specific attributes rather than ticking an oversimplistic

degree or job experience box.

Author: Natascha Whitehead FCICM is Senior Business

Director at Hays specialising in credit management.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 43


HR MATTERS

AGE OF

PROHIBITION

Selling union lists and the practicalities of re-engaging

wayward staff.

BY GARETH EDWARDS

UNDER the Blacklist Regulations

it is unlawful to compile,

use or sell a list of people who

take part in trade union activities.

This known as a ‘prohibited

list’.

In Morais and Others v Ryanair DAC and Another, the

Court of Appeal considered whether workers who

take part in official strikes are protected from being

unfairly treated by their employer. The case involved a

group of pilots who participated in a strike organised

by their union, the British Airline Pilots' Association.

After the strike, Ryanair withdrew certain travel

benefits from the pilots, claiming they were not

entitled to these benefits due to their participation in

the strike.

The pilots argued that the withdrawal of their

travel benefits was a detriment resulting from their

participation in the strike and that by singling out

those who had taken part in strike action Ryanair had

created a 'prohibited list'.

At its appeal stages the case focused on whether

workers who take part in such strikes have legal

protection against actions like being blacklisted or

losing benefits.

The Court of Appeal ruled that workers are indeed

protected from such treatment under the Regulations

and this protection applies regardless of whether the

union followed all the formal procedures typically

required for a strike.

Ryanair argued that the pilots should not be protected

because the union’s strike action did not meet certain

procedural requirements, such as notifying the

company in advance.

The court rejected Ryanair's argument, ruling that

workers who participate in official union action,

like strikes, are protected from detriment under

the Regulations regardless of whether the union has

complied with all legal formalities.

The court made it clear that this protection is not

dependent on whether the strike action is legally

immune from claims against the union but rather

focuses on the fact that the workers were engaging in a

recognised union activity.

RYANAIR

ARGUED THAT

THE PILOTS

SHOULD NOT

BE PROTECTED

BECAUSE THE

UNION’S STRIKE

ACTION DID NOT

MEET CERTAIN

PROCEDURAL

REQUIREMENTS

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 44


CREDIT MANAGEMENT

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 45 continues on next page >


HR MATTERS

RE-ENGAGEMENT

FOLLOWING

UNFAIR DISMISSAL?

THE Employment Appeal Tribunal

(EAT) recently clarified the limits

of ordering re-engagement in

cases of unfair dismissal, focusing

on the practicalities of restoring

employment relationships and the

scope of tribunal powers.

When an Employment Tribunal (ET) upholds a complaint

of unfair dismissal, it can order remedies beyond financial

compensation. These include reinstatement, which

restores the employee to their previous role as though they

were never dismissed, or re-engagement, which places the

employee in a comparable role with the employer.

Reinstatement and re-engagement orders are relatively

rare, as tribunals must consider several factors before

granting such remedies, including the employee’s express

wish to return; whether re-engagement is practicable

for the employer; if the employee contributed to their

dismissal, whether re-engagement would be just; and

the practicability of re-engagement which hinges on

whether trust and confidence between the parties can

be restored.

In The British Council v Sellers, Mr Sellers, a longserving

employee, was dismissed for gross

misconduct following allegations of sexual

misconduct at a social event. The ET

found that the dismissal was unfair due

to a flawed investigation, which failed to

properly evaluate the evidence. It held

that the decision-maker’s belief in Sellers’

misconduct was unreasonably derived

from this flawed process.

way.

Despite this, the ET concluded that it was required to

determine whether Sellers had caused or contributed

to his dismissal. It made its own findings on the alleged

misconduct, an issue that had not been raised by the

employer and ordered re-engagement.

The EAT overturned the re-engagement order, finding

that the ET had made significant errors. It held that

tribunals are not required to assess whether an employee

contributed to their dismissal unless this is raised as a live

issue by the parties. By addressing this point unnecessarily,

the ET exceeded its remit and made findings on Sellers’

alleged conduct that were not part of the dispute.

The EAT also found that the ET had failed to

properly assess the practicability of reengagement.

Instead of focusing on whether

the British Council’s belief in Sellers’

misconduct was genuine and rationally

held, the ET scrutinised the quality of the

independent investigation. The EAT clarified

that practicability must be assessed from

the employer’s perspective. In this case, the

council’s belief that trust and confidence had

been irreparably damaged was both genuine

and rational, making re-engagement

impractical.

Author: Gareth Edwards is a partner

in the employment

team at VWV.

Following the unfair dismissal finding,

the British Council commissioned

an independent investigation which

upheld the original findings of gross

misconduct. At the remedy stage,

Sellers sought re-engagement. The

council opposed re-engagement,

arguing that it was impracticable

due to a genuine and rational loss of

trust and confidence, operational

restructuring, and disputes over Sellers’

continued residence in Council-provided

accommodation and failure to return artwork.

The council explicitly chose not to argue that

Sellers had contributed to his dismissal in any

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 46


BRANCH NEWS

UK ECONOMIC

OUTLOOK AND AGM

AGM Report: Sheffield and District Branch

BY PAULA UTTLEY FCICM

WHAT an outstanding

branch event – a fantastic

speaker in a grand

historic building, need I

say more? Well, I’m going

to have to, so please dear

reader, read on...

