Tower Limited/Announcement
Tower Limited logo

Tower Limited Amended 2018 Annual Report

Annual Report30 January 2019TWRFinancials

2018
Tower Limited

Annual Report

2
Looking back on a year

of transformation, strong

growth and customer

confidence.

Tower has a history spanning nearly 150 years.

What started as a conversation to provide fairer,

local insurance to those who called New Zealand

home is now the Tower Insurance of today.

As we transform into a challenger brand, we

once again find ourselves in a position where

we’re challenging the market and offering Kiwis

a genuinely different choice for insurance.

Tower Snapshot

2

Over the past year...
• Added over 18,000 risks to our core New Zealand portfolio

• Grew GWP in our core New Zealand portfolio by 11.9%

• Launched risk based pricing, resulting in 4% growth in larger,

low risk areas like Auckland and Taranaki, while reducing our

exposure in extreme risk areas by an annualised figure of 17%

• Increased sales through digital channels to 45% of new

business in September 2018, up from less than 10% in FY16

• Hit the half way point of our major technology upgrade with

new business to be on sale on the new platform midway

through the 2019 calendar year

3

4
Our ambitious plan is all about

New Zealanders and Pacific

Islanders being able to see


Tower in a new light, and for

Tower to set the bar for how


insurance ‘should’ be.

Tower Limited annual report 20184

For almost 150 years
Tower has been insuring

New Zealanders, and over

the course of those years,

has transformed and

changed considerably.

A little over two years ago, we embarked

on our latest – and arguably most difficult –

transformation to date, to reposition the

business as a contemporary, challenger

brand, underpinned by a customer-focused,

digital-first strategy to successfully compete

in the 21st century.

We recognised that we hold a unique position in the

New Zealand insurance market. We have a solid existing

customer base, yet plenty of room to continue growing and

acquiring market share from the two large incumbents.

Over the past 18 months, research has shown us that

customers are unhappy with insurers. Our goal is to challenge

industry norms to change this because we believe this

customer dissatisfaction provides us with opportunity.

Our ambitious plan is all about New Zealanders and Pacific

Islanders being able to see Tower in a new light, and for Tower

to set the bar for how insurance “should” be. We believe that

delivering unique customer value through amazing claims

experiences will be our key differentiator and will build strength

and long-term value in our business.

Our focus on customers and the creation of new products and

processes will enable amazing claims experiences and allow

us to reach our challenger brand aspiration faster. This will be

supported with continued refinement of our underwriting,

enhanced operational efficiency and the replacement of our

core IT platform.

Over the past year we have delivered a number of proof

points that demonstrate our transformation is well underway.

New technology is accelerating growth with work already

completed resulting in a significant uplift in customers. In the

past year we added over 18,000 risks to our core New Zealand

portfolio, grew GWP in the core New Zealand portfolio by 11.9%

and saw total GWP reach $336 million across New Zealand

and the Pacific. Online sales comprised 45% of new business

in September 2018, up from less than 10% in 2016.

This uptake from our customers is proof that our confidence

in user-friendly technology is well placed.

Throughout the year we continued investing in our business,

building capability to enable growth and we achieved this

while reducing our expense ratio almost 1%, to 39%.

We are also well progressed on our technology upgrade,

recently moving through the half way point, where costs are

within tolerances, however like all projects of this nature there

remains risk and complexity in the delivery. We are managing

this with robust governance controls at all levels.

It is unfortunate that this growth and good progress has

been offset by increased claims costs and the settlement of

the Peak Re dispute earlier in the year. Weather in the Pacific

was the most significant impact on claims costs along with

some prior year development in New Zealand and other costs.

Each of these is well understood with pricing and underwriting

responses either already implemented or in train to improve

performance through the coming year.

Achieving settlement with Peak Re marked an important

step towards finalising this legacy issue and resulted in a

$16.2 million after-tax impact on profit.

These results show that we are removing legacy risks and

at the same time, realising the potential in the underlying

Tower business.

We are proud of the vision for Tower and the commitment

and passion of the team that is working to see our

transformation come to life. It is gratifying to see Tower’s

approach really resonating with our customers and as a

result, delivering the substantial growth seen in 2018.

Shareholders can be confident that the work we are doing

will deliver significant long-term value.

Update from the Chair and CEO

on behalf of the directors

Richard Harding

Chief Executive Officer

Michael Stiassny

Chairman

5

Features of full year 2018.
• Transformation of core business well underway and driving

strong GWP growth in the core New Zealand book of 11.9%

on the prior year, and strong volume growth, with 18,192

risks added to the core New Zealand book

1

• Claims costs increased due to severe weather in the Pacific

along with some prior year development in New Zealand

and other cost impacts. Each of these is well understood

and pricing and underwriting responses either already

implemented or in train to improve performance through

the coming year

• Major technology upgrade progressing well, with

replacement of core platform with leading technology

tracking well

• Reported full year loss of $6.7 million impacted by

-$16.2 million after-tax impact from Peak Re settlement

-$11 million before-tax impact from weather and

large events

-Minor adjustment to Canterbury provisions,

resulting in a $3.6 million after-tax impact

• Continued positive progress closing Canterbury

earthquake claims, with open claims almost halved,

down to 163, from 323 on October 1 2017

Tower management review

Full year to 30 September 2018

Tower Limited annual report 20186

7
GWP Growth in core

NZ book on prior year

11.9%

7

Full year
summary

Tower has strong

underlying New Zealand

and Pacific businesses

and the 2018 Financial

Year has seen the

continued delivery

against its strategy

to transform.

With a focus clearly on simplifying and

improving all aspects of our business to

differentiate the company, strong growth

in GWP and customer numbers, contained

expenses and a major technology upgrade

progressing well, all demonstrate that

transformation is well underway.

The implementation of risk-based pricing and continued

improvements in digital channels added 18,192 new risks

2

to

Tower’s core New Zealand portfolio, seeing core NZ GWP for

the year grow 11.9% contributing to total GWP of $336 million.

Tower reported a loss after tax of $6.7 million for the year

ended 30 September 2018 (FY18), narrowing from a loss of

$8 million for the year ended 30 September 2017 (FY17).

The strong growth of $23.7m in gross written premium and

$13.1m in net earned premium has been offset by storm

activity, higher claims costs, the resolution of the Peak Re

dispute as well as an increase in ultimate incurred claims

for Canterbury.

Severe storm activity in New Zealand and the Pacific resulted

in an $11 million before-tax impact to underlying profit, seeing

it decline to $13.6 million, from $18 million in the year prior.

Tower Limited annual report 20188

1. Following the end to Tower’s distribution relationship with Kiwibank on 4 April 2018,
the ‘core’ portfolio now refers to the NZ business excluding the ANZ Bank and

Kiwibank portfolios. The FY17 comparative has been restated to be consistent

with this approach.

2. In prior years Tower has reported volumes using policy numbers as the relevant

metric. Tower has changed to using risk numbers as the key metric in FY18 to align

with internal management reporting and to better illustrate risk exposures, e.g.,

where one policy might cover several risks.

9

Claims costs increased over the 2018 financial year, with

weather in the Pacific the most significant impact along

with some prior year development in New Zealand and

other cost impacts. Each of these is well understood

and pricing and underwriting responses either already

implemented or in train to improve performance through

the coming year.

Severe weather across the Pacific increased claims

costs significantly in FY18. Cyclone Gita impacted

Tonga heavily, while Cyclones Keni and Josie impacted

Fiji, resulting in a 10.4 percentage point uplift on the

Pacific FY17 claims ratio. Reinsurance is being utilised

to minimise impacts of weather along with ongoing

refinement of products and underwriting criteria.

New Zealand claims expenses also increased over the

2018 financial year due to a number of claims challenges,

however, these are being countered with pricing and

underwriting responses to improve performance.

A continued focus on non-personnel costs saw the

management expense ratio decrease almost 1% to 39%,

while still allowing further investment in the business.

Tower’s Pacific premium remains stable and in line with

the same period in the prior year, however, underlying

profit of $2.2 million has been impacted by Cyclones Gita,

Josie and Keni and a small number of commercial fires.

Tower continues to make solid progress settling claims in

Canterbury, reducing open claims by 160. On October 1 2017,

Tower had 323 open claims remaining. In the intervening 12

months, the number of open Canterbury Earthquake claims was

reduced to 163, with 318 claims closed, however, 115 new claims

from the EQC were received and 43 claims were reopened.

Group Profit Summary (NZ$m)

1

$ MILLIONFY18FY17Change

Gross written premium336.1 312.4 23.7

Gross earned premium323.1 306.1 17.0

Reinsurance expense(53.1)(49.2)(3.9)

Net earned premium270.0256.9 13.1

Net claims expense(141.2)(124.2)(17.1)

Large events claims expense(11.0)(7.4)(3.6)

Management and sales expenses(105.4)(102.4)(3.0)

Underwriting profit12.422.9 10.5

Investment revenue and other revenue7.2 6.1 1.1

Financing costs(0.6)(0.8)0.3

Underlying profit before tax19.1 28.2 (9.2)

Income tax expense(5.5)(10.2)4.7

Underlying profit after tax13.6 18.0 (4.5)

Peak Re settlement(16.2)0.0(16.2)

Christchurch impact(3.6)(18.6)15.1

Kaikoura impact0.3(4.1)4.5

Corporate transaction costs(0.2)(3.1)2.9

Foreign tax credit write-offs(1.2) (1.9) 0.7

Business in runoff(0.0)1.7(1.7)

Other non-underlying items0.60.00.6

Reported loss after tax(6.7)(8.0)(1.3)

9

Transformation momentum
is accelerating

Tower holds a

unique position in the

New Zealand insurance

market, with a solid

existing customer base,

yet plenty of room

to grow.

A clear strategic plan to continue

transforming and growing the business

by delivering a compelling, challenger

proposition to the market will see Tower

turn industry norms upside down and

revolutionise the way customers interact

with us.

The achievements seen to date show that there is a powerful

platform for future growth with progress in crucial areas:

• Focus on customers has delivered strong growth

• Management expenses ratio has reduced,

while continuing to invest

• Major technology upgrade progressing well

• Increases to claim costs well understood with

action taken to offset inflation

Tower Limited annual report 201810

11
Overview

• Strong GWP growth of 11.9% in core book with total

GWP growing strongly at 7.6%

• Growth in risks in core New Zealand book increased

significantly by 18,192

• 45% of new business sales online in September 2018,

up from less than 10% during FY16

• New approach to pricing combined with simple and

easy products driving impressive customer growth

and improved mix

Tower’s focus on customers has seen continued growth in

its core New Zealand portfolio in FY18, with 18,192 risks

added to the core book and GWP increasing 11.9%.

With Tower’s new product suite fully available online, and

continued refinement and optimisation of the digital sales

channels, more customers are choosing Tower, delivering

a significant uplift in new business sales, with 45% of new

business sales online in September 2018, up from less

than 10% in FY16.

In the Pacific, Samoa, American Samoa and the Solomon

and Cook Islands have returned to growth thanks to additional

underwriting, pricing and marketing support for local teams.

However, this growth has been offset by the continued

remediation of the Papua New Guinea portfolio to reduce

risk and exposure which will lead to improved profitability.

This positive result across Tower’s businesses is being

achieved through a combination of:

• Ongoing pricing improvements in New Zealand motor, house

and contents portfolios to offset increased claims costs

• Constant refinement of underwriting criteria enabling more

granular assessment to improve profitability of portfolio

• Attracting new, profitable customers with improved and

targeted offerings;

• Building and refining Tower’s digital offering and online

sales process

• The creation of the Pacific operations centre, centralising back

office functions, ensuring that the pricing and underwriting

approach is consistent and minimises claims leakage

Growth in GWP (NZ$m)

FY17 GWPNZ RateNZ VolumePacific GrowthRemediation

in PNG

FY18 GWP

312.4

336.2

15.3

8.2

2.4

2.1

Focus on customers driving growth

11

New Zealand and Pacific
claims expenses

Overview

• Claims costs increased across New Zealand and Pacific

• Inflation is well understood and has been addressed through

pricing and underwriting responses already implemented or

in train to improve performance through the coming year

• Strengthened underwriting and risk selection in the Pacific

to improve profitability

New Zealand claims expenses increased in FY18 due to a

number of claims challenges, however, these challenges are

well understood and swift action has been taken to address

each of them.

Throughout the year an increase in the development of open

FY17 claims was experienced. The reserving model used didn’t

respond well during the claims backlog experienced due to

storms, understating expected development of claims in FY17.

This resulted in a 1.2 percentage point increase in the claims

ratio and the reserving methodology has now been updated

accordingly.

Tower’s new, simpler products have resulted in a decrease in

NZ House claim frequency, however, this positive result has

been offset by an increase in severity, driven by a number of

large house fires and the increased costs relating to increasing

Health & Safety costs and asbestos testing requirements

which are both industry-wide issues driven by regulatory

change. In response to these issues Tower has strengthened

pricing and improved its underwriting criteria and expects to

see improved outcomes in the coming year.

Supply chain constraints and inflation continues to impact the

industry with increasingly advanced technology in cars seeing

the cost of repair rise. Tower is addressing motor claims inflation

through pricing and more granular underwriting.

A higher cost per claim in Tower’s NZ Contents book is also

linked to the increase in house fires and work has been

completed to actively address this through improved pricing

and underwriting.

In the Pacific, severe weather increased claims costs significantly

in FY18. Cyclone Gita impacted Tonga heavily, while Cyclones

Keni and Josie impacted Fiji, resulting in a 10.4 percentage point

uplift on Tower’s FY17 Pacific claims ratio.

In Fiji, an increase in claims expenses mostly relates to motor

claims inflation and in Tower’s National Pacific Insurance

business, a small number of large commercial fires have driven

the claims ratio higher.

Reinsurance is being utilised to minimise impacts of weather

and constant refinement of Tower’s pricing, product offering

and underwriting criteria in response to weather events and

claims inflation means that Tower expects to see its claims

ratio excluding large events revert to prior year levels.

Tower Limited annual report 201812

13
FY17 claims ratio,

including large

events

0.8%

1.2%

-1.3%

Year on year change in the claims ratio – New Zealand

1.1%

0.6%

0.6%

Change in

products mix

vs FY17

Increases to prior

year claims

FY17 adjusted for

claims re serving

and mix

Improved claim

frequency on

NZ House

Higher cost

per claim on

NZ House

Higher cost

per claim on

NZ Motor

Higher cost

per claim on

NZ Contents

FY18 claims ratio,

including large

events

57.2%

56.2%

54.2%

FY17 claims

ratio, including

large events

0.3%

9.2%

Year on year change in the claims ratio – Pacific

-1.5%

3.6%

4.0%

Change in

products mix

vs FY17

Cyclone

Gita

Cyclones

Josie and

Keni

FY17 adjusted

for storms and

country mix

Papua New

Guinea

Fiji,

excluding

cyclones

NPI,

excluding

cyclones

Other

countries

FY18 claims

ratio, including

large events

-1.2%

51.8%

1.2%

36.2%

46.9%

13

Severe weather events and
reducing volatility

Overview

• Severe and unprecedented weather drove increased

claims expenses in both FY17 and FY18

• Losses for these two years are significantly

above long-term trends

• Gross impact of weather events in FY18,

before reinsurance $20.1 million

• Reinsurance structure will reduce volatility from

exposure to large events with FY19 reinsurance

secured on favourable terms

The past two years have seen a number of unprecedented and

severe weather events that have impacted communities and

the business beyond expectations. Impacts to Tower in FY17

totalled $15.5 million before reinsurance, and this year reached

a gross amount of $20.1 million, well above both Tower’s 10 year

average of $7.6 million, and its five year average of $11.3 million.

This is not unique to Tower, with industry wide losses in

New Zealand from weather in the 2018 calendar year

totalling over $200 million so far.

In response to these increased impacts Tower has adjusted

pricing and strengthened its reinsurance programme to

increase cover and reduce volatility from large events in FY19

Tower has:

• Doubled its aggregate cover from $10 million to $20 million

and increased the excess from $7 million to $10 million

• Increased cover for single large events from $5 million

to $7.5 million, once its excess of $10 million is used

• Purchased drop-down cover to bridge the gap between

aggregate and catastrophe cover

• Secured FY19 reinsurance on favourable terms

Tower is putting in considerable effort and taking all appropriate

steps to preserve capital and reduce any volatility from these

short-term weather abnormalities.

Building capability while

controlling costs

Achievements

• Management expense ratio continues to improve

• Investment made to build capability and deliver growth

Tower has maintained its focus on non-personnel related

costs, reducing the management expense ratio to 39% in FY18,

compared to 39.9% FY17.

Tower has achieved a significant capability lift with a lower

expense ratio thanks to close management of costs. Tower has

increased capability in the pricing and underwriting, technology

and digital, data lake, data science, claims management,

procurement and customer insights areas.

In addition, the management expense ratio of 39.0%, includes

incremental investment of:

• $1.0m to reduce cyber security risks

• $1.2m on acquisition, including partnerships and marketing

• $0.7m on ancillary IT system refresh

Tower expects expenses will continue to stabilise as simplification

programme initiatives are embedded, with a step change in

productivity gains to be realised after the implementation of its

new IT platform.

Tower Limited annual report 201814

1515

Major technology
upgrade underway

Overview

The key to accelerating Tower’s transformation is a new IT

platform that enables the simplification of products and

processes. This will remove complexity for frontline teams

and enable the delivery of a unique and revolutionary

customer experience.

Combined with Tower’s push to move 50 - 70% of all

transactions online, removing complexity from the business

will deliver significant cost savings and productivity gains.

Tower is now approaching the half way mark of this programme

and progress to date is in line with expections. This programme

is complex and includes legacy replacement, digital

enhancement and product rationalisation. The programme

remains on track to deliver in the first half of the 2019

calendar year.

At the half way point costs are within tolerances, however like

all projects of this nature there remains risk and complexity in

the delivery. Tower’s robust governance controls include a

focus on managing delivery risk and cost trade-off.

Key benefits to be seen from Tower’s new IT platform include

the ability to:

• Create and deliver a unique customer experience

• Quickly deliver simple, customer focussed products

• Target specific, profitable customer segments through

granular, and automated pricing and underwriting

• Charge fairer and more accurate premiums through improved

access to, and use of, internal and external data

• Easily trial new products and pricing

• Rationalise products and reduce claims costs by improving

the customer claims journey and overall claims management

• Significantly reduce our cost base and realise large

productivity gains by moving low value transactions online

• Add value through improved employee engagement

Tower’s approach to implementing this new IT platform

is designed to deliver on a dual purpose – accelerate

transformation and protect and realise shareholder value.

Tower’s robust governance approach and clear roadmap

forward will enable Tower to commence selling new business

on the new platform in the first half of the 2019 calendar year.

Once new business is live, migration of the existing book

can start.

Canterbury update

Tower continues to make solid progress settling claims in

Canterbury, reducing open claims by 160. On October 1 2017,

Tower had 323 open claims remaining. In the intervening 12

months, the number of open Canterbury Earthquake claims was

reduced by 318. However, 115 new claims from the EQC were

received and 43 claims were reopened.

Tower’s gross outstanding claims have more than halved since

September 2016. This demonstrates that solid progress is being

made. In addition, the amount of IBNR / IBNER and risk margin

has increased from 60% to 95% of case estimates.

Tower also welcomes the recent government announcement of

an enquiry into EQC as an important step toward ensuring that

mistakes of the past are learnt from and not repeated in future.

EQC Act reform will assist in ensuring past experience is not

repeated and that the pitfalls and problems associated with the

EQC set up and the 2010 model can be avoided. Tower strongly

believes that the Kaikoura model is successful and that any

reform of the EQC must include these changes.

Tower Limited annual report 201816

17
$ MILLIONSep 18Mar 18Sep 17Mar 17Sep 16

Case estimates37.548.0 58.973.993.2

IBNR/IBNER

1

21.4 22.0 34.4 47.4 44.0

Risk margin9.010.813.918.211.9

Additional risk margin5.010.010.0--

Actuarial provisions35.442.858.365.655.9

Gross outstanding claims72.990.8 117.2139.5149.1

Ratio of provisions to case estimates

2

95%89%99%89%60%

1. IBNR / IBNER includes claims handling expenses

2. Ratio of IBNR / IBNER plus risk margin to case estimates

17

Solvency position
Overview

Tower holds significant capital over and above the minimum

regulatory requirement.

As at 30 September 2018, following the Peak re settlement and

the weather events earlier this year, Tower Insurance Limited

held approximately $78 million of solvency margin, $28 million

above RBNZ requirements and equivalent to 234% of minimum

solvency capital.

An additional $25 million in corporate cash is also held

by Tower Limited.

Tower retains access to undrawn debt facilities and has

a preference to fund remaining IT investment from debt.

Net cash held in corporate

TIL's solvency margin above RBNZ minimum

TIL's RBNZ minimum solvency margin

TIL's MSC

BNZ facility (drawndown)

25

39

50

59

28

25

50

58

38

50

61

-30

1

200%

180%

100%

Tower Insurance Limited solvency

position plus corporate cash ($m)

30 Sep 17 31 Mar 1830 Sep 18

Tower Limited annual report 201818

19
Overview

Tower is transforming, and is focussed on progressing initiatives

that will continue accelerating momentum and deliver long-

term shareholder value.

Tower has provided a one-off guidance for FY19 to demonstrate

its confidence in the strategy and performance of its underlying

business. Tower’s guidance for underlying NPAT in FY19 is in

excess of $22m.

This includes the following assumptions:

• Continued momentum in revenue growth and sales through

improved digital channels

• Underwriting and pricing changes will be implemented,

continuing to drive improvement in mix of risk, as well as

addressing inflation

• Pacific contribution will return to normal levels

• The management expenses ratio will be maintained at a

steady level

• The Aggregate excess will be fully utilised for weather events

Accordingly, Tower’s Board has determined that in FY19,

Tower will pay a dividend of 50% to 70% of reported NPAT

where prudent to do so.

Tower is being transformed and the work underway will

deliver significant long-term value

Outlook

19

Over the past two years
we’ve spoken about the

significant opportunity

that exists in the Tower

business. Our clear

strategic plan is seeing

us realise this potential

with our transformation

into a digital challenger

brand well underway.

Our desire to step outside the confines of

a traditional insurer to challenge industry

norms, along with our dynamic size means

that we can make decisions faster and

capitalise on opportunities quicker and

more efficiently than our competitors.

There are many similarities between the New Zealand and

Australian insurance industries where two large multi-nationals

hold a high percentage of the market. In Australia, challenger

brands entered and achieved significant growth thanks to

their ability to quickly deliver something unique and targeted

to customers.

Over the past 18 months, research has shown us that customers

are unhappy with insurers. Our goal is to challenge industry

norms to change this because we believe this customer

dissatisfaction provides us with opportunity.

We believe that delivering unique customer value through

amazing claims experiences will be our key differentiator and

will build strength and long-term value in our business.

Our focus on customers and the creation of new products and

processes will enable amazing claims experiences and allow

us to reach our challenger brand aspiration faster. This will

be supported with continued refinement of our underwriting,

enhanced operational efficiency and the replacement of our

core IT platform.

With this work already delivering benefits and we are now

accelerating our progress to deliver a step change in results

and long-term shareholder value.

Delivering against our challenger strategy will enable us to

achieve our uplifted, medium-term operating targets of:

• GWP growth of 8-10%

• Combined Operating Ratio < 85%

• Return on equity of 14–16%

Transformation

Tower Limited annual report 201820

Customer and community
Our transformation is

driven by our purpose

to set things right for

our customers and

communities.

Over the past 18 months we’ve spent time

working with our customers to understand

their frustrations and what they think a

Tower of the future could look like.

As a result of this work, we’ve come to a firm belief that

customers deserve better and we have refined our customer

proposition to start offering customers a truly different choice

for insurance.

We are removing jargon filled policies and making our award

winning policies even simpler. Not only does this benefit our

customers, it reduces the complexity and leakage that comes

from having over 400 different products.

We will continue with our push for fairer pricing which will

allow us to grow in the large low risk areas, like Auckland and

Taranaki, that had previously been subsidising those in high-

risk areas. We have communicated this change openly and

honestly, receiving positive feedback about our approach and

we will continue operating and educating the community in

this way – transparently.

Our key differentiator will see us deliver amazing claims

experiences. Our new platform, combined with a number

of other ancillary systems, will increase automation. This will

improve the customer experience, reduce claim turn-around-

times and reduce leakage, resulting in improved efficiency

and profitability.

