Public statement relating to enforcement action against Sarasin Funds Management (Ireland) Limited

• Date: 30 September 2021

Enforcement Action

Central Bank of Ireland

and

Sarasin Funds Management (Ireland) Limited

Sarasin Funds Management (Ireland) Limited fined €385,000 and reprimanded by the

Central Bank of Ireland for breaches of investment restrictions and inadequate supervision

of delegates

On 27 September 2021, the Central Bank of Ireland (the Central Bank) reprimanded and fined

Sarasin Funds Management (Ireland) Limited (the Firm or SFMIL) €385,000 in respect of f our

admitted breaches of investment funds regulations which occurred between 25 May 2017 a nd

2 March 2018 (the Relevant Period).

The Central Bank determined the appropriate fine to be €550,000, which was reduced by 30%

to €385,000 in accordance with the settlement discount scheme provided for in the Central

Bank’s Administrative Sanctions Procedure.

The Firm is authorised by the Central Bank as a UCITS fund management company and is

managed by a board of non-executive directors (the Board). The Firm uses a delegation model,

whereby a number of fund management functions are delegated to external service providers,

subject to ongoing monitoring by specific directors (the Designated Directors) and the Board.

Among its delegations, the Firm delegates investment management services to an investment

manager (the Investment Manager) and delegates the depositary function to a depositary (the

Depositary).

The Central Bank’s investigation commenced following a disclosure in August 2017 by th e

Depositary, in accordance with its statutory reporting obligation, about an advertent breach of