2021-03-31-accounts

Wormwood Scrubs Charitable Trust

Trustee’s Report and Financial Statements for the year ended 31 March 2021

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TABLE OF CONTENTS

Overview of the Year ....................................................................................................................... 3 An Oasis of Green Space in West London ...................................................................................... 3 Structure, Governance and Management ........................................................................................ 3 Objectives and Activities .................................................................................................................. 4 Public Benefit ................................................................................................................................... 4 Fundraising ...................................................................................................................................... 4 Working with the Friends of Wormwood Scrubs .............................................................................. 4 High Speed 2 (HS2) ......................................................................................................................... 5 Old Oak and Park Royal Development Corporation (OPDC) ........................................................... 6 Habitat and Ecology ......................................................................................................................... 6 Kensington Aldridge Academy (KAA) .............................................................................................. 6 Achievements and Performance ...................................................................................................... 7 Grounds Maintenance and Site Management .................................................................................. 7 Community Safety ............................................................................................................................ 8 Financial Review .............................................................................................................................. 9 Plans for future periods .................................................................................................................. 10 Reserves and Treasury Management Policy ................................................................................. 10 Risk Management .......................................................................................................................... 11 Statement of Trustee’s Responsibilities in respect of the Trustee’s Annual Report and the financial statements ..................................................................................................................................... 13 Independent auditor’s report to the Trustees of Wormwood Scrubs Charity .................................. 14 Reference and Administrative details ............................................................................................. 17 STATEMENT OF ACCOUNTS ...................................................................................................... 19

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Overview of the Year

The Wormwood Scrubs Charitable Trust (the Trust) exists to ensure that this much valued area of open space in West London is used for the exercise and recreation of Londoners. In its local plan, the Old Oak and Park Royal Development Corporation describes Wormwood Scrubs (the Scrubs) as ‘… a cherished public open space and important ecological asset …’.

2020/21 saw some significant developments for the Trust:

• Delivering a financial surplus of £48,984 as it continues to benefit from increased rental income, albeit not all of which is expected to recur in future years.

• Continuing to provide the site for temporary buildings for the Kensington Aldridge Academy school in the aftermath of the Grenfell Tower fire.

• Engaging consultants to develop a £3.9m plan to improve biodiversity (funded by High Speed 2 (HS2)), consulting with the public and presenting masterplan proposals.

• Engaging in the development of the Old Oak and Park Royal Development Corporation Local Plan, to ensure it does not impact adversely on the Scrubs.

• Continuing to work closely with the Friends of Wormwood Scrubs through the two Friends who are co-opted members of the governing committee.

An Oasis of Green Space in West London

The Scrubs is an open space located in the north-eastern corner of the London Borough of Hammersmith and Fulham in West London. It is the largest open space in the Borough, at 80 hectares (200 acres), and is one of the largest areas of common land in London. It has been a public open space since the Wormwood Scrubs Act of 1879.

The Scrubs is a Site of Importance for Nature Conservation with areas designated as Local Nature Reserves including Braybrook Woods, Martin Bell's Wood and the Central Woodland Copse.

Habitats include woodland (plantation), scrub and grassland. Animals include common lizards, approximately 100 species of bird and 20 species of butterfly. There are also approximately 250 native plant species which make up one sixth of UK native flora.

Structure, Governance and Management

The London Borough of Hammersmith and Fulham (the Council) is the sole corporate trustee for the Trust.

Responsibility for the management of the Trust rests with the Wormwood Scrubs Charitable Trust Committee (the Committee) which is constituted under the Council’s constitution.

The Committee is charged with managing all the affairs of the Trust, improving focus and performance and ensuring it achieves its charitable objectives.

Under the Council’s constitution, the Committee consists of three appointed Councillors; the Committee may also co-opt non-voting independent members. The Committee members for 2020/21 were Councillors Alexandra Sanderson, Helen Rowbottom and Belinda Donovan. There were also two non-voting co-opted members, Miriam Shea and Sir Stephen WaleyCohen, both of whom are also members of the Friends of Wormwood Scrubs.

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Day to day running of the Trust is undertaken by officers in line with the Committee’s scheme of delegation. The de facto chief executive of the Trust is Kim Smith, the Council’s Chief Executive. Steve Hollingworth, Assistant Director (Leisure, Sports & Culture), is the officer responsible for the day to day running of the Trust. The Council’s Director of Finance, Emily Hill, is the Trust’s chief finance officer.

The Council's Standard’s Committee provides advice and training for Councillors. Under the constitution, Councillors are required to accept a personal responsibility to take up such opportunities for training and development that may be provided by the Council to better to carry out their duties as effective members.

Objectives and Activities

The Scrubs is the subject of a charitable trust created by the Wormwood Scrubs Act 1879. The Council is the sole corporate trustee and holds the land in trust for the “use by the inhabitants of the metropolis for exercise and recreation”. This is the Trust’s sole objective.

The Trust seeks to encourage sporting and recreational use of the Scrubs through the provision and maintenance of an environment that is conducive to its objective. The Trust is not linked with the prison located nearby.

The Linford Christie stadium is sited on the Scrubs and was built by the Greater London Council when that body was responsible for the Scrubs. The stadium is operated by the Council and the Trust makes an annual contribution to its running costs.

In addition to supporting the recreational activities provided by the Council through the Linford Christie stadium, the Trust’s main activity relates to the maintenance of the Scrubs itself. Since 6 May 2008, IDVerde UK (which acquired Quadron Services Ltd in 2016) has provided a grounds maintenance service at Wormwood Scrubs following a procurement exercise run by the Council.

The Trustee has paid due regard to the Charity Commission's public benefit guidance in preparing its annual report. The Trust delivers public benefit in meeting its charitable objective of holding the land in trust in accordance with the 1879 Act.

Public Benefit

The Trustee has referred to the Charity Commission’s guidance on the public benefit when deciding the activities the charity should undertake. The charity provides public benefit by maintaining an environment to enable sporting and recreational use by the public.

Fundraising

The Trust does not actively fundraise. The Trust does not contact or seek funding from the public or individuals, nor does it work with professional fundraisers

Working with the Friends of Wormwood Scrubs

The Trust continues to work closely with the Friends of Wormwood Scrubs and two of its members are co-opted onto the Committee as non-voting members. Regular contact has been maintained with the Friends of Wormwood Scrubs throughout the year and the Trust and

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those involved in the day-to-day management of the site welcome their updates in terms of observations and views on works required.

