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Credit Management magazine June 2025

THE CICM MAGAZINE FOR CONSUMER AND COMMERCIAL CREDIT PROFESSIONALS

THE CICM MAGAZINE FOR CONSUMER AND COMMERCIAL CREDIT PROFESSIONALS

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CREDIT MANAGEMENT

CM

THE CICM MAGAZINE FOR CONSUMER AND

COMMERCIAL CREDIT PROFESSIONALS

JUNE ISSUE 2025

Red Flag

The FCA gets serious

on financial crime

CONSUMER

More needs to be

done to support

mental health.

PAGE 12

INTERVIEW

Father and son

elected to the

Advisory Council.

PAGE 24

ENFORCEMENT

Fee increases are

inappropriate and

unjustifiable.

PAGE 22


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SEAN FEAST FCICM

MANAGING EDITOR

Editor’s column

DOES CONSUMER

DUTY DESERVE

THE CREDIT?

FIGURES published a few weeks ago

by the Financial Conduct Authority

(FCA) show that complaints against

firms in the regulated consumer

finance space have fallen overall by

more than 4% (H2 2024 compared to

H1).

Banking and credit card complaints fell by 1.3%, with

decumulation and pensions down by 4.2% and home

finance complaints 10% lower at 83,936. There were also

decreases in the three most-often complained about

products: current accounts by 0.3%; motor and transport

by 8.0%; and credit cards by 2.4%.

The good news continues into the consumer collections

space. Speaking to Chris Leslie, Chief Executive of the

Credit Services Association, he welcomes the news as

well as the fact that only relatively few complaints about

the collections sector are ending up with the Financial

Ombudsman Service, and with a complaint ‘uphold’ rate

of just 24% this is significantly better than the average

for the rest of complaints against financial services firms

generally (see news special page 6).

Much smarter people than me attribute the fall to

the success of the FCA’s Consumer Duty initiative.

Sue Chapple, the CICM’s Chief Executive, says that

Consumer Duty has changed the way that creditors and

debt collectors do business. She stops short of attributing

all the success to the FCA’s actions but acknowledges

that they are taking ‘a step in the right direction’.

Many of the complaints registered against firms like

Lowell and Cabot involved in debt sale and purchase,

for example, will be around the fact that the debt has

been sold in the first place, rather than there has been

any consumer detriment, and that probably counts for

the comparatively low number of complaints that are

upheld.

Instinct tells me that Consumer Duty may all have

something to do with it, but that one swallow doesn’t

make a summer, and one six-month falls does not make a

trend. Chris agrees. He says it is still too early to tell. He

also, most interestingly, says that Consumer Duty could

equally be a source of new complaints in the years ahead

if these broader, less-definitive duties generate a broader

range of less rule-specific complaints. So let’s wait

and see.

But given the falling number of complaints that are

upheld, perhaps the FCA could be looking at the issue

from another angle. Could making it more difficult

to complain, rather than easier and openly inviting

complaints, actually make it better for those who are

vulnerable or have a genuine grievance? Or will the

vulnerable be even less inclined to complain – and

therefore increase their vulnerability – if they are greeted

with something they see as an impenetrable roadblock?

Reducing the volume of complaints would certainly be a

good thing for everyone. Every complaint received adds

a cost to the recipient, consuming time and resource

that could be better deployed. The higher the volume of

complaints, the more difficult it also becomes to discern

the ‘genuine’ cases who deserve focus from those that are

nefarious or mischievous in nature or are being made to

shift blame or responsibility.

Perhaps it’s time for a more radical rethink before

anyone starts patting themselves on the back. It’s a

tricky one. The best measure of real progress is surely

the percentage of complaints that are upheld, rather

than the volume received. A fall in complaints does not

necessarily suggest the consumer is getting a better deal.

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


contents

JUNE 2025 issue

11 – RESTRUCTURING PLANS

What are they and what impact can they have

on creditors?

12 – MIND GAMES

How can the credit industry respond and fulfil

its responsibilities to its vulnerable customers?

16 – CUTTING IT FINE

FCA fines – are your controls up to scratch?

22 – TRANSFER FEE

A fair fee for enforcement is long overdue.

24 – INTERVIEW

Sean Feast FCICM speaks to two members

of the Advisory Council with a family

connection.

31 – ROUGH JUSTICE

The wrong increase at the wrong time.

32 – COUNTRY FOCUS

There is more to Saudi Arabia than sand

and oil.

38 – REMEDIAL ACTION

Why backing the Civil Justice Council’s

Enforcement Report matters.

40 – RAIN OR SHINE

The challenges of speculating, age, and

umbrella companies.

42 – IN REAL-LIFE

How to make industry events worth

your while.

44 – FUNDING LINES

Litigation funding: to regulate

or not to regulate?

52 – THE WALLS OF JERICHO

Is the construction industry on the brink

or are statistics misleading?

16

CUTTING IT FINE

How can the credit

industry respond to

vulnerability?

11

INSOLVENCY

What are they and what impact

can they have on creditors?

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


24

INTERVIEW

CICM GOVERNANCE

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 FCICM(Grad)

Natalie Bunyer FCICM / Glen Bullivant FCICM

Alan Church FCICM(Grad) / Larry Coltman FCICM

Peter Gent FCICM(Grad) / Tom Hope MCICM

Neil Jinks FCICM / Martin Kirby FCICM

Charles Mayhew FCICM / Joshua Mayhew MCICM

Hans Meijer FCICM / 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

32

COUNTRY FOCUS

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.

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


THE NEWS

CMNEWS

A round-up of news stories from the

world of consumer and commercial credit.

WRITTEN BY: SEAN FEAST FCICM

FCA fall in complaints down

to success of Consumer Duty

LATEST figures from

the Financial Conduct

Authority (FCA) show

that complaints in the

regulated consumer

finance space fell in

the second half of 2024,

which experts in part attribute to the success

of the FCA’s Consumer Duty initiative

which mandates that firms prioritise

customer needs in their operations.

In H2 2024, financial services firms

received 1.78m complaints, a 4.3% decrease

from H1. Since 2021, complaints have stayed

relatively constant between 1.7m and 2.0m.

All product groups saw a decrease in

their complaint numbers in H2: banking

and credit card complaints fell by 1.3%,

with decumulation and pensions down

by 4.2% and home finance complaints 10%

lower at 83,936. There were also decreases

in the three most-often complained about

products: current accounts by 0.3%; motor

and transport by 8.0%; and credit cards by

2.4%.

The percentage of complaints that were

upheld by firms remained around 57%

between H1 and H2 2024. In H2 2024 the

total amount of redress was £236m. This is

a 3.0% decrease on the H1 figure of £243m.

In terms of specifics, the most complained

about firms in the consumer credit space

were Black Horse (Lloyds Banking Group)

with just short of 261,000 complaints of

which almost half (48%) were upheld;

First Rand Bank (the largest financial

institution by market capitalisation in

Africa whose portfolio in the UK includes

Aldermore) with approximately 136,000

complaints with only 10% upheld; and

BMW Financial Services with around

142,000 complaints and only 13% upheld.

Analysis of the tables shows that there

were more than 73,000 complaints made

against Close Brothers, 50,000 against

Clydesdale Financial Services, 44,000

against RCI Financial Services, 31,000

against PayPal and 21,000 against Mercedes

Benz Financial Services.

Darren Richards, Head of Insurance,

Regulatory and Risk at independent

financial services consultancy Broadstone,

says he is pleased to see complaints falling:

“While the drop is a small one for now,

it nonetheless marks a step in the right

direction and suggests that initiatives

like Consumer Duty are starting to pay

dividends. Markets remain volatile and

consumer confidence shaky, so financial

services firms need to retain a laser focus

on ensuring they are looking after the longterm

financial interests of their customers

throughout their interactions.”

Hugh Fairclough, Partner and Head

of Financial Services at RSM UK agrees:

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


“The decreasing complaints seen across all

financial services products is good news and

suggests that measures to improve outcomes

for customers introduced by Consumer

Duty are having a positive impact. Many

firms have improved their customer service

practices in response, which may now

be coming through in today’s H2 2024

complaints data.”

Within the collections space specifically,

and in detail, Lowell Financial Limited

received 8,028 complaints with 26.25%

upheld; Cabot Credit Management received

6,159 complains with 18.54% upheld;

PRA Group UK Limited received 1,977

complaints with 19.41% upheld; and Wescot

Credit Services Limited received 1,823

complaints with 22.4% upheld.

Capquest Debt Recovery (Intrum Group)

had a low number of complaints (803) but

a high number were upheld (55.18%), so too

Moorcroft Debt Recovery Limited (578 and

46.06% respectively). Also on the list were

Lantern Debt Recovery (1,135 complaints

with 21.84% upheld).

Sue Chapple FCICM, Chief Executive

of the Chartered Institute of Credit

Management, believes that while there are

a number of features that will impact the

complaints, Consumer Duty has changed

the way that creditors and debt collectors

do business: “While one set of figures does

not necessarily indicate a trend, it’s certainly

a step in the right direction,” she says.

“Of the firms that are complained against

in the collections sector, for example, many

are from the world of debt purchase and

doubtless many of the complaints will be

around the fact that the debt has been sold

in the first place, rather than there has been

any consumer detriment, and that probably

counts for the low number of complaints

that are upheld.

“It’s also interesting to note,” she

continues, “that Trust Pilot and Google

ratings of collections firms have shifted

upwards significantly, and that also speaks

to an industry whose leaders – many of

whom are members of the CICM – are

taking huge strides in treating customers

fairly.”

Chris Leslie, Chief Executive of the Credit

Services Association (CSA), told Credit

Management: “It’s positive that relatively few

complaints about the collections sector are

ending up with the Financial Ombudsman

Service, and with a complaint ‘uphold’ rate

of just 24% this is significantly better than

the average 34% for the rest of complaints

against financial services firms generally.

These numbers tally broadly with our own

experience adjudicating complaints from

the public about members of the CSA and

compliance with our Code of Practice. And

the FCA’s complaints data seems to tell a

similar story.

“While the

drop is a small

one for now,

it nonetheless

marks a step

in the right

direction and

suggests that

initiatives like

Consumer Duty

are starting to

pay dividends.’’

“Perhaps there are a variety of reasons

for this,” he continues, “including the

continued professional development of the

collections sector, the general economic

climate and of course the activities of

third-party complaints management

companies who often target different

sectors at different times. While the advent

of the FCA’s Consumer Duty has helped

reinforce good practices across all parts of

the regulated financial services sector, it

is still quite early days to know if this is a

cause for lower complaints. It could equally

be a source of new complaints in the years

ahead if these broader, less-definitive duties

generate a broader range of less rule-specific

complaints. On this I think the jury is still

out.”

Other notable firms on the list include

Experian who received 11,397 complaints

with 16.97% upheld; Transunion

International UK Limited (2,285 and

21.92%); and Equifax Limited (2,117 and

37.48%).

While motor finance firms tended to

do badly, they also registered some of the

better successes. Toyota Financial Services

UK received 27,267 complaints with only

4.83% upheld; and Hyundai Capital Uk

Limited received 13,329 complaints with

only 5.48% upheld.

Commenting on the figures, a Black Horse

spokesperson told Credit Management: “We

want to provide the best possible experience

for our customers. However, if something

doesn’t go as well as it should, we work hard

to address it as quickly and sensitively as

possible and look to resolve the root cause

of any issue."

BMW declined to comment.

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

CREDIT MANAGEMENT

Trade deal

ALLIANZ Trade in Asia Pacific has

appointed Rodrigo Jimenez as Asia

Pacific Regional CEO to succeed Paul

Flanagan who is retiring after 34-years

with the business. Rodrigo will assume

his new responsibilities in October,

subject to standard regulatory approval

requirements. Joining Allianz Trade

in Brazil as CEO in 2014, Rodrigo is

currently Regional Commercial Director

for the Northern Europe region. He

is described as a keen advocate of

digital transformation and has been

closely involved in a number of crucial

transformation projects in the Northern

Europe region.

Regional growth

CASHFLOW finance provider eCapital

Commercial Finance (eCapital) has

appointed Jason Sedgwick as Regional

Sales Manager within its South of England

team. The appointment is said to enhance

eCapital’s sales presence as the company

continues its growth trajectory in the

competitive financial services market. It

is also said to reaffirm eCapital’s strategic

focus on each region of the UK. Jason will

be aligned with the Southern sales team

based out of the Reading headquarters,

while primarily focusing his business

development activities in and around

Essex, Cambridgeshire, Hertfordshire,

East Anglia, and Peterborough.

Imaginative Render

EQUIFAX UK has formed a strategic

partnership with Render to launch

what it describes as a comprehensive

data decisioning platform for lenders

that uses Equifax credit bureau data and

categorised Open Banking insights. The

firm says that the new platform – Clear

Decision, powered by Render – will help

lenders make more informed decisions

based on customers’ individual financial

circumstances, using a combination of

Credit Reference and Open Banking

data that provides an enhanced picture

of affordability and creditworthiness. In

particular, it will help lenders tackle the

challenge of marginal credit applications.

continues on page 8 >


THE NEWS

Banks face mixed fortunes

as uncertainty grows

THE main High Street

banks have reported

mixed fortunes in the

first quarter of 2025,

with profit rises for

NatWest, Barclays

and TSB and falls for

Santander and HSBC.

NatWest reported a 36% increase in

profits in the first quarter of this year,

reaching £1.8bn, up from £1.3bn last year.

The bank's revenues rose to £4bn, boosted

by higher deposits in its retail and commercial

bank. The amount of money deposited

by customers increased by £2.1bn during

the period, while net loans increased by

£3.4bn, driven by mortgage and business

lending.

Barclays similarly reported a 19% increase

in pre-tax profits, reaching £2.72bn for

the first quarter, despite facing economic

challenges. The bank has raised its loan loss

provisions to £643m, up from £513m a year

earlier, with £74m attributed to elevated

US macroeconomic uncertainty.

Effective cost-cutting measures and a

fall in operating costs were the cause of a

surge in profits for TSB. It posted a profit

of £101.3m in the first quarter, up from

£53.4m last year. The lender experienced a

particular boost in its mortgage portfolio.

Santander, meanwhile, experienced an

8% decrease in profits compared to the

same period last year. Commenting on a

pre-tax profit of £358m for the first quarter,

Chief Executive Mike Regnier stated that

charges relating to changes to its branch

network were largely to blame. The bank

is restructuring its operations, leading to a

69% increase in provisions to £140m.

As part of this overhaul, Santander plans

to close 95 branches and reduce hours at 36

locations, putting 750 jobs at risk. The bank

has also revised its UK economic growth

forecast down to 0.8% for this year, citing

reduced consumer confidence and geopolitical

uncertainties.

HSBC’s profits also took a hit. It reported

a pre-tax profit decline of £2.4bn, totalling

£7.1bn for the first quarter of 2025, a drop

attributed to economic uncertainty and

market unpredictability. The bank’s revenue

also fell by 15% year-on-year, amounting

to £13.2bn.

HSBC increased its provisions for bad

loans and predicted lending would be

muted this year. Group Chief Executive

Georges Elhedery described the results as

‘strong,’ pointing to the bank's resilienceamid

global economic challenges.

Profit warnings signal need for resilience NEWS

UK-listed companies issued 62 profit

warnings during Q1 2025, an 11% year-onyear

fall. The proportion of listed firms

to warn in the last 12 months, however,

remains high (18%).

EY-Parthenon’s latest Profit Warnings

report found that the leading factor

behind profit warnings in Q1 was contract

and order cancellations or delays, cited in

40% of warnings – the highest percentage

recorded for this cause in 25 years of EY’s

analysis. Policy change and geopolitical

uncertainty (26%) and labour market

issues (18%) were cited as the other main

drivers for warnings during Q1.

So far in Q2, half (50%) of the profit

warnings issued by UK-listed businesses

in April cited the direct or indirect impact

of tariffs and resulting recent global trade

disruption. The average share price fall

on the day of warning also climbed, up

from 13% in Q4 2024 to 17% in Q1 2025 and

almost a fifth (19%) in April 2025.

Jo Robinson, EY-Parthenon Partner

and UK&I Turnaround and Restructuring

Strategy Leader, says the latest profit

warnings data reveals underlying

weaknesses that will be magnified by

recent tariff disruptions and the resulting

economic fallout: “Nearly one in five

listed firms issued a warning in the last

12 months and that's a level typically

associated with a period of economic

shock,” he explains.

“UK businesses have faced

unprecedented challenges in recent years

and have developed admirable levels of

resilience in response, which should serve

many well as the global economy navigates

the coming months of uncertainty.

At times like these, businesses must

focus on staying nimble by planning

for a range of different scenarios and

continuing to build operational and

financial resilience.”

The FTSE sectors with the highest

number of profit warnings in Q1 2025 were

Software and Computer Services, with 10

warnings issued, and Industrial Support

Services – which encompasses business

service providers, industrial suppliers and

recruitment companies – with nine. FTSE

Construction and Materials companies

issued five profit warnings during the first

quarter.

Claire Gambles, EY-Parthenon

Turnaround and Restructuring Strategy

Partner, believes ongoing global trade

disruption has the potential to bring

even more substantial and far-reaching

repercussions: “Demand and supply shocks

from the pandemic and geopolitical events

were significant but primarily cyclical

disruptions, whereas major changes to

international trade policy may have more

enduring effects.

“Naturally, these changes won’t happen

immediately, and companies will need

to balance immediate responses, such as

strengthening financial resilience, with

strategic shifts, whether by reassessing

supply chains and pricing models or

exploring new global partnerships, to

help respond to further uncertainty over

the coming months.”

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


THE NEWS

Family support brings

younger buyers to market

NEW analysis from UK Finance has

highlighted the impact of family financial

support in the first-time buyer (FTB)

market – often known as the Bank of Mum

and Dad.

In looking at assisted and unassisted

buyers in terms of deposits, age, household

income and purchase price in 2024 UK

Finance found notable differences across

these in each region of the UK.

Nationally, first-time buyers who receive

assistance are able to buy a home at an

average age of just over 30, with an average

household income of £56,000. In contrast,

those purchasing without support tend

to be older—over 32 years old—and have

a higher household income, at £65,000.

Despite this, assisted buyers are on average

purchasing higher-priced properties,

thanks to larger deposits facilitated by

family support.

