FCA fines GAM International Management and former Investment Director Timothy Haywood

Apr 4, 2022 12:00:00 AM

What has happened?

In March 2022, the FCA fined asset manager GAM International Management Limited £9,103,523 for failing to conduct its business with due care and attention and failing to adequately manage its conflicts of interest between 2014 and 2018. The FCA also fined Timothy Haywood, a former Investment Director and Business Unit Head at GIML, £230,037. The main basis of the FCA’s enforcement action, in this case, was the breaching, by GAM and Timothy Haywood, of FCA Principles 2. 7 and 8.

What was the basis of the FCA’s enforcement action?

The firm failed to manage conflicts of interest arising from three transactions, two of which (investments in Laufer 1 and the SCF Fund) were linked to Greensill Capital (UK) Ltd and involved Timothy Haywood as the investment decision-maker. Potential incentives were offered which would have provided benefits to GIML or its parent company and, although these were not taken up, they were not dealt with properly by GIML.

The firm’s internal governance around conflicts of interest policies and procedures was weak and as a result, any potential conflicts were not considered by staff who should have been responsible for doing so.

Mr Haywood received gifts and entertainment, including travelling to Sardinia on a Greensill employee’s private aircraft, but failed to record them in a timely manner with GIML. Although the FCA found no 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 might have been incentivised to invest for personal interest.

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