FCA has fined GAM International Management Limited £9m, and its former Investment Director and Business Unit Head Timothy Haywood £230,000 following failure to conduct business with due care and attention, and failure to manage conflicts of interest adequately.
FCA found the failures arose in respect of 3 transactions, 2 of which were linked to Greensill Capital. Mr Haywood was the investment manager who made investment decisions. Potential incentives (which were in fact not taken up) were offered which would have provided benefits to GAM or its parent. The offer was not properly addressed, and conflicts policies were not followed with the result that potential conflicts were not considered by the appropriate people.
Mr Haywood received gifts and entertainment valued at over £22,000 that he did not record in a timely manner; and although FCA found no evidence that this affected his decision making, the lack of proper conflict management heightened the risk that he may have been incentivised to invest for personal interest.
In both cases, the fines benefited from a 30% discount for early settlement.