Aviva Investors Global Services Limited

On 24 February 2015, the Authority imposed a financial penalty of £17,607,000 on Aviva Investors Global Services Limited (Aviva Investors) for breaches of Principles 3 (Management and Control) and 8 (Conflicts of Interest) of the Authority's Principles for Businesses (the Principles) in the FCA's Handbook, as well as for breaches of the COBs rules. Aviva Investors agreed to settle at an early stage of the Authority's investigation. It therefore qualified for a 30% (Stage 1) discount under the Authority's executive settlement procedures. Were it not for this discount, the Authority would have imposed a financial penalty of £25,152,900 on Aviva Investors. Aviva Investors failed to properly implement systems and controls adequate to control the conflicts of interest created by the side-by-side management of hedge funds with high performance fees and other funds with lower performance fees. The combination of a poor control environment and the incentive to favour their interests over those of customers led to the risk that traders would cherry pick. In May of 2013, Aviva Investors found evidence that two traders had delayed booking trades, improperly allocated trades and cherry picked. £135,000,000 in compensation was paid to eight funds that Aviva Investors identified may have been impacted by the poor control environment. A copy of the Final Notice is displayed on the Authority's web site and can be accessed using the following link: http://www.fca.org.uk/your-fca/documents/final-notices/2015/aviva-investors