Robin Crispin Odey v The Financial Conduct Authority

Facts

Robin Crispin Odey founded, ultimately controlled and worked as a fund manager at Odey Asset Management LLP, a full-scope alternative investment fund manager regulated by the Financial Conduct Authority. In February 2021, following an investigation by Simmons & Simmons into 46 alleged incidents of inappropriate conduct towards female staff, the firm's Executive Committee issued him a final written warning, which he signed and never appealed. Allegations that he had breached it by exchanging personal messages with, and inviting to lunch, a temporary receptionist led the committee to convene a second disciplinary hearing. On 24 December 2021 Mr Odey used his voting control to remove the three-member committee and appointed himself its sole member, postponing the hearing indefinitely. A second committee appointed in January 2022 was removed on 31 March 2022 after it proposed safeguarding measures following a further complaint from a new joiner. A third committee eventually held the hearing in November 2022 and found two technical breaches without dismissing him. On 3 March 2025 the Authority issued a Decision Notice finding that he had breached Individual Conduct Rule 1 of COCON, the requirement to act with integrity, and imposed a prohibition order under section 56 of the Financial Services and Markets Act 2000 and a penalty of £1,835,200 under section 66 of the Financial Services and Markets Act 2000. Mr Odey referred both decisions to the Upper Tribunal, which heard eleven witnesses over thirteen days.