This FAQ was last updated on 21 November 2018 and will continue to be updated from time to time. All historic announcements and letters remain available on GAM’s website.
The key priorities in liquidating the ARBF funds have been to protect our clients’ interests through the timely distribution of the liquidation proceeds and maximisation of value for investors. As of 28 November 2018, between 89% to 92% of the Luxembourg and Irish-domiciled UCITS funds, and 66% to 72% of the assets in the Cayman and Australian feeder funds will have been returned. Remaining assets in funds will be liquidated over the coming months, dependent on market conditions.
GAM’s priority is to maximise value for the investors throughout the liquidation process, while ensuring fair treatment to all. We are focused on ensuring we balance value maximisation with speed of liquidation, taking into account market conditions. As such, additional payments in respect of redemption proceeds will be made in tranches as proceeds from the sale of the underlying fund investments become available. This is subject to us hitting the 5% threshold that we believe makes a distribution efficient and in the economic interest of clients. We expect there to be another distribution over the coming months, depending on market conditions.
Our focus will be on optimising the prices we can obtain for all assets to maximise value for clients. As such, we cannot provide additional details on the ARBF funds’ remaining assets during this stage of the liquidation process, as this could put GAM’s liquidation efforts and fund investors at a disadvantage when these assets are liquidated.
Risk management at GAM
GAM is continually reviewing and enhancing its risk management framework in line with regulatory standards and industry good practice. The specific steps we have taken in the last 18 months to restructure and strengthen our risk management approach across our three lines of defence are listed below:
First line: In 2017, GAM created a new role of Head of Investments and hired an individual who has approximately 20 years of relevant investment and control experience, to strengthen the first line investment oversight across key investment and trading areas. Further, a new and dedicated front office controls function has been created with responsibility for managing risk within the front office control environment. Additionally, GAM has made enhancements to the day to day oversight of risk by shifting current regionally-based governance arrangements to a group-led model via the implementation of a series of group oversight committees covering risk, compliance, investment, distribution and change activities.
Second line: GAM took the decision to separate the compliance and legal function in 2018 to reinforce the critical importance of these functions in their own right. Additionally, specialist compliance expertise has been recently recruited in the areas of financial crime and conflicts of interest. The Group Chief Risk Officer and Group Head of Compliance now report to the group Chief Executive Officer and participate in the Group Management Board, underscoring the importance of these functions to GAM. At the end of 2017, the quantitative analytics team, formerly within the operations function, joined the risk function to provide greater independence. In 2018, the risk function took over group-wide ownership for the investment restrictions compliance monitoring activities. Both the compliance and risk functions will continue to assess their effectiveness and related capabilities as part of our on-going commitment to operate robust risk management across the group. In addition, we are in the process of recruiting for a new role of Head of Investment Risk which we aim to have in place by March 2019.
Third line: A new Head of Internal Audit with extensive asset management experience was hired at the end of 2017, and the team has been strengthened by the hiring of additional roles. The function is in the process of recruiting a senior auditor with specialist experience in the trading and investment management area. These, amongst other planned enhancements to methodology and reporting, will further support internal audit in providing assurance on the operation of first and second line activities to manage risk to the Board of Directors (non-executive).
As a result of the findings from our investigation, we have made a number of improvements to our policies and procedures, for example, we have:
We have continued to strengthen our three lines of defence model with a number of enhancements over the past 12 to 18 months in the following areas:
There have also been a number of personnel additions which have further strengthened capabilities in areas including financial crime prevention, compliance monitoring and regulatory developments and front office controls.
We aim to differentiate ourselves as an independent global asset management firm, investing our clients’ assets across active and specialised discretionary and systematic investment solutions. We continue to build upon the strength of GAM as a diversified asset manager and are confident that GAM’s investment management teams will continue to deliver investment returns expected by our clients.
We are taking immediate and near-term steps to adapt our business to support GAM’s profitability. As such we are focussing on the following:
We plan to update on our strategic priorities by our full-year results on 21 February 2019.
Update on GAM’s internal disciplinary process of Tim Haywood
As previously stated, we conducted a thorough investigation involving external counsel. This part of our internal investigation is largely completed and the internal disciplinary processes are on-going.
Given the on-going disciplinary process, we are unable to give any further detail.
While Tim Haywood has been suspended, he remains an employee of GAM, he is currently engaged in the firm’s internal disciplinary processes. It is inappropriate to comment any further pending the completion of those processes.
We reported in our Interim Management Statement for the three-month period to 30 September 2018 that our AuM was CHF 146.1 billion, including investment management and private labelling. The majority of the outflows were directly related to the liquidation of the ARBF funds, and the market environment also contributed to non-ARBF outflows of CHF 5.3 billion in investment management and CHF 0.4 billion in private labelling.
The macro backdrop remains difficult and we will continue to engage with our clients.
The GMB and the Board have and will continue to review broader cost saving measures on an ongoing basis in order to create value for clients, shareholders and employees by improving efficiency and enabling us to continue investing in areas where we have real strength and differentiation.
Our engagement with clients showed a marked improvement as we moved into Q4.
1Our investigation is confidential and subject to legal privilege. GAM does not waive confidentiality or privilege in the investigation.
2These figures as per 30 September 2018 exclude CHF 1.9 billion ARBF-related assets in funds and CHF 0.4 billion ARBF-related assets in mandates to be liquidated, depending on market conditions.