1

The Financial Conduct Authority (the FCA) gave an individual a warning notice on 30
January 2020 proposing to take action in respect of the conduct summarised in this
statement.

IMPORTANT: a warning notice is not the final decision of the FCA. The individual
has the right to make representations to the Regulatory Decisions Committee
(RDC) which, in the light of those representations, will decide on the appropriate
action and whether to issue a decision notice. The RDC is a Committee of the
FCA Board which decides whether the FCA should give certain statutory notices
described as within its scope by the FCA’s Handbook.

If a decision notice is issued, the individual has the right to refer the matter to
the Upper Tribunal which would reach an independent decision on the
appropriate action for the FCA to take, if any.

If either the RDC or the Upper Tribunal decides that no further action should be
taken, the FCA will publish a notice of discontinuance provided it has the
individual’s consent.

The following is a summary of the reasons why the FCA gave the individual a warning
notice:

•
The FCA considers that:

o
Between 20 January 2017 and 15 May 2017 the individual, who was a
partner and portfolio manager at an investment fund, deliberately engaged
in market abuse contrary to Article 15 of the Market Abuse Regulation ((EU)
No 596/2014).

o
Specifically, the individual, in the course of his role at the investment fund,
placed large orders for Contracts for Difference (referenced to five UK listed
securities) on an inter-dealer trading platform that he did not intend to
execute (“Misleading Orders”), on the opposite side of the order book to
existing smaller orders which he intended to execute (“Genuine Orders”).

o
Through the Misleading Orders the individual falsely represented to the
market an intention to buy or sell when his true intention was the opposite.
The individual’s intention in placing the Misleading Orders was to facilitate
the execution of the Genuine Orders at a more advantageous price, or on a
more timely basis, than he would otherwise have achieved but for the
Misleading Orders.

•
The FCA considers that the individual’s behaviour constituted market abuse within
the meaning of Article 12 of the Regulation and in contravention of Article 15 of the
Regulation as, in placing the Misleading Orders he gave, or is likely to have given,
false and misleading signals as to the supply or demand for the shares to which the
Misleading Orders related.