Scope of the Review

1. LBG has asked an appropriate independent person (the "Independent Expert") to assess whether information about issues relating to HBOS Reading, which, between 19 January 2009 and 30 January 2017 (the "Relevant Period"), LBG knew, or should have known about through reasonable diligence, was properly investigated and appropriately reported to the police and/or FSA/FCA/PRA (the "Relevant Authorities").

2. Taking into account the legal and regulatory obligations on LBG, the Independent Expert will assess whether, during the Relevant Period:

  1. Issues relating to HBOS Reading were properly investigated;
  2. Issues relating to HBOS Reading were appropriately reported to the Relevant Authorities.

3. For these purposes, “issues relating to HBOS Reading” means:

  1. for the purpose of 2a above, matters which, if properly investigated, might have led to evidence of fraud and/or corruption; and
  2. for the purpose of 2b above, information suggesting fraud and/or corruption.

4. The review is intended to include an assessment of whether any individuals within LBG deliberately sought to suppress or cover up information relating to these issues.

5. The Independent Expert will examine the sources from which customers and other interested parties indicate that LBG knew or should have known about the issues relating to HBOS Reading, including communications from customers and other interested parties, internal LBG documents and reports on HBOS Reading, information that came to light during the trial and other material provided by customers and interested parties.

6. Should further sources of relevant information come to light and/or be identified by the Independent Expert during the Independent Legal Assessment, these will be included in the scope of the assessment.

7. The Independent Expert will also, drawing from her conclusions, set out for LBG any lessons to be learnt not already covered by other reports.

8. The findings will be provided to the FCA, in the context of their enforcement investigation, and to the PRA as required.