In September we launched our first community partnership

and Tower became staunch supporters of the New Zealand

Paralympic Team. This partnership signals a change for our

brand and a shift to closer connections with the communities

within which we operate. We will continue increasing our

presence and engagement with the community to improve

these connections and build a brand that is known for being a

part of local communities.

In the Pacific, our new operations centre will support local

teams through improved product, pricing and underwriting

capability to ensure we grow within our risk appetite. Complex

claims management will improve customer experience and

reduce leakage.

What we’re building will be unique and will continue to attract

more customers to Tower and drive strong growth.

21

The positive results
we’ve delivered in the

underlying business

are being driven by our

people and a noticeable

change in our culture.

We actively encourage our people to do

things differently and challenge the traditions

and norms of the industry in which we

operate. Pleasingly, we are seeing positive

shifts in our culture measures as well as

steady increases in employee engagement

measures over the past two years.

This passion to do things differently has seen our people

initiate and drive a number of projects that have improved

our performance thanks to improving customer experience.

We have reduced the amount of duplication occurring in

our back offices and implemented a number of diversity

and inclusion initiatives.

In 2018 we held our first annual Buddy Up day, where employees

from across the business buddied up with our frontline teams

to understand our current customer experience and the steps

we’re taking to improve this. Activities like this signal a shift in our

culture toward one that is more customer centric and focussed

on delivering on our strategy.

Throughout 2018 our employees also helped us celebrate

International Women’s Day, Diwali, the Paralympics

New Zealand Spirit of Gold Day, Chinese New Year,

Christmas, Matariki, Eid Mubarak, Te Wiki O Te Reo Maori,

Tongan Language Week, the Auckland Pride Parade and

launched a women’s networking and development initiative,

Lean-In.

In the coming year, our focus on diversity and inclusion

and improving culture and engagement will increase with

a continued drive to make Tower recognised as an employer

of choice.

Being an employer of choice is an important strategic decision

for us as it enables us to attract and retain employees who

continuously improve and reinvigorate the business and what

we do for our customers.

Our people

Tower Limited annual report 201822

23

Graham Stuart
BCom (Hons), MS, FCA

Non-Executive Director

Independent

Appointed Director: 24 May 2012

With over 30 years of senior

management experience, Graham has

held senior leadership roles with several

major corporates, in New Zealand and

overseas, the latest being the Sealord

Group of which he was Chief Executive

Officer for 7 years. Prior to that he held

a number of diverse leadership roles

including CEO of Mainland Products,

Managing Director of Lion Nathan

International, and Chief Financial Officer

and Director of Strategy for the Fonterra

Co-operative Group. Graham has a

Bachelor of Commerce (First Class

Hons) from the University of Otago, a

Master of Science from Massachusetts

Institute of Technology and is a Fellow

of Chartered Accountants Australia and

New Zealand. Graham has served on a

number of Government bodies including

the Food & Beverage Taskforce and the

Maori Economic Development Panel.

Graham resides in Auckland,

New Zealand.

Michael Stiassny

LLB, BCom, FCA, CFInstD

Chairman

Non-Executive Director

Independent

Appointed Director: 12 October 2012

Michael is a Fellow of Chartered

Accountants Australia and New Zealand.

He has both a Commerce and Law

degree from the University of Auckland.

He is Chairman of Ngati Whatua Orakei

Whai Rawa Limited, New Zealand

Transport Agency and is a director of a

number of other companies. Michael

is the immediate past President and

a Chartered Fellow of the Institute of

Directors in New Zealand (Inc).

Michael resides in Auckland,

New Zealand.

Board of Directors

Tower Limited annual report 201824

Steve Smith
BCom, CA, Dip Bus (Finance),

CFInstD

Non-Executive Director

Independent

Appointed Director: 24 May 2012

Steve has been a professional Director

since 2004. He has over 35 years'

business experience, including being a

specialist corporate finance partner at a

leading New Zealand accountancy firm.

He has a Bachelor of Commerce and

Diploma in Business from the University

of Auckland, is a member of Chartered

Accountants Australia and New

Zealand and a Chartered Fellow of the

Institute of Directors in New Zealand

(Inc). Steve is Chairman of Pascaro

Investments Ltd, and a Director of Rimu

S.A. (Chile) and the National Foundation

for the Deaf Inc.

Steve resides in Auckland,

New Zealand.

Warren Lee

BCom, CA

Non-Executive Director

Independent

Appointed Director: 26 May 2015

Warren has extensive experience

and a long record of leadership in

the international insurance industry,

including 15 years at AXA in senior

management positions within the

company’s Australian and Asian

businesses. Warren's two most

recent executive positions were Chief

Executive Officer of the Victorian Funds

Management Corporation and Chief

Executive Officer, Australia and New

Zealand for AXA Asia Pacific Holdings

Limited. Warren is a non executive

director of MyState Limited, a listed

Australian Financial Services Group

and the Go Hold Limited Group. He

has a Bachelor of Commerce from

the University of Melbourne and is a

member of Chartered Accountants

Australia and New Zealand.

Warren resides in Melbourne,

Australia.

Wendy Thorpe

BA (French), BBus (Accounting),

Grad Dip, Applied Fin & Inv,

Harvard AMP, FFin, GAICD

Non-Executive Director

Independent

Appointed Director: 1 March 2018

Wendy is an experienced financial

services leader and for the past 15 years

her executive career has focused on

leading technology and operations in

insurance and wealth management. Her

most recent executive role was as Group

Executive, Operations for AMP Ltd, and

she was previously Chief Operations

Officer and Chief Information Officer for

AXA Asia Pacific Holdings Ltd. Wendy

is also a Director of AMP Bank Limited,

Chair of Online Education Services Pty

Ltd, and a Director of Very Special Kids,

an Australian Not for Profit. Wendy has a

Bachelor of Arts from LaTrobe University,

a Bachelor of Business from Swinburne

University and a Graduate Diploma in

Applied Finance and Investment from

the Securities Institute of Australia. She

completed the Advanced Management

Program at Harvard Business School, is a

Fellow of the Financial Services Institute

of Australasia and a Graduate member

of the Australian Institute of Company

Directors.

Wendy resides in Melbourne,

Australia.

25

Contents
Independent

Auditor’s Report 27

Consolidated

Income Statement 33

Consolidated Statement of

Comprehensive Income 34

Consolidated

Balance Sheet 35

Consolidated Statement of

Changes in Equity 36

Consolidated Statement of

Cash Flows 37

Notes to the

Financial Statements 38-78

TOWER Limited

Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201826

27
The above statement should be read in conjunction 1ith the accompanying notes.

Tower Limited

Independent Auditor’s Report

For the year ended 30 September 2018

PricewaterhouseCoopers, 188 Quay Street, Private Bag 92162, Auckland 1142, New Zealand

T: +64 9 355 8000, F: +64 9 355 8001, pwc.co.nz

Independent auditor’s report

To the shareholders of Tower Limited

The financial statements comprise:

the consolidated balance sheet as at 30 September 2018;

the consolidated income statement for the year then ended;

the consolidated statement of comprehensive income for the year then ended;

the consolidated statement of changes in equity for the year then ended;

the consolidated statement of cash flows for the year then ended; and

the notes to the financial statements, which include a summary of general accounting policies.

Our opinion

In our opinion, the financial statements of Tower Limited (the Company), including its subsidiaries

(the Group), present fairly, in all material respects, the financial position of the Group as at 30

September 2018, its financial performance and its cash flows for the year then ended in accordance

with New Zealand Equivalents to International Financial Reporting Standards (NZ IFRS) and

International Financial Reporting Standards (IFRS).

Basis for opinion

We conducted our audit in accordance with International Standards on Auditing (New Zealand) (ISAs

NZ) and International Standards on Auditing (ISAs). 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 believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for

our opinion.

We are independent of the Group in accordance with Professional and Ethical Standard 1 (Revised)

Code of Ethics for Assurance Practitioners (PES 1) issued by the New Zealand Auditing and Assurance

Standards Board and the International Ethics Standards Board for Accountants’ Code of Ethics for

Professional Accountants (IESBA Code), and we have fulfilled our other ethical responsibilities in

accordance with these requirements.

Our firm carries out other services for the Group in the areas of solvency return assurance and agreed

upon procedures. The provision of these other services has not impaired our independence as auditor

of the Group.

Our audit approach
Overview

An audit is designed to obtain reasonable assurance whether the financial

statements are free from material misstatement.

Overall group materiality: $3,241,000, which represents approximately 1% of

premium revenue.

We chose premium revenue as the benchmark because, in our view, it is a key

financial statement metric used in assessing the performance of the Group and

is not as volatile as other profit and loss measures, and is a generally accepted

benchmark. The 1% is based on our professional judgement, noting that it is

also within the range of commonly accepted revenue related thresholds.

The following have been determined as key audit matters:

Valuation of outstanding claims

Valuation of EQC recovery receivables

Recoverability of the deferred tax asset

Materiality

The scope of our audit was influenced by our application of materiality.

Based on our professional judgement, we determined certain quantitative thresholds for materiality,

including the overall Group materiality for the fi nancial statements as a whole as set out above. These,

together with qualitative considerations, helped us to determine the scope of our audit, the nature,

timing and extent of our audit procedures and to evaluate the effect of misstatements, both

individually and in aggregate on the financial statements as a whole.

Audit scope

We designed our audit by assessing the risks of material misstatement in the financial statements and

our application of materiality. As in all of our audits, we also addressed the risk of management

override of internal controls including among other matters, consideration of whether there was

evidence of bias that represented a risk of material misstatement due to fraud.

We tailored the scope of our audit in order to perform sufficient work to enable us to provide an

opinion on the financial statements as a whole, taking into account the structure of the Group, the

accounting processes and controls, and the industry in which the Group operates.

Our Group audit scope focused on the most financially significant subsidiary, which contributes

approximately 83% of the Group’s premium revenue. We performed further audit procedures over the

balances and transactions of the non-significant subsidiaries and the consolidation of the Group’s

subsidiaries.

Tower Limited annual report 201828

29
The above statement should be read in conjunction 1ith the accompanying notes.

Key audit matters

Key audit matters are those matters that, in our professional judgment, were of most significance in our audit

of the financial statements of the current year. These matters were addressed in the context of our audit of

the financial statements as a whole, and in forming our opinion thereon, and we do not provide a separate

opinion on these matters.

Key audit matter How our audit addressed the key audit matter

(1) Valuation of outstanding claims (2018

$148 ,976,000, 2017 $181,156,000)

We considered the valuation of outstanding claims

a key audit matter because of the complexity

involved in the estimation process and the

significant judgements that management make in

determining the balance.

The valuation of outstanding claims relies on the

quality of underlying data and involves significant

judgements and assumptions given the inherent

uncertainty in estimating the expected present

value of future payments for claims incurred.

In particular, judgement arises over the estimation

of payments for claims that have been incurred at

the reporting date but have not yet been reported to

the Group, as there is generally less information

available in relation to these claims, and claims that

have been reported but there is uncertainty over the

amount which will be settled.

Outstanding claims include a risk margin that

allows for the inherent uncertainty in the central

estimate of the future claim payments. In

determining the risk margin, the Group makes

judgements about the volatility of each class of

business written and the correlation between each

division and between different geographical

locations.

Relevant references in the financial statements

Refer to notes B2, B3, B4 and B5 to the financial

statements, which also describes the elements that

make up the balance.

Our audit procedures included obtaining an

understanding of key controls, including key data

reconciliations and management review of the

estimates.

Historical claims data is a key input to the actuarial

estimates. Accordingly, we:

oEvaluated the design effectiveness and tested

controls over claims processing;

oRe-performed claims data reconciliations;

oAssessed a sample of claim case estimates at

the year end to check that they were

supported by appropriate documentation;

and

oInspected a sample of claims paid during the

year to confirm that they were supported by

appropriate documentation and approved

within delegated authority limits.

Together with PwC actuarial experts we:

oEvaluated the actuarial models and

methodologies used by comparing with

generally accepted models and

methodologies applied in the sector and with

the prior year;

oAssessed key actuarial judgements and

assumptions and challenged them by

comparing with our expectations based on

the Group’s experience, our own sector

knowledge and independently observable

industry trends;

oConsidered the work and findings of the

external independent actuaries engaged by

the Group; and

oAssessed the risk margin, by comparing to

known industry practices and the Actuaries

Institute recommended framework. In

particular we focused on the assessed level of

uncertainty in the central estimate.

We have no matters to report from the procedures

performed.

(2) Valuation of Earthquake Commission
(EQC) recovery receivables (2018

68,400,000, 2017 $65,100,000)

We considered EQC recovery receivables a key audit

matter because significant management judgement

is required t o value expected recoveries from EQC

in respect of land damage and building costs, as

these recoveries are subject to agreement with EQC.

The expected recoveries from EQC are related to the

Canterbury earthquakes which requires judgement

and actuarial expertise to evaluate the attribution of

claims cost between the major earthquake events, in

particular the September 2010 and February 2011

events.

Relevant references in the financial statements

Refer to notes B3 and E1 to the financial

statements.

We assessed management’s approach to estimate the

EQC recovery receivables. We reviewed

correspondence with EQC and held discussions with

management, lawyers, external advisors and external

independent actuaries to understand assumptions,

including the attribution of losses to the different

Canterbury earthquake events, used to establish the

right to recovery. We compared these assumptions

with sector peers and obtained evidence for any

significant variances.

We considered the range from which the amount

recognised has been determined and assessed whether

the current circumstances could support a different

recovery receivable amount.

We have no matters to report from the procedures

performed.

(3) Recoverability of the deferred tax asset

on tax losses (2018 36,376,000, 2017

37,782,000)

The Group has a deferred tax asset balance of

$36,376,000, of which $30,685,000 relates to

deferred tax assets arising from past tax losses.

We considered recoverability of the deferred tax

asset a key audit matter because it is sensitive to the

Group’s expected future profitability and its

entitlement to offset these losses against future

profits. Significant management judgement is

involved in forecasting future taxable profits which

are inherently uncertain.

Relevant reference in the financial statements

Refer to note D6 to the financial statements.

We evaluated management’s assessment of the

recoverability of the deferred tax asset, including

understanding the progress made by management in

improving the profitability of the business in recent

periods, which includes the remediation of the causes

of past losses through, amongst other things,

assessment of the Canterbury earthquakes claims and

related reinsurance and other recoveries (assessment

of the recoverability of the receivables from EQC) and

other expense reduction and income initiatives.

We assessed the operational plan used in the deferred

tax asset recoverability assessment by comparing

previous operational plans with actual results and

assessed the appropriateness of the assumptions used

in the operational plan. We used our tax specialist to

assess whether the Group is entitled to offset the tax

losses against future profits.

We have no matters to report from the procedures

performed.

Tower Limited annual report 201830

31
The above statement should be read in conjunction 1ith the accompanying notes.

Information other than the financial statements and auditor’s report

The Directors are responsible for the annual report. Our opinion on the financial statements does not

cover the other information included in the annual report and we do not express any form of assurance

conclusion on the other information.

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, based on the work we have performed on the other information that we obtained prior to

the date of this auditor’s report, 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, except that

not all other information was available to us at the date of our signing.

Responsibilities of the Directors for the financial statements

The Directors are responsible, on behalf of the Company, for the preparation and fair presentation of

the financial statements in accordance with NZ IFRS and IFRS, and for such internal control as the

Directors 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 Directors are responsible for assessing the Group’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 Directors either intend to liquidate the Group or to cease

operations, or have no realistic alternative but to do so.

Auditor’s responsibilities for the audit of the financial statements

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 NZ and ISAs will always detect a material

misstatement when it exists. Misstatements can arise from fraud or error and are considered material

if, individually or in the aggregate, they could reasonably be expected to influence the economic

decisions of users taken on the basis of these financial statements.

A further description of our responsibilities for the audit of the financial statements is located at the

External Reporting Board’s website at:

https://www.xrb.govt.nz/standards-for-assurance-practitioners/auditors-responsibilities/audit-report-1/

This description forms part of our auditor’s report.

Who we report to

This report is made solely to the Company’s shareholders, as a body. Our audit work has been

undertaken so that we might state those matters which 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 Company and the Company’s shareholders, as a body, for our

audit work, for this report or for the opinions we have formed.

The engagement partner on the audit resulting in this independent auditor’s report is Karl Deutschle.

For and on behalf of:

Chartered Accountants Auckland

28 November 2018

Tower Limited annual report 201832

33
The above statement should be read in conjunction 1ith the accompanying notes.

TOWER Limited

Consolidated Income Statement

For the year ended 30 September 2018

NOTE

2018

$000

2017

$000

Revenue

Premium revenueB1323,093 306,079

Less: Outwards reinsurance expense(54,251)(49,164)

Net premium revenue 268,842 256,915

Investment revenueC17,125 7,643

Fee and other revenue5,755 3,040

Net operating revenue281,722 267,598

Expenses

Claims expense200,467 225,384

Less: Reinsurance and other recoveries revenue(23,835)(37,833)

Net claims expenseB2176,632 187,551

Management and sales expenses D189,728 81,744

Impairment of reinsurance receivablesD222,511 –

Acquisition proposal expensesD3302 3,467

Financing expenses570 835

Total expenses289,743 273,597

Profit (Loss) attributed to shareholders before tax(8,021)(5,999)

Tax (expense) benefit attributed to shareholders’ profitsD61,295 (2,001)

Profit (Loss) for the year(6,726)(8,000)

Profit (Loss) attributed to:

Shareholders(6,773)(8,461)

Non-controlling interest47 461

(6,726)(8,000)

CENTSCENTS

Basic and diluted profit (loss) per shareF5(2.20)(4.12)

TOWER Limited
Consolidated Statement of

Comprehensive Income

For the year ended 30 September 2018

NOTE

2018

$000

2017

$000

Loss for the year(6,726)(8,000)

Other comprehensive income

Currency translation differences42 105

Gain on asset revaluationE3434 247

Deferred income tax relating to asset revaluationD6(81)(29)

Other comprehensive income net of tax395 323

Total comprehensive loss for the year(6,331)(7,677)

Total comprehensive (loss) income attributed to:

Shareholders (6,474)(8,143)

Non-controlling interest143 466

(6,331)(7,677)

Tower Limited annual report 201834

35
The above statement should be read in conjunction 1ith the accompanying notes.

TOWER Limited

Consolidated Balance Sheet

As at 30 September 2018

NOTE

2018

$000

2017

$000

Assets

Cash and cash equivalentsC2102,001 83,876

Receivables E1259,607 286,569

InvestmentsC3198,000 186,702

Derivative financial assetsC5271 231

Deferred acquisition costsD422,595 20,961

Property, plant and equipment E38,510 8,780

Intangible assetsE245,042 31,334

Current tax assetsD613,831 13,462

Deferred tax assetsD636,376 32,745

Total assets686,233 664,660

Liabilities

PayablesE580,375 68,824

ProvisionsE65,789 5,773

Insurance liabilitiesB4324,527 343,498

BorrowingsC4 – 29,921

Current tax liabilitiesD6174 560

Deferred tax liabilitiesD6589 340

Total liabilities411,454 448,916

Net assets274,779 215,744

Equity

Contributed equityF1447,543 382,172

Accumulated (losses) profit(58,077)(51,299)

ReservesF2(116,155)(116,454)

Total equity attributed to shareholders273,311 214,419

Non-controlling interest1,468 1,325

Total equity274,779 215,744

The consolidated financial statements were approved for issue by the Board on 28 November 2018.

Michael P Stiassny Graham R Stuart

Chairman Director

ATTRIBUTED TO SHAREHOLDERS
NON-

CONTROLLING

INTEREST

$000

TOTAL

EQUITY

$000NOTE

CONTRIBUTED

EQUITY

$000

ACCUMULATED

(LOSSES)

PROFIT

$000

RESERVES

$000

TOTAL

$000

Year Ended 30 September 2018

At the beginning of the year 382,172 (51,299)(116,454) 214,419 1,325 215,744

Total comprehensive income (loss)–(6,773)299 (6,474)143 (6,331)

Transactions with shareholders

Net proceeds of capital raiseF165,371 – – 65,371 – 65,371

Other – (5) – (5) – (5)

Total transactions with shareholders65,371 (5) – 65,366 – 65,366

At the end of the year447,543 (58,077)(116,155)273,311 1,468 274,779

Year Ended 30 September 2017

At the beginning of the year 382,172 (42,822)(116,772) 222,578 1,374 223,952

Total comprehensive income (loss) – (8,461)318 (8,143)466 (7,677)

Transactions with shareholders

Dividends paidF1 – – – – (515)(515)

Other – (16) – (16) – (16)

Total transactions with shareholders – (16) – (16)(515)(531)

At the end of the year382,172 (51,299)(116,454)214,419 1,325 215,744

TOWER Limited

Consolidated Statement of Changes in Equity

For the year ended 30 September 2018

Tower Limited annual report 201836

37
The above statement should be read in conjunction 1ith the accompanying notes.

TOWER Limited

Consolidated Statement of Cash Flows

For the year ended 30 September 2018

NOTE

2018

$000

2017

$000

Cash flows from operating activities

Premiums received 319,329 309,147

Interest received 8,010 7,734

Net realised investment gain (loss)(605)(1,928)

Fee and other income received5,285 3,040

Reinsurance received45,780 28,962

Reinsurance paid(52,327)(50,228)

Claims paid(231,843)(248,183)

Payments to suppliers and employees (80,614)(76,408)

Income tax paid(2,831)(4,908)

Net cash inflow (outflow) from operating activities C610,184 (32,772)

Cash flows from investing activities

Net proceeds from financial assets(6,815)2,852

Purchase of property, plant and equipment and intangible assets(19,802)(6,883)

Disposal of property, plant and equipment and intangible assets73 136

Net cash inflow (outflow) from investing activities (26,544)(3,895)

Cash flows from financing activities

Net proceeds of share issue65,371 –

Facility fees and interest paid(734)(778)

Repayment of borrowings(30,000) –

Proceeds of borrowings – 30,000

Payment of non-controlling interest dividends – (515)

Net cash inflow (outflow) from financing activities 34,637 28,707

Net increase (decrease) in cash and cash equivalents18,277 (7,960)

Foreign exchange movement in cash(152)(392)

Cash and cash equivalents at the beginning of year 83,876 92,228

Cash and cash equivalents at the end of year C2 102,001 83,876

Accounting policy

The consolidated statement of cash flows presents the net changes in cash flow for financial assets. Tower considers that knowledge of gross

receipts and payments is not essential to understanding certain activities of Tower based on either: the turnover of these items is quick, the

amounts are large, and the maturities are short or the value of the sales are immaterial.

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201838

| Part A – Introduction

This section provides introductory information that is helpful to an overall understanding of the financial statements, including an explanation of

Tower’s group structure and the areas of critical accounting judgements and estimates included in the financial statements. It also includes a

summary of Tower’s financial performance by operating segment.

| A1 Reporting Entity and Basis of Preparation

Entities reporting

The financial statements presented are those of Tower Limited (the Company) and its subsidiaries. The Company and its subsidiaries together are

referred to in this financial report as Tower or the Group. The address of the Company’s registered office is 45 Queen Street, Auckland, New Zealand.

Statutory base

Tower Limited is a company incorporated in New Zealand under the Companies Act 1993 and listed on the NZX Main Board and the Australian

Securities Exchange. The Company is a reporting entity under Part 7 of the Financial Markets Conduct Act 2013.

Basis of preparation

The financial statements of the Group have been prepared in accordance with New Zealand Generally Accepted Accounting Practice (NZ GAAP). They

comply with International Financial Reporting Standards (IFRS) and also New Zealand Equivalents to International Financial Reporting Standards (NZ

IFRS) and other applicable financial reporting standards, as appropriate for Tier 1 for-profit entities.

The financial statements of the Group have been prepared in accordance with the requirements of Part 7 of the Financial Markets Conduct Act 2013 and

the NZX Main Board Listing Rules.

The Group financial statements are presented in New Zealand dollars and rounded to the nearest thousand dollars. They have been prepared on a fair

value measurement basis with any exceptions noted in the accounting policies below, or in the notes to the financial statements.

Changes in comparatives

Refer to Note G5 for details of change in comparatives. Changes relate to income statement reclassification, balance sheet reclassification

and presentation of notes. There is no change to net assets or the 2017 income statement.

| A2 Consolidation

Principles of consolidation

The Group financial statements incorporate the assets and liabilities of all subsidiaries of the Company at balance date and the results of all subsidiaries

for the year.

Subsidiaries are those entities over which the consolidated entity has control, being power over the investee; exposure, or rights to variable returns

from its involvement with the investee; and the ability to use its power over the investee to affect the amount of the investor’s returns.