This divide is seen across the UK but

the difference in deposit amounts is most

pronounced in London. In 2024, a firsttime

buyer purchasing without support

typically put down a deposit of nearly

£150,000. However, for those receiving

family assistance, the average deposit was

just under £225,000.

UK Finance also looked at the impact of

the temporary Stamp Duty holiday, which

the Government introduced during the

pandemic. This was aimed at supporting

the market during a period of economic

instability, but it appears to have had

uneven effects, helping those who could

also get help from the Bank of Mum and

Dad the most.

By reducing transaction costs, analysis

by UK Finance found a disproportionate

increase in the number of assisted-

FTBs. UK Finance also found that the

policy coincided with a notable increase

in borrowers withdrawing very sizeable

amounts of equity when remortgaging,

suggesting that some households were

drawing on their own property wealth to

help family get on the housing ladder.

James Tatch, UK Finance’s Head of

Analytics, says that while the majority

of first-time buyers are still managing

to purchase without help, the growing

reliance on family support risks deepening

inequality in the housing market: “A

balanced approach which addresses both

supply and affordability issues is essential

to ensure the door to homeownership

remains open to all,” he says.

New US trade deal greeted

with cautious optimism

THE US-UK Trade deal, secured just

as Credit Management went to press, has

received mixed reviews from industry

leaders as the details of the deal become

clearer.

Sir Keir Starmer and US President

Donald Trump hailed the trade deal

between the UK and the US as ‘historic’,

which eases some, but not all, of the tariffs

imposed by the US in April.

The deal will see tariffs on British car

exports to the US fall from 27.5% to 10%,

for the first 100,000 vehicles per year; the

25% tariffs on steel and aluminium will

be removed and the UK’s pharmaceutical

industry has been promised preferential

treatment. British beef farmers will be

allowed access to the US market and vice

NEWS

versa, with no reduction in food standards

in the UK. Jonathan Reynolds, the Business

and Trade Secretary, said the UK would

continue trying to reduce the 10% baseline

tariff, adding that the agreement did not

include any concessions on the digital

services tax, online safety laws, or the NHS.

A separate deal on technology is expected

to be agreed at a later date.

UK manufacturers currently export in

excess of 100,000 vehicles to the US but

Mike Hawes, Chief Executive of the Society

of Motor Manufacturers and Traders, still

gave a cautious welcome to the news: "The

application of these tariffs was a severe

and immediate threat to UK automotive

exporters so this deal will provide much

needed relief."

All square

SQUARE 4 Partners, a consultancy and

interim solutions provider specialising

in governance, risk, and compliance,

has appointed Roma Pearson as Senior

Advisory Director within its Consultancy

Division. Roma previously served as

Director of Consumer Finance at the

Financial Conduct Authority (FCA).

Her appointment comes at a critical

time for financial services firms as they

face increasing pressure to meet evolving

regulatory expectations, particularly in

relation to the Consumer Duty regime

and the FCA’s shift towards outcomesbased

supervision. At the FCA, Roma led

the supervision and policy development

of the consumer lending market and held

several senior positions, including Head

of Mortgages & Consumer Lending, Head

of Retail General Insurance, and Head of

Risk Advisory.

Perpetual motion

CAPGEMINI has announced the

rollout of a technology sandbox that

offers financial institutions a sound

framework to migrate from legacy, static

Know-Your-Customer (KYC) processes

and labour-intensive periodic reviews

towards perpetual KYC (pKYC) and

event-based reviews. Described by the

firm as a first of its kind, Capgemini has

collaborated with multiple technology

partners to orchestrate the integration

of this architecture. The sandbox offers

a safe and secure test environment for

firms to visualize how they can transition

to a pKYC process and demonstrate its

effectiveness to senior management and

regulators.

Approval stamp

POST Office branches will continue to

provide access to cash for another five

years following a new agreement with

banks. Neil Brocklehurst, the new Chief

Executive, stated that this partnership

will underpin access to cash for millions

of individuals and small businesses.

Customers of 30 banks and building

societies will be able to perform various

transactions at their local Post Office,

which is also enhancing postmaster

remuneration for cash handling.

Additionally, The Post Office says it

will be making a significant investment

in automating cash services to lower

operational costs.

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

continues on next page >


THE NEWS

Solaris completes

purchase of Equivo

Legal Services

SOLARIS Law, part of the Azzurro

Group, has completed the purchase of

the Equivo Legal Services division. This is

the final part of a two-stage transaction

which sees the Equivo legal team join

Solaris Law and follows the first stage of

the transaction in 2024 to purchase the

Shoosmith’s commercial debt recovery

team and integrating it into its new

Solent office.

The purchase creates one of the largest

commercial and consumer specialist

collections and legal debt recovery

businesses in the UK with a focus on

Asset and Motor finance recoveries,

Mortgage recoveries, Unsecured lending

and commercial and business to business

debt recovery.

Solaris Law will be structured as two

law firms with the new Consumerfocused-firm,

led by Mel Chell having

both Solicitor Regulation Authority

(SRA) and Financial Conduct Authority

(FCA) permissions. The Commercial law

firm, which will be regulated by the SRA,

will continue to be led by Karen Bulgarelli,

CEO of Solaris Law. Both Karen and Mel

are lawyers and were formerly Partners of

Shoosmiths.

Work has already started on transitioning

the teams into the new business, which

the firm says will now comprise over

190 paralegals, lawyers and support

staff across offices in Southampton,

Northampton and Manchester. The case

management platform is common across

Dispute resolution

scheme faces scrutiny

THE Business Banking Resolution

Service (BBRS), established to assist small

businesses affected by banking scandals

and financed by the participating banks,

is facing ongoing criticism for its financial

management.

Critics argue that the BBRS has

functioned more as a protective measure

for banks than a support system for

victims. The BBRS in its quarterly report

(April 2025), however, claims that to date it

has secured more than £2.75m of financial

redress as a result of its intervention, and

the true figure ‘is likely to be significantly

higher’.

As of 31 March 2025, the BBRS had a

total of 1,106 case registrations and says

all parties, and further investment into

additional systems and infrastructure is

already underway.

Equivo’s Field Team and High Court

Enforcement Business will not form part

of the new business and will continue to

operate under the Equivo brand.

Mel Chell.

Karen Bulgarelli, CEO of Solaris Law.

NEWS

that in addition to the 130 customers

who have received financial award or

settlement, BBRS ‘has also resolved cases

to the satisfaction of the customer and the

bank in instances where no award has been

made’.

A spokeswoman quoted in The Times said

the service had been ‘established to address

a scale of complaints that ultimately didn't

materialise and our set-up and operating

costs reflect that, as well as the complexity

of the cases.’

They added that the service also achieved

‘non-financial outcomes’ for complainants.

The BBRS closed to new complaint

registrations in December 2024 and is set

to close by the end of 2025.

Switching off

ACCORDING to a survey for Smart

Money People by Opinium, nearly a third

(31%) of respondents would only consider

switching financial services providers if

the new company had a minimum rating

of four stars out of five. The survey

revealed that 74% of participants read

reviews before making decisions about

financial products. The research also

highlighted that 62% of reviewers shared

positive experiences, while 42% reported

stressful situations with their providers.

Building foundations

TAYLOR Wimpey has reported good

levels of customer demand leading to a

robust start to 2025, with its order book

reaching £2.34bn, nearly £300m higher

than last year. Despite this positive

outlook, the company's shares have fallen

by over 25% since last October. The firm

plans to build between 10,400 and 10,800

homes this year, but analysts expect a

return to pre-pandemic levels of over

16,000 homes.

Life’s a gas

LEEDS Building Society says it has

dramatically improved the accuracy of

its reported financed emissions within

its residential lending portfolio thanks

to a new partnership with Experian. The

improvement aligns with the transition

to a low-carbon economy and the

Government’s Net Zero ambition. As part

of that journey, UK lenders are obliged to

report Scope 3 financed emissions, which

can account for anywhere between 80%

and 95% of a business’ total footprint. By

deploying Experian datasets, the building

society has been able to access aggregated

and anonymised property level energy

data and emission factors for properties

in its portfolio. This has removed its

reliance on estimated EPC data which

was found to have overestimated its

residential mortgage emissions by more

than a third (36%).

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


.

INSOLVENCY

RESTRUCTURING

PLANS

What are they and what impact can they have on creditors?

BY GIUSEPPE PARLA

RESTRUCTURING Plans (RPs)

are very much in the news at the

moment, not least because they

are being used to save Thames

Water. But what is an RP

and could they be something

we may be seeing more of as a

credit manager?

The Corporate Insolvency and Governance Act

2020 introduced the new RP during the COVID-19

pandemic, with the aim of helping companies avoid

insolvency whilst ensuring creditors and stakeholders

are treated fairly.

Unlike any other ‘traditional’ insolvency procedures,

an RP provides greater flexibility in how it is

structured, allowing companies to propose bespoke

solutions that suit their financial situation. It can also

help a company remain operational, preserve jobs and

maintain relationships with customers and suppliers,

while avoiding a formal insolvency process, where

returns to key stakeholders may be impacted more

severely.

While RPs offer some benefits, however, they also

come with challenges and risks. So it’s worth knowing

how RPs are approved and their impact on creditors’

rights, so you can determine what actions to take next.

Obtaining approval

For a company to implement an RP, it must satisfy two

eligibility criteria:

1. Financial Difficulty – the company must be

encountering, or be likely to encounter, financial

difficulties that affect its ability to carry on as a going

concern.

2. Compromise or Arrangement – the plan must

involve a compromise or arrangement between the

company and its creditors and/or shareholders to

restructure its obligations.

Once an RP is proposed, it must go through a

structured approval process via the Court. The

significant involvement of the Court means the costs

associated with RPs are typically high, and this may

explain why we have not seen a great deal of them.

The Court needs to determine whether the RP is fit

for consideration, including the appropriate classes of

creditors and shareholders. The affected creditors and

shareholders are then divided into classes and asked

to vote on the RP. At least 75% in value of creditors

in each class must vote in favour but even if the RP

receives the required votes, the Court must assess its

fairness before granting final approval.

One of the most powerful features of an RP is the

cross-class ‘cram-down’, which allows the Court to

sanction an RP even if one or more creditor classes

vote against it. This mechanism ensures that RPs can

proceed even if faced with creditor opposition. This

makes them a highly effective restructuring tool, but it

also makes them quite controversial.

If we are to compare the RP to a Company Voluntary

Arrangement (CVA), for example, the RP can proceed

even if creditors vote against it should the court

approve it, whereas in a CVA, it cannot proceed

without the creditors’ approval (75% of creditors’

support is required) and it does not require the court’s

involvement.

Impact on creditors

An RP can have a significant impact on creditors, from

loss of control by the cross-class ‘cram-down’ feature,

to your debt being compromised. This means you may

have to accept reduced payments, extended repayment

terms, or even full debt write-offs.

Should you be faced with an RP, you should seek

assistance to understand what the RP is proposing for

you and your class of creditors. Where possible, you

should negotiate new terms of business, and you

should ensure you vote in the RP process.

You should also monitor the outcome of the

Court’s decision on the RP as it is the Court

that has the final say.

Author: Giuseppe Parla is a Business

Recovery Director and Licensed Insolvency

Practitioner at Menzies LLP.

Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 11


CONSUMER CREDIT

MIND

GAMES

How can the credit industry respond and fulfil

its responsibilities to its vulnerable customers?

BY STEPHEN KIELY

IN March, Chancellor Rachel Reeves

announced her Spring Statement,

including plans to cut and freeze Universal

Credit incapacity benefit payments for

new claimants, who have been assessed as

too unwell to work due to experiencing

poor mental health or other conditions.

These payments will be cut by 50% compared to

payments for existing claimants, and will be frozen

at this rate until 2030. Naturally, this decision has

become a significant political issue, with concerns

that some households could struggle under the new

arrangements. One notable phenomenon, however,

was the increased emphasis on mental health, and the

relationship of debt to consumers’ wellbeing.

Hammer blow

Responding to the Spring Statement, Helen Undy,

Chief Executive of the Money and Mental Health

Policy Institute, spoke for many commentators when

she said that the announcement amounted to ‘another

hammer blow’ for people who are struggling with

their mental health and finances.

“Incapacity benefits are a lifeline for people who have

been assessed as too unwell to work due to their mental

or physical health,” she said. “Cutting these payments

and freezing them, while the cost of everyday essentials

continues to rise, effectively penalises people for

becoming sick, and the Government’s own estimates

show this reform package will push an additional

250,000 people into poverty.

“This hardship can make it harder to recover and

to return to work, risking undermining, rather

than boosting, the Government’s efforts to grow

the economy. It will also pile on more anxiety and

fear for many people with mental-health problems

who are still reeling from the plans to cut Personal

Independence Payment (PIP) announced.”

Meanwhile, in April, the Welsh Government began

a 12-week consultation to extend enforcement rules.

At the moment, missing a council tax payment means

residents can become liable for the full annual bill

if they do not pay within seven days of receiving

a reminder, and the requirements on councils for

sending reminders and final notices are considered to

be too complex.

The consultation proposes that people will be given

more time to recover from unexpected financial

setbacks, highlighting the potential impact on mental

health.

Cabinet Secretary for Finance and Welsh Language,

Mark Drakeford, said: “I know councils want to help

wherever possible, and we will spread the best practice

we have seen through this fairer framework. This will

help councils differentiate between people who are

struggling and those who are persistently disengaging.

A longer timeframe also allows households to recover

from unexpected events or circumstances that may

have contributed to their financial struggles.”

Bespoke training

This is an issue which is clearly high on the agenda

for many in the industry. Virgin Money recently said

that it had launched a bespoke training programme

for all its 4,000 customer-facing colleagues to equip

them with the skills to support and talk to customers

about their money worries and mental health. It

is working with mental-health charities Mind and

SAMH (Scottish Action for Mental Health).

The new five-module training programme covers

key areas including: understanding mental health;

how to engage in sensitive conversations; and helpful

conversation examples and language to avoid. It also

covers duty of care and how to raise a welfare concern,

as well as how to recognise their own mental wellbeing.

Virgin Money commissioned research showing that

financial pressures are impacting people’s mental

health, with over half (52%) of adults reporting feelings

of anxiety, 45% experiencing stress, and 27% feeling

depressed due to money worries.

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


CREDIT MANAGEMENT

“CUTTING THESE PAYMENTS AND

FREEZING THEM, WHILE THE COST OF

EVERYDAY ESSENTIALS CONTINUES

TO RISE, EFFECTIVELY PENALISES

PEOPLE FOR BECOMING SICK’’

Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 13

continues on next page >


CONSUMER CREDIT

Household bills and the rising costs of everyday

essentials are driving this heightened anxiety, and 66%

of adults worry that the cost of living will rise again,

while 57% fear that essential household items and

paying bills will become unaffordable in the future if

prices continue to increase.

Syreeta Brown, Group Chief People and

Communications Officer at Virgin Money, said:

"We understand the impact financial worries can

have on mental health, which is why it is important

for us to ensure our colleagues can offer the best

possible support to any of our customers facing these

challenges.”

Andrew Berrie, Head of Corporate Partnerships at

Mind, added: “Financial pressures can significantly

impact mental health and with the ongoing costof-living

crisis, these pressures are only increasing.

This programme will ensure vital support is available

to customers, making a real difference for those

struggling with their mental health.”

Weather vane

The industry is eager to get across the message that

help is at hand. Rebecca Nunn, Senior Manager at

Fidelity International describes mental health as

being like the weather, in that it can be unpredictable

and might change for all sorts of reasons – some of

which are within our control, some not.

She insists there are measures that people can take to

help with poor mental health as some diagnoses are

more preventable than others. From awareness and

education at one end of the spectrum, to supporting

people who are more likely to develop mental-health

problems and helping people with mental ill-health to

stay well by empowering them to manage their wellbeing

to reduce the risk of relapse.

“WE WANT FIRMS

TO BUILD ON

THE GOOD WORK

IDENTIFIED, TO

HELP PEOPLE

OPEN UP AND

MAKE SURE THEY

GET THE SUPPORT

THEY MAY NEED.”

While many are making significant efforts, research

by the Money and Mental Health Policy Institute

suggests that more needs to be done to support

people experiencing the long-term cycle of money

and mental-health problems. It concludes that an

extended struggle with either mental or financial

health ‘heightens the probability of one impacting the

other’.

Specifically, the report examined how people aged 25 to

54 experienced this combination of issues differently

depending on whether they faced them on a shortterm

(one to two years) or long-term basis (three or

more years). People who experienced mental-health

problems for three or more years faced significantly

worse income, employment and debt outcomes.

In particular, the report highlights that people

aged 25 to 54, who had long-term mental-health

problems in this period, were nine times more likely

to have struggled financially than people who have

never experienced a mental-health problem. This is

significantly higher than people with shorter mentalhealth

problems, who were just over three times

more likely to have struggled financially than people

without mental-health problems.

It also found that they were 11 times more likely to

have been out of work due to illness or disability than

people without mental-health problems. Again, this

is a significantly higher likelihood than for those who

experienced mental-health problems for a shorter

period of time, who were five times more likely to be

out of work than those without such problems.

The report identified other alarming trends. People

within that age group were more likely to have had low

incomes – with an average income gap of £3,360 a year

compared to people without mental-health problems.

For people with shorter-term problems, the average

annual income gap was £2,376 compared to those who

have not experienced such difficulties. They were also

four times as likely to have been behind on bills than

people without mental-health problems. In contrast,

people who experienced mental-health problems for a

shorter period of time were nearly twice as likely to be

behind on bills than those who have not experienced

problems.

Opening up

Just as financial firms are taking their responsibilities

seriously, however, there needs to be a partnership,

with vulnerable customers opening up to firms in

order to get the right support.

Understandably, this is a difficult issue to approach.

Recent Financial Conduct Authority (FCA) research

finds that just four in 10 vulnerable customers say they

have disclosed their needs to their financial services

provider.

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


CREDIT MANAGEMENT

However, those that do open up tend to have better

experiences. Three-quarters of vulnerable customers

who told their firm about their circumstances said

that staff asked the right questions to understand

their situation, six in 10 said their firm ‘cared’, and 58%

said their firm took action to provide support they

needed.

