Man Global Private Markets (Uk) Limited

Allegations: ON APRIL 7, 2021, MAN GROUP PLC ("MAN"), AN ADVISORY AFFILIATE OF MAN GLOBAL PRIVATE MARKETS (USA) INC,BASED IN LONDON, U.K., AGREED TO PAY A FINE OF EURO 240,000 TO THE COMISION NACIONAL DEL MERCADO DEVALORES (THE "CNMV"), PURSUANT TO A SETTLED RESOLUTION, IN CONNECTION WITH THE CNMV'S FINDINGS THAT MANHAD NOT COMPLIED WITH EUROPEAN UNION ("EU") REGULATIONS REQUIRING THE DISCLOSURE OF AN INVESTOR'SSHORT POSITIONS IN THE SECURITIES OF ANY ISSUER BASED IN AN EU MEMBER COUNTRY, SUCH AS SPAIN.SPECIFICALLY, THE EUROPEAN SECURITIES AND MARKETS AUTHORITY ("ESMA") HAS ISSUED REGULATIONS ON SHORTSELLING AND CREDIT DEFAULT SWAPS ("SSR") THAT REQUIRE INVESTORS TO FILE REPORTS DISCLOSING ANY SHORTPOSITIONS ABOVE A THRESHOLD OF 0.2% OF AN ISSUER'S OUTSTANDING SHARES, WITH ADDITIONAL DISCLOSURETHRESHOLDS AT INCREASING INTERVALS OF 0.1%. THUS, AN INVESTOR MUST FILE DISCLOSURES CALCULATING ITS NETSHORT POSITION WHENEVER IT CROSSES THRESHOLDS (UP OR DOWN) OF 0.2%, 0.3%, 0.4%, 0.5% ETC. IN THE CASE OFMAN, THE CNMV DETERMINED THAT, BETWEEN DECEMBER 2017 AND NOVEMBER 2018, THREE OF MAN'S AFFILIATEDMANAGERS HAD ON FIVE OCCASIONS FAILED TO CORRECTLY DISCLOSED THEIR NET SHORT POSITION IN FOUR SPANISHISSUERS AMOUNTING TO BETWEEN 0.2% AND 0.7% OF THE ISSUERS' OUTSTANDING SHARES. THE SSR REGULATIONSIMPOSE RULES FOR CALCULATING NET SHORT POSITIONS AT THE FUND LEVEL AMONG AFFILIATED ENTITIES, WHICH MANATTEMPTED TO APPLY IN GOOD FAITH. SEE ESMA 70-145-408, QUESTION 8.5, AVAILABLE ATHTTPS://WWW.ESMA.EUROPA.EU/SITES/DEFAULT/FILES/LIBRARY/ESMA70-145-408_QA_ON_SSR.PDF. IN FOUR CASES, THEIRREGULARITIES AROSE FROM THE INCORRECT IDENTIFICATION OF THE POSITION HOLDING ENTITY WITHIN MAN; (FOREXAMPLE, A POSITION HELD BY ONE MAN MANAGER WAS INCORRECTLY NOTIFIED AS A POSITION HELD BY ANOTHER MANMANAGER). THIS MISREPORTING RESULTED IN DELAYED CORRECTING NOTIFICATIONS TO THE CNMV. IN ONE INSTANCE, APOSITION WAS INADVERTENTLY NOT REPORTED. THE ORDER RELATED TO MAN IS SET FORTH IN DISPATCH RECORD NO. 2021025805 OF THE CNMV. THE CNMV DID NOT DETERMINE THAT MAN ENGAGED IN ANY MISLEADING OR DECEPTIVECONDUCT, NOR THAT IT COMMITTED ANY VIOLATION IN CONNECTION WITH PROVIDING INVESTMENT ADVISORY SERVICESTO ANY CLIENTS. Status: Final Sanction Detail: ON APRIL 7, 2021, MAN, AN ADVISORY AFFILIATE OF MAN GLOBAL PRIVATE MARKETS (USA) INC., AGREED TO PAY AFINE OF EURO 240,000 TO THE COMISION NACIONAL DEL MERCADO DE VALORES (THE "CNMV") IN CONNECTION WITHTHE CNMV'S FINDINGS THAT MAN HAD NOT COMPLIED WITH EUROPEAN UNION ("EU") REGULATIONS REQUIRINGTHE DISCLOSURE OF AN INVESTOR'S SHORT POSITIONS IN THE SECURITIES OF ANY ISSUER BASED IN AN EUMEMBER COUNTRY, SUCH AS SPAIN. Summary: ON APRIL 7, 2021, MAN AGREED TO ACCEPT THE FINDINGS WITHOUT CONTESTING AND PAY A FINE OF EURO 240,000.