The results of any subsidiaries acquired during the year are consolidated from the date on which control was transferred to the consolidated entity and

the results of any subsidiaries disposed of during the year are consolidated up to the date control ceased.

The acquisition of controlled entities from external parties is accounted for using the acquisition method of accounting. Non-controlling interests in the

results and equity of subsidiaries are shown separately in the consolidated income statement, statement of comprehensive income, statement of

changes in equity and balance sheet respectively. Acquisition related costs are expensed as incurred.

When the Group ceases to have control, any retained interest in the entity is re-measured to its fair value at the date when control is lost, with the

change in carrying amount recognised in profit or loss.

Intercompany transactions and balances between Group entities are eliminated on consolidation.

Foreign currency

(i) Functional and presentation currencies

The financial statements of each Group entity are presented in the currency of the primary economic environment in which the entity operates. The

Group financial statements are presented in New Zealand dollars and rounded to the nearest thousand dollars unless stated otherwise.

(ii) Transactions and balances

In preparing the financial statements of the individual entities, transactions denominated in foreign currencies are translated into New Zealand

dollars using the exchange rates in effect at the transaction dates. Monetary items receivable or payable in a foreign currency are translated at

reporting date at the closing exchange rate.

39
Translation differences on non-monetary items such as financial assets held at fair value through profit or loss are reported as part of their fair value

gain or loss.

Exchange differences arising on the settlement or retranslation of monetary items at year end exchange rates are recognised in the income

statements unless the items form part of a net investment in a foreign operation. In this case, exchange differences are taken to the Foreign Currency

Translation Reserve and recognised in the statements of comprehensive income and the statements of changes in equity.

(iii) Consolidation

For the purpose of preparing consolidated financial statements the assets and liabilities of subsidiaries with a functional currency different to the

Company are translated at the closing rate at the balance date. Income and expense items for each subsidiary are translated at a weighted

average of exchange rates over the period, as a surrogate for the spot rates at transaction dates. Foreign currency translation differences are taken

to the Foreign Currency Translation Reserve and recognised in the statements of comprehensive income and the statements of changes in equity.

Goodwill and fair value adjustments arising on the acquisition of a foreign operation are treated as assets and liabilities of the foreign operation and

are translated at the closing rate with movements recorded through the Foreign Currency Translation Reserve in the statements of changes in

equity.

On disposal of a foreign entity, the deferred cumulative amount recognised in equity relating to that particular foreign operation is recognised in the

income statement.

Subsidiaries

The table below lists Tower Limited’s principal subsidiary companies and controlled entities. All entities have a balance date of 30 September.

NAME OF COMPANY

COUNTRY

INCORPORATED IN

HOLDINGS

NATURE OF BUSINESS20182017

Incorporated in New Zealand

Tower Financial Services Group LimitedNZ100%100%Holding company

Tower Insurance LimitedNZ100%100%General insurance

Tower New Zealand LimitedNZ100%100%Management services

Incorporated Overseas

Tower Insurance (Cook Islands) LimitedCook Islands100%100%General insurance

Tower Insurance (Fiji) LimitedFiji100%100%General insurance

Tower Insurance (PNG) LimitedPNG100%100%General insurance

National Pacific Insurance LimitedSamoa71%71%General insurance

Tower Insurance (Vanuatu) LimitedVanuatu100%100%General insurance

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201840

| A3 Critical Accounting Judgements and Estimates

The Group makes estimates and judgements in respect of certain key assets and liabilities. Estimates and judgements are continually evaluated and

are based on historical experience and other factors, including expectations of future events that are believed to be reasonable under the

circumstances. Key areas where critical accounting estimates and judgements have been applied are noted below.

Canterbury earthquake claims estimation

The valuation of net outstanding claims is an area of significant judgement and estimation. Key elements of judgement included within claims

estimations are: the rate of claims closure; the quantum of closed claims reopening; the level of future increases in building and other claims costs;

future claim management expenses; assessments of risk margin; apportionment of claims costs between the four main earthquake events; and the

quantum of new claims being received from EQC and the average cost of these claims.

Key elements of judgement included within recoveries estimations are: the collectability of reinsurance recoveries; recoveries from EQC in respect of

land damage and building costs; and the assessments of risk margin. The nature of estimation uncertainties, including from those factors listed above,

mean that actual claims experience may deviate from reported results.

Refer to Note B3 for further detail on the Canterbury Earthquakes.

EQC recoveries

Valuation of additional EQC recoveries in respect of building costs and land damage is an area of significant judgement and estimation. Areas

of judgement and subjectivity exist in assessments of: claim file review of earthquake event allocation; the quality of assessment information; litigation

risk factors; and portfolio conservatism. Tower has filed a statement of claim against EQC in respect of land damage recoveries.

Refer to Note B3 and Note E1 for further detail on EQC recoveries for Canterbury earthquakes.

Tax provisions

The Group is subject to income taxes in New Zealand and jurisdictions where it has foreign operations. Significant management judgement is required

in determining the worldwide provision for income taxes. There are some transactions and calculations undertaken during the ordinary course of

business for which the ultimate tax determination is uncertain. The Group estimates its tax liabilities based on its understanding of tax law in each

relevant jurisdiction. Where the final tax outcome of these matters is different from the amounts that were initially recorded, such differences will impact

the current and deferred income tax assets and liabilities in the period in which such determination is made.

Deferred taxation

Deferred tax assets are recognised for all unused tax losses to the extent it is probable that taxable profits will be available against which the losses can

be utilised. Significant management judgement is required to determine the amount of deferred tax assets that can be recognised based on the likely

timing and quantum of future taxable profits.

This assessment is completed on the basis of the approved strategic plans of Tower Insurance Limited and subsidiaries. If future profits do not occur as

expected, or there is a significant change in ownership, Tower may not be able to utilise all of these tax losses.

Capitalised IT development costs

Capitalisation of IT development costs is an area of judgement and estimation. The application of NZ IAS 38 Intangible Assets includes accounting

considerations required for capitalisation of IT projects. When applying NZ IAS 38, areas of judgement include consideration of impairment indicators,

economic useful life, and previous Board impairment decisions.

Goodwill

Goodwill is an area of significant judgement and estimation. Areas of judgement and subjectivity exist in the assessment of cash generating units and

assumptions underlying goodwill impairment testing. Refer to Note E2 for further details of key assumptions used.

41
| A4 Segmental Reporting

NEW ZEALAND

GENERAL

INSURANCE

$000

PACIFIC ISLANDS

GENERAL

INSURANCE

$000

OTHER (HOLDING

COMPANIES &

ELIMINATIONS)

$000

TOTAL

$000

Year Ended 30 September 2018

Revenue

Net operating revenue235,335 43,174 3,213 281,722

Total revenue 235,335 43,174 3,213 281,722

Earnings before interest, tax, depreciation and amortisation(10,590)3,964 5,870 (756)

Interest expense – – (570)(570)

Depreciation and amortisation(1,027)(482)(5,186)(6,695)

Profit (Loss) before income tax(11,617)3,482 114 (8,021)

Income tax credit (expense)2,751 (2,016)560 1,295

Profit (Loss) for the year(8,866)1,466 674 (6,726)

Total assets 30 September 2018480,664 95,072 110,497 686,233

Total liabilities 30 September 2018345,406 63,224 2,824 411,454

Acquisition of property, plant and equipment and intangibles173 603 19,026 19,802

Year Ended 30 September 2017

Revenue

Net operating revenue222,117 44,816 665 267,598

Total revenue 222,117 44,816 665 267,598

Earnings before interest, tax, depreciation and amortisation(15,648)12,688 6,223 3,263

Interest expense – – (835)(835)

Depreciation and amortisation(1,529)(521)(6,377)(8,427)

Profit (Loss) before income tax(17,177)12,167 (989)(5,999)

Income tax credit (expense)2,470 (4,958)487 (2,001)

Profit (Loss) for the year(14,707)7,209 (502)(8,000)

Total assets 30 September 2017501,299 88,091 75,270 664,660

Total liabilities 30 September 2017355,369 59,910 33,637 448,916

Acquisition of property plant and equipment and intangibles819 295 12,059 13,173

Accounting policy

An operating segment is a group of assets and operations engaged in providing products or services that are subject to risks and returns that

are different to those of other operating segments. Operating segments are reported in a manner consistent with the internal reporting provided

to the chief operating decision-maker who reviews the operating results on a regular basis and makes decisions on resource allocation and

assessing performance.

Tower operates predominantly in two geographical segments, New Zealand and the Pacific region. New Zealand segment comprised general

insurance business written in New Zealand. Pacific Islands segment includes general insurance business with customers in Pacific Islands written

by Tower subsidiaries and branch operations. Other includes head office expenses, financing costs and eliminations.

The Group does not derive revenue from any individual or entity that represents 10% or more of the Group’s total revenue.

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201842

| Part B – Revenue and Claims

This section provides information about Tower’s insurance related financial performance. Tower operates as a general insurance company and its

insurance operations drive its performance and financial position.

Tower collects premiums from customers in exchange for providing insurance coverage over their assets and activities. These premiums are

recognised as revenue when they are earned by Tower, with a liability for unearned premiums recognised on the balance sheet.

When customers suffer a loss that is covered by their policy, Tower will make payments to customers or suppliers, which it recognises as claims

expenses. To ensure that Tower’s obligations to customers are properly recorded within the financial statements, Tower recognises provisions for

outstanding claims.

To manage Tower’s risk and optimise its returns, Tower reinsures some of its exposure with reinsurance companies. The premiums paid to reinsurers

are recognised as an expense, while recoveries from reinsurers are recognised as revenue.

| B1 Premium Revenue

2018

$000

2017

$000

Gross written premiums336,109 312,396

Less: Gross unearned premiums(13,016)(6,317)

Premium revenue323,093 306,079


Accounting policy

Premium revenue is recognised in the period in which the premiums are earned during the term of the contract. The proportion of premiums not

earned in the income statement at reporting date is recognised in the balance sheet as unearned premiums.

Premiums ceded to reinsurers under reinsurance contracts are recorded as outwards reinsurance expense and are recognised over the period of

the reinsurance contract. Accordingly, a portion of outwards reinsurance premium is treated at balance date as a prepayment.

| B2 Net Claims Expense

NOTE

2018

$000

2017

$000

Canterbury earthquake claims (4 key events)B310,100 15,916

Additional risk marginB3(5,000)10,000

Kaikoura earthquake claims(579)5,739

Other claims172,111 155,896

Total net claims expense176,632 187,551

43
Accounting policy

Claims expense is recognised when claims are notified. Provision is made for the estimated cost of claims incurred but not settled at balance date,

including the cost of claims incurred but not yet reported (IBNR) to the Group.

The estimated cost of claims includes direct expenses incurred in settling claims net of any expected salvage value and other recoveries. The Group

takes all reasonable steps to ensure that it has appropriate information regarding its claims exposures. However, given the uncertainty in establishing

claims provisions, it is likely that the final outcome will prove to be different from the original liability established.

The estimation of claims IBNR is generally subject to a greater degree of uncertainty than the estimation of the cost of settling claims already notified

to the Group, where more information about the claim event is generally available. IBNR claims may not be apparent to the insured until many years

after the events giving rise to the claims have happened. In calculating the estimated cost of unpaid claims the Group uses a variety of estimation

techniques, generally based on statistical analyses of historical experience, which assumes that the development pattern of current claims will be

consistent with past experience. Allowance is made for changes or uncertainties which may create distortions in underlying statistics or which may

cause the cost of unsettled claims to increase or reduce when compared with the cost of previously settled claims including:

—changes in Group processes which might accelerate or slow down the development and (or) recording of paid or incurred claims, compared with

statistics from previous periods;

—the effects of inflation; and

—the impact of large losses.

A component of these estimation techniques is the estimation of the cost of notified but not paid claims. In estimating the cost of these, the Group

has regard to the claim circumstances reported, any information available from loss adjusters and information on the cost of settling claims with

similar characteristics in previous periods.

Provisions are calculated net of any reinsurance recoveries. Gross provisions are estimated by adding the expected reinsurance recovery to the

net provisions. Details of specific assumptions used in deriving the outstanding claims liability at year end are detailed in Note B5.

Reinsurance and other recoveries on claims expense are recognised as revenue. Recoveries are measured as the present value of expected

future receipts.

| B3 Canterbury Earthquakes

As at 30 September 2018 Tower has 163 claims remaining to settle (2017: 323 claims) out of a total number of 16,152 claims received as a result of

earthquakes impacting the Canterbury region during 2010 and 2011 (2017: 16,106 claims). To date, Tower has paid out more than $869 million to

customers (2017: $825 million) in respect of the four main earthquakes that occurred on 4 September 2010; 22 February 2011; 13 June 2011 and

23 December 2011.

Outstanding claims comprises case estimates, claims incurred but not reported (IBNR) and risk margins. In the year ended 30 September 2018,

case estimates have reduced as claims have been settled and paid. There have been increased costs on remaining open claims; new over-cap

claims being received from EQC; and litigation on claims.

As at 30 September 2018, Tower has estimated gross ultimate incurred claims of $905.8 million in respect of the four main Canterbury earthquake

events (2017: $897.4 million).

The financial cost to Tower of the Canterbury earthquakes is reduced through reinsurance and is reflected within net outstanding claims.

Tower continues to work closely with its catastrophe reinsurance partners as it works through its Canterbury claims settlement programme.

Catastrophe reinsurance partners are required to have a financial strength rating of at least A- issued by a recognised international rating agency.

The table below presents a financial representation of Tower’s net outstanding claims provision at 30 September 2018 in relation to the four main

earthquake events.

Canterbury earthquake provisions

2018

$000

2017

$000

Insurance liabilities

Gross outstanding claims(67,900)(107,200)

Additional risk margin(5,000)(10,000)

(72,900)(117,200)

Receivables

Reinsurance recovery receivables7,800 13,600

EQC related to open claims4,500 5,800

Less: EQC payable to reinsurers(1,000)(1,700)

11,300 17,700

Net outstanding claims(61,600)(99,500)

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201844

B3 Canterbury Earthquakes (continued)

EQC recovery receivables

Tower has one significant receivable amount related to closed Canterbury earthquake claims, being $68.4 million from EQC (2017: $65.1 million).

$16.4 million of this EQC amount is payable to reinsurers which has been allowed for in payables (2017: $17.7 million). The amount payable to

reinsurers may vary depending on the balance collected from EQC. A risk margin of $10.1 million has been allowed for on the receivable from EQC

(2017: $10.7 million).

Tower estimates the gross amount receivable due from EQC is significantly higher than the $68.4 million, but has adopted this amount, which is the

actuarial valuation of the Appointed Actuary. The method by which the actuarial valuation is completed recognises the inherent risk and uncertainty

with recovery of the full gross amount.

Tower acknowledges that the EQC recoveries relating to Canterbury earthquakes are an area of significant accounting estimation and judgement,

including earthquake event allocation, litigation risk factors and other actuarial assumptions.

Additional risk margin

At 30 September 2017, the Board elected to create an additional risk margin of $10.0 million over and above the provision of the Appointed Actuary,

which is set at the 75th percentile probability of sufficiency. This provision has been reviewed by the Board and has been reduced to $5.0 million as

at 30 September 2018. The Board will continue to review this additional risk margin each half year and the remaining $5.0 million is expected to be

released once the Canterbury Outstanding Claims Liability has sufficiently run off.

The following table presents the cumulative impact of the four main Canterbury earthquake events on the income statement.

NOTE

2018

$000

2017

$000

Cumulative expenses associated with Canterbury earthquakes:

Earthquake claims estimate(905,840)(897,440)

Reinsurance recoveries723,173 746,623

Claim expense net of reinsurance recoveries(182,667)(150,817)

Reinsurance expense(25,045)(25,045)

Additional risk margin(5,000)(10,000)

Cumulative impact of Canterbury earthquakes before tax(212,712)(185,862)

Income tax60,228 52,710

Cumulative impact of Canterbury earthquakes after tax(152,484)(133,152)

Recognised in current period (net of tax)

Net claims expenseB2(7,272)(11,460)

Additional risk marginB23,600 (7,200)

Impairment of receivablesD2(15,660) –

(19,332)(18,660)

The Board are actively engaged in monitoring Canterbury earthquake developments. Board process relies on the Appointed Actuary’s determination of

earthquake ultimate incurred claims estimates and the derivation of estimated outcomes. Recognising relative complexities which exist within remaining

open claims, the Appointed Actuary has reviewed each remaining property file with Tower claims staff. This individual claim methodology included

review of the latest specialist assessment reports and scope of works to repair or rebuild properties to determine the propensity for future costs to vary.

In addition, further provision was made for claims re-opening; claims moving over the EQC cap of $100,000; claims in litigation and other claim categories.

The actuarial reviews performed during the year ended 30 September 2018 identified the following as key contributors to the increase in expected

earthquake claims costs:

—Greater than anticipated new over-cap claims received from EQC;

—Continued growth in the level of litigated claims received;

—Continued development of claim costs as they progress through the claims life cycle; and

—Increase in the level of claims handling expenses;

45
The key elements of judgement within the claims estimation are as follows:

Claims

—the level of future increases in building and other claims costs

—the number of claims subject to litigation and the average cost of these claims

—the number of new claims expected from EQC and the average cost of these claims

—the rate of closed claims reopening

—risk margin

—future claim management expenses, and

Recoveries

—recoveries from EQC (including litigation risks) in respect of land damage and building costs

—risk margin.

Given the nature of estimation uncertainties (including those listed above) actual claims experience may still deviate, perhaps substantially, from the

gross outstanding claims liabilities recorded as at 30 September 2018. Any further changes to estimates will be recorded in the accounting period when

they become known.

The catastrophe reinsurance cover headroom remaining is included in the table below.

CATASTROPHE REINSURANCE

COVER REMAINING

DATE OF EVENT

2018

$000

2017

$000

June 2011255,700 254,200

December 2011486,900 486,500

Tower has exceeded its catastrophe reinsurance limit in relation to the September 2010 and February 2011 events.

Sensitivity analysis – impact of changes in key variables

Net outstanding claims are comprised of several key elements, as described earlier in this note. Sensitivity of net outstanding claims is therefore driven

by changes to the assumptions underpinning each of these elements. The impact of changes in significant assumptions on the net outstanding claims

liabilities, and hence on Tower’s profit, are shown in the table below. Each change in assumption has been calculated in isolation of any other changes

in assumptions.

The impact of a change to claims costs is offset by reinsurance where there is reinsurance capacity remaining. The impact will be nil where the change

in claims costs is less than the remaining reinsurance capacity. However, if the change in claims costs exceeds the reinsurance capacity then Tower’s

profit will be impacted by the amount of claims costs in excess of the reinsurance capacity.

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201846

The changes in the table below reflect the impact on Tower’s profits should that event occur.

CHANGE

VARIABLE

SPLIT BETWEEN EVENTSFOUR MAIN EARTHQUAKES

SEP 2010

$M

FEB 2011

$M

JUN 2011

$M

DEC 2011

$M

30-SEP-18

$M

30-SEP-17

$M

Outstanding claims:

(i)Change to costs and quantity of expected

claim estimates including building costs and

other impacts.

+ 5%

- 5%

(0.9)

0.9

(1.9)

1.9





(2.8)

2.8

(4.3)

4.3

(ii)Change in apportionment of claim costs

to / from February 2011 event.

+ 1%

- 1%

6.4

(6.9)

(8.8)

8.8





(2.4)

1.9

(4.1)

2.0

Receivables:

Reinsurance recovery receivables

(iii)Recoveries from EQC in respect of land

damage

+ 10%

- 10%

0.1

(0.1)

0.7

(0.7)





0.8

(0.8)

0.8

(0.8)

(iv)Recoveries from EQC in respect of building

costs

+ 10%

- 10%

3.4

(3.4)

1.0

(1.0)





4.4

(4.4)

4.1

(4.1)

(i)Calculated as the change in case estimates (net of EQC contributions) plus IBNR/IBNER and the impact on Tower’s profit quantified. Changes in

case estimates include over-cap claims, closed claims re-opening and risk margin.

(ii)Calculated as 1% of total reported costs (net of EQC contributions) plus IBNR/IBNER moved to/from Feb 2011 event and the impact on Tower’s

profit quantified.

| B4 Insurance Liabilities

2018

$000

2017

$000

Unearned premiums175,551 162,342

Outstanding claims143,976 171,156

Additional risk margin5,000 10,000

Total insurance liabilities324,527 343,498

Analysed as

Current 291,711 300,064

Non current32,816 43,434

Total insurance liabilities324,527 343,498

The table below includes the reconciliation of the unearned premiums as at the reporting date:

Opening balance162,342 157,620

Premiums written336,109 296,855

Premiums earned(323,093)(291,472)

Foreign exchange movements193 (661)

Closing balance175,551 162,342

B3 Canterbury Earthquakes (continued)

47
Accounting policy

Outstanding claims are measured at the central estimate of the present value of expected future payments after allowing for inflation and

discounted at the risk free rate. In addition a risk margin is added to the claims provision to recognise the inherent uncertainty of the central estimate

and to ensure provision is at least at 75% probability of sufficiency.

The expected future payments include those in relation to claims reported but not yet paid, claims incurred but not yet reported (IBNR), claims

incurred but not enough reported (IBNER) and anticipated claims handling costs. Claims handling costs include costs that can be associated directly

with individual claims, such as legal and other professional fees, and costs that can only be indirectly associated with individual claims, such as

claims administration costs.

Provision has been made for the estimate of claim recoveries from third parties.

Liability adequacy testing is performed in order to recognise any deficiencies in the income statement arising from the carrying amount of the

unearned premium liability less any related deferred acquisition costs and intangible assets not meeting the estimated future claims under current

insurance conditions. Liability adequacy testing is performed at a portfolio level of contracts that are subject to broadly similar risks and are managed

together as a single portfolio.

Refer to Note B3 for further details on the additional risk margin.

| B5 Other Insurance Disclosures

B5.1 Net claims expense

20182017

RISKS BORNE IN

CURRENT YEAR

$000

RISKS BORNE IN

PRIOR YEARS

$000

TOTAL

$000

RISKS BORNE IN

CURRENT YEAR

$000

RISKS BORNE IN

PRIOR YEARS

$000

TOTAL

$000

Gross claims expense

Direct claims – undiscounted188,452 12,035 200,487 175,078 50,235 225,313

Movement in discount(60)40 (20)43 28 71

Total gross claims expense188,392 12,075 200,467 175,121 50,263 225,384

Reinsurance and other recoveries

Reinsurance and other recoveries

– undiscounted(20,073)(3,762)(23,835)(20,559)(17,272)(37,831)

Movement in discount – – – (1)(1)(2)

Total reinsurance recoveries(20,073)(3,762)(23,835)(20,560)(17,273)(37,833)

Net claims expense168,319 8,313 176,632 154,561 32,990 187,551

Current year amounts relate to risks borne in the current financial year. Prior period amounts relate to a reassessment of the risks borne in all previous

financial years including those arising due to the Canterbury earthquakes. Refer to Notes B2 and B3.

B5.2 Outstanding claims

(a) Assumptions adopted in calculation of insurance liabilities

The estimation of outstanding claims as at 30 September 2018 has been carried out by the following Actuaries:

Rick Shaw, B.Sc. (Hons), FIAA, Appointed Actuary; and

John Feyter, B.Sc., FNZSA.

The New Zealand actuarial assessments are undertaken in accordance with the standards of the New Zealand Society of Actuaries, in particular

Professional Standard No. 30 “Valuations of General Insurance Claims”. The Actuaries were satisfied as to the nature, sufficiency and accuracy of the data

used to determine the outstanding claims liability. The outstanding claims liability is set by the Actuaries at a level that is appropriate and sustainable to

cover the Group’s claims obligations after having regard to the prevailing market environment and prudent industry practice.

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201848

B5 Other Insurance Disclosures (continued)

The following assumptions have been made in determining net outstanding claims liabilities:

20182017

Inflation rates varied from0.0%0.0% – 3.8%

Inflation rates for succeeding year0.0%0.0% – 3.8%

Inflation rates for following years 0.0%0.0% – 3.8%

Discount rates varied from 0.0% – 2.5%0.0% – 6.3%

Discount rates for succeeding year0.0% – 2.5%0.0% – 6.3%

Discount rates for following years0.0% – 2.5%0.0% – 6.3%

Claims handling expense ratio3.5% – 32.3%3.1% – 39.1%

Risk margin6.5% – 31.5%4.9% – 23.1%

In addition to the risk margin range shown above, the total risk margin also includes $14,000,000, gross of reinsurance (2017: $23,900,000) associated

with the Canterbury earthquakes.

