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       T R O U B L E D   C O M P A N Y   R E P O R T E R

                          E U R O P E

          Thursday, May 26, 2022, Vol. 23, No. 99

                           Headlines



B E L A R U S

EUROTORG HOLDING: S&P Lowers Foreign Currency ICRs to 'CC/C'


F R A N C E

KILOUTOU: S&P Raises Rating on Sr. Secured Notes to 'B+'


G E R M A N Y

KME SE: Fitch Hikes Sr. Secured Rating to 'BB-' & Affirms 'B-' IDR


G R E E C E

EUROBANK ERGASIAS: S&P Assigns 'B-/B' ICRs, Outlook Stable


K A Z A K H S T A N

KAZAKHMYS INSURANCE: Fitch Alters Outlook on BB- Rating to Positive


N E T H E R L A N D S

ATHORA NETHERLANDS: Fitch Hikes Rating on Jr. Sub. Debt to 'BB+'


R U S S I A

[*] RUSSIA: EUR23 Billion of Central Bank Assets Frozen in EU
[*] RUSSIA: US Ends Debt Payment Exemption Amid Ukraine War


T U R K E Y

EMLAK KATILIM: Fitch Affrims 'B-/B+' IDRs, Outlook Negative
TURK EXIMBANK: Fitch Affirms 'B/B+' LongTerm IDRs, Outlook Negative
TURKIYE SINAI KALKINMA: Fitch Affirms 'B/B+' IDRs, Outlook Neg.


U N I T E D   K I N G D O M

BURNLEY FOOTBALL: Relegation Triggers Requirement to Repay Loan
CALEDONIAN MODULAR: Subcontractors Seek to Recoup Materials
MECHANICAL FACILITIES: Owes GBP9.5MM+ to Unsecured Creditors
ORTHIOS ANGLESEY: Owes GBP210 Million to Creditors, Report Shows
THG PLC: S&P Affirms 'B' Long-Term ICR & Alters Outlook to Negative

WISE PLC 2006-1: Moody's Hikes Rating on Class C Notes to Caa2

                           - - - - -


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B E L A R U S
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EUROTORG HOLDING: S&P Lowers Foreign Currency ICRs to 'CC/C'
------------------------------------------------------------
S&P Global Ratings lowered its long-term foreign currency issuer
credit ratings on Belarussian retailer Eurotorg Holding PLC to
'CC/C' from 'CCC/C'. S&P also lowered its issue rating on its
senior unsecured obligations to 'CC' from 'C'. These ratings remain
on CreditWatch negative.

S&P said, "At the same time, we affirmed our local currency issuer
credit ratings on Eurotorg at 'CCC/C' and removed the long-term
rating from CreditWatch negative, where we placed it on March 10,
2022, as we consider Belarusian ruble-denominated debt is less
vulnerable to nonpayment."

On May 5, 2022, S&P Global Ratings lowered its foreign currency
sovereign credit ratings on Belarus to 'CC/C' from 'CCC/C'. The
foreign currency long- and short-term rating remains on CreditWatch
negative.

S&P said, "The downgrade of our foreign currency ratings on
Eurotorg to 'CC', the same level as the foreign currency rating and
the T&C assessment on Belarus, reflects the heightened sovereign
risk for all Belarussian corporate issuers. A country T&C
assessment reflects S&P Global Ratings' view of the likelihood of a
sovereign restricting nonsovereign access to foreign exchange
needed to satisfy the nonsovereign's debt service obligations. The
foreign currency ratings remain on CreditWatch negative.

"We affirmed our local currency ratings on Eurotorg because we
consider that Eurotorg's Belarussian ruble-denominated debt is less
vulnerable to nonpayment than the foreign-currency-denominated
debt.

"The rating action on Eurotorg mirrors that on the sovereign.

"The international community could apply further sanctions to
Belarus and the macroeconomic environment continues to deteriorate.
In our view, if there is no unforeseen positive development,
Eurotorg is likely to face a fall in demand, with consumers
slashing spending on all product categories, leading to pressures
on operating performance. Coupled with the expected depreciation of
the Belarussian ruble against both the dollar and the Russian
ruble, and taking into account that 99% of Eurotorg's debt is
denominated in foreign currencies (49% in Russian ruble, 37% in
U.S. dollars, and 13% in euros, as of end-December 2021), we
believe that the group's liquidity is increasingly at risk.

"The negative outlook on the local currency ratings reflects our
anticipation that macroeconomic fallout in Belarus is likely to
weaken Eurotorg's earnings and that difficult operating conditions
due to the sanctions affecting the banks and the sovereign will
lead to liquidity depletion.

"We could lower the local currency ratings if we saw indications
that Eurotorg would be prevented from accessing daily operation
financing through local banks and if we believed the company would
face a liquidity crunch likely to translate into a distressed debt
restructuring.

"We could revise the outlook to stable or raise the local currency
ratings if the macroeconomic fallout for Belarus proved weaker than
we anticipate.

"The foreign currency ratings remain on CreditWatch negative. We
could lower the foreign currency ratings to 'SD' in the next few
months if Eurotorg fails to make a debt service or principal
payment in accordance with the terms of its foreign-denominated
obligations, or if we do not expect such a payment to be made
within the applicable grace period."

ESG credit indicators: E-2, S-2, G-4




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F R A N C E
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KILOUTOU: S&P Raises Rating on Sr. Secured Notes to 'B+'
--------------------------------------------------------
S&P Global Ratings raised its long-term ratings on French rental
equipment group Kapla Holding (Kiloutou) and it senior secured
notes to 'B+' from 'B', with the recovery rating unchanged at '3',
indicating its expectation of 50%-70% recovery in a default
scenario (rounded estimate: 55%).

The stable outlook reflects S&P's expectation that Kiloutou will
successfully integrate GSV and any further bolt-on acquisitions,
while maintaining adjusted EBITDA margins higher than 35% and
adjusted debt to EBITDA of 4.0x-4.5x in 2022.

Kapla Holding (Kiloutou) has acquired Danish competitor GSV,
thereby strengthening its position in Europe and diversifying its
revenue streams.

Because the acquisition of GSV is EBITDA accretive, Kiloutou's
leverage will remain broadly commensurate with a 'B+' rating.
Kiloutou typically funds acquisitions with a blend of cash and new
debt. However, its acquisition targets usually also boost its
EBITDA, therefore leverage remains stable. S&P said, "We assume
that, to replenish its cash balances and liquidity lines after the
GSV acquisition, which included about EUR11 million of fees, the
company will eventually issue new term debt, likely on the same
terms and conditions as its outstanding EUR860 million fixed- and
floating-rate notes. Pro forma the acquisition, and based on our
assumptions on Kiloutou's capital structure, we expect Kiloutou
will have S&P Global Ratings-adjusted debt of about EUR1.6
billion-EUR1.7 billion at year-end 2022 (which includes our
assumptions on senior secured fixed and floating-rate notes,
bilateral loans, government loans, IFRS-16 debt and financial
leases and new debt that the company could potentially issue). We
do not expect the company to make further large acquisitions over
our 12-month rating horizon. Kiloutou continues to exhibit good
operating performance, in line with our expectations, and we
forecast revenue growth at about 29% for 2022, adjusted EBITDA
margins at 36%-37%, slightly diluted by the acquisition of GSV, and
adjusted debt to EBITDA at 4.0x-4.5x. In 2023, we forecast about
10% top-line growth, with margins at 37%-38% and leverage in the
same range."

S&P said, "With Kiloutou investing heavily in its fleet to capture
rising rental volumes, we expect FOCF to turn negative in 2022 but
recover to positive in 2023. In 2022, Kiloutou will likely generate
negative FOCF of about EUR20 million before this returns to more
than EUR50 million positive in 2023 as capital expenditure (capex)
reduces. However, we note that Kiloutou continuously invests in a
high amount of expansion capex that it could scale back rapidly if
volumes were to soften, as rental equipment companies demonstrated
during the pandemic.  In our base case, we forecast about EUR320
million gross capex in 2022 and EUR265 million in 2023, up from
EUR137 million in 2021. Furthermore, we estimate funds from
operations (FFO) cash interest coverage to remain robust,
surpassing 5x for 2022 and 2023."

Although Kiloutou's geographic footprint is widening, it remains
mainly concentrated on one market versus peers. The acquisition of
GSV, a Danish rental equipment player, enables the group to
penetrate a new but relatively small market, Denmark (estimated at
about EUR620 million in 2021), and strengthen its European
position.  S&P sees the increased geographic diversification as
positive, since the group will generate about 30% of its revenue
outside France. In S&P's view, the group will consolidate further
its No. 3 position in the European rental equipment market and
reduce the gap to its competitors Loxam and Boels. Although
Kiloutou has gradually diversified and expanded its geographic
coverage -- France represented 84% of revenue for 2019, versus 91%
in 2017--we note that direct peers are much better geographically
diversified. For example, Loxam generates about 40% of its revenue
in France and the rest across Europe, and it is more than twice the
size of Kiloutou by revenue and EBITDA.

S&P said, "We estimate that Kiloutou has no material exposure to
Russia or Ukraine. We understand from management that the group
does not have any branches or operations in Russia or Ukraine, and
Kiloutou doesn't rely on either country for new fleet, raw
materials, or labor. Therefore, we believe the conflict has no
direct impact on Kiloutou's operating performance.

"The stable outlook reflects our expectation that Kiloutou will
successfully integrate GSV and continued bolt-on acquisitions,
increase revenue and EBITDA, and exhibit adjusted EBITDA margins
higher than 35%. We assume Kiloutou will moderate the pace of
future acquisitions to avoid a meaningful imbalance between rising
debt and accretive earnings. We forecast adjusted debt to EBITDA
will be below 5.0x in 2022-2023.

"We could lower the ratings if the company demonstrated weaker
results amid unfavorable market conditions and paid out a large
amount of cash without reducing capex in a timely manner. Credit
metrics such adjusted EBITDA margins below 35%, and debt to EBITDA
exceeding 5x for a prolonged period, with no prospects of recovery,
would put pressure on the ratings. If the company continued to make
sizable acquisitions that led to significant debt buildup, with
consistently weaker-than-expected debt to EBITDA, we could lower
the ratings.