Sheffield & District Branch held this year’s AGM on 12

February in the Reception Room of the Grade II Listed

Cutlers Hall in Sheffield. Built in 1832 by the Company

of Cutlers of Hallamshire, on the site of the original hall

from 1638, Cutlers Hall is one of the finest livery halls on

the North of England. CICM members and guests ascended

the grand staircase and admired the stunning cutlery and

silverwork displays en route to the registration desk to sign

in before networking with other credit professionals over

refreshments and relaxing after a busy day.

Branch Chair, Jamie Thornton MCICM, opened the

meeting and welcomed everyone before handing over to the

meeting’s guest speaker, Paul Mount of Bank of England.

Paul introduced himself explaining that he joined the Bank

of England in 2019 as Deputy Agent for Yorkshire and the

Humber and that he represents the Bank in our region

and engages with businesses and public sector leaders to

understand the environment they face, and to explain the

policy stance and work of the Bank. With the assistance

of Jamie Thornton (‘next slide please Jamie’), Paul took us

through his presentation on the economic outlook. He first

clarified that the Bank’s mission is to promote the good

of the people of the UK by maintaining monetary and

financial stability. Paul talked about how the interest rate is

used to influence inflation and the Bank’s process for setting

the interest rate, which it last did just a few days prior. We

looked at the graph of the bank rate and inflation from 2001

to date (with the last inflation spike resembling Mount

Everest!) and then just the CPI since 2001, both actual and

short-term projection. So, what’s next for the base rate?

Paul shared with us some notes from the latest MPC Minutes

and also some commentary on risks from that meeting,

both upside and downside. Paul finished with a look at

the potential effects of US tariffs on the UK – watch this

space!

At the end of his presentation, Paul took questions from the

floor, and it did resemble an episode of BBC’s Question Time,

just minus the long-arm microphones. Many questions were

asked of Paul covering all topics from the time lags between

a change in the base rate and banking product interest rates,

to concerns about our local steel industry. Certainly, the

most amusing question asked to Paul was done in private

by the youngest member of the audience and that was ‘why

doesn’t the bank just print more money’!

With all questions addressed, Paul handed the meeting back

to Jamie who thanked Paul for his time and presentation.

Jamie announced that we would be moving on to the formal

AGM meeting, so non-members were given time for further

networking before taking their leave.

Jamie opened the AGM and dealt with the formalities of

apologies, approval of the 2024 AGM Minutes, approval

of the 2024 Branch Financial Report, nominations and

elections of Committee members for 2025 and then a review

of the 2024 branch events. As the winner of the third CICM

Sheffield & District Branch Student Prize - Rebecca Ross

- was unable to attend on the evening, it was noted that

the presentation would take place later that week. Many

congratulations to Rebecca for coming top in her CICM

Level 3 Diploma Mandatory Unit in 2024.

Many thanks to Paul Mount of Bank of England, Andrew

Walker of Sharp Consultancy and all attending members

and guests for making the evening a great success.

Author: Paula Uttley MCICM(Grad), Vice Chair & Treasurer

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 47


Looking for

your next

career move?

Part Time Accounts Receivable/

Credit Controller

Littlehampton, £27k - £31k pro rata

This position is a 12-month fixed term contract, to cover maternity

leave. We are looking for an organised credit professional to

start asap. The ideal candidate will have a varied skillset, with

experience in managing financial matters related to sales ledger,

including invoicing, debtor management, processing customer

payments and perform bank reconciliations. Ref: 4665824

Contact Kitty Ford on 0333 010 6339

or email kitty.ford@hays.com

Billings Assistant

Manchester City Centre, £27k + excellent company benefits

Working for a Manchester City Centre Law Firm and reporting

to the Billings Manager, you will work as part of a small Billings

team and be responsible for ensuring all invoices are created

accurately within agreed timeframes. Working closely with

partners and clients alike, you will provide assistance relating

to billings & invoice queries, providing speedy resolutions to

ensure cases are processed and closed. Ref: 2109MC

Contact Joanna Taylor-Coburn on 0161 926 8605

or joanna.taylor-Coburn@hays.com

Credit Control Administrator

Glasgow, £28k

This is a varied role that will include proactively managing

customer payments, maintaining accurate financial

records, allocation of receipts on the system and resolving

disputed queries. The ideal candidate will have the ability to

communicate clearly with others in both written and verbal

formats, and strong attention to detail.

Ref: 4666082

Contact John Crossan on 0141 212 3665

or email john.crossan@hays.com

Sole Charge Credit Control/AR

Guildford, 35k

As a skilled credit and receivable professional, you will be

responsible for ensuring that debt is monitored and collected,

in line with company terms. Duties will include raising invoices,

setting up new accounts, chasing payments, resolving queries,

and all the sales ledger administration, including allocating

payments and reconciling accounts. Hybrid working available.

