Gam London Limited

Allegations: THIS FOLLOWED AN INCIDENT WHEREBY GIML EXECUTED TWO EXCHANGE FOR RELATED POSITION ("EFRP") TRANSACTIONS IN THE 10-YEAR U.S. TREASURY NOTE FUTURES MARKET THAT WERE CONTINGENT UPON EACH OTHER FOR THE PURPOSE OF OFFSETTING THE RELATED POSITION WITHOUT THE INCURRENCE OF MARKET RISK. A PANEL OF THE CBOT FOUND THAT THESE TRANSACTIONS WERE TRANSITORY IN NATURE AND, THEREFORE, WERE NOT BONA FIDE. ADDITIONALLY, THE PANEL FOUND THAT THE QUANTITY OF THE RELATED POSITION WAS NOT APPROXIMATELY EQUIVALENT TO THE QUANTITY OF THE EXCHANGE COMPONENT OF THE EFRP. THE PANEL THUS CONCLUDED THAT GIML THEREBY VIOLATED CBOT RULES 538.C. AND 538.E. Status: Final Sanction Detail: IN 2017 GAM INTERNATIONAL MANAGEMENT LIMITED AGREED TO AN OFFER OF SETTLEMENT WITH THE CHICAGO BOARD OF TRADE ("CBOT") IN WHICH GAM INTERNATIONAL MANAGEMENT LIMITED NEITHER ADMITTED NOR DENIED A RULE VIOLATION AND AGREED TO PAY A FINE OF $25,000. Summary: THE OFFER OF SETTLEMENT HAS BEEN AGREED BUT NOT SETTLED.

Allegations: SIX EXCHANGE REGULATION AG ("SIX"), THE SWISS LISTING AUTHORITY UPHELD SANCTIONS AGAINST GAM HOLDING AG RELATING TO BREACHING IFRS ACCOUNTING STANDARDS IN CONNECTION WITH ITS ACQUISITION OF CANTAB CAPITAL PARTNERS LLP ("CANTAB") IN 2016. IN CONNECTION WITH THIS ACQUISITION, GAM HOLDING ENTERED INTO A CONTRACTUAL OBLIGATION TO PAY A SHARE OF FUTURE PERFORMANCE FEES TO THE PREVIOUS OWNERS FOR AN INDEFINITE PERIOD OF TIME. GAM HOLDINGS DID NOT RECOGNIZE THIS CONTRACTUAL OBLIGATION AS A FINANCIAL LIABILITY IN THE CONSOLIDATED INCOME STATEMENT OF THE 2017 IFRS FINANCIAL STATEMENTS AND INSTEAD DISCLOSED THIS OBLIGATION AS A CONTINGENT LIABILITY Status: Final Sanction Detail: ADDITIONAL MONETARY FINE OF CHF 100,000 RELATING TO COSTS OF THE FINE. Summary: GAM HOLDING AG HELD A DIFFERENT POINT OF VIEW IN GOOD FAITH OF THIS TECHNICAL ACCOUNTING MATTER, DUE IN PART TO EXTERNAL AND INDEPENDENT EXPERT ADVICE. HOWEVER, GAM HOLDING AG DECIDED TO ACCEPT THE DECISION MADE BY SIX'S SANCTIONS COMMISSION AND PAY THE RELATED FINANCIAL PENALTY OF CHF 400,000 (CONVERTED TO USD 425,059.38) AND COSTS OF APPROXIMATELY CHF 100,000. AS A RESULT OF THIS DECISION, GAM HOLDING AG IS REQUIRED TO RECOGNISE THE FINANCIAL LIABILITY RELATING TO THE ACQUISITION OF CANTAB AT FAIR VALUE AND HAS RESTATED IMPACTED HISTORICAL COMPARATIVE AMOUNTS IN THE FOLLOWING CONSOLIDATED FINANCIAL STATEMENTS.

Allegations: GAM INTERNATIONAL MANAGEMENT LIMITED (GIML) HAS REACHED A SETTLEMENT WITH THE FCA. THE FCA OPENED THE INVESTIGATION INTO GIML FOLLOWING THE SUSPENSION OF AN INVESTMENT DIRECTOR ON 31ST JULY 2018. THIS SETTLEMENT CONCERNS THE OPERATION OF GIML'S CONFLICTS OF INTEREST FRAMEWORK BETWEEN NOVEMBER 2014 AND OCTOBER 2017 AND CONFLICTS OF INTEREST ARISING OUT OF THREE SPECIFIC INVESTMENTS MADE BY THE ABSOLUTE RETURN BOND FUND (ARBF) TEAM BETWEEN OCTOBER 2016 AND MARCH 2018. GIML HAS FULLY COOPERATED WITH THE FCA'S INVESTIGATION, AND THIS BRINGS THEIR INVESTIGATION INTO GIML TO A CLOSE. GIML IS PAYING A FINANCIAL PENALTY OF GBP 9.1 MILLION. Status: Final Sanction Detail: FINANCIAL SETTLEMENT Summary: THE FCA OPENED THE INVESTIGATION INTO GIML FOLLOWING THE SUSPENSION OF AN INVESTMENT DIRECTOR ON 31ST JULY 2018. THIS SETTLEMENT CONCERNS THE OPERATION OF GIML'S CONFLICTS OF INTEREST FRAMEWORK BETWEEN NOVEMBER 2014 AND OCTOBER 2017 AND CONFLICTS OF INTEREST ARISING OUT OF THREE SPECIFIC INVESTMENTS MADE BY THE ABSOLUTE RETURN BOND FUND (ARBF) TEAM BETWEEN OCTOBER 2016 AND MARCH 2018.