"We could raise the ratings if Kiloutou achieved and sustained
stronger credit metrics, with adjusted EBITDA margins higher than
35%, not significant negative FOCF, and debt to EBITDA sustainably
below 4.0x. Kiloutou could achieve this if it continues to
diversify its geographic diversification, thereby reducing its
dependence on the French market, decreases debt, and demonstrates
better-than-anticipated operating performance."

ESG credit indicators: E-2, S-2, G-3

S&P said, "Governance factors are a moderately negative
consideration in our credit rating analysis of Kiloutou because we
view financial sponsor-owned companies with aggressive financial
risk profiles as demonstrating corporate decision-making that
prioritizes the interests of the controlling owners, typically with
finite holding periods and a focus on maximizing shareholder
returns. Environmental and social factors are an overall neutral
consideration in our credit rating analysis. Despite a construction
sector concentration, the long-term growth prospects are supported
by the structural shift toward equipment rental instead of each
customer owning its own fleet, with equipment reused for five to
seven years on average. This allows the company's customers to meet
their corporate social responsibility targets in terms of
compliance with regulations, safety, and carbon-footprint
reduction. In our view, Kiloutou can comfortably meet the capex
required for a new fleet that meets rising demand from its
customers for more environmentally sustainable rental equipment."




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G E R M A N Y
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KME SE: Fitch Hikes Sr. Secured Rating to 'BB-' & Affirms 'B-' IDR
------------------------------------------------------------------
Fitch Ratings has upgraded German-based manufacturer KME SE's
senior secured rating to 'BB-' from 'B' following a partial bond
redemption and removed it from Rating Watch Positive (RWP). Its
Recovery Rating has been revised to 'RR1' from 'RR3'. KME SE's
Long-Term Issuer Default Rating (IDR) has been affirmed at 'B-'
with Stable Outlook.

The upgrade reflects the EUR190 million early redemption of KME's
EUR300 million notes due in February 2023, with proceeds from the
divestment of a 55% stake in its special division to German
private-equity fund Paragon Partners GmbH. As a result, Fitch
expects KME's total debt/EBITDA to stabilise at around 4x-5x over
2022-2024, which is in line with the rating, compared with previous
high levels.

The IDR is constrained by the volatility of copper product
manufacturing, an effect of KME's dependence on copper prices, and
by fairly weak profitability and cash flow, reflecting KME´s
position in the value chain.

KEY RATING DRIVERS

Leverage in Line with Rating: Following the divestment of 55% of
KME's special division, M&A activities and improving EBITDA on
price increases Fitch forecasts total debt/EBITDA at around 4.5x at
end-2022, down from 5.3x at end-2021. From 2023, Fitch forecasts
moderate deleveraging to around 4x, which is in line with the upper
range of a 'B' rating in Fitch's Diversified Industrials and
Capital Goods Ratings Navigator. Fitch views that moderate leverage
would allow a volatile business, such as KME's, which is dependent
on copper prices, to better withstand market swings.

Less Diversified Offering: Following the stake divestment, KME will
be focused on rolled copper products and its alloys. Revenue will
therefore be lower in 2022, but Fitch-forecast growth for the
remaining business in 2023 will partly compensate the shortfall.
Growth is driven by strong demand for copper products, accretive
revenue from its recently announced acquisition of Aurubis'
flat-rolled product plant in The Netherlands, high copper prices
and KME's realised price increases. The divestment gives KME some
financial capacity to strengthen its position in rolled copper with
acquisitions, but Fitch presently views its product range and
geographic diversification as weaker than before the divestment.

Refinancing Risk Remains High: Fitch believes that the upcoming
maturity of the remaining EUR110 million notes in February 2023,
combined with maturities of KME's borrowing base and factoring
facilities in November 2022, will define their future liquidity
profile. Fitch continues to see high refinancing riskfor these
facilities.

Low but Improving Profitability: KME's Fitch-adjusted EBITDA margin
almost doubled yoy to 4.2% in 2021, mainly on higher copper prices,
but also reflecting the IFRS accounting of inventory valuation. It
was, however, below Fitch's previous forecast due to a time lag in
the pass-through of higher copper prices. A material part of KME's
EBITDA was generated in the divested special division, but Fitch
expects its overall EBITDA margin to improve slightly to 4.5% in
2022, due to favourable market sentiment and price increases,
before stabilising on continued strong demand for copper.
Nevertheless, KME's profitability is below that of similarly rated
peers and constrains the rating to 'B-'.

Thin FCF Margin: Despite KME's higher profitability, Fitch expects
the free cash flow (FCF) margin to turn negative in 2022 due to
high working-capital outflows, mainly related to revenue growth and
high copper prices. Thereafter, Fitch forecasts a recovery to above
1% as working capital outflows stabilise and interest costs
decrease. Fitch views this as a long-term sustainable level based
on KME's low-margin operating environment for a producer of copper
and copper alloy products.

Strong Demand for Copper: Copper prices have soared from their low
point in March 2020, driven by high demand globally with tight
inventories as a result. Fitch forecasts average copper prices to
reach USD10,000/tonne at end-2022, up on USD9,300/tonne at end-2021
as supply issues in Latin America combined with the Russia-Ukraine
conflict push prices to new highs. Fitch expects prices to slightly
ease in 2H22 as supply improves, but long-term demand mainly driven
by the global transition to a green economy will continue to
support prices. Fitch expects KME's revenue and profitability to
continue to benefit from high copper prices in the medium term.

Constrained Business Profile: KME's business profile is constrained
by its fairly small scale, concentration on Europe and a limited
product range after the disposal of the special division. This is
also related to low entry barriers, which are an effect of the
highly commoditised processing of most copper products. Further,
Fitch see risks related to its uncertain M&A strategy. The business
profile is supported by KME's leading market positions in Europe
within copper products and a diversified customer base with
long-term customer relationships, of up to 20 years with some
larger clients and KME's exposure to end-markets with firm growth
prospects driven by investments in the green economy.

DERIVATION SUMMARY

KME's scale is smaller than that of its direct competitor Wieland
Group's and Aurubis Group's and aluminium processing peer
Constellium's. They all operate in a low-margin environment due to
their position in the value chain, but Constellium has higher
margins than KME. It is mainly due to lower basic metal prices
(aluminium versus copper), given Constellium's higher value-added
product portfolio.

KME's leverage has been higher than that of similarly rated peers
in the diversified industrials and capital goods sector, but
expected deleveraging in 2022 will result in lower total
debt/EBITDA than industrial belt manufacturer Ammega Group B.V.'s
(B-/Stable) and elevator manufacturer TK Elevator Holdco GmbH's
(B/Stable). This is balanced by weaker product and geographical
diversification and weaker profitability and cash flow generation.
KME´s leverage will, however, remain higher than that of
Constellium in the medium-to-long term.

KEY ASSUMPTIONS

-- Revenue to have increased around 14% in 2021 due to high
    copper prices, price increases and demand recovery. Revenue to

    decline 15% in 2022 on the disposal of the special division
    and wire business followed by an increase of 9% in 2023 on
    organic and acquisition growth, and single-digit growth in
    2024;

-- EBITDA margin to have improved to around 4% 2021 and to around

    4.5% in 2023-2024;

-- High working capital outflows in 2021-2022 due to business
    recovery and high copper prices, before normalising from 2023;

-- Capex at around 1% sales in 2021 and around 1.4% for 2022-
    2024;

-- No dividend paid and received to 2024;

-- Refinancing of its EUR110 million outstanding bond in 2022;

-- Extension of KME's borrowing-base facility and factoring
    lines on a regular basis.

KEY RECOVERY ASSUMPTIONS

-- Fitch's bespoke recovery for KME's senior secured debt is
    based on a liquidation approach;

-- The approach reflects the security package of the senior
    secured notes and the borrowing-base facility, which contains
    separate collateral;

-- The recovery analysis is based on the recent partial early
    redemption of the EUR300 million notes (outstanding amount
    EUR110 million at end-April 2022) and the residual security
    package value after the disposal of the special division;

-- Fitch applies a discounted market value of KME's property and
    the net book value of the machinery and equipment related to
    the property securing the notes;

-- A going-concern EBITDA of EUR35 million and a 4.0x distressed
    enterprise value/EBITDA multiple adjusted with a 10%
    administrative charge;

-- These assumptions result in a recovery rate for the senior
    secured rating within the 'RR1' range, which enables a three-
    notch uplift to the debt rating from the IDR.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

-- Funds from operations (FFO) gross leverage sustainably
    below 5.0x;

-- Debt/EBITDA sustainably below 4.0x;

-- FFO margin sustainably above 4%;

-- FCF margin above 2%;

-- Improving diversification.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

-- FFO gross leverage consistently above 7.0x;

-- Debt/EBITDA consistently above 6.0x;

-- Negative FCF margin;

-- Lack of progress to refinance 2023 maturities.

LIQUIDITY AND DEBT STRUCTURE

Limited Liquidity: Fitch views KME's liquidity profile as adequate
for continued operations in the short term. This is based on EUR75
million of cash on the balance sheet at end-2021, after adjusting
for not-readily-available cash of EUR5 million, as well as an
available EUR30 million shareholder working-capital facility line.
Further, KME has access to a committed EUR320 million
borrowing-base facility, which is highly utilised for outstanding
letters of credit, leaving no headroom for regular cash funding.

Fitch expects a working-capital outflow in 2022, due to high copper
prices, before it normalises in 2023-2024. Further, restructuring
costs also weigh on FCF generation, which Fitch forecasts to be
neutral to positive until 2024.

Fitch assumes that KME will have continued access to
working-capital facilities based on its regular extension pattern
in the past as well as compliance with financial covenants under
its borrowing-base facility agreement and factoring programme. This
mitigates liquidity risks.

Refinancing Risk: Refinancing risk related to the senior secured
notes maturing in February 2023 is high, but has been partly
mitigated through their recent partial redemption. Leverage metrics
have improved and Fitch believes the business recovery in 2022 will
allow KME to gain access to new financing.

ISSUER PROFILE

KME is a producer of semi-finished and finished copper and copper
alloy products for use in other products and processes by a wide
range of end users and industries. The production facilities are
located in Europe, China and the US.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means ESG issues are
credit-neutral or have only a minimal credit impact on the entity,
either due to their nature or the way in which they are being
managed by the entity.