The Wormwood Scrubs Development Manager worked with the Friends of Wormwood Scrubs to develop proposals for the £3.9m biodiversity improvement project and in the identification of general management issues on a day to day basis.

High Speed 2 (HS2)

HS2 Bill – Environmental Improvement Works

The agreement between HS2 and the Council dated 20 October 2016 secured £3.9m for alternative ecological mitigation (AEM) works. These works were agreed as an alternative to the ecological mitigation within the HS2 Bill and form an appendix to the agreement.

Land Use Consultants (LUC) collated information on the significance and use of the Scrubs to produce a Conservation Management Plan (CMP). This was used to inform the public. Design proposals were developed over Autumn 2020 and Spring 2021 and were presented to a Committee subgroup in March 2021 and further consultation is on-going.

HS2 Bill – Stamford Brook Sewer Realignment

The planned re-route of the Stamford Brook sewer through the northern section of the Scrubs will involve digging a trench, disturbing ecology and temporarily cutting off sections of the Scrubs for public use.

A variation to HS2’s consented access route across the Scrubs was granted Planning consent in January 2021. This will limit ecological damage by providing a shorter and less ecologically sensitive route. A legal agreement is in place to protect and reinstate the ecological habitats in this process.

Works to re-route the sewer and utilities equipment are planned to start in Summer 2021.

HS2 Bill – Compulsory Purchase orders

HS2 has served preliminary notices of compulsory purchase for three areas of Wormwood Scrubs open space. These comprise:

• an area of 14.04 square metres, adjacent to Old Oak Common Lane (OOCL) to accommodate the realignment of OOCL and footpath. Once the work has been completed this would form part of the highway under the responsibility of the London Borough of Ealing.

• The UTX site, to allow HS2 to grant easements to the utility companies; and

• An area of subsoil under the UTX site.

The Trust are seeking compensation for these CPOs and confirmation that the UTX site will be returned to the Trust once HS2s work has been completed.

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Old Oak and Park Royal Development Corporation (OPDC)

The OPDC came into existence with full planning powers over the Old Oak and Park Royal regeneration area (including most of the Scrubs but excluding the Linford Christie stadium) on 1 April 2015.

OPDC Draft Local Plan

The draft Local Plan contains their land use and spatial strategy over the next 15-20 years and contains policies on housing, community facilities, transport, the environment, and more. These policies will guide future development, and proposals for development will be assessed against the policies contained within the OPDC’s Local Plan. The Trust has played a full part in responding to any consultations and formulation of the OPDC’s Local Plan.

The Draft Local Plan can be viewed here: www.london.gov.uk/opdclocalplan

A revised draft Local Plan was submitted to the Planning Inspector in March 2021. The Inspector’s Report is expected to be published in early 2022 before the Local Plan is adopted by the OPDC in Spring 2022.

Habitat and Ecology

Biodiversity surveys completed in 2016 and 2017 and the CMP formed the basis of recommendations for the AEM (Alternative Ecological Mitigation) proposals presented by LUC in March 2021. These proposals include a 10-year management and maintenance plan to maximise habitat improvement for wildlife as well as regular surveys to demonstrate improvements to biodiversity. The AEM proposals will not be able to tackle all the issues at the Scrubs as the HS2 funding is limited to ecological improvements. Nevertheless, both the CMP and the management and maintenance plan will identify options to address issues with other funding mechanisms.

The proposals for the northern boundary are likely to be the most complex due to the range of habitats, the influence of the Japanese knotweed and the realignment of the Stamford Brook Sewer along this route.

Kensington Aldridge Academy (KAA)

This Kensington Aldridge Academy is located very close to Grenfell Tower in North Kensington. In the aftermath of the fire in June 2017 it was apparent that the school could not operate from that site. It identified the old gravelled military training area in the Scrubs (sometimes known as the ‘Redgra’) as a suitable site for temporary school buildings and set about seeking the permission of the Trust, the planning authority and the Ministry of Defence to use the site.

Temporary structures were installed over the summer of 2017 and the school was ready for occupation in September. The Academy pays the Trust a suitable market rent which is greater than the income it would normally receive by renting out the area for short term uses, such as lorry parking for trade shows at Olympia.

It is anticipated that the Academy will remain on the Scrubs for several years and planning permission and rental arrangements are being reviewed on an annual basis.

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Achievements and Performance

Sport

Currently, the Linford Christie Outdoor Sports Centre (LCOSC) and the Scrubs itself boasts eight full size football pitches, three junior nine-a-side pitches, two junior seven-a-side pitches and two junior five-a-side pitches. In addition, there are two Gaelic football pitches, seasonal baseball pitches and a football pitch in the central area of the athletics track which is the home pitch of the Kensington Dragons Football Club senior team. The facility also offers a fully certified athletics track and five all weather pitches.

The facility is the home of Thames Valley Harriers Athletics Club and PHC Chiswick Hockey Club.

A number of other sports activities take place on the Scrubs including:

• Tackle Africa Football Tournament

• London Junior Baseball League

• Pretty Muddy

• British Athletic League meetings

• Weekend 5K Park Runs

• Extensive school usage including district sports day

With the onset of the Covid-19 pandemic all sporting activities were temporarily suspended. Many activities have now resumed, subject to government guidelines and recommendations.

Events

A number of sporting events (above) were held on the Scrubs without incident and enjoyed by all participants. The Trust remains interested in facilitating a small number of larger events and discussions continue with companies that specialise in organising these. As a consequence of the Covid-19 pandemic, all events with the exception of filming were suspended.