On 7 March 2025, the FCA published a review and

good and poor practice examples to further help

firms provide the right care consistent with the

Consumer Duty. Sarah Pritchard, Executive Director,

Competition, Markets and International, said: “It

can be hard to tell your bank or insurer about your

specific needs, but those who ask for help tend to feel

more supported. We have seen good examples where

financial firms are making a difference for vulnerable

customers, but we know that vulnerable people report

more negative experiences than others.

“We want firms to build on the good work identified,

to help people open up and make sure they get the

support they may need.”

Supporting colleagues

Such support for vulnerable customer is, without

doubt, essential, but it can also take its emotional

strain on collections professionals, who need to deal,

sensitively, with difficult cases.

In response, in 2022 NatWest began a collaboration with

JAAQ, an online mental-health platform, powered by

AI. This gives colleagues access to respected mentalhealth

professionals to have their own questions

answered. They are presented with video responses

from over 40 experts, including David Veale, Professor

in Cognitive Behavioural Psychotherapies at Kings

College and Dr Erin Brown, Consultant Psychiatrist in

Early Intervention in Psychosis.

Jen Tippin, now Group Chief Operating Officer at

NatWest, said: “The wellbeing of our employees is of

fundamental importance at any time, but particularly

when faced with concerns around cost of living. My

team is focused on ensuring that employees have access

to the right resources and support.”

Conclusion

After many years of secrecy, mental health is finally

becoming less stigmatised and more openly discussed,

and with that comes an expectation that the finance

industry will take its responsibilities seriously and offer

adequate support – both for customers and colleagues.

Many, in the industry, are making significant

efforts, but there is still much to do to understand what

help is needed, when, and how it can best be offered.

Author: Stephen Kiely is a freelance business writer.

Ways to care for your mental health when

you have money worries – guidance from

the NHS – Every Mind Matters.

• Be kind to yourself – self-compassion is vital for our

mental wellbeing, especially in tough times, and getting

into the right mind space can help before dealing

with money problems. If you are struggling to cope

with money or unemployment, accepting that things

might be outside your control, or take time to sort

can help you feel calmer. Try to treat yourself kindly

and avoid negative self-talk or unhelpful thoughts.

It can also help to remember that things change. Try

cognitive behavioural therapy (CBT) techniques, such

as focussing on what you can control.

• Talk about your money issues – it can help to talk

about your money worries with someone you trust,

like a friend or family member. You might prefer to

talk to someone confidentially, perhaps to work out

how you feel right now or what to do next, like getting

money advice.

• Switch off from money worries – relaxation techniques

and meditation can help us feel calmer, which might

help with feelings of anxiety about money. Taking time

to pause and focus on our breathing can help us feel

more present – even taking a few deep breaths in and

out can help.

• Create good self-care routines - sticking to a routine

might give us a sense of purpose and boost our mood.

This can be tough if you are feeling low, so start with

simple things, such as getting up and going to bed at

the same time every day. As you stick to your routine,

you should notice that your mood starts to improve.

Perhaps start building more into your routine as you

go along, like planning something social or fun, or

trying to exercise more.

• Face unemployment fears – our mental wellbeing can

take a hit if we are not working. A job is often vital

to our financial wellbeing and security – and our selfesteem.

It might also give us a sense of achievement,

a feeling of belonging, and be an important social

network, which helps with feelings of loneliness.

Taking practical steps for our mental health, which we

use every day, can help us build resilience. This could

include having a good self-care routine, exploring

unhelpful thoughts, and looking for solutions to

problems that are within our control.

• Maintain physical health to help ease anxiety - our

physical health often affects how we feel emotionally

and mentally. Being active can really help when we

are dealing with stress caused by money problems and

work issues. Try to be active and stick to a healthy diet.

• Create a budget or money plan – aim to set a regular

time to look at your costs, so you can work out what

you can spend each week or month. It might also help

you identify whether you can save a bit of money,

perhaps for covering unexpected life challenges, such

as replacing an expensive household item.

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


SANCTIONSW

POTENTIAL

RED FLAGS FOR

SANCTIONS

EVASION ARE

SET OUT IN

ALERTS ISSUED

BY THE NATIONAL

ECONOMIC CRIME

CENTRE.

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


CREDIT MANAGEMENT

CUTTING

IT FINE

FCA fines – are your controls up to scratch?

BY JOCELYNE GIRGIS AND

ANDREW NORTHAGE

LAST October (2024), the Financial

Conduct Authority (FCA) fined

Starling Bank just under £29m for

inadequacies in its financial sanctions

screening processes, citing ‘shockingly

lax’ financial crime controls which

left the financial system wide open to

criminals and those subject to sanctions.

Over the last couple of years the FCA has been ramping

up its enforcement and has issued several fines in response

to banks' failures to prevent and control financial crime.

The action against Starling highlighted once again the

importance of making sure financial crime systems and

controls are robust enough to stand up to scrutiny.

Core commitment

There's no escaping it, reducing and preventing financial

crime is one of the FCA's core commitments, detailed

in its 2024/25 Business Plan. When considered against

the backdrop of macroeconomic challenges, including

ongoing conflicts and the lingering effects of Brexit and

COVID, the urgent need for healthy financial sanctions

screening processes is brought into sharp focus.

Given the background, it makes sense to look at what's

been happening, including coverage of the latest updates

to the FCA's Financial Crime Guide (FCG), the risks to a

business and what firms should be doing to ensure their

financial crime controls are up to scratch.

What's been happening?

The FCA has hit banks with some of its biggest fines

of late. Examples include the £108m penalty against

Santander UK in 2022 and £265m penalty against

NatWest in 2021, both relating to serious gaps in antimoney

laundering controls.

The action against Starling follows a 2021 FCA review of

financial crime controls at challenger banks. The review

uncovered issues ranging from failures to consistently

apply enhanced due diligence checks, to underdeveloped

risk assessment frameworks and inadequate management

of financial crime change programmes. In Starling's case,

the FCA identified particular concerns with anti-money

laundering and sanctions frameworks, exacerbated by

Starling's notable growth – the systems designed to

address financial crime couldn't keep up.

This activity by the FCA reflects a proactive approach

to meeting an evolving financial crime landscape

head on. Towards the end of last year, the FCA also

released a policy statement detailing changes and

updates to its FCG. The amended FCG applies to all

FCA financial crime supervised firms, or any firm

otherwise supervised under the Money Laundering,

Terrorist Financing and Transfer of Funds (Information

on the Payer) Regulations 2017 (Money Laundering

Regulations).

Updates addressed a number of topics:

Sanctions

The FCA updated the terminology around sanctions

for improved consistency and clarity on key subject

areas such as management accountability for sanctions

governance, cryptoasset businesses, and manual versus

automated sanctions screening processes.

The FCA also provided further clarification on which

suspected sanctions breaches would require FCA

notification (for example, those arising from significant

failings in screening systems and controls) and hinted at

future guidance on enhanced reporting requirements for

significant breaches.

Updates were also made surrounding sanctions screening

processes. In particular that depending on the nature of

a firm's business and assessment of risk, the investigation

of alerts must form a part of the process. Screening

processes may vary firm-to-firm, and screening against

published sanctions lists alone may not be sufficient

to identify potential sanctions evasion involving third

parties.

Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 17 continues on next page >


SANCTIONS

As referenced in the changes to the FCG, potential red

flags for sanctions evasion are set out in alerts issued by

the National Economic Crime Centre.

There's also now a reinforced expectation that firms will

perform ‘lessons learned’ exercises following sanctions

developments and that senior managers take ‘clear

responsibility’ for managing sanctions risks, firms are

‘actively engaged’ in addressing non-compliance risks;

and firms are ‘sufficiently aware’ of their sanctions

obligations.

Although unlikely to be sector-specific, future sanctions

screening guidance anticipated from the FCA will

include updated examples of good and poor practice,

more case study examples to assist firms with evaluating

their controls, and further references to guidance from

the Office of Trade Sanctions Implementation and nonfinancial

sanctions.

Proliferation financing

Although captured previously in its chapter on

sanctions, the FCG now refers explicitly to proliferation

financing. This update reflects the 2022 amendments to

the Money Laundering Regulations, which now require

risk assessments and controls to be in place for the

identification of proliferation financing risks.

Transaction monitoring

New examples of good and bad practice when using

transaction monitoring systems have been provided with

reference to the use and impact of artificial intelligence

(AI) in increasing transaction monitoring efficiency.

Revisions to the guidance have ultimately been designed

to balance existing regulatory expectations with the

increasing use of AI.

Examples of good practice include tailoring monitoring

system rules to the business, risk and relevant typologies

to ensure accuracy of outcome, regularly testing and

reviewing transaction monitoring system parameters,

and recording any reasons for the decommissioning of

automated systems.

In contrast, examples of poor practice include uncritical

reliance on automated systems or systems which are

not calibrated to specific needs, and dependence on

threshold-based transaction monitoring approaches.

Consumer duty

The FCG has been updated to align with the Consumer

Duty for new and existing products and emphasises

the obligation on firms to provide better outcomes

for consumers. This is particularly pertinent where a

situation raises issues of unfair client treatment which

conflict with due diligence requirements, asset freezing

or risk-based approaches.

To assist businesses with balancing financial crime and

consumer duty obligations, firms are encouraged to

BUSINESSES IN THE

FINANCIAL SECTOR

SHOULD REMAIN

AWARE OF THE

RISKS TO THEM

WHEN CONDUCTING

SANCTIONS

SCREENING.

consider FCA Principle 12 – ‘a firm must act to deliver

good outcomes for retail customers’ – in tandem with the

associated cross-cutting rules. While the Consumer Duty

recognises that not all harms are foreseeable, which is

especially true in the context of newly emerging financial

crime obligations, the duty means that businesses are

expected to consider the necessary action to take once a

harm does become foreseeable.

Data security

The FCG has been updated to include self-assessment

questions on data systems and management, along with

examples of good and poor data security practice. The

FCA has also added links to the National Cyber Security

Centre's Cyber Security Toolkit for boards and its 10

Steps to Cyber Security guidance. The FCA continues

to monitor data security in the context of generative

AI, with a view to providing subsequent guidance on its

secure implementation.

ECCTA 2023

The FCA has endorsed the implementation of enhanced

anti-money laundering and information-sharing powers

under the Economic Crime and Corporate Transparency

Act 2023. Updates to the FCG encourage data sharing

partnerships between businesses, to share information to

combat economic crime without civil liability, provided

compliance with the UK General Data Protection

Regulation is maintained.

Consequential changes

The FCA has generally amended the practice examples

and self-assessment questions available within the FCG

to reflect updates to UK legislation and to remove

redundant EU references. Other consequential changes

include once again naming firms within case studies to

allow other firms to identify whether they've already

assessed a particular case and its relevance to them.

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


CREDIT MANAGEMENT

The full extent of changes to the FCG can be read in

the FCA’s Policy Statement PS24/17. The FCA has also

indicated that further updates and more detailed guidance

can be expected on fraud, particularly Authorised Push

Payment scams, synthetic identity fraud and digital

fraud, and the use of AI in detecting financial crime.

Such updates will equip businesses to better understand

and address their compliance obligations in relation

to existing and emerging financial crime risks, thereby

allowing them to tailor their screening tools to match

business risk exposure and meet sanctions screening

needs.

What are the risks to a

business?

Overreliance on automated screening processes

Technology and the automation of repetitive tasks

certainly seems like the bee's knees as it streamlines

processes, frees up resources and saves time and money.

However, the reality is that automated processes are

not always able to align with the nuances of every

circumstance. Individuals, criminal organisations,

corrupt officials and terrorism financiers frequently

change their methods, meaning reliance on static

algorithms without human command risks leaving the

door to financial crime wide open.

Responsibility for failing to prevent financial crime internally

While facilitating any economic crime is undoubtedly

problematic, the fact is one doesn't need to have actively

facilitated crime to be held responsible. The series of

‘failure to prevent’ offences for bribery, tax evasion and

the recently introduced failure to prevent fraud offence

(coming into force on 1 September 2025), means it's now

easier than ever to find oneself in hot water for certain

financial crimes. Large organisations are expected not

only to monitor their customers, but also the activities of

persons associated with the business including employees

and agents.

Reputational damage

Failing to protect a business against financial crime

poses severe reputational risk, particularly for financial

institutions. If a bank repeatedly loses money to fraud, its

ability to keep money safe may be doubted. Association

with illegal activity is likely to lead to negative publicity

and customer distrust.

Increased costs

As the complexity and scope of financial crime regulation

increases, so too do compliance costs. This costs risk is

exacerbated further by rising penalties for compliance

failures.

What can be done?

The action against Starling provides a cautionary

reminder to update and bolster sanctions policies and

procedures. There are a number of practical steps a firm

can take to guard against landing on the wrong side of an

FCA investigation.

Implement strategies to enhance financial crime control

frameworks

An efficient compliance framework serves as a shield to

safeguard the integrity of business transactions. Firms

should make sure that their controls are comprehensive

enough to identify and screen all parties relevant to a

transaction, including the individuals or entities that

may have control over the parties. They should ensure

that their systems can address red flags and that recordkeeping

procedures thoroughly document any decision

making, due diligence and mitigation measures taken.

Ensure risk assessments and due diligence checks are fit for

purpose

Weaknesses in customer due diligence checks, such

as failing to obtain customer income and occupation

information, was one deficiency flagged by the FCA in

its final notice to Starling. The identification of high risk

or sanctioned individuals or entities before transacting

should be a priority. Beyond basic due diligence, firms

should implement enhanced measures when verifying

high-risk customers and ensure that any concerns are

promptly reported to the responsible authority.

Proactively monitor internal policies and processes

Organisations need to use a risk-based approach to

periodically review anti-money laundering and sanctions

screening policies in a way that anticipates future needs.

By identifying the highest compliance risks as early as

possible, any changes or mitigation measures stand a

better chance of being effective. Dealing with financial

crime issues on a reactive basis puts the firm on the back

foot and may mean failing to address triggers before they

escalate into full-blown compliance issues.

Being aware of changing financial crime risks

Lastly, an ever-changing regulatory landscape demands

continual revision and development of financial crime

systems and controls. Employees should also be kept

updated of any such developments with frequent

communication and role-specific training. Firms need to

ensure that the message is adapted to present events.

Summary

Businesses in the financial sector should remain aware of

the risks to them when conducting sanctions screening

and be proactive in taking the appropriate steps to

mitigate those risks. The rules are only going to get

harsher and apart from any sanctions applied, the act

of naming non-compliant firms is never going to be a

positive outcome for businesses.

Author: Andrew Northage is a Partner, and Jocelyne Girgis

is an associate, in the Regulatory & Compliance team at

Walker Morris.

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


FINANCIAL

FORECAST ON

THE FINANCIAL

FUTURE

A report from the recent Esker-hosted round table.

BY MILICA COSIC

ESKER hosted ‘The Credit Industry: 2025 In Review’ at PwC’s London offices on 9 April, bringing together

industry experts John Payne (Dun & Bradstreet) and Lucy Fulmer (PwC) to share insights on the UK economy,

the Spring Forecast, and sector-specific risks, notably insolvency trends and emerging vulnerabilities.

An insightful panel debate followed, moderated by Luke Sculthorpe (CICM) with contributions from

Natascha Whitehead (Hays), Ray Massey (Tokio Marine HCC) and Martyn Brooke (Esker).

THE year 2024 marked the highest

level of business failures in three

decades, with 24,112 insolvencies –

96% of which were small or micro

businesses. The construction

sector remains particularly

vulnerable, owing to sensitivity

to interest rate fluctuations and increasing labour

costs. And while some improvement is projected,

John forecasts that financial conditions will remain

‘tight’ well into this year. This will be further strained

by new cost pressures, including changes to National

Insurance Contributions, an uplift in the National

Living Wage, and rising inflation, forecast at over 3.2%

this year.

Furthermore, trade tensions between the UK and the

US may result in new tariffs, which could either drive

up prices or dampen the pound, depending on how

the Bank of England chooses to respond. A retaliatory

tariff move or a free trade agreement with the US could,

for instance, flood the market with cheaper imports –

potentially undercutting UK farmers and domestic

producers. Lending is becoming increasingly difficult

to access for SMEs, who are already struggling with

high borrowing costs and dwindling credit appetite

among lenders.

The Spring Economic Statement also painted a

cautious picture: Government plans include £4.8bn

in welfare cuts, a £3.6bn reduction in departmental

budgets, and a 6.4% rise in the energy cap from April

2025. All signs point to a tighter fiscal environment

for the foreseeable future.

Insolvency: Outlook for 2025

Lucy Fulmer, Head of the Creditor Markets Team

at PwC, emphasised that while 2024 was one of the

worst years for insolvencies in recent memory, the

distress is likely to continue – albeit that the most

severe impact may be delayed. While voluntary

liquidations and overall company failures showed

minor percentage changes between early 2024 and

early 2025, the underlying pressures on businesses

remain intense. In fact, in 2024, 98% of insolvency

appointments involved businesses with turnovers

of less than £1 million. While there were notable

exceptions – including high-street names like The

Body Shop and Ted Baker – the brunt of the damage

was borne by smaller firms.

The sectors most at risk in 2025 include retail,

hospitality, construction, manufacturing, automotive,

and business services. Interestingly, even the

previously resilient ‘defensible’ sectors, such as tech,

media, telecoms, and healthcare, are now feeling the

strain. Rising debt and underperformance in these

areas suggest that no sector is truly immune to the

current financial climate.

Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 20


CREDIT MANAGEMENT

After a tumultuous few years, the UK economy remains

in a state of cautious recovery, though challenges

continue to weigh on businesses and households alike.

While certain sectors – particularly services and

technology – have powered through post-pandemic

turbulence, the economy at large has yet to return

to full pre-pandemic strength. According to John

Payne, Senior Economist at Dun & Bradstreet, the

UK economy grew by 1.4% in Q4 2024, outperforming

expectations and edging closer to its pre-pandemic

average of 1.9%. However, this modest growth is offset

by ongoing structural weaknesses and wider financial

pressures.

Encouragingly, the economy is now 15% larger than

it was in 2019 – principally thanks to the robust

performance of the services sector, the traditional

backbone of the UK. But this recovery hasn’t been

felt evenly across the board. Key industries such as

construction, agriculture, and mining continue to face

difficulties, compounded by post-Brexit disruption

and economic uncertainty stemming from US market

fluctuations.