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G R E E C E
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EUROBANK ERGASIAS: S&P Assigns 'B-/B' ICRs, Outlook Stable
----------------------------------------------------------
S&P Global Ratings assigned its 'B-/B' long- and short-term issuer
credit ratings to nonoperating holding company (NOHC) Eurobank
Ergasias Services Holdings (Eurobank Holdings). The outlook is
stable.

S&P said, "The ratings on Eurobank Holdings reflect our assessment
of the 'b+' group credit profile (GCP) for its consolidated
activities with Eurobank S.A., the operating entity, as well as
Eurobank Holdings' NOHC status.As a result, its creditors are
structurally subordinated to those of the operating bank
subsidiary. Since the GCP is speculative-grade, we deduct two
notches to derive the rating on the NOHC to indicate the increased
credit risk arising from possible regulatory and operational
constraints on upstreaming resources, especially as tier 2
instruments will be retained at the NOHC level and coupon payments
will depend on cash flows from Eurobank S.A. Eurobank Holdings owns
100% of Eurobank S.A. and has no other large-scale businesses.

"Our 'b+' GCP assessment reflects Eurobank's solid franchise within
the concentrated Greek banking system against its low level of
risk-adjusted capital, and the low quality of its risk-adjusted
capital, owing to a high amount of deferred tax credits. The
ratings are constrained by the large stock of legacy nonperforming
exposures (NPEs) on its books compared with those of peers
elsewhere in Europe. Management has made progress toward the
targets set in the corporate transformation plan. Nevertheless,
restoration of domestic profitability will take time as the private
sector recovers from the crisis and demand for new loans remains
weak. Because the GCP is speculative-grade, we deduct two notches
to derive the rating on the NOHC.

"Our stable outlook on Eurobank and Eurobank Holdings over the next
12 months balances their low quality of capital against their
strong business franchise in Greece and improved liquidity. In that
time, we expect the economic rebound in Greece, supported by
expected use of structural EU funds, to bolster the bank's ongoing
transformation and the restoration of its operational performance
and asset quality. We expect Eurobank's risk-adjusted capital (RAC)
ratio to improve to 4.0% by end-2023. Eurobank, like National Bank
of Greece, has disposed of a large part of its legacy problem
loans, which should support its lending growth against a strong
economic rebound. In our view, the benefits of significant
cost-cutting efforts in recent years will be partly offset until
year-end 2022 by additional provisioning needs for planned NPE
sales, and slight margin contraction. Because it plans to dispose
of more NPEs, we expect Eurobank's NPE ratio to improve further,
but remain above the European average.

"We could raise the rating on Eurobank S.A. in the next 12 months
should the bank maintain its recent positive momentum on earnings
and asset quality. An upgrade could occur if the quality of capital
and RAC ratio improve materially, although this is not our
base-case scenario. In the coming year, we will closely monitor how
the bank reduces its risk exposure and brings its earnings, NPE
ratio, and cost of risk more in line with those of higher-rated
peers.

"A positive rating action on Eurobank Holdings would most likely
follow a positive rating action on Eurobank. This might not occur
if we were to see significant increase in double leverage, in a
scenario where the NOHC's investments in Eurobank materially and
sustainably exceeds 120% of its equity.

"We could lower the rating on both entities if the RAC ratio drops
and stays below 3% or its asset-quality metrics deteriorate
further. This could happen if economic conditions in Greece do not
improve as we anticipate.

"In addition, we could lower the rating on Eurobank Holdings if we
saw a lower likelihood of the bank meeting its obligations toward
the NOHC."




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K A Z A K H S T A N
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KAZAKHMYS INSURANCE: Fitch Alters Outlook on BB- Rating to Positive
-------------------------------------------------------------------
Fitch Ratings has revised the Outlooks on JSC Kazakhmys Insurance
Company's (Kazakhmys Ins) Insurer Financial Strength (IFS) Rating
and National IFS Rating to Positive from Stable and affirmed the
IFS Rating at 'BB-' and National IFS Rating at 'BBB+(kaz)'.

KEY RATING DRIVERS

The revision of the Outlook to Positive reflects higher volumes of
profitable business retained by Kazakhmys Ins and Fitch's
expectations that the company will maintain risk retention at least
at the current levels.

The ratings continue to reflect Kazakhmys Ins's 'favourable'
business profile, adequate capital position and profitability, but
are constrained by high, albeit reducing, dependence on outwards
reinsurance.

Fitch ranks Kazakhmys Ins' business profile as 'favourable'
relative to that of other insurers in Kazakhstan, Russia and the
broader CIS region. Kazakhmys Ins remains a commercially focused
insurer with a significant dependence on one customer - Kazakhmys
Corporation LLC. Nevertheless, the size of the related-party
business allows Kazakhmys Ins to be one of the largest local
commercial underwriters.

Kazakhmys Ins' reinsurance utilisation ratio, measured as a share
of earned premiums, improved to 76% in 2021 from 88% in 2020 and
was lower than its five-year average of 87% in 2017-2021, which we
view as a positive development. Fitch understands from management
that Kazakhmys Ins plans to continue retaining business at least at
the current levels. Fitch views decreasing dependence on
reinsurance as important for the insurer's successful long-term
development.

In 2021, Kazakhmys Ins reported KZT4.4 billion net income and 31%
return on equity, compared with KZT2.7 billion and 21% the previous
year. The increase in net profit was supported by a very strong
underwriting result due to a higher volume of net earned premiums.
Kazakhmys Ins's portfolio has had strong underwriting results with
an average loss ratio of 2% on gross basis (before reinsurance) in
2017-2021. However, due to the nature of its written commercial
risks, Kazakhmys Ins ceded on average 87% of its earned premiums to
reinsurers in the same period. Given the absence of large claims,
the strong underwriting result generated by Kazakhmys Ins's
portfolio is mainly consumed by reinsurers.

Kazakhmys Ins's risk-adjusted capital position, measured by Fitch's
Prism Factor-Based Capital Model, weakened to 'Strong' at end-2021
from 'Very Strong' at end-2020 due to a KZT3.5 billion dividend
pay-out in 1Q22. The insurer complied with regulatory solvency
requirements with a solvency margin of 265% at end-3M22. Kazakhmys
Ins updated its dividend policy to pay-outs at no more than 80% of
current year earnings, in order to allow organic capital growth to
support increasing business volumes and more predictable capital
levels. However, Kazakhmys Ins's capital remains highly exposed to
risks related to the quality of reinsurance protection.

Fitch views Kazakhmys Ins's investment strategy as fairly prudent
given the available choice of domestic investment instruments. The
insurer does not have any meaningful equity holdings and maintains
good average credit quality of bonds and bank instruments.

RATING SENSITIVITIES

IFS RATING

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

-- Reduction of Kazakhmys Ins's dependence on reinsurance,
provided the insurer repositions its business mix while maintaining
the current levels of asset risk, capital and profitability

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

-- Failure of the reinsurance programme to protect the insurer's
capital from material underwriting losses

-- The Outlook is likely to be revised to Stable if risk retention
levels fall back to their pre-2020 levels

NATIONAL IFS RATING:

Factors that could, individually or collectively, lead to positive
rating action /upgrade:

-- Strengthening of business profile as a result of better
portfolio diversification and reduced dependence on premiums ceded
from related parties

Factors that could, individually or collectively, lead to negative
rating action /downgrade:

-- Failure of the reinsurance programme to protect the insurer's
capital from material underwriting losses

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means ESG issues are
credit-neutral or have only a minimal credit impact on the entity,
either due to their nature or the way in which they are being
managed by the entity.




=====================
N E T H E R L A N D S
=====================

ATHORA NETHERLANDS: Fitch Hikes Rating on Jr. Sub. Debt to 'BB+'
----------------------------------------------------------------
Fitch Ratings has upgraded Athora Life Re Ltd.'s, Athora Ireland
plc's and SRLEV N.V.'s Insurer Financial Strength Ratings (IFS) to
'A' (Strong) from 'A-' and Athora Holding Ltd.'s and Athora
Netherlands N.V.'s (Athora NL) Issuer Default Ratings (IDR) to 'A-'
from 'BBB+' (Good). The Outlooks are Stable.

The upgrades reflect the improvement in Athora's business profile
and financial performance. The ratings reflect Athora's very strong
business profile, very strong capitalisation and leverage, strong
financial performance and the group's high investment risk.

KEY RATING DRIVERS

Improved Company Profile: In 2021, Athora entered into the Italian
life insurance market with the acquisition of Amissima Vita S.p.A.,
further improving its geographical diversification. The group also
is becoming active in external reinsurance. Fitch now regards the
group's geographical diversification as 'favourable', up from
'moderate'.

Fitch said, "We regard Athora's business profile as 'favourable'
compared with other Dutch and Western European life insurers.
Athora has a leading market position and franchise within the
European life consolidator market. With total assets of EUR81
billion at end-2021, Athora's operating scale is favourable
compared with other European life insurance groups."

Strong Financial Performance: Fitch expects Athora NL's
profitability to benefit from the implementation of Athora's
strategic asset allocation favouring investments with higher
expected returns. Fitch expects Athora to achieve a
Fitch-calculated net income return on equity (ROE) of 8% and more
in 2023 although we expect that 2022 will be a transition year with
an ROE of 5% to 8%.

Athora's ROE fell to 3% in 2021 from 28% in 2020. However, Fitch's
pre-tax operating profit RoE was more stable at 12% in 2021 (2020:
25%). As such, underlying profitability was relatively stable in
2021 because 2020 return figures benefited from large one-offs and
a low starting equity position for 2020, while 2021 net income
suffered from a high tax burden.

Very Strong Capitalisation and Leverage: Fitch expects Athora's
group capitalisation to decline somewhat as the group grows its
business, but that the group's Prism Factor-Based Capital Model
(Prism FBM) score will remain at least 'Very Strong'. Athora's
Prism FBM score was 'Extremely Strong' at end-2021. Fitch expects
financial leverage ratio (FLR) to remain stable at around 25% at
end-2022 (2021: 24%).