Ref: 4664470

Contact Natascha Whitehead on 0777 078 6433

or natascha.whitehead@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.

hays.co.uk/credit-control-jobs


Legal Aid Biller (Civil/Crime department)

Central London, £40k - £45k

This role involves managing accurate and efficient billing for a

legal team, focusing on criminal/civil legal aid. The successful

candidate will work closely with barristers to improve billing

practices and debt recovery, while providing high-level

customer service. Candidates must have knowledge of

legal aid. Ref: 4662745

Contact Max Witek on 0203 465 0020

or email max.witek@hays.com

Legal Aid Credit Controller (Civil)

Central London, £40k - £45k

This role involves managing efficient credit control for a legal

team, focusing on debt collection and resolving queries.

The successful candidate will work closely with barristers to

improve billing practices and debt recovery, while providing

high-level customer service. Candidates must have knowledge

of legal aid. Ref: 4666165

Contact Max Witek on 0203 465 0020

or email max.witek@hays.com

Discover new

opportunities today

© Copyright Hays plc 2025. All rights are reserved. CM-00780

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 49


THE MANUFACTURING MOVEMENT:

Overcoming Challenges in a Time of Change

Manufacturing is at a crossroads. While negative

headlines often dominate the conversation, there are

also green shoots of optimism emerging within the

sector. Menzies and the CICM hosted a roundtable

discussion at the Principality Stadium in Cardiff,

bringing together key individuals in the industry

to discuss the challenges and potential solutions

shaping the future of manufacturing. Three key

themes emerged during the discussions: recruitment

and retention, supply chain challenges, and the

growing threat of fraud.

One of the most pressing concerns raised in the

roundtable was recruitment and the retention

of skilled staff. There has been a shortage of

skilled workers, which has become increasingly

evident as traditional career paths in construction

and engineering have become less sought after.

Many manufacturers struggle to replace an aging

workforce, with the retirement of experienced

employees leaving a significant skills gap.

Additionally, the impact of Brexit has meant that there

has been a decline in returning European workers,

intensifying staffing challenges.

Another significant concern was the decline of

apprenticeships. Many businesses have shifted

towards in-house training rather than relying on

external apprenticeship schemes, particularly

as training facilities in Wales remain few and

far between. Some firms even find themselves

sending trainees further afield for the required

skills development. This, combined with evolving

workplace expectations, has reshaped employment

trends. Employees are continuously prioritising worklife

balance over overtime and financial incentives,

making retention more challenging. In South Wales,

a lack of clear career pathways for young people has

led to lower retention rates among the 16-24 age

group. Roundtable participants agreed that to attract

and retain talent, manufacturers must strengthen their

employer branding by fostering social engagement

initiatives, offering flexible work policies, and providing

clear career progression opportunities.

Supply chain challenges were another key area

of discussion during the roundtable. The post-

Brexit landscape has increased reliance on

European suppliers, resulting in greater instability

and uncertainty. Many businesses are also more

dependent on China, which has therefore, led to an

increase in carbon footprints and disruptions due

to major holidays and logistical delays. Attendees

emphasised the additional supply chain risks posed

by public sector contracts, which require businesses

to conduct careful due diligence to mitigate

potential issues. In response to these uncertainties,

manufacturers are reassessing their supply chain

strategies to build greater adaptability and resilience.

Fraud and cybersecurity emerged as growing threats

within the manufacturing industry, as highlighted

by many roundtable participants. Businesses

are increasingly finding themselves targets of

highly developed phishing scams and AI-driven

cyberattacks, which inevitably leads to financial

losses and operational disruptions. Even with the

rising risks, cybersecurity awareness remains low

in countless organisations, making them vulnerable

to attacks. Roundtable participants agreed that in

order to combat these threats, manufacturing firms

must apply stringent security measures, educate their

employees on potential risks, and invest in advanced

cybersecurity technologies to safeguard sensitive

information.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 50


Despite the challenges discussed, there has been

significant developments within the manufacturing

sector. Young talent is entering the workforce,

bringing fresh ideas and enthusiasm. Many

businesses have successfully adapted to Brexitrelated

disruptions, demonstrating flexibility

and resilience in their supply chain strategies.

Companies that survived the repercussions of

COVID-19 have emerged stronger, with more

streamlined operations and improved efficiencies.

Collaboration across industries has also increased,

fostering knowledge-sharing and driving innovation.

The Welsh manufacturing sector continues to

operate well in exports, specifically in high-tech

industries. Additionally, emerging investments in

environmental, social, and governance (ESG)

initiatives, as well as advancements in science

and technology, are paving the way for remarkable

transformation. These developments indicate

a promising future for manufacturing, provided

businesses continue to embrace innovation and

adaptability.

Looking ahead, the manufacturing sector must

remain proactive in addressing its challenges

while capitalising on opportunities for growth. By

embracing technological advancements, redefining

recruitment strategies, and fostering a culture of

resilience, businesses can navigate the evolving

landscape successfully. The discussions at the

CICM roundtable underscored the importance of

collaboration, forward-thinking strategies, and a

commitment to continuous improvement. With the

right approach, the manufacturing industry can

thrive in an ever-changing economic environment.