For households, the impact of the ongoing cost-ofliving

crisis remains a daily reality. Since 2021, wages

and prices have surged by 24% – a rate that previously

took a decade to reach. The sharp climb in living

costs, concertinaed into just four years, has left many

struggling to keep up. Unemployment is also creeping

upwards, with many firms slowing down their hiring

plans amid rising operational costs and continued

economic ambiguity.

Additionally, high-profile restructuring cases – such

as Thames Water in the utilities sector – highlight

broader concerns in areas like real estate and wind

energy. Manufacturing wind turbines, for example, has

been plagued by quality control issues, affecting key

components like rotor blades and gearboxes.

Looking ahead, a mix of geopolitical shifts, AI

disruption, potential inflation resurgence, and

legislative changes could act as further triggers for

distress. Lucy also notes a likely uptick in the use of

restructuring plans, although their effectiveness for

SMEs remains uncertain.

A Fragile Recovery

In summary, while the UK is not in crisis, it’s far from

comfortable. Business conditions remain challenging,

households are stretched, and inflation pressures

continue to loom. The service sector’s strength and

steady GDP growth provide a foundation, but it is a

fragile one.

As 2025 continues, financial resilience – whether in

the form of effective restructuring, targeted lending,

or policy support – will be critical to navigating an

economic landscape that, while no longer in freefall,

still demands caution and adaptability.

LOOKING

AHEAD, A MIX OF

GEOPOLITICAL

SHIFTS, AI

DISRUPTION,

POTENTIAL

INFLATION

RESURGENCE,

AND LEGISLATIVE

CHANGES COULD

ACT AS FURTHER

TRIGGERS FOR

DISTRESS.

The Managing Editor, Sean Feast FCICM, writes: Since

the panel debate, the Insolvency Service has released the

March insolvency figures that show a c30% increase in

administrations, a notable increase since COVID-19. Since

administrations are most popular with larger firms, they

tend to have the biggest impact on creditors and insurers.

While one month’s data does not signify a trend, the figures

are interesting, nonetheless.

At the time of going to press also, the absence of a UK/

US trade deal and/or a UK/EU trade deal also remains an

ongoing concern and brings uncertainty regarding future

economic prosperity. Perception is everything, and with

uncertainty inevitably comes delays in investment and a

fall in discretionary spend, which could do more harm than

any eventual deal could do good. The longer the uncertainty

continues, the poorer it will be for the UK economy.

Author: Milica Cosic.

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


ENFORCEMENT

TRANSFER FEE

A fair fee for enforcement is long overdue.

BY RUSSELL HAMBLIN-BOONE

IMAGINE if you will, being invited to

invest in a business that was solely dependent

on central and local Government

contracts. However, the business revenue

does not come from your Government

clients. In fact, you must provide your

services to the public sector for free and

your income is not guaranteed.

Now, add in the fact that the prices you can charge are

set by the Government, and an inflationary increase is

not automatic, so your prices have been frozen for over

a decade. That is the reality of the civil enforcement

sector, which recovers debts on behalf of local

authorities and His Majesty’s Courts and Tribunals

Service (HMCTS). This includes council tax arrears,

business rates, road traffic and parking penalties,

magistrates’ court fines, employment tribunal awards,

child support payments, and commercial rent arrears.

The enforcement fee structure was established under

the Taking Control of Goods Regulations 2014. At the

time the regulations were drafted, the Government

commissioned economic analysis to design an effective

fees mechanism. The economist recommended

adjusting fees annually to track inflation. Since the

statutory fees were introduced in April 2014, inflation

has eroded their real value by 24%.

Annual inflation review

The Ministry of Justice included an annual inflation

review and implementation mechanism in the

Explanatory Memorandum to the Taking Control

of Goods (Fees) Regulations 2014, intending it to be

incorporated into the regulations.

The Ministry has acknowledged that infrastructure

and reform costs were not foreseen in the original

2014 statutory fees, including advanced technology for

vulnerability identification and support, body-worn

video, tracking and tracing services, independent

advisory groups, and the Enforcement Conduct

Board.

Ensuring enforcement agents receive appropriate

remuneration is essential for maintaining a sustainable

service and attracting new professionals to the field.

Between August 2017 and January 2023, the number

of certificated enforcement agents decreased by 33%.

There are few instances where private contracts

with public sector bodies have fixed prices. Legal aid

provision serves as a close example; however, many

firms closed due to fees not being increased regularly

enough to prevent market collapse.

This situation also contrasts with significant fee

increases at HMCTS during the same period and with

Scotland, where enforcement fees have increased five

times over the same timeframe.

Civil Enforcement Association CIVEA members

collect approximately £2bn annually in outstanding

debt for numerous local authorities, businesses,

and individuals across England and Wales. CIVEA's

research indicated that civil enforcement prevents

losses to the public purse estimated at £12bn. Effective

debt recovery helps prevent today’s creditors from

becoming tomorrow’s debtors.

Supporting growth

In February, Justice Minister Alex Davies-Jones MP

stated that the enforcement sector plays an important

role in supporting economic growth, funding public

services, and underpinning the rule of law. This

underscores the importance of civil enforcement in

maintaining revenue streams for local governments

and ensuring social justice.

A viable enforcement fee structure is critical to

achieving this. Without it, there is a higher risk of

unpaid debts, leading to decreased confidence in

the system, potential discouragement of investment,

reduced funds for local councils, and jeopardised

economic growth.

The approach to reviewing fees is not new. It was

originally established in the Tribunals, Courts and

Enforcement Act of 2007, introduced by the previous

Labour government, which led to the Taking Control

of Goods Regulations.

This spring, the Ministry of Justice plans to increase

171 court and tribunal fees to reflect changes to

the Consumer Price Index (CPI). However, the

enforcement sector continues to await secondary

legislation to enact a nominal 5% uplift approved by

the previous administration based on 2022 figures.

Timely revisions

The civil enforcement sector faces numerous

challenges due to this outdated fee structure. Without

timely revisions to the fees, smaller enforcement

firms are at risk of collapsing, which would lead to a

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


CREDIT MANAGEMENT

MANY DEBT COLLECTION AGENCIES

EXEMPLIFY RESPONSIBLE DEBT

RESOLUTION PRACTICES, AND

THEIR INNOVATIVE APPROACHES

INCREASINGLY LEAD THE WAY IN

MODERN ENFORCEMENT.

monopolized industry dominated by a few large players.

This reduction in competition could result in service

failures and diminish the ability of local authorities

to efficiently enforce debts. Ensuring a viable fee

structure is essential not just for the continuation of

enforcement services but also for maintaining public

confidence in the system.

In addition to debt collection, enforcement agents

play a crucial role in identifying and signposting

vulnerable individuals to welfare support. Last

year, they identified 351,000 vulnerable individuals

unknown to councils. Many debt collection agencies

exemplify responsible debt resolution practices, and

their innovative approaches increasingly lead the way

in modern enforcement.

An industry that stands still quickly becomes

irrelevant. The civil enforcement sector must remain

dynamic and forward-looking, constantly adapting to

new challenges and opportunities. It is imperative to

lead the way in ensuring the industry remains fit for

purpose and enforcement is conducted responsibly.

Given it has been over 10 years since the Taking Control

of Goods Regulations were introduced, it is high time

to review and update the fee structure to better reflect

current economic realities. Governments must seize

this unique opportunity to ensure fair treatment and a

fair fee structure that aligns with the costs of delivering

these crucial services.

Author: Russell Hamblin-Boone is CEO of the Civil

Enforcement Association.

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


INTERVIEW

FAMILY

TIES

Sean Feast FCICM speaks to two

members of the Advisory Council

with a family connection.

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


CREDIT MANAGEMENT

Both Josh and Charles

share a love of classic cars

and motor racing.

CHARLES Mayhew FCICM and his

son Joshua Mayhew MCICM have

recently been elected to the CICM

Advisory Council and as father

and son their election is a rarity in

the annals of the Institute’s history.

Sean Feast FCICM caught up with

them both while the pair were en route to their offices

in the United Arab Emirates.

SF: What careers’ advice did you receive at school?

JM: Honestly, I can't really recall ever getting

dedicated careers’ advice whilst at school. I attended

a boys grammar school (Maidstone Grammar School

for boys) and I think that the attitude was very much

steered towards university. I did achieve four A Levels

but when it came to further studying, I already knew

that I wanted to get into the world of work rather

than paying to study for a further three years. At the

time, amongst my peers, this was quite ‘out there’ but

I think it’s definitely much more common today and

certainly paid dividends for me.

CM: I was going to join the police and the school

encouraged it. We had some great role models in

our school including Lorna Duggleby for French and

academic studies (she later became head teacher at

Bromley High School) and Rob Probyn for Rugby.

Both were amazing, encouraging but tough, nononsense

teachers.

SF: What did you want to be when you grew up?

JM: Charles and I have always loved motor engineering

and classic cars/racing so that world always excited

me, but being 6ft 5ins tall and 120kg does not suit a

racing driver, so credit and collections it was!

CM: I wanted to be a Policeman and join the Police

cadets at 16. Unfortunately, by the time I reached 16

they had phased this out, so it wasn’t an option.

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

continues on next page >


INTERVIEW

Josh was a professional rugby

player and still has a passion for

the game.

SF: How did you get into the world of credit?

JM: Inevitably, through Charles, somewhat. I worked

at ASDA through my sixth form studies and as soon

as school was finished, I applied at Cabot Credit

Management as it was close to the family home and I

already knew a few people there through the local area

and Dad. I worked there for more than three years,

latterly as a pre-litigation officer. (Josh spent his first

four months within Cabot’s collections department

before being asked to join FIRE Ltd in August 2010.

This was Cabot’s last stage of telephone collections

and, after a merger in June 2012 with Morgan

Solicitors, also its in-house litigation department. He

dealt primarily with the settlement of defaulted and

ongoing debts, alongside dealing with accounts post

litigation action.)

CM: A sales career dropped me into the world of

credit in 1994, working for STA Graydon. (Charles

spent almost 10 years with the business at the start

of a career that now spans more than 30 years. He

has been a European Board member of ICTF, the

owner/director of Moreton Smith, and is a partner at

CoCredo.)

SF: What do you do now/what is your current role?

JM: I am Managing Director at Global Credit

Recoveries, helping to recover funds globally on a no

recovery, no fee basis. I am also Chair of the CICM

Kent Branch and sit on the Advisory Council for the

CICM. I am also a husband, and dad to a fantastic

two-and-a-half-year-old daughter.

CM: I am CEO of Global Credit Recoveries, a role I

have had since August 2018, dividing my time between

our offices in London and Dubai.

SF: When did you first come across the ICM (CICM)

and why?

JM: From a young age I have always known of

the CICM, likely from being when I was 16 and

doing work experience at one of Charles's previous

collection agencies. The CICM has played a huge role

in my career already and I sincerely look forward to

the input I can have over the span of my career - if

they keep me around! I first got involved around 2018

when Global Credit Recoveries was conceived, with

a view to networking and knowledge sharing. The

professional network within the CICM is absolutely

immense, and you quickly find that everyone within

the industry is very happy to share their expertise and

their time to helping younger credit professionals

exceed. There are far too many people for me to

mention, but it’s a wonderful group.

CM: I first came across the ICM (as it was then) in

1994. I was establishing an office for Stanley Tulchin

of STA Graydon (the initials ‘STA’ came from Stanley

Tulchin Associates) and he said it would be a good

idea to get involved with the Institute. I have now

been a member for more than 27 years.

SF: As part of the Advisory Council, how do you

think you can help the CICM moving forwards?

JM: I say that the key thing for me to is try and attract

younger credit professionals into the community. It’s

something that appears to be missing a little, especially

with those finishing their studies, but I am pleased to

confirm that the Advisory Council is already working

on this. More to come on that space! It has also been

a pleasure to work with other Southern Branches

creating the annual Southern Branches CICM Event,

which is coming into its third year in September. It’s

getting bigger and better every year! Save the Date –

18 September 2025 at Brands Hatch Racetrack, Kent.

(There’s the racing again....)

I hope that I come across as someone that anyone in

the industry, or hoping to be part of our industry, can

approach with any questions. I am very happy to share

a virtual call, coffee, etc with anyone that’s interested

or has any ideas.

CM: I hope I can contribute by way being an ‘ideas’

person with a keen business acumen, that will help in

promoting the CICM to an even wider audience.

SF: Josh - in your opinion, what are the principal

strengths (i.e. best qualities) of your dad?

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


CREDIT MANAGEMENT

THE PROFESSIONAL

NETWORK WITHIN THE

CICM IS ABSOLUTELY

IMMENSE, AND YOU

QUICKLY FIND THAT

EVERYONE WITHIN

THE INDUSTRY IS VERY

HAPPY TO SHARE

THEIR EXPERTISE.

Josh claims that his father, Charles, occasionally gets mistaken for his brother.

JM: We are very fortunate that Charles and I

complement each other very well – he occasionally

gets mistaken for my brother not father, which he

doesn’t let me forget. Operationally, I manage GCR

on the day-to-day, but Charles's wealth of experience

from previous agencies gives us a real advantage

when forecasting our targets and goals. I have a lot

of ambition when it comes to GCR, but Charles is

often the voice of reason - as a result of that mixture of

excitement and tried and tested methods - we have a

business which has beautifully grown organically over

the past eight years.

In saying that though, the decision to open our UAE

office three years ago was one that gave us plenty of back

and forth. Ultimately, when we sat together alongside

our management team, the depth of knowledge and

understanding that Charles has within the region,

matched with the desire to grow our offering globally,

led us to pushing forward with this. This turned out to

be a great idea and that office is now looking to expand

further in 2025.

SF: Charles – in your opinion, what are the principal

strengths (i.e. best qualities) of your son?

CM: He’s hardworking, and has the ability to learn

and adapt, and bring a younger person’s viewpoint

- many of the traits he learned playing rugby (Josh

was a professional rugby player in New Zealand and

Australia).

SF: What would you change about him?

JM: An important thing for both of us is definitely

keeping our mental and physical health in check. I am

always checking in with Charles to ensure that he is

getting his daily swim in and taking enough time to

unwind and relax. With the amount of travelling we

do seeing clients globally (I type this from an Emirates

flight to the UAE) its integral that we do find the time

to relax. I would like him to switch off a little more.

CM: I’d give him more patience and tell him sometimes

to slow down.

SF: If you weren’t doing what you are now, what

would you be/where would you be?

JM: I do believe I would have always found my way

into the credit world, but maybe I would still be trying

to push my rugby career forward. Who knows? I’m

very happy and proud to be working with my dad – I

wouldn’t change it for the world.

CM: I probably would have joined the services,

although at one point I was going to train to be a deepsea

diver.

SF: And that seems a good place to end!

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


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


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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

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assess credit risk and make the best, most informed

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Key IVR provide a suite of products to assist

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

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OPINION

ROUGH

JUSTICE

The wrong increase at the wrong time.

BY ROB THOMPSON, FCICM

ON 8 April 2025, some 171 court fees

were increased in line with inflation.

Most were increased by 3.2% to reflect

the increase in the Consumer Price

Index (CPI) over the previous year.

Hearing fees in the fast and multitrack

increased a whopping 13.5%,

representing the increase in the CPI over the last two years.

In normal circumstances, linking court fees to inflationary

increases would not be controversial. It could well be seen

as sensible. However, recent circumstances have been far

from normal. Let’s take a look back over the last decade

or so.

Front loaded

As a starting point, consider that court fees are front

loaded. When issuing a money claim over £10,000, the fee

is 5% of claim value. For claims over £200,000, the fee is

capped at £10,000. Just as well. That is an obscene amount

of money just to issue a claim. It doesn’t cover any further

work, such as court hearings. The vast majority of money

claims conclude with a default judgment, requiring the

bare minimum of administration. It may not be ‘money for

nothing’, but it often comes close.

We then had the introduction of so-called ‘enhanced court

fees’. These enable fees to be charged which exceed the cost

of providing the service. Since their introduction, civil

court users cover the entire cost of the civil courts, plus a

significant contribution to the financing of the family and

criminal courts.

For years, bulk users in the civil courts had been encouraged

to issue their claims digitally. In return, digital issue fees

were discounted. However, as digital claims increased and

paper claims declined, the decision was taken to ‘align’

the fees. Would they align downwards? That would seem

logical, since the mission had been accomplished, and most

claims were now digital. Or would the fees maybe align

halfway between the two? Oh no, court users were then

expected to pay the higher ‘paper’ fee, for the cheaper-toprovide

‘digital’ service.

Lauded reforms

Then we’ve had the much-lauded court ‘reform project’

A supposedly five-year project launched in 2016 and

‘concluding’ last month, some nine years later. Over

that time, we’ve learned what was meant by ‘reform’.

Centralisation, digitalisation, streamlining and cost saving.

No real, fundamental reform of processes, many of which

are decades old and crying out with opportunities for

improvement to deal more effectively with the modern

world.

A civil court system which is arguably now more

fragmented than when the so-called reform started, with

multiple platforms, including the new OCMC alongside

MCOL, but with bulk users left behind and unable to

participate. Systems and processes half-built, partially

online, but still no change to enforcement processes, which

is where the real opportunities were always to be found.

In the meantime, court files are destroyed earlier and

earlier in the name of data security, but the real purpose

clearly being cost saving. Court users forced to recreate

the destroyed court file in order that a further step can

be taken. The court user serving the court service, despite

having paid a fortune for a service which has then been

ended prematurely.

Poor service

Finally, an ongoing poor level of service plumbed even

greater depths following the pandemic and continues to

struggle to recover, with huge delays and administrative

issues only now beginning to be finally brought under

control.

And whilst court fees enjoy the luxury of inflationary fee

increases, the same is denied to private sector enforcement,

who are expected to continue to maintain standards with

ever dwindling margins.

The court service exists to provide justice for the benefit

of court users. It is not there purely to generate revenue

for the state, providing a bare minimum service in return.

That needs to be remembered. In the circumstances, this

was an extremely inappropriate and unjustifiable time for

fee increases.

Author: Rob Thompson FCICM is Chair, Civil Court Users

Association (CCUA).

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


COUNTRY FOCUS

on Saudi Arabia

The pitcher

and the well

There is more to Saudi Arabia

than sand and oil.

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


CREDIT MANAGEMENT

SAUDI Arabia is a relatively new construct

as countries go. Known for its application

of Islamic principles and the birthplace of

the religion, the country is thought of – by

many who don’t really know it – as a place

of just oil and sand.