High Investment Risk: Fitch regards Athora's investment risk as
high, but manageable. Most of Athora's investments are holdings of
investment-grade corporate and sovereign bonds. Athora also invests
in private credit assets, alternative investments and commercial
mortgage loans.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

-- A sustained ROE of more than 10% while maintaining at least a
'Very Strong' Prism FBM score. However, we regard this as unlikely
in the medium term.

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

-- A fall in the Prism FBM score to 'Strong'.

-- A sustained increase in the FLR above 30%.

-- A sustained ROE below 5%.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means ESG issues are
credit-neutral or have only a minimal credit impact on the entity,
either due to their nature or the way in which they are being
managed by the entity.

Rating Actions

                                  Rating             Prior
                                  ------             -----
SRLEV N.V.               LT IDR        A-   Upgrade   BBB+
                         Ins Fin Str   A    Upgrade   A-
subordinated            LT            BBB  Upgrade   BBB-

Athora Ireland plc       Ins Fin Str   A    Upgrade   A-

Athora Holding Ltd.      LT IDR        A-   Upgrade   BBB+

Athora Life Re Ltd.      Ins Fin Str   A    Upgrade   A-

Athora Netherlands N.V.  LT IDR        A-   Upgrade   BBB+
senior unsecured        LT            BBB+ Upgrade   BBB
subordinated            LT            BBB- Upgrade   BB+
junior subordinated     LT            BB+  Upgrade   BB




===========
R U S S I A
===========

[*] RUSSIA: EUR23 Billion of Central Bank Assets Frozen in EU
-------------------------------------------------------------
Francesco Guarascio at Reuters reports that European Union states
have reported the freezing of about EUR23 billion (US$24.5 billion)
of assets of the Russian Central Bank, a top EU official said on
May 25 revealing for the first time a figure that was expected to
be much higher.

According to Reuters, Russia has publicly said that Western
sanctions led to the freezing of about US$300 billion of its
central bank's assets globally.

Of these frozen assets, only less than one-tenth is in the EU,
according to information that the European Commission has collected
from the 27 EU governments, EU Justice Commissioner Didier Reynders
told a news conference, Reuters relates.

He said that about EUR23 billion had been frozen in the EU since
the start of the war in Ukraine in February, a figure that is
dwarfed by the US$100 billion frozen by the United States, Reuters
discloses.

Mr. Reynders said in addition to that, EU countries have also
frozen about EUR10 billion of physical assets, such as yachts and
villas, linked to oligarchs and officials with ties to the Kremlin,
according to Reuters.

He did not explain why the third largest economy in the world had
apparently attracted so few assets from the Russian central bank,
Reuters notes.


[*] RUSSIA: US Ends Debt Payment Exemption Amid Ukraine War
-----------------------------------------------------------
AFP reports that the United States will end an exemption allowing
Moscow to pay foreign debt held by American investors with funds
held in Russia, the US Treasury said on May 24, a move that could
push Vladimir Putin's country closer to default.

The escape clause to the drastic financial sanctions imposed on
Moscow after it invaded Ukraine in late February, which allowed US
banks to receive and process the payments to creditors, was due to
end Wednesday, May 25, two days before Russia's next debt service
payment is due, AFP discloses.

Punishing Western sanctions on Russia have largely severed the
country from the international financial system, including blocking
Moscow's ability to access funds held in US banks to pay its
foreign creditors, AFP notes.

The latest move scraps the final outlet, which was forcing Putin's
government to drain its war chest of reserves to make payments, AFP
states.

According to AFP, US Treasury Secretary Janet Yellen had signaled
the default was the goal, part of President Joe Biden's efforts to
intensify the pressure on Putin as the war rages on.

"Russia is not able right now to borrow in global financial
markets, it has no access to capital markets.  If Russia is unable
to find a legal way to make these payments . . . they technically
default on their debt," AFP quotes Ms. Yellen as saying last week.

The Russian government has attempted to pay in domestic currency,
but many of the bonds do not allow repayment in rubles, AFP
discloses.

The government still faces a dozen debt service deadlines this
year, AFP notes.

The next one, on May 27, is for EUR100 million in interest on two
bonds: one requires payment in dollars, euros, pounds or Swiss
francs only; the other can be paid in rubles, AFP discloses.

According to reports by Reuters and The Wall Street Journal on
Friday, the Russian Finance Ministry transferred funds out of the
country early to make the payments and avoid default, AFP relays.

Nearly US$400 million in interest is due in late June, AFP states.

After a 15- to 30-day grace period following a missed payment, the
country likely would be declared in default, further deteriorating
its financial position and allowing creditors to take legal action
to recover the funds, according to AFP.

However, Moscow is still bringing in vast amounts of cash from its
energy exports, and is forcing countries in Europe to pay in rubles
to avoid sanctions, AFP notes.

That situation could change if Europe goes through with an oil
embargo, although EU officials have been discussing the issue for
weeks without a resolution, AFP discloses.




===========
T U R K E Y
===========

EMLAK KATILIM: Fitch Affrims 'B-/B+' IDRs, Outlook Negative
-----------------------------------------------------------
Fitch Ratings has affirmed Turkiye Emlak Katilim Bankasi A.S.'s
(Emlak Katilim) Long-Term Foreign-Currency (LTFC) Issuer Default
Rating (IDR) at 'B-' and Long-Term Local-Currency (LTLC) IDR at
'B+'. The Outlooks are Negative.

Fitch has assigned Emlak Katilim a 'b-' Viability Rating (VR),
reflecting the bank's fast growing operations and expanding, albeit
still limited, independent franchise, despite a short record.

KEY RATING DRIVERS

Emlak Katilim's LTFC IDR is driven by its VR and underpinned by
government support at 'B-'. The VR and the Negative Outlook on the
LTFC IDR reflect the bank's still fairly untested business model,
limited franchise and rapid growth in the challenging Turkish
operating environment. Concentration risk is significant in both
financing and deposits, given the bank's small size. Risks to
capitalisation are heightened by high foreign-currency (FC)
financing, given the Turkish lira depreciation, seasoning risks and
growth.

The bank's 'B+'/Negative LTLC IDR is equalised with the sovereign
rating on the basis of support, reflecting a stronger sovereign
ability to provide support in local currency (LC) and a lower risk
of government intervention in lira. The Negative Outlook reflects
that on the sovereign. The Short-Term LC and FC IDRs of 'B' map to
the Long-Term IDRs.

The 'AA' National Rating reflects the bank's state ownership and is
in line with other state-owned commercial banks.

Operating Environment Pressure: Emlak Katilim's operations are
concentrated in the Turkish market, resulting in exposure to macro
and financial stability risks, including high inflationary and
significant lira volatility.

Limited but Growing Franchise: Emlak Katilim has been expanding its
franchise (end-1Q22: 0.5% of total banking sector assets) in the
participation banking sector since it was established in 2018. The
bank targets aggressive financing growth, although from a low base,
mainly in Turkish lira and targeting SMEs. However, its strategy
could change depending on the government's economic agenda.

Emlak's ESG Relevance Scores of '4' for Governance Structure and
Management Strategy (in contrast to typical '3' for comparable
banks) reflects potential government influence over its board's
effectiveness and management strategy in the challenging Turkish
operating environment, which has a negative impact on the credit
profile, and is relevant to the ratings in conjunction with other
factors.

High Risk Appetite; Concentrated Financing Portfolio: Credit risk
is heightened by Emlak Katilim's rapid growth and concentration by
sector and borrower. Exposure to the troubled construction and real
estate sectors was a high 17% of total financing at end-2021.
Exposure to wholesale and retail trade, and the manufacturing
sectors made up 26% and 17%, respectively, of total financing at
end-2021.

Unseasoned Financing Portfolio: The bank's non-performing financing
ratio was a low 0.8% at end-1Q22, while new non-performing
financing inflows have been limited thus far. However, its rapid
financing growth in the volatile Turkish market could result in
asset quality problems as financings season, particularly given
high borrower concentration, high construction exposure and high FC
financing.

Volatile Performance: The bank's return on assets (2021: 0.6%;
sector: 1.3%) is below the peer average, due to its weaker net
financing margin, reflecting competitive pricing, and higher costs
given limited economies of scale. We expect profitability to
increase, given lower interest rates and financing growth, although
performance is likely to be volatile due to concentration risk in
volatile market conditions and sensitivity to asset quality risks.

Weak Core Capitalisation: The bank's common equity Tier 1 ratio was
a weak 11.5% at end-2021 (including a 260bp uplift due to
regulatory forbearance) given its risk profile, only moderate
profitability and very rapid growth. The bank has the lowest
equity/assets ratio among peers at 4.5% at end-2021, reflecting the
use of 50% alpha factor on capital calculation as an Islamic bank.
Its reported Tier 1 and total capital adequacy ratios were more
comfortable at 27.6% and 27.9%, respectively, although they are set
to fall due to budgeted growth.

Mainly Deposit Funded: Customer deposits made up 74% of total
funding at end-2021 and are contractually short-term, as for the
sector. An above sector average 71% was in FC, which heightens
risks to FC liquidity in case of deposit instability, particularly
given high depositor concentration. The bank plans to tap the
wholesale funding markets in the medium term to diversify and
lengthen the tenor of its funding.

Government Support: Emlak Katilim's 'b-' Government Support Rating
(GSR) is two notches below Turkey's LTFC IDR, despite a high
government propensity to provide support based on the bank's state
ownership and the record of capital support. The two notches
reflect the sovereign's weak financial flexibility to provide
support in FC, in case of need, given its weak external finances
and sovereign FX reserves.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

Emlak Katilim's LTFC IDR is sensitive to a change in its VR and to
our assessment of the sovereign's ability and willingness to
provide support.

The VR could be downgraded if there was further marked
deterioration in the operating environment, particularly if it
leads to further erosion of the bank's capital and FC liquidity
buffers. The VR is sensitive to further weakening in Emlak
Katilim's capitalisation, given its weak buffers relative to its
risk profile, if not offset on a timely basis by state support, and
to FC deposit instability if this leads to material erosion of its
FC liquidity.

The bank's GSR could be downgraded if Fitch concludes that stress
to Turkey's external finances further reduces the reliability of
sovereign support for Emlak Katilim in FC, or that the government's
propensity to provide support weakened.

