The UK FCA fines companies sharing strategic information on a bilateral basis during an initial public offering (Hargreave / Newton / RAMAM)

On 21 February, the UK Financial Conduct Authority (the “FCA”) found that Hargreave Hale Ltd (“Hargreave Hale”), Newton Investment Management Limited (“Newton”), and River and Mercantile Asset Management LLP (“RAMAM”) had breached competition law by sharing strategic information on a bilateral basis during an initial public offering and a placing, shortly before share prices were set. [1] The FCA imposed fines of £306,300 on Hargreave Hale and £108,600 on RAMAM. Newton was granted immunity and therefore avoided a financial penalty, although its former fund manager, Paul Stephany, was separately fined £32,200 for his role in the breaches. [2] Hargreave Hale is reportedly considering appealing the FCA’s decision. This is the FCA’s first competition enforcement decision since it gained