But of course, there’s more to Saudi Arabia if we consider

the Jeddah Floating Mosque, Arabic calligraphy, the Shada

Mountain caves, desert safaris – either by 4x4 or camel, and

the King Fahd International Airport in Dammam City –

the largest airport in the world.

And let’s not forget that in 2034 the country will be hosting

the FIFA World Cup tournament which will no doubt

provide a fillip for the economy.

A melting ice cap

Evidence of humans in the Arabian Peninsula dates back

15,000 to 20,000 years, living off wild animals and plants.

After the European ice cap melted after the last Ice Age,

the climate became dry; plains once covered with lush

grasslands gave way to deserts.

Located between the Nile River Valley and Mesopotamia,

the Arabian Peninsula became the crossroads of the ancient

world, especially in terms of trade.

The peoples of the region remained largely untouched by

the political turmoil elsewhere with their goods in great

demand regardless of whichever power was dominant.

The early 600s saw the birth of Islam and within 100 years

an Islamic Empire extended from Spain to parts of India

and China. Arabic emerged as the language of international

learning and Muslim scholars made major contributions

to many fields including medicine, biology, philosophy,

astronomy, arts and literature.

Come the 17th century the empire broke up into smaller

Muslim kingdoms and the Arabian Peninsula entered

a period of relative isolation. The First Saudi State was

formed in 1727 and prospered, ruling over the entire central

plateau; by the early 19th century it took in most of the

Arabian Peninsula. Ottoman forces effectively ended the

state in 1818 following an invasion.

A Second Saudi State came into being in 1824 and within 11

years had regained most of the lands lost to the Ottomans.

But a second campaign by the Ottomans, in 1865, led to the

end of that state some 25 years later.

The state’s hierarchy eventually fled to Kuwait where it

stayed until 1902. But a scion of the ruling family then

marched into Riyadh and took control. With the collapse

of the Ottoman Empire, by September 1932, the country

had become the Kingdom of Saudi Arabia.

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

continues on next page >


COUNTRY FOCUS

The Prophet's Mosque is the second mosque built by the

Islamic prophet Muhammad in Medina, after the Quba Mosque,

as well as the second largest mosque and holiest site in Islam,

after the Masjid al-Haram in Mecca. the Saudi region of the

The Gulf of Aqaba in the northwest separates Saudi

Arabia from Egypt and Israel. Notably, Saudi Arabia

is the only country with a coastline along both the Red

Sea and the Persian Gulf.

Sand covers a significant part of the country – around

33% or 635,000km2. Most of the sand clusters are

concentrated in the east and southeast of the kingdom.

However, there are mountainous areas as well as plains;

mountain ranges traverse the Kingdom's length - Hijaz

and Aseer mountains have peaks above 3000m. But it

is the central region with its deserts and rocky plateaus

that account for 90% of the overall area.

Saudi Arabia has no permanent rivers, and the country

is considered deficient in water.

Growing population

According to the CIA World Factbook the 2024

population stood at 36.5m with males making up

20.7m, and females 15.8m, of the total.

If we look at a UN World Population Prospects, we see

how the population has grown over the years – from

3.91m in 1960, to 10.1m in 1980, and 35.9m in 2020. The

growth rate over the same was 3.2%. 5.06% and 0.47%.

It is now 1.38%

In 1938 they discovered oil. In 1960 Saudi Arabia

helped to found the Organisation of Petroleum

Exporting Countries (OPEC) and in 1973 led an oil

boycott which saw a quadrupling of the price. In 1990

Saudi Arabia asked the US to intervene in the Iraqi

invasion of Kuwait. In recent years the country has

liberalised – a little.

Central geography

The Kingdom is located in the centre of the Middle

East and is bordered by the Red Sea to the west;

Jordan, Iraq, and Kuwait to the north; the Persian

Gulf, Bahrain, Qatar and the United Arab Emirates

to the east; Oman to the southeast; and Yemen to the

south.

As for area, Saudi Arabia is placed 12th in the global

rankings with 2.15m km2. It sits below the Democratic

Republic of Congo (2.34m km2) but above Mexico

(1.96m km2). The usual comparison with the UK shows

it a minnow being placed 78th with just 244,376 km2.

The population pyramid is mostly what one would

expect from a modern country – it has narrow base

with a minor bulge at age 10-14 which constricts again

before expanding once more in the 30-49 age bracket.

From there on it tapers to age 60 and markedly more

so to age 89. In general, the age brackets are reasonably

symmetrical with one exception – a huge imbalance

in favour of males between 35 and 49. This has been

largely explained by SpringerLink which noted that

‘the very high sex ratios of Arabian Gulf countries are

… due to excess male labour force from East Asian and

African countries.’

Ethnically speaking, the CIA reckons – logically

– that it’s 90% Arab and 10% Afro-Asian. Arabic

is the official language. However, Australia-based

Cultural Atlas reckons that Arabic is spoken by 51.6%

of the population, English by 16.2%, Urdu by 14.8%,

Malayalam by 7.4%, and ‘other’ by 8.9%.

As to where the population lives, until the 1960s,

most were nomadic or semi-nomadic. But due to

rapid economic and urban growth, more than 95% are

now settled and 80% of Saudis live in 10 major urban

centres.

According to Investment Monitor, using December

2022 data, Riyadh has 7.68m residents, Jeddah 4.7m,

Mecca 1.58m, Medina, 1.18m, Dammam 1.25m, Al-

Mubarra 837,000, Taif 695,000, Tabuk 670,000,

Buraydah 669,000, and Jubail 680,000.

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


CREDIT MANAGEMENT

x Sindalah is a luxury

island destination

in Tabuk Province,

Saudi Arabia, home to

kaleidoscopic-coloured

coral reefs and an

abundance of diverse

marine life.

It’s worth noting that Saudi Arabia employs millions

of foreign workers. Argaam.com reported in January

2025 that the number of workers reached 17.2m by the

end of Q3 2024 (General Authority for Statistics).

Most of the workers in Saudi Arabia are in the private

sector (66%), followed by Government (7%), public

sector (3%), and domestic workers (23%).

The number of foreign workers in Saudi Arabia

reached about 13.2m, representing 77% of the total;

Saudi workers numbered four million, or 23% of the

total.

Saudi Arabia is, it should be said, building a new city

at the north end of the Red Sea, Neom, at a cost of

some $8.8tn. It’s expected to be completed by 2039.

Expanding economy

Worldmeters, using 2023 data, places Saudi Arabia’s

economy as the 19th largest in the world with a GDP

of $1.06tn. Turkey is 18th ($1.18tn) and Switzerland

is 20th ($884.9bn). In comparison, Canada is 10th

($2.14tn), UK 6th ($3.37tn) while the US is placed first

($27.7tn).

If we look at growth rates, the World Bank details some

spectacular rates and a dramatic peak (52.6% in 1970)

and less dramatic trough (-16.1% in 1980). There have

been the odd years of sub 1% growth, but in general,

anywhere between 5% and 11% is normal for Saudi

Arabia. In comparison, the UK has seen peaks and

troughs, but which maintain a sawtooth profile with

highs until 2000 of around 5% and lows of -2.5%. But

over the last 25 years the peaks have been nearer 3%.

And as for inflation, apart from a 34.58% peak in 1975

Saudi inflation appears generally stable at no more

than 5%.

Business sectors

Oil and gas

Not unsurprisingly, oil and gas are the bedrock of

the Saudi economy. The US International Trade

Administration, citing OPEC data, says that the

Saudi’s possess around 17% of the world’s proven oil

reserves and the country is one of the largest exporters

of oil.

An IMF publication, Saudi Arabia: 2024 September

Article IV Consultation-Press Release; and Staff

Report, published February 2025, noted that oil

accounts for approximately 30% of Saudi GDP and

55% of Government revenue – subject to substantial

fluctuations depending on oil prices - each year.

However, the Government has seen the future and is

looking at a net-zero economy by 2050. It is investing

in areas such as cleaner conventional engines, carbon

capture, utilisation and storage, hydrogen, and

renewables.

State producer Saudi Aramco reported a workforce of

approximately 75,100 in 2024, up from approximately

56,000 in 2011. Given the size of the company, it needs

to spend well in terms of capital expenditure. Indeed,

the US noted that in March 2023, Aramco had set a

capital expenditure goal of $45-$55bn in FY2023 to

support an increase in oil production to 13m barrels

per day by 2027. Opportunities exist in relation to

exploration and production, equipment and services,

and refining.

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


COUNTRY FOCUS

Ca

It’s well known that the country is on a journey of

reform. As part of this, in 2018, the Government

ended a 30-year ban on cinemas. Consequently, by

April 2022, there were 56 cinemas and a Media City

in Riyadh. Allied to this are theme parks, live events,

and sports-related infrastructure.

Chemicals

With ready availability of raw materials, Saudi Arabia

has a chemicals sector run by Saudi Aramco.

In 2024, Management consultants IMARC Group

reported that the country’s speciality chemicals

market size reached $7.2bn in 2024. Looking forward,

IMARC Group thinks that figure will rise to reach

$10.4bn by 2033 following a growth rate of 4.17%

between 2025-2033. Fundamentally, it says the need

for high-performance and function-specific chemicals

across different end use industries, such as oil and

gas, pulp and paper, personal care, etc., is primarily

driving the market growth.

Interestingly, Mordor Intelligence thinks that the

market was worth $11.29bn in 2024 and will worth

$15.20bn in 2030. One of the two reports may be right.

The move away from oil is well documented in Vision

2030 – the country’s plan to reduce its dependence on

oil, diversify its economy, and develop public service

sectors. However, CityAM wrote, in July 2024, ‘the

plan doesn’t mean by any sense that manufacturing

and the production of vital raw materials will fall

away. In fact, one of Saudi’s most thriving sectors is

the chemicals industry, which employs some 89,000

and provides indirect employment for at least three

times as many across the Kingdom.

Construction

With the development of Neom and other projects,

this sector has grown somewhat. Big 5 Construct Saudi

reckoned that by the end of the fourth quarter of 2022,

the sector in Saudi Arabia employed approximately

2.46m workers (those covered by social insurance

regulations). The sector was valued at $120.4bn in 2021

and between 2023 to 2026 should grow by 4% a year

according to a report from Gulf Business.

The reason for the growth is the substantial

investments in transportation, renewable energy,

housing, and tourism projects, aligned with the

Vision 2030. Big 5 Construct Saudi sees construction

as playing a pivotal role in this, especially as there are

over 5,200 ongoing projects worth a combined total

of $819bn.

Tourism

The US Government highlights that travel, tourism,

and entertainment is a priority sector under Saudi

Arabia’s Vision 2030 plan.

Saudi Arabia’s plans suggest that there will be more

100m visitors annually by 2030. It is facilitating the

opening of its UNESCO World Heritage sites, the

construction of resorts on its Red Sea coast, and the

launch of a cruise line. The country is investing in

sports teams, infrastructure, and events at home and

abroad, from football to golf to Formula 1 to video

games – and the World Cup. There’s also the annual

Hajj pilgrimage with 2m visitors. But the jobs created

by the Hajj are temporary. It generates $2–3bn in

revenue.

Argaam.com states that the number of workers in

the tourism sector increased by 5% year-on-year to

approximately 959,200 workers in Q2 2024. And the

World Travel and Tourism Council reported that the

sector contributed $131.9bn to the Kingdom's economy

in 2024, representing 12.45% of GDP.

Other

Despite being a desert, largely, Saudi Arabia has

regions where a small agricultural sector can thrive –

one that is worth, according to Mordor Intelligence,

$19.75bn. It is the world’s largest exporter of dates

(in 2022, $341.5m from a volume of 321,000 tons). As

for other products, in 2021 Report Linker said barley

production was 673,100 tons, and in 2025, World Grain

reckons that wheat production will be 1.5m tons.

There are other aspects to the sector with millions of

head of sheep, goats, camels and cattle.

Saudi Arabia possesses some minerals – gold,

silver, iron, copper, zinc, manganese, tungsten,

lead, sulphur, phosphate, soapstone, and feldspar;

resourcegovernance.org reckons that the estimated

value of unexploited mineral resources in Saudi

Arabia is around $2.5tn (2024). And as part of its

goal of economic diversification and reduce reliance

on oil, Saudi Arabia aims to increase the mining

industry’s GDP contribution from $17bn to

$75bn by 2035.

Summary

Saudi Arabia is clearly a country of

vast wealth that is transitioning away

from a dependence on oil. Given

its position in the Middle East, it

would be foolhardy to ignore it as

a destination for export. However,

visitors need to very carefully

observe its laws and etiquette.

Author: Adam Bernstein is a freelance

finance writer for CM magazine.

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


BRANCH NEWS

FRESH VISION

AND PURPOSE

The CICM North West Branch Re-launch.

ON a bright and sunny afternoon

in Manchester, the CICM North

West Branch marked a significant

milestone with an official re-launch

event held at the Hays office on

10 April. A warm thank you to

Hays for graciously hosting us and

providing a fittingly bright backdrop for what proved to

be a vibrant and optimistic occasion.

This was more than just a gathering; it was the first step in

revitalising the branch and reaffirming our commitment

to serving credit professionals across the region. We are

sincerely grateful to all who attended and contributed to

such a promising start.

We’re excited to share our refreshed vision and goals as

we look ahead. Our aim is to become the leading branch

in the CICM network. At the heart of this ambition is

our commitment to putting members first—your voice,

feedback, and participation will shape everything we

do. We’re also keen to bring branches together more

often, with joint events and greater opportunities

for networking. Together, we believe we can achieve

remarkable things.

We are pleased to introduce the new committee guiding

this renewed direction: Paul Quinti FCICM serves

as Chair, Laurie Beagle FCICM takes on the role of

Secretary, and Jacqueline Hitchen FCICM (Grad) joins as

Treasurer. Supporting the leadership team are committee

members Chris Hardman MCICM, Peter Gent FCICM

(Grad), Xerxes Stallworthy ACICM, and David Thornley

FCICM (Grad).

recovery, and insolvency was delivered by Ross and Kevin

Lucas of Lucas Ross Ltd. The event concluded with an

open forum where members were invited to share their

ideas and expectations for the branch going forward.

Looking ahead, the 2025 event calendar is already shaping

up. Plans include a virtual event (date to be confirmed),

Credit Fest on 23 September, a joint branch event in

October, and a festive end-of-year social. Networking

opportunities will continue throughout the year to help

members connect, collaborate, and grow.

We’re thrilled with the energy and enthusiasm that

marked this re-launch. Thank you once again to everyone

who supported the event—and to our generous hosts and

brilliant speakers. If you didn’t receive an invite this time,

let us know and we’ll make sure you’re included in our

future events.

Author: Laurie Beagle FCICM.

The day featured a rich programme of presentations

and discussion. Chair Paul Quinti opened with an

overview of our branch’s new direction, followed by a

recruitment update from Natascha Whitehead FCICM,

Senior Business Director at Hays, who shared insights on

navigating market challenges. Luke Sculthorp FCICM

brought news from CICM HQ, offering a look at what’s

in store for 2025. A compelling session on business rescue,

Dear Branch Members,

If you have a branch event that you would like to be featured in the CM magazine, please submit your article to the Art Editor.

Articles should be no more than 400 words, and if you are providing images, they must be of high quality for print.

Please note that inclusion is subject to space and the editor’s approval. We look forward to showcasing your branch activities!

Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 37


ENFORCEMENT

REMEDIAL

ACTION

Why backing the Civil Justice Council’s

Enforcement Report matters.

BY ALAN J. SMITH

HIGH Court Enforcement Officers

Association (HCEOA) is calling

for action to implement the recommendations

of the Civil Justice

Council’s (CJC) recent report on

Enforcement as it will benefit

creditors, debtors, and the wider

justice system.

The CJC’s newly published report on enforcement

represents a significant step forward in efforts to

modernise and improve the way judgments are enforced

in England and Wales. As a profession with deep,

practical experience of what works in practice, the

HCEOA has welcomed the report’s impartial, balanced

recommendations and is urging the Government to take

swift action to bring about the reforms outlined.

For those unfamiliar with the workings of the enforcement

sector, it’s easy to overlook the pivotal role it plays in

supporting the rule of law and underpinning economic

confidence. When people and businesses are awarded

judgments, they have the right to see those judgments

enforced effectively. Without a fair and functioning

enforcement system, the justice process breaks down, and

trust in the system starts to erode.

That’s why the CJC’s aim of delivering ‘a fair and effective

enforcement system’ resonates so strongly with us. It’s also

clearly something that aligns with public expectations:

Our 2024 perception research showed that 83% of

respondents agreed or strongly agreed that enforcement

is a necessary part of the justice system.

At the heart of the report is a long-term recommendation

for the creation of a single unified digital court for the

enforcement of judgments. We support this goal in

principle. As with any reform, the devil is in the detail.

It’s crucial that such a digital system gives creditors

real choice, including the ability to select High Court

enforcement if that is the most appropriate and effective

route. For this to happen, the government must act

on the report’s recommendation to bring Part 4 of the

Tribunals, Courts and Enforcement Act 2007 into force.

Doing so would provide enforcement professionals and

creditors with controlled access to important financial

information about debtors, helping everyone involved to

make informed, fair decisions.

One of the more immediate recommendations in the

report addresses the current pressures on the County

Court system. Anyone familiar with day-to-day court

operations will know that the County Court is under

severe strain. The report reflects this reality, describing

the system as ‘under-resourced and overburdened’, and

highlighting widespread concerns among court users.

There’s a straightforward, practical solution that would

help – give creditors the choice to use High Court

enforcement for debts under £600. Currently, these

smaller debts must be enforced through the County

Court. This is a change we have long championed, and

it’s one that court users clearly support. Our ‘Freedom of

Choice’ research found strong backing for this proposal,

which can be implemented without additional cost to the

debtor by using the non-High Court fee scale.

This is not about pushing out County Court bailiffs

– it’s about relieving pressure on the system and

providing more effective service for everyone. That

includes protecting vulnerable debtors. The CJC rightly

emphasises that any extension of HCEOs’ powers must

come with robust safeguards. These safeguards already

exist. National Standards issued by the Ministry of Justice,

the Enforcement Conduct Board’s (ECB) new standards

and independent complaints procedures, and oversight

mechanisms all work together to ensure accountability

and fairness.