A downgrade of Emlak Katilim's 'b-' GSR would only result in a
downgrade of its LTFC IDR if the VR was simultaneously downgraded.

Emlak Katilim's LTLC IDR could be downgraded if Turkey's LTLC IDR
was downgraded, Fitch believes the sovereign's propensity to
provide support in LC has reduced, or our view of the likelihood of
intervention risk in lira in the banking sector increases.

The Short-Term IDRs are sensitive to changes in the Long-Term
IDRs.

The National Rating is sensitive to adverse changes in the bank's
LTLC IDR and its creditworthiness relative to other Turkish
issuers.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Upside for the bank's ratings is limited in the near term given the
Negative Outlook on the LT IDRs. The VR and LTFC IDR could be
upgraded if the bank's core capitalisation and leverage improve and
it successfully strengthens its Islamic banking franchise in
Turkey, while maintaining adequate FC liquidity buffers. However,
this should be accompanied by the development of a robust risk
framework that is able to contain asset quality and seasoning risks
resulting from the bank's rapid growth strategy.

Downside pressure on the bank's VR could ease in case of a marked
improvement in the operating environment, likely characterised by a
reduction in macroeconomic and financial volatility, and
potentially also a revision of the sovereign Outlook to Stable,
particularly if this reduces risks to the bank's capital and FC
liquidity.

An upgrade of the bank's GSR is unlikely given the Negative Outlook
on Turkey's sovereign rating and its weak ability to provide
support in FC, as reflected in its low net FX reserves.

The National Rating is unlikely to be upgraded given the bank's
LTLC IDR is at the same level with the sovereign rating.

VR ADJUSTMENTS

The operating environment score of 'b' for Turkish banks is lower
than the category implied score of 'bb', due to the following
adjustment reasons: Sovereign rating (negative) and macroeconomic
stability (negative). The latter adjustment reflects heightened
market volatility, high dollarisation and high risk of FX movements
in Turkey.

The earnings and profitability score of 'b-' has been assigned
below the implied score of 'bb' due to the following adjustment
reason: Earnings stability

BEST/WORST CASE RATING SCENARIO

International scale credit ratings of Financial Institutions and
Covered Bond issuers have a best-case rating upgrade scenario
(defined as the 99th percentile of rating transitions, measured in
a positive direction) of three notches over a three-year rating
horizon; and a worst-case rating downgrade scenario (defined as the
99th percentile of rating transitions, measured in a negative
direction) of four notches over three years. The complete span of
best- and worst-case scenario credit ratings for all rating
categories ranges from 'AAA' to 'D'. Best- and worst-case scenario
credit ratings are based on historical performance.

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

PUBLIC RATINGS WITH CREDIT LINKAGE TO OTHER RATINGS

The bank's LTFC IDR is underpinned by potential government support.
The bank's LTLC IDR is driven by potential government support.

ESG CONSIDERATIONS

Emlak's ESG Relevance Scores of '4' for Governance Structure and
Management Strategy (in contrast to a typical Relevance Scores of
'3' for comparable banks) reflects potential government influence
over its board's effectiveness and management strategy in the
challenging Turkish operating environment, which has a negative
impact on the credit profile, and is relevant to the ratings in
conjunction with other factors.

Emlak's ESG Relevance Score of '4' for Governance Structure also
takes into account its status as an Islamic bank. Its operations
and activities need to comply with sharia principles and rules,
which entails additional costs, processes, disclosures,
regulations, reporting and sharia audit. In addition, Islamic banks
have an exposure to social impacts relevance score of '3' (in
contrast to a typical ESG relevance score of '2' for comparable
conventional banks), which reflects that Islamic banks have certain
sharia limitations embedded in their operations and obligations,
although this only has a minimal credit impact on Islamic banks.

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of 3. This means ESG issues are
credit-neutral or have only a minimal credit impact on the
entities, either due to their nature or to the way in which they
are being managed by the entities.

Rating Actions

                       Rating              Prior
                       ------              -----
Turkiye Emlak Katilim Bankasi A.S.

     LT IDR               B-      Affirmed   B-
     ST IDR               B       Affirmed   B
     LC LT IDR            B+      Affirmed   B+
     LC ST IDR            B       Affirmed   B
     Natl LT              AA(tur) Affirmed   AA(tur)
     Viability            b-      New Rating
     Government Support   b-      Affirmed   b-


TURK EXIMBANK: Fitch Affirms 'B/B+' LongTerm IDRs, Outlook Negative
-------------------------------------------------------------------
Fitch Ratings has affirmed Turkiye Ihracat Kredi Bankasi A.S.'s
(Turk Eximbank) Long-Term Foreign- Currency (LTFC) Issuer Default
Rating (IDR) at 'B' and Long-Term Local-Currency (LTLC) IDR at
'B+'. Both ratings have a Negative Outlook.

KEY RATING DRIVERS

Turk Eximbank's LTFC and LTLC IDRs are driven by support from the
Turkish authorities, if needed. The LTFC IDR is driven by its 'b'
Government Support Rating (GSR), reflecting Fitch's view of a high
government propensity to support the bank in case of need, given
its 100%-state ownership and its policy role. The rating also takes
into account significant Central Bank of Turkey (CBRT) funding and
the record of support from the authorities.

The bank's 'B+' LTLC IDR, one notch above its LTFC IDR, is
equalised with the sovereign rating on the basis of support,
reflecting a higher sovereign ability to provide support and a
lower risk of government intervention in lira, in Fitch's view. The
Negative Outlooks on both Long-Term IDRs mirror the Turkish
sovereign's Rating Outlook.

The bank's 'B' Short-Term IDRs are the only possible option in the
'B' rating category.

Turk Eximbank's senior unsecured debt is rated in line with the
bank's FC IDRs, reflecting average recoveries for this type of
debt.

The bank's National Rating at 'AAA(tur)' is driven by government
support, as reflected in its LTLC IDR, based on its policy role,
state ownership and funding guarantees.

Government Support: Turk Eximbank's GSR is one notch below Turkey's
LTFC IDR, despite a high government propensity to provide support,
reflecting its fairly large absolute size and volumes of external
market funding relative to sovereign resources, given Turkey's weak
financial flexibility in FC. The latter is reflected in its weak
net FC reserves position, amid increased risks to macroeconomic and
financial stability and external financing.

Operating Environment Pressures: Turk Eximbank is exposed to
heightened Turkish operating-environment risks, including
inflationary pressures and currency volatility. The bank's role as
Turkey's credit export agency also exposes it to deterioration in
the economies of Turkey's main trading partners.

Export Policy Role: Turk Eximbank is the country's credit export
agency. Exports are a key pillar in the government's strategy to
support growth and reduce its current account deficit. The bank
mainly provides short-term trade finance to corporate exporters,
mostly through the central bank's low-cost rediscount loan
programme, and export credit insurance (the latter risk is to a
large extent transferred to reinsurers). The bank also aims to
increase export loans to SMEs. In 2021 the bank set up the Export
Development Fund (5% shareholder), which provides export guarantees
to SMEs.

Government Guarantees: The loan book partly benefits from
government guarantees for loans issued under the Credit Guarantee
Fund (whereby the exposures are typically guaranteed by the Turkish
Treasury up to a certain non-performing loan cap). The bank's
policy role is reinforced through regulatory privileges, including
exemption from corporate taxes and reserve requirements, and access
to compensation from the Turkish Treasury for losses incurred in
credit, insurance and guarantee transactions due to political
risks.

Sound Asset Quality: Turk Eximbank's asset quality has historically
outperformed peers', due to its effective use of credit mitigation
whereby loans are covered by local bank guarantees. Its impaired
loans and Stage 2 loans ratios were low at 0.2% and 1%,
respectively, at end-2021.

Moderate Profitability: Turk Eximbank's profitability is moderate,
underpinned by low-cost funding sourced from the CBRT, as well as
low impairment charges. The bank's operating profit/risk weighted
assets ratio increased to 2.8% in 2021 from 1.9% in 2020 on the
back of higher net interest income and lower loan impairment
charges.

Moderate Capitalisation: Turk Eximbank's capitalisation is
underpinned by sound asset quality and support from the
authorities. The bank received a TRY3 billion capital increase in
1Q22, to help offset the sensitivity of capital to lira
depreciation. Core capitalisation is moderate (end-2021: 12.95%
common equity Tier 1 ratio), and flattered by regulatory
forbearance.

Rediscount Loans, Central Bank Funding: Turk Eximbank's funding is
almost entirely FC-denominated and sourced (56% at end-2021) from
the CBRT in the form of low-cost rediscount loans - which in turn
underpin Turkey's FC reserves. Remaining borrowings comes from
mostly wholesale funding sources and mainly comprise international
financial institution (IFI) funding, Eurobonds, syndicated loans
and bilateral funding.

As is usual for development banks Fitch does not assign a Viability
Rating to Turk Eximbank. This is because the bank's business model,
which is driven by its dedicated policy and development role, is
strongly dependent on support from the state, in Fitch's view.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

-- The bank's Long-Term IDRs are sensitive to a sovereign
downgrade and to Fitch's view of an increase in government
intervention risk in the banking sector. At the 'B' rating level,
the bank's LTFC IDR is constrained by Fitch's view of government
intervention risk in the banking sector.

-- A sovereign downgrade is likely to trigger a similar rating
action on Turk Eximbank, particularly if it reflects a further
weakening in the sovereign's ability to provide support in FC. A
material weakening in Turk Eximbank's policy role could also result
in a downgrade of its LTFC IDR, although this is not Fitch's base
case.

-- The GSR could be revised down if the reliability of support in
FC for the bank from the Turkish authorities reduces further.

-- The Short-Term IDRs are sensitive to changes in the Long-Term
IDRs.

-- The bank's senior unsecured debt ratings are primarily
sensitive to changes in the IDRs.

-- The National Rating is sensitive to changes in Turk Eximbank's
LTLC IDR and in its creditworthiness relative to other Turkish
issuers'.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

-- An upgrade of the bank's Long-Term IDRs and senior debt ratings
is unlikely in the near term given the Negative Outlook on Turkey's
ratings and Fitch's view of government intervention risk in the
banking sector. A revision of the sovereign's Outlook to Stable
would likely result in a similar action on the bank.