Grounds Maintenance and Site Management

Officers and the contractor, IDVerde UK, have worked hard over the last year to ensure the grounds maintenance of the site is kept at an acceptable standard. This has included a number of volunteer projects such as laying bark chippings to stabilise some of the wettest pathways through the Scrubs, as well as the tasks undertaken on a routine and reactive basis scheduled below as part of the grounds maintenance contract:

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----- Start of picture text -----
Activity
Maintenance of all grass pitches including within Linford Christie Stadium
Grass cutting all non-pitch areas across the site including play areas and dog area
Strimming across the site and Linford Christie Stadium
Maintaining grass path access through scrub areas allowing access to nature
Pruning and maintenance of hedges and access routes through copses and woodlands
Maintaining and pruning of all shrub bed areas
Low level tree works and reporting defects and further action required
Inspecting daily three on-site play areas reporting defects and further action required
Attending to vandalised or damaged equipment, facilities or surfaces
Emptying of litter/dog waste bins
Cleansing hard surfaces across the site including within the Linford Christie Stadium
Treating of Japanese Knotweed and Giant Hogweed
Cleansing and sweeping synthetic pitch areas within Linford Christie Stadium
Litter picking across the site including within the Linford Christie Stadium
Leaf clearance across parts of the site (leaves in woodland areas are left as mulch)
Attending to fly tips and clearance after illegal encampments
Liaising with site and facility users and Parks Constabulary
Assisting in the preparation for large events
Assisting with Volunteer initiatives
----- End of picture text -----

The operation of sports, playgrounds, BMX track and outdoor gyms has been subject to prevailing government regulation during the Covid-19 pandemic. Sports facilities were reopened during 2021, subject to guidance and regulations.

The Scrubs is a very popular site attracting a diverse range of users from dog walkers to model aircraft flyers; from ornithologists to those wanting a quiet walk. The closure of many indoor recreational facilities and the recommendations on social distancing has brought more people than usual to the Scrubs, with residents seeking an open space for exercise. This has resulted in pressure on open spaces. Although this has begun to diminish due to the opening up of other recreation opportunities, parks and open spaces are still significantly busier than usual.

The current Grounds Maintenance contract will end in February 2022 and the to tender for a new contract has been completed. The new contract is expected to be for 5 years, with an option to extend for a further 5 years, commencing in February 2022. Under the new contract, the maintenance of the Scrubs will form a separate contract, enabling a more targeted and responsive approach.

Community Safety

The Scrubs continued to be patrolled by the Borough’s uniformed Parks Police Service using vehicles, pedal cycles, and on foot. No major crimes were reported, and most incidents involved anti-social behaviour. The encampments established by HS2 protestors at the north of the Scrubs were patrolled and monitored, and the protesters left the site in September 2021.

The Parks Police Service was restructured as the Law Enforcement Team in April 2021, patrolling across all council sites and continuing to offer the same level of service as the Parks Police.

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Licensing for professional dog walkers was introduced this year and will be monitored to provide feedback on the effectiveness of this measure.

Financial Review

The Trust is reporting a surplus of £48,984 in 2020/21. This is £54,880 less than budget mainly due to the impact of the of Covid-19 pandemic on pay & display and cashless parking income, which was £87,244 below budget.

The main reason for the surplus is the continued income received from the Kensington Aldridge Academy (KAA) for the operation of the school, which was £315,658 in 2020/21. KAA are now expected to remain on site for a few more years.

A summary of the Trust’s financial position, together with the historical position, is below:

The main income sources were the short-term KAA occupation; pay & display parking income (from four machines) and cashless parking income from the Wormwood Scrubs car park; and licence income for the Hospital’s use of the other car park. Additional income was also achieved from filming, the Park Lodge and utilities licensing.

The Linford Christie stadium is operated by the Council and the Council has, historically, borne the majority of expenditure associated with its operation. The Trust however contributes to the Linford Christie stadium (together with other sports facilities located on the Trust grounds) to promote it objectives to support exercise and recreation.

Since 2016/17 the Trust’s contribution has been limited to £31,500 however it was agreed in 2020/21 budgeting process to make an additional contribution of £30,000 to the stadium’s repairs. The 2020/21 contribution, therefore, totalled £61,500. The contribution stated in the Income and Expenditure Statement is slightly higher (at £63,963) as this reflects the absorption of governance and recharge costs.

Expenditure incurred by the Trust is in line with the objectives of the Trust.

Within total funds brought forward, the Trust has fixed asset funds of £5,000,001 relating to the valuation of the car park and tangible fixed assets in their existing use. The remaining, unrestricted income funds are solely used for the specific purposes of the Trust. These total £938,377 as at 31 March 2021 (see the Statement of Accounts note 12), an increase of £49,984 when compared to 2019/20.

No capital projects were undertaken in 2020/21.

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Plans for future periods

In approving the budget for 2021/22, the Committee took account of essential asbestos removal and roadway improvements. Originally predicting a £31,595 surplus, the budget was adjusted to a £113,675 deficit. Kensington Aldridge Academy (KAA) licence income is the main reason for the Trust’s increase in unrestricted funds since 2017/18. The extension of the KAA licence to July 2021 and expected further extensions will continue the significant favourable impact on 2021/22 and 2022/23 accounts.

The Committee is determined to bring the financial performance of the Trust to breakeven or better over the longer-term. This will however need to be balanced against Trust’s core objectives and the Trust is keen to ensure that any development around the site does not threaten its integrity. As part of future plans, it has been proposed that a regeneration manager is appointed to act on behalf of the Trust.

The Trust is seeking ways to ensure a steady progress towards being able to operate at a breakeven position or better with normal activities. To create this secure financial position in the longer-term, the Trust is working on optimising the use of its assets and developing events on the Scrubs. Consultation with residents and key stakeholders will be part of this plan. Prior to the Covid-19 pandemic. the Trust was optimistic of such income and approaches to organisers included:

• Secret Cinema to build a temporary set on the Scrubs in 2021 and put on performances over the summer for a 4-week period. The capacity for each show would be approximately 4,000 people.

• small music festival organisers, attracting audiences of approximately 5,000, to consider the Scrubs as a suitable site. Should interest be forth coming, consultation will again be conducted with residents and key stakeholders before agreement and terms reached.

Grounds Maintenance (GM) is the Trust’s main expenditure. The existing contract has been extended until 1 February 2022 to design a new specification and carry out the procurement process.

• This procurement has sought to obtain a price and specification for Wormwood Scrubs that can be part of, or separate from the overall contract, depending on the advantages offered by the Contractor in terms of economies of scale.

• The specification will ensure that the Biodiversity management required due to the unique nature of the Scrubs is included and can be part of the 10-year conservation management plan developed as part of the AEM project.

Future plans will be closely monitored and subject to regular review in light of the Covid-19 pandemic. This will be managed through the regular management reports to the Committee.

