UK Financial Services Authority imposes first fine for breach of Model Code

On 14 February 2013, the UK Financial Services Authority (FSA) fined Nestor Healthcare Group £175,000 for failing to take proper and reasonable steps to secure the compliance of its board members and senior executives with the share dealing provisions of the Model Code.

Despite implementing a share dealing policy, adherence to which would have satisfied its obligations under the Model Code, Nestor failed to take reasonable steps to ensure adherence to its policy and to review and update it. In addition, the FSA found that Nestor did not maintain adequate procedures, systems and controls to ensure its persons discharging managerial responsibilities (PDMRs) complied with their obligations under the Model Code.

The fine is the first of its kind and highlights that implementation of a share dealing policy on its own is not sufficient to meet the requirements of the Model Code…

If you are registered and logged in to the site, click on the link below to read the rest of the Nabarro briefing. If not, please register or sign in with your details below.


Sign in or Register to continue reading this article

Sign in


It's quick, easy and free!

It takes just 5 minutes to register. Answer a few simple questions and once completed you’ll have instant access.

Register now

Why register to The Lawyer


Industry insight

In-depth, expert analysis into the stories behind the headlines from our leading team of journalists.


Market intelligence

Identify the major players and business opportunities within a particular region through our series of free, special reports.


Email newsletters

Receive your pick of The Lawyer's daily and weekly email newsletters, tailored by practice area, region and job function.

More relevant to you

To continue providing the best analysis, insight and news across the legal market we are collecting some information about who you are, what you do and where you work to improve The Lawyer and make it more relevant to you.

Analysis from The Lawyer

View more analysis from The Lawyer


Lacon House
84 Theobald's Road

Turnover (£m): 116.70
No. of lawyers: 405