Of course, the CJC’s report goes beyond High

Court enforcement. It includes a series of broader

recommendations, such as simplifying court forms and

making legal language easier for users to understand.

While these proposals sit outside our direct remit,

we support them as part of a thoughtful, joined-up

programme of reform that must involve the Ministry of

Justice, HMCTS, the ECB, and other key stakeholders.

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


CREDIT MANAGEMENT

Ultimately, reform needs to be about more than just

systems and structures; it’s about delivering a justice

system that works for everyone. That means efficiency,

but also fairness, clarity, and accessibility. Enforcement

isn’t about punishment; it’s about ensuring that

people can access the remedies they’re entitled to

and that those remedies are delivered in a way that’s

proportionate and respectful.

We believe the CJC report has laid a strong

foundation. The HCEOA and its members stand ready

to support delivery of this reform agenda. We are not

just implementers – we are stakeholders, partners,

and experts. And we’re committed to working with

government and regulators to build an enforcement

system for the future that delivers better outcomes for

all.

Author: Alan J. Smith is Chair of the High Court

Enforcement Officers Association (HCEOA).

THIS IS NOT ABOUT

PUSHING OUT

COUNTY COURT

BAILIFFS – IT’S

ABOUT RELIEVING

PRESSURE ON

THE SYSTEM AND

PROVIDING MORE

EFFECTIVE SERVICE

FOR EVERYONE.

Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 39


HR MATTERS

RAIN

OR SHINE

The challenges of speculating, age, and umbrella companies.

BY GARETH EDWARDS

IN Gourlay v West Dunbartonshire Council,

the claimant, a corporate health and safety

officer, was dismissed for gross misconduct.

He successfully brought claims for unfair

dismissal, disability discrimination, and

victimisation, with the tribunal accepting

that the respondent’s discriminatory

treatment left him permanently unfit for work due to

severe depression.

At the remedy stage, the tribunal calculated the

claimant’s past and future wage loss and pension loss.

However, it then reduced the award by 80%, based on

two key assumptions:

That the claimant’s employment would have ended

by 2017, either through a breakdown in working

relationships or a mutual agreement to leave; and that

the claimant might have taken ill-health retirement

due to pre-existing conditions (multiple sclerosis and

Type 2 diabetes), regardless of his depressive illness.

The claimant appealed, arguing that the tribunal’s

compensation reduction was legally flawed. The EAT

upheld his appeal and found that the tribunal made

errors in how it assessed financial loss.

The purpose of compensation in discrimination

claims is to restore the claimant to the position

they would have been in had the employer not acted

unlawfully. The tribunal wrongly assumed that the

claimant would have been lawfully dismissed within

a few years. However, because the discriminatory

dismissal caused his inability to work, the tribunal

needed to consider whether a lawful dismissal would

have had the same effect. There was no evidence to

suggest that it would have.

The tribunal also wrongly speculated that the

claimant might have retired early due to other health

conditions. The EAT found that this assumption was

made without any medical evidence and contradicted

the expert psychiatric opinion that the claimant’s

condition was caused entirely by the respondent’s

unlawful treatment. As a result, the EAT overturned

the 80% reduction and remitted the compensation

assessment to a new tribunal.

Compulsory retirement

In Scott v Walker Morris LLP, the claimant was an

equity partner at Walker Morris LLP; his relationship

with the firm was governed by a members' agreement.

The claimant was due to retire on 30 April 2020, in

accordance with the retirement policy for partners in

the members’ agreement. The policy allowed partners

to apply for an extension to their membership if

they wished to continue working beyond the age of

60. A partner could apply for an extension of up to

three years if they could demonstrate an ‘exceptional

contribution’ to the firm. After the first extension,

a further request could be made at age 63 to extend

membership until the age of 65.

Under the Equality Act 2010, age is a protected

characteristic. Direct age discrimination occurs when

an individual is treated less favourably because of their

age and the treatment cannot be justified. Justification

must be both legitimate and proportionate and

supported by evidence.

A PARTNER COULD

APPLY FOR AN

EXTENSION OF UP

TO THREE YEARS

IF THEY COULD

DEMONSTRATE

AN ‘EXCEPTIONAL

CONTRIBUTION’

TO THE FIRM.

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


CREDIT MANAGEMENT

In this case, the respondent admitted that the

termination of the claimant's membership due to his

age constituted less favourable treatment. However, it

argued that its actions were justified as a proportionate

means of achieving legitimate business objectives, such

as protecting the firm’s interests and ensuring intergenerational

fairness among its partners.

The tribunal focused on whether the justification was

proportionate. The respondent argued the policy helped

maintain a cohesive and collegiate atmosphere among

partners, avoiding potentially difficult and degrading

performance management of older partners. Second,

it suggested that the policy supported workforce and

succession planning, ensuring that there were enough

partners to maintain the business’s profitability and

stability.

However, the tribunal found that while these aims were

legitimate, the firm's approach was not an appropriate

or reasonably necessary means of achieving them. The

tribunal noted that the respondent couldn’t show that

poor performance at partner level was an issue, or

that the policy contributed to workforce or succession

planning.

Additionally, the tribunal found that less discriminatory

alternatives could have been implemented. The tribunal

concluded that while the firm's aims were valid, its

approach was not justified as a proportionate means of

achieving them.

Umbrella companies

HM Treasury published the Government’s response

to its consultation on tackling non-compliance with

employment rights and tax obligations by umbrella

companies.

The response confirms that the Employment Rights

Bill will be amended to define umbrella companies,

introduce a regulatory framework, and bring them

within the remit of the Employment Agency Standards

Inspectorate.

THE REGULATION

OF UMBRELLA

COMPANIES WILL

ALIGN THEM WITH

THE CONDUCT OF

EMPLOYMENT

AGENCIES AND

EMPLOYMENT

BUSINESSES

REGULATIONS 2003

The Government will define umbrella companies

with two key indicators – a company that employs

individuals with the purpose of supplying them to a

hirer, and an entity that manages payment for services

performed by individuals supplied to a hirer.

The regulation of umbrella companies will align them

with the Conduct of Employment Agencies and

Employment Businesses Regulations 2003, ensuring

consistency with existing rules governing employment

agencies and businesses. A statutory consultation will

be required before implementing any amendments to

the regulations.

Author: Gareth Edwards is a partner in the employment

team at VWV.

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


CAREERS

IN REAL-LIFE

How to make industry events worth your while.

BY NATASCHA WHITEHEAD FCICM

PICTURE this: you’ve come across

an event on your LinkedIn feed

and it sounds like an interesting

opportunity, so you register to

attend. You go along with all the

right intentions, grab a free coffee

and croissant, listen in to the

panellists, take a mental note of a few relevant pointers

and make a swift exit. The trouble is you arguably

can’t tap into the long-lasting value of industry events

just by simply going along – a more proactive

approach will undoubtedly pay off in the long run.

Here’s how to get the best out of events, before,

during and after attendance, to ultimately advance

your career.

Before

A little bit of prep work prior to the event goes a long

way. It’s a good idea to carry out some surface level

research about the organiser, the main topic or debate

and if there are any panellists, so you know what

you’re heading into. You could come up with a couple

of questions that you’d like to ask, so you can address

what you want to get out of the discussion to expand

your knowledge and support your role.

It goes without saying but for an in-person event,

be sure to map out your journey in advance to avoid

being late or arriving in a fluster. Similarly, if the event

is online, seek a quiet room to help you focus and

consider muting your emails or other communication

channels to limit distractions and fully immerse

yourself in the event.

During

Attending events, and hearing relevant presentations

from industry leaders, is one of the most effective

ways to stay up to speed with all the pressing topics

that are affecting the word of credit. To make the

most out of the valuable insights up for grabs, listen

actively and write notes about anything that strikes

you as interesting and useful.

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


CREDIT MANAGEMENT

instance. Attendees of credit circles often share legal

information on debtors and problematic customers,

which in turn will help you to know your customers

better and reduce credit risk to your business.

This goes both ways, as you can also give something back

to the industry and offer someone else a helping hand,

as they progress their career and navigate challenges

that they are facing within their own business. Be open

to offer your expertise, advice and recommendations.

After

Take a moment to reflect on the event including what

went well, what your key takeaways were, who you met

and how what you learnt this time around can benefit

you when it comes to future events.

Consider what your next steps are for continuing to

strengthen your network. You could reach out to a

key contact you made and arrange to meet for a coffee

to continue your conversation. Make sure you keep a

record of who you networked with so you can return

to this list should future opportunities arise to connect

again and support one another. Remember it’s not

all work and no play – networking and socialising go

hand in hand and it is amazing how quickly industry

contacts become friends!

Push yourself out of your comfort zone and strike up

a conversation with a stranger. A lot of people attend

events on their own, and are also feeling apprehensive,

so be brave and make the first move by asking

something light such as “how was your journey” or

“how’s business for you at the moment?”.

Take the prime opportunity to grow your network

by building new connections and sharing contact

details. People working in credit have their own web of

contacts across the sector and often refer each other for

new opportunities or projects, and attending industry

events will raise your own profile within the industry,

so you can utilise this vast network of professionals.

Networking at events enables you to get

recommendations that you may otherwise miss out on,

as your credit peers might be able to tell you about a

brilliant company that can automate your allocations

process, a new credit referencing agency or a business

that can implement AI into your O2C process for

A great way to raise your profile internally within your

own business is to bring information and new ideas

that you have acquired back into your organisation,

to support your team in their day-to-day roles and

to boost productivity across your company. You can

also have suggestions at the ready in terms of how to

implement your key learns into your role specifically

that your colleagues can learn from to support progress

and innovation. Talking to other credit professionals

about the challenges they’ve overcome and successes

they’ve achieved will hopefully give you a new

perspective and fresh ideas that you can take back to

your business. These could be anything from how they

incentivise their workforce or how they have built a

stronger relationship with sales.

Final thoughts

There is so much to be gained from industry events

by dedicating time beforehand to prep, clarifying

what you need from the event to enhance your career,

arriving with the right attitude, being approachable

and personable, actively engaging with the insights

available, offering your own and putting in some work

post-event to keep the ball rolling.

Author: Natascha Whitehead is Senior Business Director

at Hays specialising in Credit Management.

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


LITIGATION

FUNDING

LINES

Litigation funding: to regulate or not to regulate?

BY JONATHAN RUSH AND BARNEY STANNARD

THE litigation funding market in

England and Wales has grown

rapidly in recent years under a

largely self-regulated regime but

change may be on the horizon

in the aftermath of the Supreme

Court's decision in PACCAR,

which prompted renewed public discussion about the

funding industry and the extent to which it facilitates

access to justice.

The Government has indicated that it will consider

any recommendations made by the Civil Justice

Council (CJC), which recently released its interim

report on the subject, and which is currently running

a public consultation on approaches to regulation.

Once the CJC's final report and recommendations

are published, the Government has indicated it will

consider further regulation. Meanwhile, the European

Parliament has urged the EU to impose more extensive

regulation of litigation funding across all EU member

states. Should the UK follow suit?

Third-party litigation funding (TPF) is an arrangement

whereby a third-party (typically a commercial funder)

agrees to cover all or part of the legal costs of a party

to legal proceedings, in return for a fee if the party is

successful. TPF is provided on a non-recourse basis,

which means that there will be no return for the

funder in the event the funded party does not win the

case. The terms of these arrangements will generally

be set out in a litigation funding agreement (LFA).

Current Regulation

Since its introduction, TPF in England and Wales

has been subject only to voluntary self-regulation,

with no formal regulatory oversight. Protections

for parties involved in funded claims are afforded

primarily by a combination of funders joining

the voluntary regulatory body (the Association of

Litigation Funders – the ALF) and by the courts

applying common law rules.

Historically, TPF was not permitted in England and

Wales because of the rule against champerty, which

is concerned with controlling the circumstances

in which a person with no direct interest in the

proceedings may exert control over them, for example,

by paying some of the costs of the litigation in return

for a share of the proceeds. The policy concern here is

that the funder's interest in its own profit may have a

distorting effect on the conduct of the litigation.

However, in 2002, the Court of Appeal ruled that

only funding arrangements that 'undermine the

ends of justice' should be subject to the rule against

champerty. This has meant that, until very recently,

it was rare for funding arrangements to be challenged

in the courts.

Voluntary Regulation

A voluntary system of regulation does exist for

litigation funders in England and Wales, for those

which are members of the ALF. The majority of large,

established litigation funders in England and Wales

are members of the ALF and must comply with its

code of conduct which provides rules on capital

adequacy of funders and outlines sanctions for

upheld complaints against funders. The sanctions are

relatively minor given the scale and value of funded

litigation, including expulsion from the ALF, the

imposition of a fine of up to £500 and the payment of

all or any of the costs of determining the complaint.

In PACCAR, the Supreme Court reversed the

findings of the lower courts and held that litigation

funding agreements pursuant to which the funder

is entitled to a percentage of any damages recovered

are ‘damages-based agreements’ (DBAs) within the

meaning of section 58AA of the Courts and Legal

Services Act 1990. Consequently, such agreements

are (i) unenforceable unless they comply with the

Damages-Based Agreements Regulations 2013; and

(ii) impermissible in opt-out collective proceedings

pursuant to section 47C(8) of the Competition Act

1998.

PACCAR led to a widespread revision of funding

arrangements, a large proportion of which overnight

became unenforceable. The attempts to fix such

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


CREDIT MANAGEMENT

If affected, the recommendations made in the Voss

Report would have a significant impact on the

litigation funding market in Europe by introducing

award caps, independent regulators, and disclosure

obligations.

It should be noted that the European Commission is

under no obligation to propose any corresponding

legislation in response to the report, but the

recommendations paint a clear picture of the potential

direction of travel towards increased regulation of

litigation funding in the EU.

Reversing PACCAR

The former Conservative Government had intended

to reverse the PACCAR decision by implementing the

Litigation Funding Agreements (Enforceability) Bill.

However, the Bill did not make it through the washup

prior to the general election and the incoming

Labour Government has confirmed that it has no

immediate plans to reintroduce it. The Government

has indicated that it will await the outcome of the

CJC's review of the current regulatory landscape for

litigation funding before considering any legislation.

agreements in place for various significant claims

in the High Court and the Competition Appeal

Tribunal (CAT) have been or are in the process of

being challenged by defendants.

The effect of PACCAR has been felt particularly

acutely in the collective actions regime in the CAT.

This is because all successful applicants for Collective

Proceedings Orders have satisfied the requirement

that they have access to sufficient resources to enable

them to act fairly and adequately in the interests of

the class (and are therefore a suitable person to be

authorised as a class representative) by having an LFA

in place. Accordingly, there are multiple appeals on

funding issues outstanding (some of which are to be

heard together), impeding the progress of cases in the

CAT.

New Proposals

Currently, there is no formal EU-wide system of

regulation of litigation funders but in September

2022, the European Parliament voted in favour of a

report entitled Recommendations to the Commission

on responsible private funding of litigation. Known

as the Voss Report, it seeks to introduce a regulatory

framework for TPF across EU member states and

makes recommendations to the Commission to

implement a directive which will establish ‘common

minimum standards’ for TPF in the EU.

So is there a case for greater regulation in the UK?

Beyond the continuing commercial uncertainty for

litigation funders and funded claimants as the courts

grapple with the impact of PACCAR, and concrete

legislative proposals from the new Government are

yet to materialise, the Post Office Horizon case has

also increased public scrutiny of the TPF sector.

Of the £58m settlement award made in that case

(which was funded by Therium) only £12m was

distributed between over 550 claimants (equating to,

on average, just over £21,000 per claimant – although

some may have been entitled to a higher share than

others) with the remaining sum being claimed by

the funders. This outcome has been widely criticised

as unjust in circumstances in which many of the

claimants had lost their livelihoods and contributed

to the Government introducing a compensation

scheme to ‘top-up’ the settlement amounts received

by claimants.

On the other hand, Sir Alan Bates, one of the former

sub-postmasters and first claimant in the proceedings,

has publicly stated that without litigation funding,

the sub-postmasters could not have brought their

case and exposed the wrongdoing of the Post Office.

As such, the Post Office litigation demonstrates both

why litigation funding is needed and some of the

drawbacks to pursuing funded claims.

Potential recommendations

Following the decision in PACCAR, the Lord

Chancellor commissioned the CJC to conduct a

review of the litigation funding sector. The CJC

Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 45

continues on next page >


LITIGATION

interim report, published in October 2024, precedes a

consultation process which will result in a final report

with recommendations.

The interim report contains a survey of the different

approaches taken in other jurisdictions with respect

to TPF. This survey includes an overview of the EU's

approach and makes reference to the Voss Report

but makes no assessment of the suitability of the

Voss proposals for regulation of litigation funding in

England and Wales. While the final recommendations

from the CJC's review are awaited, the suggestion that

the CJC might be evaluating proposals for regulation

similar to those made in the Voss Report (as described

above) will likely raise concern in some quarters, given

the mixed response that report received.

But do we need more regulation of litigation funders?

According to the European Parliament, the answer is

a clear ‘yes’ – hence the regulatory regime proposed by

the Voss report – but only the European Commission

has the power to initiate legislation, and its response

is still awaited. In the interim, the proposals set out

in the Voss report have been subject to criticism

from the funding industry due to a perceived lack of

evidence-based analysis in the report.

The CJC is yet to set out any proposals to reform

the approach to litigation funders in the courts of

England and Wales but there are suggestions that it

will be far less interventionist than the EU regulatory

regime proposed by the Voss report.

Andrew Lenon KC, who sits as a chairman of the

CAT indicated that it seems ‘unlikely at this stage that

the CJC will recommend particularly prescriptive

regulation of funding’ during a keynote speech given

at the Global Class Actions Symposium in November

2024. It is also worth noting that the European Law

Institute (ELI) published a report in October 2024

(Principles Governing the Third Party Funding of

Litigation) which set out principles intended to

constitute a blueprint for light-touch regulation of the

litigation funding market. The report acknowledges

the Voss Report's advocacy for increased regulation

but notes that ‘prescriptive regulation’ is ‘is only

appropriate where there is an identifiable problem or

market failure’.

To regulate or not

Depending on the outcome of the CJC review, and

in light of the criticism that the Voss report has

received from the funding industry, the Government

may be disinclined to impose further regulation on

the market for litigation funding in England and

Wales. Yet, the key risks outlined by the Voss Report

apply equally to funded cases in England and Wales

– in particular that funders will maximise their own

returns at the expense of those expecting to benefit

from litigation. Indeed, these risks are acknowledged

in the CJC's interim report.

