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Tower Limited Annual Report 2021

Annual Report22 December 2021TWRFinancials

OUR STRATEGIC PRIORITIES02
UPDATE FROM THE CHAIR & CEO04

2021 YEAR IN REVIEW

—GOOD GROWTH IN A CHALLENGING ENVIRONMENT


06

• Results achieved while navigating the challenges07

• Impact of external factors08

• Good growth in customers and premium

09

• Sharp focus on claims management10

• Product, pricing, & underwriting enhanced through data

14

• Investing in digital platform for efficiency & scalability15

• Management expenses improving while continuing to invest16

• Strong capital & solvency, delivering shareholder returns17

LOOKING FORWARD—LONG TERM GROWTH & IMPROVEMENT18

• Supporting our people & communities 22

• Well positioned to deliver dividends & growth24

BOARD OF DIRECTORS26

CONSOLIDATED FINANCIAL STATEMENTS28

• Financial Statements30

• Notes to the consolidated financial statements34

INDEPENDENT AUDITOR'S REPORT74

APPOINTED ACTUARY'S REPORT80

CORPORATE GOVERNANCE AT TOWER LIMITED82

• Tower Directory91

• Registrar92

TOWER LIMITED

ANNUAL REPORT 2021

5. PARTNER EVERYWHERE
Wherever possible Tower will work with

partners. We will nurture and develop

partnerships with the best organisations.

They will help us to continue to innovate

and improve our delivery.

1. CUSTOMER FOCUS

A relentless focus on customer

relationships. We will deliver

beautifully simple and rewarding

experiences through new rewards,

products and offerings that make

sense and drive value.

2. DIGITAL & DATA

Our significant investment in cloud-based

information technology allows us to use

digital and data to deepen our relationships

with our customers. At the same time, we

will use our digital and data strengths to

attract new customers.

3. TALENT & AGILE

Tower will embrace agile and talent. We need

the best people to grow our business capability

and to keep up the pace of innovation. This

means making sure Tower remains a great

place to work and a place where talent wants to

be. Our move to agile is already underway and

we are seeing benefits in our delivery cadence.

4. CAPITAL STRENGTH

We will maintain a strong capital and solvency

structure. Tower is committed to being a

financially robust business that delivers value

to customers and shareholders. Our solvency

margin is strong and higher than required by

the Reserve Bank of New Zealand.

OUR STRATEGIC

PRIORITIES

1

2

3

4

5

OUR VISION — To deliver

beautifully simple & rewarding

experiences that our people

& customers rave about

TOWER LIMITED ANNUAL REPORT 2021 02TOWER LIMITED ANNUAL REPORT 202103OUR STRATEGIC PRIORITIESOUR STRATEGIC PRIORITIES

Tackling the challenges
The insurance industry has faced an

incredibly challenging year. It has been

characterised by a marked increase in

large events and large house claims,

as well as lower investment income

and pandemic induced inflationary

pressures swiftly leading to increased

business as usual claims costs.

Tower has not been immune.

These challenges which were

emerging at the half year, continued

to put pressure on profits during the

second half. Consequently, in the year

to 30 September 2021, underlying

profit including large events was

$20.8 million (m), compared to

$28.4m in the prior year. Reported

profit including large events was

$19.3m, up from $11.2m at the full

year 2020 (which included a $9.5m

impact from the settlement with the

Earthquake Commission). It has been a

tough year, and we acknowledge and

share our shareholders’ frustration.

We are well underway addressing

these issues and their impact on

profitability across the business.

Most significantly, we have already

implemented rating and underwriting

changes including the introduction of

a full house fire replacement cap and

risk‐based pricing for inland flooding.

These actions are a substantial

response, and their benefit will continue

to be realised throughout FY22.

UPDATE FROM

CHAIR & CEO

Strong and well capitalised

Above all, Tower remains a resilient,

strong and well capitalised business.

Accordingly, we announced that based

on Tower’s ordinary dividend policy

of paying 60 to 80% of cash earnings

where it is prudent to do so, the Board

declared a final dividend of 2.5 cents

per share, to be paid on the 2nd of

February 2022, bringing total dividends

for FY21 to 5 cents per share.

In March this year, the Reserve Bank

lowered Tower’s solvency condition

from $50m to $25m in recognition of

Tower’s decreasing risk related to the

Canterbury earthquakes. As at 30th

September, Tower’s New Zealand

Parent solvency ratio was 271% and

the company was holding $56.6m

above its target solvency margin.

Considering current opportunities

and our capital position, the Board

has proposed the return of $30.4m

in excess capital to shareholders, by

way of a compulsory share buyback,

under a Court Scheme of Arrangement.

This is subject to shareholder approval,

High Court approval and Inland

Revenue approval.

Positioned for long-term growth

Tower is delivering on its innovation and

growth strategy. Our flagship Tower

Direct business and unique partnership

distribution capability continue to go

from strength to strength. The Pacific

business has proven remarkably

resilient through Covid and digitisation

will lead to further improvements in

efficiency and competitiveness. Our

leading technology partnerships are

enabling the business to be increasingly

nimble in responding to challenges and

capitalising on opportunities.

As we all recognise, it’s been a difficult

year on many fronts. However, despite

this, we are paying a dividend, we

remain strong and well capitalised, and

we have achieved sustained premium

growth, reaching a milestone this year,

with Tower writing more than $400m

in premiums.

These hard won victories are a credit

to Tower’s focused strategy and

the dedication of the people who

implement it. In short, even with the

obstacles of 2021, Tower continues to

be well positioned for long term growth.

After a challenging year, our unique technology & distribution footprint

have positioned Tower well to grow and deliver shareholder value.

MICHAEL

STIASSNY

Chairman

BLAIR

TURNBULL

CEO

TOWER LIMITED ANNUAL REPORT 2021 05TOWER LIMITED ANNUAL REPORT 2021 04UPDATE FROM CHAIR & CEOUPDATE FROM CHAIR & CEO

Underlying NPAT does not have a standardised meaning under
Generally Accepted Accounting Practice (GAAP). Consequently

it may not be comparable to similar measures presented

by other reporting entities and is not subject to audit or

independent review. Underlying NPAT is derived from reported

profit after tax adjusted for any large or non-recurring items

that may obscure trends in Towers underlying performance. For

FY21 these are adjustments in relation to Canterbury impact,

Insurance Face decommissioning and SaaS impact.

2021 YEAR IN REVIEW

—GOOD GROWTH IN A

CHALLENGING ENVIRONMENT

Our leading online presence, combined

with our unique partnerships, is helping

to deliver consistent growth ahead of

the market in New Zealand.

Results achieved while

navigating the challenges

Tower’s journey to deliver a beautifully simple

and rewarding customer experience through

an innovative, quality product range, enabled

through digital, data and leading partnerships

is gaining momentum.

These gains have supported reported profit after tax up 72%,

from $11.2m in FY20. Underlying net profit after tax (including

large events) was at $20.8m, versus $28.4m in FY20 reflecting

the combined impact of an increase in large events and large

house claims, Covid-related claims costs inflation, and lower

investment income.

Tower’s combined operating ratio increased 2.7% during the

prior year to 91.4%, reflecting claims inflationary pressure and

higher large events.

Offering customers a simple and rewarding experience

through our leading technology platform has helped grow

Tower’s gross written premium (GWP) to a milestone $404m,

up 5% on the same period last year.

Key successes include reaching a $42.1m settlement with

EQC and the Reserve Bank recognising our decreasing risk

related to the Canterbury earthquakes by reducing our licence

condition, from $50m to $25m. We also further simplified our

structure, placing us on a solid foundation to deliver long term

earnings, dividends, and sustained growth.

By continuing to scale our cloud-based digital and data

platforms, and enhancing our Tower Pacific and Partnerships

business, we are heading in a positive direction in line with

our strategy. In future, we’ll keep offering a versatile, varied

product suite, coupled with greater customer satisfaction

and engagement, to deliver improved retention and growth.

Our focus on exceptional customer service remains

unchanged, underpinned by investment in growing and

developing our amazing Tower team.

FY20

FY21

FY19

$20.8

$10.0

$28.4

$7.0

$35.4

$30.8

$27.4

$0.9

$28.4

FY20

FY21

FY19

$19.3

$16.8

$11.2

UNDERLYING NPAT


($M)

$19.3m

REPORTED PROFIT AFTER TAX ($M)

Large eventsUnderlying NPAT


($m)

Tower’s FY21 results were achieved

while navigating a challenging external

environment. Our investments in technology

mean we are well placed to respond rapidly

with rating and underwriting actions to

address these challenges.

We are pleased to resume

shareholder dividends after a

five-year hiatus. The total dividend

represents a dividend pay-out

ratio of 80% of cash earnings and

reflects our strong capital position.

Considering current

opportunities and the

company’s capital

position, the Board has

proposed the return of

$30.4m excess capital

to shareholders by

way of a compulsory

share buyback.

TOWER LIMITED ANNUAL REPORT 202107TOWER LIMITED ANNUAL REPORT 2021 062021 YEAR IN REVIEW2021 YEAR IN REVIEW

Impact of
external factors

Good growth in

customers & premium

Insurance, by nature, is an industry that

involves managing risks, accidents, and

weather events on a daily basis.

Large events are a source of volatility for New Zealand

and the Pacific that are likely to become more pronounced

with the impacts of climate change.

This year featured an unusual and challenging

combination of external events that weighed on our

FY21 profits, including:

• Seven large events contributed to $13.9m in

costs, compared with $9.7m in FY20

• Large house claims rose significantly to 92, from

57 in FY20

• Inflation was responsible for $7.1m additional

business-as-usual claims costs.

• Our net investment income before tax dropped

$5.1m to $0.2m

Covid-induced supply chain issues have impacted

New Zealand and the Pacific, resulting in significant delays

in resolving some motor, home and contents claims.

While the impact of any one of these factors alone

would be sustainable in a normal year, with the ongoing

effects of the pandemic, this was not a normal year.

Despite this year’s challenges, we have

experienced growth ahead of the market,

particularly in New Zealand, where gross

written premium (GWP) rose by 7.9%

to $350m.

This was achieved through a combined effort of offering a

well-balanced mix of market premium ratings and attracting

new Tower customers. Overall customers grew 5% to

304,000, increasing market share to 9.2%. This growth also

reflects improvements in customer satisfaction, shown by

an improved net promoter score (NPS) of 43%, compared

with 27% last year.

Tower Direct leapt from strength to strength, recording

132,000 My Tower registrations this year, up substantially

on 45,000 in 2020. The portfolio grew to $273m, and now

includes the ANZ legacy portfolio, which is still migrating

customers over to Tower.

Prioritising business partnerships also delivered growth,

as our Partnerships business begins to transform from

a more traditional model to usher in a portfolio of new

technology-led organisations.

Our Pacific business remained resilient, despite GWP

declining by 10%, primarily because of Covid-associated

economic challenges. We were proud to become the first

insurer with a digital presence in the Pacific, after launching

our cloud-based platform in Fiji. This online offering will

expand across the Pacific to bring more alignment between

the New Zealand and Pacific business units moving forward.

7

.

9

%

43

%

7

.

9

%

43

%

$0.2m92

$13.9m

$7.1m

NET INVESTMENT

INCOME (PRE-TAX)

LARGE HOUSE

CLAIMS

MOVEMENT IN UNDERLYING NPAT ($M)

LARGE EVENTS (PRE-TAX)

CLAIMS INFLATION (PRE-TAX)

NET PROMOTER SCORE


NZ GWP GROWTH

VS $5.3M

PRIOR YEAR

VS 57

PRIOR YEAR

+5% ON PRIOR YEAR

VS 45K PRIOR YEAR

VS $9.7M PRIOR YEAR

INCREASE IN CLAIMS EXPENSE

VS 27% PRIOR YEARTO $350 GWP

FY19

FY20FY21

9.1%

9.2%

8.3%

304,000

132,000

CUSTOMERS

MY TOWER REGISTRATIONS

TOWER NZ PERSONAL LINES MARKET SHARE

FY20

underlying

NPAT

FY21

Underlying

NPAT

Large

events

Higher large

house claims

Claims

inflation

Investment

income

Covid-19

claims

reduction

Business

growth

Reduced

commission

216

190

$28.4

$-3.0

216

190

$20.8

190

$-3.7

$3.3

$-5.1

$5.6

$2.3

$-6.9

Pacific

FY19

FY20FY21

$216

$11 0

$59

$190

$1 07

$60

$273

$7 7

$54

$404

$357

$385

GWP GROWTH BY BUSINESS UNIT ($M)

PartnershipsDirect

TOWER LIMITED ANNUAL REPORT 2021 08TOWER LIMITED ANNUAL REPORT 2021092021 YEAR IN REVIEW2021 YEAR IN REVIEW

Sharp focus on
claims management

FY21 saw a combined 5% increase in the BAU

claims loss ratio and large events loss ratio.

The resultant 54% of net earned premium (NEP)

is the highest claims loss ratio since 2018.

The impact of inflation

We anticipated that Covid may cause inflationary pressures,

particularly for motor. However, it wasn’t until the FY21 March

quarter that evidence of inflation emerged and it has since

accelerated rapidly.

The average motor claim has increased 6% and the average

house claim is up 7% on FY20.

Supply chain issues for new vehicles have driven up the value

of second-hand vehicles by 13% year on year, significantly

increasing the cost of total loss motor claims. While the

inflationary impact on motor parts and repairs hasn’t been

as dramatic, the full impact may not yet have been felt, with

significant delays in completing repairs due to supply chain

issues with motor parts.

Double-digit inflation is materially impacting the cost of

building materials.

Tower has increased premiums across motor and home to

offset inflation. We are also working closely with supply

chain partners to enhance efficiencies and moderate the

impact on customers as much as possible.

AVERAGE MOTOR

CLAIMS


CARSHOMES

AVERAGE HOUSE

CLAIMS


FY19FY20FY17FY18FY21

4̗%

3%

3%

51%

52%

50%

4%

4%

56%

4̗%

4̗%

49%

0%

46%

54%

$26.3m

166769

GROSS INCURRED LARGE CLAIMS

TOTAL CLAIMS RATIO

FY19FY20FY17FY18FY21

$13.1

$1 4.1

$21.5

$26.3

$17.5

$9.7

$9.6

$1.8

$1.8

$25.4

Lake Ōhau

fires

Napier

flood

Canterbury

flood

Motueka

flood

West

AK flood

Central Otago

flood

Papatoetoe

tornado

Westland

flood


MAY

21

NOV

20

JUNE

21

AUG

21

JULY

21

OCT

20

JAN

21

LARGE EVENTS CLAIMS ($M)

(BASED ON EVENT DATE)

Net incurred

BAU

Gross incurred

Large events

Large events and large house claims

Alongside inflationary pressures, in FY21 Tower

experienced the highest number of large house

claims and large event claims for many years.

The majority of large house claims were fire

related. As a result of this marked increase, Tower

removed the uncapped total loss, house fire benefit,

capping the benefit to 120% of the sum insured.

The majority of large events during the year were

floods in New Zealand. During the year we supported

customers through major floods in West Auckland,

Westport, Motueka, Canterbury, Central Otago

and Napier.

This increase in flooding highlights the importance of

the change we’ve made in how we identify and price

risk appropriately for inland flooding. The changes on

the 10th of November impact all new and renewing

house policies.

Managing through volatility

Large events are a source of volatility for New Zealand

and the Pacific that are likely to become more

pronounced with the impacts of climate change.

For Tower, this volatility is primarily managed by our

aggregate reinsurance programme.

However, the key to managing all these challenges is

also prompt recognition and remedial action.

Automation and data management are at the forefront of

all our remedial action. We are continuously optimising to

better understand our claims, as well as to improve our

claims assessment and management.

Through our leading technology capability, we now have

the ability to act swiftly to adjust ratings and underwriting.

We are also working with data science and risk partners

to better understand the links between large events,

climate change and large house fires in order to help

mitigate and reduce such events in the future.

6%7%

Helping our customers

through large events

TOWER LIMITED ANNUAL REPORT 2021 10TOWER LIMITED ANNUAL REPORT 2021112021 YEAR IN REVIEW2021 YEAR IN REVIEW

Core to our strategy is leading
with a quality, innovative product

range which enables us to

deepen our relationships with

customers, improve revenue

and increase retention.

̄tã*š aNiN ̄*$ kk¶a š*—tš ̄ 2̏2̐ 12TOWER LIMITED ANNUAL REPORT 2021 132021 YEAR IN REVIEW2021 YEAR IN REVIEW

SEP-21JUN-21MAR-21
$205

4,932

794

3,118

1,659

3̕̕

1̕9

Product, pricing &

underwriting enhanced

through data

Our quality, innovative, balanced product

range enables us to deepen our relationships

with customers, improve revenue and

increase retention.

Half of our New Zealand customers now hold multiple

products. These customers stay with Tower approximately

three years longer, compared to those with one product.

This highlights the opportunity to increase existing customers’

purchases, engaging and retaining them for longer.

To further engage customers we launched a series of new

products. This included an end‐to‐end online boat experience

and a new travel product. In the Pacific we also launched new

home and contents, and motor policies.

By enhancing our product set to keep pace with customers’

lifestyles, we can further improve retention rates and build

relationships. For example, our boat offering is already gaining

pace, with around 5,000 new business policies sold this year

and our motor policy sales for EVs have increased by 60%

since February.

While external events prompted the New Zealand loss ratio

to increase to 53.6% for the year, we quickly identified the

emerging challenges, such as construction inflation, and

used our technology platform to quickly adjust and control

our margin.

In November, we launched an innovative address-based

rating tool for flood risk. By investing in detailed modelling to

highlight the flood risk from rivers and rain to Kiwis’ homes,

we’ve been able to better align premium pricing with risk, and

better manage our loss ratio. Customers’ positive response to

this initiative showed our shift to more transparent pricing is a

welcome one.

FY19

FY20FY21

$122

$1 0

$183

$193

$1 00

$13

$205

$134

$11

$350

$325

$296

FY19

FY20FY21

52%

117

219

47

42%

51%

40%

SEP-21SEP-20MAR-21

50

%

53

.

6

%

50

%

53

.

6

%

7.9 years

NZ PRODUCT MIX GWP ($M)

NZ NEW BUSINESS RISK —

ELECTRIC VEHICLE & BOAT

TECHNOLOGY SYSTEM RELEASE

NZ SERVICE TASKS COMPLETED DIGITALLY

NZ CUSTOMERS WITH

MULTIPLE PRODUCTS

NZ BAU

LOSS RATIO

Motor

Electric vehicle

OtherHome & contents

Boat

Investing in digital

platform for efficiency

& scalability

Central to Tower’s strategy is delivering

beautifully simple and rewarding

customer experiences.

We use data smartly to understand the changing needs of

our customers. By harnessing data insights, we can learn

how to serve our customers better, as well as offer new

products and features.

During 2021, we rolled out 219 technology upgrades to help

refine our service delivery, remove cumbersome legacy

systems, and assist with building deeper relationships with

our customers.

With more than half of all service tasks in New Zealand

now completed digitally (vs 40% last year), and around a

third of claims lodged digitally (vs 23% in the prior year),

the customer and efficiency benefits from our leading

digital and data technology platform are being realised.

Our approach to digital has also underpinned increased

uptake of our My Tower platform. It gives customers the

convenience of managing all aspects of their insurance,

including accessing documents, making payments,

changing excess, and making claims.

80% of Tower customers have now migrated to our cloud-

based, digital EIS platform. This is up on 62% in 2020 and

enables us to scale quickly as we acquire new business.

We remain focused on decommissioning legacy systems,

with a further two decommissioned in this financial year. This

means we anticipate just two remaining by the end of 2022.

Meanwhile, innovative technology releases continue to

trend upwards as we become more agile and responsive in

anticipating customers’ needs.

VS 4.8 YEARS FOR A SINGLE PRODUCT HOLDER

VS 40% PRIOR YEAR

VS 23% PRIOR YEAR

135,000 NZ

CUSTOMERS HAVE

MULTIPLE PRODUCTS

UP 4% ON

PRIOR YEAR

VS 62% IN SEP 2020

VS 6 IN PRIOR YEAR

2 REMAINING BY

END 2022

NZ CLAIMS

LODGED DIGITALLY

NZ SERVICE TASKS

COMPLETED

DIGITALLY

TOTAL

CUSTOMERS

MIGRATED TO EIS

CORE ADMIN LEGACY

SYSTEMS REMAINING

51

%

8

0

%

31

%

51

%

8

0

%

31

%

51

%

8

0

%

31

%

4

MULTIPLE PRODUCTS HOLDER TENURE

TOWER LIMITED ANNUAL REPORT 2021 14TOWER LIMITED ANNUAL REPORT 2021152021 YEAR IN REVIEW2021 YEAR IN REVIEW

This year, we were pleased to resume
shareholder dividends after a five-year hiatus

due to resolving claims from the Canterbury

earthquakes.

We paid a 2.5 cents per share dividend at the half year and the

Board has declared another 2.5 cents per share at the full year,

bringing total dividends for FY21 to 5 cents per share. This

represents a dividend pay-out ratio of 80% of cash earnings.

Our New Zealand parent solvency ratio is 271%, which is

$56.6m above our target solvency margin and reflects our

strong capital position.