The weighted average expected term to settlement of outstanding claims (except for Canterbury earthquake claims) based on historical trends is:

20182017

Short tail claims within 1 yearwithin 1 yearwithin 1 year

Long tail claims in the Pacific Islands1.0 to 1.8 years1.0 to 1.8 years

Inflation and discount rate

Insurance costs are subject to inflationary pressures. The valuation implicitly assumes that future inflation will be similar to that experienced in recent

years. For the Pacific countries it is assumed that additional superimposed inflation is offset by the discount effect and 0% has, therefore, been assumed

for both the inflation rate and discount rate.

For New Zealand business all liabilities are short-tail. Nil additional inflation has been assumed. Outstanding claim liabilities are discounted to present

value using a short-term discount rate.

EQC recoveries

For each claim to which additional EQC recoveries relate, Tower has allocated recoverable amounts according to the quality of information and

evidence available. Claims with primary evidence (e.g. independent expert documentation) have been assessed as having a strong position for recovery.

Claims with non-primary evidence (e.g. general documentation like post code analysis or adjacent locations) will have a lower likelihood of recovery.

Apportionment

Tower assesses claims and apportions damage between Canterbury earthquake events on an individual property basis. The allocation process uses a

hierarchical approach based on the relative quality and number of claim assessments completed after each of the four main earthquakes. Results from

the hierarchical approach are used as an input to the actuarial valuations which estimate the ultimate claims costs.

Claims handling expense

The estimate of outstanding claim liabilities incorporates an allowance for the future cost of administering the claims. This allowance is determined

after analysing historical claim related expenses incurred by the classes of business.

Risk margin

The outstanding claim liabilities also include a risk margin that relates to the inherent uncertainty in the central estimate of the future payments.

Risk margins are determined on a basis that reflects the business. Regard is given to the robustness of the valuation models, the reliability and volume

of available data, past experience of the insurer and the industry, and the characteristics of the classes of business written.

Uncertainty in claims is represented as a volatility measure in relation to the central estimate. The volatility measure is derived after consideration of

statistical modelling and benchmarking to industry analysis. The measure of the volatility is referred to as the coefficient of variation (CoV), defined as

the standard deviation of the distribution of future cash flows divided by the mean.

Risk margins are calculated by jurisdiction. The risk margin for all classes when aggregated is less than the sum of the individual risk margins. This reflects

the benefit of diversification. The measure of the parameter used to derive the diversification benefit is referred to as correlation, which is adopted with

regard to industry analysis, historical experience and actuarial judgement.

The risk margins applied to future claims payments are determined with the objective of achieving 75% probability of sufficiency for both the outstanding

claims liability and the unexpired risk liability.

49
The following analysis is in respect of the insurance liabilities:

2018

$000

2017

$000

Central estimate of expected present value of future payments for claims incurred95,425 110,398

Risk margin17,936 27,885

Claims handling costs6,901 9,714

120,262 147,997

Discount(271)(270)

Net outstanding claims119,991 147,727

Reconciliation of movements in discounted outstanding claim liabilities

20182017

GROSS

$000

REINSURANCE

$000

NET

$000

GROSS

$000

REINSURANCE

$000

NET

$000

Balance brought forward181,156 (33,429)147,727 210,202 (83,205)126,997

Effect of change in foreign exchange rates71 (99)(28)(553)98 (455)

Incurred claims recognised in the income

statement200,467 (23,835)176,632 225,384 (37,833)187,551

Claims paid and reinsurance recoveries raised(232,718)28,378 (204,340)(253,877)87,511 (166,366)

Total outstanding claims148,976 (28,985)119,991 181,156 (33,429)147,727

Reconciliation of movements in undiscounted claims to outstanding claim liabilities

20182017

GROSS

$000

REINSURANCE

$000

NET

$000

GROSS

$000

REINSURANCE

$000

NET

$000

Outstanding claims undiscounted3,461 (80)3,381 1,968 (367)1,601

Discount – – – 60 – 60

Outstanding claims3,461 (80)3,381 2,028 (367)1,661

Short tail outstanding claims116,610 146,066

Total outstanding claims119,991 147,727

(b) Sensitivity analysis

The Group’s insurance business is generally short tail in nature. Key sensitivities relate to the volume of claims, in particular for significant events

such as earthquakes or extreme weather.

The Group has exposure to historical inwards reinsurance business which is in run off. While this business is not material, it is sensitive to claims

experience, timing of claims and changes in assumptions. Movement in these variables does not have a material impact on the performance and equity

of the Group.

(c) Future net cash out flows

The following table shows the expected run-off pattern of net outstanding claims:

2018

$000

2017

$000

Expected claim payments

Within 3 months50,771 45,205

3 to 6 months25,762 28,699

6 to 12 months17,955 38,456

After 12 months25,503 35,367

Total outstanding claim liabilities119,991 147,727

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201850

B5.3 Development of claims

The following table shows the development of net outstanding claims relative to the current estimate of ultimate claims costs for the five most

recent years:

ULTIMATE CLAIMS COST ESTIMATE

PRIOR

$000

2014

$000

2015

$000

2016

$000

2017

$000

2018

$000

TOTAL

$000

At end of incident year116,297 125,054 133,776 138,647 149,260

One year later114,810 126,231 132,388 141,378

Two years later117,108 126,067 134,640

Three years later117,629 127,552

Four years later116,131

Current estimate of ultimate claims cost116,131 127,552 134,640 141,378 149,260

Cumulative payments(115,833)(127,092)(131,941)(136,344)(109,517)

Undiscounted central estimate47,192 298 460 2,699 5,034 39,743 95,426

Discount to present value(271)

Discounted central estimate95,155

Claims handling expense6,901

Risk margin17,936

Net outstanding claim liabilities119,991

Reinsurance recoveries on outstanding claim

liabilities and other recoveries28,985

Gross outstanding claim liabilities148,976

B5.4 Liability adequacy test

Liability adequacy tests are performed to determine whether the unearned premium liability is sufficient to cover the present value of the expected

cash flows arising from rights and obligations under current insurance contracts, plus an additional risk margin to reflect the inherent uncertainty in

the central estimate. The future cash flows are future claims, associated claims handling costs and other administration costs relating to the business.

If the unearned premium liability less related deferred acquisition costs exceeds the present value of expected future cash flows plus additional risk

margin then the unearned premium liability is deemed to be adequate. The risk margins applied to future claims were determined with the objective of

achieving at least 75% probability of sufficiency of the unexpired risk liability using the methodology described above. The unearned premium liabilities

as at 30 September 2018 were sufficient (2017: sufficient).

2018

%

2017

%

Central estimate claim % of premium44.9%41.2%

Risk margin11.3%12.0%

B5.5 Insurer financial strength rating

Tower Insurance Limited has an insurer financial strength rating of ‘A-’ (Excellent) issued by international rating agency AM Best Company Inc. with an

effective date of 9 March 2018.

B5.6 Reinsurance programme

Reinsurance programmes are structured to adequately protect the solvency and capital positions of the insurance business. The adequacy of

reinsurance cover is modelled by assessing Tower’s exposure under a range of scenarios. The plausible scenario that has the most financial significance

for Tower is a major Wellington earthquake. Each year, as part of setting the coming year’s reinsurance cover, comprehensive modelling of the event

probability and amount of the Group’s exposure is undertaken.

B5.7 Assets backing insurance business

The Group has determined that all assets within its insurance companies are held to back insurance liabilities, with the exception of property, plant and

equipment and investments in operating subsidiaries.

Assets backing insurance liabilities are managed in accordance with approved investment mandate agreements on a fair value basis and are reported

to the Board on this basis.

B5 Other Insurance Disclosures (continued)

51
| Part C – Financial Instruments and Liquidity

Funds provided by shareholders and collected as premiums are invested by Tower, providing a financial return and also ensuring that Tower’s

obligations to pay claims and expenses can be met.

This section provides information about Tower’s financial instruments, including information about the cash and investments that Tower holds, its

approach to managing risk for these financial instruments, and its cash flows.

| C1 Investment Revenue

2018

$000

2017

$000

Fixed interest securities

Interest income8,010 7,734

Net realised gain (loss)146 (631)

Net unrealised gain (loss)596 913

Total fixed interest securities8,752 8,016

Equity securities

Net unrealised gain (loss)(745)(3)

Total equity securities(745)(3)

Other

Net realised gain (loss)(751)(1,297)

Net unrealised gain (loss)(131)927

Total other(882)(370)

Total investment revenue8,010 7,734

Total net realised gain (loss)(605)(1,928)

Total net unrealised gain (loss)(280)1,837

Total investment revenue7,125 7,643

Accounting policy

Investment revenue is recognised as follows:

(i) Interest income on fixed interest securities

Interest income is recognised using the effective interest method.

(ii) Fair value gains and losses

Fair value gains and losses on investments are recognised through the income statement in the period in which they arise. The gains and losses

from fixed interest, equity and property securities have been generated by financial assets designated on initial recognition at fair value through

profit or loss. Other investment gains and losses have been generated by derivative financial assets and financial liabilities classified as held for

trading at fair value through profit or loss.

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201852

| C2 Cash and Cash Equivalents

2018

$000

2017

$000

Cash at bank and in hand45,986 21,981

Deposits at call55,561 57,689

Restricted cash454 4,206

Total cash and cash equivalents102,001 83,876

Accounting policy

Cash and cash equivalents includes cash on hand and deposits held at call with financial institutions, other short-term, highly liquid investments that

are readily convertible to known amounts of cash and which are subject to an insignificant risk of changes in value, and bank overdrafts.

The effective interest rate at 30 September 2018 for deposits at call is 2.25% (2017: 2.60%). There was no offsetting within cash and cash equivalents

(2017: nil).

Restricted cash

Tower is a party to the Canterbury Earthquake Shared Property Process – Insurer Contract (SPP) which sets out obligations for insurers and appoints

a lead insurer to act on behalf of other insurers with respect to the repair and rebuild of shared properties (known as multi-units). As lead insurer on

Canterbury multi-unit repairs or rebuilds, Tower receives cash from other insurance companies as settlement of their obligations under building contracts

covered within the SPP. Tower separately holds this cash on behalf of other insurers in a segregated bank account.

At 30 September, Tower was holding $0.5 million (2017: $4.2 million) cash in respect of multi-unit claims as lead insurer on Canterbury claims. This is

recognised within Cash and cash equivalents on the balance sheet. Related to this are corresponding amounts being $0.2 million (2017: $1.6 million)

recorded within Insurance liabilities for Tower’s portion of multi-unit outstanding claims; and $0.3 million (2017: $2.6 million) recorded within Payables

as held on behalf of other insurers in respect of SPP claims.

| C3 Investment Assets

2018

$000

2017

$000

Fixed interest securities197,367 185,256

Equity securities599 1,412

Property securities34 34

Total Investments198,000 186,702

53
| C4 Borrowings

CURRENCY

INTEREST

RATE

ROLLOVER DATE

(DRAWN) /

MATURITY DATE

(UNDRAWN)

FACE

VALUE

$000

UNAMORTISED

COSTS

$000

CARRYING

VALUE

$000

FAIR

VALUE

$000

As at 30 September 2018

Bank facilities (undrawn)NZDVariable9-Sep-1950,000 – – –

Total borrowings – – –

As at 30 September 2017

Bank facilities (drawn)NZD4.505%13-Nov-1730,000 (79)29,921 29,921

Bank facilities (undrawn)NZDVariable9-Sep-1920,000 – – –

Total borrowings(79)29,921 29,921

2018

$000

2017

$000

Analysed as

Current – 29,921

Non current – –

Total borrowings – 29,921

Accounting policy

Borrowings are recognised initially at fair value, net of transaction costs incurred. Subsequent to initial recognition, borrowings are measured at

amortised cost with any difference between the initial recognised amount and the redemption value being recognised in the income statement over

the period of the borrowings using the effective interest method.

Fees paid on the establishment of loan facilities are recognised as transaction costs of the loan to the extent that it is probable that some or all of the

facility will be drawn down. The fee is capitalised as a pre-payment for liquidity services and amortised over the period of the facility to which it relates.

The following table represents the change in borrowings:

2018

$000

2017

$000

Opening balance30,000 –

Drawdown of credit facility – 30,000

Repayment of credit facility(30,000) –

Closing balance – 30,000

Standby credit facility

The Company entered into a cash advance facility with Bank of New Zealand on 7 September 2016. The facility provides for an amount of up to

$50.0 million that can be drawn for general corporate purposes over a three year term and is subject to normal terms and conditions for a facility

of this nature, including financial covenants.

In May 2017, the Company utilised the cash advance facility agreement. An amount of $30.0 million was drawn (from the available $50.0 million).

Funds were used for new share capital within Tower Insurance Limited.

In December 2017, the Company repaid the drawn cash advance facility using funds obtained from the capital raise.

All borrowings are unsecured and are subject to various financial covenants. The Company has fully complied with all covenants during the year ended

30 September 2018.

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201854

| C5 Financial Instruments

C5.1 Financial instrument categories

Accounting policy

Financial assets and liabilities are classified in the following categories: at fair value through profit or loss; loans and receivables; and liabilities at

amortised cost. The classification depends on the purpose for which the financial assets and liabilities were acquired. Management determines the

classification of its financial assets and liabilities at initial recognition.

(i) Loans and receivables

Loans and receivables are measured initially at fair value plus transaction costs and subsequently at amortised cost using the effective interest

method less any impairment.

(ii) Financial liabilities at amortised cost

Financial liabilities at amortised cost are measured initially at fair value plus transaction costs and subsequently at amortised cost less any impairment.

(iii) Financial assets and liabilities at fair value through profit or loss

Financial assets at fair value through profit or loss are stated at fair value, with any resultant gain or loss recognised in the income statements. The net

gain or loss recognised in the income statements includes any dividend or interest earned on the financial assets.

(iv) Offsetting financial instruments

Financial assets and liabilities are offset and the net amount reported in the balance sheet when there is a legally enforceable right to offset the

recognised amounts and there is an intention to settle on a net basis or realise the asset and settle the liability simultaneously.

(v) Derecognition

Financial assets are derecognised when the rights to receive cash flows from the investments have expired or have been transferred and the Group

has transferred substantially all risks and rewards of ownership.

(i) Loans and receivables

Loans and receivables are non-derivative financial assets with fixed or determinable payments that are not quoted on an active market. The Group’s

loans and receivables comprise trade and other receivables and cash and cash equivalents in the balance sheet.

(ii) Financial liabilities at amortised cost

Financial liabilities at amortised cost are non-derivative financial liabilities with fixed or determinable payments that are not quoted on an active market.

The Group’s financial liabilities comprise trade, reinsurance and other payables in the balance sheet.

(iii) Financial assets and liabilities at fair value through profit or loss

Financial assets and liabilities at fair value through profit or loss comprise of financial assets that are either held for trading or designated on initial

recognition at fair value through profit or loss. A financial asset is classified in this category if acquired principally for the purpose of selling in the

short-term or if so designated by management. Designation by management takes place when it is necessary to eliminate or significantly reduce

measurement or recognition inconsistencies or if related financial assets or liabilities are managed and evaluated on a fair value basis.

Derivatives are categorised as held for trading unless they are designated as hedges. All derivatives entered into by the Group are classified as held for

trading.

The analysis of financial assets and liabilities into their categories and classes is set out in the following tables:

AT AMORTISED COST

AT FAIR VALUE

THROUGH PROFIT OR LOSS

TOTAL

$000

LOANS AND

RECEIVABLES

$000

FINANCIAL

LIABILITIES

$000

DESIGNATED

$000

HELD FOR

TRADING

$000

As at 30 September 2018

Assets

Cash and cash equivalents102,001 102,001 – – –

Trade and other receivables255,779 255,779 – – –

Investments198,000 – – 198,000 –

Derivative financial assets271 – – – 271

Total financial assets556,051 357,780 – 198,000 271

Liabilities

Trade and other payables50,590 – 50,590 – –

Total financial liabilities50,590 – 50,590 – –

55
AT AMORTISED COST

AT FAIR VALUE

THROUGH PROFIT OR LOSS

TOTAL

$000

LOANS AND

RECEIVABLES

$000

FINANCIAL

LIABILITIES

$000

DESIGNATED

$000

HELD FOR

TRADING

$000

As at 30 September 2017

Assets

Cash and cash equivalents83,876 83,876 – – –

Trade and other receivables283,158 283,158 – – –

Investments186,702 – – 186,702 –

Derivative financial assets231 – – – 231

Total financial assets553,967 367,034 – 186,702 231

Liabilities

Trade and other payables43,514 – 43,514 – –

Borrowings29,921 – 29,921 – –

Total financial liabilities73,435 – 73,435 – –

C5.2 Fair value of financial assets and liabilities

Fair value is the price that would be received to sell an asset, or paid to transfer a liability, in an orderly transaction between market participants at the

measurement date. Refer below for details of valuation methods and assumptions used for each category of financial assets and liabilities.

(i) Cash and cash equivalents

The carrying amount of cash and cash equivalents reasonably approximates its fair value.

(ii) Financial assets at fair value through profit or loss and held for trading

The fair value of financial instruments traded in active markets is based on quoted market prices at the balance sheet date. A market is regarded as

active if quoted prices are readily and regularly available from an exchange, dealer, broker, industry group, pricing service, or regulatory agency, and

those prices represent actual and regularly occurring market transactions on an arm’s length basis. The quoted market price used for financial assets

held by the Group is the current bid price. These instruments are included in Level 1.

The fair value of financial instruments that are not traded in an active market (for example, over-the-counter derivatives) is determined by using

valuation techniques. These valuation techniques maximise the use of observable market data where it is available and rely as little as possible on

entity specific estimates. If all significant inputs required to fair value an instrument are observable, the instrument is included in Level 2. The following

fair value measurements are used:

—The fair value of fixed interest securities is based on the maturity profile and price/yield.

—The fair value of forward foreign exchange contracts is determined using forward exchange rates at the balance sheet date, with the resulting value

discounted back to present value.

—Other techniques, such as discounted cash flow analysis, are used to determine fair value for the remaining financial instruments.

If one or more of the significant inputs is not based on observable market data, the instrument is included in Level 3.

(iii) Loans and receivables and other financial liabilities held at amortised cost

Carrying values of loans and receivables, adjusted for impairment values, and carrying values of other financial liabilities held at amortised cost

reasonably approximate their fair values.

(iv) Derivative financial liabilities and assets

The fair value of derivative financial liabilities and assets is determined by reference to market accepted valuation techniques using observable market

inputs.

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201856

The following tables present the Group’s assets and liabilities categorised by fair value measurement hierarchy levels.

TOTAL

$000

LEVEL 1

$000

LEVEL 2

$000

LEVEL 3

$000

As at 30 September 2018

Assets

Investment in equity securities599 – – 599

Investments in fixed interest securities197,367 – 197,367 –

Investments in property securities34 – 34 –

Investments198,000 – 197,401 599

Derivative financial assets271 – 271 –

Total financial assets198,271 – 197,672 599

As at 30 September 2017

Assets

Investment in equity securities1,412 – – 1,412

Investments in fixed interest securities185,256 – 185,256 –

Investments in property securities34 – 34 –

Investments186,702 – 185,290 1,412

Derivative financial assets 231 – 231 –

Total financial assets186,933 – 185,521 1,412

Liabilities

Borrowings29,921 – 29,921 –

Total financial liabilities29,921 – 29,921 –

The Level 3 category includes investment in equity securities of $599,000 (2017: $1,412,000). This investment is in unlisted shares of a company which

provides reinsurance to Tower. The fair value is calculated based on the net assets of the company from the most recently available financial information,

adjusted for market conditions. The following table represents the changes in Level 3 instruments:

INVESTMENT IN

EQUITY SECURITIES

2018

$000

2017

$000

Opening balance1,412 1,406

Total gains and losses recognised in profit or loss(745)(3)

Foreign currency movement(46)9

Disposals(22) –

Closing balance599 1,412

The following table shows the impact of increasing or decreasing the combined inputs used to determine the fair value of the investment by 10%:

CARRYING

AMOUNT

$000

FAVOURABLE

CHANGES OF 10%

UNFAVOURABLE

CHANGES OF 10%

As at 30 September 2018

Investment in equity securities599 60 (60)

As at 30 September 2017

Investment in equity securities1,412 141 (141)

C5 Financial Instruments (continued)

57
C5.3 Impairment of financial assets

Accounting policy

Financial assets, with the exception of those measured at fair value through profit or loss, are assessed for indicators of impairment at each reporting

date. Financial assets are impaired when there is objective evidence that the estimated future cash flows of the asset have been impacted as a result

of one or more events that occurred after the initial recognition of the financial asset.

For financial assets carried at amortised cost, the amount of the impairment is the difference between the carrying amount and the present value of

estimated future cash flows, discounted at the original effective interest rate.

For all financial assets, other than trade receivables, the carrying amount is reduced by the impairment loss directly. For trade receivables the

carrying amount is reduced via an allowance account, against which an uncollectible trade receivable is written off.

A trade receivable is deemed to be uncollectible upon receipt of evidence that the Group will be unable to collect the amount. Changes in the

carrying amount of the allowance account are recognised in the income statement.

A previously recognised impairment loss is reversed when, in a subsequent period, the amount of the impairment loss decreases and the decrease

can be related objectively to an event occurring after the impairment loss was initially recognised.

In respect of financial assets carried at amortised cost, with the exception of trade receivables, the impairment loss is reversed through the income

statement to the extent that the carrying amount of the investment at the date the impairment is reversed does not exceed what the amortised cost

would have been had the impairment not been recognised. Subsequent recoveries of trade receivables previously written off are credited against

the allowance for credit losses and impairment.

| C6 Reconciliation of Loss for the Period to Net Cash Flows From Operating Activities

2018

$000

2017

$000

Loss for the year(6,726)(8,000)

Adjusted for non-cash items

Depreciation of property, plant and equipment1,499 2,032

Amortisation of software5,195 6,395

Impairment of reinsurance receivables21,750 –

Unrealised (gain) loss on financial assets280 (1,837)

Movement on disposal of property, plant and equipment(50)(42)

Change in deferred tax(3,404)(3,024)

25,270 3,524

Adjusted for movements in working capital (excluding the effects of exchange differences on consolidation)

Change in receivables4,907 (7,653)

Change in payables(13,279)(21,537)

Change in taxation(722)116

(9,094)(29,074)

Adjusted for other items classified as investing / financing activities

Facility fees and interest paid734 778

734 778

Net cash inflows (outflows) from operating activities10,184 (32,772)

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201858

| Part D – Management Expenses and Taxation

To grow and operate its business, Tower incurs management expenses, including payments to employees, suppliers and commission payments to

third parties.

This section includes information about Tower’s management expenses and taxation.

| D1 Management and Sales Expenses

2018

$000

2017

$000

Employee benefits expense (1) 59,610 56,581

Net change in deferred acquisition costs (1,634) (988)

Bad debts written off 232 176

Change in provision for doubtful debts(159) (945)

Amortisation of software5,1956,395

Depreciation 1,499 2,032

Directors’ fees 515 509

(Gain) on disposal of property, plant and equipment (50) (42)

Claims related management expenses reclassified to claims expense (2) (23,151) (28,979)

Auditors fees 603 576

Commission expense 19,488 18,927

Lease expenses3,393 3,256

Other expenses24,187 24,246

Total management and sales expenses89,728 81,744

(1) Personnel costs are net of capitalised labour costs in relation to internally generated software assets.

(2) Claims handling expenses do not include costs in relation to Kaikoura earthquake or Canterbury earthquake related claims, as these are charged to

provisions created in previous years.

| D2 Impairment of Reinsurance Receivable

On 28 February 2018, Tower Limited announced it had entered into a settlement agreement with Peak Re regarding an adverse development cover

policy entered into in 2015. Under the settlement agreement Tower received $22.0 million of the $43.75 million claimed under the reinsurance contract

and all sums claimed in the arbitration proceeding. This has resulted in a write off of the residual amount of $21.75 million. This amount along with

associated professional fees of $0.76 million have been recorded in the Consolidated Income Statement as Impairment of reinsurance receivables.

| D3 Acquisition Proposal Expenses

The Company has worked with various legal, financial and Board advisers to assist with the acquisition proposals from Suncorp Group Limited/Vero

Insurance New Zealand Limited and Fairfax Financial Holdings Limited. At 30 September 2018, Tower has provided for all costs incurred to date in

respect of the acquisition activity. These have been recorded in the Consolidated Income Statement as a separate line item (Acquisition proposal

expenses).