As for funders themselves, it might be thought that

they would have little interest in being regulated

more than they are at present. However, many of the

claims which litigation funders are often called upon

to back involve large numbers of individual claimants

with limited resources. Currently, the market for

those types of claims is somewhat constrained by the

limited availability of procedural mechanisms for

bringing collective actions on an opt-out (rather than

an opt-in) basis; in practice, it is difficult to bring such

claims except in the context of certain competition

law damages actions.

So far, the Government has resisted calls to expand the

competition collective actions regime to other areas,

usually citing concerns that this could encourage

a US-style litigation culture. It may be that greater

regulation of litigation funders, particularly greater

transparency about their role and perhaps greater

powers of oversight for the courts, would help to allay

some of these concerns – which could in turn pave

the way for an extension of the competition collective

actions regime to other areas.

Proportionate approach

The EU's tendency to take a more prescriptive

approach to regulation is reflected in some of the

recommendations of the Voss report, notably the

requirement for what is effectively a licensing regime

for funders and the 40% award cap. The UK has often

expressed a preference for what it regards as a more

proportionate and market-led approach, as reflected

in its better regulation principles. In particular,

the danger of a one-size-fits-all cap on the share of

proceeds that funders can seek is that it may result

in funders becoming unwilling to back litigation on

that basis. This might mean the UK would not feel

the need for a licensing regime but could instead

increase the ability of the courts to scrutinise funding

arrangements on a case-by-case basis. Such an

approach would be more flexible with the potential

to be varied according to the circumstances of each

case – and would only involve intervention where the

court judged it to be necessary.

If the UK does take a lighter touch approach to

regulation, any such regulatory divergence between

the UK and the EU may affect the relative allocations

of funders and the availability of funding between the

jurisdictions.

Author: Jonathan Rush is a Knowledge Counsel, and

Barney Stannard is a Partner, at Travers Smith.

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


BRANCH NEWS

A REVITALISING

FOCUS

The CICM Yorkshire Ridings Branch Re-launch.

CREDIT management professionals

from across Yorkshire came together

in April for a dynamic and forward-looking

event marking the

relaunch of the CICM Yorkshire

Ridings Branch, hosted in partnership

with Hays Recruitment.

Held in Leeds, the event welcomed a packed audience

for a morning of insightful sessions, networking,

and strategic discussions on the future of credit

management. With a revitalised focus on supporting

credit professionals across North, East, and West

Yorkshire, the branch reaffirms its commitment to

community, training, and excellence in these changing

times.

The event opened with a warm welcome from Claire

McManus, Director at Hays, and Ian Torkington

MCICM, Branch Chair and Head of Client Services at

Cashroom. Setting the tone, they highlighted the vital

role credit management plays in today’s uncertain

economy and the importance of re-establishing a

strong regional network.

Dan Walker MCICM, Co-Founder of AI for Business,

delivered an engaging keynote on AI in Credit &

Collections. Dan explored how artificial intelligence

is revolutionising the sector, with practical advice

on deployment strategies, ROI measurement, and

managing organisational change when integrating AI

into credit teams.

Following Dan, Luke Sculthorp FCICM, Head of

Strategic Relationships at CICM, presented essential

updates on CICM's 2025 initiatives. His talk focused

on the expanding CICM apprenticeship programmes,

the value of CICMQ accreditation for organisations

aiming to benchmark best practice, and the Institute’s

renewed efforts to support career development,

governance, and talent retention.

Rounding off the speaker sessions, Claire McManus

from Hays provided a comprehensive overview of

current credit recruitment trends, highlighting key

labour market challenges, skills shortages, the impact

of new government legislation, and strategies for both

hiring and retaining top talent in the credit sector.

Key themes and takeaways:

• AI is here to stay: Credit teams need to start

integrating AI thoughtfully to boost efficiency, reduce

risk, and maintain competitive advantage

• Talent development is critical: With rising

employment costs and increased competition for

skilled professionals, businesses must invest in

training, apprenticeships, and flexible working

environments

• Market pressures require adaptation: From

demographic shifts to wage inflation and societal

demands for sustainability and diversity, credit

management must evolve to meet new challenges.

The Yorkshire Ridings committee announced plans

for further events later in 2025 and invited feedback

from attendees to shape future agendas around realworld

needs. They encouraged all professionals —

CICM members and non-members alike — to get

involved, strengthen networks, and help raise the

profile of credit management in the region

The event concluded with a lively Q&A session and

an opportunity for delegates to network over lunch,

setting the foundation for a renewed and energised

CICM presence across Yorkshire.

Author: Luke Sculthorp FCICM.

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


Looking for

your next

career move?

Credit Controller

North Manchester, £29k

With markets across the UK and Europe, due to business growth,

our client is seeking an experienced Credit Controller to join

their credit team. Reporting to the Credit Manager you will work

as part of a credit team and be tasked with managing your own

B2B European ledger, chasing overdue monies via Portal & Email,

allocating cash and customer query resolution. Proficiency in

using SAP is preferred. Ref: 29425MB

Contact Joanna Taylor-Coburn on 0161 926 8605

or joanna.taylor-coburn@hays.com

Credit Controller

Sutton/Epsom, up to £35k + bonus

Reporting to the Credit Control Supervisor, and working as part

of a friendly team, you will be responsible for managing circa 300

live accounts with a debtor ledger of approx £8m per month. The

varied duties within this role include ensuring timely collections

of payments, processing incoming funds, resolving account

queries, and overseeing debt recovery process. Ref: 4639637

Contact Mark Ordona on 07565 800574

or email mark.ordona@hays.com

Credit Team Leader

Birmingham, £34k - £38k

We are supporting a charitable organisation based in

Birmingham that is recruiting for a Credit Team Leader

to join them on a permanent basis. You will manage a

small but growing team of three and will remain hands-on,

managing your own ledger of up to 600 accounts.

This position offers hybrid working, with two days a week

in the office. Ref: 4655167

Contact Henry Brook on 0333 010 7517

or email henry.brook@hays.com

Credit Controller (Insurance)

Norwich Norfolk, up to £35k

As an experienced Insurance Credit Controller, you will work

closely with brokers and underwriters to ensure the collection

of all monies. The portfolio will have at least 25 key customers,

and you will manage approximately 1800 premiums from major

businesses based across Europe. This role is based in Central

Norwich, Norfolk, and you must have previous experience of the

insurance markets to be considered. Ref: 4678539

Contact Andy Jarman on 01603 760141

or email andy.jarman@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


Senior Accounts Receivable Assistant

London, up to £40k

This is an exciting opportunity to join a dynamic retail company,

managing a ledger of EMEA clients. You will oversee the

accounts receivable processes, ensuring timely collections and

handling multicurrency transactions. You will collaborate with

internal teams to resolve payment discrepancies and prepare

financial reports. Experience of working with multi-currencies is

essential. Ref: 4639645

Contact Katie Bohun on 0203 465 0020

or email katie.bohun@hays.com

Legal Biller

London, £40k - £46k

A top UK law firm, based in the City of London is looking for a

bright legal biller to join their successful and welcoming finance

team. This opportunity is well suited for an individual with 2-5

years of legal billing experience and offers brilliant progression,

supported by an experienced team of billers. Ref: 4659334

Contact Lara Santis on 0333 010 2474

or email lara.santis@hays.com

Discover new

opportunities today

© Copyright Hays plc 2025. All rights are reserved. CM-00885


BEREAVEMENT

DIGITAL

NOTIFICATIONS

Guidance welcome but digital notifications should be mandated.

BY PHIL HICKSON

IN our recent report Probate or Pro-wait – how to

make the hardest part of life easier, we recounted a

story of how a bereaved widow had to contact

more than 20 individual organisations to

inform them that her husband had died. We

also reported that nearly three in four (72%)

of 2,000 UK adults surveyed agreed that every

bank and utility company should have a specific death

notification service similar to the ‘Tell Us Once’ service

provided by the Government.

We are delighted, therefore, to learn that the Financial

Conduct Authority (FCA) has published new guidance

on how banks should treat customers in vulnerable

circumstances – including bereavement – following a

review of current practices (published 12 April, 2025).

‘Good’ firms, it identified, had clear customer policies and

procedures with regard to vulnerability, which often set out

the expected timeframe for staff to process registration of

bereavement and Power of Attorney (PoA) cases.

The FCA also identified where things needed to improve.

In some cases, there was clear evidence of poor practice

or lack of awareness of internal policies exacerbating the

distress for customers and their representatives when they

did not get the support they needed. Staff did not always

acknowledge that customers were noticeably upset, even

though failing to recognise and respond sensitively can have

a direct impact on the customer’s confidence in engaging

with financial services.

There are several recommendations as to how firms might

consider adapting their bereavement customer journeys

to help ensure they are as straightforward and flexible as

possible. It is also encouraging to know that most firms that

the FCA engaged with have dedicated bereavement teams.

What especially stuck out for me, however, was the

common issue shared across multiple banks and financial

services providers: customers (particularly in bereavement

processes) had to repeat information when speaking

to different staff members, or had their cases delayed

or dropped altogether because they had been ‘lost’ in

the firm’s systems, risking further distress and upset.

The FCA also highlighted how fragmented customer

relationship management (CRM) systems across business

lines could make it more difficult to keep track of cases

and process them efficiently. ‘We encourage firms to focus

on ensuring customer journeys are fit for purpose across

legal entities, to reduce the risk that consumers do not get

their needs met or must repeat information unnecessarily,’

it says.

It is especially interesting because it taps into our opinion –

borne out by our research – that the lack of any universally

agreed, digitally-based process for death notifications

within the private sector is contributing to a more stressful

bereavement experience.

As owners of the bereavement notification services

NotifyNOW and Settld, we have previously called on the

FCA and the Government to go much further in their

plans to require firms to accept digital death verification.

We have also long believed that third-party providers

should be mandated to have a dedicated bereavement

team and minimum Key Performance Indicators

in how the bereaved are handled. It seems that the

FCA agrees.

Every bank, utility company and service provider – and not

just those regulated by the FCA – should have a consistent

death notification service and much better signposting

is needed to steer consumers to the help available in

explaining how the process works.

The guidance from the FCA is a welcome first step – but it

needs to go further. We should harness the momentum that

is now being generated and accelerate the appointment of

a Bereavement ‘Tsar’ within the Government to champion

the better treatment of consumers managing a death. We

need a powerful voice with the authority to hold firms

to account. Guidance is the first stage, but what’s really

needed is mandatory action.

For a copy of our report, Probate or Pro-wait – how to make

the hardest part of life easier, Go to the FCA website.

Author: Phil Hickson is SVP, global Partnerships at The Estate

Registry.

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


CREDIT MANAGEMENT

WE HAVE ALSO LONG BELIEVED

THAT THIRD-PARTY PROVIDERS

SHOULD BE MANDATED TO HAVE A

DEDICATED BEREAVEMENT TEAM

AND MINIMUM KEY PERFORMANCE

INDICATORS (KPIS) IN HOW THE

BEREAVED ARE HANDLED.

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


INSOLVENCY

THE WALLS

OF JERICHO

Is the construction industry on the brink

or are statistics misleading?

BY PHILIP KING FCICM

SINCE 2021, the construction sector

has accounted for almost one in five

of all corporate insolvencies. The

percentage has ranged between the

lowest of 15.1% (November 2024) and

the highest of 20.4% (February 2022).

The percentage for all corporate

insolvencies across the 10-year period from 2015 to

2024 was 17.7%, or one in every 5.65. Sadly, there’s little

to suggest the number’s going to change any time

soon.

The latest Government Office for National Statistics

(ONS) trend figures over three months reveal an

industry in stagnation, recording no net growth

overall. The S&P Global/CIPS UK Construction PMI

in March remained in contraction, with new orders

declining for the third month in a row, and just 40%

of firms expecting output to rise in the coming 12

months. The more recent Flash Composite PMI for

April slid to a 29-month low of 48.2.

At the time of writing, many are predicting a cut in

the Bank of England interest rate from 4.5% to 4.25%

in May. While this can be beneficial for small firms

that rely on borrowing, it can also lead to companies

taking on debt that can hide underlying financial

problems. It’s a time to be watchful and wary.

Fixed-price challenges

Firms in the construction sector struggle when fixedprice

contracts prevent them from passing on rising

costs. Also, cashflow suffers from hikes in material

costs, project delays, and supply chain disruption.

Costs are increasing, both through National

Insurance Contributions and a rise in the minimum

wage. Inflation is still an issue, as is the uncertainty

arising from tariffs being imposed by the US. As such,

it’s reasonable to assume the rate of insolvencies is

unlikely to diminish across the rest of 2025.

Brendan Clarkson of PKF Littlejohn Advisory

agrees. He observes that Compulsory Liquidations in

February 2025 reached their highest level in 10 years

as a result of HMRC and local authorities stepping up

their activity and showing less forbearance than had

hitherto been the case. The total in February 2025 was

49% higher than in February 2024.

Creditors are also becoming more proactive in

pursuing outstanding debts and are increasingly

resorting to legal action. His firm is seeing a rise in

enquiries for restructuring and insolvency support,

with directors seeking specialised advice on managing

their business finances amidst escalating costs. Small

businesses, in particular, find it challenging to pass on

additional costs to customers while still wanting to

remain competitive.

So what are things like on the ground? I’ve talked to

some Top Service clients and members to get their

views on the year so far.

Reduction in overdues

There’s a consensus that collections have performed

well; relatively few bad debts have been experienced

and, generally, they are of low value. A reduction in

overdues is also being seen and, where customers are

struggling, more are taking a proactive approach to

arranging payment plans. This is a positive sign of a

willingness and desire to honour debts rather than

walk away and leave the supplier unpaid.

There’s less common consensus on the commercial

front, however. Some have seen sales start to pick up

and are feeling positive, opening more new accounts

than ever, while others say trade has not increased

to the levels they’d anticipated and that it’s a

battleground to win business. One member observed

that things are eerily good and they’re waiting for a

shock!

I also asked what their main current ‘pain-points’

were and identified a variety of issues. Taking

decisions without adequate information was high

on the list. There are a number of reasons for this:

companies filing minimum information or having no

requirement to file because they are so new, and the

resulting unavailability of credit insurance leading to

trading at their own risk.

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


CREDIT MANAGEMENT

Requests for payment plans, and customers seeking

increased credit limits, also featured. A particular

difficulty was granting more credit when customers

were unwilling to provide additional information, such

as management accounts or draft statutory accounts.

Handling the commercial pressure to offer more credit

in these circumstances was also a factor causing pain.

Account analysis

One member highlighted the difficulty of reaching

any form of conclusion from analysing year-on-year

accounts. Everybody has had a tough year, and the

majority of accounts show negative movement. Success

lies in determining which had a tough year and are

weathering the storm, and which had a tough year and

are on their last legs.

There was common recognition of increasing instances

of fraud, and the need for greater vigilance and better

avoidance systems. One single instance can have a

devastating impact on a company’s survival, so it’s an

area that needs constant focus.

In general, and particularly in regard to collections

performance, it seems that experience at the coal face

is better than suggested by the more general insolvency

statistics and predictions. I see a couple of possible

reasons for this. Firstly, the impact of increased

employment costs, US tariffs, and rising employment

costs have yet to be fully felt, and it may be a matter

of timing. Secondly, it’s likely that these Top Service

members have best practice credit management

processes, get real-time shared payment experience,

and have effective systems in place. They’re more adept

at spotting risks and warning signs, at being proactive

in managing and minimising overdue debts, and – as I

said in my last contribution to this magazine – at being

willing to give and receive information about their

customers which puts them on the front-foot.

Author: Philip King FCICM is a non-executive

director at Top Service Ltd.

A REDUCTION IN OVERDUES IS

ALSO BEING SEEN AND, WHERE

CUSTOMERS ARE STRUGGLING,

MORE ARE TAKING A PROACTIVE

APPROACH TO ARRANGING

PAYMENT PLANS.

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


International Trade

Monthly round-up of the latest stories

in global trade by Andrea Kirkby.

MADE IN BRITAIN’S

EXPORT SUPPORT IN 2025

*

*

A Government agency, Made in Britain,

aims to support members to sell more of

what they make overseas, as well as in

the UK. It has a number of programmes

to help it do so.

There’s an International Trade

Newsletter, published quarterly that

features curated export news, events,

and updates. Also available is an

International Trade programme which

offers online sessions that cover key

markets identified in a Made in Britain

export survey as holding the best

options for UK manufacturers. Each

session features presentations and

Q&A by Made in Britain companies plus

insights from Department for Business

and Trade experts and the organisation’s

Export Academy.

There have been sessions on

Latin America with discussions on

the Comprehensive and Progressive

Agreement for Trans-Pacific Partnership’s

impact after it comes into force; and

Europe with detail on how to export

to European markets. Later in 2025

sessions are planned on the USA and

Canada (July), and the Middle East

(September) including the UAE and Saudi

Arabia.

Beyond this is help with navigating

regulatory challenges in international

markets, market-entry assistance,

and overseas partnerships. There are

other resources to tap into such as free

Government resources for exporters, a

UK Export Academy with free training,

funding from UK Export Finance,

Keep an eye on the Made in Britain

website at https://tinyurl.com/2n3kv25w.

China as a business opportunity?

THERE’S an interesting bit of editorial

in ExportExperts Magazine which asks,

‘can the UK optimise China as its best

business opportunity?’

It considers that China is now the only

functioning major economy in the world

and looks set to be so for some time.

But this is not the only factor that

puts it in the position of being the UK’s

best international sales prospect as

there’s also a great appreciation of

British brands, culture and heritage

and the respect for the way business is

conducted. Beyond that there’s Chinese

enthusiasm for Brexit combined with the

handicap rival US businesses face due to

Trump’s hostility to China.

However, it’s not all plain sailing as

there’s the ‘British Disease’ – the lack

of awareness and ability to localise to

indigenous culture and business practice

– a point noted by Domenica Di Lieto,

CEO of Chinese marketing consultancy,

Emerging Communications.