Reserves and Treasury Management Policy

The Trust’s reserves policy is to consider the level of its balances annually, taking into account;

• Whether the Trust has approved a balanced budget

• The robustness of the assumptions and calculations that have underpinned the budget strategy

• The frequency and effectiveness of in year budget monitoring

• The effectiveness of Risk Management

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• The affordability of its commitments in respect of grounds maintenance and support of the Linford Christie stadium

• The review of, and the opinion on, the Trust’s financial statements by the External Auditor

• The condition of the Trust’s assets

• The affordability considerations of prudential borrowing

The Fund’s general unrestricted income funds of £938,378 represents an amount approaching 100% of the Trust’s gross annual expenditure. This is considered prudent and provides a solid base for operating over the medium term. However, the Trust recognises that recent surpluses are underpinned by temporary income sources and balancing its income and expenditure in the longer-term remains a challenge. The Committee has a key role in improving financial performance.

Determining an adequate level of balance requires professional judgement in the context of assessing performance against the key criteria listed above. Consequently, it is considered inappropriate to stipulate either a minimum or a maximum level of balances held. It is considered more important that the key criteria are reviewed annually at the time of preparing the annual revenue budget and reviewing the previous year’s performance.

Pay and display parking income in 2020/21 has decreased by £112,000 compared to 2019/20, due the impact of Covid-19 restrictions in place at the beginning of the financial year. Added to this pressure is increased grounds maintenance costs due to annual contract inflation and contributions to the running costs for the Linford Christie Stadium. The Trust continues to closely monitor and scrutinise its income and expenditure. Council officers are focussing on reducing the net expenditure of the Trust in the short, medium and long term. Increased income is being targeted through initiatives to optimise use of the scrubland.

The Trust’s cash balances are managed by the Council. The Council’s Treasury Management Strategy governing the investment policy adopted, was adopted by the Council in February 2020. The Committee report can be found on the Council’s website at the following location:

http://democracy.lbhf.gov.uk/documents/s112425/Treasury%20Management%20Strategy%2 0Statement%20202021.pdf

Risk Management

• The Trustee has a risk management strategy which comprises:

• An annual review of the risks the charity may face

• Establishment of plans to mitigate those risks identified

• Implementation of steps designed to minimise any potential impact on the charity should those risks materialise.

The work has identified only a few risks and the situation is being monitored. A key element in the management of risk is managing income and expenditure and setting a reserves policy with regular review by the Committee. The full schedule of risks is set out overleaf.

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Risk Assessment Schedule 2020/21

Risk Index No.	AREA OF RISK	IMPACT OF RISK	SEVERITY High/Medium/ Low	POTENTIAL High/medium /Low	VALUATION	COMMENT
001	High Speed 2 Railway and the development of Old Oak	Adverse impacts on the Scrubs that are contrary to the objectives of the Trust	High	Medium	May not be a financial loss	Trust is engaging with HS2 and TFL and the Old Oak Development Corporation to agree outcomes that do not adversely impact.
002	Pay and Display income level	Lower income levels due to decisions taken about Pay and Display tariffs.	Medium	Medium	Potential loss of income.	Usage fluctuates. Pay & Display tariffs are set to match those in nearby streets. The introduction of cashless parking has significantly reduced the theft risk.
003	Hammersmith Hospital Trust car park income	The licensing agreement with Hammersmith Hospital Trust has a three- month notice period with a possible impact on the level of income.	High	Medium	Potential loss of income.	The hospital relies on the car park. The Trust has been successful in securing increased income from this source in recent years.
004	Condition – Wormwood Scrubs car park	Wormwood Scrubs car park is in need of resurfacing.	High	Low	Significant expenditure.	There is no obligation on the Trust to carry out capital repairs to the area of car park leased to the hospital. However, both the Trust and the Hospital are obliged to cover the Routine Repair Fund costs of up to £10k per annum if required.
005	Insurance claims against Trust	Liability of trust in case of personal injury claims.	Low	Low	Possible liability of Trust in case of insurance claim.	Wormwood Scrubs would be covered by the Council’s insurance.
006	Safety of Artillery Wall	Cost of demolition, collapse could possibly lead to damage or liability of Trust.	Medium	Medium	Cost of demolition or insurance claims.	The condition of the wall is being monitored. The Council are considering demolishing it at no cost to the Trust.
007	Costs of Operating Linford Christie Stadium	Contribution by the Trust varies according to the trading conditions for the stadium	High	Medium	Expenditure could be significant	In some years this contribution has been small, but it is volatile. The financial performance of the stadium is monitored closely.
008	Fraud and financial irregularities	May cast doubt over the Trust’s ability to continue as a going concern	High	Low	Cost could be significant	Accounts are independently audited annually.

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Statement of Trustee’s Responsibilities in respect of the Trustee’s Annual Report and the financial statements

The charity trustee is responsible for preparing a trustees’ annual report and financial statements in accordance with applicable law and United Kingdom Accounting Standards (United Kingdom Generally Accepted Accounting Practice).

The law applicable to charities in England and Wales requires the charity trustee to prepare financial statements for each year which give a true and fair view of the state of affairs of the charity and of the incoming resources and application of resources, of the charity for that period. In preparing the financial statements, the trustee is required to:

• select suitable accounting policies and then apply them consistently;

• observe the methods and principles in the applicable Charities SORP;

• make judgements and estimates that are reasonable and prudent;

• state whether applicable accounting standards have been followed, subject to any material departures that must be disclosed and explained in the financial statements;

• prepare the financial statements on the going concern basis unless it is inappropriate to presume that the charity will continue in business.

The trustee is responsible for keeping proper accounting records that disclose with reasonable accuracy at any time the financial position of the charity and to enable them to ensure that the financial statements comply with the Charities Act 2011, the applicable Charities (Accounts and Reports) Regulations, and the provisions of the Trust deed. It also responsible for safeguarding the assets of the charity and taking reasonable steps for the prevention and detection of fraud and other irregularities.

The trustee is responsible for the maintenance and integrity of the charity and financial information included on the charity’s website in accordance with legislation in the United Kingdom governing the preparation and dissemination of financial statements.

Disclosure of Information to Auditors

The Trustee who held office at the date of approval of this Trustee’s Report confirms that, so far as it is aware, there is no relevant audit information of which the charity’s auditor is unaware; and the Trustee has taken all steps that ought to have been taken as a trustee to make itself aware of any relevant audit information and to establish that the charity’s auditor is aware of that information.