-- Upward revision of the bank's GSR is unlikely given the
Negative Outlook on Turkey's sovereign ratings and its weak ability
to provide support in FC.

ESG CONSIDERATIONS

Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means ESG issues are
credit neutral or have only a minimal credit impact on Turk
Eximbank, either due to their nature or to the way in which they
are being managed by Turk Eximbank.

Rating Actions

                                Rating                Prior
                                ------                -----
Turkiye Ihracat Kredi Bankasi A.S.

                       LT IDR        B         Affirmed  B
                       ST IDR        B         Affirmed  B
                       LC LT IDR     B+        Affirmed  B+
                       LC ST IDR     B         Affirmed  B
                       Natl LT       AAA(tur)  Affirmed  AAA(tur)
                       Gov't Support b         Affirmed  b

  senior unsecured     LT            B         Affirmed RR4  B

  senior unsecured     ST            B         Affirmed B


TURKIYE SINAI KALKINMA: Fitch Affirms 'B/B+' IDRs, Outlook Neg.
---------------------------------------------------------------
Fitch Ratings has affirmed Turkiye Sinai Kalkinma Bankasi A.S.'s
(TSKB) Long-Term Foreign-Currency Issuer Default Rating (LTFC IDR)
at 'B' and Long-Term Local Currency (LTLC) IDR at 'B+'. The
Outlooks are Negative.

Fitch has also downgraded the bank's Viability Rating (VR) to 'b'
from 'b+' and removed it from Rating Watch Negative (RWN). Fitch
placed TSKB's VR on RWN in February 2022 following the Turkish
sovereign downgrade.

The VR downgrade reflects heightened risks to the bank's credit
profile, given the concentration of its operations in the volatile
and challenging Turkish operating environment. Fitch considers the
strength of TSKB's credit profile and capital and foreign currency
(FC) liquidity buffers to be commensurate with the risk of the
Turkish operating environment, given its policy role (providing
investment loans and funding projects in areas of strategic
importance to the authorities among others) and exceptionally high
balance sheet dollarisation.

KEY RATING DRIVERS

TSKB's LTFC IDR and senior debt rating are driven by its 'b' VR, or
standalone credit profile. The LTFC IDR is constrained but not
capped by Fitch's view of government intervention risk in the
banking sector. Operating environment risks, potentially feeding to
the bank's financial profile, are the main driver of the Negative
Outlook on the LTFC IDR.

The bank's 'B+' LTLC IDR is based on government support, reflecting
a stronger sovereign ability to provide support and a lower risk of
government intervention in lira. The Negative Outlook on the LTLC
IDR reflects that on the sovereign.

The bank's 'B' Short-Term (ST) IDRs are the only possible option in
the 'B' rating category.

TSKB's VR considers its policy role and development bank focus,
which underpin its niche franchise and business model, despite its
small size (1% of banking sector assets at end-1Q22). It also
considers the bank's record of reasonable asset quality and
consistent performance. Fitch considers core capitalisation and FC
liquidity to be moderate, in view of TSKB's risk profile and
predominantly FC-denominated balance sheet amid volatile market
conditions. Fitch downgraded the operating environment score for
Turkish banks to 'b'/negative in March 2022, signalling increased
risks to macroeconomic and financial stability.

Furthermore, risks to the bank's credit profile remain skewed to
the downside, given policy uncertainty in the run-up to the 2023
elections and Turkey's large external financing need amid tighter
global financing conditions. Turkish banks are vulnerable to
exchange-rate volatility due to refinancing risks, high sector FC
lending, given that not all exposures will be fully hedged against
lira depreciation, and risks to FC liquidity, due to banks'
exposure to external FC wholesale funding amid exposure to investor
sentiment and high deposit dollarisation.

Below Sector-Average Loan Growth: TSKB has grown below the
sector-average every year since end-2018 and has shrunk its loan
book on an FX-adjusted basis since end-2020. This reflects its
conservative risk appetite as the operating environment has
deteriorated but also capital constraints and subdued demand for
long-term FC investment loans given lira weakness. Management
guides for further loan book contraction on an FX-adjusted basis in
2022.

Asset Quality Risks: Asset quality risks remain significant for
TSKB, given the operating environment pressures, single-name risk
(notably in project finance; around 60% of loans at end-2021),
material FC lending (93% of gross loans at end-1Q22), as not all
borrowers will be fully hedged against the lira depreciation, and
exposure to pressured sectors, such as energy lending (a high 45%
at end-2021, primarily comprising project finance). However, the
loan book contraction in recent years limits seasoning risks, and
loans are closely monitored given concentration risk. Energy
exposures largely also relate to renewable projects, which are
mainly covered by a government-guaranteed feed-in tariff set in FC.
The long-term slowly amortising nature of FC lending means asset
quality problems should feed through fairly slowly.

The bank's impaired loans ratio increased to 3.4% at end-1Q22. Its
Stage 2 loans ratio was a fairly high 13%, of which a high 63% was
restructured. Average reserves coverage of Stage 2 loans was 19%.
The bank's total loan loss allowances covered 156% of Stage 3 loans
at end-1Q22.

Reasonable Profitability: The bank has historically outperformed
the sector in terms of its operating profit/risk-weighted assets
(RWA) ratio, underpinned by its reasonable net interest margin,
reflecting access to concessional Treasury guaranteed funding and
exposure predominantly to FC interest rates, reasonable cost
control and manageable but increased loan impairment charges (2021:
57% of pre-impairment operating profit). Profitability in 2022 will
be boosted by nominal loan growth and gains on CPI linkers in the
high inflation environment, largely offsetting pressure on costs.

Weak Core Capitalisation: TSKB's common equity Tier 1 ratio fell to
8.9% (excluding forbearance) at end-2021, representing only a
moderate buffer over the regulatory minimum. Core capitalisation is
sensitive to lira depreciation (due to the inflation of FC RWAs)
and asset quality weakening, given seasoning risks (including in
the restructured and Stage 2 portfolios), high FC lending and
concentration risk. However, pre-impairment profit provides a solid
buffer to absorb losses through the income statement (2021: equal
to about 6% of average loans; adjusted for hedging gains), while
impaired loans are fully covered by total reserves.

The total capital ratio (14% excluding forbearance at end-1Q22) is
also supported by USD200 million additional Tier 1 from its
majority owner Turkiye Is Bankasi A.S. (issued in 1Q22 to replace
Tier 2 debt).

Wholesale Funded, Adequate FC Liquidity: TSKB is fully wholesale
funded, primarily in FC, by development financial institutions
(DFI) and a significant portion is Treasury guaranteed. Funding
maturities are reasonably diversified with well-spaced out
repayment schedules mitigating refinancing risks. Nevertheless, FC
liquidity is only adequate, given TSKB would rely on FC loan
repayments and undrawn DFI funding to cover short-term maturing FC
wholesale borrowings up to one year in case of market closure. FC
liquid assets typically comprise mainly deliverable FC swaps with
the Central Bank of the Republic of Turkey and placements with
foreign banks.

Government Support Rating (GSR) of 'b-': Fitch's view of support
for TSKB is based on a high propensity of the Turkish authorities
to provide support given the bank's policy role. However, the GSR
is two notches below Turkey's LTFC IDR, due to the sovereign's weak
financial flexibility to provide support in FC, in case of need,
given its weak external finances and weak sovereign FX reserves, as
well as TSKB's private ownership.

The bank's National Rating has been affirmed at 'AA(tur)' on the
basis of government support, as reflected in TSKB's LTLC IDR, and
considers the bank's policy role, but also its private ownership.

RATING SENSITIVITIES

Factors that could, individually or collectively, lead to negative
rating action/downgrade:

The LTFC IDR and senior debt rating are primarily sensitive to the
bank's standalone creditworthiness or VR. In addition, the ratings
are sensitive to an increase in Fitch's view of government
intervention risk, which currently caps most Turkish banks' LTFC
IDRs at 'B', one notch below the sovereign rating, and to a
sovereign downgrade.

TSKB's VR could be downgraded due to further marked deterioration
in the operating environment, or a greater than expected
deterioration in core capitalisation or asset quality, or a
prolonged market closure that puts pressure on TSKB's FC
liquidity.

TSKB's GSR could be downgraded if Fitch concludes further stress in
Turkey's external finances materially reduces the reliability of
support for the bank in FC from the Turkish authorities, or in case
of a lower sovereign propensity to provide support, for example due
to a weakening in the bank's policy role.

TSKB's LTLC IDR would be downgraded in case of a sovereign
downgrade, if Fitch believes the sovereign's propensity to provide
support in local currency has reduced or that the risk of
government intervention in the banking sector in lira has
increased.

The Short-Term IDRs are sensitive to changes in their respective
Long-Term IDRs.

The National Rating is sensitive to changes in TSKB's LTLC IDR and
creditworthiness relative to other Turkish issuers.

Factors that could, individually or collectively, lead to positive
rating action/upgrade:

Upgrades of the bank's LT IDRs and senior debt rating are unlikely
in the near term, given the Negative Outlook on the bank, the
Negative Outlook on Turkey's rating and Fitch's view of government
intervention risk in the banking sector.

A revision of the sovereign Outlook to Stable would reduce downward
pressure on the bank's ratings, particularly if accompanied by a
reduction in Fitch's view of government intervention risk, and
could lead to similar actions on bank ratings.

Downside pressure on the bank's VR could ease in case of marked
improvement in the operating environment, likely characterised by a
reduction in macroeconomic and financial volatility, and
potentially also a revision of the sovereign Outlook to Stable,
particularly if this reduces risks to the bank's capital and FC
liquidity.

An upgrade of the bank's GSR is unlikely given the Negative Outlook
on Turkey's sovereign rating and its weak ability to provide
support in FC, as reflected in its low net FC reserves.

VR ADJUSTMENTS

The operating environment score of 'b' for Turkish banks is lower
than the category implied score of 'bb', due to the following
adjustment reasons: Sovereign rating (negative) and macroeconomic
stability (negative). The latter adjustment reflects heightened
market volatility, high dollarisation and high risk of FX movements
in Turkey.