She reckons that misunderstanding

Chinese culture leads to

underperformance and failure and has

resulted in highly damaging consumer

boycotts. She gives the example of

Dolce and Gabanna’s flawed decision

to use a Chinese model struggling to

eat Italian food with chopsticks as the

theme for a promotional video – it was

said to comprehensively wipe-out longterm

sales in what was by far its biggest

market.

Di Lieto says that there are only two

ways forward – ‘create a cross-cultural

team or appoint a specialist third party to

create and oversee strategy and tactics

while at the same time training to build

management self-sufficiency.’

You have been warned.

JEREMY CLARKSON HAS

AMBITIONS WITH BEER

BUSINESS Matters has reported on plans

that motoring journalist, farmer and now

brewer, Jeremy Clarkson has for his beer

brand, Hawkstone.

As the publication said, what began as

a local collaboration using barley from

his Diddly Squat farm is now Britain’s

fastest-growing privately owned brewery

— and it’s just getting started.

Launched in 2021, Hawkstone is

brewed in partnership with the Cotswold

Brewing Company. The brand, co-owned

by Clarkson and entrepreneur Johnny

Hornby, had revenues of £7.8m in the

year to March 2025. It’s now planning to

go international.

The original idea was to combine

Clarkson’s profile with British farming

and brewing. Hawkstone uses barley

grown on Clarkson’s farm and has

positioned itself as a premium product.

The brewery has since expanded its

range to include low-alcohol options.

Business Matters said that Clarkson

envisions Hawkstone in 200,000 pubs,

from the Pacific Northwest to Brisbane.

Though tongue-in-cheek, the ambition

is serious. It added that Elon Musk was

recently seen sipping Hawkstone on a

yacht in France.

SMALL BUSINESSES AND THE

WINDSOR FRAMEWORK

THE FSB in Northern Ireland has

launched a survey to assess the

impact of the Windsor Framework on

small businesses across the UK. The

framework is an agreement aimed at

easing trade between Northern Ireland

and the rest of the UK after Brexit.

The survey seeks to gather feedback

from businesses of various sizes,

sectors, and across the regions, and

provide crucial insights into how the

framework is affecting them. The

findings, we are told, will play a key role

in FSB's efforts to advocate for policies

that improve the trading environment for

SMEs in the UK.

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


THE FT ON TRUMP’S TARIFFS

IT may be old news, but we cannot ignore

the elephant in the room – President

Trump’s tariffs on global US imports that

the FT says will dent the UK Government’s

fragile growth ambitions and hit key

manufacturing sectors.

The UK’s 10% levy – while less than the

20% faced by the EU and higher elsewhere

– will clearly weaken demand and disrupt

supply chains at a time when businesses

are already facing rising costs.

The paper quoted Shevaun Haviland,

Director-General of the British Chambers

of Commerce, who said that orders will

drop, prices will rise, and global economic

demand will be weaker as a result.

Similarly, Emma Rowland, trade policy

advisor at the Institute of Directors, told

the FT that the tariffs would be a blow to

British businesses that would force many

HIGH LOW TREND

to reassess the viability of the US as both a

market and a supply-chain hub.

The UK sells more services than goods

to the US and export sectors were left

non-plussed by the imposition of tariffs.

Farmers will be concerned as the US is

the UK’s second-largest destination for

British food exports after the EU; car

manufacturers will be too as one in six

[high end] cars goes to the US.

On the positive side, the FT noted that

UK manufacturing just became more

competitive than many other countries,

especially when compared with a number

of low-cost countries.

Tariffs can be lifted at any time and there

is some hope that either Trump is forced to

change course, or a deal can be negotiated.

Regardless, if he doesn’t a one-man-made

global recession is on the cards.

Trade bodies call for EU-UK

standards mutual recognition

GBP/EUR 1.18993 1.16041 UP

GBP/USD 1.34433 131433 FLAT

GBP/CHF 1.11852 1.07685 UP

GBP/AUD 2.10072 2.04906 DOWN

GBP/CAD 1.86251 1.8304 UP UP

GBP/JPY 196.369 187.586 UP UP

THE Chartered Institute of Export &

International Trade has written that several

trade organisations on both sides of the

English Channel have called for a change in

conformity regulation could boost UK and

European economic growth and remove

trading barriers.

According to the organisations – the

institute as well as LightingEurope,

Make UK, and the Confederation of

Swedish Enterprise, such an agreement

would increase stability for regulatory

environments; avoid duplicating

conformity assessments for both British

and European businesses who want to

trade in both markets; and provide greater

availability of conformity assessment

bodies.

The call for change reckons that such

an agreement could be achieved either

as part of a ‘mini-deal’ or alongside other

industry-focused measures. The call notes

that the UK Accreditation Service (UKAS)

is assessed to the same standard as EU

equivalents making it easier to achieve an

agreement.

Notably, the UK-EU Trade and

Cooperation Agreement which governs

trade relations between the UK and the

EU, is also due to be reviewed next year.

For the latest

exchange rates visit

www.currenciesdirect.com

or call 020 7874 9400

Currency Exchange Rates

This data was taken on 16th May

and refers to the month previous

to/leading

up to 15th May 2025.

CREDIT MANAGEMENT

THERE’S MONEY IN WIND

UK Export Finance is to provide a

£184m credit guarantee to support the

construction of the 495 MW Fengmiao

1 offshore windfarm in Taiwan,

securing £55m in manufacturing and

service export contracts for British

suppliers.

As the story runs, Cadeler – based

in East Anglia – is to supply an

installation vessel together with crew,

sea-fastening services and crane

operators.

The deal is part of a wider $3.7bn

financing package by Copenhagen

Infrastructure Partners which involves

export credit agencies from Denmark,

Netherlands, Poland, Belgium, and

Taiwan.

Located off the west-coast of

Taichung City, the offshore wind site is

due to be completed in 2027.

GOOD NEWS FOR NI?

A report on the BBC, citing Nobel prize

winning economist Paul Krugmanm,

reckons that following the imposition

of US trade tariffs, EU firms will try to

export goods via Northern Ireland in

an attempt to get a reduced tariff rate

when exporting to the US.

Northern Ireland is part of the UK but

also has an open trade border with the

Republic of Ireland, which is in the EU.

Krugman said that ‘probably a lot of

EU goods trans-ship through Northern

Ireland to get the lower tariff rate.’

However, goods cannot just be

exported via a lower tariff country to

get a lower tariff. Instead, they need to

undergo ‘substantial transformation’

in the lower tariff country, which usually

means some form of processing.

This could bode well for Northern

Ireland in terms of work for ports and

firms involved in ‘processing’.

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


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

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


EXCLUSIVE PAYMENT TRENDS

ON THE ROCKS

Late payments on the up across the board.

BY ROB HOWARD

WHEREAS last

month’s Payment

Trends provided

plenty of optimism,

the latest late

payment statistics

are a stark contrast,

with the vast majority of regions and sectors across the

UK and Ireland heading in the wrong direction. The

average Days Beyond Terms (DBT) across UK regions

and sectors increased by 0.3 and 0.5 days respectively.

In Ireland, average DBT rose by 1.2 and 1.5 days

respectively. Across the four provinces of Ireland, the

average figure increased by 2.9 days.

Sector Spotlight

More than half (13) of the 22 UK sectors saw increases

to their DBT. But before diving into those, it’s worth

noting that nine sectors did make improvements. Of

those, the standout performer without a doubt, is the

Manufacturing sector, which moves off the bottom of

the standings after cutting its DBT by 8.1 days taking

its overall tally to 11.1 days. At the other end of the

scale, the Financial and Insurance sector, which was

among the top performing sectors, saw an increase of

7.7 days taking its overall DBT to 12.4 days and making

it the second worst performing sector. The Water and

Waste sector has taken over as the worst performing,

with a rise of 5.8 days taking its overall DBT to 13.0

days.

The sector outlook in Ireland is similar, with 12 of the

19 sectors going backwards. Its Water and Waste sector

continues to suffer and move further adrift at the

bottom of the standings, with a further increase of 11.8

days taking its overall DBT to a massive 72.8 days. For

context, and to highlight the size of the gap, the second

worst performing sector – Agriculture, Forestry and

Fishing (+8.4 days), now has an overall DBT of 18.2

days. Elsewhere, the Education (+7.5 days) and Mining

and Quarrying (+6.2 days) sectors are also on the slide.

Looking at the positives, the IT and Comms sector

is on the up, and moves into the top five performing

sectors, with a reduction of 6.0 days taking its overall

DBT to 5.0 days.

Regional Spotlight

On the surface, the UK regional figures probably look

worse than they are. Some seven of the 11 regions saw

increases to DBT, but the majority of these were fairly

minor. For instance, London and the West Midlands

saw the biggest increases, both experiencing a rise of

2.4 days to their DBT, followed by Wales (+1.6 days)

and Northern Ireland (+1.4 days). Meanwhile, the

North West (+0.9 days), South West (+0.7 days) and

South East (+0.4 days) all saw increases of less than one

day.

The picture across the Irish counties is more of a

mixed bag. Some 16 of the 26 counties saw increases

and some of these are significant, but equally, there are

some significant improvements among the 10 counties

moving in the right direction. Of those making strides,

Wexford and Waterford made the biggest gains,

reducing their DBT by 9.2 and 8.9 days respectively.

Meanwhile, a reduction of 4.7 days puts Offaly into

second place in the standings with an overall DBT of

3.9 days. However, a number of counties are in freefall.

A significant rise of 13.2 days means Cavan is now the

second worst performing county with an overall DBT

of 22.7 days, while Monaghan (+10.6 days) and Galway

(+9.3 days) also saw large increases to their DBT.

Three of the four Irish provinces saw increases to DBT,

while Leinster (-0.4 days) made a small improvement.

Ulster saw the biggest jump, and is now the worst

performing province, with an increase of 7.3 days

taking its overall DBT to 14.7 days.

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


*

STATISTICS

Data supplied by the Creditsafe Group

Top Five Prompter Payers

Region (UK) 25 Apr Changes from Mar 2025

SOUTH WEST 6.8 0.7

SCOTLAND 7.8 -0.2

SOUTH EAST 8.2 0.4

EAST MIDLANDS 8.5 -1.7

WALES 9.2 1.6

Bottom Five Poorest Payers

Region (UK) 25 Apr Changes from Mar 2025

EAST ANGLIA 12.7 -4.6

NORTH WEST 10.5 0.9

NORTHERN IRELAND 10.4 1.4

WEST MIDLANDS 10.0 2.4

YORKSHIRE AND HUMBERSIDE 9.9 0

Getting worse

Financial and Insurance 7.7

Water & Waste 5.8

International Bodies 5.1

Energy Supply 4.7

Business Admin & Support 2.1

IT and Comms 1.8

Construction 1.5

Other Service 1.5

Real Estate 0.9

Entertainment 0.4

Top Five Prompter Payers

Sector (UK) 25 Apr Changes from Mar 2025

BUSINESS FROM HOME 5.0 0.1

EDUCATION 5.2 -0.8

INTERNATIONAL BODIES 5.7 5

ENTERTAINMENT 6.3 0.4

AGRICULTURE, FORESTRY & FISHING 6.4 0.3

Bottom Five Poorest Payers

Sector (UK) 25 Apr Changes from Mar 2025

WATER & WASTE 13.0 5.8

IT AND COMMS 12.8 1.8

FINANCIAL AND INSURANCE 12.4 7.7

BUSINESS ADMIN & SUPPORT 11.5 2.1

OTHER SERVICE 11.5 1.5

Agriculture, Forestry and Fishing 0.3

Public Administration 0.2

Business from Home 0.1

Getting better

Manufacturing -8.1

Dormant -3.9

Professional and Scientific -3.2

Hospitality -1.8

Wholesale and retail trade; repair of

motor vehicles and motorcycles -1.6

Education -0.8

Mining and Quarrying -0.7

SCOTLAND

-0.2 DBT

Health & Social -0.5

Transportation and Storage -0.3

NORTHERN

IRELAND

1.4 DBT

SOUTH

WEST

0.7 DBT

WALES

1.6 DBT

NORTH

WEST

0.9 DBT

WEST

MIDLANDS

2.4 DBT

YORKSHIRE &

HUMBERSIDE

0 DBT

EAST

MIDLANDS

-1.7 DBT

LONDON

2.4 DBT

SOUTH

EAST

0.4 DBT

EAST

ANGLIA

-4.6 DBT

Region

Getting Better – Getting Worse

-4.6

-1.7

-0.2

2.4

2.4

1.6

1.4

0.9

0.7

0.4

0.0

East Anglia

East Midlands

Scotland

London

West Midlands

Wales

Northern Ireland

North West

South West

South East

Yorkshire and Humberside

Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 58


EXCLUSIVE PAYMENT TRENDS

Getting worse

CONNAUGHT

3.8 DBT

LEITRIM

-2.8 DBT

ULSTER

7.3 DBT

CAVAN

13.2 DBT

Water & Waste 11.8

Agriculture, Forestry and Fishing 8.4

Education 7.5

MUNSTER

1.1 DBT

CLARE

-1.2 DBT

LEINSTER

-0.4 DBT

CARLOW

-2.8 DBT

WATERFORD

-8.9 DBT

LOUTH

-4.1 DBT

DUBLIN

2.6 DBT

Mining and Quarrying 6.2

Hospitality 3.4

Energy Supply 3.0

Public Administration 2.7

Professional and Scientific 1.7

Health & Social 0.7

Financial and Insurance 0.5

Top Five Prompter Payers – Ireland

Region 25 Apr Changes from Mar 2025

LEITRIM 3.0 -2.8

OFFALY 3.9 -4.7

LONGFORD 5.3 -3.1

CLARE 6.0 -1.2

WICKLOW 6.3 2

Bottom Five Poorest Payers – Ireland

Region 25 Apr Changes from Mar 2025

CARLOW 35.2 -2.8

CAVAN 22.7 13.2

LOUTH 18.8 -4.1

WATERFORD 18.2 -8.9

GALWAY 17.3 9.3

Top Four Prompter Payers – Irish Provinces

Region 25 Apr Changes from Mar 2025

MUNSTER 7.9 1.1

LEINSTER 11.1 -0.4

CONNACHT 11.9 3.8

ULSTER 14.7 7.3

Other Service 0.3

Real Estate 0.2

Manufacturing 0.1

Getting better

IT and Comms -6

Transportation and Storage -3.6

Entertainment -1.8

Construction -1.6

Business Admin & Support -1.4

Wholesale and retail trade; repair of

motor vehicles and motorcycles -0.3

Real Estate -0.2

Top Five Prompter Payers – Ireland

Sector 25 Apr Changes from Mar 2025

INTERNATIONAL BODIES 0.0 0

ENTERTAINMENT 2.2 -1.8

OTHER SERVICE 4.3 0.3

IT AND COMMS 5.0 -6

MINING AND QUARRYING 6.2 6.2

Nothing changed

International Bodies 0

Bottom Five Poorest Payers – Ireland

Sector 25 Apr Changes from Mar 2025

WATER & WASTE 72.8 11.8

AGRICULTURE, FORESTRY & FISHING 18.2 8.4

BUSINESS ADMIN & SUPPORT 13.2 -1.4

TRANSPORTATION AND STORAGE 12.3 -3.6

REAL ESTATE 11.0 -0.2

Brave | Curious | Resilient / www.cicm.com / June 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.

Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 60


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 are the CICM Enforcement Business

of the Year. Recognised for our professional, client-focused,

and approachable service, our expert team has enforced over

100,000 Writs, recovering over £105m for clients and claimants

since the end of the pandemic. Our commitment to excellence

is reflected in our client satisfaction survey, where 100% of

respondents confirmed we meet or exceed expectations as a

High Court enforcement supplier, with many highlighting our

superior collection performance over industry competitors. We

work closely with legal professionals, businesses, and individuals

to provide ethical, effective, and fully compliant enforcement

solutions. Combining experience with innovation, we ensure the

best possible outcomes while upholding the highest standards of

professionalism, integrity, and service excellence.

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.

Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 61


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

E: creditorservices@menzies.co.uk

W: www.menzies.co.uk/creditor-services

Our Creditor Services team can advise on the best way for you

to protect your position when one of your debtors enters, or

is approaching, insolvency proceedings. Our services include

assisting with retention of title claims, providing representation

at creditor meetings, forensic investigations, raising finance,

financial restructuring and removing the administrative burden

– this includes completing and lodging claim forms, monitoring

dividend prospects and analysing all Insolvency Reports and

correspondence.

For more information on how the Menzies LLP Creditor

Services team can assist, please contact Giuseppe Parla,

Licensed Insolvency Practitioner, at:

E: gparla@menzies.co.uk / tel:+44 3309 129828

FIS

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.

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.

W: www.fisglobal.com.

FIS is a financial technology company providing solutions to

financial institutions, businesses and developers. We unlock

financial technology that underpins the world’s financial system.

Our people are dedicated to advancing the way the world pays,

banks and invests, by helping our clients confidently run, grow

and protect their businesses. Our expertise comes from decades

of experience helping financial institutions and businesses adapt

to meet the needs of their customers by harnessing the power that

comes when reliability meets innovation in financial technology.

Headquartered in Jacksonville, Florida, FIS is a member of the

Fortune 500® and the Standard & Poor’s 500® Index. To learn

more, visit www.FISglobal.com. Follow FIS on Facebook, LinkedIn

and X (@FISglobal).

Thornbury Collection Services Ltd

T: 01443 224407

E: Info@thornburycollections.co.uk

W: www.thornburycollections.co.uk

We are a CICM Award winning company, founded in 2002

Our head office is located in Cardiff, helping clients throughout

the UK and internationally, specialising in commercial B2B debt.

Working with clients of all sizes, from one-man bands to

multinational companies, offering a full turn key service with end

to end support, the perfect piece of the credit jigsaw. Offering

terms and conditions, reviewing, enhancing and drafting credit

processes. Credit control support packages , awareness and

training sessions, recovering debts and dispute resolution.

Facilitation of court work, enforcement and the collect out of full

debtor books.Small enough to care Big enough to win.

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.

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.

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.

Brave | Curious | Resilient / www.cicm.com / June 2025 / PAGE 62


View our digital version online at www.cicm.com

Log on to the Members’ area, and click on the tab

labelled ‘Credit Management magazine’

Just another great reason to be a member

Credit Management is distributed to the entire UK and international

CICM membership, as well as additional subscribers

Brave | Curious | Resilient

www.cicm.com | +44 (0)1780 722900 | editorial@cicm.com

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


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