Proposed compulsory share buyback

Tower proposes returning $30.4m in capital by way of

a compulsory share buyback, under a Court Scheme of

Arrangement of one in every ten shares held at a price of

$0.72 per share. This is a premium of 12% on the closing

price on the 23rd of November of $0.645. This is subject to

obtaining IRD approval that the capital return is not taxable

in New Zealand and is not in lieu of a dividend, in addition to

High Court approval and shareholder approval.

Continuing to seek sensible investment opportunities

We continue to look at sensible acquisitions that are value

accretive for shareholders. This year we acquired the ANZ

legacy portfolio and are finalising the acquisition of the

remaining shares in National Pacific Insurance (NPI). The Tower

subsidiary is headquartered in Samoa and serves people

across Tonga, American Samoa and Samoa.

Management expenses

improving while

continuing to invest

Strong capital &

solvency, delivering

shareholder returns

One in every three dollars of Tower’s

management expenses relates to digital and

data technology. We see this as a valuable

investment to help evolve our customer

experience and accelerate efficiency

improvements throughout the organisation.

During the year, management expense ratio (MER) improved

2% dropping to 37%, thanks to reducing our acquisition costs,

down to 12.6%.

We introduced various cost containment measures this year,

reducing overall management expenses by $3.9m before

tax to $123.3m. This represents a significant saving from the

FY20 figure, $127.2m, and translates into a 2.3% reduction of

MER as a percentage of NEP to 37%.

In addition, a reduction in People expenses of $4.0m before

tax, and other expenses of $0.6m before tax, was achieved in

part through the benefits of the EIS platform implementation.

Net commission reduced $3.2m before tax, driven by

acquisition of the ANZ portfolio, and higher proportional

reinsurance profit share. In addition, the liability adequacy

test resulted in a $2.5m deficiency before tax, requiring an

additional $2.1m expense in FY21 for acquisition costs that

would otherwise have been capitalised.

MANAGEMENT EXPENSE RATIO (% NEP)

COMMISSION EXPENSE RATIO (% GEP)

FY19

FY20FY21

3.8%

2.9%

5.0%

FY19

FY20FY21

39%

37%

40%

TOWER

MANAGEMENT

EXPENSE RATIO

ACQUISITION COSTDIGITAL & DATA

NET COMMISSION

EXPENSE

REDUCED

37

%

12

.6

%

22

%

37

%

12

.6

%

22

%

12.6%

$

1

in $

3

271%$21m

60-80%

$30.4m

TOWER PARENT

SOLVENCY

FULL YEAR

DIVIDEND PAYMENT

ORDINARY DIVIDEND POLICY

PROPOSED CAPITAL RETURN OF

BEFORE RETURN

OF CAPITAL

$10.5M TO BE PAID

2 FEB 2022

VIA COMPULSORY SHARE BUYBACK

REDUCTION

FOLLOWING BOOK

PURCHASE AND

REINSURANCE

PROFIT

2% BETTER THAN

PRIOR YEAR

VS 13% IN

PRIOR YEAR

OF TOTAL

MANAGEMENT

EXPENSES

OF CASH EARNINGS WHERE

PRUDENT TO DO SO

2.5c dividend bringing

full year to 5c per share

TOWER LIMITED ANNUAL REPORT 2021 16TOWER LIMITED ANNUAL REPORT 2021172021 YEAR IN REVIEW2021 YEAR IN REVIEW


LOOKING FORWARD—

LONG-TERM GROWTH

& IMPROVEMENT

We are very focused on addressing

the challenges we’ve identified,

improving profitability and continuing to

leverage our technology, customer and

partnership advantage for growth.

Our core strategy is around personal

lines and small to medium sized

commercial segments in New Zealand

and the Pacific region.

We have a clear and focused set of five

strategic priorities.

We are relentlessly focused on our

customers, deepening our relationships

with them through rewards, new

products and other offerings that make

sense and drive value.

We are leveraging the full capability

of our cloud‐based platform by using

Despite the headwinds, this year’s results demonstrate

the resilience of our customer and digitally led strategy.

We continue to grow, to drive down expenses, and to

respond quickly to the changing external environment.

the insights from our data to make

our customers’ lives easier and to

understand their needs better.

We are finding the best people to

partner with to boost our offering,

develop new products, and deliver

services in better ways and

more efficiently.

We understand that our people are

the ultimate drivers of our success

as they are on the front line, building

our customer relationships.

And importantly, we are committed

to maintaining a strong capital and

solvency structure, and delivering

value for shareholders.

We are relentlessly focused on

our customers, deepening our

relationships with them through

rewards, new products and

other offerings that make sense

and drive value.

TOWER LIMITED ANNUAL REPORT 2021 18TOWER LIMITED ANNUAL REPORT 202119LOOKING FORWARDLOOKING FORWARD

Our 2022 goal is to offer a world-class digital experience
on one core leading platform, for all our personal lines

customers across New Zealand and the Pacific.

This year, we took an important step towards this aim

by acquiring the remaining shares in NPI.

One of our first steps will be to rebrand NPI to Tower,

coinciding with the launch of the first digital insurance

solution in these markets. We will also complete Tower’s

digital rollout across the Pacific in FY22.

Our agility and digital capabilities are also leading

to new product lines to support the unique needs of

our Pacific customers, as well as growth in this

important market.

In our Partnerships division, we are building a unique

model that relies less on higher commission and more

on our technology capability, customer experience and

balanced referral arrangements with our partners.

These include corporates, insurtechs, advisory businesses

and our cornerstone partner Trade Me, with whom we

recently renewed our agreement for another five years.

For our direct business, a key element of our strategic

focus has been to secure mutually beneficial

partnerships that drive significant growth and quickly

give us capabilities that we would otherwise have to

build from scratch.

Our exciting partnership with Allianz, one of the world’s

largest insurers, has already led to the development of

new pet and travel products this year.

In the coming year we will be working hard on a new

home renovation product. We are also planning to

upgrade our rural and SME offerings.

We’re continuously utilising more than 1.7 billion data

points thanks to over 25 external partners including

Microsoft, EIS, Friss, Amodo and Ushur, who are all

helping us to improve customer outcomes and make

better decisions.

Our 2022 goal is to offer a world-

class digital experience on one

core leading platform, for all our

personal lines customers across

New Zealand and the Pacific.

TOWER LIMITED ANNUAL REPORT 2021 20TOWER LIMITED ANNUAL REPORT 2021 21LOOKING FORWARD LOOKING FORWARD

Supporting our people
While our people can work remotely, we know

it is not easy to navigate the challenges of Covid

lockdowns, both in New Zealand and across the

Pacific. We have put in place several initiatives

to support our people during this time and are

pleased our employee engagement score has

increased to 77%, up 6% on FY20.

SUPPORTING OUR PEOPLE

& COMMUNITIES

Supporting our communities

This year, we started our sustainability journey with

the development of an ESG strategy. This will guide

how Tower manages its environment, social and

governance issues under the following focus areas:

• A diverse and inclusive workplace that builds

people’s physical and emotional wellbeing

• No-surprises, easy to understand insurance

that is accessible and affordable

• Championing informed dialogue about

climate change

• Moving all aspects of our business towards

zero-carbon and zero-waste and ensuring we

have a positive impact on New Zealand and the

Pacific, now and in the future.

Importantly, we have measured our total carbon

emissions across our operations and have set a

science-based target to reduce our Scope 1 and 2

emissions by 21% over five years against FY20.

This year, we also pledged to support scientific

research, education, and innovation via scholarships

for the world’s first Bachelor of Climate Change

degree at the University of Waikato.

Our ability to continue to grow, partner and innovate as a leading digital and

data business is only possible with the support of our fantastic team and the

communities we serve.

We will continue to prioritise and

invest in our people to ensure we

have a diverse, inclusive culture

where everyone can contribute

and feel valued.

We’re partnering with Coastguard

to help out even more Kiwis

on the water by supporting

their operations as well as their

phenomenal volunteers.

TOWER LIMITED ANNUAL REPORT 2021 23TOWER LIMITED ANNUAL REPORT 2021 22SUPPORTING OUR PEOPLE & COMMUNITIESSUPPORTING OUR PEOPLE & COMMUNITIES

It’s clear that FY21 was a challenging year
and we have taken decisive actions to deliver

improvements and positive results in FY22.

Tower is a well-capitalised business with a strong balance sheet

and solvency margins. We have delivered customer and premium

growth while further improving our management expense ratio.

We are delighted to have resumed dividends within the year and

propose to return excess capital to shareholders.

In FY22, our focus is on driving shareholder value by accelerating

the positive growth and innovation we have achieved in FY21.

We will continue to take decisive action to address challenges

with claims inflation and climate change risks, and we will

continue to invest in our digital and data platform to drive

efficiency and support growth.

WELL POSITIONED TO

DELIVER DIVIDENDS

& GROWTH

Tower continues

to invest in our

digital and data

platform to drive

efficiency and

support growth.

In FY22, our focus is on

driving shareholder value

by accelerating the positive

growth and innovation we

have achieved in FY21.

TOWER LIMITED ANNUAL REPORT 202125TOWER LIMITED ANNUAL REPORT 2021 24WELL POSITIONED TO DELIVER DIVIDENDS & GROWTHWELL POSITIONED TO DELIVER DIVIDENDS & GROWTH

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

40 years of 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 in

the international financial services

industry. 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 currently

a non-executive director of MetLife

Limited, MyState Limited, and Avenue

Hold Limited. 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 had an extensive executive

career in financial services, 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 in

Australia.

Wendy is Chair of Online Education

Services, Chair of Epworth Healthcare,

and a Non-Executive Director of

Ausgrid, and Peoples’ Choice Credit

Union. 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.

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

seven years.

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 Māori Economic

Development Panel.

Graham resides in Auckland

—New Zealand.

MICHAEL STIASSNY

LLB, BCom, FCA (retired), CFInstD

Chairman

Non-Executive Director

Independent

Appointed Director: 12 October 2012

Michael is a Fellow of Chartered

Accountants Australia and New

Zealand. Michael is also a Chartered

Fellow and past President of the

Institute of Directors. He has both a

Commerce and Law degree from

the University of Auckland. He is

Chairman of Ngāti Whātua Ōrākei

Whai Rawa Limited and is a director

of a number of other companies

including Tegel Group Holdings Ltd,

and New Talisman Gold Mines Ltd.

Michael resides in Auckland

—New Zealand.

BOARD

OF DIRECTORS

MARCUS NAGEL

MBA (International Management),

MBA (Banking and Finance)

Non-Executive Director

Not Independent

Appointed Director: 14 January 2019

Marcus has significant insurance

industry experience.

For a decade he has performed

senior leadership roles for Zurich in

Europe and globally. In his last role

at Zurich, he served as the Chief

Executive Officer of Zurich Germany

managing both life insurance and

general insurance businesses. He

has also held the position of Vice

Chairman of the joint venture with

ADAC, Germany’s largest Automotive

Club, Chairman of the direct insurer,

DA Direct, and Chairman of the life

insurer, Zurich Deutscher Herold.

Prior to that, he also managed the

independent financial adviser/broker

business for Zurich Global Life.

Marcus holds a Master’s Degree in

Banking and Finance from Goethe

University in Frankfurt, Germany and

Master of International Management

from the Arizona State University

Thunderbird School of Global

Management in Arizona, United States

of America. Marcus was nominated by

Bain Capital Credit LP (Bain Capital) to

represent Bain Capital’s stake in Tower

(Bain Capital hold 19.99% of Tower’s

ordinary shares) and his appointment

was supported by the Tower Board.

Marcus resides in Schindellegi

—Switzerland.

TOWER LIMITED ANNUAL REPORT 2021 26TOWER LIMITED ANNUAL REPORT 2021 27BOARD OF DIRECTORSBOARD OF DIRECTORS

Notes to the consolidated financial statements
1Overview34

1.1About this report34

1.2Consolidation34

1.3Critical accounting judgements and estimates36

1.4Segmental reporting36

2Underwriting activities38

2.1Underwriting revenue38

2.2Net claims expense39

2.3Underwriting expense39

2.4Net outstanding claims40

2.5Unearned premium liability44

2.6Deferred insurance costs45

2.7Receivables46

2.8Payables47

2.9Provisions48

2.10Assets backing insurance liabilities48

3Investments48

3.1Investment revenue48

3.2Investments49

3.3Fair value hierarchy49

4Risk management50

4.1Risk management overview50

4.2Strategic risk50

4.3Insurance risk51

4.4Credit risk52

4.5Market risk53

4.6Liquidity risk55

4.7Capital management risk55

4.8Operational risk56

4.9Regulatory and compliance risk56

4.10Conduct risk56

4.11Cyber risk57

5Capital structure57

5.1Borrowings57

5.2Contributed equity57

5.3Reserves58

5.4Net tangible assets per share58

5.5Earnings per share59

5.6Dividends59

6Other balance sheet items60

6.1Property, plant and equipment60

6.2Intangible assets61

6.3Leases63

7Tax 66

7.1Tax expense66

7.2Current tax67

7.3Deferred tax67

7.4Imputation credits69

8Other information69

8.1Notes to the consolidated cash flow statement69

8.2Related party disclosures70

8.3Auditor's remuneration70

8.4Contingent liabilities70

8.5Subsequent events71

8.6Capital commitments71

8.7Impact of new accounting standards and changes in

interpretation of current standards71

Independent Auditor's report,

and Appointed Actuary's report

Independent Auditor's report74

Appointed Actuary's report80

Financial statements

Consolidated statement of comprehensive income30

Consolidated balance sheet31

Consolidated statement of changes in equity32

Consolidated statement of cash flows33

CONSOLIDATED

FINANCIAL

STATEMENTS

TOWER LIMITED ANNUAL REPORT 202129TOWER LIMITED ANNUAL REPORT 2021 28CONSOLIDATED FINANCIAL STATEMENTSCONSOLIDATED FINANCIAL STATEMENTS

Consolidated statement of comprehensive income
FOR THE YEAR ENDED 30 SEPTEMBER 2021

Consolidated balance sheet

AS AT 30 SEPTEMBER 2021

NOTE

2021

$000

RESTATED

2020

$000

Gross written premium 404,681 377,159

Unearned premium movement(9,151)(4,607)

Gross earned premium 2.1 395,530 372,552

Outward reinsurance premium(63,767)(58,030)

Movement in deferred reinsurance premium1,540 810

Outward reinsurance premium expense(62,227)(57,220)

Net earned premium 333,303 315,332

Claims expense(228,903)(206,767)

Less: Reinsurance and other recoveries revenue2.124,635 25,711

Net claims expense2.2(204,268)(181,056)

Gross commission expense(18,058)(20,947)

Commission revenue2.1 6,753 6,457

Net commission expense(11,305)(14,490)

Underwriting expense2.3(89,751)(89,520)

Underwriting profit27,979 30,266

Investment income3.1 580 5,810

Investment expense(384)(466)

Corporate and other income707 288

Corporate and other expense(54)(2,967)

Impairment of EQC receivable2.7 – (13,126)

Financing and other costs(378)(1,125)

Profit before taxation28,450 18,680

Tax expense7.1(9,135)(7,470)

Profit after taxation19,315 11,210

Items that may be reclassified to profit or loss

Currency translation differences(1,213)(1,374)

Items that will not be reclassified to profit or loss

Gain on asset revaluation5.3159 41

Deferred income tax relating to asset revaluation5.3(16)8

Other comprehensive loss net of tax(1,070)(1,325)

Total comprehensive profit for the year18,245 9,885

Earnings per share:

Basic and diluted earnings per share (cents)5.54.43 2.58

Profit after taxation attributed to:

Shareholders18,683 10,761

Non-controlling interests632 449

19,315 11,210

Total comprehensive profit attributed to:

Shareholders 17,729 9,522

Non-controlling interests516 363

18,245 9,885

The above statement should be read in conjunction with the accompanying notes.

NOTE

2021

$000

RESTATED

2020

$000

Assets

Cash and cash equivalents8.1116,129 80,108

Investments3.2277,470 237,904

Receivables 2.7215,853 250,746

Current tax asset7.2a12,901 12,892

Deferred tax asset7.3a24,450 28,822

Deferred insurance costs2.631,967 34,667

Right of use assets6.3a(i)25,577 7,211

Property, plant and equipment 6.19,374 10,041

Intangible assets6.288,592 77,847

Total assets802,313 740,238

Liabilities

Payables2.868,905 66,600

Unearned premiums2.5212,275 203,452

Outstanding claims2.4122,338 107,747

Lease liabilities6.3a(ii)39,421 8,695

Provisions2.96,709 9,531

Current tax liabilities7.2b170 821

Deferred tax liabilities7.3b2,775 1,346

Total liabilities452,593 398,192

Net assets349,720 342,046

Equity

Contributed equity5.2492,424 492,424

Accumulated losses(39,995)(48,107)

Reserves5.3(105,385)(104,431)

Total equity attributed to shareholders347,044 339,886

Non-controlling interests2,676 2,160

Total equity349,720 342,046

The above statement should be read in conjunction with the accompanying notes.

The financial statements were approved for issue by the Board on 24 November 2021.


Michael P Stiassny Graham R Stuart

Chairman Director

TOWER LIMITED ANNUAL REPORT 2021 30TOWER LIMITED ANNUAL REPORT 202131CONSOLIDATED BALANCE SHEETCONSOLIDATED STATEMENT OF COMPREHENSIVE INCOME

Consolidated statement of changes in equity
YEAR ENDED 30 SEPTEMBER 2021

ATTRIBUTED TO SHAREHOLDERS

CONTRIBUTED

EQUITY

$000

ACCUMULATED

LOSSES

$000

RESERVES

$000

NON-CONTROLLING

INTEREST

$000

TOTAL EQUITY

$000

Year Ended 30 September 2021

Balance as at 30 September 2020492,424 (48,107)(104,431)2,160 342,046

Comprehensive income

Profit for the year – 18,683 – 632 19,315

Currency translation differences – – (1,097)(116)(1,213)

Gain on asset revaluation – – 159 – 159

Deferred income tax relating to asset revaluation – – (16) – (16)

Total comprehensive income – 18,683 (954)516 18,245

Transactions with shareholders

Dividends paid – (10,541) – – (10,541)

Other – (30) – – (30)

Total transactions with shareholders – (10,571) – – (10,571)

At the end of the year492,424 (39,995)(105,385)2,676 349,720

Year Ended 30 September 2020

Balance as at 30 September 2019 209,990 (36,101)9,808 1,801 185,498

Impact of amalgamation – 107,160 – – 107,160

Balance post amalgamation 209,990 71,059 9,808 1,801 292,658

Adjustment on initial application of NZ IFRS 16 – (1,333) – (4)(1,337)

Adoption of accounting policy on cloud computing

arrangements

– (3,986) – – (3,986)

Restated balance at beginning of the year 209,990 65,740 9,808 1,797 287,335

Comprehensive income

Profit for the year – 10,761 – 449 11,210

Currency translation differences – – (1,288)(86)(1,374)

Gain on asset revaluation – – 41 – 41

Deferred income tax relating to asset revaluation – – 8 – 8

Total comprehensive income

– 10,761 (1,239)363 9,885

Transactions with shareholders

Net proceeds of capital raise

45,000 (119) – – 44,881

Dividends written off

– (99) – – (99)

Other

44 44

Cancellation of shares on amalgamation

(254,990)254,990 – – –

Recognition of shares on amalgamation

492,424 (379,424)(113,000) – –

Total transactions with shareholders

282,434 (124,608)(113,000) – 44,826

At the end of the year

492,424 (48,107)(104,431)2,160 342,046

The above statement should be read in conjunction with the accompanying notes.

Please note, Tower amalgamated its corporate structure on 30 September 2020. Refer to note 5.2 for further information.

Refer to note 8.7 for further information.

Consolidated statement of cash flows

FOR THE YEAR ENDED 30 SEPTEMBER 2021

2021

$000

RESTATED

2020

$000

Cash flows from operating activities

Premiums received 398,601 366,738

Interest received 5,273 7,328

Fees and other income received6,328 7,345

Reinsurance and other recoveries received17,686 18,035

Settlement of EQC receivable52,883 –

Motor premium refund payments(1,351)(5,849)

Reinsurance paid(55,979)(54,867)

Reinsurance paid in relation to settlement of EQC receivable(10,741) –

Claims paid(213,350)(223,751)

Employee and supplier payments(97,912)(97,499)

Income tax paid(2,797)(1,317)

Net cash inflow from operating activities 98,641 16,163

Cash flows from investing activities

Proceeds from sale of interest-bearing investments158,509 112,484

Proceeds from sale of unlisted equity investments572 –

Payments for purchase of interest-bearing investments(191,319)(117,734)

Payments for purchase of intangible assets (8,866)(4,645)

Payments for purchase of customer relationships(14,434)(9,473)

Payments for purchase of property, plant and equipment(3,163)(3,122)

Net cash outflow from investing activities (58,701)(22,490)

Cash flows from financing activities

Proceeds from share capital issuance – 47,300

Received from lessor on signing of new lease10,945 –

Payments for cost of share capital issuance – (2,419)

Dividends paid(10,541) –

Repayment of borrowings – (15,000)

Facility fees and interest paid(378)(1,115)

Payment relating to principal element of lease liabilities(2,848)(3,070)

Net cash (outflow)/ inflow from financing activities (2,822)25,696

Net increase in cash and cash equivalents37,118 19,369

Effect of foreign exchange rate changes(1,097)(1,279)

Cash and cash equivalents at the beginning of the year 80,108 62,018

Cash and cash equivalents at the end of the year 116,129 80,108

The above statement should be read in conjunction with the accompanying notes.