SUMMARY OF FINANCIAL ADJUSTMENTS

Fitch has made an adjustment in its financial spreadsheets for TSKB
that has impacted Fitch's core and complementary metrics. Fitch has
taken a loan classified as a financial asset measured at fair value
through profit and loss in the bank's financial statements and
reclassified it under gross loans as it believes this is the most
appropriate line in Fitch spreadsheets to reflect this exposure.

REFERENCES FOR SUBSTANTIALLY MATERIAL SOURCE CITED AS KEY DRIVER OF
RATING

The principal sources of information used in the analysis are
described in the Applicable Criteria.

PUBLIC RATINGS WITH CREDIT LINKAGE TO OTHER RATINGS

The bank's LTLC IDR is linked to the Turkish sovereign.

ESG CONSIDERATIONS
Unless otherwise disclosed in this section, the highest level of
ESG credit relevance is a score of '3'. This means ESG issues are
credit-neutral or have only a minimal credit impact on the entity,
either due to their nature or the way in which they are being
managed by the entity.

Turkiye Sinai Kalkinma Bankasi A.S.
                    LT IDR          B       Affirmed  B
                    ST IDR          B       Affirmed  B
                    LC LT IDR       B+      Affirmed  B+
                    LC ST IDR       B       Affirmed  B
                    Natl LT         AA(tur) Affirmed  AA(tur)
                    Viability       b       Downgrade b+
                    Gov't. Support  b-      Affirmed  b-
senior unsecured   LT              B       Affirmed RR4 B
senior unsecured   ST              B       Affirmed  B




===========================
U N I T E D   K I N G D O M
===========================

BURNLEY FOOTBALL: Relegation Triggers Requirement to Repay Loan
---------------------------------------------------------------
Leigh Curtis at Derby Telegraph reports that the Burnley Football
Club could be set for a transfer fire sale after it emerged
relegation from the Premier League has triggered a requirement to
repay a significant proportion of a GBP65 million loan used to fund
their takeover.

The Clarets, or the nickname for the Burnley FC, were bought in a
GBP170 million deal last year but the majority of the cash came
from loans in what was a leveraged buyout, Derby Telegraph
recounts.  But now they have dropped into the Championship, it
means their star players could now be offloaded to keep them
afloat, Derby Telegraph states.

Football finance experts fear the situation could lead them to
become the next Derby County Football Club, who were put into
administration by former owner Mel Morris last September, Derby
Telegraph notes.

Burnley must repay GBP65 million to MSD UK Holdings as a result of
their relegation which, ironically, is the same firm that ex-Rams
chairman Morris borrowed money from to help Derby, secured against
the club's stadium, Derby Telegraph discloses.

According to Derby Telegraph, a report by The Times said: "There
are understandable concerns that measures are taken so the club
does not go down the path of Derby County, who went into
administration last season and were relegated to League One."

Football finance expert Kieran Maguire told the newspaper:
"Leveraged buyouts are high-reward, high-risk methods of takeovers.
Burnley earned over 86 per cent of their revenues during their
time in the Premier League and this, despite parachute payments,
will fall sharply in 2022-23.  If the club has to repay all or
almost all of the GBP65 million debt following relegation, it
leaves the club with little leeway to meet ongoing costs.

"If there is a sale of assets such as Pope and McNeil then,
combined with many players out of contract this summer, there will
be a substantial rebuilding exercise needed on a very modest
budget.  They punched above their weight from a financial
perspective before the takeover but the new ownership structure
will put significant demands on cash flow over the near future."

The Burnley Football Club is an English association football club
based in Burnley, Lancashire, that competes in the EFL
Championship, the second tier of English football, following
relegation from the 2021–22 Premier League.  The club is
nicknamed "the Clarets".



CALEDONIAN MODULAR: Subcontractors Seek to Recoup Materials
-----------------------------------------------------------
Greg Pitcher at Construction News reports that subcontractors on
Caledonian Modular's 279-room aparthotel in Canary Wharf are
desperately trying to recoup materials they claim they supplied to
the failed firm, but were never paid for.

A number of firms told Construction News they were locked in a
process to recover goods sent to the offsite construction
specialist before it entered administration.

Caledonian Modular announced in March 2021 that it had secured a
contract for the 21-storey One Charter Street building, backed by
Canary Wharf Group and designed by architects HTA, Construction
News recounts.

However, Caledonian, which was producing serviced apartments for
the hotel at its Newark factory, collapsed into administration in
March, Construction News relates.

According to Construction News, a report by administrators at
Alvarez & Marsal in April set out the details of GBP11.2 million
owed to unsecured trade creditors and warned there was unlikely to
be any cash to pay these invoices.

But some firms believe their best way to cut their losses from
their dealings with Caledonian is to get hold of products they
believe they remain entitled to, Construction News notes.

One source working on the Canary Wharf project claimed to have
visited Caledonian's Newark factory since administrators were
called in and was left "gobsmacked" by the amount of unused
material, Construction News states.

According to Construction News, the source said they had a
"retention of title" clause in their contract, which meant no goods
were owned by Caledonian until they were paid for in full. However,
attempts to prove ownership of specific items had proved complex,
they added, as some shipments had been paid for, and discussions
were ongoing, Construction News notes.

Another source told Construction News they had been in lengthy
correspondence with the administrators over items related to the
Canary Wharf hotel, which they believed they were entitled to
reclaim.

A third source told Construction News they were aware of various
claims for material recovery being ongoing.

Construction Solutions firm JRL bought the assets, records and
goodwill of Caledonian Modular from administrators for GBP6.25
million in early April, Construction News recounts.


MECHANICAL FACILITIES: Owes GBP9.5MM+ to Unsecured Creditors
------------------------------------------------------------
Grant Prior at Construction Enquirer reports that M&E specialist
Mechanical Facilities Services Limited owed more than GBP9.5
million to unsecured creditors when it went into administration
last month.

An update by administrator Interpath Advisory revealed the scale of
debts to subcontractors and suppliers who are unlikely to receive a
penny for their unpaid invoices, Construction Enquirer relates.

According to Construction Enquirer, it said: "Current estimates
suggest it is unlikely there will be sufficient funds in the
administration to enable a distribution to be made to the unsecured
creditors."

Interpath said Mech FS was brought down by an outstanding
intercompany debt and a dispute on one of its largest contracts,
Construction Enquirer notes.


ORTHIOS ANGLESEY: Owes GBP210 Million to Creditors, Report Shows
----------------------------------------------------------------
Owen Hughes at NorthwalesLive reports that the scale of debts the
Orthios group left after the recycling venture at the former
Anglesey Aluminium site collapsed have been revealed.

The group officially took over the site in Holyhead in 2016 after
smelting came to an end in 2009, NorthwalesLive recounts.

After an attempt to develop a biomass facility failed, they built a
materials recycling facility (MRF) and were in the process of
developing a Plastics-to-Oil (P-2-O) unit, NorthwalesLive
discloses.  The company was praised by Prime Minister Boris Johnson
on a visit to the island in January but in March the business
collapsed, with around 140 staff losing their jobs, NorthwalesLive
recounts.

Begbies Traynor were appointed as administrator to operator Orthios
(Anglesey) Technologies Ltd (OATL) while Voscap Ltd have been
appointed for Orthios Eco Parks (Anglesey), (OEPAL) which owned the
230-acre site, NorthwalesLive relates.  Now they have both released
notice of administrator's proposals for the failed ventures,
NorthwalesLive states.

It shows creditors are owed in excess of GBP200 million -- with a
vast majority bond holders who invested in the ventures but money
is also due to local companies and workers, NorthwalesLive notes.
In the case of those local businesses they are not expected to get
any of the money back, according to NorthwalesLive.

The report outlines the huge sums owed to creditors, NorthwalesLive
discloses.  In terms of secured creditors OEPAL has debts of GBP115
million owed to bond holders, NorthwalesLive states.  Around GBP1.1
million is owed to Close Brothers Asset Finance, who handled the UK
Government backed CBILs loan, NorthwalesLive notes.

There are then dozens of unsecured creditors who stand to lose over
GBP1.2 million, NorthwalesLive relates.  In total, the amount owed
to creditors -- including undertakings within the group -- is over
GBP131 million, NorthwalesLive discloses.  In terms of realisations
from land and machinery this has an estimated book value of around
GBP5.5 million meaning a gigantic financial back hole, according to
NorthwalesLive.

The total estimated deficiency once debts and realisations are
taken into account is GBP78.6 million, NorthwalesLive notes.  This
means across the two businesses over GBP210 million is owed to
creditors, NorthwalesLive states.


THG PLC: S&P Affirms 'B' Long-Term ICR & Alters Outlook to Negative
-------------------------------------------------------------------
S&P Global Ratings revised its outlook on U.K.-based online
retailer THG PLC to negative from stable and affirmed its 'B'
long-term issuer credit rating on the group.

S&P said, "The negative outlook reflects THG's recent
underperformance compared with our previous expectations in terms
of profitability and leverage. It also reflects our view that the
inflationary environment and weak consumer confidence could still
hamper THG's earnings, delaying the benefits to its operating
leverage from growth in its e-commerce platform, and partly
affecting its liquidity."

The outlook revision to negative reflects the likely pressure on
THG's profitability over the next 12 months.

THG had strong revenue growth of 35% in 2021, thanks to organic
growth and numerous acquisitions throughout the year. However, the
increase in revenue did not translate into an improvement in
earnings or cash flow due to several factors, including:

-- Input cost inflation, especially for whey protein, which is an
important raw material in THG's nutrition segment;

-- Supply chain disruptions, which caused the group to hold higher
amounts of inventory;

-- Transportation costs, particularly in Asia, where the group
does not have any manufacturing facilities;

-- Foreign-exchange headwinds, particularly for Asian currencies;
and

-- Restructuring costs to achieve the synergies arising from a
review of the corporate structure.

THG's profitability could suffer further in 2022, with management
opting to limit the pass-through of increases in raw material
prices and other input costs. As such, S&P's forecasts that the
group's EBITDA will remain flat and in the range of GBP75
million-GBP110 million in 2022, compared with GBP90 million in
2021. This is materially weaker than our previous EBITDA
expectation of GBP180 million-GBP200 million in 2022.