This report is based on a roundtable event for

employers and credit professionals, chaired by the

CICM and hosted by accountancy firm Menzies LLP.

Menzies LLP’s Creditor Services team offers

complimentary support and advice to credit managers

and businesses of all sizes, across industry sectors.

Where possible, the firm’s experts provide practical

solutions for improving cash management and

operational resilience. Early management is key to

improving outcomes.

For further information on our creditor services

offering, please get in touch.

Giuseppe Parla

Director at Menzies LLP

gparla@menzies.co.uk

+44 (0)33 0912 9828

Visit www.menzies.co.uk/creditorservices for more.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 51


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Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 52

THE PENINSULA, VICTORIA PLACE, MANCHESTER M4 4FB


EXCLUSIVE PAYMENT TRENDS

STEADYING

THE SHIP

Late payment performance looks to be back on course.

BY ROB HOWARD

THE March edition of Payment

Trends teased choppy waters ahead,

with late payments on the rise

right across the board. The latest

figures, however, suggest a calmer

outlook, and a return to the right

course, with the majority of UK and

Irish regions and sectors improving. The average Days

Beyond Terms (DBT) across UK regions and sectors

reduced by 0.7 and 1.7 days respectively. In Ireland, the

average figures dropped by 1.5 days across both regions

and sectors. Average DBT across the four provinces of

Ireland decreased by 0.1 days.

Sector spotlight

The UK sector standings are full of positives, with three

quarters (16) of the 22 sectors making reductions to DBT.

The Real Estate sector made the biggest stride forward

and moves well clear of the bottom of the standings,

with a reduction of 10.5 days taking its overall DBT

to 9.3 days. The Health and Social sector also moved

away from the lower reaches of the table, cutting 8.5

days off its tally to take overall DBT to 8.2 days. A cut

of 5.0 days means the Business from Home sector has

leapfrogged the International Bodies sector to become

the best performing UK sector with an overall DBT of

5.4 days. Of the six sectors that saw increases in late

payments, the Financial and Insurance (+7.6 days) and

Hospitality (+4.1) sectors drop into the bottom five

worst performing sectors, now with an overall DBT of

13.8 and 14.3 days respectively.

Regional spotlight

Some eight of the 11 regions across the UK made

improvements to late payment performance, although

the vast majority of these were steady rather than

spectacular. The South West of England made the biggest

improvement (-2.9 days), meanwhile a reduction of 2.7

days for the South East take it to the summit of the UK

standings with an overall DBT of 9.9 days. Yorkshire

and Humberside is on the up too (-1.5 days), now the

second-best performing UK region with an overall DBT

of 10.5 days.

Performance across Irish counties is more of a split,

but still with the positives outweighing the negative,

with 16 of the 26 counties cutting their DBT. Of the 10

counties going backwards, Donegal (+12.8 days), Laois

(+10.9 days) and Longford (+7.9 days) took the biggest

hits. Focusing on the positives, a number of counties

– Tipperary (-8.8 days), Wexford (-8.6 days), Sligo

(-8.6 days) and Carlow (-7.4 days) took positive steps

forward. Meanwhile, a reduction of 7.5 days means that

county Leitrim is now the best performing Irish

county with an overall DBT of zero days.

Three of the four Irish provinces were moving

in the right direction, with Ulster (+7.3 days)

the only exception. Munster takes over as

the best performing province, with a

reduction of 3.4 days taking its overall

DBT to 7.3 days.

The outlook across Irish sectors is similarly positive,

with 14 of the 20 sectors making improvements,

three seeing no change and only three sectors seeing

increases to DBT. The Transportation and Storage

sector made the biggest improvement, reducing its

DBT by 10.0 days to take its overall tally to 7.0 days.

Elsewhere, the Manufacturing (-5.7 days), Education

(-4.5 days) and Construction (-4.3 days) sectors all

made gains. Meanwhile, a cut of 3.4 days for the Mining

and Quarrying sector means it joins the International

Bodies sector at the top of the standings with an overall

DBT of zero days. The Irish Real Estate sector, however,

is on the slide, with an increase of 9.1 days taking its

overall DBT to 17.1 days.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 53