The 2021 balance represents the purchase of ANZ's rights and obligations relating to servicing a portfolio of insurance underwritten by Tower. Please refer to note 6.2 for more information.

The comparative 2020 balance reflects the net cashflow associated with the purchase of Youi NZ Pty Ltd's insurance portfolio.

TOWER LIMITED ANNUAL REPORT 2021 32TOWER LIMITED ANNUAL REPORT 202133CONSOLIDATED STATEMENT OF CASH FLOWSCONSOLIDATED STATEMENT OF CHANGES IN EQUITY

Notes to the consolidated financial statements
FOR THE YEAR ENDED 30 SEPTEMBER 2021

OVERVIEW

This section provides information that is helpful to an overall understanding of the financial statements and the areas of critical accounting

judgements and estimates included in the financial statements. It also includes a summary of Tower's operating segments.

1.1 About this Report

a. 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 136 Fanshawe Street, Auckland, New Zealand.

During the periods presented, the principal activity of the Group was the provision of general insurance. The Group predominantly operates in New

Zealand with some of its operations based in the Pacific Islands region.

The financial statements were authorised for issue by the Board of Directors on 24 November 2021. The entity’s owners or others do not have the power

to amend the financial statements after issue.

b. 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.

c. Basis of preparation

The Company is a for-profit entity and the financial statements have been prepared in accordance with New Zealand Generally Accepted Accounting

Practice (NZ GAAP). They comply with International Financial Reporting Standards (IFRS), 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.

d. Restatement of comparatives

In April 2021, the IFRS Interpretations Committee (IFRIC) issued an agenda decision 'Configuration or Customisation Costs in a Cloud Computing

Arrangement (NZ IAS 38 Intangible Assets)'. This IFRIC agenda decision clarifies the interpretation on how NZ IAS 38 Intangible Assets applies to

configuration and customisation costs incurred in implementing Software-as-a-Service (SaaS) cloud computing arrangements. Refer to note 8.7 for

further details of change in comparatives.

1.2 Consolidation

a. 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. There have been no acquisitions or disposals

of subsidiaries during the year ended 30 September 2021.

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 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.

1.2 Consolidation (continued)

b. 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 the entities’

functional and reporting currency 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.

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 impact profit after tax in the

consolidated statements of comprehensive income 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 (as part of comprehensive profit) in the statement of

comprehensive income and the statement 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 statement of comprehensive income and the statement 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 statement 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

statement of comprehensive income.

c. Subsidiaries

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

HOLDINGS

NAME OF COMPANYINCORPORATION20212020

Parent Company

New Zealand general insurance operations

Tower Limited (formerly named Tower Insurance Limited)NZParentParent

Subsidiaries

Overseas general insurance operations

Tower Insurance (Cook Islands) LimitedCook Islands100%100%

Tower Insurance (Fiji) LimitedFiji100%100%

Tower Insurance (PNG) LimitedPNG100%100%

National Pacific Insurance Limited (NPI)Samoa71%71%

Tower Insurance (Vanuatu) LimitedVanuatu100%100%

Management service operations

Tower Services LimitedNZ100%100%

TOWER LIMITED ANNUAL REPORT 2021 34TOWER LIMITED ANNUAL REPORT 202135NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

1.3 Critical accounting judgements and estimates
In preparing these financial statements, management is required to make estimates and related assumptions about the future. The estimates and related

assumptions are based on experience and other factors that are considered to be reasonable, and are reviewed on an ongoing basis. Revisions to the

estimates are recognised in the period in which they are revised, or future periods if relevant. The key areas in which estimates and related assumptions

are applied are as follows:

—Net outstanding claims note 2.4

—Liability adequacy test note 2.5

—Intangible assets note 6.2

—Lease liabilities (incremental borrowing rate) note 6.3a(ii)

—Deferred taxation note 7.3

—Software-as-a-service arrangements note 8.7a

COVID-19 Pandemic

An assessment of the impact of COVID-19 on Tower's balance sheet is set out below based on information available at the time of preparing these

financial statements.

BALANCE SHEETIMPACT

InvestmentsInvestments are carried at fair value and reflect a lower interest rate environment.

ReceivablesImmaterial impact. Provision for impairment of premium receivables and "other recoveries" has been updated to

include an allowance for increased non-payment.

Right of Use AssetsTower has assessed that there is no material impairment to right of use assets.

Intangible assets No impact. Tower has assessed that its intangible assets have not been impaired.

Deferred acquisition costs

(DAC)

Writedown in DAC due to deficiency reported as a result of the Liability Adequacy Test, partially influenced by

higher claims costs driven by covid-related inflationary pressures.

Unearned premiumsImmaterial impact. Provision for unearned premium cancellation has been updated to include an allowance for

increased non-payment.

Net outstanding claimsImpacts on the quantum of outstanding claims due to supply chain delays and lockdown both slowing the

settlement of claims and, therefore, increasing outstanding balances. An additional risk margin has also been

established, partially to allow for additional uncertainty in the post-covid environment.

RBNZ continues to engage with Tower on its response to COVID-19 and the sufficiency of its capital position. This is part of an ongoing sector-wide

regulatory engagement in response to COVID-19 focused on financial stability, and operational changes/decisions that have customer impacts.

1.4 Segmental reporting

a. Operating segments

Tower operates in two geographical segments, New Zealand and the Pacific region. New Zealand comprises the general insurance business

underwritten in New Zealand. Pacific Islands comprises the general insurance business underwritten in the Pacific by Tower subsidiaries and branch

operations. Other contains balances relating to Tower Services Limited (management services entity), and also includes intercompany eliminations and

group diversification benefits.

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

1.4 Segmental reporting (continued)

b. Financial performance

NEW ZEALAND

$000

PACIFIC ISLANDS

$000

OTHER

$000

TOTAL

$000

Year Ended 30 September 2021

Gross written premium351,058 53,623 – 404,681

Gross earned premium – external340,568 54,962 – 395,530

Outwards reinsurance expense(44,918)(17,309) – (62,227)

Net earned premium295,650 37,653 – 333,303

Net claims expense(195,343)(8,836)(89)(204,268)

Net commission expense(9,762)(1,543) – (11,305)

Underwriting expense(76,519)(13,232) – (89,751)

Underwriting profit14,026 14,042 (89)27,979

Net investment income44 152 – 196

Other expenses182 93 – 275

Profit before tax14,252 14,287 (89)28,450

Profit after tax8,855 10,533 (73)19,315

Year Ended 30 September 2020

Gross written premium317,478 59,681 – 377,159

Gross earned premium – external311,671 60,881 – 372,552

Outwards reinsurance expense(38,774)(18,446) – (57,220)

Net earned premium272,897 42,435 – 315,332

Net claims expense(162,032)(19,361)337 (181,056)

Net commission expense(12,027)(2,463) – (14,490)

Underwriting expense(76,323)(13,197) – (89,520)

Underwriting profit22,515 7,414 337 30,266

Net investment income4,265 769 310 5,344

Impairment of EQC receivable(13,126) – – (13,126)

Other expenses(286)62 (3,580)(3,804)

Profit before tax13,368 8,245 (2,933)18,680

Profit after tax8,776 4,789 (2,355)11,210

c. Financial position

NEW ZEALAND

$000

PACIFIC ISLANDS

$000

OTHER

$000

TOTAL

$000

Total assets 30 September 2021707,368 105,561 (10,616)802,313

Total assets 30 September 2020529,370 105,376 105,492 740,238

Total liabilities 30 September 2021401,523 51,688 (618)452,593

Total liabilities 30 September 2020336,192 61,096 904 398,192

Definition

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 (the Chief Executive Officer) who reviews the operating results on a regular basis and makes decisions on resource

allocation and assessing performance.

TOWER LIMITED ANNUAL REPORT 2021 36TOWER LIMITED ANNUAL REPORT 202137NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

2. UNDERWRITING ACTIVITIES
This section provides information on Tower's underwriting activities.

Tower collects premiums from customers in exchange for providing insurance coverage. 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.

2.1 Underwriting revenue

Composition

2021

$000

2020

$000

Gross written premium 404,681 384,359

Motor premium refund – (7,200)

Movement in unearned premium liability(9,151)(4,607)

Gross earned premium 395,530 372,552

Reinsurance and other recoveries revenue 24,635 25,711

Reinsurance commission 5,635 5,242

Insurance administration services commission1,118 1,215

Commission revenue6,753 6,457

Underwriting revenue 426,918 404,720

In the year ended 30 September 2020, Tower received lower motor vehicle claims in New Zealand due to travel restrictions imposed during the time spent in New Zealand government’s

COVID-19 alert level 3 and 4. On 21st April 2020 Tower Limited committed to returning the benefit of lower New Zealand motor claims to customers through motor vehicle premium refunds.

Total premiums of $7.2m (excluding GST) were refunded to motor customers related to the year ended 30 September 2020. Gross Written Premiums were reduced accordingly and a provision

created (see note 2.9) to recognise this obligation.

Recognition and measurement

Gross earned premium is recognised in the period in which the premiums are earned during the term of the contract, excluding taxes and levies

collected on behalf of third parties. It includes a provision for expected future premium cancellations (which is offset against net premium

receivables, see note 2.7) and customer premium refunds (see note 2.9 for more information). The proportion of premiums not earned in the

consolidated statement of comprehensive income at reporting date is recognised in the consolidated balance sheet as unearned premiums.

Reinsurance and other recoveries on paid claims, reported claims not yet paid, claims incurred but not reported and claims incurred but not

enough reported are recognised as revenue. Recoveries are measured as the expected future receipts and recognised when the claim is incurred.

Reinsurance commission revenue includes reimbursements by reinsurers to cover part of Tower's management and sales expense which are

broadly recognised with the reference premium over the term of the reinsurance agreements. Reinsurance commission income can also include a

proportion of expected profitability of business ceded to the reinsurer. The final value of the variable commission is based on the achievement of a

hurdle rate over time. This revenue is recognised on a systematic basis and reassessed at each reporting date.

Insurance administration services commission includes a percentage of levies collected on behalf of third parties and is recognised at the point

the levy is collected.

2.2 Net claims expense

Composition

EXC. CANTERBURY EARTHQUAKECANTERBURY EARTHQUAKETOTAL

2021

$000

2020

$000

2021

$000

2020

$000

2021

$000

2020

$000

Gross claims expense228,594 201,943 309 4,824 228,903 206,767

Reinsurance and other recoveries revenue(23,430)(24,698)(1,205)(1,013)(24,635)(25,711)

Net claims expense205,164 177,245 (896)3,811 204,268 181,056

Recognition and measurement

Net claims expense is measured as the difference between net outstanding claims liability at the beginning and end of the financial year plus any

claims payments made net of reinsurance and other recoveries received during the financial year. Please refer to note 2.4 for more information.

Additional disclosures related to the Canterbury earthquake events in 2010 and 2011 are provided in note 2.4.

2.3 Underwriting expense

Composition

2021

$000

RESTATED

2020

$000

People costs65,042 72,635

People costs capitalised during the year(3,569)(2,933)

Technology 14,326 17,383

Amortisation 12,556 9,705

Depreciation4,712 4,590

External fees10,375 7,137

Marketing8,518 8,181

Communications4,007 3,691

Miscellaneous1,090 (522)

Movement in indirect deferred acquisition costs892 (1,416)

Claims-related management expenses reclassified to claims expense(28,198)(28,931)

Underwriting expenses89,751 89,520

Includes $2.4m (2020: $2.6m) of depreciation on right of use assets. See note 6.3b for further information.

TOWER LIMITED ANNUAL REPORT 2021 38TOWER LIMITED ANNUAL REPORT 202139NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

2.4 Net outstanding claims
a. Composition

EXC. CANTERBURY EARTHQUAKECANTERBURY EARTHQUAKETOTAL

2021

$000

2020

$000

2021

$000

2020

$000

2021

$000

2020

$000

Central estimate of future cash flows87,535 65,475 16,402 21,236 103,937 86,711

Claims handling expense5,430 4,151 1,314 1,908 6,744 6,059

Risk margin6,724 4,325 4,933 10,652 11,657 14,977

Gross outstanding claims99,689 73,951 22,649 33,796 122,338 107,747

Reinsurance recoveries(18,970)(9,643)(3,880)(3,246)(22,850)(12,889)

Net outstanding claims80,719 64,308 18,769 30,550 99,488 94,858

Net claim payments within 12 months69,687 56,110 7,508 12,220 77,195 68,330

Net claim payments after 12 months11,032 8,198 11,261 18,330 22,293 26,528

Net outstanding claims80,719 64,308 18,769 30,550 99,488 94,858

Includes nil additional (2020: $5.0m) for the Canterbury earthquake over and above the provision of the Appointed Actuary, which is set at the 75th percentile of sufficiency.

The $5.0m has been released as the Canterbury outstanding claims liability has sufficiently run off.

b. Reconciliation of movements in net outstanding claims liability

2021

$000

2020

$000

GROSSREINSURANCENETGROSSREINSURANCENET

Balance brought forward107,747 (12,889)94,858 124,060 (13,457)110,603

Claims expense – current year234,675 (22,171)212,504 209,766 (26,084)183,682

Claims expense – prior year(5,772)(2,464)(8,236)(2,999)373 (2,626)

Incurred claims recognised in the consolidated

statement of comprehensive income

228,903 (24,635)204,268 206,767 (25,711)181,056

Claims paid and reinsurance and other

recoveries raised

(213,350)14,397 (198,953)(223,654)26,444 (197,209)

Foreign exchange(962)277 (685)573 (165)408

Outstanding claims122,338 (22,850)99,488 107,747 (12,889)94,858

2.4. Net outstanding claims (continued)

c. 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

2017

$000

2018

$000

2019

$000

2020

$000

2021

$000

TOTAL

$000

At end of incident year138,574 148,088 146,873 157,845 183,450

One year later140,610 145,887 143,975 154,459 –

Two years later141,989 145,763 143,121 – –

Three years later142,280 145,344 – – –

Four years later142,701 – – – –

Ultimate claims cost142,701 145,344 143,121 154,459 183,450

Cumulative payments(141,779)(144,586)(141,541)(149,522)(123,772)

Undiscounted central estimate13,212 922 758 1,580 4,937 59,678 81,087

Claims handling expense6,744

Risk margin11,657

Net outstanding claim liabilities99,488

Reinsurance recoveries22,850

Gross outstanding claim liabilities122,338

Prior year numbers have been restated at current year exchange rates to reflect the underlying development of claims.

d. Actuarial information

The estimation of outstanding claims as at 30 September 2021 has been carried out by:

(i) Geoff Atkins, BA (ActuarDc), FIAA, FIAL, FANZIIF, Appointed Actuary – Canterbury earthquake claims; and

(ii) John Feyter, B.Sc., FNZSA – all other outstanding claims

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 ANNUAL REPORT 2021 40TOWER LIMITED ANNUAL REPORT 202141NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

2.4. Net outstanding claims (continued)
e. Canterbury earthquakes

Cumulative impact of Canterbury earthquakes

As at 30 September 2021, Tower has 33 claims remaining to settle (2020: 59) as a result of the earthquakes impacting the Canterbury region during

2010 and 2011. The following table presents the cumulative impact of the four main Canterbury earthquake events on the consolidated statement of

comprehensive income. Figures include the EQC settlement which has been received at 30 September 2021.

2021

$000

RESTATED

2020

$000

Earthquake claims estimate net of EQC payments(944,418)(939,109)

Reinsurance recoveries732,090 730,885

Claim expense net of reinsurance recoveries(212,328)(208,224)

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

Additional risk margin – (5,000)

Cumulative impact of Canterbury earthquakes before tax(237,373)(238,269)

Income tax66,464 66,715

Cumulative impact of Canterbury earthquakes after tax(170,909)(171,554)

Canterbury earthquake impact on profit or loss

2021

$000

2020

$000

Net claims (gain)/expense (896)3,811

Recognition and measurement

Gross outstanding claims liability comprises a central estimate of future cash outflows and a risk margin for uncertainty. Tower has not applied a

discount given the short-tail nature of the portfolio and the low interest rate environment.

The outstanding claims liability is measured at the central estimate of future cash outflows relating to claims incurred prior to the reporting date

including direct and indirect claims handling costs. The liability is measured based on the advice of the Appointed Actuary or on valuations which

have been peer reviewed by the Appointed Actuary. It is intended to include no deliberate or unconscious bias toward over or under-estimation.

Given the uncertainty in establishing the liability, it is likely the final outcome will differ from the original liability established. Changes in the claim

estimates are recognised in profit or loss in the reporting period in which the estimates are changed.

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

payments. The risk margin represents the amount by which the liability recognised in the financial statements is greater than the actuarial estimate.

Tower currently applies a 75% probability of adequacy to the outstanding claims liability which means there is a 1-in-4 chance all future claim

payments will exceed the overall reserve held.

Uncertainties surrounding the liability estimation process include those relating to the available data, actuarial models and assumptions, the

statistical uncertainty associated with the general insurance run-off process and external risks.

Net outstanding claims liability is calculated by deducting reinsurance and other recoveries from gross outstanding claims. Reinsurance and other

recoveries on outstanding claims are recognised as income with the corresponding asset being recognised on the balance sheet.

2.4. Net outstanding claims (continued)

Critical accounting estimates and judgements

Outstanding claims liability (excluding Canterbury Earthquakes)

The estimation of the outstanding claims liability involves a number of key assumptions. Tower's estimation uses Company specific data, relevant industry

data and general economic data for each major class of business. The estimation process factors in a number of considerations including the risks to

which the business is exposed to at a point in time, claim frequency and severity, historical trends in the development of claims as well as legal, social

and economic factors that may affect each class of business.

ASSUMPTION20212020

Expected future claims development proportion19.7%50.5%

Claims handling expense ratio6.7%7.1%

Risk margin9.1%7.2%

Expected future claims development proportion

This is the proportion of additional claims cost that is expected to be recognised in the future for BAU claims that have already been reported.

The assumption is expressed as a proportion of current case estimates for open claims and the resulting amount is recognised in the balance sheet as an

outstanding claims liability. The reduction in the expected future claims proportion has arisen following a change in case estimation process in the year

ended 30 September 2021.

Claims handling expense ratio

This reflects the expected cost to administer future claims. The ratio is calculated based on historical experience of claims handling costs.

Risk margin

Risk margins are calculated for outstanding claims in each country separately and a diversification benefit is calculated taking into account the

uncorrelated effect of random risk. The total risk margin percentage shown is calculated on a weighted average basis. The increase in the risk margin this

year reflects the heightened uncertainty on claim outcomes as a result of the COVID-19 pandemic.

Canterbury earthquake outstanding claims liability

Assumptions are made for the estimation of outstanding claims related to the Canterbury earthquakes. The key assumptions are estimated ultimate

costs (including building costs) for settling open claims, and the numbers of new overcap claims, litigated claims, re-opened claims and their associated

costs. Other elements of judgement include the apportionment of claim costs between the four main earthquake events, future claim management

expenses and assessment of the risk margin.

ASSUMPTION

2021

$000

2020

$000

Number of new overcap and new litigated claims 38 68

Average cost of new overcap or new litigated claim $121,000 $107,000

Provision for re-opened claims $2,400,000 $2,800,000

New overcap and new litigated claims

New overcap claims are typically for properties that have previously been managed by EQC but where damage is now assessed as being more extensive

than previously thought and there is now an insurance claim payable.

New litigated claims are existing or future new claims that are referred to either the Insurance Tribunal or the High Court for resolution. Costs for new

litigated claims are assumed to be substantially higher than costs for other overcap claims. Only a small number of new litigated claims is now expected.

Provision for re-opened claims

Re-opened claims arise where additional liability arises for additional scope not previously identified or where a repair has failed or where another

expense is payable for a claim that is currently closed.

TOWER LIMITED ANNUAL REPORT 2021 42TOWER LIMITED ANNUAL REPORT 202143NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

2.4. Net outstanding claims (continued)
f. Sensitivity analysis

The impact on profit or loss of changes in key assumptions used in the calculation of the outstanding claims liabilities is summarised below. Each change

has been calculated in isolation from the other variables and is stated before income tax.

Outstanding claims excluding Canterbury earthquake

MOVEMENT IN

ASSUMPTION

IMPACT ON PROFIT OR LOSS

2021

$000

2020

$000

Expected future claims development + 10%1,339 1,771

- 10%(1,339)(1,771)

Claims handling expense ratio + 10%543 415

- 10%(543)(415)

Risk margin + 10%

672 431

- 10%(672)

(431)

Canterbury earthquake outstanding claims

MOVEMENT IN

ASSUMPTION

IMPACT ON PROFIT OR LOSS

2021

$000

2020

$000

Number of new overcap or new litigated claims + 35%(1,610)(2,560)

- 35%1,610 2,560

Change in average cost of a new overcap or new litigated claim+ 20%(920)(1,460)

- 20%920 1,460

Number of reopened claims + 35%(840)(980)

- 35%840 980

Change in average cost of a reopened claim + 20%(480)(560)

- 20%480 560

2.5 Unearned premium liability

Reconciliation

2021

$000

2020

$000

Opening balance 203,452 187,855

Premiums written during the year 404,681 377,159

Premiums earned during the year(395,530)(372,552)

Unearned premium movement9,1514,607

Unearned premium balance purchased – 12,003

Foreign exchange movements(328)(1,013)

Unearned premium liability 212,275 203,452

Unearned premium balance acquired through the purchase of customer relationships in the year ended 30 September 2020 (see note 6.2).