59
| D4 Deferred Acquisition Costs

2018

$000

2017

$000

Balance at the beginning of year20,961 19,973

Acquisition costs during the year39,555 38,385

Current period amortisation(37,921)(37,397)

Total deferred acquisition costs22,595 20,961

Analysed as:

Current22,595 20,961

Non-current – –

Total deferred acquisition costs22,595 20,961

Accounting Policy

Acquisition costs incurred in obtaining general insurance contracts are deferred and recognised as assets where they can be reliably measured and

where it is probable that they will give rise to premium revenue that will be recognised in subsequent reporting periods.

Deferred acquisition costs are amortised systematically in accordance with the expected pattern of the incidence of risk under the general insurance

contracts to which they relate. This pattern of amortisation corresponds to the earning pattern of the corresponding premium revenue.

| D5 Operating Leases

2018

$000

2017

$000

As lessee

Rent payable to the end of the lease terms are:

Not later than one year3,286 2,806

Later than one year and not later than five years7,701 7,444

Later than five years – 2,010

10,987 12,260

Accounting policy

Leases in which a significant portion of the risks and rewards of ownership are retained by the lessor are classified as operating leases. Operating

lease payments are recognised as an expense in the periods the services are received over the period of the lease. Operating lease payments

represent future rentals payable for office space under current leases. Initial leases were for an average of four years with rental rates reviewed

every one to three years.

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201860

| D6 Tax

Accounting Policy

Current tax

Current tax is the amount of income taxes payable or recoverable in respect of the taxable profit or loss for the period. It is calculated using tax rates

and laws that have been enacted or substantively enacted by the reporting date. Current tax for current and prior periods is recognised as a liability

(or asset) to the extent that it is unpaid (or refundable).

Deferred tax

Deferred tax is accounted for using the comprehensive balance sheet liability method in respect of temporary differences arising from differences

between the carrying amount of assets and liabilities in the financial statements and the corresponding tax base of those items.

Deferred tax assets and liabilities are recognised for temporary differences at the tax rates expected to apply when the assets are recovered or

liabilities settled, based on the tax rates enacted or substantively enacted for each jurisdiction. Deferred tax assets are recognised to the extent that it

is probable that taxable profits will be available against which deductible temporary differences or unused tax losses can be utilised. Such assets and

liabilities are not recognised if the temporary difference arises from goodwill or from the initial recognition (other than in a business combination) of

the other assets and liabilities in a transaction that affects neither the taxable profit nor the accounting profit.

Deferred tax balances attributable to amounts recognised directly in equity are also recognised directly in equity.

Income tax expense

The income tax expense is the tax payable on taxable income for the current period, based on the income tax rate for each jurisdiction and adjusted

for changes in deferred tax assets and liabilities attributable to temporary differences and unused tax losses.

GST

All revenues, expenses and certain assets are recognised net of goods and services taxes (GST) except where the GST is not recoverable. In these

circumstances the GST is included in the related asset or expense. Receivables and payables are reported inclusive of GST. The net GST payable to

or recoverable from the tax authorities as at balance date is included as a receivable or payable in the balance sheet.

Tax consolidation

Tower Limited and its subsidiaries are part of a single consolidated group for New Zealand tax purposes, with the exception of Tower Insurance Limited.

Tax cash flows

Tax cash flows are included in the statements of cash flows on a net basis other than to the extent that the GST is not recoverable and has been

included in the expense or asset.

Imputation credit account

The balance of the imputation account at the end of the year is determined having adjusted for imputation credits that will arise from the payment

of income tax provided; dividends recognised as a liability; and the receipt of dividends recognised as receivables at the reporting date.

61
D6.1 Tax expense

2018

$000

2017

$000

Current tax2,714 4,468

Deferred tax(3,463)(3,064)

Under (over) provided in prior years(546)597

Total tax (benefit) expense (1,295)2,001

The tax (benefit) expense can be reconciled to the accounting profit as follows:

Loss before tax from continuing operations(8,021)(5,999)

Income tax at the current rate of 28%(2,246)(1,680)

Tax effect of:

Prior period adjustments(546)597

Non-deductible expenditure/non-assessable income120 967

Foreign tax credits written off1,372 1,874

Other5 243

Total tax (benefit) expense (1,295)2,001

D6.2 Current tax assets

2018

$000

2017

$000

Current1,575 1,206

Non-current12,256 12,256

Total current tax assets13,831 13,462

A non-current tax asset of $12,256,000 is recognised in the financial statements of the Group as at 30 September 2018 in relation to excess tax payments

made in previous years (2017: $12,256,000). Non-current tax assets are expected to be recovered from 2022, as determined by the Board approved

operational plan for financial years 2019 to 2022. A current tax asset of $1,575,000 is recognised in relation to excess tax payments made in the Pacific

Islands over and above the estimated tax liabilities for the year (2017: $1,206,000).

D6.3 Current tax liabilities

Current tax liabilities of $174,000 relate to taxes payable to off shore tax authorities in the Pacific Islands (2017: $560,000).

D6.4 Imputation credits

The Group imputation credit account reflects the imputation credits held by the Company as the representative member of the Group.

2018

$000

2017

$000

Imputation credits available for use in subsequent reporting periods489 489

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201862

D6.5 Deferred tax assets and liabilities


OPENING

BALANCE AT

1 OCTOBER

$000

(CHARGED)

CREDITED

TO INCOME

STATEMENT

$000

(CHARGED)

CREDITED TO

COMPREHENSIVE

INCOME

$000

CLOSING

BALANCE AT

30 SEPTEMBER

$000

For the Year Ended 30 September 2018

Movement in deferred tax assets

Provisions and accruals2,265 576 – 2,841

Property, plant and equipment7,781 45 – 7,826

Tax losses26,958 3,727 – 30,685

Other778 (15) – 763

Total deferred tax assets37,782 4,333 – 42,115

Set-off of deferred tax liabilities pursuant to NZ IAS 12(5,739)

Net deferred tax assets 36,376

Movement in deferred tax liabilities

Deferred acquisition costs(5,078)(661) – (5,739)

Other(299)(209)(81)(589)

Total deferred tax liabilities(5,377)(870)(81)(6,328)

Set-off of deferred tax liabilities pursuant to NZ IAS 125,739

Net deferred tax liabilities(589)

For the Year Ended 30 September 2017

Movement in deferred tax assets

Provisions and accruals3,141 (876) – 2,265

Property, plant and equipment3,288 4,493 – 7,781

Tax losses29,086 (2,128) – 26,958

Other – 778 – 778

Total deferred tax assets35,515 2,267 – 37,782

Set-off of deferred tax liabilities pursuant to NZ IAS 12(5,037)

Net deferred tax assets 32,745

Movement in deferred tax liabilities

Deferred acquisition costs(4,851)(227) – (5,078)

Other(1,294)1,024 (29)(299)

Total deferred tax liabilities(6,145)797 (29)(5,377)

Set-off of deferred tax liabilities pursuant to NZ IAS 125,037

Net deferred tax liabilities(340)

Recognition of deferred tax assets is a key area of judgement. Management expects to utilise the tax losses against future profits over the next four

years. Management had expected to utilise the tax losses against future profits over the following four years as at 30 September 2017.

Deferred tax liabilities of nil have not been recognised in respect of temporary differences associated with investments in subsidiaries (2017: liabilities

of $946,000).

D6 Tax (continued)

63
| Part E – Other Balance Sheet Items

This section includes information about assets and liabilities not included elsewhere, including receivables, non-current assets, payables

and provisions.

| E1 Receivables

2018

$000

2017

$000

Premium receivables141,578 124,030

Reinsurance recovery receivables32,600 81,647

Claim recoveries and unearned reinsurance premiums11,616 10,783

Trade receivables185,794 216,460

EQC receivables69,272 66,437

Other4,541 3,672

Total receivables259,607 286,569

Premium receivables represent net amounts owed to Tower (including GST) by policyholders. The majority of the amounts outstanding are not due.

Accounting policy

Receivables are recognised initially at fair value and subsequently measured at amortised cost, less provision for impairment. Premium receivables

and other trade receivables are presented net of allowance for credit losses and impairment.

The table below shows the reconciliation of the allowance for credit losses and impairment at the reporting date.

2018

$000

2017

$000

Opening balance(805)(1,750)

Provisions added during the year(208)(41)

Provisions released during the year362 978

Foreign exchange movements5 8

Closing balance(646)(805)

Trade and other receivables, including EQC reinsurance recoveries, are included in current assets except for those with maturities greater than

12 months after the reporting date, which are classified as non-current assets.

2018

$000

2017

$000

Analysed as

Current 185,133 199,960

Non current74,474 87,005

Total receivables259,607 286,569

Collectability of trade receivables

Collectability of trade receivables is reviewed on an on-going basis. The allowance for credit losses and impairment in relation to trade receivables

is provided for based on estimated recoverable amounts determined by reference to current customer circumstances and past default experience.

In determining the recoverability of a trade receivable the Group considers any change in the credit quality of the trade receivable from the date the

credit was initially granted up to the reporting date. The Group has provided fully for receivables over 120 days past due. Trade receivables between

60 and 120 days past due are provided for based on estimated irrecoverable amounts.

Assets arising from reinsurance contracts

Assets arising from reinsurance contracts are also determined using the above methods. In addition, the recoverability of these assets is assessed

on a periodic basis to ensure that the balance is reflective of the amounts that will ultimately be received, taking into consideration factors such as

counterparty and credit risk. Impairment is recognised where there is objective evidence that the Group may not receive amounts due to it and these

amounts can be reliably measured.

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201864

Earthquake Commission receivables

Kaikoura Region earthquake

At 30 September 2018, the amount due from EQC for reimbursement of claims handling expenses and claims paid in relation to the Kaikoura event

is $0.9 million (2017: $1.3 million).

Canterbury earthquakes

Other receivables include an amount of $68.4 million due from EQC for land damage and building costs relating to the Canterbury earthquake

provisions as disclosed in Note B3 (2017: $65.1 million).

| E2 Intangible Assets

SOFTWARE

GOODWILLACQUIRED

INTERNALLY

DEVELOPED

UNDER

DEVELOPMENTTOTAL

Year Ended 30 September 2018

Cost:

Opening balance17,744 5,097 37,045 4,484 64,370

Additions – – – 19,026 19,026

Disposals – – – (74)(74)

Transfers – 285 600 (885) –

Transfers to Property, plant and equipment – – – (49)(49)

Closing balance17,744 5,382 37,645 22,502 83,273

Accumulated amortisation:

Opening balance – (4,501)(28,535) – (33,036)

Amortisation charge – (197)(4,998) – (5,195)

Closing balance – (4,698)(33,533) – (38,231)

Net book value

At cost17,744 5,382 37,645 22,502 83,273

Accumulated amortisation – (4,698)(33,533) – (38,231)

Closing net book value17,744 684 4,112 22,502 45,042

Year Ended 30 September 2017

Cost:

Opening balance17,744 5,020 31,305 4,554 58,623

Additions – – – 6,237 6,237

Disposals – (6) – (17)(23)

Transfers – 82 5,740 (5,822) –

Transfers to Property, plant and equipment – – – (468)(468)

Foreign exchange movements – 1 – – 1

Closing balance17,744 5,097 37,045 4,484 64,370

Accumulated amortisation:

Opening balance – (4,265)(22,376) – (26,641)

Amortisation charge – (235)(6,160) – (6,395)

Foreign exchange movements – (1)1 – –

Closing balance – (4,501)(28,535) – (33,036)

Net book value

At cost17,744 5,097 37,045 4,484 64,370

Accumulated amortisation – (4,501)(28,535) – (33,036)

Closing net book value17,744 596 8,510 4,484 31,334

E1 Receivables (continued)

65
Software

Accounting policy

Application software is recorded at cost less accumulated amortisation and impairment. Amortisation is charged on a straight line basis over the

estimated useful life of the software.

Internally generated intangible assets are recorded at cost which includes all the directly attributable costs necessary to create, produce and

prepare the asset capable of operating in the manner intended by management. Amortisation of internally generated intangible assets begins when

the asset is available for use and is amortised on a straight line basis over the estimated useful life.

General use computer software 3 – 5 years

Core operating system software 3 – 10 years

Impairment testing for software under development

Software under development includes expenditure relating to the development of a new core IT platform, digital enhancements, communications

technology and work to extend the useful life of other IT assets. Software under development is subject to impairment testing and no impairment loss

has been recognised in 2018 (2017: Nil). In assessing the recoverable amount for software under development, Management has based its assumptions

on the five year projections covered by Tower’s 2019-2023 operating plans, including an assessment of additional revenue and expense savings expected

to be generated by each asset. These assumptions are determined from a variety of sources, including Management’s past experience, comparison of

key metrics to industry baselines, sensitivity of revenues to changes in drivers and analysis of current expenditure that can be reduced. Management

has not put any value on projected cash flows beyond a five year period. A discount rate of 12% has been used in the valuation (2017: 12%).

Goodwill

Accounting policy

Goodwill acquired in a business combination is initially measured at cost being the excess of the cost of the business combination over the Group’s

interest in the fair value of the identifiable assets, liabilities and contingent liabilities of the entity acquired, at the date of acquisition. Following initial

recognition, goodwill on acquisition of a business combination is not amortised but is tested for impairment bi-annually or more frequently if events

or changes in circumstances indicate that the carrying value may be impaired.

For the purpose of impairment testing, goodwill acquired in a business combination is, from the acquisition date, allocated to each of the Group’s

cash generating units, or groups of cash generating units, that are expected to benefit from the synergies of the combination, irrespective of whether

other assets or liabilities of the acquiree are assigned to those units or groups of units.

Any impairment is recognised immediately in the income statement.

Impairment testing for goodwill

Goodwill is allocated to the New Zealand general insurance cash generating unit. The carrying amount of goodwill allocated to the cash generating

unit is shown below:

2018

$000

2017

$000

Carrying amount of goodwill17,744 17,744

Goodwill is subject to impairment testing at the cash-generating unit level and no impairment loss has been recognised in 2018 as a result of the

impairment review (2017: Nil). The recoverable amount of the general insurance business has been assessed with reference to its appraisal value to

determine its value in use. A base discount rate of 13% was used in the calculation (2017: 14%). Other assumptions used are consistent with the actuarial

assumptions in Note B5 in respect of Tower Insurance. The cash flows were projected over the expected life of the policies. The projected cash flows

are determined based on past performance and management’s expectations for market developments with a terminal growth rate of 2% (2017: 2%).

Management considers that the recoverable amount from the general insurance business, as determined by the appraisal value, will exceed the

carrying value under a reasonable range of adverse scenarios.

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201866

| E3 Property, Plant and Equipment

LAND AND

BUILDINGS

$000

OFFICE

EQUIPMENT AND

FURNITURE

$000

MOTOR

VEHICLES

$000

COMPUTER

EQUIPMENT

$000

TOTAL

$000

For the Year Ended 30 September 2018

Cost

Opening balance2,959 7,715 1,122 14,764 26,560

Additions – 513 65 198 776

Revaluations434 – – – 434

Disposals – (14)(165)(9)(188)

Foreign exchange movements22 7 (3)17 43

Closing balance3,415 8,221 1,019 14,970 27,625

Accumulated depreciation

Opening balance – (2,880)(837)(14,063)(17,780)

Depreciation – (958)(38)(503)(1,499)

Disposals – 15 176 2 193

Foreign exchange movements – 35 (84)20 (29)

Closing balance–(3,788)(783)(14,544)(19,115)

Closing balance

Cost / revaluation3,415 8,221 1,019 14,970 27,625

Accumulated depreciation – (3,788)(783)(14,544)(19,115)

Net book value3,415 4,433 236 426 8,510

For the Year Ended 30 September 2017

Cost

Opening balance2,710 7,481 1,277 14,038 25,506

Additions – 291 69 754 1,114

Revaluations247 – – – 247

Disposals(27)(74)(231)(19)(351)

Foreign exchange movements29 17 7 (9)44

Closing balance2,959 7,715 1,122 14,764 26,560

Accumulated depreciation

Opening balance – (2,004)(930)(13,061)(15,995)

Depreciation – (928)(93)(1,011)(2,032)

Disposals – 57 188 16 261

Foreign exchange movements – (5)(2)(7)(14)

Closing balance–(2,880)(837)(14,063)(17,780)

Closing balance

Cost / revaluation2,959 7,715 1,122 14,764 26,560

Accumulated depreciation – (2,880)(837)(14,063)(17,780)

Net book value2,959 4,835 285 701 8,780

67
Accounting policy

Measurement of property, plant and equipment

Property, plant and equipment is initially recorded at cost including transaction costs and subsequently measured at cost less any accumulated

depreciation and impairment losses.

Depreciation is calculated using the straight line method to allocate the assets’ cost or revalued amounts, net of any residual amounts, over their

useful lives. The assets’ useful lives are reviewed and adjusted if appropriate at each balance date. An asset’s carrying amount is written down

immediately to its recoverable amount if it is considered that the carrying amount is greater than its recoverable amount.

Computer equipment 3 – 5 years

Furniture & fittings 5 – 9 years

Motor Vehicles 5 years

Buildings 50 – 100 years

Leasehold property improvements 3 – 12 years

Measurement of land and buildings

Land and buildings are shown at fair value, based on periodic valuations by external independent appraisers less subsequent depreciation for

buildings. Any accumulated depreciation at the date of revaluation is eliminated against the gross carrying amount of the asset and the net amount is

restated to the revalued amount of the asset.

Land and buildings are located in Fiji and are stated at fair value. Fair value is determined using an income approach whereby future rental streams are

capitalised at a rate appropriate for the type of property and lease arrangement. This value is then adjusted to take into account recent market activity.

Valuation was performed as at 14 September 2018 by Rolle Associates, registered valuers in Fiji. There has been no material movement in the valuation

between 14 September 2018 and 30 September 2018. Inputs to the valuation of the Fiji property are considered to be based on non-observable market

data, thus classified as level 3 in the fair value hierarchy. Inputs include gross rentals per square meter of similar property in the Suva area, recent

comparable sales of commercial property in Suva and a capitalisation rate of between 7.5% and 9.5% (2017: 7.0%).

Had land and buildings been recognised under the cost model the carrying amount would have been $1,145,000 (2017: $1,145,000). The revaluation

surplus for the period is recorded in other comprehensive income and has no restrictions on the distribution of the balance to shareholders.

| E4 Capital Commitments

As at the 30 September 2018, the Group has capital commitments of $13.9 million dollars in relation to the implementation and delivery of a new

insurance policy management system (2017: nil).

| E5 Payables

2018

$000

2017

$000

Trade payables16,028 16,479

Reinsurance payables23,388 21,763

Payable to other insurers268 2,590

Investment settlement balances5,099 –

GST payable16,272 12,991

Other payables19,320 15,001

Total payables80,375 68,824

Analysed as:

Current 63,975 51,124

Non current16,400 17,700

Total payables80,375 68,824

Accounting policy

Payables represent liabilities for goods and services provided to the Group prior to the end of the financial year which are unsettled. Payables are

recognised initially at fair value less transaction costs and subsequently measured at amortised cost using the effective interest method.

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201868

Payable to other insurers

At 30 September 2018 there was $0.3 million (2017: $2.6 million) recorded within Payables as funds held on behalf of other insurers in respect of SPP

claims. Refer to Note C2 for further details on cash held in respect of multi-unit claims as lead insurer.

| E6 Provisions

2018

$000

2017

$000

Employee benefits5,789 5,773

Total provisions5,789 5,773

Analysed as:

Current 5,402 5,592

Non current387 181

Total provisions5,789 5,773

Accounting policy

Provisions are recognised when the Group has a present legal or constructive obligation as a result of a past event or decision, and it is more likely

than not that an outflow of resources will be required to settle the obligation. Provisions are recognised as the best estimate of future cash flows

discounted to present value where the effect is material.

Provision is made for employee entitlements for services rendered up to the balance date. This includes salaries, wages, bonuses, annual leave and

long service leave.

| Part F – Capital and Risk Management

This section provides information about Tower’s capital structure and its approaches to managing risk.

| F1 Contributed Equity

2018

$000

2017

$000

Opening balance382,172 382,172

Issue of share capital70,838 –

Costs of capital raise(5,467) –

Total contributed equity447,543 382,172

On 14 November 2017 the Company invited its eligible shareholders to subscribe to a rights issue of 1 new share for every 1 existing share held at the

record date on 22 November 2017 at a price of NZD0.42 (or AUD0.39) for each new share. The issue was fully subscribed on 20 December 2017.

Represented by:

2018

NUMBER

OF SHARES

2017

NUMBER

OF SHARES

Opening balance168,662,150 168,662,150

Issued shares168,662,150 –

Total shares on issue337,324,300 168,662,150

Ordinary shares issued by the Group are classified as equity and are recognised at fair value less direct issue costs. All shares rank equally with one vote

attached to each share. There is no par value for each share.

There were no Tower Limited dividend payments during the year ended 30 September 2018 (2017: nil).

69
| F2 Reserves

2018

$000

2017

$000

Foreign currency translation reserve (FCTR)

Opening balance(4,343)(4,443)

Currency translation differences arising during the year(54)100

Closing balance(4,397)(4,343)

Separation Reserve

Opening balance(113,000)(113,000)

Closing balance(113,000)(113,000)

Asset revaluation reserve

Opening balance889 671

Gain on revaluation, net of deferred tax353 218

Closing balance1,242 889

Total reserves(116,155)(116,454)

Accounting policy

FCTR

Exchange differences arising on translation of foreign controlled entities and net investment of a foreign entity are taken to the foreign currency

translation reserve. The reserve is recognised in profit and loss when the net investment is disposed.

Separation reserve

The separation reserve was created in 2007 at the time of the demerger of the New Zealand and Australian businesses in accordance with a ruling

provided by the Australian Tax Office (ATO). It will be carried forward indefinitely as a non-equity reserve to meet the requirements of the ATO.

Asset revaluation reserve

The asset revaluation reserve is used to recognise unrealised gains on the value of land and buildings above initial cost.

| F3 Capital Risk Management & Solvency

Solvency requirements

The methodology and bases for determining the solvency margin are in accordance with the requirements of the Solvency Standard for Non-life

Insurance Business published by the Reserve Bank of New Zealand. The minimum solvency capital required to meet solvency requirements under

the Insurance (Prudential Supervision) Act 2010 is shown below. Actual solvency capital exceeds the minimum solvency capital requirement for Tower

Insurance Group by $82.4 million (2017: $96.3 million) and Tower Insurance parent by $78.2 million (2017: $87.9 million).

TOWER INSURANCE LIMITEDTOWER INSURANCE LIMITED GROUP

UNAUDITED

2018

$000

UNAUDITED

2017

$000

AUDITED

2018

$000

AUDITED

2017

$000

Actual solvency capital136,476 149,317 156,765 166,823

Minimum solvency capital58,298 61,387 74,344 70,545

Solvency margin78,178 87,930 82,421 96,278

Solvency ratio234%243%211%236%

The Reserve Bank of New Zealand imposed a condition of license requirement for Tower Insurance Limited to maintain a minimum solvency margin of

$50.0 million. This minimum solvency requirement continues to be a requirement for Tower Insurance Limited. The actual solvency capital as determined

under the solvency standards is required to exceed the minimum solvency capital level by at least this amount.

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201870

Capital risk management

The Group’s objective when managing capital is to ensure that the level of capital is sufficient to meet the Group’s statutory solvency obligations

including on a look forward basis to enable it to continue as a going concern in order to meet the needs of its policyholders, to provide returns for

shareholders, and to provide benefits for other stakeholders of the Group. The Group’s capital resources include shareholders’ equity.

NOTE

2018

$000

2017

$000

Tower shareholder equity273,311 214,419

Standby credit facility (undrawn)C450,000 20,000

Total capital and liquidity resources323,311 234,419

The Group measures adequacy of capital against the Solvency Standards for Non-life Insurance Business (the solvency standards) published by the

Reserve Bank of New Zealand (RBNZ) alongside additional capital held to meet RBNZ minimum requirements and any further capital as determined

by the Board. During the year ended 30 September 2018 the Group complied with all externally imposed capital requirements.

The Group holds assets in excess of the levels specified by the various solvency requirements to ensure that it continues to meet the minimum

requirements under a reasonable range of adverse scenarios. The Group’s capital management strategy forms part of the Group’s broader strategic

planning process overseen by the Audit and Risk Committee of the Board.

| F4 Net Assets per Share

2018

$

2017

$

Net assets per share0.81 1.28

Net tangible assets per share0.57 0.90

Accounting Policy

Net assets per share represent the value of the Group’s total net assets divided by the number of ordinary shares on issue at the period end. Net

tangible assets per share represent the net assets per share adjusted for the effect of intangible assets and deferred tax balances. Net assets per

share and net tangible assets per share for 30 September 2017 have not been restated to reflect the bonus element of the rights issue.