Auditors

The Trustee appointed MHA Macintyre Hudson during the year to undertake the audit of accounts in this year. The Independent auditor’s report to the Trustee of Wormwood Scrubs Charitable Trust follows on page 14.

For and on Behalf of Wormwood Scrubs Charitable Trust Signed

Name: Stephen Hollingworth

Date: 31 January 2022

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Independent auditor’s report to the Trustees of Wormwood Scrubs Charity

Opinion

We have audited the financial statements of Wormwood Scrubs Charitable Trust (the 'Charity') for the year ended 31 March 2021 which comprise the Statement of Financial Activities, the Balance Sheet, the Statement of Cash Flows and the related notes, including a summary of significant accounting policies. The financial reporting framework that has been applied in their preparation is applicable law and United Kingdom Accounting Standards, including Financial Reporting Standard 102 'The Financial Reporting Standard applicable in the UK and Republic of Ireland' (United Kingdom Generally Accepted Accounting Practice). In our opinion the financial statements:

• give a true and fair view of the state of the Charity's affairs as at 31 March 2021 and of its incoming resources and application of resources for the year then ended;

• have been properly prepared in accordance with United Kingdom Generally Accepted Accounting Practice; and

• have been prepared in accordance with the requirements of the Charities Act 2011.

Basis for opinion

We conducted our audit in accordance with International Standards on Auditing (UK) (ISAs (UK)) and applicable law. Our responsibilities under those standards are further described in the Auditor’s Responsibilities for the audit of the financial statements section of our report. We are independent of the group and parent charity in accordance with the ethical requirements that are relevant to our audit of the financial statements in the UK, including the FRC’s Ethical Standard, and we have fulfilled our other ethical responsibilities in accordance with these requirements. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.

Conclusions relating to going concern

In auditing the financial statements, we have concluded that the Trustees’ use of the going concern basis of accounting in the preparation of the financial statements is appropriate. Our evaluation of the Trustees’ assessment of the entity’s ability to continue to adopt the going concern basis of accounting included critical reviews of budgets and forecasts provided. Based on the work we have performed, we have not identified any material uncertainties relating to events or conditions that, individually or collectively, may cast significant doubt on the Charity's ability to continue as a going concern for a period of at least twelve months from when the financial statements are authorised for issue.

Our responsibilities and the responsibilities of the Trustees with respect to going concern are described in the relevant sections of this report.

Other information

The Trustees are responsible for the other information. The other information comprises the information included in the Annual Report other than the financial statements and our

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Auditor's Report thereon. Our opinion on the financial statements does not cover the other information and, except to the extent otherwise explicitly stated in our report, we do not express any form of assurance conclusion thereon.

In connection with our audit of the financial statements, our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the audit or otherwise appears to be materially misstated. If we identify such material inconsistencies or apparent material misstatements, we are required to determine whether there is a material misstatement in the financial statements or a material misstatement of the other information. If, based on the work we have performed, we conclude that there is a material misstatement of this other information, we are required to report that fact.

We have nothing to report in this regard.

Matters on which we are required to report by exception

We have nothing to report in respect of the following matters where the Charities (Accounts and Reports) Regulations 2008 requires us to report to you if, in our opinion:

• the information given in the Trustees' Report is inconsistent in any material respect with the financial statements; or

• sufficient or proper accounting records have not been kept; or

• the financial statements are not in agreement with the accounting records and returns; or

• we have not received all the information and explanations we require for our audit.

Responsibilities of Trustees

As explained more fully in the Trustees’ responsibilities statement included in the Trustees’ Annual Report, the Trustees are responsible for the preparation of the financial statements and for being satisfied that they give a true and fair view, and for such internal control as the Trustees determine is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error.

In preparing the financial statements, the Trustees are responsible for assessing the Charity's ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless the Trustees either intend to liquidate the charity or to cease operations, or have no realistic alternative but to do so.

Auditor's responsibilities for the audit of the financial statements

We have been appointed as auditor under section 144 of the Charities Act 2011 and report in accordance with the Act and relevant regulations made or having effect thereunder. Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are

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considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements. Irregularities, including fraud, are instances of non-compliance with laws and regulations. We design procedures in line with our responsibilities, outlined above, to detect material misstatements in respect of irregularities, including fraud. The extent to which our procedures are capable of detecting irregularities, including fraud is detailed below:

• Obtaining an understanding of the legal and regulatory frameworks that the entity operates in, focusing on those laws and regulations that had a direct effect on the financial statements;

• Enquiry of management and those charged with governance around actual and potential litigation and claims;

• Enquiry of staff to identify any instances of non-compliance with laws and regulations;

• Performing audit work over the risk of management override of controls, including testing of journal entries and other adjustments for appropriateness, evaluating the business rationale of significant transactions outside the normal course of business and reviewing accounting estimates for bias;

• Reviewing minutes of meetings of those charged with governance;

• Reviewing financial statement disclosures and testing to supporting documentation to assess compliance with applicable laws and regulations.

Because of the inherent limitations of an audit, there is a risk that we will not detect all irregularities, including those leading to a material misstatement in the financial statements or non-compliance with regulation. This risk increases the more that compliance with a law or regulation is removed from the events and transactions reflected in the financial statements, as we will be less likely to become aware of instances of non-compliance. The risk is also greater regarding irregularities occurring due to fraud rather than error, as fraud involves intentional concealment, forgery, collusion, omission or misrepresentation.

A further description of our responsibilities for the audit of the financial statements is located on the Financial Reporting Council's website at: www.frc.org.uk/auditorsresponsibilities. This description forms part of our Auditor's Report.

Use of our report

This report is made solely to the Charity's Trustees, as a body, in accordance with Part 4 of the Charities (Accounts and Reports) Regulations 2008. Our audit work has been undertaken so that we might state to the Charity's Trustees those matters we are required to state to them in an Auditor's Report and for no other purpose. To the fullest extent permitted by law, we do not accept or assume responsibility to anyone other than the Charity and its Trustees, as a body, for our audit work, for this report, or for the opinions we have formed.

MHA MacIntyre Hudson Statutory Auditor London, United Kingdom Date: 31/01/2022 MHA MacIntyre Hudson is eligible to act as an auditor in terms of section 1212 of the Companies Act 2006.