*

STATISTICS

Data supplied by the Creditsafe Group

Top Five Prompter Payers

Region (UK) Feb 25 Changes from Jan 25

South East 9.9 -2.7

Yorkshire and Humberside 10.5 -1.5

London 10.7 0.2

East Midlands 10.8 -1

Scotland 10.8 0.8

Bottom Five Poorest Payers

Region (UK) Feb 25 Changes from Jan 25

Northern Ireland 14.6 -0.2

East Anglia 12.7 -1

North West 12.2 -0.6

West Midlands 11.8 2.2

South West 11.7 -2.9

Getting worse

Financial and Insurance 7.6

Hospitality 4.1

Professional and Scientific 3.7

Other Service 3.6

International Bodies 2

Business Admin & Support 0.6

Getting better

Real Estate -10.5

Top Five Prompter Payers

Sector (UK) Feb 25 Changes from Jan 25

Business from Home 5.4 -5

International Bodies 5.8 2

Agriculture, Forestry and Fishing 6.2 -4.6

Public Administration 6.8 -5.4

Entertainment 7.4 -1.5

Bottom Five Poorest Payers

Sector (UK) Feb 25 Changes from Jan 25

Hospitality 14.3 4.1

Financial and Insurance 13.8 7.6

Energy Supply 12.1 -1.9

Business Admin & Support 12.0 0.6

Manufacturing 12.0 -6.6

Health & Social -8.5

Dormant -7.2

Manufacturing -6.6

Public Administration -5.4

Business from Home -5

Agriculture, Forestry and Fishing -4.6

IT and Comms -2.3

Energy Supply -1.9

Mining and Quarrying -1.8

Wholesale and retail trade; repair of

motor vehicles and motorcycles -1.7

Entertainment -1.5

Education -0.8

SCOTLAND

0.8 DBT

Water & Waste -0.5

Transportation and Storage -0.2

NORTHERN

IRELAND

-0.2 DBT

SOUTH

WEST

-2.9 DBT

WALES

-1.1 DBT

NORTH

WEST

-0.6 DBT

WEST

MIDLANDS

-1.0 DBT

YORKSHIRE &

HUMBERSIDE

-1.5 DBT

EAST

MIDLANDS

-1.0 DBT

LONDON

0.2 DBT

SOUTH

EAST

-2.7 DBT

EAST

ANGLIA

-1.0 DBT

Construction -0.2

Region

Getting Better – Getting Worse

-2.9

-2.7

-1.5

-1.1

-1.0

-1.0

-0.6

-0.2

2.2

0.8

0.2

South West

South East

Yorkshire and Humberside

Wales

East Anglia

East Midlands

North West

Northern Ireland

West Midlands

Scotland

London

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 54


EXCLUSIVE PAYMENT TRENDS

Getting worse

CONNAUGHT

-2.6 DBT

SLIGO

-8.6 DBT

LEITRIM

-7.5 DBT

MONAGHAN

2.4 DBT

Real Estate 9.1

IT and Comms 2.9

Professional and Scientific 1.4

LIMERICK

-1.8 DBT

LAOIS

10.9 DBT

LOUTH

1.4 DBT

MUNSTER

-3.4 DBT

CLARE

-5.3 DBT

ROSCOMMON

0.1 DBT

WATERFORD

1.7 DBT

WICKLOW

xx DBT

Getting better

Transportation and Storage -10

Top Five Prompter Payers – Ireland

Region Feb 25 Changes from Jan 25

LEITRIM 0.0 -7.5

SLIGO 3.5 -8.6

LIMERICK 3.6 -1.8

CLARE 4.9 -5.3

TIPPERARY 5.6 -8.8

Bottom Five Poorest Payers – Ireland

Region Feb 25 Changes from Jan 25

WATERFORD 22.5 1.7

ROSCOMMON 22.1 0.1

LAOIS 21.5 10.9

MONAGHAN 18.4 2.4

LOUTH 17.4 1.4

Top Four Prompter Payers – Irish Provinces

Region Feb 25 Changes from Jan 25

MUNSTER 7.3 -3.4

LEINSTER 10.5 -1.9

CONNACHT 12.4 -2.6

ULSTER 16.5 7.3

Manufacturing -5.7

Education -4.5

Construction -4.3

Mining and Quarrying -3.4

Business Admin & Support -3.3

Agriculture, Forestry and Fishing -3.2

Entertainment -1.6

Public Administration -1.6

Wholesale and retail trade; repair of

motor vehicles and motorcycles -1.3

Health & Social -1.2

Other Service -1

Financial and Insurance -1

Energy Supply -1

Top Five Prompter Payers – Ireland

Sector Feb 25 Changes from Jan 25

International Bodies 0.0 0

Mining and Quarrying 0.0 -3.4

Entertainment 3.4 -1.6

Other Service 5.7 -1

Financial and Insurance 6.5 -1

Bottom Five Poorest Payers – Ireland

Sector Feb 25 Changes from Jan 25

Water & Waste 27.0 0

Professional and Scientific 18.1 1.4

Real Estate 17.1 9.1

IT and Comms 16.8 2.9

Wholesale and retail trade; repair of

motor vehicles and motorcycles 11.5 -1.3

Nothing changed

Hospitality 0

International Bodies 0

Water & Waste 0

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 55


*

International Trade

Monthly round-up of the latest stories

in global trade by Andrea Kirkby.

'GLOBAL GROWTH TEAM'

TO further the UK’s export prospects,

the Government, at the end of January

appointed a new ‘global growth team’ of

UK Trade Envoys ‘to drive UK exports and

investment’ as the Government pulls every

lever available to drive economic growth

under its Plan for Change.

Judging from the list of the 32

parliamentarians, they’ve been drawn

from across the political spectrum, with

each having been assigned target markets

around the globe and have been told to

identify trade and investment opportunities

for businesses while ‘championing the UK

as a destination of choice for investment in

those markets’.

The envoys have reportedly been

appointed on their ability, relevant skills

and experience which can be based on

their respective markets or UK sector

knowledge, including previous Governmentto-Government

experience, as well as their

commitment to the UK’s growth mission.

