FCA fines GAM International Management, former Director Timothy Haywood
The UK Financial Conduct Authority (FCA) today announced the imposition of a fine of £9,103,523 on GAM International Management Limited (GIML) for failing to conduct its business with due care and attention and failing to adequately manage conflicts of interest. The FCA has also fined Timothy Haywood, a former Investment Director and Business Unit Head at GIML, £230,037.
The penalties are in line with those announced in December 2021.
GIML failed to manage conflicts of interest arising from three transactions, two of which were linked to Greensill Capital (UK) Ltd where Mr Haywood was the investment manager making investment decisions. Potential incentives were offered which would have provided benefits to GIML or its parent company. Although these were not taken up, they were not dealt with properly by GIML.
Conflict of interest policies were not followed and as a result any potential conflicts were not considered by those who should have been responsible for doing so.
Mr Haywood received gifts and entertainment, including travelling on a Greensill private aircraft, but failed to record them in a timely manner with GIML. Although the FCA did not find evidence that Mr Haywood made investment decisions because of these gifts and entertainment, the fact that conflicts were not properly managed heightened the risk that he may have been incentivised to invest for personal interest.
Both GIML and Mr Haywood agreed to resolve the cases against them at an early stage of the FCA’s investigation and therefore qualified for a 30% discount. Mr Haywood’s fine includes the £22,437 of the value of the gifts and entertainment he did not record in a timely manner.