The majority of unearned premiums will be earned in the 12 months after 30 September 2021 and therefore are current liabilities. The unearned premium

liability is presented net of cancellation provisions.

2.5 Unearned premium liability (continued)

Recognition and measurement

Unearned premium liability is the portion of premiums written that are yet to be earned in the consolidated statement of comprehensive income.

It is calculated based on the term of the risk and in accordance with the expected pattern of the incidence of risk underwritten using an appropriate

pro-rate method.

Adequacy of unearned premium liability

Tower undertakes a liability adequacy test ("LAT") to determine whether the unearned premium liability is sufficient to pay future claims net of

reinsurance recoveries.

If the present value of expected future net cash flows relating to current insurance contracts, plus a risk margin, exceeds the unearned premium

liabilities less related deferred acquisition costs and intangible assets, then the unearned premium liability is deemed deficient. This deficiency is

immediately recognised in profit or loss. In recognising the deficiency, Tower will first write down any related deferred acquisition costs or intangible

assets before recognising an unexpired risk liability.

The unearned premium liability as at 30 September 2021 was not sufficient for the New Zealand business and a deficiency of $2.0m was recognised

(2020: no deficiency). The unearned premium liabilities for Pacific entities were sufficient with the exception of Fiji and Vanuatu (2020: Fiji, NPI and

Vanuatu) where small deficits were recognised. The total deficit for the group recognised as a charge against deferred acquisition cost was $2.5m

(2020: $0.4m).

%20212020

Central estimate net claims as a % of unearned premium liability45.2%44.5%

Risk margin as a % of net claims11.0%10.2%

Critical accounting estimates and judgements

The LAT is conducted using a central estimate of premium liability adjusted for risk margin and it is carried out on an individual country basis.

The test is based on prospective information and so is heavily dependent on assumptions and judgements.

2.6 Deferred insurance costs

Reconciliation

DEFERRED ACQUISITION COSTS

DEFERRED OUTWARDS

REINSURANCE EXPENSEDEFERRED INSURANCE COSTS

2021

$000

2020

$000

2021

$000

2020

$000

2021

$000

2020

$000

Balance bought forward25,22023,7369,4478,79434,66732,530

Costs deferred40,32342,13617,96815,39658,29157,532

Amortisation expense(41,897)(40,221)(16,428)(14,586)(58,325)(54,807)

Writedown due to LAT deficiency(2,534)(440) – – (2,534)(440)

Foreign exchange movements49(136)(157)(132)(148)

Closing balance21,11625,22010,8519,44731,96734,667

Deferred insurance costs are expected to be amortised within 12 months from reporting date.

TOWER LIMITED ANNUAL REPORT 2021 44TOWER LIMITED ANNUAL REPORT 202145NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

2.6 Deferred insurance costs (continued)
Recognition and measurement

Acquisition costs comprises costs incurred in obtaining and recording general insurance contracts such as advertising expenses, sales expenses

and other underwriting expenses. These costs are initially capitalised and then expensed in line with the earning pattern of the related premium.

Deferred acquisition costs at the reporting date represent the acquisition costs related to unearned premium.

Outwards reinsurance expense reflects premiums ceded to reinsurers and is recognised as an expense in accordance with the pattern of

reinsurance service received. Deferred outwards reinsurance expense at the reporting date represents outwards reinsurance expenses related to

unearned premium.

2.7 Receivables

Composition

2021

$000

2020

$000

Gross premium receivables

177,141 171,041

Provision for impairment

(655)

(1,383)

Premium receivable176,486 169,658

Business as usual reinsurance recoveries 20,326 15,105

Canterbury earthquake reinsurance recoveries

3,880 3,246

Other recoveries

5,208

5,262

Reinsurance and other recoveries29,414 23,613

EQC receivable523 52,883

Finance lease receivables4,278 –

Prepayments3,279 2,664

Miscellaneous receivables1,873 1,928

Receivables215,853 250,746

Receivable within 12 months213,432 250,746

Receivable in greater than 12 months2,421 –

Receivables215,853 250,746

The EQC receivable for 2021 does not relate to the historic Canterbury earthquakes (CEQ) receivable settled during the period. This receivable relates to non-CEQ receivables.

Recognition and measurement

Receivables (inclusive of GST) are recognised at fair value and are subsequently measured at amortised cost less any impairment.

Tower's premium receivables and reinsurance and other recoveries arise from insurance contracts. These receivables are impaired if there is

objective evidence that Tower will not be able to collect all amounts due according to the original terms of the receivable.

The remainder of Tower's receivables are assessed for impairment based on expected credit losses. The EQC receivable is the only material item

that falls into this category and is discussed further in the sub-note below.

EQC recovery receivable related to Canterbury earthquakes

During the year Tower received $52.9m (excluding GST) in a full and final settlement agreement with EQC regarding the recovery of claims costs related

to the 2010 and 2011 Christchurch earthquakes during the period. Tower fully reimbursed amounts payable to reinsurers of $10.7m and settled other

outstanding costs during the period. Tower's net proceeds from this settlement were $42.1m.

There was nil impairment expense in the year ended 30 September 2021 (2020: $13.1m).

2.7 Receivables (continued)

Finance lease receivables

Tower entered a sub-lease for its previous Auckland premises. The sub-lease is for the remaining non-cancellable term of the head lease and therefore

is classified as a finance lease. The profile of the net receipts is illustrated in the table below:

2021

$000

2020

$000

Less than one year 2,019 –

Between one and five years 2,421 –

More than five years – –

Total undiscounted finance lease receivable 4,440 –

Unearned finance income(162) –

Net investment in the finance lease 4,278 –

2.8 Payables

Composition

2021

$000

2020

$000

Trade payables 10,380 13,527

GST payable 23,264 20,519

EQC receivable payable to reinsurers –10,741

EQC & Fire and Emergency New Zealand levies payable 10,857 11,068

Reinsurance premium payable 6,343 3,414

Unsettled investment purchases 11,456 –

Other 6,605 7,331

Payables 68,905 66,600

Payable within 12 months 68,905 66,600

Payable in greater than 12 months – –

Payables 68,905 66,600

Recognition and measurement

Payables are recognised where goods or services that have been received or supplied and have been invoiced or formally agreed with the

supplier. Payables are stated at the fair value of the consideration to be paid in the future inclusive of GST. GST payable represents the net amount

payable to the respective tax authorities.

TOWER LIMITED ANNUAL REPORT 2021 46TOWER LIMITED ANNUAL REPORT 202147NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

2.9 Provisions
Composition

2021

$000

2020

$000

Annual leave and other employee benefits 6,709 6,901

Customer premium refunds – 2,422

Other – 208

Provisions 6,709 9,531

Payable within 12 months 6,235 9,157

Payable in greater than 12 months 474 374

Provisions 6,709 9,531

Recognition and measurement

Tower recognises a provision when it has a present obligation as a result of a past event and it is more likely than not that an outflow of resources

will be required to settle the obligation. Tower's provision represents the best estimate of the expenditure required to settle the present obligation

at the end of the reporting period.

2.10 Assets backing insurance liabilities

Tower has determined that all assets within its insurance companies are held to back insurance liabilities, with the exception of: (i) property, plant and

equipment; (ii) right of use assets, (iii) intangible assets; and (iv) 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 that basis.

3. INVESTMENTS

Tower invests funds collected as premiums and provided by shareholders to ensure it can meet its obligations to pay claims and expenses and to

generate a return to support its profitability. Tower has a low risk tolerance and therefore the majority of its investments are in investment grade

supranational and government bonds, and term deposits.

3.1 Investment income

2021

$000

2020

$000

Interest income5,148 7,328

Net realised loss(2,152)(1,277)

Net unrealised loss(2,416)(241)

Investment income 580 5,810

Net realised losses relate to the maturity of fixed interest bonds, with interest coupon rates higher than market rates, purchased at higher than face value.

The corresponding higher interest received is reflected in the interest income amount.

Recognition and measurement

Tower's investment income is primarily made up of realised and unrealised interest income on fixed interest investments and fair value gains or

losses on its investment assets. Both are recognised in the period that they are earned through profit or loss.

3.2 Investments

2021

$000

2020

$000

Fixed interest investments277,436 237,298

Equity investment – 572

Property investment34 34

Investments277,470 237,904

Recognition and measurement

Tower's investment assets are designated at fair value through profit or loss. Investment assets are initially recognised at fair value and are remeasured to

fair value through profit or loss at each reporting date. Tower's approach to measuring the fair value of these assets is covered in the following note.

Purchases and sales of investments are recognised at the date which Tower commits to buy or sell the assets (i.e. trade date). Investments are

derecognised when the rights to receive future cash flows from the assets have expired, or have been transferred, and substantially all the risks and

rewards of ownership have transferred.

3.3 Fair value hierarchy

Tower designates its investments at fair value through profit or loss in accordance with its Treasury Policy. It categorises its investments into three levels

based on the inputs available to measure fair value:

Level 1 Fair value is calculated using quoted prices in active markets. Tower currently does not have any Level 1 investments.

Level 2 Investment valuations are based on direct or indirect observable data other than quoted prices included in Level 1. Level 2 inputs include: (1)

quoted prices for similar assets or liabilities; (2) quoted prices for assets or liabilities that are not traded in an active market; or (3) other

observable market data that can be used for valuation purposes. Tower investments included in this category include government and

corporate debt, where the market is considered to be lacking sufficient depth to be considered active, and part ownership of a property that

is rented out to staff.

Level 3 Investment valuation is based on unobservable market data. Tower's equity investment in the unlisted reinsurance company Pacific Re was the

only investment in this category. Tower sold the investment to a third party in November 2020 at the carrying value as at 30 September 2020.

LEVEL 1

$000

LEVEL 2

$000

LEVEL 3

$000

TOTAL

$000

As at 30 September 2021

Fixed interest investments – 277,436 – 277,436

Equity investment – – – –

Property investment – 34 – 34

Investments – 277,470 – 277,470

As at 30 September 2020

Fixed interest investments – 237,298 – 237,298

Equity investment – – 572 572

Property investment – 34 – 34

Investments – 237,332 572 237,904

There have been no transfers between levels of the fair value hierarchy during the current financial period (2020: nil).

TOWER LIMITED ANNUAL REPORT 2021 48TOWER LIMITED ANNUAL REPORT 202149NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

4. RISK MANAGEMENT
Tower is exposed to multiple risks as it works to set things right for its customers and their communities whilst maximising returns for its

shareholders. Everyone across the organisation is responsible for ensuring that Tower's risks are managed and controlled on a day-to-day basis.

4.1 Risk management overview

Tower’s approach to achieving effective risk management is to embed a risk-aware culture where everyone across the organisation (including

contractors and third parties) is responsible for managing risk.

Tower’s Board expresses its appetite for risk in a Risk Appetite Statement, which:

(i) Gives clear concise guidance to management of parameters for risk taking.

(ii) Embeds risk management into strategic and decision-making processes.

(iii) Facilitates risk to be managed at all levels of the organisation through a structured process to identify risk, and the allocation of clear, personal

responsibility for management of identified risks by assigned risk owners.

The Board then approves and adopts: (i) the Risk Management Programme (RMP) which is the central document that explains how Tower effectively

manages risk within the business; and (ii) the Reinsurance Management Strategy (ReMS) which describes the systems, structures, and processes which

collectively ensures Tower's reinsurance arrangements and operations are prudently managed. These documents are approved annually by the Board.

The Board has delegated its responsibility to the Risk Committee to provide oversight of risk management practices and provide advice to the Board and

management when required. In addition, the Risk Committee also monitors the effectiveness of Tower’s risk management function which is overseen by

the Chief Risk Officer (CRO). The CRO provides regular reports to the Risk Committee on the operation of the Risk Management Framework (RMF), the

status of material risks, risk and compliance incidents and risk framework changes.

Tower has embedded an RMF with clear accountabilities and risk ownership to ensure that Tower identifies, manages, mitigates and reports on all key

risks and controls through the three lines of defence model.

(i) First line: Operational management has ownership, responsibility and accountability for directly identifying, assessing, controlling and mitigating key

risks which prevent them from achieving business objectives.

(ii) Second Line: Tower’s Risk and Compliance Functions are responsible for developing and implementing effective risk and compliance management

processes; providing advisory support to the first line of defence and constructively challenging operational management and risk and obligation

owners to ensure positive assurance.

(iii) Third line: Internal audit is responsible and accountable for providing an independent and objective view of the adequacy and effectiveness of the

Group’s risk management, governance and internal control framework. Internal audit, along with other groups such as external audit, report

independently to the Board and/or the Audit Committee.

The RMF is supported by a suite of policies that address the risks and compliance obligations covered in this section.

4.2 Strategic risk

Strategic risk is the risk that internal or external factors compromise Tower's ability to execute its strategy or achieve its strategic objectives. Strategic risk

is managed through:

(i) Monitoring and managing performance against Board-approved plan and targets.

(ii) Board leading an annual strategy and planning process which considers our performance, competitor positioning and strategic opportunities.

(iii) Identifying and managing emerging risks using established governance processes and forums.

4.3 Insurance risk

Insurance risk is the risk that for any class of risk insured, the present value of actual claims payable will exceed the present value of actual premium

revenues generated (net of reinsurance). This risk is inherent in Tower's operations and arises and manifests through underwriting, insurance

concentration and reserving risk.

a. Underwriting risk

Underwriting risk refers to the risk that claims arising are higher (or lower) than assumed in pricing due to bad experience including catastrophes,

weakness in controls over underwriting or portfolio management, or claims management issues. Tower has established the following key controls to

mitigate this risk:

(i) Use of comprehensive management information systems and actuarial models to price products based on historical claims frequencies and claims

severity averages, adjusted for inflation and modelled catastrophes, trended forward to recognise anticipated changes in claims patterns after

making allowance for other costs incurred by the Group.

(ii) Passing elements of insurance risk to reinsurers. Tower's Board determines a maximum level of risk to be retained by the Group as a whole.

Tower's reinsurance programme is 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.

(iii) Underwriting limits are in place to enforce appropriate risk selection criteria and pricing with specific underwriting authorities that set clear

parameters for the business acceptance.

b. Concentration risk

Concentration risk refers to the risk of underwriting a number of like risks, where the same or similar loss events have the potential to produce claims

from many of Tower's customers at the same time. Tower is particularly subject to concentration risks in the following variety of forms:

(i) Geographic concentration risk – Tower purchases a catastrophe reinsurance programme to protect against a modelled 1-in-1000 years whole of

portfolio catastrophe loss. In addition it takes out additional aggregate reinsurance cover for large events which fall outside the catastrophe

reinsurance programme and tends to cover weather events in New Zealand and across the Pacific.

(ii) Product concentration risk – Tower's business is weighted towards the NZ general insurance market where its risks are concentrated in house

insurance (Home & Contents) and motor insurance. Tower limits its exposure through proportionate reinsurance arrangements. The table below

illustrates the diversity of Tower's operations.

GROSS WRITTEN PREMIUM (%)

20212020

NZPACIFICTOTALNZPACIFICTOTAL

Home & Contents51%4%55%51%4%55%

Motor33%4%37%30%5%35%

Commercial1%4%5%1%6%7%

Liability1%0%1%1%0%1%

Workers compensation0%1%1%0%1%1%

Other1%0%1%0%1%1%

Total87%13%100%83%17%100%

Tower has limited exposure to long-tail classes (which comprises part of "liability" and "workers compensation"). Long-tail classes have increased

uncertainty of the ultimate cost of claims due to the additional period of time to settlement.

c. Reserving risk

Reserving risk is managed through the actuarial valuation of insurance liabilities and monitoring of the probability of adequacy booked reserves. The

valuation of the net central estimate is performed by qualified and experienced actuaries. The central estimate is subject to a comprehensive review at

least annually.

TOWER LIMITED ANNUAL REPORT 2021 50TOWER LIMITED ANNUAL REPORT 202151NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

4.4 Credit risk
Credit risk is the risk of loss that arises when a counterparty fails to meet their financial obligations to Tower in accordance with the agreed terms. Tower's

exposure to credit risk primarily results from transactions with security issuers, reinsurers and policyholders.

a. Investment and treasury

Tower manages its investment and treasury credit risks in line with limits set by the Board:

(i) New Zealand cash deposits that are internally managed are limited to banks with a minimum Standard & Poor's (S&P) AA- credit rating.

(ii) Cash deposits and investments that are managed by external investment managers are limited to counterparties with a minimum S&P A- credit rating.

(iii) Tower holds deposits and invests in Pacific regional investment markets through its Pacific Island operations to comply with local statutory

requirements and in accordance with Tower investment policies. These deposits and investments generally have low credit ratings representing the

majority of the value included in the 'Below BBB' and unrated categories in the table below. This includes deposits and investments with Australian

bank subsidiaries that comprise 88% (2020: 83%) of the "not rated" category.

CASH AND CASH EQUIVALENTSFIXED INTEREST INVESTMENTSTOTAL

2021

$000

2020

$000

2021

$000

2020

$000

2021

$000

2020

$000

AAA – – 94,430 106,805 94,430 106,805

AA 83,614 55,478 143,548 90,859 227,162 146,337

A

– –

33,100

29,737 33,100

29,737

BBB –

– –


– –

Below BBB 9,173 5,409 2,226 3,456 11,399 8,865

Not rated 23,342 19,221 4,132 6,441 27,474 25,662

Total 116,129 80,108 277,436 237,298 393,565 317,406

b. Reinsurance

Tower manages its reinsurance programme in line with the ReMS. Tower seeks to manage the quantum and volatility of insurance risk in order to reduce

exposure and overall cost.

Tower's policy is to only deal with reinsurers with a credit rating of S&P "A-" or better unless local statutory requirements dictate otherwise. Additional

requirements of the policy are for no individual reinsurer to have more than 25% share of the overall programme and Tower is prohibited from offering

inwards reinsurance to external entities. The following table provides details on Tower's exposure to reinsurance recoveries:

REINSURANCE ON:

OUTSTANDING CLAIMSPAID CLAIMSTOTAL

2021

$000

2020

$000

2021

$000

2020

$000

2021

$000

2020

$000

AAA – – – – – –

AA 12,005 6,738 1,028 3,490 13,033 10,228

A 10,805 6,106 320 1,986 11,125 8,092

BBB – – – – – –

Below BBB – – – – – –

Not rated 40 29 4 2 44 31

Total 22,850 12,873 1,352 5,478 24,202 18,351

4.4 Credit risk (continued)

The following table provides further information regarding the ageing of reinsurance recoveries on paid claims at the balance date.

PAST DUE

NOT DUE

$000

1 MONTH

$000

1 TO 2 MONTHS

$000

2 TO 3 MONTHS

$000

OVER 3 MONTHS

$000

TOTAL

$000

As at 30 September 2021

Reinsurance recoveries on paid claims 1,352 – – – – 1,352

As at 30 September 2020

Reinsurance recoveries on paid claims 5,379 – – – 99 5,478

c. Premium receivable

Tower's premium receivable balance primarily relates to policies which are paid on either a fortnightly or monthly basis. Payment default or policy

cancellation – subject to the terms of the policyholder's contract – will result in the termination of the insurance contract eliminating both the credit risk

and insurance risk.

PAST DUE

NOT DUE

$000

1 MONTH

$000

1 TO 2 MONTHS

$000

2 TO 3 MONTHS

$000

OVER 3 MONTHS

$000

TOTAL

$000

As at 30 September 2021

Net premium receivable 168,843 5,514 1,484 562 83 176,486

As at 30 September 2020

Net premium receivable 162,935 3,705 1,992 986 40 169,658

this includes premiums that are less than 30 days outstanding (which are owed but not past due) of $5.5m (2020: $7.1m).

4.5 Market risk

Market risk is the risk of adverse impacts on investment earnings resulting from changes in market factors. Tower's market risk is predominately as a

result of changes in the value of the New Zealand dollar (currency risk) and interest rate movements. Tower's approach to managing market risk is

underpinned by its Treasury Policy as approved by the Board.

a. Currency risk

Tower's currency exposure arises from the translation of foreign operations into Tower's functional currency (currency translation risk) or due to

transactions denominated in a currency other than the functional currency of a controlled entity (operational currency risk). The currencies giving rise to

this risk are primarily the US dollar, Fijian dollar and Papua New Guinea (PNG) kina.

Tower's principal currency risk is currency translation (where movement impacts equity). Tower generally elects not to hedge this risk as it is difficult given

the size and nature of the currency markets in the Pacific. Tower seeks to minimise its net exposure to foreign operational risk by actively seeking to

return surplus cash and capital to the parent company.

Operational currency risk impacts profit and generally arises from:

(i) Procurement of goods and services denominated in foreign currencies. Tower may enter into hedges for future transactions, using authorised

instruments, provided that the timing and amount of those future transactions can be estimated with a reasonable degree of certainty.

(ii) Investment assets managed by the external investment manager that are denominated in foreign currencies. Tower's Board set limits for the

management of currency risk based on prudent asset management practice. Regular reviews are conducted to ensure that these limits are

adhered to.

TOWER LIMITED ANNUAL REPORT 2021 52TOWER LIMITED ANNUAL REPORT 202153NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

4.5 Market risk (continued)
The following table demonstrates the impact of the New Zealand dollar weakening or strengthening against the most significant currencies for which

Tower has foreign exchange exposure holding all other variables constant.