Looking at the appointments made

you’ve got to wonder how participants felt

when some had been given Australia or

Switzerland, but others had been handed

locations that appear less glamorous.

More importantly, will they deliver?

UK digital trade deal with the US?

ACCORDING to Business Matters, the UK

Government is seeking a deal with the US

over digital trade – all at a time of rising

global trade tensions.

Apparently, UK Government insiders think

that the prime minister has already raised

trade issues with President Trump, who in

turn has hinted a deal can be ‘worked out’

while claiming he and the prime minister are

‘getting along very well’.

Similarly, some in the US think that an

agreement of sorts could be achieved within

months, particularly if negotiations focus

on technology, digital trade and services –

the areas seen as most promising for UK

exporters.

British exports to America hit £182.6bn

in the year to November 2024, with services

accounting for 69%. It’s thought that the

digital trade agreement the UK signed with

Singapore in 2022 could act as a possible

blueprint – it streamlined regulations for

professional and financial services, law

firms, banks and tech companies.

There are, however, two sticking points:

the UK’s digital services tax. It yields

nearly £700m in tax by targeting revenue

generated by the likes of Google and Meta.

It’s possible that it may be reviewed if a

deal becomes possible; and the UK having

to choose between the US and the EU if a

trade war fully begins.

The UK is the world’s second-largest

services exporter, and since leaving the

EU, its services exports have thrived while

goods trade has lagged behind comparable

nations.

RESIGNATION OVER

LABOUR’S ‘ANTI-

BUSINESS POLICIES’

JUST as the Government created

new export roles, so another became

vacant as Mark Stewart, Chief Executive

of Gloucester-based Stewart Golf,

resigned from his role as an ‘export

champion’, which The Times said was

due to frustration with what he calls

Labour’s ‘anti-business policies’ under

Sir Keir Starmer and Rachel Reeves.

The company manufactures electric

golf buggies and exports half of its £7m

turnover to the US.

His departure came after returning

from a trip to the US where he says that

the contrast in attitudes to business

could not be starker. “I can’t be part

of this. Every turn, there’s something

that makes life more difficult for people

trying to run small businesses like

mine. I don’t feel we’re being supported

or encouraged even to try and be

better.”

He pointed specifically to Labour’s

rhetoric as undermining British

optimism, referencing the shadow

chancellor’s comments about aspiring

to ‘American-style optimism’ during a

trip on China’s bullet train. “Between

you and the boss [Starmer], all you’ve

done is talk down the UK,” Stewart said.

Stewart also expressed dismay

at Government plans for stricter

employment rights and what he sees

as punitive taxes on business assets

passed between family members,

echoing widespread disquiet among

SMEs.

The entrepreneur was one of about

400 ‘export champions’ appointed by

the Department for Business and Trade.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 56


Go to India for export growth

MONEYWEEK has highlighted that

India is on the cusp of greatness and so

should be target for any exporter looking

to grow.

However, India’s stockmarket has

slowed with concerns about the country’s

economy. This is a problem considering

that between 2020 and 2023, it delivered

a total gain of 90%.

That said, the country is one to watch

since its economy is on course to become

the world’s third largest, possibly as soon

as 2027. Then there’s the rising number

of working-age Indians. On top of that are

the middle classes that have been growing

at an average rate of 6% a year over the

past 30 years. Higher disposable incomes

clearly help spending.

Some think that India is where China

was in the 1990s and the 2000s; it’s

manufacturing could seriously take off if

the Indian Government’s target of reaching

$1tn-worth of goods exports by 2030 is

met.

Further, there’s infrastructure spending

– India has built 75 new airports in the past

five years alone and set up more than 20

metro rail projects. It now plans to invest a

further $1.4tn over the next five years and

will invest billions more in the country’s

renewable energy capacity.

So, what does this tell us?

Widening bespoke export support

RESEARCH from the FSB, Ready to

Dispatch, has found that over a third of

UK non-exporting SMEs would consider

selling to overseas markets in future, with

the smallest businesses showing greater

interest in international trade.

The body thinks that ‘boosting SME

exports must be a central part of the

Government’s new growth plan’.

The report found that 35% of nonexporting

small firms would consider

doing so in future. Some 38% of nonexporting

microbusinesses (with

under 10 employees) said they would

consider exporting, compared to 20% of

businesses with 10-49 employees.

The most beneficial tool to help small

exporters explore new markets is general

information on how to start exporting

(41%), followed by target market

information (37%) and financial support

for specific activities such as tradeshows,

translation (34%).

Bespoke Government export

support allows free access to UK-based

International Trade Advisors and in-market

trade advisors to help businesses develop

their own export strategy.

The current turnover threshold of such

services is set at £500,000. However,

61% of small employers and 91% of sole

traders had a turnover of below £500,000

and so have no access.