Reconciliation to net tangible assets is provided below:

2018

$000

2017

$000

Net assets274,779 215,744

Less: deferred tax(35,787)(32,405)

Less: intangible assets(45,042)(31,334)

Net tangible assets193,950 152,005

F3 Capital Risk Management & Solvency (continued)

71
| F5 Earnings per Share

2018

$000

2017

$000

Loss attributable to shareholders(6,773)(8,461)

2018

NUMBER

OF SHARES

2017

NUMBER

OF SHARES

Weighted average number of ordinary shares for basic and diluted earnings per share308,077,348 205,532,480

2018

CENTS

2017

CENTS

Basic and diluted (loss) earnings per share(2.20)(4.12)

Accounting Policy

Basic earnings per share is calculated by dividing the net profit attributed to shareholders of the Company, excluding any costs of servicing equity

other than ordinary shares, by the weighted average number of ordinary shares outstanding during the year.

Diluted earnings per share is calculated by dividing the net profit attributed to shareholders of the Company by the weighted average number of

ordinary shares on issue during the year adjusted for the weighted average number of ordinary shares that would be issued on the conversion of all

the dilutive potential ordinary shares into ordinary shares.

As a result of the rights issue, the weighted average number of ordinary shares have been adjusted retrospectively for the bonus element of the rights

issue. The basic and diluted (loss) per share for 30 September 2017 has been restated to reflect the change.

There was no dilutive impact on basic earnings per share for 2018 (2017: nil).

| F6 Risk Management

The financial condition and operating results of the Group are affected by a number of key financial and non-financial risks. Financial risks include

market risk, credit risk, financing and liquidity risk. The non-financial risks include insurance risk, compliance risk and operational risk.

Tower Limited’s objective is to satisfactorily manage these risks in line with the Board approved Group Risk and Compliance policy. Various procedures

are put in place to control and mitigate the risks faced by the Group. Business managers are responsible for understanding and managing their risks

including operational and compliance risk. The consolidated entity’s exposure to all high and critical risks is reported monthly to the Board and quarterly

to the Audit and Risk Committee.

The Board has delegated to the Audit and Risk Committee the responsibility to review the effectiveness and efficiency of management processes,

internal audit services, risk management and internal financial controls and systems as part of their duties. The Risk and Compliance team is in place

in an oversight and advisory capacity and to manage the risk and compliance framework.

Financial risks are generally monitored and controlled by selecting appropriate assets to back policy liabilities. The assets are regularly monitored

to ensure that there are no material asset and liability mismatching issues and other risks such as liquidity risk and credit risk are maintained within

acceptable limits.

The Board has responsibility for:

—reviewing investment policies for Tower Limited funds;

—reviewing the Treasury Policy which includes our strategy for investment management and the use of derivatives;

—considering the establishment, adjustment or deletion of limits and counter-party approvals, and the scope of financial instruments to be used

in the management of Tower Limited’s investments;

—reviewing the appointment of external investment managers;

—monitoring investment and fund manager performance; and

—monitoring compliance with investment policies and client mandates.

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201872

F6.1 Insurance risk

The financial condition and operations of the insurance business are affected by a number of key risks including insurance risk, interest rate risk,

currency risk, market risk, financial risk, compliance risk, fiscal risk and operational risk. Notes on the policies and procedures employed in managing

these risks are set out below.

(a) Objectives in managing risks arising from insurance contracts and policies for mitigating those risks

The risk management activities include prudent underwriting, pricing, and management of risk, together with claims management, reserving and

investment management. The objective of these disciplines is to enhance the financial performance of the insurance operations and to ensure sound

business practices are in place for underwriting risks and claims management.

The key controls in place to mitigate risks arising from writing insurance contracts include:

—comprehensive management information systems and actuarial models using historical information to calculate premiums and monitor claims;

—monitoring natural disasters such as earthquakes, floods, storms and other catastrophes using models; and

—the use of reinsurance to limit the Group’s exposure to individual catastrophic risks.

(b) Concentration of insurance risk

RISKSOURCE OF CONCENTRATIONRISK MANAGEMENT MEASURES

An accumulation of risks

arising from a natural peril

Insured property concentrations Accumulation risk modelling, reinsurance protection

A large property lossFire or collapse affecting one building

or a group of adjacent buildings

Maximum acceptance limits, property risk grading,

reinsurance protection

F6.2 Market risk

Market risk is the risk of change in the fair value of financial instruments from fluctuations in foreign exchange rates (currency risk), market interest rates

(interest rate risk) and market prices (price risk), whether such change in price is caused by factors specific to an individual financial instrument, or its

issuer or factors affecting all financial instruments traded in a market.

(i) Currency risk

Currency risk is the risk of loss resulting from changes in exchange rates when applied to assets and liabilities or future transactions denominated in a

currency that is not the Group’s functional currency. The exposure is not considered to be material.

The Group’s principal transactions are carried out in New Zealand dollars and its exposure to foreign exchange risk arises primarily with respect to

the Pacific Island insurance business. The Group generally elects to not hedge the capital invested in overseas entities, thereby accepting the foreign

currency translation risk on invested capital.

The Group also has foreign exchange risk on payments to suppliers that are denominated in other currencies. Tower may hedge future payments,

where appropriate, and provided that the timing and amount of those transactions can be estimated with a reasonable degree of certainty.

The Board sets limits for the management of currency risk arising from its investments based on prudent international asset management practice.

Regular reviews are conducted to ensure that these limits are adhered to. In accordance with this policy, Tower Insurance does not hedge the currency

risk arising from translation of the financial statements of foreign operations other than through net investment in foreign operations.

(ii) Interest rate risk

Interest rate risk is the risk that the value or future value cash flows of a financial instrument will fluctuate because of changes in interest rates.

Interest rate and other market risks are managed by the Group through strategic asset allocation and approved investment management guidelines

that have regard to policyholder expectations and risks and to target surplus for solvency as advised by the Appointed Actuary.

Interest rate risk arises to the extent that there is a mismatch between the fixed interest portfolios used to back outstanding claim liabilities and those

outstanding claims. Interest rate risk is managed by matching the duration profiles of investment assets and outstanding claim liabilities.

(iii) Price risk

Price risk is the risk of loss resulting from the decline in prices of equity securities or other assets. The exposure is not considered to be material.

F6.3 Credit risk

Credit risk is the risk of loss that arises from a counterparty failing to meet their contractual commitment in full and on time, or from losses arising from

the change in value of a trading financial instrument as a result in changes in credit risk of that instrument.

The Group’s exposure to credit risk is limited to deposits and investments held with banks and other financial institutions, reinsurance receivables from

reinsurers, as well as credit exposure to customers or other counterparties. Credit exposure in respect of the Group’s cash deposit balances is limited

to banks with minimum AA- credit ratings. Investments held with banks and financial institutions that are managed by investment managers have a

minimum credit rating accepted by the Group of ‘A-’. Overall exposure to credit risk is monitored on a Group basis in accordance with limits set by the

Board. The Group has no significant exposure to credit risk.

F6 Risk Management (continued)

73
(i) Credit risk concentration

Concentration of credit risk exists when the Group enters into contracts or financial instruments with a number of counterparties that are engaged in

similar business activities or exposed to similar economic factors that might affect their ability to meet contractual obligations. Tower Limited manages

concentration of credit risk by credit rating, industry type and individual counterparty.

The significant concentrations of credit risk are outlined by industry type below.

CARRYING VALUE

2018

$000

2017

$000

New Zealand government919 8,184

Other government agencies39,352 18,412

Banks227,180 229,526

Financial institutions32,186 13,241

Other non-investment related receivables255,782 283,158

Total financial assets with credit exposure555,419 552,521

(ii) Maximum exposure to credit risk

The Group’s maximum exposure to credit risk without taking account of any collateral or any other credit enhancements, is as follows:

CARRYING VALUE

2018

$000

2017

$000

Cash and cash equivalents102,001 83,876

Loans and receivables255,780 283,158

Financial assets at fair value through profit or loss197,367 185,256

Derivative financial assets271 231

Total credit risk555,419 552,521

(iii) Credit quality of financial assets that are neither past due nor impaired

The credit quality of financial assets that are neither past due nor impaired can be assessed by reference to external credit ratings (if applicable) or to

historical information about counterparty default rates:

CARRYING VALUE

2018

$000

2017

$000

Credit exposure by credit rating

AAA85,321 67,201

AA183,095 184,233

A16,484 527

BBB – –

Below BBB13,020 15,706

Total counterparties with external credit ratings297,920 267,667

Group 1245,702 230,795

Group 2 – –

Group 31,717 1,696

Total counterparties with no external credit rating247,419 232,491

Total financial assets neither past due nor impaired with credit exposure545,339 500,158

Group 1 _ trade debtors outstanding for less than 6 months

Group 2 – trade debtors outstanding for more than 6 months with no defaults in the past

Group 3 – unrated investments

Tower Insurance invests in Pacific regional investment markets through its Pacific Island operations to comply with local statutory requirements and

in accordance with Tower Insurance investment policies. These investments generally have low credit ratings representing the majority of the value

included in the ‘Below BBB’ and unrated categories in the table above.

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201874

(iv) Financial assets that would otherwise be past due whose terms have been renegotiated

No financial assets have been renegotiated in the past year (2017: nil).

(v) Financial assets that are past due but not impaired

The Group considers that financial assets are past due if payments have not been received when contractually due. At the reporting date, the total

carrying value of past due but not impaired assets held are as follows:

LESS THAN

30 DAYS

$000

31 TO 60 DAYS

$000

61 TO 90 DAYS

$000

OVER 90 DAYS

$000

TOTAL

$000

As at 30 September 2018

Reinsurance recoveries receivable – 27 – – 27

Outstanding premiums and trade receivables5,526 1,422 2,641 464 10,053

Total5,526 1,449 2,641 464 10,080

As at 30 September 2017

Reinsurance recoveries receivable3,7352,6801,99935,49143,905

Outstanding premiums and trade receivables5,0261,7541,2684108,458

Total8,7614,4343,26735,90152,363

(vi) Financial assets that are individually impaired

CARRYING VALUE

2018

$000

2017

$000

Outstanding premiums and trade receivables – –

Total – –

F6.4 Financing and liquidity risk

Financing and liquidity risk is the risk that the Group will not be able to meet its cash outflows or refinance debt obligations, as they fall due, because

of lack of liquid assets or access to funding on acceptable terms. To mitigate financing and liquidity risk the Group maintains sufficient liquid assets to

ensure that the Group can meet its debt obligations and other cash outflows on a timely basis.

Financial liabilities and guarantees by contractual maturity

The table below summarises the Group’s financial liabilities and guarantees into relevant maturity groups based on the remaining period to the

contractual maturity date at balance date. All amounts disclosed are contractual undiscounted cash flows that include interest payments and exclude

the impact of netting agreements.

CARRYING VALUE

$000

TOTAL

CONTRACTUAL

CASH FLOWS

$000

LESS THAN

ONE YEAR

$000

GREATER THAN

ONE YEAR

$000

As at 30 September 2018

Financial liabilities

Trade payables16,296 16,296 16,296 –

Reinsurance payables23,388 23,388 6,988 16,400

Other payables10,906 10,906 10,906 –

Total50,590 50,590 34,190 16,400

As at 30 September 2017

Financial liabilities

Trade payables19,069 19,069 19,069 –

Reinsurance payables21,763 21,763 4,063 17,700

Other payables2,682 2,682 2,682 –

Borrowings29,921 29,921 29,921 –

Total73,435 73,435 55,735 17,700

F6 Risk Management (continued)

75
F6.5 Derivative financial instruments

The Group utilises derivative financial instruments to reduce investment risk. Specifically, derivatives are used to achieve cost effective short-term

re-weightings of asset class, sector and security exposures and to hedge portfolios, as an economic hedge, when a market is subject to significant

short-term risk.

Derivative financial instruments used by the Group include interest rate swaps, foreign exchange forward contracts and foreign exchange options.

Derivatives are initially recognised at fair value on the date a derivative contract is entered into and are subsequently remeasured at their fair value.

The fair values of interest rate swaps are calculated by discounting estimated future cash flows based on the terms and maturity of each contract

using market interest rates. The average interest rate is based on the outstanding balances at the start of the financial year.

The table below details the notional principal amounts, fair values and remaining terms of derivatives outstanding as at the reporting date:

AVERAGE CONTRACTED

FIXED INTEREST

NOTIONAL

PRINCIPAL AMOUNTFAIR VALUE

2018

%

2017

%

2018

$000

2017

$000

2018

$000

2017

$000

Less than 1 year0%0%23,555 25,249 271 166

1 to 2 years0%0% – – – –

2 to 5 years0%2% – 20,580 – 65

Over 5 years0%0% – – – –

23,555 45,829 271 231

F6.6 Sensitivity analysis

The analysis below demonstrates the impact of changes in interest rates, exchange rates and equity prices on profit after tax and equity on continuing

business. The analysis is based on changes in economic conditions that are considered reasonably possible at the reporting date. The potential impact

is assumed as at the reporting date.

(i) Interest rate

The impact of a 50 basis point change in New Zealand and international interest rates as at the reporting date on profit after tax and equity is included

in the tables below. The sensitivity analysis assumes changes in interest rates only. All other variables are held constant.

2018

IMPACT ON:

2017

IMPACT ON:

PROFIT

AFTER TAX

$000

EQUITY

$000

PROFIT

AFTER TAX

$000

EQUITY

$000

Change in variables

+ 50 basis points(696)(696)(546)(546)

- 50 basis points768 768 474 474

This analysis assumes that the sensitivity applies to the closing market yields of fixed interest investments. A parallel shift in the yield curve is assumed.

The risks assumed and methods used for deriving sensitivity information and significant variables have been applied consistently over the reporting

period included in the analysis.

(ii) Foreign currency

The following tables demonstrate the impact of a 10% movement of currency rates against the New Zealand dollar on profit after tax and equity.

The analysis assumes changes in foreign currency rates only, with all other variables held constant. The potential impact on the profit and equity

of the Group is due to the changes in fair value of currency sensitive monetary assets and liabilities as at the reporting date.

2018

IMPACT ON:

2017

IMPACT ON:

PROFIT

AFTER TAX

$000

EQUITY

$000

PROFIT

AFTER TAX

$000

EQUITY

$000

Change in variables

10% appreciation of New Zealand dollar129 (2,641)292 (2,380)

10% depreciation of New Zealand dollar(158)2,905 (357)2,909

The dollar impact of the change in currency movements is determined by applying the sensitivity to the value of the international assets.

The risks assumed and methods used for deriving sensitivity information and significant variables have been applied consistently over the reporting

period included in the analysis.

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201876

(iii) Other price

Other price sensitivity includes sensitivity to unit price fluctuations. Unit price risk is the risk that the fair value of investments in property fund units and

international equities held in unit trusts will decrease as a result of changes in the value of these units.

The following tables demonstrate the impact of a 10% movement in the value of property funds and other unit trusts on the profit after tax and equity.

The potential impact is assumed as at the reporting date.

2018

IMPACT ON:

2017

IMPACT ON:

PROFIT

AFTER TAX

$000

EQUITY

$000

PROFIT

AFTER TAX

$000

EQUITY

$000

Change in variables

+ 10% property funds and other unit trusts2 2 2 2

- 10% property funds and other unit trusts(2)(2)(2)(2)

The risks assumed and methods used for deriving sensitivity information and significant variables have been applied consistently over the two reporting

periods included in the analysis.

| Part G – Other Disclosures

This section includes additional disclosures which are required by financial reporting standards.

| G1 Auditors’ Remuneration

2018

$000

2017

$000

Fees paid to Group’s auditors:

Audit of financial statements

(1)

554 495

Other assurance related services

(2)

30 30

Non-assurance advisory related services

(3)

5 6

Total fees paid to Group’s auditors589 531

Fees paid to subsidiaries’ auditors different to Group auditors:

Audit of financial statements

(1)

14 45

Total fees paid to auditors603 576

(1) Audit of financial statements includes fees for both the audit of annual financial statements and the review of interim financial statements. In 2018

the Group’s auditors were further engaged to perform the audit of National Pacific Insurance Limited (2017: BDO). The audit of Tower Insurance

(Vanuatu) Limited was performed by Law Partners (2017: Law Partners).

(2) Other assurance related services includes annual solvency return assurance and Pacific Island regulatory return audits.

(3) Non-assurance advisory related services related to Annual Shareholders’ Meeting procedures.

| G2 Transactions With Related Parties

The remuneration of key management personnel during the year was as follows:

2018

$000

2017

$000

Salaries and other short term employee benefits paid3,981 4,244

Independent director fees 515 509

4,496 4,753

Accounting policy

Key management personnel are those persons having authority and responsibility for planning, directing and controlling the activities of the entity,

directly or indirectly, including any director (whether executive or otherwise) of that entity.

Tower considers key management personnel to consist of the Board of Directors, Chief Executive Officer and executive leadership team. Information

regarding individual director and executive compensation is provided in the Corporate Governance section of the annual report.

F6 Risk Management (continued)

77
There have been no loans made to directors of the Company and other key management personnel of the Group, including their personally related

parties (2017: nil).

Key management hold various policies and accounts with Tower Group companies. These are operated in the normal course of business on normal

customer terms.

| G3 Contingent Liabilities

The Group is occasionally subject to claims and disputes as a commercial outcome of conducting insurance business. Provisions are recorded for these

claims or disputes when it is probable that an outflow of resources will be required to settle any obligations. Best estimates are included within claims

reserves for any litigation that has arisen in the usual course of business.

The Group has no other contingent liabilities.

| G4 Subsequent Events

There were no subsequent events after balance date.

| G5 Change in Comparatives

Comparative information has been reclassified to achieve consistency with the current year presentation. Changes relate to income statement

reclassification, balance sheet reclassification and presentation of notes. There is no change to net assets or the 2017 profit.

Income Statement – Gross up of premium revenue and outwards reinsurance expense

Premium revenue and outwards reinsurance expense in the Income Statement have been changed to recognise unearned reinsurance expense as

opposed to being netted off against premium revenue. The 2017 amount for premium revenue has decreased from $306.8 million to $306.1 million

and outwards reinsurance expense has decreased from $49.8 million to $49.2 million. There is no change to net premium revenue.

Changes for internal consistency have also been made to Note B1 Premium revenue.

Income Statement _ Gross up of claims expense and reinsurance recoveries revenue

Claims expense and reinsurance and other recoveries revenue in the Income Statement have been changed to recognise non-reinsurance recoveries

revenue as opposed to being netted off against the claims expense. The 2017 amount for claims expense has increased from $217.5 million to

$225.4 million and reinsurance and other recoveries revenue has increased from $30.0 million to $37.8 million. There is no change to net claims expense.

Balance Sheet – Gross up of reinsurance receivables and reinsurance payables

In 2017 amounts payable to reinsurers on receipt of the amount receivable from EQC for recoveries related to the Canterbury earthquakes were netted

off reinsurance receivables. On the Balance sheet, 2017 receivables increased $17.7 million and 2017 payables increased $17.7 million. Total assets and

total liabilities have increased accordingly. There is no change to net assets.

Changes for internal consistency have also been made to Note A4 Segment reporting, B4 Other insurance business disclosures, C5 Financial

instruments, E1 Receivables, E5 Payables, and F6 Risk management.

Balance Sheet – Gross up of other trade receivables and unearned premium liabilities

In 2017 a portion of unearned reinsurance assets were netted off against unearned premium liabilities. On the Balance sheet, 2017 receivables increased

$7.5 million and 2017 insurance liabilities increased $7.5 million. Total assets and total liabilities have increased accordingly. There is no change to net assets.

Changes for internal consistency have also been made to Note A4 Segment reporting, B4 Insurance liabilities, C5 Financial instruments, E1 Receivables,

and F6 Risk management.

Balance Sheet – Reclassification between cash and cash equivalents and investments

Within the balance sheet $19.0 million of term deposits with maturity dates greater than 3 months but less than 12 months has been reclassified from

cash and cash equivalents to investments.

Changes for internal consistency have also been made to the cash flow statement, Note C2 Cash and cash equivalents, Note C3 Investments, Note C5

Financial Instruments, and F6 Risk management.

Note Disclosure – Reclassification of management expenses

Within Note D1 management and sales expenses, there has been a reclassification between employee benefits expense and claims related to

management expenses reclassified to claims expense. In 2017, internal assessor personnel costs had been netted off against personnel costs.

To achieve consistent presentation with 2018, the employee benefits expense has increased by $3.0 million to $56.6 million and the claims related

management expenses reclassified to claims expense has decreased by $3.0 million to $29.0 million.

Tower Limited
Notes to the Financial Statements

For the year ended 30 September 2018

Tower Limited annual report 201878

Tower Limited

Notes to the Financial Statements

For the year ended 30 September 2018

Note Disclosure – Change in presentation of deferred acquisition costs

Within Note D4 deferred acquisition costs the movements (“acquisition costs during the year” and “current period amortisation”) have been changed

to reflect the gross movement during the year. The 2017 balance for acquisition costs during the year has increased from $21.0 million to $38.4 million.

The 2017 balance for current period amortisation has decreased from $20.0 million to $37.4 million. The overall movement has not changed.

Note Disclosure – Change in presentation of claims handling expense and central estimate of expected present value of future payments

for claims incurred

Within Note B5 other insurance business disclosures the claims handling expenses for the Canterbury earthquake have been reclassified from

IBNR into the general provision for claims handling expense. The 2017 balance for claims handling costs has therefore increased from $3.9 million

to $9.7 million, offset by a movement in the 2017 balance for central estimate of expected present value of future payments for claims incurred.

| G6 Impact of Amendments to NZ IFRS

G6.1 Standards, amendments and interpretations to existing standards that are not yet effective and have not been early adopted by

the Group

The following standards, amendments and interpretations to existing standards have been published and are mandatory for the Group’s accounting

periods beginning after 1 October 2018 or later periods, and the Group has not adopted them early. The Group expects to adopt the following new

standards on 1 October after the effective date.

—NZ IFRS 9 Financial instruments is effective for periods beginning on or after 1 January 2018. Tower will apply the standard for the year ending

30 September 2019. The standard replaces the existing accounting standards that relate to the classification and measurement of financial instruments.

Tower’s investments are currently designated as at fair value through profit or loss on initial recognition and are subsequently re-measured to fair

value at each reporting date, and Tower does not designate any financial instruments in hedging relationships. Consequently, NZ IFRS 9 is not

expected to have a material impact on Tower’s financial statements.

—NZ IFRS 15 Revenue from Contracts with Customers is effective for periods beginning on or after 1 January 2018. Tower will apply the standard

for the year ending 30 September 2019. The standard will provide a single source of requirements for accounting for all contracts with customers

and will replace all current accounting pronouncements on revenue. New revenue disclosures are also introduced. NZ IFRS 15 does not apply to

insurance contracts and financial instruments and consequently, as the majority of Tower’s revenue comes from such items, is not expected to have

a material impact on Tower’s financial statements.

—NZ IFRS 16 Leases is effective for periods beginning on or after 1 January 2019. Tower will apply the standard for the year ending 30 September

2020. The standard replaces the current guidance in NZ IAS 17 Leases. Under NZ IAS 17, a lessee was required to make a distinction between a

finance lease, which is recognised on balance sheet, and an operating lease, which is not recognised on the balance sheet. NZ IFRS 16 now requires

a lessee to recognise a lease liability reflecting future lease payments and a right-of-use asset for most lease contracts. Following adoption of

NZ IFRS 17, the treatment of leases for Tower’s office buildings, motor vehicles, and other equipment will change. The expected impact of the

changes on Tower’s financial statements is an increase to assets of approximately $11.0 m, an increase to liabilities of approximately $9.1 m and a

decrease to retained earnings of approximately $1.9 m. There will also be some impact on the pattern of expense recognition for leases, which is

not expected to be material. This is based on lease commitments and discount rates at 30 September 2018.

—NZ IFRS 17 Insurance Contracts is effective for periods beginning on or after 1 January 2021. Tower will apply the standard for the year ending

30 September 2022. The standard replaces the current guidance in NZ IFRS 4, and establishes the principles for recognition, measurement,

presentation and disclosure of insurance contracts. Tower has commenced work to assess the impact of adopting NZ IFRS 17. Due to the complexity

of the requirements within the standard the final impact may not be determined until global interpretations and regulatory responses to the new

standard are developed.