S&P said, "THG's credit metrics will remain weak for the current
rating. Weakening profitability resulted in adjusted debt to EBITDA
spiking at 9.5x in 2021, and we forecast that the ratio will
deteriorate further in 2022. THG's free operating cash flow after
lease payments was negative by GBP200 million in 2021. These ratios
are not commensurate with the current rating. While we calculate
the group's leverage on a gross debt basis, we acknowledge that its
GBP573 million of available cash provides enough of a cushion to
absorb cost headwinds and continue its capital expenditure (capex).
Moreover, we expect some of the input and transport cost inflation
to dissipate by 2023, and the group to pass most of it on to its
customers.

"The boost to THG's operating leverage from growth of the Ingenuity
e-commerce platform could help with quick deleveraging. THG's capex
was elevated at about 10% of revenue in 2021, compared with its
target rate of 5.5%-6.5% in the medium term. The group incurred the
excess capex to build necessary fulfilment capacity across various
countries. In 2021, the group completed the commission and internal
fit-out of 2.0 million square foot fulfilment space out of a
multi-facility expansion plan of 3.6 million square foot in total.
THG will have the capability to process orders worth GBP14 billion
in gross merchandise value. We estimate that the company is
processing orders on its platform worth less than GBP5 billion,
signifying the scale of the operating leverage available for the
group as the Ingenuity platform grows."

Acquisitions have improved THG's geographical diversification and
helped it to execute its vertical integration strategy. THG has
used the proceeds of equity raises over the past two years,
including GBP768 million in 2021, to fund some key acquisitions,
including:

-- GBP261 million for Dermstore, the largest online retailer of
skincare and beauty brands in North America;

-- GBP180 million for Bentley Laboratories, a developer and
manufacturer of prestige skincare and hair products; and

-- GBP291 million for Cult Beauty, a U.K.-based online retailer of
independent beauty brands.

These acquisitions have helped THG build scale in the beauty
segment, increased the revenue contribution from the U.S., and
brought in-house manufacturing capabilities. Recent acquisitions
(such as of Brighter Foods) and investments have expanded THG
Nutrition's vertical integration and brought in house components of
product development and manufacturing. This is part of THG's
strategy to expand into larger addressable markets such as healthy
snacking, vegan foods, vitamins, and athleisure. The group now has
the capabilities to produce powders, bars, vitamins, and drinks,
products that account for more than 80% of THG Nutrition's
revenue.

S&P said, "For us to revise our view of THG's business strength, we
would need to see an improvement in its operating margins and cash
flow.THG's revenue growth has been stronger than we anticipated.
The group doubled its revenue base to GBP2.2 billion in 2021 from
GBP1.1 billion in 2019. While acquisitions contributed part of this
revenue growth, THG's influencer-centered marketing strategy
increased its active member base and supported its organic growth.
However, the group's S&P Global Ratings-adjusted EBITDA remained
flat at around GBP90 million in 2021, translating into an EBITDA
margin of 4.1%. An upward revision of our assessment of the group's
business strength would require a track record of profit margins
approaching 10%. THG's management states that the group should
attain an EBITDA margin of 9%-10% in the medium term.

"The negative outlook reflects THG's recent underperformance
compared with our previous expectations in terms of profitability
and leverage. The outlook also reflects our view that the
inflationary environment and weak consumer confidence could still
hamper the group's earnings profile, including secondary demand for
its Ingenuity e-commerce platform. These factors could also delay
the benefits to THG's operating leverage from growth in the
Ingenuity platform and partly affect its liquidity."

S&P could lower the rating if THG did not return to strong and
profitable sales growth in line with its material investments,
allowing it to generate neutral to positive FOCF, reduce its high
financial leverage, and maintain an appropriate liquidity cushion.
This could occur if:

-- The revenue and margin growth that S&P anticipates from the
Ingenuity e-commerce platform did not materialize as it expected
due to lower customer volumes;

-- Consumer demand weakened more than S&P expected, as higher
prices continued to squeeze consumers' purchasing power for
products in discretionary categories such as premium beauty and
nutrition;

-- S&P considered the group's capital structure unsustainable due
to sustained high gross leverage, and saw no path for adjusted debt
to EBITDA to return below 6.5x in the medium term; or

-- Liquidity fell below a level that S&P considers adequate for
the group to meet its funding requirements in the next 12-18
months.

Due to the weakening operating margins we anticipate and the
ongoing negative cash flow, S&P considers a revision of the outlook
to stable in the next 12 months as unlikely. S&P could consider
revising the outlook to stable if the group demonstrated:

-- A track record of organic revenue growth above 15%, despite the
weakening economic conditions, while improving its adjusted margins
to 7%;

-- A track record of reducing and maintaining adjusted leverage of
5.0x-6.0x;

-- Evidence of reducing cash burn or of raising additional equity
to fund the capex associated with onboarding new Ingenuity clients;
and

-- Maintenance of financial policies consistent with stronger
credit metrics and a track record of governance standards in line
with those of other U.K. publicly listed companies.

ESG credit indicators: E-2, S-2, G-3

S&P said, "Governance factors are a moderately negative
consideration in our credit rating analysis of THG. Mr.
Moulding--THG's founder and the largest shareholder with a 15%
stake--exercises material direct and indirect influence over the
group. Mr. Moulding is also the landlord of most of the operating
assets that THG leased in 2021. We recognize the group's efforts in
strengthening its governance framework with the recent appointment
of an independent chairman, Lord Allen of Kensington CBE. THG's
eight-member board comprises six nonexecutive directors, three of
which are fully independent."

THG's auditor notes that the accounting of related-party
transactions is compliant with the relevant accounting standards
and appropriate. However, the auditor noted some deficiencies in
the internal controls due to conflicts of interest arising from
common management between THG and the property entity that leases
operating assets to the group. S&P understands that management has
been working on a remediation plan and that it will be fully
implemented by year-end 2022.


WISE PLC 2006-1: Moody's Hikes Rating on Class C Notes to Caa2
--------------------------------------------------------------
Moody's Investors Service has upgraded the ratings on the following
notes issued by WISE 2006-1 PLC:

Issuer: WISE 2006-1 PLC

GBP30,000,000 Class A Credit-Linked Notes due 2058, Upgraded to
Baa2 (sf); previously on Jun 22, 2021 Upgraded to Baa3 (sf)

GBP22,500,000 Class B Credit-Linked Notes due 2058, Upgraded to
Ba3 (sf); previously on Jun 22, 2021 Upgraded to B2 (sf)

GBP11,250,000 Class C Credit-Linked Notes due 2058, Upgraded to
Caa2 (sf); previously on Jun 22, 2021 Affirmed Caa3 (sf)

Moody's has also affirmed the rating on the following Super Senior
Credit Default Swap:

Buyer: Dexia Credit Local - Super Senior Credit Default Swap WISE
2006-1 PLC

GBP1,436,250,000 (Current outstanding balance GBP944,174,902)
Super Senior Credit Default Swap, Affirmed Aa2 (sf); previously on
Jun 22, 2021 Affirmed Aa2 (sf)

WISE 2006-1 PLC, a partially-funded synthetic securitisation, with
an underlying portfolio consisting of GBP denominated PFI and
regulated utility bonds located in the UK, each guaranteed by one
of three (originally seven) monolines.

RATINGS RATIONALE

Moody's said that the rating actions are a result of an improvement
in the credit quality of the underlying reference portfolio and of
the monoline that is guaranteeing a portion of the portfolio over
the last year.

The credit quality has improved as reflected in the improvement in
the average credit rating of the portfolio (measured by the
weighted average rating factor, or WARF) and of the monoline that
is guaranteeing a portion of the portfolio. Moody's WARF of the
underlying reference portfolio considering the protection provided
by the guarantors is 1,546, compared with 1,733 a year ago.

Moody's also note that since the last rating action, the size of
the reference portfolio has gone down to GBP1,007.9m from
GBP1,118.8m.

Methodology Underlying the Rating Action:

The principal methodology used in these ratings was "Project
Finance and Infrastructure Asset CLOs Methodology" published in
November 2021.

Counterparty Exposure:

The rating action took into consideration the notes' exposure to
relevant counterparties, such as account bank and swap provider(s),
using the methodology "Moody's Approach to Assessing Counterparty
Risks in Structured Finance" published in May 2021. Moody's
concluded the ratings of the notes are not constrained by these
risks.

Factors that would lead to an upgrade or downgrade of the ratings:

The ratings of the notes rely on the ratings of the wrappers but
also on the credit quality of the underlying reference portfolio.
In particular, an upgrade or downgrade to the Insurance Financial
Strength rating of one or more of the wrappers could result in an
upgrade or downgrade to the ratings of the notes.

Other sources of uncertainty that may impact notes performance
include limitations of historical data for some of the project
finance asset types, long maturities of the underlying loans and
counterparty influence on loan performance. Additionally, this
transaction is subject to a high level of macroeconomic
uncertainty, which could negatively affect the ratings on the note,
in light of uncertainty about credit conditions in the general
economy.

Additional uncertainty about performance is due to the following:

Weighted average life: The notes' ratings are sensitive to the
weighted average life assumption of the underlying portfolio.
Moody's has assumed the average life of the bonds as reported,
however legal final maturity could be up to 34 years.

In addition to the quantitative factors that Moody's explicitly
modelled, qualitative factors are part of the rating committee's
considerations. These qualitative factors include the structural
protections in the transaction, its recent performance given the
market environment, the legal environment, specific documentation
features. All information available to rating committees, including
macroeconomic forecasts, input from other Moody's analytical
groups, market factors, and judgments regarding the nature and
severity of credit stress on the transactions, can influence the
final rating decision.


                           *********


S U B S C R I P T I O N   I N F O R M A T I O N

Troubled Company Reporter-Europe is a daily newsletter co-
published by Bankruptcy Creditors' Service, Inc., Fairless Hills,
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Marites O. Claro, Rousel Elaine T. Fernandez, Joy A. Agravante,
Julie Anne L. Toledo, Ivy B. Magdadaro, and Peter A. Chapman,
Editors.

Copyright 2022.  All rights reserved.  ISSN 1529-2754.

This material is copyrighted and any commercial use, resale or
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Information contained herein is obtained from sources believed to
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