DIRECT IMPACT ON EQUITYIMPACT ON PROFIT OR LOSS

2021

$000

2020

$000

2021

$000

2020

$000

New Zealand Dollar – USD

Currency strengthens by 10%(581)(407)2317

Currency weakens by 10%710497(28)(20)

New Zealand Dollar – Fijian Dollar

Currency strengthens by 10%(1,667)(1,350)(38)(73)

Currency weakens by 10%2,0371,6504790

New Zealand Dollar – PNG Kina

Currency strengthens by 10%(743)(1,078)3057

Currency weakens by 10%9081,318(36)(70)

b. Interest rate risk

Tower is exposed to interest rate risk through its holdings in interest-bearing assets. Interest-bearing assets with a floating interest rate expose Tower to

cash flow interest rate risk, whereas fixed interest investments expose Tower to fair value interest rate risk.

Tower's interest rate risk primarily arises from fluctuations in the valuation of fixed interest investments recognised at fair value and from the underwriting

of general insurance contracts, which creates exposure to the risk that interest rate movements materially impact the fair value of the insurance liabilities.

Interest rate risk arises to the extent that there is a mismatch which arises between the two.

Fixed interest investments are measured at fair value through profit or loss. Movements in interest rates impact the fair value of interest-bearing financial

assets and therefore impact profit or loss (there is no direct impact on equity). The impact of a 0.5% increase or decrease in interest rates on fixed interest

investments is shown below (holding everything else constant). The assumption made for 0.5% decrease in interest rates is that the lower bound is

capped at 0% as negative rates on fixed interest investments are highly unlikely.

IMPACT ON PROFIT OR LOSS

2021

$000

2020

$000

Interest rates increase by 0.5%(988)(921)

Interest rates decrease by 0.5%960750

Tower manages its interest rate risk through Board-approved investment management guidelines that have regard to policyholder expectations and risks

and to target surplus for solvency as advised by the Appointed Actuary.

4.6 Liquidity risk

Liquidity risk arises where liabilities cannot be met as they fall due as a result of insufficient funds and/or illiquid asset portfolios. Tower mitigates this risk

through maintaining sufficient liquid assets to ensure that it can meet all obligations on a timely basis.

Tower is primarily exposed to liquidity risk through its obligations to make payment for claims of unknown amounts on unknown dates. Fixed interest

investments can generally be readily sold or exchanged for cash to settle claims and are managed in accordance with the policy of broadly matching the

overall maturity profile to the estimated pattern of claim payments. This is illustrated in the table below.

NET OUTSTANDING CLAIMS LIABILITYCASH AND INVESTMENTS

2021

$000

2020

$000

2021

$000

2020

$000

Floating interest rate (at call) – – 116,217 80,108

Within 3 months 42,949 32,943 75,129 36,982

3 to 6 months 17,070 15,140 31,890 53,797

6 to 12 months 17,176 20,246 47,381 55,352

After 12 months 22,293 26,529 122,948 91,167

Total 99,489 94,858 393,565 317,406

4.7 Capital management risk

Capital risk is the risk that capital is insufficient or not of the best form to provide a buffer against losses arising from unanticipated events, while also

maximising the efficient use of capital with a view to enhancing growth and returns and adding long-term value to Tower's shareholders.

Tower has a documented description of its capital management process which sets out Tower's principles, approaches, and processes in relation to

capital management that enables it to operate at an appropriate level of target solvency capital which is within the bounds of Tower's risk appetite.

The capital management process allows the Board, management, rating agencies and the regulator to understand Tower's approach to capital

management, including requirements for formulating capital targets, and monitoring, reporting and remediating capital as required.

The operation of the capital management process is reported annually to the Board, together with a forward-looking estimate of expected capital

utilisation and capital resilience. In addition, Tower carries out stress, reverse stress and scenario testing to ensure the level of capital is appropriate given

its risk appetite.

In October 2020, the Reserve Bank of New Zealand (RBNZ) commenced consultation on a review of the Insurance (Prudential Supervision) Act 2010. The

consultation process is expected to continue through to 2022. Tower has actively participated in the consultation to date, with an ongoing assessment of

the impacts to solvency being performed as information becomes known. As part of the overall process, the RBNZ issued an exposure draft on an interim

solvency standard (ISS) in July 2021 which anticipates the introduction of IFRS 17 during the consultation period. This draft ISS: combines requirements for

life and non-life insurers, which were previously separate standards; proposes enhancements to the transparency of solvency reporting; provides for

increased prudential supervision for insurers operating close to their minimum solvency margin; and imposes changes that would reduce solvency

margins, such as the introduction of an operational risk capital charge. In October 2021, the RBNZ advised that the effective date of the ISS would be

deferred until 2023, and that the feedback received would likely require some changes to the ISS. Tower considers it is not yet possible to provide a

reasonable estimate of the impact of changes to its solvency position from the ISS, as the ISS has not been finalised, the RBNZ has stated that it will

change, and a lack of clarity in certain areas of the draft ISS means that there are different possible interpretations as to the potential impact.

a. Regulatory solvency capital

The Reserve Bank of New Zealand (RBNZ) is the prudential regulator and supervisor of all insurers carrying on insurance business in New Zealand, and is

responsible for administering the Insurance (Prudential Supervision) Act 2010. Tower measures the adequacy of capital against the Solvency Standards

for Non-life Insurance Business published by the RBNZ alongside additional capital held to meet RBNZ minimum requirements and any further capital as

determined by the Board.

Foreign operations are subject to regulatory oversight in the relevant jurisdiction. It is Tower's policy to ensure that each of the licenced insurers in the

Group maintain an adequate capital position within the requirements of the relevant regulator.

During the year ended 30 September 2021, the Group complied with all externally imposed capital requirements (2020: complied).

TOWER LIMITED ANNUAL REPORT 2021 54TOWER LIMITED ANNUAL REPORT 202155NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

4.7 Capital management risk (continued)
During the year RBNZ reduced Tower’s required minimum solvency margin, via a license condition, to $25.0m (2020: $50.0m). Tower Limited's Group and

Parent solvency margin are illustrated in the table below.

2021

$000

2020

$000

PARENTGROUPPARENTGROUP

Actual solvency capital 179,439 214,128 150,451 181,214

Minimum solvency capital 66,252 79,927 52,342 65,728

Solvency margin 113,187 134,201 98,109 115,486

Solvency ratio271%268%287%276%

The solvency presented as of 30 September 2021 does not reflect any possible change to solvency as a result of the RBNZ's Insurance (Prudential

Supervision) Act 2010 review. Policy changes and legislative reforms as a result of this review are expected to come into legislation in 2023 – 2024.

b. Capital composition

The balance sheet capital mix at reporting date is shown in the table below:

2021

$000

RESTATED

2020

$000

Total shareholder equity 347,044 339,886

Total 347,044 339,886

c. Financial strength rating

Tower Limited has an insurer financial strength rating of "A- (Excellent)" and a long-term issuer credit rating of "A-" as affirmed by international rating

agency AM Best Company Inc. with an effective date of 23 April 2021.

4.8 Operational risk

Operational risk is the risk of loss due to inadequate or failed internal processes or systems, human error or from external events.

Tower's approach is to proactively manage our operational risks to mitigate potential customer detriment, regulatory or legal censure, financial and

reputational impacts.

Tower has in place appropriate operational processes and systems, including prevention and detection measures. These include processes which seek

to ensure Tower can absorb and/or adapt to internal or external occurrences that could disrupt business operations.

Management and staff are responsible for identifying, assessing and managing operational risks in accordance with their roles and responsibilities.

Failures in controls are recorded and then actively monitored and managed. Incidents are managed by the first line of defence and overseen by the

second line of defence, with ongoing reporting to management and the Board Risk Committee.

4.9 Regulatory and compliance risk

Regulatory and compliance risk is defined as the risk of legal, regulatory or reputational impacts arising from failure to manage compliance obligations,

or failure to anticipate and prepare for changes in the regulatory environment.

Tower engages with regulators and regularly monitors developments in regulatory requirements to support ongoing compliance.

4.10 Conduct risk

Conduct risk is defined as the risk that conduct may contribute to poor outcomes for customers.

Tower manages Conduct risk through a number of measures including undertaking ongoing product reviews to ensure products are delivering good

customer outcomes, reviewing customer feedback to identify conduct trends or issues, managing vulnerable customers, holding workshops with

frontline staff to identify potential conduct issues and embedding and monitoring controls across the business to deliver good customer outcomes.

There is robust governance in place to oversee Tower's conduct risk management programme including reporting to the Management and Board

Committees.

4.11 Cyber risk

Cyber risk is any risk associated with financial loss, disruption or damage to the reputation of Tower resulting from either the failure, or unauthorised or

erroneous use of its information systems.

Tower’s approach to Cyber risk is to proactively protect against, monitor for and respond to those cyber threats seen to be targeting the organisation.

Tower continues to monitor evolving key cyber risks, which are being discussed and reviewed on a monthly basis through our Management Risk and

Conduct Committee and on a quarterly basis with the Risk and Audit Committee. Risk mitigation is achieved through ongoing investment in Tower’s

Security programme and Tower’s dedicated security function.

5. CAPITAL STRUCTURE

This section provides information about how Tower finances its operations through equity. Tower's capital position provides financial security to its

customers, employees and other stakeholders whilst operating within the capital requirements set by regulators.

5.1 Borrowings

There were no new short term cash advances during the year ended 30 September 2021. The previous facility agreement with a limit of $15m with Bank

of New Zealand expired on 30 September 2020.

Total borrowing costs for the year were nil (2020: $0.8m, none of which were capitalised).

5.2 Contributed equity

2021

$000

2020

$000

Opening balance492,424 209,990

Issue of share capital – 45,000

Cancellation of shares on amalgamation – (254,990)

Recognition of shares on amalgamation – 492,424

Total contributed equity492,424 492,424

Represented by:

Opening balance421,647,258 211,107,758

Issued shares – 45,000,000

Cancellation of shares on amalgamation – (256,107,758)

Recognition of shares on amalgamation – 421,647,258

Total shares on issue421,647,258 421,647,258

On 30 September 2020, Tower Insurance Limited was renamed Tower Limited (the Company) and was amalgamated by way of a short form amalgamation under the Companies Act 1993 with

its ultimate parent, Tower Limited (the prior Tower Limited); its parent, Tower Financial Services Group Limited; and another subsidiary of Tower Limited, Tower New Zealand Limited. At this date

the Company's existing share capital of $255m (including the issue of $45m new share capital) was cancelled without payment or other consideration, and instead the shares of the prior Tower

Limited (of $492m) became the shares of the Company, so that the shareholders of the prior Tower Limited became shareholders of the Company.

Ordinary shares issued by the Company 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 have been no changes in contributed equity during the year.

TOWER LIMITED ANNUAL REPORT 2021 56TOWER LIMITED ANNUAL REPORT 202157NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

5.3 Reserves
2021

$000

2020

$000

Opening balance(4,985)(3,697)

Currency translation differences arising during the year(1,097)(1,288)

Foreign currency translation reserve(6,082)(4,985)

Opening balance1,564 1,515

Gain on revaluation159 41

Deferred tax on revaluation(16)8

Asset revaluation reserve1,707 1,564

Capital reserve11,990 11,990

Opening balance(113,000) –

Impact of amalgamation – (113,000)

Separation reserve(113,000)(113,000)

Reserves(105,385)(104,431)

Recognition and measurement

The assets and liabilities of entities whose functional currency is not the New Zealand dollar are translated at the exchange rates ruling at balance

date. Income and expense items are translated at a weighted average of exchange rates over the period approximating spot rates at the

transaction dates. Exchange rate differences are taken to the foreign currency translation reserve.

Tower's land and buildings are valued at fair value less accumulated depreciation. Any surplus on revaluation of these items is transferred directly

to the asset revaluation reserve unless it offsets a previous decrease in value recognised in profit or loss in which case it is recognised in the

consolidated statement of comprehensive income.

On 30 September 2020, the Company was amalgamated with other Tower entities. On this date, the separation reserve was recognised. The

separation reserve was originally created in the prior Tower Limited 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 to meet the requirements

of the ATO.

5.4 Net tangible assets per share

2021

$

2020

$

Net tangible assets per share 0.57 0.56

Net tangible assets per share have been calculated using the net assets as per the balance sheet adjusted for intangible assets (including goodwill) and

deferred tax assets divided by total shares on issue.

5.5 Earnings per share

2021

RESTATED

2020

Profit attributable to shareholders ($ thousands)18,683 10,761

Weighted average number of ordinary shares for basic and diluted earnings per share (number of shares)421,647,258 417,172,654

Basic and diluted earnings per share (cents)4.43 2.58

The Group has used the ordinary shares of the prior Tower Limited up to 30 September 2020, and of the Company from that date, for the purposes of

calculating the weighted average number of ordinary shares. The prior Tower Limited issued an additional 84,322,958 shares as per its 1-for-4 rights offer

(refer to Note 5.2). The shares were issued at NZ$0.56 which represented a 19% discount to the share price of NZ$0.69 as at 15 October 2019 (the date

immediately prior to the exercise of rights). As a result, 13,118,388 shares issued as part of the rights offer are treated as a bonus issue. The weighted

average number of ordinary shares on issue in both 2020 and 2019 have been adjusted in accordance with NZ IAS 33 Earnings per share.

5.6 Dividends

20212020

CENTS PER SHARE$ THOUSANDSCENTS PER SHARE$ THOUSANDS

Final dividend for the year – – – –

Interim dividend for the period 2.5 10,541 – –

On 24 November 2021, the Board approved a full year dividend of 2.5 cents per share, with the dividend being payable on 2 February 2022. The

anticipated cash impact of the final dividend is approximately $10.5m.

During the year ended 30 September 2021 no dividends were written off (2020: $0.1m).

TOWER LIMITED ANNUAL REPORT 2021 58TOWER LIMITED ANNUAL REPORT 202159NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

6. OTHER BALANCE SHEET ITEMS
This section provides information about assets and liabilities not included elsewhere.

6.1 Property, plant and equipment

Composition:

30 September 2021

LAND AND

BUILDINGS

$000

OFFICE EQUIPMENT

AND FURNITURE

$000

MOTOR VEHICLES

$000

COMPUTER

EQUIPMENT

$000

TOTAL

$000

Composition:

Cost4,102 4,257 1,616 17,292 27,267

Accumulated depreciation – (2,289)(847)(14,757)(17,893)

Property, plant and equipment4,102 1,968 769 2,535 9,374

Reconciliation:

Opening balance4,035 2,989 1,083 1,934 10,041

Depreciation – (928)(260)(1,106)(2,294)

Additions – 1,437 – 1,654 3,091

Revaluations159 – – – 159

Disposals – (1,527)(34)56 (1,505)

Foreign exchange movements(92)(3)(20)(3)(118)

Closing balance4,102 1,968 769 2,535 9,374

30 September 2020

Composition:

Cost4,035 8,599 1,748 15,622 30,004

Accumulated depreciation – (5,610)(665)(13,688)(19,963)

Property, plant and equipment4,035 2,989 1,083 1,934 10,041

Reconciliation:

Opening balance4,082 4,002 205 815 9,104

Depreciation – (1,048)(205)(751)(2,004)

Additions – 31 1,211 2,004 3,246

Revaluations41 – – – 41

Disposals – 21 (125)(130)(234)

Foreign exchange movements(88)(17)(3)(4)(112)

Closing balance4,035 2,989 1,083 1,934 10,041

Recognition and measurement

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 asset's 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.

Furniture & fittings 5-9 years

Leasehold property improvements 3-12 years

Motor vehicles 5 years

Computer equipment 3-5 years

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.

6.2 Intangible assets

a. Amounts recognised in the balance sheet

30 September 2021

GOODWILL

$000

SOFTWARE

$000

CUSTOMER

RELATIONSHIPS

$000

TOTAL

$000

Composition:

Cost17,744 98,850 28,656 145,250

Accumulated amortisation – (50,323)(6,335)(56,658)

Intangible assets17,744 48,527 22,321 88,592

Reconciliation:

Opening balance17,744 47,866 12,238 77,848

Amortisation

– (8,205)

(4,351)

(12,556)

Additions – 10,528 14,434 24,962

Disposals – (237) – (237)

Transfers – (1,425) – (1,425)

Closing balance17,744 48,527 22,321 88,592

30 September 2020

Composition:

Cost17,744 89,985 14,222 121,951

Accumulated amortisation – (42,119)(1,984)(44,103)

Intangible assets17,744 47,866 12,238 77,848

Reconciliation:

Opening balance17,744 56,467 – 74,211

Adjustment to opening balance – (5,536) – (5,536)

Restated opening balance17,744 50,931 – 68,675

Amortisation – (7,721)(1,984)(9,705)

Additions – 4,819 14,222 19,041

Disposals – (43) – (43)

Transfers – (120) – (120)

Closing balance17,74447,86612,23877,848

Comparative information with respect to Software and related IT projects in progress has been restated due to a change in accounting policies as specified in Note 8.7.

Tower acquired and assumed ANZ's rights and obligations relating to servicing a portfolio of insurance underwritten by Tower. Tower provided insurance for ANZ and National Bank customers

between 1990 and 2009 and continues to cover over 23,000 people under those policies. On completion of the acquisition of the rights and obligations these customers will be insured directly

by Tower under a Tower branded policy. The amount capitalised includes the price paid for acquiring the portfolio outright and associated acquisition costs. The asset will be amortised over a

5- to 10-year period, with the pattern of amortisation being aligned with expected net cashflow benefits over this period.

TOWER LIMITED ANNUAL REPORT 2021 60TOWER LIMITED ANNUAL REPORT 202161NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

6.2 Intangible assets (continued)
Recognition and measurement

Intangible assets are assets without physical substance. They are recognised as an asset if it is probable that expected future economic benefits

attributable to the asset will flow to Tower and that costs can be measured reliably.

Application software and customer relationships are recorded at cost less accumulated amortisation and impairment. Application software is

amortised on a straight line basis over the estimated useful life of the software. Customer relationships are amortised over the estimated useful life

in accordance with the pattern of economic benefit consumption.

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

the asset to be 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.

The useful lives for each category of intangible assets with a finite life are as follows:

—capitalised software: 3-5 years for general use computer software and 3-10 years for core operating system software

—customer relationships: 5-10 years

Goodwill (i.e. assets with an indefinite useful life) generated as a result of business acquisition is initially measured as the excess of the purchase

consideration over the fair value of the net identifiable assets and liabilities acquired. Goodwill is not subject to amortisation but is tested for

impairment annually or more frequently where there are indicators of impairment.

Critical accounting estimates and judgements

Tower has determined that the ANZ customer relationship asset consists of two component intangible assets with different useful lives, and these

components are therefore expected to provide a different pattern of benefits to Tower.

The asset components, being 1) a customer relationship asset with a useful life equivalent to the customer base’s expected lifespan of ten years,

and; 2) a non-compete period with a contracted useful life of five years. The estimated capitalised cost related to the ANZ customer relationship

asset has been apportioned between the two asset components by valuing the non-compete at the differential in net present value of the asset

from improved customer retention over the non-compete period, pro-rated over the full asset value. This valuation is calculated with reference to

cash flow forecasts that combine past experience with future expectations based on prevailing and anticipated market factors, expected retention

rate and a discount rate of 12.5%.

b. Impairment testing

An impairment charge is recognised in profit or loss when the carrying value of the asset, or cash-generating unit (CGU), exceeds the calculated

recoverable amount.

(i) Software and customer relationships

Software and customer relationships are reviewed at each reporting date by determining whether there is an indication that the carrying values may

be impaired. If an indication exists, the asset is tested for impairment. A loss is recognised for the amount by which the carrying value exceeds the

asset's recoverable value.

There were no indications of impairment during the year and therefore these assets were not tested for impairment (2020: no indications).

Critical accounting estimates and judgements

The recoverable amount for software and customer relationships is determined by reference to a value in use calculation based on (i) cash flow

forecasts that combine past experience with future expectations based on prevailing and anticipated market factors; and (ii) a discount rate that

appropriately reflects the time value of money and the specific risks associated with the assets.

Value-in-use calculations involve the use of accounting estimates and assumptions to determine the projected net cash flows, which are

discounted using an appropriate discount rate to reflect current market assessment of the risks associated with the assets. An impairment charge

for capitalised software is incurred where there is evidence that the economic performance of the asset is not as intended by management.

Customer relationships represent the present value of future benefits expected to arise from existing customer relationships. The assumptions for

the useful life are based on historical information.

6.2 Intangible assets (continued)

(ii) Goodwill

Goodwill is deemed to have an indefinite useful life and is tested annually for impairment or more frequently where there is an indication that the

carrying value may not be recoverable.

Goodwill is allocated to cash generating units (CGUs) expected from synergies arising from the acquisition giving rise to goodwill. Tower's goodwill is

allocated to the general insurance CGU.

Tower undertook an annual impairment review and no loss has been recognised in 2021 as a result (2020: nil). COVID-19 impacts were again taken

into account when performing the review.

Critical accounting estimates and judgements

The recoverable amount of the New Zealand general insurance business is assessed with reference to its appraisal value, which is a common

practice for insurance companies. A base discount rate of 12.0% was used in the calculation (2020: 10.5%). The cash flows are in line with the

FY22 - FY24 operational plan (2020: FY21 - FY23) and longer term profitability is assumed to continue to grow at 2.5% per annum. The projected

cash flows are determined based on past performance and management's expectations for market developments with a terminal growth rate of

2.5% (2020: 2%).