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Reference and Administrative details

Charity Name and Number

Wormwood Scrubs Charitable Trust, Registration No. 1033705

Emily Hill Director for Finance Wormwood Scrubs Charitable Trust Hammersmith Town Hall King Street W6 9JU

Charity Correspondent King Street W6 9JU Trustee Telephone [phone] Email Address Governing Document Objects Area of Benefit

The Council of the London Borough of Hammersmith & Fulham

[e-mail]

Wormwood Scrubs Act 1879 As Amended by Scheme of The Charity Commissioners Dated 25 March 2002.

For recreational use as set out in the Wormwood Scrubs Act 1879

Wormwood Scrubs and West London. (Area prescribed by Governing Document)

Area of Operation

Greater London – Hammersmith and Fulham

Registration History 23 Feb 1994 Registered

Auditor Details

MHA MacIntyre Hudson 6th Floor, 2 London Wall Place London EC27 5AU

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STATEMENT OF ACCOUNTS Vlomwood Scwub5 CharilableTNst ststenBrtof Flnanclal Acijvhles (kntowp￿a1ln9 an Income •tt(YJnt)forYe¥￿d8d 31 Marth 2021 Ir¢w ar￿ E¥ r&rfwre Notes I￿ne a￿] endLwmutsfrL¥n.' I￿ryne trom Chan•b￿3(tmOes." Payand Dis￿aY Parkiw Mete[5 Hammèrsmith Car Path 212.757 3S3 $47 324.946 3489gS 3 OthertrathrwJ I￿oMe from InvesThents I￿oMe trom donat￿ll5 ￿grants 338.391 3.020 94.365 315.441 6,631 201.883 rqo 95,895 Ex drtureon-. char1tame3cb￿tie￿.' Cortn￿1)ntO Lintord Christie srajium n R(rtine Maintenance rfWormwo(KJ ScTubs RoutineGrcuDd5 M£4ntenance ufWDrmwood Scrubs Charible expen¢Slire 163.9631 I￿.205> 1779,3701 IY.3651 1738,3681 12frfl,3951 OU*rexpendilu R￿￿￿1rd￿0[FUnQ fL¥)d5 brlluYhtf￿Ward 5.889.393 5.742.188 C3TrfedfrywJd Al aCtNIti￿ olherthan thosedi5cknsed in Note 12 are unres1nrt￿1. 19

W(ffiN¥ood Scrubs charfIa￿T￿$t Balancé ShÈÉtas at 31 Marh 21121 2019no Fixed ts5d5 T￿gible Ass 5.OW.001 5.OfK),WI Add.. CurrentAsset5 Cash in Bank 10 Deblars 684,358 3rN),277 30.800 310.723 Le55'. Liablibe5 11 CreditLYS'. AM￿lntSfaIIi￿9 dUe￿ithin one year 146.2581 ThEfunds Dfthethari UNesDitted ReSuv￿. Unr￿tnCted Incrthefund5 Revaluation ￿SerVe 1938,3771 15.OW.0011 IW.3921 15.000,0011 70ts1 ChWtyF&￿d5 15gW781 Appmd on 31st1￿u￿2D22and SIgn￿ on tht4hby. S*phen Hdllnwrth As515kntDtrxknr-LeI5￿spD￿&¢U￿r 20

Wornwood ScNbs Charflatrl•TNst t4otes Slan￿￿Of Cash Flow5 fOrywend￿ 31Mwch 2021 13 Nei cash 0¥￿e1 ￿￿0￿eratin 3CDvibes X,537 37 ¥267 Ca5hfbw5frryn iTrrtstingathib£5.' Diwdends. Interest and r￿￿5 from Investments 3.020 6.631 6￿31 ca5haMI ca5hW4thts kn therq1￿ k￿ld 53 Cash and cash eouivalents at the be9inniNJ ofthe reporow perffAI 630.8 622,902 Womw•oodScrnbsClwllA•TNs¢ Atal MthXQI Cosh& l¥nka￿ in hty .8 53.557 684.357 21

Notes to the Accounts

(1) Statement of Accounting Policies

(i) Basis of preparation and assessment of going concern

The accounts (financial statements) have been prepared under the historical cost convention with items recognised at cost or transaction value unless otherwise stated in the relevant notes to these accounts. The financial statements have been prepared in accordance with the Statement of Recommended Practice: Accounting and Reporting by Charities preparing their accounts in accordance with the Financial Reporting Standard applicable in the UK and Republic of Ireland (FRS 102) issued on 16 July 2014 and the Financial Reporting Standard applicable in the United Kingdom and Republic of Ireland (FRS 102) and the Charities Act 2011.

The trust constitutes a public benefit entity as defined by FRS 102.

In preparing the accounts, the trustee has considered whether in applying the accounting policies required by FRS 102 and the Charities SORP FRS 102 a restatement of comparative items was needed. No restatements were required relating to the previous year’s accounts. The functional currency is £ sterling.

The trustee has a reasonable expectation, including considerations for any potential disruption and economic impact caused by the Covid-19 pandemic, that the charity has adequate resources to continue in operational existence for the foreseeable future. They therefore continue to accept the going concern basis of accounting in preparing the financial statements. There were not any material uncertainties exist in arriving at this conclusion.

(ii) Accounting Concept

The accounts have been prepared on an accruals basis. That is, on the basis of income being due and expenditure being payable in the related financial year.

(iii) Fixed Assets, revaluation and depreciation

The Trust has ownership of land, passed under the Wormwood Scrubs Act 1879 for the perpetual use of the inhabitants of London for exercise and recreation. Due to the restrictions on the use of the land and its disposal, it is included in the balance sheet at a fair value at the point of donation. As there are no records of this value a nominal value of £1 is used. This is in line with FRS102. The car park is held at historic value. This was initially established by a valuation in 2004 which has been used as ""deemed cost"" on transition to FRS 102, though the Trust does not operate a policy of revaluation. Depreciation has not been charged to tangible fixed assets (the land or the car park) as these are considered to have an indefinite useful economic life. The trustee is not aware of any indication that an impairment has occurred. Further exploration of land interest is included within areas of significant judgement and estimates.

(iv) Income Recognition and Incoming Resources

All income is recognised once the charity has entitlement to the income, it is probable that the income will be received, and the amount of income receivable can be measured reliably. Material income includes Pay and Display parking fees and filming income, that would be recognised this way.