G5 Change in Comparatives (continued)

79
Corporate Governance

at Tower Limited (Tower)

Tower Limited annual report 201880
This section of the Annual Report provides

an overview of the corporate governance

principles, policies and processes

adopted and followed by Tower’s Board.

The Board is committed to achieving the highest standards of

corporate governance, ethical behaviour, and accountability,

and has implemented corporate governance practices that

are consistent with best practice. Where developments arise

in corporate governance, the Board reviews Tower’s practices

and incorporates changes where appropriate.

Governance Framework

Tower Limited is a company incorporated in New Zealand

under the Companies Act 1993 (NZ) (‘Companies Act’), whose

fully paid ordinary shares (‘Shares’) are listed on the NZX Main

Board and Australian stock exchange (‘NZX’ and ‘ASX’). As an

ASX Foreign Exempt Listing, Tower is primarily regulated by

the listing rules of its home exchange (being the NZX Main

Board (NZX)) and is exempt from complying with most of

ASX’s Listing Rules.

Compliance

In addition to compliance with the NZX listing rules, Tower’s

corporate governance framework also requires compliance

with the NZX Corporate Governance Code (NZX Code) and

the Financial Markets Authority's ‘Corporate Governance in

New Zealand: Principles and Guidelines’ handbook (FMA

Handbook).

Tower Insurance Limited, a subsidiary of Tower Limited, is

licensed to undertake general insurance business in New

Zealand under the Insurance (Prudential Supervision) Act

2010 (IPSA). Tower Insurance Limited must comply with the

requirements of IPSA, and is regulated by the Reserve Bank

of New Zealand.

For the reporting period to 30 September 2018, the Board

considers that Tower’s corporate governance practices have

materially adhered to the NZX Code and the FMA Handbook,

other than as outlined in this corporate governance section.

In May 2017, NZX published a new Corporate Governance

Code (new Code), which replaced the existing NZX Code

from 31 December 2017.

Tower fully supports the new Code and is undertaking a

review of its governance practices to ensure alignment with

the new Code. From 2017, Tower amended the structure of

its Corporate Governance section to better align with the new

Code, and the content of reporting will comply with the new

Code upon release of the FY19 annual report.

This statement is current as at 14 November 2018 and has

been approved by Tower’s Board.

More information

Tower’s principal governance policies and practices can

be found on Tower’s website at https://www.tower.co.nz/

investor-centre/corporate-governance.

| Ethical behaviour

Code of Ethics

Tower is committed to acting responsibly and ethically, and

meeting its legal and other obligations to shareholders,

customers, employees and the wider community. Maintaining

Tower’s reputation for honesty and fairness is crucial to its

success as a financial services business. To help achieve these

goals, Tower has a Code of Ethics which sets out minimum

standards of ethical behaviour. The Code of Ethics applies to

Tower’s directors, executives, employees and contractors.

The Code of Ethics is available to Tower’s people on its staff

intranet and website, and training is provided on the Code

through the orientation process. The behavioural expectations

set out in the Code of Ethics include:

• Acting honestly, with personal integrity, and in the best

interests of Tower, its shareholders and stakeholders

• Avoiding situations in which personal interests interfere or

appear to interfere with the interests of Tower, and advising

of any such conflicts

• Proper receipt and use of Tower’s corporate information,

assets and property

• Taking appropriate action when giving and receiving gifts

• Adhering to whistleblowing procedures

The Code of Ethics requires any person who becomes aware

of a breach or suspected breach of the Code to report it

immediately to the Head of Risk and Controls or the People

and Culture Team. Failure to comply with the Code of Ethics

may lead to disciplinary action and, in serious cases, dismissal.

All persons who disclose a breach will be protected in

accordance with Tower’s Whistleblower Policy.

Insider Trading and Market Manipulation Policy

Tower has an Insider Trading and Market Manipulation Policy

which governs dealing in financial products. The policy applies

to directors, employees, consultants and contractors and

helps provide transparency around Tower’s requirements in

relation to financial dealing, in particular protecting Tower’s

people from the risk of breaching Insider Trading laws. The

policy prohibits these people from trading and dealing in

81
Tower shares while they are in possession of information that

has not been released to the public and that is likely to have a

material effect on the price of Tower securities. The policy also

requires directors and designated employees to obtain prior

consent to trade, and specifies blackout periods where all

trading is prohibited.

The policy is available on Tower’s staff intranet and website,

and is circulated to all staff at the beginning of each blackout

period.

| Board composition and performance

Board charter

Tower’s Board operates in accordance with a written charter

which sets out the roles and responsibilities of the Board.

It provides that the primary role of the Board is to effectively

represent and promote the interests of shareholders with

a view to enhancing growth and returns across Tower and

its subsidiaries, adding long-term value to Tower shares.

The Board, when fulfilling its roles and responsibilities, is

required to have appropriate regard to Tower’s values, the

concerns of its shareholders, policy holders, its relationships

with significant stakeholders and the communities and

environment in which it operates.

The Board reserves certain functions to itself. These include:

• approving and overseeing the implementation of the

company's strategic objectives, annual operating plans,

financial targets and capital expenditure plans

• ongoing assessment and monitoring of performance,

including management’s performance against the strategic

objectives, operating plans and financial targets

• approving all changes to the company's corporate

structure, including tax and financial, where these are of

strategic importance

• determining company financial and treasury strategies

and policies, including approving all dividend policies

and distributions to shareholders, lending and borrowing,

charging of assets, tax, and investment and foreign

exchange policies in respect of shareholders’ funds

• approving capital expenditure, operating expenditure,

asset acquisitions and divestments, and settlement of legal

proceedings, in all cases where this is outside the normal

course of business and/or above delegated limits

• approving all transactions relating to major business and

company acquisitions, mergers and divestments

The Charter provides that the day-to-day leadership and

management of the company is undertaken by the Chief

Executive Officer and senior management. The Chief

Executive Officer is solely accountable to the Board for

management performance. The Chief Executive Officer

has also formally delegated decision making to senior

management within their areas of responsibility and subject to

quantitative limits to ensure consistent and efficient decision

making across the company. Senior management has no

power to do anything which the Chief Executive Officer cannot

do pursuant to his delegations. Within this formal delegation

framework those executives who report directly to the Chief

Executive Officer have authority to sub-delegate certain

authorities to their direct reports.

The Board meets regularly with management to provide

strategic guidance for Tower and effective oversight of

management.

Nomination and Appointment of

Directors to the Board

Tower’s procedure for the nomination and appointment of

directors to the Board is set out in Tower’s Remuneration

and Appointments Committee Terms of Reference. The

Remuneration and Appointments Committee will identify and

recommend to the Board suitable candidates for appointment

as directors. The Committee will consider, among other

matters, a candidate’s:

• experience as a director

• skills, expertise and competencies (the Board aims to have

a mix of skilled directors with particular competencies in the

insurance and financial services sector)

• the extent to which those skills complement the skills of

existing directors

• the candidate’s ability to devote sufficient time to the

directorship, and

• the candidate’s reputation and integrity.

To ensure that the Board appoints directors and officers

who have appropriate skills, knowledge, experience and

integrity to perform their duties and to fulfil their roles, Tower

has developed a Fit and Proper Policy benchmarked to the

requirements of the Insurance (Prudential Supervision) Act

2010 and the Fit and Proper Standard for Licensed Insurers,

along with the Fit and Proper Policy Guidelines for Licensed

Insurers issued by the Reserve Bank of New Zealand. All

newly appointed directors and relevant officers are subject

to Fit and Proper assessments prior to appointment. The Fit

and Proper assessment considers a candidate’s character,

experience, education, criminal record, and credit history.

Tower Limited annual report 201882
In the case of a candidate standing for election as a

director for the first time, Tower will provide information to

shareholders about the candidate to enable them to make an

informed decision on whether or not to elect the candidate,

including:

• Material adverse information revealed by any Fit and Proper

checks

• Details of any interest, position, association or relationship

that might influence, or reasonably be perceived to

influence in a material respect the candidate’s capacity to

exercise judgement on board matters or to act in the best

interests of Tower and its shareholders

• The Board’s view on whether the candidate will be

considered to be an independent director; and

• A recommendation by the Board in respect of the

candidate’s election.

Written agreements with directors

All Tower directors have entered into written agreements

establishing the terms of their appointment. These written

agreements include information relating to:

• Tower’s expectations of the director in his or her role

• The director’s expected time commitment to Tower

(including other duties)

• Remuneration entitlements (including any superannuation

included); and

• Indemnity and insurance arrangements.

Director profiles and independence

Profiles of Tower’s directors are available at pages 24 and 25

of this report. Directors’ independence is assessed in

accordance with the requirements for independence set out

in Tower’s Board and Director Protocols. Those independence

requirements are benchmarked against the Reserve Bank of

New Zealand and NZX independence requirements.

At 30 September 2018, the Board comprised of five non-

executive directors, all of whom are independent. Tower’s

constitution currently requires a minimum of five directors

and provides for a maximum of eight.

Diversity policy

Tower has a written diversity policy which embodies Tower’s

commitment to pursuing an inclusive and flexible workplace.

The Board is responsible for overseeing the implementation of

Tower’s Diversity Policy. The Remuneration and Appointments

Committee are delegated responsibility to annually review

and report on policy effectiveness and diversity within Tower.

Tower’s business operations are spread across 11 sites in

9 different countries and Tower recognises the value of

its diverse employee population as an essential driver of

performance culture, brand and shareholder returns. An

inclusive environment improves the quality of decision

making, incentivises productivity, and creates innovation

through collaboration. Tower’s Board is committed to further

developing an inclusive culture that encourages Tower’s

people to perform to their highest potential.

During FY18, Tower celebrated the diversity of its people

through a number of initiatives, including International

Women’s Day, Pride March, Women in Leadership Lean In

Circles, Diwali, Harmony Day, Matariki, Eid Mubarak, Te Wiki O

Te Reo Maori and Tongan Language Week.

Tower is also committed to attracting and retaining quality,

passionate people who are dedicated to helping transform

Tower’s business. Throughout FY18, Tower’s Executive

Leadership Team, Senior Leadership Team and People

Leaders continued participation in a leadership development

programme focussed on developing key leadership skills and

enhancing engagement.

While the Board considers that Tower has addressed the

requirements of its Diversity Policy, the Policy does not

currently require the Board to set measurable objectives for

achieving diversity. Tower’s diversity programme remains

under review and will be finalised in FY19.

83
The table below shows gender representation across Tower

as at 30 September 2018.

2017-20182016-2017

GROUP% BY

GROUP

NUMBER% BY

GROUP

NUMBER

Board of Directors

Male80%4100%5

Female20%10%0

Executive leadership team

1


Male75%663%5

Female25%237%3

Senior leadership team

2


Male58%2166%21

Female42%1534%11

Employees

Male 41%24142%256

Female59%34958%352

Total company

3

Male42%26844%283

Female58%36656%304

1 ‘Executive Leadership Team’ includes the Chief Executive Officer, and

those employees who report directly to the Chief Executive Officer.

2 ‘Senior Leadership Team’ is the second level of employees below the

Chief Executive Officer, who report directly to the Executive Leadership

Team.

3. ‘Total Company’ figures do not include the Board of Directors.

Both the 2016-2017 and 2017-2018 figures include Tower’s

Pacific Island subsidiaries.

Director training

Directors are expected to develop their skills, competencies

and industry knowledge by taking responsibility for their

continuing education. To ensure ongoing education, directors

are regularly informed of developments that affect Tower’s

industry and business environment, as well as company and

legal issues that impact the directors themselves. Directors

receive comprehensive board papers and briefing information

before Board meetings, including reports from the Chief

Executive Officer and senior management.

Directors have unrestricted access to management and any

additional information they consider necessary for informed

decision making. Senior management also attend Board

meetings in order to provide presentations to the Board and

answer any queries directors may have.

Director, Board and Committee performance

The Board recognises that the performance of its directors

and Board Committees is crucial to Tower’s success and to

the interests of its shareholders. The Board regularly reviews

its own composition and performance and that of the Board

Committees in accordance with the terms of the Board Charter.

Independence of Chair and CEO

Tower’s Chair is responsible for leading the board, facilitating

the effective contribution of all directors and promoting

constructive and respectful relations between the board

and management. The Chair of the Board is elected by the

directors.

The Board supports the separation of the roles of Chair and

Chief Executive Officer, and these roles are separate at Tower.

Michael Stiassny was appointed Chair of Tower on 21 March

2013 and is independent.

| Board committees

The Board currently has two standing committees: the Audit

and Risk Committee and the Remuneration and Appointments

Committee. Other committees are established from time to

time to examine specific issues as required by the Board.

The Committees are governed by written terms of reference,

which detail their specific functions and responsibilities.

The terms of reference for each Committee are reviewed

periodically.

The Committees make recommendations to the Board.

They have no decision making ability except where expressly

provided by the Board. The Board is required to annually

confirm the membership and Chair of each of the Committees.

The experience and skills of individual Committee members

are set out in the directors’ profiles on pages 24 and 25.

Member attendance at each Committee meeting is set

out on page 85.

Tower Limited annual report 201884
Audit and Risk Committee

Members: Graham Stuart (Chair), Michael Stiassny, Steve

Smith, Warren Lee and Wendy Thorpe.

The written Terms of Reference of the Audit and Risk

Committee include the following duties and responsibilities:

• Ensure processes are in place so that the Board is regularly

informed about significant financial matters relating to Tower

• Review Tower’s draft half yearly and annual financial

statements and reports

• Obtain reports from management, external audit, legal

counsel or internal audit on any regulatory, accounting or

financial reporting issues of significance.

• Review adequacy of accounting policies and actuarial

methodologies

• Recommend the appointment and removal of, and oversee

the performance of, the external auditor and be satisfied as

to the auditor’s independence

• Review the effectiveness and efficiency of management

processes, risk management and internal financial controls

and control systems

• Monitor and review compliance with regulatory and

statutory requirements and obligations

• Monitor the internal audit function and receive regular

reports from the internal auditors on risks, exposures and

compliance; and

• Maintain unrestricted and direct lines of communication

with the external and internal auditors

The Committee meets with the external auditors at least

twice per year and has regular contact with the internal

audit function.

The Terms of Reference require that the Committee has a

minimum of three non-executive directors, the majority of

whom are independent. At least one must have a financial or

accounting background. The Board appoints the Chair of the

Committee, who cannot also be Chair of the Board, and who

is an independent director.

The Chair is also required to provide an annual report

summarising the Committee’s activities, findings,

recommendations and results for the past year.

Employee attendance at Committee meetings

Tower’s employees may attend Audit and Risk Committee

meetings only at the invitation of Chair of the Committee.

Remuneration and Appointments Committee

Members: Michael Stiassny (Chair), Steve Smith, Graham

Stuart, Warren Lee and Wendy Thorpe.

The Remuneration and Appointments Committee advises the

Board in respect of a number of matters, including:

• performance management and appraisals for individual

Directors’ performance and any training requirements

• performance evaluations of the Board Committees and the

Board as a whole

• review of Directorships in terms of ongoing compliance with

relevant NZX Listing Rule and NZX Corporate Governance

Code requirements

• the Board’s composition, structure and succession

planning; and

• the Chief Executive Officer and senior executive

appointments, termination, performance appraisal

and remuneration.

The written Terms of Reference for the Remuneration and

Appointments Committee require that the Committee

comprises suitably qualified non-executive directors, the

majority of whom are independent. The Board appoints the

Chair of the Committee, who will be an independent, non-

executive director.

Following each meeting the Chair of the Committee provides

a report to the Board. The Chair is also required to provide

an annual report summarising Committee activities, findings,

recommendations and results for the past year.

Management may attend Remuneration and Appointments

Committee meetings only at the invitation of Chair of the

Committee.

The Company’s remuneration policies for directors and senior

executives are set out on page 86 and 87.

Nominations Committee

Tower’s Remuneration and Appointments Committee

carries out the functions of a nominations committee.

The Committee’s authority, duties, responsibilities and

relationship with the Board are set out in the Remuneration

and Appointments Committee’s Terms of Reference.

Tower’s Board considers that due to its size and the nature

of Tower’s business, it is appropriate for its remuneration

and nomination committees to be combined.

85
Other Committees

Tower’s Board has the ability to establish additional

subcommittees from time to time. During FY17, the Board

established a Due Diligence Committee to consider the

merits of undertaking a Capital Raise and to ensure the

Capital Raise adhered to appropriate laws and regulations.

Acquisition proposals

Tower was not subject to any acquisition proposals in FY18.

Board and Committee meeting attendance

The following numbers of Board and Committee meetings

were held during the year from 1 October 2017 to

30 September 2018:

• Board meetings – 15

• Audit and Risk Committee meetings – 6

• Remuneration and Appointments Committee – 3

• Capital Raise Due Diligence Committee – 3

The Chief Executive Officer and Chief Financial Officer attend

all Board and Committee meetings. The Chief Executive

Officer, Chief Financial Officer and Chief Risk Officer attend

all Audit and Risk Committee meetings. All meetings are

attended by an appropriately qualified person who is

responsible for taking accurate minutes of each meeting and

ensuring that Board procedures are observed.

Director attendance at these meetings is set out below.

2017/2018 Tower Limited directors’

attendance record

TO

WER LIMITED BOARD

AUDIT AND RISK

COMMITTEE

REMUNERATION

AND APPOINTMENTS

COMMITTEE

CAPTIAL RAISE DUE

DILIGENCE COMMITTEE

Meetings held (to 30 September 2018)15633

Michael Stiassny15633

Steve Smith14533*

Graham Stuart14423

Warren Lee13633

David Hancock**2111*

Wendy Thorpe***932N /A

*Attended as an observer.

** David Hancock resigned as director from 1 March 2018,

having signalled his intention to retire on 31 August 2017,

and was not eligible to attend meetings after the 1 March

2018 date.

***Wendy Thorpe was appointed on 1 March 2018.

She attended one meeting of the Audit and Risk Committee

meeting and one meeting of the Remuneration and

Appointments Committee as a guest, pending Board

approval of her membership to the respective committees.

| Reporting and disclosure

Continuous disclosure policy

Tower recognises that public confidence in the integrity of

Tower is based on continuous, full and open disclosure of

information about its activities to the market and relevant

stakeholders. Tower’s Corporate Disclosure Policy provides

for a planned, proactive communication programme with

shareholders and the wider investment community to

encourage their participation and interaction with Tower.

Tower believes this communication programme assists in

creating a fully informed market and enhances shareholder

value. The Policy explains the respective roles of directors,

officers and employees in relation to:

• Complying with Tower’s continuous disclosure obligations

• Safeguarding the confidentiality of corporate information to

avoid premature disclosure

• External communications, including analyst briefings

• Responding to or avoiding the emergence of a false market

The policy provides that only authorised spokespersons

can communicate on behalf of Tower with the investment

community, shareholders and the media.

Announcements

Tower makes the following regular announcements to the

market and shareholders:

• Annual results are announced in November

• Annual reports are released in December

• Tower’s Notice of Annual Shareholders' Meeting is generally

sent to shareholders in December or January

• Tower's Annual Shareholders' Meeting is generally held in

February or March

• Half year results are announced in May

• Half year reports are released in June.

Tower Limited annual report 201886
Key governance documents

Tower’s website provides information to shareholders and

investors about Tower. The website includes copies of past

annual reports, results announcements, media releases

(including NZX and ASX announcements) and general

Tower information.

The following key governance documents are also available

on Tower’s Investor Centre website, https://www.tower.co.nz/

investor-centre/corporate-governance/policies.

• Tower Limited constitution

• Board Charter

• Board Protocols

• Audit and Risk Committee Terms of Reference

• Remuneration and Appointments Committee Terms

of Reference

• Insider Trading and Market Manipulation Policy

• Corporate Disclosure Policy

• External Audit Independence Policy

• Director and Executive Remuneration Policy

• Code of Ethics

• Diversity Policy

• Health and Safety Policy

Financial reporting

The Financial information contained in this annual report has

been audited by Tower’s external auditors, PwC, and complies

with relevant financial reporting requirements under the

Companies Act 1993, Financial Markets Conduct Act 2013,

and the NZX Listing Rules.

Tower has a structure to independently verify and

safeguard the integrity of its financial reporting. The principal

components of this are the Audit and Risk Committee, the

external and internal auditors, and the certifications provided

to the Board by senior management. These certifications

include a representation letter from the CEO and CFO

provided to the Board prior to the Board’s approval of Tower’s

financial statements, which states that, to the best of the CEO

and CFO’s knowledge and belief, Tower’s financial records

have been properly maintained, that Tower’s accounting

policies and financial statements comply with the appropriate

accounting standards, and that the financial statements fairly

represent the financial position of Tower as at the balance

date. This letter is provided on the basis that Tower has

maintained an internal control structure which is sufficient to

produce reliable accounting records.

Non-financial reporting

Tower recognises the importance of environmental, social and

governance (ESG) practices for the long-term sustainability of

its business. While Tower has not chosen to report against a

formal ESG reporting framework, a number of initiatives have

been undertaken in FY18 to promote sustainable processes

and minimise waste.

Tower is passionate about setting things right for our

customers and their communities. All of Tower’s people have

the ability to take one volunteer day per year to give back to

the community. Tower teams have volunteered their time and

resources to clearing scrub and planting trees in Auckland,

holding a family day at a home for orphaned children in Fiji,

and donating water tanks for fresh, clean water to schools in

the Solomon Islands.

Tower intends to develop an ESG framework in FY19, and

continues to work on improving recording and reporting of

sustainability measures.

| Remuneration

Director remuneration

The Board’s approach is to remunerate directors at a similar

level to comparable Australasian companies, with a small

premium to reflect the complexity of the insurance and

financial services sector. At the Annual Shareholders’ Meeting

in February 2004 shareholders approved an increase in

non-executive director annual remuneration to the current

maximum of NZ$900,000 per annum.

Tower seeks external advice when reviewing Board

remuneration. The Remuneration and Appointments

Committee is responsible for reviewing directors’ fees.

Non-executive directors are also paid additional annual

fees for sitting on certain Board Committees.

BOARD/COMMITTEECHAIRMEMBER

Base fee – Board of directors$130,000$78,570

Audit and Risk Committee$15,000$9,000

Remuneration and Appointments Committee

1

--

1 The Board determined that from 1 December 2012 no fees would be

payable for sitting on the Remuneration and Appointments Committee

Additional fees may be paid to non-executive directors for

one-off tasks and/or additional appointments where required.

87
2017/2018 directors’ remuneration and

benefits of Tower and its subsidiaries

Amounts in the table below reflect fees paid and accrued

for the year ended 30 September 2018.

Fees include base fees and additional fees in the financial

year for one-off tasks and additional appointments.

DIRECTORS’ REMUNERATION AND BENEFITS OF TOWER LIMITED

FOR THE YEAR TO 30 SEPTEMBER 2018FEES (NZ$)

Michael Stiassny139,000

Graham Stuart93,570

Steve Smith87,570

Warren Lee87,570

Wendy Thorpe51,083

David Hancock36,488

DIRECTORS’ REMUNERATION AND BENEFITS OF TOWER LIMITED SUBSIDIARIES

FOR THE YEAR TO 30 SEPTEMBER 2018FEES

Alden Godinet

1

$7,250

Rodney Reid

1

$7,250

Isikeli Tikoduadua

2

$18,000

1. Fees earned in capacity as director of National Pacific Insurance

Limited. NPI fees are paid in Western Samoan Tala.

2. Fees earned in capacity as director of Tower Insurance (Fiji) Limited.

Tower Insurance (Fiji) Limited fees are paid in Fijian Dollars.

Remuneration policy

Tower aims to attract and retain talented and motivated

directors and employees by offering remuneration that is

competitive, equitable and related to the achievement of

individual, team and business unit objectives. Tower rewards

high performing staff for providing superior performance.

Tower’s Remuneration Policy will be updated in FY19,

in accordance with the new Code and as appropriate

for Tower’s business.

CEO and senior executive remuneration

The Board’s approach to remunerating the Chief Executive

Officer and other key executives is to provide market

based remuneration packages comprising a blend of

fixed and incentive based remuneration with clear links

between individual and company performance, and reward.

Remuneration packages currently comprise a mixture of fixed

and performance-based remuneration in the form of short and

long term incentives. The Remuneration and Appointments

Committee reviews the remuneration packages of the Chief

Executive Officer and other senior executives at least annually.

This approach is intended to encourage Tower’s executives

to meet Tower’s short and long term objectives.

Employee remuneration

Set out in the following table are the number of employees

or former employees of Tower, not being directors or former

directors, who received remuneration and other benefits

valued at or exceeding $100,000 for the year ended 30

September 2018. Remuneration includes redundancy

payments and termination payments made during the year

to employees whose remuneration would not otherwise

have been included in the table. The remuneration bands

are expressed in New Zealand Dollars.