HIGH LOW TREND

GBP/EUR 1.21283 1.18357 DOWN

GBP/USD 1.30042 1.25624 UP

GBP/CHF 1.15009 1.12967 UP

GBP/AUD 2.06227 1.97601 UP

GBP/CAD 1.87673 1.78483 UP

GBP/JPY 194.791 188.111 UP

FSB therefore suggests the Government

reduce the turnover threshold of one-toone

export support to £400,000

and develop new tailored services for

start-ups to encourage more small firms

to trade internationally or consider it from

day one.

For the latest

exchange rates visit

www.currenciesdirect.com

or call 020 7874 9400

Currency Exchange Rates

This data was taken on 18th

March and refers to the month

previousto/leading up to 17th

March2025

CREDIT MANAGEMENT

LOOK OUT FOR

GOVERNMENT EXPORT

CONFERENCES

EARLY February the Government’s

trade body, UK Export Finance (UKEF),

held what it described as its largest

ever national conference, promoting

SME growth.

At the event some 1,000 business

leaders – including directors from CBI

and British Chambers of Commerce –

came together to help UK businesses

access international opportunities. The

event, the UK Trade and Export Finance

Forum, sought to discuss ways of

reducing financial barriers to exporting.

The majority of businesses seeking

UKEF support and attending the

conference were reported to be small

and medium-sized enterprises.

While the conference has been

and gone the point is that firms

interested in export and export-related

opportunities should keep an eye on

the UKEF website at ukexportfinance.

gov.uk for more events. The site also

has links to products and services that

it offers.

REPORTING SUSPECTED

BREACHES OF TRADE

SANCTIONS

THE Government has updated its

page on trade sanctions breaches –

breaches that may lead to enforcement

action, possible criminal prosecution or

a civil monetary penalty.

The page details how to report

a suspected breach, who to report

to – the Office of Trade Sanctions

Implementation or HMRC depending

on the matter in hand, and how to

report. There’s also detail on how

information may be shared, legal

privilege, and other obligations to be

noted.

The page is on gov.uk under ‘Report

a suspected breach of trade sanctions’.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 57


Another benefit

for CICM Members

Download and view your digital

membership card via the Folio app today!

Download the app for your iOS or Android operating system


ENFORCEMENT

CONSTRUCTIVE

PROGRESS

Engaging with the enforcement sector will deliver better

outcomes for Government and regulators as they look to shape

the future of the enforcement profession.

BY ALAN J. SMITH FCICM

LAST month, the HCEOA responded to the

Enforcement Conduct Board’s consultation

on its 2025-26 Business Plan. We didn’t

agree with absolutely every detail the ECB

is proposing, but we’re supportive of the

overall direction the organisation is taking.

What’s really important, however, is the fact that the consultation

took place in the first place. The ECB has consulted on its

draft business plan every year since its formation. It does so

in a transparent, genuine and straightforward fashion. Our

experience is that (on this and its other consultations so far) the

ECB also listens to feedback and welcomes detailed observations

that will help it achieve its objectives.

This in turn, gives the signal to consultees like the Association

that it is worth investing the time and energy to respond in

detail as it is a genuine opportunity to provide guidance for

the ECB’s next steps. The same cannot always be said for every

consultation I have been involved in responding to over the years,

but things seem to be moving forward in a positive manner.

In the past two years, we’ve responded to consultations from

the Ministry of Justice, the ECB and the Civil Justice Council.

There are a number of threads that link all of them, but two

stand out.

1) A shared focus on delivering better outcomes for everyone

involved in enforcement – debtors, creditors and the

enforcement sector – is something we characterise as a ‘fair

and effective’ enforcement service.

2) The devil is in the detail – and by that, I don’t mean that

these organisations are trying to sneak changes through in

a consultation!

There is a high degree of consensus amongst lots of the

stakeholders that I speak to and engage with – including

many in the debt advice sector as well as in Government – on

common objectives, e.g.

i) Increasing settlements at the compliance stage,

ii) Ensuring compliance with National Standards,

iii) Ensuring vulnerable debtors are identified and treated

appropriately, and

iv) The need to improve the information and guidance

that debtors currently receive. (This information is mainly

communicated through the Notice of Enforcement, which is

a prescribed document that our members must use).

It’s when it comes to detailing changes and laying out the specific

proposals and wording that the challenges come in. The phrase

‘unintended consequences’ can very quickly become very relevant.

From a High Court perspective, it is inevitably those of us

involved in enforcing Writs of Control who have the most

knowledge of the nuances of the law and the current system.

That means we are well placed to identify problems with

proposed solutions and suggest alternatives that achieve the

agreed objectives without adding unnecessary extra costs – which

will ultimately have to be funded by debtors or the taxpayer

– and that are deliverable without running into operational

roadblocks or legal minefields.

Our members are happy to share this expertise – for many of

us it is decades in the making. But it makes such a difference

when you feel that you are being listened to and appreciated

by decision-makers.

At the time of writing, we are still awaiting news from the new

Government on increasing enforcement fees. These have now

been frozen for 11 years and devalued in real terms by about 25%.

In 2023, Government also consulted on a wide range of reforms

it was considering introducing across the enforcement sector.

We, along with many others, responded in detail to this range

of proposals, and it’s fair to say that the sector is waiting for the

detailed outcomes and next steps with great interest.