The overall valuation is sensitive to a range of assumptions including the forecast combined operating ratio used in terminal value calculation,

discount rate, and terminal value long-term growth rate. Reasonable changes to these assumptions will not result in an impairment.

6.3 Leases

a. Amounts recognised in the Balance Sheet

(ii) Right of use assets

30 September 2021

OFFICE SPACE

$000

MOTOR

VEHICLES

$000

TOTAL

$000

Composition:

Cost26,901 25 26,926

Accumulated depreciation(1,332)(17)(1,349)

Right of use assets25,569 8 25,577

Reconciliation:

Opening balance7,189 22 7,211

Depreciation(2,404)(14)(2,418)

Additions24,332 – 24,332

Disposals(3,308) – (3,308)

Revaluations(3) – (3)

Impairment – – –

Net foreign exchange movements(237) – (237)

Right of use assets25,569 8 25,577

In August 2021 Tower entered into a new lease with a 10-year term for its Auckland premises. Tower recognised an initial right of use asset of $24.0m and an initial lease liability of $33.3m with

the difference primarily representing lease incentives. Tower has assumed no renewals of the lease past the initial 10-year term for the purposes of the right of use asset and lease liability.

TOWER LIMITED ANNUAL REPORT 2021 62TOWER LIMITED ANNUAL REPORT 202163NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

6.3 Leases (continued)
30 September 2020

OFFICE SPACE

$000

MOTOR

VEHICLES

$000

TOTAL

$000

Composition:

Cost9,619 53 9,672

Accumulated depreciation(2,430)(31)(2,461)

Right of use assets7,189 22 7,211

Reconciliation:

Opening balance10,097 86 10,183

Depreciation(2,518)(68)(2,586)

Additions

961 4 965

Disposals(1,249) – (1,249)

Revaluations(96) – (96)

Impairment(27) – (27)

Net foreign exchange movements21 – 21

Right of use assets7,189 22 7,211

Recognition and measurement

Right of use assets are recognised when Tower has the right to use the assets. Right of use assets are measured at cost comprising the initial

measurement of the lease liability adjusted for any lease payments made at or before the commencement date less any lease incentives received;

and indirect costs; and restoration costs. Right of use assets are generally depreciated over the shorter of the asset's useful life and the lease term

on a straight line basis.

(ii) Lease liabilities

2021

$000

2020

$000

Composition:

Current6,082 2,721

Non-current33,339 5,974

Lease liabilities39,421 8,695

Due within 1 year6,082 2,721

Due within 1 to 2 years6,041 2,584

Due within 2 to 5 years12,055 3,534

Due after 5 years19,514 418

Discount(4,271)(562)

Lease liabilities39,421 8,695

6.3 Leases (continued)

Recognition and measurement

Lease liabilities are recognised at the date Tower has the right to use the corresponding asset. Lease liabilities are initially measured as the present

value of expected lease payments under lease arrangements. Lease liability will include any option to extend where it is reasonably certain that the

option will be exercised. The lease payments are discounted using the incremental borrowing rate as the interest rate in the lease cannot be readily

determined. Incremental borrowing rates used during the year ranged between 1.9% and 3.6% (2020: between 2.3% and 3.6%).

Subsequent repayments are split between principal and interest cost where the finance cost represents the time value of money and is charged to

the profit or loss over the lease period. The discount rate applied is unchanged from the applied at the initial recognition of the lease, unless there

are material changes to the lease.

b. Amounts recognised in the consolidated statement of comprehensive income

CLASSIFICATION

2021

$000

2020

$000

Depreciation and impairment

Underwriting expense & corporate and other expenses(2,418)

(2,598)

Interest expenseFinance costs

(378)(369)

Gain on disposalUnderwriting expense1,179 167

Lease expense(1,617)(2,800)

c. Amounts recognised in the consolidated statement of cash flows

2021

$000

2020

$000

Total cash outflow for lease principal payments(2,848)(3,070)

TOWER LIMITED ANNUAL REPORT 2021 64TOWER LIMITED ANNUAL REPORT 202165NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

7. TAX
This section provides information on Tower's tax expense during the year and its position at balance date.

7.1 Tax expense

Composition

2021

$000

RESTATED

2020

$000

Current tax 3,745 3,621

Deferred tax5,785 3,900

Adjustments in respect of prior years(395)(51)

Tax expense9,135 7,470

Reconciliation of prima facie tax to income tax expense

2021

$000

RESTATED

2020

$000

Net profit before tax28,450 18,680

Prima facie tax expense at 28% (2020: 28%)7,966 5,230

Adjustments in respect of prior years(395)(51)

Tax effect of non-deductible expenses and non-taxable income796 788

Foreign tax credits written off861 1,127

Other(93)376

Tax expense9,135 7,471

Recognition and measurement

Tax expense is calculated on the basis of the applicable tax rates that have been enacted or substantively enacted at the end of the reporting

period in the jurisdictions Tower operates in. There have been no tax rate changes during the year in these jurisdictions. Current tax expense relates

to tax payable for the current financial reporting period while deferred tax will be payable in future periods.

7.2 Current tax

a. Current tax asset

2021

$000

2020

$000

Excess tax payments related to prior periods 12,038 12,038

Excess tax payments/tax payable related to current period 863 854

Current tax assets12,901 12,892

Expected to be recovered from 2024 as per the Board-approved operational plan for 2022 to 2025.

Excess tax payment made in the Pacific Islands during the reporting period.

b. Current tax liability

The current tax liability balance of $170k (2020: $821k) relates to taxes payable to offshore tax authorities in the Pacific Islands.

Recognition and measurement

Overpayment of tax in the current and prior periods is recognised as a current tax asset. Current tax assets are measured at the amount expected

to be recovered from the taxation authorities, using the tax rates and tax laws that have been enacted or substantively enacted by the end of the

reporting period.

7.3 Deferred tax

a. Deferred tax asset

Composition

2021

$000

RESTATED

2020

$000

Tax losses recognised24,116 25,720

Software, property, plant and equipment2,834 3,744

Leases373 501

Provisions and accruals4,165 3,882

Recognised in profit or loss31,488 33,847

Impact through other comprehensive income – 1,550

Recognised in comprehensive profit or loss31,488 35,397

Set off of deferred tax liabilities pursuant to NZ IAS 12(7,038)(6,575)

Deferred tax asset24,450 28,822

Reconciliation of movements

2021

$000

2020

$000

Opening balance35,397 36,360

Movements recognised in other comprehensive income – 2,051

Movements recognised in consolidated statement of comprehensive income(3,909)(3,014)

Deferred tax asset pre NZ IAS 12 set off31,488 35,397

TOWER LIMITED ANNUAL REPORT 2021 66TOWER LIMITED ANNUAL REPORT 202167NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

7.3 Deferred tax (continued)
b. Deferred tax liability

Composition

2021

$000

2020

$000

Deferred acquisition costs(5,481)(6,588)

Customer relationships(3,433) –

Other (461)(911)

Recognised in profit or loss(9,375)(7,499)

Asset revaluation(438)(422)

Recognised in comprehensive profit or loss(9,813)(7,921)

Set off of deferred tax liabilities pursuant to NZ IAS 12

7,038 6,575

Deferred tax liability(2,775)(1,346)

Primarily relates to withholding tax on undistributed profit from the Pacific Islands.

Reconciliation of movements

2021

$000

2020

$000

Opening balance(7,921)(7,043)

Movements recognised in consolidated statement of comprehensive income (1,876)(886)

Movements recognised in equity(16)8

Deferred tax liability pre NZ IAS 12 set off(9,813)(7,921)

Recognition and measurement

Deferred tax is income tax which is expected to be payable or recoverable in the future as a result of the unwinding of temporary differences.

These arise from differences in the recognition of assets and liabilities for financial reporting and from the filing of income tax returns. Deferred tax

is recognised on all temporary differences, other than those arising from (i) goodwill or (ii) from the initial recognition of assets and liabilities in a

transaction (other than in a business combination) that affects neither the accounting nor taxable profit or loss.

At the reporting date, the Group has recognised a deferred tax asset in respect of its unused tax losses of $86.1m (2020: $92.2m).

Deferred tax is calculated at the tax rates that are expected to apply to the year when the liability is settled or the asset realised, based on tax rates

and tax laws that have been enacted or substantively enacted at balance date.

Deferred tax assets and liabilities are offset when there is a legally enforceable right to set off current tax assets against current tax liabilities and when

they relate to income taxes levied by the same taxation authority and the Group intends to settle its current tax assets and liabilities on a net basis.

Critical accounting judgements and estimates

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 Limited and subsidiaries. Tower's ability to utilise these tax

losses depends on the future profitability, changes in ownership and a major change in Tower's business. The enactment of the new business

continuity test in the Income Tax Act 2007 on 30 March 2021 for carrying forward tax losses means that Tower is able to carry forward its tax losses

even if there is a significant shareholding change, as long as the business continuity test is met.

7.4 Imputation credits

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

2021

$000

2020

$000

Imputation credits available for use in subsequent reporting periods271271

8. OTHER INFORMATION

This section includes additional disclosures which are required by financial reporting standards.

8.1 Notes to the Consolidated Cash Flow Statement

Composition

2021

$000

2020

$000

Cash at bank88,740 61,892

Deposits at call27,389 18,071

Restricted cash – 145

Cash and cash equivalents116,129 80,108

The average interest rate at 30 September 2021 for deposits at call is 0.25% (2020: 0.47%).

Reconciliation of profit for the year to cash flows from operating activities

2021

$000

RESTATED

2020

$000

Profit for the year19,315 11,210

Adjusted for non-cash items

Depreciation of property, plant and equipment2,294 2,004

Depreciation, impairment and disposals of right of use assets2,418 2,432

Amortisation of intangible assets12,556 9,706

Fair value losses on financial assets4,568 1,518

Gain/loss on disposal of fixed assets322 –

Change in deferred tax5,799 7,565

Adjusted for movements in working capital

Change in receivables41,612 (2,659)

Change in payables8,840 (15,314)

Change in taxation539 (1,414)

Adjusted for financing activities

Facility fees and interest paid378 1,115

Net cash inflows from operating activities98,641 16,163

TOWER LIMITED ANNUAL REPORT 2021 68TOWER LIMITED ANNUAL REPORT 202169NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

8.2 Related party disclosures
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.

2021

$000

2020

$000

Salaries and other short-term employee benefits paid5,0594,736

Termination benefits486 –

Independent director fees723624

Related party remuneration 6,268 5,360

Tower insurance products are available to all key management personnel on the same terms as available to other employees. In addition, Tower

purchases indemnity insurance for all directors both past and present covering liabilities and legal expenses incurred whilst in office.

Definition

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.

8.3 Auditor’s remuneration

2021

$000

2020

$000

Audit of financial statements

(1)

599550

Other assurance services

(2)

6046

Non-assurance agreed procedures

(3)

– 12

Total fees paid to Group's auditors659608

Fees paid to subsidiaries' auditors different to Group auditors:

Audit of financial statements

(4)

1415

Auditor’s remuneration673623

(1) Audit of financial statements includes fees for both the audit of annual financial statements and the review of the interim financial statements. PwC Fiji performs the audits of all overseas

incorporated subsidiaries with support of PwC New Zealand and other PwC network firms. $129,600 is paid to other PwC network firms (non New Zealand) for their audit services.

(2) Other assurance services includes annual solvency return assurance and Pacific Island regulatory return audits. The other assurance services for the year ended 30 September 2020 were

completed during the year ended 30 September 2021.

(3) Agreed procedures on Pacific Island regulatory return and Annual Shareholders' Meeting procedures in the year ended 30 September 2020. The non-assurance agreed procedures for the

year ended 30 September 2020 were completed during the year ended 30 September 2021.

(4) The audit of Tower Insurance (Vanuatu) Limited was performed by Law Partners (2020: Law Partners).

8.4 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.

8.5 Subsequent events

On 24 November 2021, the Board approved a full year dividend of 2.5 cents per share, with the dividend being payable on 2 February 2022 as specified

by Note 5.6. The anticipated cash impact of the final dividend is approximately $10.5m.

On 24 November 2021, the Board approved $30.4m capital return by way of a compulsory share buyback. The capital return is subject to shareholder

and Court approval.

On 14 October 2021 Tower Limited reached an agreement to increase its shareholding in National Pacific Insurance Limited from 71.39% to 93.88% for a

consideration of $3.4m. Tower Limited has subsequently commenced a process to acquire the remaining 6.12% shareholding.

8.6 Capital commitments

As at 30 September 2021, Tower has nil capital commitments (2020: $0.7m).

8.7 Impact of new accounting standards and changes in interpretation of current accounting standards

a. Issued and effective

Software-as-a-Service (“SaaS”) arrangements

For the year ended 30 September 2021 and its comparative period, the Group has revised its accounting policy in relation to the configuration and

customisation costs incurred in implementing Software as a Service (SaaS) arrangements. These are arrangements in which, as a Group, application

software is accessed over the internet or via a dedicated portal as required. The change in accounting policy resulted from the IFRS Interpretations

Committee pronouncements as to how current accounting standards apply to these types of arrangements in principle, primarily in relation to the

recognition and measurement criteria of IAS 38 Intangible Assets with specific respect to Software and IT related projects in progress.

SaaS arrangements are service contracts providing the Group with the right to access a cloud provider’s application software over a stated time period.

Costs the Group incurs to configure, customise and maintain access to providers’ application software are recognised as operating expenses when

incurred and in accordance with contracted terms.

Impact of accounting policy change

As a result of this change in accounting policy, the Group has determined certain costs that have been capitalised relating to SaaS arrangements should

have been expensed when they were incurred.

The changes are required to be applied retrospectively. Costs capitalised prior to 1 October 2019 that should have been expensed have been adjusted

against opening accumulated losses at 1 October 2019. Costs capitalised in the years ended 30 September 2020 and 30 September 2021 that should

have been expensed have been reclassified to the consolidated statement of comprehensive income. The impact on the financial statements for the

years ended 30 September 2020 and 30 September 2021 is summarised below:

Consolidated statement of comprehensive income

—an increase in technology expenses for the year ended 30 September 2021 of $3.1m (2020: $1.5m).

—a decrease in people costs capitalised during the year ended 30 September 2021 of $0.5m (2020: $1.3m).

—a decrease in amortisation expenses for the year ended 30 September 2021 of $1.5m (2020: $1.1m).

—a decrease in tax expense for the year ended 30 September 2021 of $0.6m (2020: $0.4m).

—an overall decrease in net profit after tax for the year ended 30 September 2021 of $1.5m (2020: $1.3m).

Consolidated balance sheet

—an increase in opening accumulated losses of $7.1m (2020: $3.9m).

—a decrease in intangible assets as at 30 September 2021 of $2.0m (2020: $7.1m).

—an increase in deferred tax assets as at 30 September 2021 of $0.6m (2020: $2.0m).

Consolidated statement of cash flows

—an increase in employee and supplier payments for the year ended 30 September 2021 of $3.5m (2020: $2.7m).

—a decrease in payments for purchase of intangible assets for the year ended 30 September 2021 of $3.5m (2020: $2.7m).

Earnings per share

—a decrease in earnings per share for the year ended 30 September 2021 of 0.34 cents (2020: 0.27 cents).

Adjustment relating to periods before 1 October 2019

—the portion of the decrease to intangible assets above relating to costs capitalised pre 1 October 2019 is $5.5m.

—the portion of the increase to deferred tax assets above relating to costs capitalised pre 1 October 2019 is $1.6m.

—the reduction in opening accumulated losses at 1 October 2019 relating to costs capitalised pre 1 October 2019 is $3.9m.

TOWER LIMITED ANNUAL REPORT 2021 70TOWER LIMITED ANNUAL REPORT 202171NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSNOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS

8.7 Impact of new accounting standards and changes in interpretation of current accounting standards
(continued)

b. Issued and not yet effective

NZ IFRS 17 Insurance Contracts is effective for periods beginning on or after 1 January 2023. Tower will apply the standard for the year

ending 30 September 2024, with the comparative period for the year ending 30 September 2023. The standard replaces the current

guidance in NZ IFRS 4 Insurance Contracts, and establishes principles for the recognition, measurement, presentation and disclosure of

insurance contracts. The standard introduces substantial changes in the presentation of financial statements and disclosures, introducing

new balance sheet and income statement line items and increased disclosure requirements compared with existing reporting. Tower has a

programme with dedicated resource to assess the impact of adopting NZ IFRS 17 and to project manage the transition to the new standard

including system development. Tower has completed an initial draft of accounting policies under IFRS 17, with the majority of the impact

assessment and systems development work expected to be completed in the financial year ended 30 September 2022. An initial

assessment has been completed on Tower's contracts, and it is expected that the majority of Tower's insurance contracts will meet the

requirements of the simplified approach available under IFRS 17. However, due to the complexity of the requirements within the standard

and the availability of accounting policy choices as to how the standard is implemented which have not yet been finalised, a full

assessment of the financial impact has not yet been completed.

TOWER LIMITED ANNUAL REPORT 2021 72TOWER LIMITED ANNUAL REPORT 202173NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTSINDEPENDENT AUDITOR'S REPORT

Pricewat erhouseCoopers, 1 5 C usto ms Street West, Priv at e Bag 92162, A uckland 1142, New Zeal and
T: + 64 9 3 55 8000, F: + 64 9 3 55 8001, pwc.co.nz

Independent auditor’s report

To t he s harehol ders of Tower Limi ted

Our opinion

In ou r op ini on , the ac compan ying con solida te d financ ial s tatements of T ower Li mited ( th e Company ),

inc ludi ng its s ub sidi ar ies ( th e Grou p), presen t f ai rly, i n al l material r es pec ts , the fi nan cial p os iti on of th e

Grou p as at 30 September 20 21, i ts f inan cial performance and i ts c as h fl ows fo r t he y ea r t he n ende d

in accordan ce with New Zeal and Equival en ts t o I nt ernati onal Fina nc ial Reporting Standa rds ( NZ IFRS)

an d Internati on al Financ ial Reporting S tan dards ( IFRS).

What we

ha ve au dite d

The G rou p's con sol ida ted f ina nc ial s ta temen ts c omprise:

●the c on solida ted b al an ce she et as at 30 Sep tembe r 2 02 1;

●the c on solida ted statemen t of compr eh ens ive i nc ome for the year then end ed;

●the c on solida ted s tatemen t of cha nge s i n equ ity fo r the y ea r th en ended;

●the c onsolida ted s tatemen t of cas h flows fo r t he y ear then e nd ed; and

●the n otes t o t he con solid ated f ina nc ial s tatements, which i nc lude signi fican t accou nti ng polic ies

an d other ex pl an at ory i nf

ormation .

Basis f or opinion

We cond uc te d our audi t in ac cordance with Int ernat ional Standa rds o n Auditi ng ( New Zealand ) ( IS As

(NZ)) and I nt ernationa l S tand ards o n Auditi ng ( ISAs). Our res po ns ibilities u nd er tho se standa rds are

further des cribe d i n th e Audi tor’s r es po ns ibi liti es f or the audi t of the c on solida ted f inanc ial s tat ements

sec ti on of our rep ort.

We be liev e that th e audi t evide nc e we hav e obtained i s s uff icient and a pp ropriate to provide a bas is

for our opi ni on.

Indepe nde nc e

We are ind epe nde nt o f the Grou p i n ac

cordanc e with Professional and Eth ical Stan da rd 1

Int ernati onal Code of Eth ics for A ssurance Prac ti tioners ( inc luding Int er na tional I nd epen den ce

Standa rds ) ( New Zealand) (PES 1) issued by t he N ew Zea land Audi ting and Assuran ce Stan dards

Boa rd and t he In ternationa l Code of Eth ics for P rofession al A ccountants ( inc luding In ternati on al

Indepe nde nc e Stan dards)issued by the I nt ernationa l Eth ics Sta nd ards Boa rd f or Accou ntants ( IE SBA

Code), an d we ha ve ful filled our other ethical r es po

nsibi lities i n accordanc e wi th the se requi rements .

Our firm carries ou t other services fo r th e G rou p in the areas of as surance over sol ven cy and

reg ul atory i ns urance returns and agreed upon proced ures i n respe ct of vot ing at t he A nn ual

Sha reholde rs Mee ting and a regulat ory i ns urance return. In ad dition , c ertain partners and employ ee s

of ou r f irm may d ea l with t he Grou p on n ormal t erms w ith in the ordinary c ou rse of tr ad ing activities of

the G roup. Thes e matte rs h av e not i mpaired ou r i nd ependenc e a

s a uditor of the Grou p.

Key audit matters

Key audi t matte rs are tho se matt ers th at, in ou r professional j udgement , were of mos t s ignifi canc e i n

ou r audi t of the c ons ol ida ted f ina nc ial s tatements of th e curren t y ea r. The se matt ers were addressed

in the c ontext o f our a udit of the cons ol idated fi nancial stat ements as a whole, and i n forming ou r

op ini on t hereon, and w e do not provide a sepa rate opini on on th es e matte rs.