FROMTO2017-20182016-2017

100,000109,9992113

110,000119,9991119

120,000129,9991513

130,000139,999910

140,000149,99999

150,000159,99996

160,000169,99906

170,000179,99943

180,000189,99914

190,000199,99931

200,000209,99923

210,000219,99932

220,000229,99952

230,000239,99951

240,000249,99912

250,000259,99905

260,000269,99901

270,000279,99922

290,000299,99910

300,000309,99921

310,000319,99912

320,000329,99912

350,000359,99911

360,000369,99901

370,000379,99910

380,000389,99911

440,000449,99901

450,000459,99910

460,000469,99910

490,000499,99910

530,000539,99910

540,000549,99910

770,000779,99910

780000+01

Total 114112

The table includes base salaries, short-term incentives (if

applicable) and vested or exercised long-term incentives.

If the individual is a KiwiSaver member the table does not

include contributions of 3% of gross earnings towards that

individual’s KiwiSaver scheme.

Tower Limited annual report 201888
| Risk management

Risk Management Framework

Tower has established a framework to identify, assess, monitor

and manage exposure to risk. The Framework applies to

Tower and all of its subsidiaries and related companies, and

all staff and contractors employed by Tower and any of its

subsidiaries. At the forefront of this are the internal audit and

compliance processes, and the risk management process for

each operating company. Tower faces a range of risks that are

inherent to the business activities undertaken. Executive and

senior management and staff must be able to demonstrate

that reasonable steps have been taken to effectively manage

Tower’s risks.

Tower maintains a risk register which records the likelihood

and impact of relevant risks on Tower’s business. Tower’s

Risk and Compliance team actively monitors the risk register,

identifies key risks and notes steps taken to mitigate the risks.

A Risk and Compliance report is provided to each Audit and

Risk Committee meeting so that the Committee is aware of

relevant risks and how they are being managed.

The Audit and Risk Committee regularly reviews its risk

management procedures and framework to ensure that it

complies with its legal obligations. Tower’s Board has adopted

a Risk Appetite Statement, which articulates the amount and

type of risk that Tower is willing to take in order to meet its

strategic objectives and provides direction to management

on how to manage risks.

The Audit and Risk Committee is responsible for reviewing

whether Tower has any material exposure to any economic,

environmental and social sustainability risks, and if so,

to develop strategies to manage such risks, and present

such strategies to the Board. For the reporting period to

30 September 2018, no material exposure to these risks

was identified.

Health and Safety risks

Health, safety and wellbeing of Tower’s people is a key Board

priority. Tower employs a Health and Safety consultant to

assist with the implementation and socialisation of policies

and processes relating to health and safety. In addition, Tower

has designated health and safety representatives at each of its

sites in New Zealand and the Pacific. All of Tower’s people are

required to complete a health and safety e-learning module

when they begin with Tower, and extensive information about

health, safety and wellbeing is available on Tower’s staff

intranet. Additional health and safety training is undertaken by

all Tower people in the field, including site assessors. Tower

has robust health and safety standards in place for contractors

and third party providers.

Tower employees, in New Zealand and across the Pacific,

have participated in a wide array of health, safety and

wellbeing activities that include operational health and safety

meetings, training, process reviews, wellness events, audits

and site visits. Tower’s Board receives regular Health

and Safety reports which are considered and discussed

at Board meetings.

| Auditors

External audit framework

The Tower Board is fully committed to ensuring the

quality and independence of the external audit process.

As part of this process Tower encourages full and frank

disclosure and discussions between the Board, Tower’s

internal auditors, management and the external auditor,

PricewaterhouseCoopers (PwC).

PwC was re-appointed as auditor by shareholders at the

Annual Shareholders' Meeting in March 2018 to audit the

financial statements for Tower and its subsidiaries.

A formal engagement letter with PwC sets out the respective

obligations and responsibilities of PwC and Tower in relation

to the preparation and audit of financial statements.

The Board also has a formal External Audit Independence

Policy that covers the provision of non-audit services by the

external auditor.

The Policy describes the Board’s approach to the approval of

Tower’s external audit firm; what services the external auditor

may and may not provide to Tower; auditor rotation; and

hiring of staff from the audit firm. The Board reviews external

auditor quality and effectiveness by reference to obligations

described in the Policy. Tenure and reappointment of the

external auditor is managed through compliance with relevant

legislation and NZX and FMA guidance.

The Board mitigates any threats to auditor independence

by prohibiting Tower’s external audit firm from providing any

non-audit services. Allowable services are limited to statutory

financial statement audit engagements and directly related

assurance engagements (including assurance opinions

on solvency returns; regulatory return audits; and opinions

required by legislation such as shareholder meeting votes

89
or proxy counts). Should a situation arise which may require

Tower’s external audit firm to provide services beyond these,

any such engagement must first be pre-approved by Tower’s

Audit and Risk Committee.

Under the Policy, PwC is required to provide the Audit and

Risk Committee with an annual certification of its continued

independence, and in particular confirm that it has not carried

out any engagements during the year which would impair

its professional independence. Non-audit services provided

by PwC to Tower and its subsidiaries during the financial

year did not, in Tower’s opinion, affect auditor objectivity and

independence.

The Policy is overseen by the Audit and Risk Committee.

The external auditor generally attends all Audit and Risk

Committee meetings.

Details of PwC fees for audit and other services provided to

Tower are set out in the Tower Limited financial statements.

Attendance at annual meeting

Tower's Annual Shareholders’ meeting is an opportunity for

shareholders to receive updates from the Chief Executive

Officer and Chair on Tower's performance, ask questions of the

Board and vote on the various resolutions affecting Tower's

business. Shareholders are also given an opportunity at the

Annual Shareholders’ Meetings to ask questions of Tower's

auditors regarding the conduct of the audit and preparation

and content of the auditor's report.

Internal audit functions

Tower has an Internal Audit Function. The structure of that

function, and the roles it performs, are set out in Tower’s

Internal Audit Policy.

The purpose of the internal audit function is to provide

independent and objective assurance of the adequacy and

effectiveness of the controls set up by management. It helps

the organisation accomplish its objectives by bringing a

systematic, disciplined approach to evaluate and improve the

effectiveness of risk management, control and governance

processes. The scope of work of the internal audit function

includes determining whether the organisation’s network

of risk management, compliance, control and governance

processes, as designed and represented by management, is

adequate. The internal audit function will complete reviews

identified and agreed in the annual Internal Audit Plan.

The internal audit function is managed within the Risk and

Controls function under the Chief Risk Officer and receives

strategic support from the Audit and Risk Committee. The

internal audit function has direct access to the Chief Executive

Officer and the Chair of the Committee whenever required.

Tower regularly evaluates the effectiveness of its risk

management framework, including the internal audit function,

to ensure that its internal control systems and processes are

monitored and updated on an on-going basis.

| Shareholder rights and relations

Investor Centre website

Tower’s website, www.tower.co.nz, provides information to

shareholders and investors about Tower. The website includes

copies of past annual reports, results announcements, media

releases (including NZX and ASX announcements) and

general Tower information.

Investor Communication

Tower encourages shareholders to receive communications

from, and send communications to, Tower and the share

registry electronically, for reasons of speed, convenience,

cost and environmental considerations. Tower shareholders

can receive company information electronically by registering

their email addresses online with Tower’s share registry

www.investorcentre.com/nz.

Tower shareholders can also contact Tower at

investor.relations@tower.co.nz

Shareholder voting

Tower confirms its compliance with Listing Rule

specifications in respect of obtaining shareholder approval.

Where appropriate, Tower will conduct voting by polls at

shareholder meetings.

Annual shareholder meeting

Tower is aware of the new Code requirements to provide

notice of annual shareholder meetings 28 days prior to the

meeting. Tower’s next shareholder meeting will be held in

February 2018 and a notice of meeting will be provided to

shareholders in due course.

Tower Limited annual report 201890
| Statutory disclosures

Some information in this section is provided as at

14 November 2018, being not less than 2 months

before the date of publication of this report.

Substantial product holders (as at 14 November 2018)

The names and holdings of Tower’s substantial product

holders based on notices filed with Tower under the Financial

Markets Conduct Act 2013 as at 14 November 2018 were:

NAMETOTAL ORDINARY SHARES

1

Bain Capital Credit LP67,464,858

Salt Funds Management Limited41,634,524

Accident Compensation Corporation28,785,340

1. Total ordinary shares held by the substantial product holder is the

number of shares disclosed in the latest Substantial Product Holder

notice filed with Tower, which may differ from the stated holdings below

Principal shareholders (as at 14 November 2018)

The names and holdings of the 20 largest registered Tower

shareholders as at 14 November 2018 were:

NAME TOTAL ORDINARY SHARES

%

Dent Issuer Designated Activity Company 67,464,80819.99

Accident Compensation Corporation 31,054,3139.2

HSBC Nominees (New Zealand) Limited 28,635,6128.48

Citibank Nominees (New Zealand) Limited 21,712,0846.43

National Nominees New Zealand Limited 16,073,9494.76

HSBC Nominees (New Zealand) Limited

A/C State Street

13,003,6063.85

BNP Paribas Nominees (Nz) Limited 12,733,5753.77

JBWere (NZ) Nominees Limited <NZ

Resident A/C>

11,843,5743.51

JP Morgan Chase Bank NZ Branch -

Segregated Clients Acct

10,537,0963.12

FNZ Custodians Limited 8,563,6082.53

Citicorp Nominees Pty Limited 4,318,1561.28

FNZ Custodians Limited <DTA Non

Resident A/C>

3,018,9820.89

Philip George Lennon 3,000,0000.88

National Nominees Limited 2,080,5740.61

One Managed Invt Funds Ltd <1 A/C>2,000,0000.59

UBS Nominees Pty Ltd 1,514,1430.44

JBWere (NZ) Nominees Limited <53329

A/C>

1,458,3760.43

Ronald James Woodrow 1,159,7270.34

Leveraged Equities Finance Limited 1,020,0000.3

UBS Nominees Pty Limited 1,008,1150.29

Directors’ shareholdings

At 30 September 2018, Tower Limited directors held the

following interests in Tower Limited shares:

ORDINARY SHARES

DIRECTORBENEFICIAL

Michael Stiassny395,464

Graham Stuart100,000

Steve Smith18,460

Wendy Thorpe5,000

Warren Lee36,400

Directors’ trading in Tower securities

No directors disclosed acquisitions or disposals of relevant

interests in Tower securities during the financial year pursuant

to section 148 of the Companies Act 1993.

DIRECTORDATE OF

DISCLOSURE

INTERESTNUMBER

ACQUIRED

(DISPOSED))

CONSIDERATION

1

Wendy Thorpe1 Mar 2018Beneficial5,000

Acquired pre-

directorship

Michael Stiassny14 Dec 2017Beneficial230,000$152,439.22

22 Dec 2017Beneficial82,732$34,747.44

Graham Stuart12 Dec 2017Beneficial87,692$54,629.58

14 Dec 2017Beneficial6,154$2,584.68

Steve Smith22 Dec 2017Beneficial9,230$3,876.60

Warren Lee8 Dec 2017Beneficial32,400$19,764 (AUD)

22 Dec 2017Beneficial2,000$780.00

1. Consideration is in New Zealand dollars, unless otherwise specified.

Shareholder analysis

Tower’s shares are quoted on both the NZSX and ASX. As at

14 November 2018, 16,115 Tower shareholders held less than

A$500 of Tower shares (i.e. less than a marketable parcel as

defined in the ASX Listing Rules), holding a total of 5,783,418

Tower shares.

Total voting securities

In December 2017, Tower raised additional capital through a

pro rata renounceable entitlement offer. As at 14 November

2018, Tower had 337,324,300 ordinary shares held by 26,066

holders. By comparison, on 14 November 2017, Tower had

168,662,150 ordinary shares held by 26,901 holders. Tower’s

ordinary shares each carry a right to vote on any resolution on

a poll at a meeting of shareholders. Holders of ordinary shares

may vote at a meeting in person, or by proxy, representative

or attorney.

The address and telephone number of each office at which a

register of Tower securities is kept is set out in the directory at

the back of this Annual Report.

91
Tower Limited Shareholder Statistics

(as at 14 November 2018)

HOLDING RANGEHOLDER

COUNT

HOLDER

COUNT %

HOLDING

QUANTITY

(ORDINARY

SHARES)

HOLDING

QUANTITY

%

1 to 1,0001852471.0778083542.31

1,001 to 5,000523520.08108673473.22

5,001 to 10,0009053.4765915311.95

10,001 to 100,00012494.793686196010.93

100,001 and over1530.5927519510881.58

Total26066100337324300100

Credit rating

Global rating organisation A.M. Best Company issued the

following ratings of companies:

Tower Insurance Limited

Financial Strength Rating A- (Excellent)

Issuer Credit Rating a-

Effective 9 March 2018

Tower Limited

Issuer Credit Rating bbb- (Good)

Effective 9 March 2018

Waivers

There were no applications to NZX or ASX for any waivers in

the financial year ending 30 September 2018.

Interests register

Tower and its subsidiaries are required to maintain an interests

register in which the particulars of certain transactions

and matters involving the directors must be recorded. The

interests register for Tower Limited is available for inspection

on request by shareholders. Tower’s constitution provides that

an ‘interested’ director may not vote on a matter in which he

or she is interested unless the director is required to sign a

certificate in relation to that vote pursuant to the Companies

Act 1993, or the matter relates to a grant of an indemnity

pursuant to section 162 of the Companies Act 1993.

General disclosures of interest

During the financial year, Tower’s directors disclosed interests,

or a cessation of interests (indicated by an asterisk (*)), in the

following entities pursuant to section 140 of the Companies

Act 1993. No disclosures were made by directors of any other

Tower subsidiary.

Any cessation of interest that occurred after 30 September

2018 is indicated by two asterisks (**). Any disclosure of new

interests that occurred after 30 September 2018 is indicated

by three asterisks (***).

Warren Lee

MyState Limited and subsidiary companiesDirector

Tasmanian Perpetual Trustees LimitedDirector

Go Hold Limited***Director

Go Blank Limited***Director

David Hancock

1

Afterpay Pty LimitedDirector

Finarch Pty LimitedDirector

Finclear Pty LimitedDirector

Freedom Insurance Pty LimitedChair

ELMO Talent Management Software Pty Limited

Director

Fix X Pty Limited

Chair

Steve Smith

Kinrich Trust

Trustee

Kinrich Holdings Limited

Director

Summerlee Investments Limited

Director

Unison Securities Limited

Director

Unison Capital Advisors Limited

Director

Pascaro Investments Limited

Chair

Trebol Investments Limited and subsidiary companies

Director

Rimu SA (Chile) and subsidiary companies

Director

The National Foundation for the Deaf Incorporated

Board Member

Good Soundz LimitedBoard Member

Michael Stiassny

Atapo Corporation LimitedDirector

Bengadol Corporation LimitedDirector

Frequency Media Group LimitedDirector

Emerald Group LimitedDirector

Gadol Corporation LimitedDirector

Geffen Holdings LimitedDirector

Glenogle Trust LimitedDirector

Knotser Properties LimitedDirector

Michael Spencer LimitedDirector

Ngati Whatua Orakei Housing Trustee LimitedDirector

Ngati Whatua Orakei Whai Rawa LimitedChair

Plan B LimitedDirector

Poukawa Estate LimitedDirector

Queenstown Airport Corporation LimitedDirector

Sasha Properties LimitedDirector

SB Entertainment Holdings and subsidiary companiesDirector

Ted Kingsway LimitedDirector

WEST24 LimitedDirector

Whai Rawa GP LimitedDirector

Whai Rawa Kainga Development LimitedDirector

LPF GroupDirector

New Zealand Transport AgencyChair

Tower Limited annual report 201892
Graham Stuart

Leroy Holdings LimitedDirector

EROAD LimitedChair

VinPro LimitedDirector

NorthWest Healthcare Properties

Management Limited***

Director

Wendy Thorpe

2


AMP Bank LimitedDirector

Online Education Services Pty Ltd Chair

Very Special KidsDirector

Epworth Foundation***Director

1. David Hancock resigned as director on 1 March 2018.

2. Wendy Thorpe was appointed as director on 1 March 2018.

Specific disclosures of interest

During the financial year, no subsidiary of Tower entered

into any transaction in which directors were interested.

Accordingly, no disclosures of interest were made.

Donations

During the financial year ended 30 September 2018, Tower

Limited and its subsidiaries did not make any donations

Tower subsidiary company director disclosures

The following persons held office as directors of subsidiary

companies at 30 September 2018. Those who were appointed

during the financial year are footnoted.

TOWER SUBSIDIARY COMPANY DIRECTOR DISCLOSURES

Tower Insurance Limited

Warren Lee, Steve Smith, Michael Stiassny,

Graham Stuart, Wendy Thorpe

1

Tower Financial Services

Group Limited

Warren Lee, Steve Smith, Michael Stiassny,

Graham Stuart, Wendy Thorpe

1

The National Insurance

Company of New

Zealand Limited

Richard Harding, David Callanan

Tower New Zealand

Limited

Richard Harding, David Callanan

National Insurance

Company (Holdings)

Limited

Richard Harding, Sarah-Jane Wild, Christopher

Sutherland, Isikeli Tikoduadua, Jeffrey Wright

2

,

Michelle James

2

Southern Pacific

Insurance Company (Fiji)

Limited

Richard Harding, Sarah-Jane Wild, Christopher

Sutherland, Jeffrey Wright

2

, Michelle James

2

Tower Insurance (Fiji)

Limited

Richard Harding, Sarah-Jane Wild, Christopher

Sutherland, Isikeli Tikoduadua, Jeffrey Wright

2

,

Michelle James

2

Tower Insurance (Cook

Islands) Limited

Richard Harding, Christopher Sutherland,

Jeffrey Wright

2

, Michelle James

2

Tower Insurance (PNG)

Limited

Richard Harding, Christopher Sutherland,

Stefan Hansen, Jeffrey Wright

2

, Michelle

James

2

National Pacific

Insurance Limited

Alden Godinet, Richard Harding, Rodney

Reid, Christopher Sutherland, Jeffrey Wright

2

,

Michelle James

2

National Pacific

Insurance (Tonga)

Limited

Alden Godinet, Richard Harding, Rodney

Reid, Christopher Sutherland, Jeffrey Wright

2

,

Michelle James

2

Tower Insurance

(Vanuatu) Limited

Richard Harding, Christopher Sutherland,

Jeffrey Wright

2

, Michelle James

2

1. Wendy Thorpe was appointed as a director on 1 March 2018.

2. Jeffrey Wright and Michelle James were appointed as directors

on 26 February 2018.


No employee appointed as a director of a subsidiary receives

any remuneration in their role as a director. The number of

employees who receive remuneration of more than $100,000

is included in the remuneration table on page 87. Auditor fees

paid on behalf of Tower and its subsidiaries are disclosed in

the financial statements.

| Other matters

Indemnity and insurance

In accordance with section 162 of the Companies Act 1993

and Tower's constitution, Tower has provided insurance for

and indemnities to, directors and employees of Tower for

losses from actions undertaken in the course of their duties.

The insurance includes indemnity costs and expenses

incurred to defend an action that falls outside the scope of

the indemnity. Particulars have been entered in the Interests

Register pursuant to section 162 of the Companies Act 1993. .

Limits on acquisition of securities

under New Zealand law

Tower undertook to the ASX, at the time it granted Tower a full

listing (July 2002), to include the following information in its

annual report. Except for the limitations detailed below, Tower

securities are freely transferable under New Zealand law.

The New Zealand Takeovers’ Code imposes a general rule by

which an acquisition of more than 20% of the voting rights in

Tower or an increase of an existing holding to 20% or more can

only occur in certain permitted ways. These include a full or

partial takeover offer in accordance with the Takeovers Code, an

acquisition or an allotment approved by an ordinary resolution of

shareholders, a creeping acquisition (in defined circumstances)

and a compulsory acquisition once a shareholder owns or

controls 90% or more of the voting rights in Tower.

93
The New Zealand Overseas Investment Act and related

regulations determine certain investments in New Zealand by

overseas persons. Generally the Overseas Investment Office’s

consent is required if an ‘overseas person’ acquires Tower shares

or an interest in Tower shares of 25% or more of the shares on

issue or, if the overseas person already holds 25% or more, the

acquisition increases that holding.

The New Zealand Commerce Act is likely to prevent a person

from acquiring Tower shares if the acquisition would, or would

be likely to, substantially lessen competition in a market.

Corporations Act 2001 (Australia)

Tower is not subject to Chapters 6, 6A, 6B or 6C of the

Corporations Act 2001 (Australia) dealing with the acquisition

of shares (such as substantial holdings and takeovers).

The Annual Report is signed on behalf of the Board by


Michael Stiassny Graham Stuart

Chair Director

Tower Limited annual report 201894

95

Tower Limited annual report 201896
Notes

97
Notes

Tower Limited annual report 201898
Notes

99
Board of Directors

Michael Stiassny (Chair)

Warren Lee

Steve Smith

Graham Stuart

Wendy Thorpe

Chief Executive Officer

Richard Harding

Company Secretary

David Callanan

Executive Leadership Team

Richard Harding

Tony Antonucci

David Callanan

Michelle James

Chris Sutherland

Glenys Talivai

Jeff Wright

Michelle McBride

Peter Muggleston

Registered Office

New Zealand

Level 14

Tower Centre

45 Queen Street

PO Box 90347

Auckland

Telephone: +64 9 369 2000

Facsimile: +64 9 369 2245

Australia

C/ – PricewaterhouseCoopers

Nominees (N.S.W) Pty Ltd

PricewaterhouseCoopers

Darling Park Tower 2

Level 1

201 Sussex Street

Sydney NSW 2000

Australia

Auditor

PricewaterhouseCoopers

Banker

Westpac New Zealand Limited

Company numbers

Tower Limited

(Incorporated in New Zealand)

NZ Incorporation 979635

NZBN 9429 0374 84576

ARBN 088 481 234

Stock exchanges

The Company’s ordinary shares are listed on the

NZSX and the ASX. On Wednesday 18 May 2016,

Tower’s ASX admission category changed to “ASX

Foreign Exempt Listing”.

Registrar

New Zealand

Computershare Investor Services Limited

Level 2, 159 Hurstmere Road,

Takapuna, Auckland

Private Bag 92119

Auckland 1142

Freephone within New Zealand: 0800 222 065

Telephone New Zealand: +64 9 488 8777

Facsimile New Zealand: +64 9 488 8787

Australia

Computershare Investor Services Pty Limited

Yarra Falls, 452 Johnston Street

Abbotsford VIC 3067

GPO Box 3329

Melbourne Vic 3000

Freephone within Australia: 1800 501 366

Telephone Australia: +61 3 9415 4083

Facsimile Australia: +61 3 9473 2500

Email: enquiry@computershare.co.nz

Website: www.computershare.com/nz

You can also manage your holdings electronically

by using Computershare’s secure website www.

investorcentre.com/nz

This website enables holders to view balances,

change addresses, view payment and tax

information and update payment instructions and

report options.

Tower recommends shareholders elect to have

any payments direct credited to their nominated

bank account in New Zealand or Australia to

minimise the risk of fraud and misplacement of

cheques.

We also encourage shareholders to receive

investor communications electronically as it keeps

costs down, delivery of our communications to

you is faster and it is better for the environment.

All you need to do is log in to www.investorcentre.

com/nz and update your ‘Communication

Preference’ to enable us to send all your investor

correspondence electronically where possible.

Please quote your CSN number or shareholder

number when contacting Computershare.

Enquiries

For customer enquiries, call

Tower on 0800 808 808 or visit

www.tower.co.nz

For investor enquiries:

Telephone: +64 9 369 2000

Email: investor.relations@tower.co.nz

Website: www.tower.co.nz

Tower Directory

Tower Limited annual report 2018100
Registrar

Computershare Investor Services Limited

Freephone within New Zealand: 0800 222 065

Telephone New Zealand: +64 9 488 8777

Freephone within Australia: 1800 501 366

Telephone Australia: +61 3 9415 4083

Email: enquiry@computershare.co.nz

Website: www.investorcentre.com/nz

Tower Limited Investor Relations

Telephone: +64 9 369 2000

Email: investor.relations@tower.co.nz

Website: www.tower.co.nz

Data sourced from publicly available filings. Our datasets may not be complete. Automated analysis can produce errors. If you believe any data on this page is incorrect, please contact us at hello@nzxplorer.co.nz. For informational purposes only. Not investment advice.