The Trust has a licensing agreement with Hammersmith Hospital NHS Trust (HHT), for the use of a limited number of parking spaces within the car park, making use of surplus capacity. The Trustee considers that the arrangement is consistent with the Trust's objectives, as the arrangement can be terminated at any time.

(v) Expenditure Recognition and Resources Expended

Liabilities are recognised as expenditure as soon as there is a legal or constructive obligation committing the charity to that expenditure, it is probable that settlement will be required, and the amount of the obligation can be measured reliably. All expenditure is accounted for on an accruals basis. All expenses including support costs and governance costs are allocated or apportioned to the applicable expenditure headings.

(vi) Allocation of support and governance costs

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Support costs have been allocated between governance costs and other support costs. Governance costs comprise all costs involving the public accountability of the charity and its compliance with regulation and good practice. These costs include costs related to statutory audit and legal fees together with an apportionment of overhead and support costs. Governance costs and support costs relating to charitable activities have been apportioned proportional to the expenditure on a particular activity. The allocation of support and governance costs is analysed in note 7.

(vii) Financial Instruments

The Charity holds only basic financial instruments, comprising Cash, trade debtors and trade creditors. These are measured as follows:

Financial instrument	Measurement on initial recognition
Cash	Amortised cost
Debtors – including trade debtors and loans receivable (trade accounts and notes receivable)	Settlement amount after any trade discounts (provided normal credit terms apply) or amount advanced by the charity
Creditors – including trade creditors and loans payable (trade accounts and notes payable)	Settlement amount after any trade discounts (provided normal credit terms apply) or amount advanced to the charity

viii) Areas of significant judgements and estimates

Accounting for land interests and associated economic flows

The land interests at the Scrubs are complex and governed by the Wormwood Scrubs Act 1879 (hereafter “the Act”). Under the Act the land at the Scrubs is held in trust for “the perpetual use thereof by the inhabitants of the metropolis for exercise and recreation”. The Act identified the Metropolitan Board of Works, and successor bodies, as trustee. Through various local authority re-organisations and subsequent provisions, the London Borough of Hammersmith and Fulham (LBHF) is the current successor body and is sole trustee of the Wormwood Scrubs Charitable Trust.

The land registry records ownership of the land in the name of “The Mayor and Burgesses of Hammersmith and Fulham”. Under the Act, the Scrubs can be reserved for military training (giving the Ministry of Defence (MoD) certain rights over the land) but outside of this they are reserved for recreational use for the public. This right for the public to enjoy the Scrubs is protected in perpetuity and cannot be taken, nor the land sold, unless the area “ceases to be used by the citizens of London”.

Under the Act, the ability to maintain and improve land rests with the administering authority (i.e. the trustee) and there have been further clarifications in subsequent agreements and memoranda. The MoD cannot build permanent structures on the Scrubs; however, the MoD must also consent to any development by the administering authority.

It is the judgement of the trustee that the land at the Scrubs is controlled by the Trust by virtue of the Wormwood Scrubs Act and as such the land interests at the Scrubs are accounted for within the Trust’s accounts. Any reference in title to LBHF is deemed to be as the trustee of the Trust, not the Council. Under the provisions of the Act, the Trust is judged to be responsible for, and controls the benefit of, the land both in terms of public access for recreation and economic benefits with respect to any income that might be generated relating to the assets.

The trustee has considered the impact of Covid-19 in making these significant judgements and estimates, and the pandemic has not resulted in them changing.

Other judgements

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The Trust has estimated that application of the governance costs is proportional to level of expenditure on each charitable activity.

The Trust’s policy is not to revalue assets, however, should an impairment indicator come to light assets would be subject to impairment. This is a matter of judgement and as stated, the Trustee is not aware of any indication that an impairment has occurred in 2020/21

ix) Reserves

The reserves of the Trust are unrestricted under FRS102 insofar as they are not restricted to any particular activity, however the Trust considers the revaluation reserve to be an unusable reserve with regard to decision making given the inherent restrictions placed on asset disposal under the Wormwood Scrubs Act 1879.

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18) GwemJKec05ts The Governa￿e costs assttk4ted with the charity are albcated to eath of the chantsb￿ Actnntie5 las per FR51021, as a wcentage afthe gro55 expenditure. reswrce5 e¥Fended that rdate to the governar£e ofthe ch7rity con515t ofthe fclknwin Fin￿£la1 Admin$trotion and Supp(rtfees- Ihe5e ctrts re5ultfrom Ihe 5tsfut(xy rwuiremert to ptepare &counts. Also i￿Ud￿l are the costs of the ￿me spwt liatsiw and ftxelng with auditors, and att￿dIng ch)INJ of ￿COurt meetiws. Lega1 Fee5. In the manag￿￿nt of theTrust dunng the year ￿gaI ad¥￿e was Tequired. This was provided by Legal Servie5 of LBHF and ifve charge5 were based ￿ a staff time ba55. A￿lt Fee5 linxcordance with statutory independent audit re(Winr￿ts>. 4,582 4.301 18.528 4.487 9.950 9.750 W38 Allttation ofthe G￿erna￿e costs.. Actiwty c0rtribut￿n to Linfvrd Chfi5tie Stdlium f+)D 11(wtine Maifjtenance of WomiY40oJ 5crub5 Routine Gr￿ThdS Mainienance of w￿mW(nd Scmbs Otker F￿[￿litU 2.463 1.705 30.005 19.900 2.1?0 19ITarylJkAssets Tt Trnst's L8nd 8nd Buik1ings I￿lUde an A0)￿lic8 sradium, Pony CÈntre, tr￿ee botrotsm cottage aTh1 storey pa￿S dewi all of whlch are valued as a Mminal £1 due to the reStnCts"￿S placed the use of the knd and its disposal. TtrE AthletKs Strdium wa5 built in 1961 GEater L￿d0￿ Cwnul IGLCI 3rKI prior to tsE crEatiw vf tIE L￿dIN} B£￿￿g￿ of HaMM￿sm￿ha[xl FLlham. who afÈ now rÈsponsible for administerirKJtrt Tnst. T￿re is no availab￿ dwumentattonto dely￿r$trate thatapprovJ has bea) gained by 5Écr•t3ry of State for Dél•nc•. TIE pL￿V CwtrE Yla5 given apwoval to be tsu1￿ by the Secretary of Stste fvr Deffen￿. TIÈ car park i% irKluled in the accounts at historic cost in line wth FR5102. The Val￿ inclu￿1 6 £5,000,C¥)O, To esttJ)ltsh a proxyfor htstonc cost the asset was valued on t￿ 31st March 2004 and this has been treated as deemed cost on trdngtion to FRS 102. Tkt Trust does nrt orerate 3 wlicy of revalu3bon car park classffiwj a5 a funrtK)nal tangible fixed asset a5 the use of th￿ land 15 considered as consistent with the charity'5 objeLtive5. TfeTrust not dep￿Ciate ts assets as tw a￿ all ¥￿thoUta d#wminable finite useful life li.e. Eandl ty ofa rK)minal value li.e. £1) IJOI Debtor5 Wfre re¥￿￿e have been rec¢)3nised but cash ha5 not ￿en ￿￿eNed. a dett￿ for Tdevant ar￿￿nt is recorded in thè Ba￿ce s￿et w￿re the e￿￿t amount of a debtor wa5 not known at the tin￿ of cbsing the accourt5 then an estimatwj amount ha5 been u5vJ. Trade debtors P¢paymwts and accrtthl 186.216 114.061 3LN)277 114.537 196.186 314n3 25