INDEPENDENT

AUDITOR'S

REPORT

TOWER LIMITED ANNUAL REPORT 2021 74TOWER LIMITED ANNUAL REPORT 202175INDEPENDENT AUDITOR'S REPORTINDEPENDENT AUDITOR'S REPORT

PwC
Descripti on o f the key audi t matt erHow our audi t ad dr es sed the key audit matt er

(1)Valuation of outstanding claims

(20 21 : $122,338,000 , 20 20:$1 07,747 ,0 00 )

We cons ide red t he v alua tion of ou ts ta nd ing

clai ms a key audi t matter bec au se t his

inv ol ves an estimati on proc es s c ombi ne d

wi th signifi cant judge men ts an d as sumpt ion s

made by man age men t to esti mate f ut ure

cas h outflows t o settle clai ms.

The outs tanding claims liability i nc ludes a

cen tr al es ti mate of the f uture cas h outfl ows

rel at ing to claims i nc urred, as at a nd prior to

the r eporting d ate, and

the ex pe cted c os ts o f

ha ndling t ho se clai ms. There i s u nc ertainty

ov er the amoun t that r ep orted c laims an d

clai ms inc urred at t he r epo rti ng date but not

yet rep orted t o th e G rou p will u lti matel y b e

sett led at. The es ti mati on proc es s r el ies o n

the q uality o f u nde rlying c laims data and t he

us e of inf ormed esti mates t o det ermine the

qu antum of the u ltimate los s.

Key actu arial assumpti on s ap plie d i n t he

val ua tion of ou ts ta nding c laims i nc lude :

●ex pe cted fut ur e claims d ev e

lopment

proportion ; and

●clai ms ha ndl ing expens e rati os

Outstanding claims in relat ion tothe

Canterbury earth qu ak es have a greater

de gree of un certainty andjud gement. This

mainlyarisesdueto theuncertaintyas to

further deterioration of open known claims,

the Earthqu ake Commi ssion (EQC) reporting

of new claims tothe Group which ha ve gon e

ov er the $1 00,000 statutory liab ility cap(ov er

cap claims), n ew liti ga tion clai ms, reope ning

of clos ed claims, ex pe cted clai ms cos ts for

op en claims andestimates of future claims

management expens es .

Change s in assumpti on s canlea d to

sign ifi cant mov ements in t he outstan ding

clai ms liability .

Cl aims d ata

is a key i np ut t o t he actuarial esti mates .

Accordingl y, we:

●ev al uated th e design eff ec tivenes s and tested

con tr ol s over clai ms proces sing ;

●as ses sed a sampl e of c lai m cas e esti mates at

the y ea r en d to chec k th at the y were supp orted

by appropriate man agement a ssessment and

do cumentation;

●as ses sed , o n a sampl e basis, the accuracy of

previou s c lai m cas e estimates by c omparing t o

the actua l amou nt s ettled during the y ear and

an alysed any es cal at ion i n the c lai m c as e

es ti mate to determine whethe r s uc h

escalati on

was based on ne w inf ormation that c ame

av ai lable during t he yea r;

●ins pe cte d a s ample of claims paid during t he

yea r to c on firm tha t they were sup ported by

ap propriate doc umentation an d ap proved with in

de leg at ed au th ority limi ts ; and

●tested t he int eg rity of data us ed i n t he actu arial

models a nd c alcul ati ons by agreeing t he

rel ev an t i np uts, s uc h as c laims data, t o sou rce.

Tog ether with our actu arial ex pe rts , we:

●considered the work and findings of the

actuaries engaged by the Group;

●evaluated the actuarial models and

methodologies used, and any changes to them,

by comparing with generally accepted models

and methodologies applied in the sector;

●assessed 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

(where applicable), taking intoconsideration

COVID-19 impacts;

PwC

Descripti on o f the key audi t matt erHow our audi t ad dr es sed the key audit matt er

The outs tanding claims liability i nc ludes a

risk margi n t hat allows fo r t he i nh er en t

un certainty i n t he cen tr al esti mate of future

clai m c as h outf lows. In determining t he risk

margi n, the G roup mak es j ud gements abou t

the v olat ility of ea ch clas s of business written

an d the c orrelat ion be tween di ffe rent

ge og rap hical loc at ions .

Refer to note 2.4 t o th e c onsol idated

fi nanc ial statements.

●as ses sed th e risk margi n as per th e

req ui rements of ap plic abl e ac cou nti ng

standa rds , by c omparing t

o k no wn indus tr y

practi ce. In particul ar we fo cus ed on the

as ses sed l ev el of un certainty i n the c entr al

es ti mate; an d wi th referen ce t o the inherent

un certainty i n t he remai ni ng Christc hurch

ea rthqua ke clai ms and i ts c on sistency with

prior p eriods .

(2)Recover abilit y of t he deferred tax

as se t ar ising f rom tax l osse s

(20 21 : $24 ,11 6, 000, 202 0: $2 5, 72 0, 00 0)

The maj ority of t he G roup ’s de ferred t ax

as set arises from ta x l os ses. We cons ide red

rec ov erability o f the deferred t ax asset a key

au dit matt er be cau se uti lis

ati on of t he as set

is s en sitive t o the G roup’s expe cted fut ur e

profitab ili ty and sufficient c on ti nuity of t he

ul timate sha reholde rs or busine ss con ti nuity.

Management j ud gement is inv ol ved i n

forecas ti ng t he t imi ng an d qu antum of future

taxab le prof its , whi ch are inhe ren tly

un certain, and whethe r it i s probabl e th e ta x

los ses will be u ti lis ed i n t he fores ee abl e

fut ure.

Refer to no te 7.3 t o th e c onsol idated

fi nanc ial s tatements.

In con side ring t he r ec ov erabi lity of th e deferred t ax


as set arising from tax los ses we performed the

fol lowing procedures:

●compa red t he prev iou s mana gement bud get

wi th ac tual r es ults to as ses s th e reliabi lity of

management ’s fo rec as ting;

●con side red t he reasona blene ss of the

as sumpti on s in the F Y22 ope rati onal pl an on

the f orecas t u tilisati on of ta x l os ses ;

●as ses sed th e Group ’s ab ility to maint ai n

suff icient conti nui ty of th e ulti mate s ha rehol de rs

or to mee t the busine ss c on ti nui ty t es t and

therefore i ts en titl ement to off set t

he t ax los ses

ag ains t future tax able profi ts; a nd

●de termined w he th er it was probabl e ( more lik ely

thanno t) t ha t t he t ax l os ses would be utilised in

the f oresee abl e f ut ure.

TOWER LIMITED ANNUAL REPORT 2021 76TOWER LIMITED ANNUAL REPORT 202177INDEPENDENT AUDITOR'S REPORTINDEPENDENT AUDITOR'S REPORT

PwC
Our audit approach

Overview

Overall grou p materiality : $3.95 mi llion,which represents approximatel y 1% of

gross earne d premium.

We chos e gros s earned premium as th e be nc hmark b ec au se,in our view, i t i s

the b en chmark agains t which the pe rforman ce of th e Grou p i s most c ommonly

meas ured by users, and is a gene rally accep ted be nc hmark fo r i ns urance

compa nies .

A full scope audit was pe rfo rmed for the Compa ny ba sed o n i ts f inan cial

sign ifi can ce to t he G roup . Spe cified audit p roc edu res an d an alyti cal r ev iew

proced ures w ere performed on the r emaining G roup enti ties .

As r ep orted abo ve, we hav e t wo key au dit matt ers, be ing :

●Val ua tion of ou ts ta nding c lai ms

●Recov erability of t he de ferred ta x as set arising from tax l os ses

As part of des igning our audi t, we determined materiality and as ses sed th e risks of material

mi sstatement i n t he con solida te d f ina nc ial s tat ements . In pa rticul ar, we cons idered where

management made s ubj ec ti ve j ud gements; for ex ample, in respe ct of s igni fican t a ccou nti ng estimates

that inv olved making assumpti on s a nd c ons ide ring fu ture even ts t ha t are inherently uncertain. As i n all

of ou r au dits , we a lso addressed th e r isk of man agemen t o verride of internal c ont rol s, i nc luding a

mong

other matt ers, c on siderati on of whe the r there was ev iden ce of bi as th at repres ent ed a risk of material

mi sstatement d ue t o fraud.

Material ity

The s cop e of our audi t was i nf luenc ed by our a pplic at ion of materiality . An audi t is designed t o obtain

rea son abl e assurance ab out whether the c ons ol idated fi nan cial s tatemen ts are fr ee from material

mi sstatement. Misstat ements may arise du e to fraud or error. The y are cons idered material i f,

individua lly or in agg rega te , th ey c ould reas on abl y b e expe cted t o i nfl u

enc e the ec on omic d ecisions of

us ers ta ken o n t he bas is of the c on solida ted f inan cial s tat emen ts .

Bas ed on ou r professional j ud gement, w e determined certain qu anti tative t hreshol ds fo r materiality ,

inc ludi ng t he over al l G rou p material ity fo r t he c ons ol idated f inanc ial s tatements as a whole as s et out

ab ov e. The se, together with qual itative con side rat ions , h elped us to determine t he scop e of o ur au dit,

the n ature, ti mi ng a nd ex te nt of ou r a ud it p roc edu res a nd to eval u

ate t he eff ec t o f mi sstat ements , b ot h

individua lly a nd in aggrega te, on th e c on sol idated fi na ncial s ta temen ts as a whol e.

How we tailored o ur group au dit s cop e

We tai lored t he scop e of our audi t i n order to pe rform suff icient work to e nabl e us t o prov ide an opi nion

on the con solida te d financ ial s tatements as a whole, t ak ing int o account th e str uc ture of the G roup ,

the accounti ng proces ses a nd c on tr ols, and t he indus tr y i n which the G roup ope rat es .

Other information

The Direc tors are res pons ibl e for the othe r i nformati on. The other inf ormation c omprises th e

information inc luded in the Annual Repo rt, but doe s n ot i nc lud e th e c on sol idated f ina nc ial s ta temen ts

an d ou r a ud itor’s r eport thereo n. The Annua l Report is ex pe cted to be mad e avai labl e to us aft er the

da te of thi s a ud itor’s r eport.

Our opini on o n t he con solidated fi nan cial s ta temen ts d oe s not c ov er the other info rmati on a nd w e will

no t e xpress a ny fo rm of audit op ini on or as surance conc lus ion t hereon.

PwC

In con nec ti on with ou r a ud it of the con solida te d financ ial s tatements, our res po ns ibi lity i s t o read t he

other information and, in doing s o, c on sider whether the oth er informati on is materially i nc on siste nt

wi th the c ons ol idated fi na ncial s ta temen ts or ou r k no wledge o btained in the a udit, or otherwise

ap pears to b e material ly misstated .

When we r ea d the ot her information no t y et recei ved, if we con clude t hat th ere is a material

mi sstatement therein, we a re required t o communicate th e matt er to the D irec tor

s an d us e our

professiona l j ud gement to de termine t he appropriate ac ti on to t ak e.

Responsibilities of t he Direc tors for t he consolidat ed financial statements

The Direc tors are res pons ibl e, on be hal f of t he C ompan y, for t he prep arati on and f air presen tati on of

the c on solida ted f inan cial s tat emen ts in accordan ce with NZ IFRS a nd IFRS, an d for suc h i nternal

con tr ol as th e Di rec tors d et ermine i s ne ces sary to e nabl e the preparation of con sol ida ted f inanc ial

stat ements that are free from material mi sstatement, w he th er due t o f rau d or error.

In preparing t he con solida ted f inanc ial s tat ements, th e Direc tors are res pon sibl e for asses sing t he

Grou p’ s a bi lity t o con

tinue as a going con cern, di sclosing , as appl icable, matt ers r el at ed t o goi ng

con cern and using t he go ing con cern bas is of accou nt ing u nl es s the Direc tors ei ther int en d to liqu ida te

th e Group or t o cea se op er ati ons , o r h av e no realis tic al ternati ve but to do s o.

Audit or’s res ponsibilit ies for t he audit of t he consolidated financi al statements

Our objec ti ves are to obtain r ea son abl e assurance ab out whether the c ons ol idated fi nan cial

stat ements, a s a whole, a re free from material mi sstatement, whether du e to fr aud or error, and t o

issue an audi tor’s r eport that inc ludes our op ini on . Reas on able as surance is a high l ev el of as suranc e,

bu t is not a gua rantee that an a ud it c on duc ted in ac cordance with ISAs ( NZ) and ISAs w ill a lways

de tect a material mi sstatemen t whe n it ex ists . Misstatements c an arise fr om fr au d or error and are

con side red material if, ind

ividual ly or in t he aggregate, they c ould reas on abl y b e expe cted t o i nfl ue nc e

the econo mic dec isions of us ers ta ken o n t he bas is of these con solida ted f inan cial s tat ements .

A fu rthe r descripti on of our res po ns ibilities fo r t he au dit of the con solida te d financ ial s tatements i s

loc ated at th e E xternal Reporting B oa rd’s website at:

htt ps ://www.xrb.govt. nz /assurance-standards/audi tors-res po ns ibilities /audi t-repo rt-1/

Thi s descript ion f orms pa rt of ou r au ditor’s r ep ort.

Who we report t

o

Thi s r ep ort is mad e solely t o t he Company ’s s ha rehol ders, a s a body . Our aud it work has been

un de rtak en s o that wemi ght stat e those matters which we are requi red t o state t o t hem in an aud itor’s

rep ort and f or no other purpos e. To the f ul les t e xten t permitt ed by l aw, we do no t ac cep t o r assume

res po ns ibility to anyone o th er than th e Company and the Compan y’s s ha reholde rs, a s a body , for o ur

au dit work, f or this r ep ort or for th e opinion s w e hav e f ormed.

The engage men t pa rtn er on t he audi t resul ting i n this i nd epen den t audi tor’s r ep ort i s K ar en Shi res .

For and on be hal f of:

Chartered AccountantsAuc kland

24 November 2021

INDEPENDENT AUDITOR'S REPORTTOWER LIMITED ANNUAL REPORT 2021 78TOWER LIMITED ANNUAL REPORT 202179INDEPENDENT AUDITOR'S REPORT



24 November 2021

The Directors

Tower Limited

136 Fanshawe Street

Auckland 1010

Dear Director s

Review of Actuarial I nf ormation contained in the financial statement s

As required by Section 78 of IPSA the Appoi nted Actuary, Geoff Atkins of Finity Consulting, has reviewed the

actuarial infor mation contained in, or used in the preparation of , the financial statements at 30 September

2021. Geoff Atkins and Finity have no relationship with or interes

t in Tower ot her than being a provider of

actuarial services.

I prepared the actuarial valuation of liabilities remaining from the Canterbury Earthquakes and reviewed the

actuarial valuations of insurance liabilities for the New Zealand business and the Pacific Islands businesses. I

reviewed the ot her actuarial infor mation as specified by IPSA in Section 77, including the sol vency calculations

for the financial statements.

No limitations

were placed on me in perfor ming the review and all data and infor mation requested was

provided.

Not hing has come to my attention that would lead me to believe that any of the actuarial information

contained in, or used in the preparation of , the financial statements is not appropriate.

In my opinion the company has maintained a sol vency margin in excess of the minimum required as at 30

September 2021.

The repor t is being prov

ided for the sol e use of Tower for the purpose state above. I t is not intended, nor

necessarily suitable, for any ot her purpose and should only be relied on for the purpose for which it is intended.

Yours sincere ly

Geoff Atkins Anagha Pasche

Appointed Actuar y

Fellows of the New Zealand Society of Actuari es

APPOINTED

ACTUARY'S

REPORT

TOWER LIMITED ANNUAL REPORT 2021 80TOWER LIMITED ANNUAL REPORT 202181APPOINTED ACTUARY'S REPORTAPPOINTED ACTUARY'S REPORT

CORPORATE GOVERNANCE
& STATUTORY DISCLOSURES

Tower Limited’s (Tower) 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. When there

are developments in corporate governance practices, the Board reviews these

against Tower’s practices and updates Tower’s practices where appropriate.

For the reporting period to 30 September 2021, the

Board considers that Tower’s corporate governance

practices have materially adhered to the NZX Corporate

Governance Code (NZX Code). Further information about

the extent to which Tower has complied with each of

the NZX Code recommendations is set out in Tower’s

corporate governance statement, available on Tower’s

website at tower.co.nz/investor-centre.

The following policies and company documentation are

available on Tower’s website (https://www.tower.co.nz/

investor-centre/corporate-governance/policies):

• Tower Limited Constitution

• Corporate Governance Statement

• Board Charter

• Board Protocols

• Audit Committee Terms of Reference

• Risk Committee Terms of Reference

• Remuneration & Appointments Committee Terms of

Reference

• Director and Executive Remuneration Policy

• Insider Trading and Market Manipulation Policy

• Corporate Disclosure Policy

• External Audit Independence Policy

• Health and Safety Policy

• Code of Ethics Policy

• Diversity and Inclusion Policy

STATUTORY DISCLOSURES

DIVERSITY

Gender Diversity

The below table provides a quantitative breakdown

of the gender composition of Tower’s Directors and

Officers and other employee groups as at 30 September

2021, compared to 30 September 2020, including

subsidiaries.

30 SEPTEMBER 202130 SEPTEMBER 2020

GROUP% GROUPNUMBER% GROUPNUMBER

Board of Directors

Males83%583%5

Females17%117%1

Executive Leadership team

1

Males67%656%5

Females33%344%4

Business Leadership team

2

Males42%1151%19

Females58%1549%18

All Other Employees

Males40%29340%230

Females60%44760%346

All Employees

Males40%31041%254

Females60%46559%368

Total Employees775622

1 ‘Executive Leadership Team’ includes the Chief Executive Officer, and those employees

who report directly to the Chief Executive Officer.

2 ‘Business Leadership Team’ consists of various senior and specialised roles that are

influential in driving the Tower strategy, but do not report to the Chief Executive Officer.

TOWER LIMITED ANNUAL REPORT 202183CORPORATE GOVERNANCE & STATUTORY DISCLOSURESCORPORATE GOVERNANCE & STATUTORY DISCLOSURES82TOWER LIMITED ANNUAL REPORT 2021

Diversity performance at Tower
Tower has a diversity policy and measurable diversity

and inclusion objectives under the following categories.

• Gender diversity

• Age and career progression

• Ethnicity and Pacific and Māori inclusion

• LGBTIQ+ identification and inclusion

• Accessibility

Tower's Board considers there has been some good

progress on initiatives focused around the pillars of gender,

culture, sexuality, age and accessibility in FY21. Of note,

significant effort has been invested into achieving the

Domestic Violence Tick and associated programmes

for leaders as well as embedded training and induction

modules for unconscious bias. The Board endorses Tower’s

plan to create further resource groups – for example

`Women in Leadership` and `Flexible Working`. There is high

engagement in other active employee resource culture

groups including the Māori Roopū and Pasifika which are

essentially employee driven (with some facilitation by Tower).

It is apparent that these groups have been successful in

providing focus and support in sustaining and continuing

to develop a diverse culture and increase employee

engagement. Tower has committed to its investment in the

Rainbow community and its re-accreditation of the Rainbow

along with the associated employee resource group.

Initiatives have been put in place around ensuring there is no

barrier for benefits from an age perspective. For instance, the

Employer Kiwisaver Contribution continues for staff over 65.

The new sustainable building on Fanshawe Street is a proud

achievement and improves accessibility for staff with the

provision of lifts, bike parks, wheelchair access, standup

desks and its location generally, on Auckland Transport

routes and close to multiple transport hubs.

Tower has embraced flexibility and now has over 70 people

permanently working from home. The new building design

and capacity has meant that there is more flexibility around

work location and hybrid solutions for certain roles. Tower

has received a recent diversity and inclusion engagement

score of 8.7 out of 10 (against the overall engagement score

of 7.7 for all categories).

There is good female representation overall 60%

Female versus 40% Male, however there is lower female

representation in the Executive team. The Board has noted

the need for a greater focus on gender balance at the

executive level. This is to be achieved through a diversity

and inclusion lens focusing on talent progression and

fair and equitable selection processes. It is recognised

that future Board appointments must also consider more

balanced gender and diversity representation.

BOARD AND BOARD COMMITTEES

Board

During FY21 the Board comprised the following

members:

Michael Stiassny (Chair), Graham Stuart, Steve Smith,

Warren Lee, Wendy Thorpe, Marcus Nagel.

With the exception of Marcus Nagel (who is employed

by Bain Capital Credit LP, Tower’s largest shareholder

as at 30 September 2021), all of the Directors are

considered to be independent directors. Director

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 RBNZ

and NZX independence requirements.

During FY21 the Board had the following committees:

Audit Committee

Members: Graham Stuart (Chair), Michael Stiassny, Steve

Smith, Warren Lee, Wendy Thorpe, Marcus Nagel.

Risk Committee

Members: Warren Lee (Chair), Michael Stiassny, Graham

Stuart, Steve Smith, Wendy Thorpe, Marcus Nagel.

Remuneration and Appointments Committee

Members: Michael Stiassny (Chair), Graham Stuart, Steve

Smith, Warren Lee, Wendy Thorpe, Marcus Nagel.

Other committees

Tower’s Board has the ability to establish additional

sub-committees from time to time. During FY21, the

Tower Audit Committee established a Disclosure sub-

committee who met once on 17 May 2021 (members of

which were Graham Stuart (Chair), Michael Stiassny, Steve

Smith, Warren Lee, and Wendy Thorpe). During FY21,

Tower’s Board also established a Results sub-committee

who met twice on 25 November 2020 and 26 May

2021 (members of which were Michael Stiassny (Chair),

Graham Stuart, and Steve Smith).