Nearly all of the principles and objectives behind that

consultation were ones that would attract widespread support,

but reforms have to be deliverable and have to be affordable.

With regards to the ECB, a key focus for it this year is the

development of new standards around ‘vulnerability’ and

‘ability to pay’. It’s no small task, and the ECB has promised

to consult widely.

We’re looking forward to playing our part in a constructive and

interesting discussion that can deliver better outcomes for all.

Alan J. Smith FCICM, is Chair of the High Court Enforcement

Officers Association.

Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 59


CreditWho?

CICM Directory of Services

COLLECTIONS

COLLECTIONS LEGAL

CREDIT DATA AND ANALYTICS

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.

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: customerservice@cocredo.com

W: www.cocredo.co.uk

For over 20 years, CoCredo, winner of the CICM British Credit

Awards 'Technology Development Award 2025', 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, Ireland 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 over 90% 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.

Dun & Bradstreet

T: 0808 239 7001

E: hello@dnb.com

W: www.dnb.co.uk

At Dun & Bradstreet, we have a standardised risk approach to

help make confident, timely, and accurate lending and credit

decisions. We help businesses access up-to-date and timely

data on hundreds of millions of global businesses. And we

don’t limit how often you’re able to run checks on businesses in

your portfolio. So, you can be sure you always have the latest

information on the companies you choose to do business with

– whether micro businesses run by a single person right up to

large, international enterprises.

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 SOFT-

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.


FOR ADVERTISING INFORMATION OPTIONS

AND PRICING CONTACT

paul.heitzman@cplone.co.uk – 01727 739 196

CREDIT MANAGEMENT SOFTWARE SOFT-

CREDIT MANAGEMENT SOFTWARE SOFT-

ENFORCEMENT

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.

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.

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.

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.

DEBT & ASSET RECOVERY SERVICE

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.

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

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.

STA International

T: 01622 600 921

E: sales@staonline.com

W: www.stainternational.com

STA International is a trusted leader in credit management,

providing expert solutions in global debt recovery, outsourced

credit control, address tracing, and legal debt recovery. For

over 30 years, we’ve helped businesses of all sizes maximise

cash flow, minimise risk, and recover outstanding debts

efficiently.

We act as extension of your credit control team, using

technology, knowledge, and an effective ethical approach

to your debt recovery. Our bespoke processes ensure that

collections are dealt with professionally and amicably, helping to

protect your reputation and relationships while achieving results

that improve your cash flow.

Our activities on individual cases and overall performance stats

can be accessed 24/7 on our market-leading client reporting

platform, Your Debts Online. At STA International, we don’t

just recover debt; we support businesses to create healthy

financial positions while fostering better long-term customer

relationships.

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.

FINANCIAL PR

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.


CreditWho?

CICM Directory of Services

FOR ADVERTISING INFORMATION

OPTIONS AND PRICING CONTACT

paul.heitzman@cplone.co.uk

INSOLVENCY

PAYMENT SOLUTIONS

RECRUITMENT

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 LLP

T: +44 (0)2073 875 868 - London

T: +44 (0)2920 495 444 - Cardiff

W: Menzies LLP.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 LLP Creditor

Services team can assist, please contact Bethan Evans,

Licensed Insolvency Practitioner, at bevans@Menzies LLP.

co.uk or call +44 (0)2920 447 512.

Key IVR

T: +44 (0) 1302 513 000 Opt 3 E: partners@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.

Bottomline Technologies

115 Chatham Street, Reading

Berks RG1 7JX | UK

T: 0870 081 8250 E: emea-info@bottomline.com

W: www.bottomline.com/uk

Bottomline Technologies (NASDAQ: EPAY) helps businesses

pay and get paid. Businesses and banks rely on Bottomline for

domestic and international payments, effective cash management

tools, automated workflows for payment processing and bill

review and state of the art fraud detection, behavioural analytics

and regulatory compliance. Businesses around the world depend

on Bottomline solutions to help them pay and get paid, including

some of the world’s largest systemic banks, private and publicly

traded companies and Insurers. Every day, we help our customers

by making complex business payments simple, secure and

seamless.

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.

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.

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.

DCS

T: 01656 663 930

E: Jason@creditpro.co.uk

W: www.dcscreditjobs.co.uk

DCS is a specialist Credit Management Recruitment

Company with over 18 years of experience, supplying

Credit Professionals at all levels.

We supply high calibre candidates to our clients within the

FinTech, Credit, Collections, Enforcement and Legal Industry.

We also cover many different sectors listed below

Utilities Gas / Electric / Water / Collections

International Collections & Credit Insurance

DCA Collections, Legal, Enforcement & Asset Recovery

Credit Information, Credit Management Software, Data &

Analytics, Invoice Factoring and Invoice Discounting,

Insolvency, Payment Solutions, Parking, Banking.

CreditWho?

CICM Directory of Services

For advertising information

options and pricing contact

paul.heitzman@cplone.co.uk 01727 739 196


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Brave | Curious | Resilient / www.cicm.com /April 2025 / PAGE 63


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