expendibJre have beai rerognised but cash ha5 not been paid. a cTe(Ji(or fLW relevart is OFded in trE 8IJKe SIEeL WtrEre ttrE eX￿t amount of è ￿(storWa$ rot knthn at the time ofcbsing the &courts tFEn èn estimat£￿ TK)Urt been us£Q. 20Xfal AccNa 129.4911 129,4911 131,9171 Deferred irthme 2021¥21 8￿ughtfOrWard baL3nce Released in the year Year bal￿e 123.6591 3.446 I￿2￿) 3.446 116,7671 (J21 Fwd Structyrn: TIETru5t¥ Urwe5tricted Funds COMW￿￿. 202W21 Generol Unrestricted InCOff￿ Fl￿d5 1938.3771 1889.3921 FiKed Asset Revali&4tyon Reserve 15.000.001) 15.000.001 119383781 1$8893931 All fund5 are unrestrictèy funds solely used f￿ t￿ srecrfic purpose of theTrusL I￿orne aThJ Expiditurewtrch meet5 tlis criteria is credked Ichorged to fund. t(xJether witha fail alltKation of fflanagementarKI 5LPPOrt Costs. as recharged by LBHF. The H52 attiViti￿ (income of £94.365 atwj expenditure of £94.365 in 2020-2l, ctmpared to irK(n of £201,883 expendiwre of £200.395 in 2019-201 a￿ (lew￿ ￿$bItted. However, tre iM￿tt on IS ITTTmdLEiidl tJLEdUSE ExpEndituie 15 MEL tjy lunQing. Trust consider5 ttE revaluation [￿erve to be an Unusab￿ reserve re9ard to deosiM maknno gwen tsE irthewt restricbons on assct d6ro5al undertr Wom)wo¢ Suubs Aa 1879. 1131 Netcash Fknwlmm 2021V21 48,984 147.205 A4Y}i￿trnthts tr. Liwdends. interestaRxYrents fR?m￿￿estn￿ts Loss/tpmfitJ onthe5bleoffixÉLla55pts (Increa5eWdKreJseindeblvrs Incre3SWId&o￿e1I￿ 8nd￿re1￿1￿COnpe 13.0201 16.6311 10.446 15.8731 337 1146.2781 6.971 1267 Ca5hfun& are hdd by t￿C0￿clI on behalf of the Trust Council of L(￿d￿ Borough of Mammersmitharyj FLlham IL8HFI 15 tt tN5tee of charty. MLEt exwditure tranSaCt￿nS of TDJSt with LBHF tIÈrdo￿ tsll under tsE definitionof rdated party tran5aCtK)ns. However, a5 5tsted t￿$ does nL confiitt w￿h cF&ATiiY5 atslity to meL ds ot4"ectNes. Th￿e are no staff empk)yed by ts charty. 202W21 . LBIIF&s crntrartorto the Tntst Environment rpartment fortr p￿1$1￿ ¢YRfAJtineGrounds mainter￿n(e ofwom)WfA)d SryLJbs IR¥ Note 71 . LBmFasrtr￿la7t0lCrnt￿thfi 749,365 723,535 Conthbubm kn Linfotd Christ siadium (Rd 61 61,500 82.500 . L8HFasgmw6erofaLlminstr&tionalandnHnaJemwtSWPOrtto the Imst ENironment Department for management & financlal adminisrr3tK)n senrices of wormwo￿ Scntjs L￿al ServKe5 forthe provision of I￿31 afvice required in the manageMentofWormw￿d Scrubs 4,582 4,301 18,528 75 4.487 Amotsnts dtsgt0orfromrÈktsY￿kne￿. 26

1151Tw5tBe Bwefi15 arKI Expw5 Cthnties SORP IFRS 1021 requires all t￿ste@ lor peop￿ tonnÉtèd the cFrityl remuneration. 8rJ Èxwses to be dtsclosed. regardless ofsYLe. There has been rn reMUn￿3￿.(￿. other be￿fir or expense payMts totmstees. or Pe￿Ie connected wrth the charity. I￿) Stsff Costs TIE Trust has not Incurr￿ any staff costs during tsE year. 1171 Em¥A￿lIcaSts Tf Tnjst has the folk)¥%ing cc6ts in rdati(x) to audti ofthe Statement ofAccounts srattrttyy prty￿ed bytheTnst¥ exÈm¥ ath1itors.' Fees payabk to the Ext￿31 Atxlitor ￿th war¢to extwrol audit servKes out by the app)Srrted auoitorfor thc yeor 9,950 9.750 9.950 9.750 181 PostBtKe SheetEvats ThÈTnJst has had no material adjusting or rKJn-adjL6b"NJ events afterthe balance sheet date of 31 March 2021. The impartofCOVID-l9 conts"n￿ to be closeky assessed and is likely to have an adverse impact on certain future income Streams however a￿hOUgh the f￿an(la1 effect canryjt te estimated the Tru5tdoe5 not consider Ihi5 will irnpact the baiince 5tEet as at 31 March 2021. 27