Board and Committee meeting attendance

The Chief Executive Officer, Chief Financial Officer,

General Counsel and Company Secretary attend all

Board meetings by standing invitation, although they

do not always attend the entire meeting. The Chief

Executive Officer, Chief Financial Officer, Chief Risk Officer,

General Counsel and Company Secretary attend all Audit

Committee and Risk Committee meetings by standing

invitation, but do not always attend the entire meeting.

The Chief Executive Officer, Chief People Officer, General

Counsel, and the Company Secretary have a standing

invitation to attend the W and Appointments Committee

meetings, but may be excluded from the meeting from

time to time as appropriate.

All Board and Committee meetings are attended by an

appropriately qualified person who is responsible for

taking accurate minutes of each meeting and ensuring

that Board and Committee procedures are observed.

Director attendance at Board and Committee meetings

held during the year to 30 September 2021 is set out below:

TOWER

LIMITED

BOARD

AUDIT

COMMITTEE

RISK

COMMITTEE

REMUNERATION

AND

APPOINTMENTS

COMMITTEE

DISCLOSURE

SUB-

COMMITTEE

RESULTS

SUB-

COMMITTEE

Meetings held1748412

Michael Stiassny 1748412

Steve Smith1648412

Graham Stuart1648412

Warren Lee174841N/A

Wendy Thorpe174841N/A

Marcus Nagel15484N/AN/A

Remuneration

Director Remuneration—Tower and its subsidiaries

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 a

maximum payment of NZ$900,000 per annum for director

fees. In February 2021 at Tower’s Annual Shareholder

Meeting, Tower’s Board Chair announced that, following a

review of current non-executive director’s fees practices

by Ernst & Young, the Board had agreed to raise directors’

fees. The total payment remained below the maximum

of $900,000 approved by shareholders in 2004, so the

decision did not require a shareholder vote.

Tower seeks external advice when reviewing Board

remuneration. The Remuneration and Appointments

Committee is responsible for assisting directors with the

review of directors’ fees.

Annual fees, including an allowance for sitting on Board

Committees, as approved by the Board with effect from

1 October 2020 for Directors of Tower are:

ROLECHAIR (NZ$)MEMBER (NZ$)

Directors

1

180,000100,000

Audit Committee member fee10,000

Included in

Director Fee

Risk Committee member fee10,000

Included in

Director Fee

Remuneration and Appointments

Committee fee

2

NilNil

1. The fee of $100,000 for non-executive directors who are members of the Board, and

the fee of $180,000 for the Chair of Tower Limited, includes Audit Committee and Risk

Committee fees.

2. 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.

Remuneration and other benefits received by Directors of

Tower during the year ended 30 September 2021 are:

FEE (NZ$), GST

(IF ANY) EXCLUSIVE

Michael Stiassny

1

180,000

Graham Stuart110,000

Steve Smith100,000

Warren Lee110,000

Wendy Thorpe100,000

Marcus Nagel

2

100,000

1. Mr Stiassny also received a further $7,994.30 in travel disbursements during FY21.

2. NZ$ amount shown is converted to, and paid in, Euros (using conversion rate at time of

monthly invoice).

Remuneration and other benefits received by Directors of

Tower subsidiaries in the year to 30 September 2021 are:

FEES

Rodney Reid

1

7,000

Heseti Vaai

1 ^

2,125

Isikeli Tikoduadua

2

18,000

Barry Whiteside

2

20,000

Ernie Gangloff

3

50,000

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.

3. Fees earned in capacity as director of Tower Insurance (PNG) Limited. Tower Insurance

(PNG) Limited fees are paid in Papua New Guinean Kina.

^ Heseti Vaai was a director of National Pacific Insurance Limited for one quarter of FY21.

DIVERSITY & INCLUSION SCORE

8.7

0.4 ABOVE

FINANCE BENCHMARK

GOOD

IN THE MIDDLE RANGE OF THE FINANCE SECTOR

0

10

TOWER LIMITED ANNUAL REPORT 2021 84TOWER LIMITED ANNUAL REPORT 202185CORPORATE GOVERNANCE & STATUTORY DISCLOSURESCORPORATE GOVERNANCE & STATUTORY DISCLOSURES

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 variable remuneration, with clear links between

individual and company performance, and reward. The

Remuneration and Appointments Committee reviews the

remuneration packages of the Chief Executive Officer and

other key executives at least annually.

The Chief Executive Officer, Mr Blair Turnbull, is

remunerated through a combination of a base salary of

$650,000 and variable performance incentives including

a Short Term Incentive (STI) and a Long Term Incentive

(LTI). The maximum STI is currently $325,000 per annum

based on meeting key financial and non-financial and

operational performance measures. The maximum LTI per

annum is currently $975,000 (total) should Tower deliver

Total Shareholder Return out performance relative to the

performance of companies within the NZX50 index.

The table below sets out the remuneration and other

benefits received by the Chief Executive Officer, Mr

Turnbull in the year ended 30 September 2021, with

a comparison to the remuneration and other benefits

received by the Chief Executive Officer in the year

ended 30 September 2020, noting that Mr Blair Turnbull

commenced the role of Chief Executive Officer on

1 August 2020.

2021

$000

2020

$000

Base salary Mr Richard Harding, including accrued

annual leave paid out

850

Compensation for changes to contractual

terms Mr Richard Harding

410

Short term incentive payments Mr Richard Harding525

Base salary Mr Blair Turnbull

1

650100

Total Chief Executive Officer remuneration

2

6501,840

1. In addition to the above, Mr Turnbull was paid a total of $587 for airport parking expenses.

2. Mr Turnbull was eligible for a STI incentive for FY21 of $47,395.83. Mr Turnbull requested,

and the Board agreed, that the STI payment be waived and not paid out. Mr Turnbull was

eligible for a LTI of $260,000 which will be vested and not paid in full until after FY24 as

per the LTI incentive plan.

Employee remuneration

The table below sets out the number of employees or

former employees of Tower, including its subsidiaries,

and excluding directors and former directors, who

received remuneration and other benefits valued at or

exceeding $100,000 for the years ended 30 September

2021, as compared to the year ended 30 September

2020. Remuneration includes base salary, performance

payments and redundancy or other termination payments.

The table does not include company contributions of 3% of

gross earnings for those individuals who are members of a

KiwiSaver scheme. The remuneration bands are expressed

in New Zealand Dollars.

FROMTO2020 2021

100,000109,9992123

110,000119,9992119

120,000129,9991816

130,000139,999188

140,000149,999137

150,000159,999138

160,000169,99965

170,000179,99962

180,000189,99931

190,000199,99932

200,000209,99951

210,000219,99901

220,000229,99933

230,000239,99922

240,000249,99930

250,000259,99922

260,000269,99912

270,000279,99910

280,000289,99923

290,000299,99940

310,000319,99910

320,000329,99901

330,000339,99911

340,000349,99902

350,000359,99901

360,000369,99920

390,000399,99910

400,000409,99910

450,000459,99901

500,000509,99910

530,000539,99901

540,000549,99910

560,000569,99901

610,000619,99901

740,000749,00001

780,000789,99910

1,880,0001,890,00010

Total155109

SECURITY HOLDER INFORMATION

Substantial product holders

(as at 30 September 2021)

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 30 September

2021 are:

NAMETOTAL ORDINARY

SHARES AS AT

30 SEPTEMBER 2021

1

Bain Capital Credit LP, Bain Capital Investments

(Europe) Limited and Dent Issuer Designated

Activity Company

67,464,858

Salt Funds Management Limited29,607,771

Accident Compensation Corporation35,290,324

Investment Services Group Limited27,379,134

New Zealand Funds Management Limited on

behalf of itself and its wholly owned subsidiary

New Zealand Funds Superannuation Limited

26,615,216

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 as at

30 September 2021, which may differ from the stated holdings below.

2. Westpac Banking Corporation ceased to be a substantial product holder on 15 April 2021.

Largest shareholdings

(as at 16 November 2021)

The names and holdings of the 20 largest registered

Tower shareholders as at 16 November 2021 are:

NAME

TOTAL

ORDINARY

SHARES%UNITS

Dent Issuer Designated Activity Company84,329,38619.99

Accident Compensation Corporation36,610,9988.68

Citibank Nominees (New Zealand) Limited35,499,0678.42

HSBC Nominees (New Zealand) Limited21,069,1895.00

BNP Paribas Nominees (NZ) Limited 17,302,0984.10

Lennon Holdings Limited17,000,0004.03

JBWere (NZ) Nominees Limited <NZ

RESIDENT A/C>

13,624,4053.23

Masfen Securities Limited 12,700,0003.01

National Nominees Limited 12,203,4962.89

HSBC Nominees (New Zealand) Limited A/C

State Street

8,631,5292.05

Public Trust 6,450,0001.53

BNP Paribas Nominees (NZ) Limited 4,440,1031.05

HSBC Nominees A/C NZ Superannuation

Fund Nominees Limited

4,313,4831.02

JP Morgan Chase Bank NA NZ Branch -

Segregated Clients Acct

3,378,4530.80

TEA Custodian Limited Client Property Trust

Account

3,228,3540.77

Investment Custodial Services Limited 2,969,9190.70

Forsyth Barr Custodians Limited 2,659,1930.63

Hobson Wealth Custodian Limited 2,486,7560.59

JBWere (NZ) Nominees Limited <53329 A/C>2,076,3020.49

Rural Equities Limited1,912,8720.45

Securities held by Directors

At 30 September 2021, Tower Limited directors held the

following interests in the following Tower securities:

DIRECTOR

Michael Stiassny694,330

Graham Stuart225,000

Steve Smith110,000

Wendy Thorpe16,250

Warren Lee120,500

Marcus Nagel62

TOWER LIMITED ANNUAL REPORT 2021 86TOWER LIMITED ANNUAL REPORT 202187CORPORATE GOVERNANCE & STATUTORY DISCLOSURESCORPORATE GOVERNANCE & STATUTORY DISCLOSURES

Director trading in Tower securities
Directors disclosed the following acquisitions and

disposals of relevant interests in Tower securities during

the financial year ending 30 September 2021 pursuant to

section 148 of the Companies Act 1993.

DIRECTOR

DATE OF

DISCLOSUREINTEREST

NUMBER

ACQUIRED

CONSIDERATION

(NZ$)

Wendy Thorpe5 Jan 2021Beneficial10,0007,309.16

Michael Stiassny30 Nov 2020Beneficial200,000120,000.00

Graham Stuart4 Dec 2020Beneficial100,00062,000.00

Steve Smith1 Dec 2020Beneficial86,92552,120.38

Warren Lee8 Dec 2020Beneficial75,00049,875.00

Marcus Nagel––––

Shareholder analysis

Tower’s shares are quoted on both the NZSX and ASX.

As at 16 November 2021, 16,301 Tower shareholders

held less than A$500 of Tower shares (i.e., less than a

marketable parcel as defined in the ASX Listing Rules),

amounting to a total of 6,249,528 of the Tower shares on

issue. In comparison, a ‘minimum holding’ under the NZX

Listing Rules means a holding of shares having a value

of at least NZ$1,000. As at 16 November 2021, 19,730

Tower shareholders held less than NZ$1,000 of Tower

Shares (being, a parcel size of 1,640 at $0.61 per share),

amounting to a total of 10,187,831 of the Tower shares

on issue.

Total voting securities

As at 16 November 2021, Tower had 421,647,258 ordinary

shares on issue, held by 24,577 holders. By comparison,

on 21 October 2020 (i.e., the date used for the 2020

Annual Report), Tower had 421,647,258 ordinary shares

on issue held by 24,984 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 the office at which

the register of Tower securities is kept is set out in the

directory at the back of this Annual Report.

Spread of shareholders

(as at 16 November 2021)

HOLDING RANGE

HOLDER

COUNT

HOLDER

COUNT

%

HOLDING

QUANTITY

(ORDINARY

SHARES)

HOLDING

QUANTITY

%

1 - 1,00017,45171.107,293,1341.73

1,001 - 5,0004,79119.529,838,8692.33

5,001 - 10,0008293.385,987,4931.42

10,001 - 100,0001,2345.0338,600,3039.15

100,001 and over2390.97359,927,45985.36

Total24,544100421,647,258100

DIRECTOR INTERESTS

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 year to 30 September 2021, pursuant to section

140 of the Companies Act 1993 Tower’s directors disclosed

new interests and cessations of interest as noted in the

table below. Disclosures made since 30 September 2021

are also noted.

Warren Lee

MyState LimitedDirector

MyState Bank LimitedDirector

TPT Wealth LimitedDirector

Avenue Hold Limited (previously called Go Hold Limited)Director

Avenue Bank Limited


(previously called Go Blank Limited)Director

MetLife Insurance LimitedDirector

MetLife General Insurance LimitedDirector

Steve Smith

Kinrich TrustTrustee

Kinrich Holdings LimitedDirector

Summerlee Investments LimitedDirector

Unison Securities LimitedDirector

Unison Capital Advisors LimitedDirector

Pascaro Investments LimitedChair

Trebol Investments Limited and subsidiary companiesDirector

Rimu SA (Chile) and subsidiary companiesDirector

The National Foundation for the Deaf IncorporatedBoard Member

Michael Stiassny

Bengadol Corporation LimitedDirector

Emerald Group LimitedDirector

Gadol Corporation LimitedDirector

Geffen Holdings LimitedDirector

Michael Spencer LimitedDirector

Ngāti Whātua Ōrākei Housing Trustee LimitedDirector

Ngāti Whātua Ōrākei Whai Rawa LimitedChair

Poukawa Estate LimitedDirector

Queenstown Airport Corporation Limited

(until 30 October 2020)

Director

Ted Kingsway LimitedDirector

Whai Rawa GP LimitedDirector

Whai Rawa Kainga Development LimitedDirector

LPF Group LimitedDirector

MS10 LimitedDirector

Morgan HoldCo LimitedDirector

Remuera Investments LimitedDirector

Te Waenga LtdDirector

Tegel Group Holdings Ltd (from 20 May 2021)Director

New Talisman Gold Mines Ltd (from 1 November 2021)Director

Graham Stuart

Leroy Holdings LimitedDirector

EROAD LimitedChair

VinPro LimitedDirector

NorthWest Healthcare Properties Management

Limited (Chair from 10 November 2021)

Chair

Metro Performance Glass LimitedDirector

Wendy Thorpe

Online Education Services Pty LimitedChair

Very Special Kids (until 25 October 2021)Director

Epworth Foundation (Epworth Healthcare)

(Chair from 24 November 2021)

Director

Ausgrid Asset PartnershipDirector

Ausgrid Operator PartnershipDirector

Plus ES PartnershipDirector

Australian Central Credit Union Ltd T/A People’s

Choice Credit Union

Director

Epworth Geelong Limited (from 25 August 2021)Director

Marcus Nagel

3Arrow AGDirector

Jarowa AG (from 8 November 2021)Director

During the financial year, the directors of Tower

subsidiaries disclosed interests and cessations of

interests as noted below, with changes following 30

September 2021 also noted.

Barry Whiteside

Kontiki FinanceDirector

Pacific Catastophe Risk Insurance CompanyDirector

Bayly TrustDirector/Trustee

Isikeli Tikoduadua

Merchant Finance (from October 2020)Chairman

Vodafone Fiji Director

Fiji Commerce Commission Commissioner

iTaukei land Trust Board Director

Special Administrators for Suva City and Lami TownChairman

USP MBA Advisory Committee Chairman

Blair Turnbull

InsurtechNZCo-Chair

Insurance Council of New Zealand Board Member

Ernie Gangloff

1

Gangloff Consulting LimitedManaging Director

Gangloff Projects LimitedDirector

Pacific Training Consortium LimitedDirector

BSP Financial Group LimitedDirector

New Britain Palm Oil LimitedDirector

Highlands Pacific LimitedDirector

Business Incubation Solution LimitedDirector

BSP Finance (Fiji) Pte LimitedDirector

Institute of National Affairs Inc.President

University Rugby Football Union ClubPresident

Capital Rugby Union Inc.Treasurer

1. Ernie Gangloff is a director of Tower Insurance (PNG) (appointed on 30 July 2021) and was

appointed to the companies disclosed in the table above prior to his appointment as a

director of the Tower subsidiary.

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.

OTHER MATTERS

Donations

During the financial year ended 30 September 2021,

donations made by Tower Limited and its subsidiaries

totalled $8,987.73.

TOWER LIMITED ANNUAL REPORT 2021 88TOWER LIMITED ANNUAL REPORT 202189CORPORATE GOVERNANCE & STATUTORY DISCLOSURESCORPORATE GOVERNANCE & STATUTORY DISCLOSURES

Tower subsidiary company directors
The following persons held office as directors of

Tower’s subsidiary companies during the year to

30 September 2021.

Tower Services LimitedBlair Turnbull and Jeffrey Wright

The National Insurance Company

of New Zealand Limited

Blair Turnbull and Jeffrey Wright

National Insurance Company

(Holdings) Pte Limited

Blair Turnbull, Isikeli Tikoduadua,

Jeffrey Wright, Peter Muggleston

1

Southern Pacific Insurance

Company (Fiji) Limited

Blair Turnbull, Isikeli Tikoduadua,

Jeffrey Wright, Peter Muggleston

1

and

Barry Whiteside

Tower Insurance (Fiji) LimitedBlair Turnbull, Isikeli Tikoduadua,

Jeffrey Wright, Peter Muggleston

1

and

Barry Whiteside

Tower Insurance (Cook Islands)

Limited

Blair Turnbull, Jeffrey Wright, and

Peter Muggleston

1

Tower Insurance (PNG) LimitedBlair Turnbull, Jeffrey Wright, Peter

Muggleston

1

, and Jeremy Norton

4

,

and Ernie Gangloff

2

National Pacific Insurance LimitedBlair Turnbull, Rodney Reid, Jeffrey

Wright, Peter Muggleston

1

, and

Heseti Vaai

3

National Pacific Insurance (Tonga)

Limited

Blair Turnbull, Rodney Reid, Jeffrey

Wright, and Peter Muggleston

1

Tower Insurance (Vanuatu)

Limited

Blair Turnbull, Jeffrey Wright, Peter

Muggleston

1

and Stephen Grant Ives

National Pacific Insurance

(American Samoa)

Blair Turnbull, Rodney Reid

4

, Jeffrey

Wright, and Peter Muggleston

1

1. Peter Muggleston was appointed as director on 27 February 2021

2. Ernie Gangloff was appointed as director on 30 July 2021

3. Heseti Vaai was appointed as director on 16 June 2021 and resigned with effect from

1 December 2021

4. Rodney Reid ceased as a director on 3 October 2021

No employee appointed as a director of a subsidiary receives

any remuneration for their role as a Director of that subsidiary.

Credit rating

With effect from 23 April 2021, Global rating organisation

A.M. Best Company issued Tower Limited a financial

strength rating of A- (Excellent).

Waivers

Tower Limited did not rely on, or make any applications

for, waivers from the NZX Listing Rules or the ASX Listing

Rules in the financial year ending on 30 September 2021.

Indemnity and insurance.

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.

Audit fees

Audit and non audit fees paid to Tower’s auditors are

listed on page 70 of this report.

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 prohibits a person

(including associates) from increasing their shareholding

to more than 20% of the voting rights in Tower except in

accordance with the Takeovers Code. The exceptions

include a full or partial takeover offer in accordance with

the Takeovers Code, a scheme of arrangement (under

the Companies Act 1993), 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.

The New Zealand Overseas Investment Act 2005 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 1986 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


Registered Office

New Zealand

Level 14, 45 Queen Street (until 22 August 2021)

Level 5, 136 Fanshawe Street (since 23 August 2021)

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

Lawyers

MinterEllisonRuddWatts

Banker

Westpac New Zealand Limited

Company numbers for FY21

Tower Limited

(Incorporated in New Zealand)

NZ Incorporation 143050

NZBN 9429040323299

ARBN 645 941 028

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”.

TOWER DIRECTORY

Enquiries

For customer enquiries, call Tower on 0800 808 808

or visit www.tower.co.nz

For investor enquires:

Telephone: +64 9 369 2000

Email: investor.relations@tower.co.nz

Website: www.tower.co.nz

Board of Directors

Michael Stiassny (Chair)

Warren Lee

Steve Smith

Graham Stuart

Wendy Thorpe

Marcus Nagel

Chief Executive Officer

Blair Turnbull

Company Secretary

Rachael Watene

(covering parental leave until 16 July 2021)

Fabrizio Ferraro

(covering parental leave from 28 July 2021 – 22

September 2021)

Hannah Snelling

(on parental leave until 22 September 2021)

Executive Leadership Team

Blair Turnbull

Jeff Wright

Gavin Pearce (until December 2020)

Richard McIntosh (until August 2021)

Michelle James

Michelle McBride (until September 2021)

Peter Muggleston

Ronald Mudaliar

Paula ter Brake

Jonathan Beale (since January 2021)

Andrew Hambleton (since September 2021)

TOWER LIMITED ANNUAL REPORT 2021 90TOWER LIMITED ANNUAL REPORT 202191CORPORATE GOVERNANCE & STATUTORY DISCLOSURESTOWER DIRECTORY

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

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

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.

TOWER LIMITED ANNUAL REPORT 2021 92REGISTRAR

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.