The regulator said that GIML's £9.1m fine was for failing to conduct its business with due care and attention and failing to adequately manage conflicts of interest. 

Timothy Haywood, a former investment director and business unit head at GIML, was separately fined £230,037 for failing to record in a "timely manner" GIML gifts and entertainment he received, including travel on a Greensill private aircraft. He will have to pay back the £22,437 value of the gifts and entertainment he did not record in a timely manner.

The watchdog said GIML failed to manage conflicts of interest related to three transactions. Two of the transactions were linked to Greensill Capital (UK) Ltd where Mr Haywood was the GIML investment manager making investment decisions.

Greensill Capital was a financial services business located in the UK and Australia and founded by entrepreneur Lex Greensill. It made the headlines after it collapsed last year. Former Prime Minister David Cameron was an adviser to the company.

The FCA said today that 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.

The FCA said that although it did not find evidence that Mr Haywood made investment decisions because of the gifts and entertainment he received, 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 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.

Mark Steward, executive director of enforcement and market oversight at the FCA, said: “A robust framework, properly implemented and followed by all staff, is required to manage any conflicts of interest. GIML failed to do this. In an asset manager, this is vital in ensuring decisions are taken for the benefit of the investors. Mr Haywood’s disclosure failings are equally serious ones.

“The FCA expects asset managers and their staff to be scrupulous in identifying and managing conflicts and their risks. This case should send a clear warning to the market.”

• The final notice for GIML can be seen here and Timothy Haywood here.