The repercussions of the Woodford debacle continue to be keeping the press boys and girls very busy and whilst I despise some of the comments that are both inflammatory and far too personal, the truth around the procedures undertaken by Woodford continues to throw up editorial gold. The damage done to the industry both for Asset Management and Wealth Management could take years to repair and yet, dare I say, this needn’t have happened if proper oversight was in place from the beginning. 

Independence of thought and work is of course critical to the success of our industry as is with others. We work in an environment priding itself with very bright people who deliver exceptional service, product and initiatives for consumers and businesses alike. Some of them I have had the pleasure of working with either directly or providing product across this country and beyond. 

Many of those individuals were at times challenging to deal with and other times downright obstinate and rude but you took it on the chin and hopefully you lived to tell the tale another day. Numerous people had very good lieutenants who in the words of one had “a massive broom clearing up the mess”. These lieutenants were there to ensure the business process was adhered to, whilst the ‘maverick’ created the ideas, the revenue, the glitz or whatever the ‘Special One’ dreamt up. But whilst this is fine in a small business that is looking after just its own clients, it’s certainly not acceptable when you step outside the inner circle and provide services/product to a wider audience. 

How do we stop another Woodford, a ‘maverick’, a  ‘control freak’, an ‘ego’ from running his own self-belief Fund AND putting the reputation the industry and the investments of thousands at risk? 

The Central Bank of Ireland introduced over a year ago, (announced five years ago), the CP86rules and guidance in seven key areas: 

  1. The rationale for board composition.
  2. Directors’ time commitments.
  3. Organisational effectiveness.
  4. Managerial functions.
  5. Delegate oversight.
  6. Operational issues.
  7. Procedural matters

The key point I take from this are the CP86 functions, effectively say to Management Companies and Fund Boards, “here are a list of Designated Functions that a Designated Person will be responsible for”. That is to say, their heads are on the block if it goes wrong. Now if that doesn’t focus the mind, I don’t know what does!

These Functions and the Designated Persons who are responsible revolves around the following 6 areas:

  1. Investment management.
  2. Distribution.
  3. Fund risk management.
  4. Operational risk management.
  5. Regulatory compliance.
  6. Capital and financial management.

These are key areas of responsibility and if adhered to, and managed well with regulatory reporting demonstrating evidence-based oversight, then no Fund Manager can go and rip up the market with excessive risk or breaking the moral compass with their ideas of getting a better return for investors. This is not rocket science. This how a business should be run particularly as the Shareholders are the ones who ultimately pay the wages of those managing the money.

So, a plea to Regulators everywhere and to all Fund Boards in the UK and elsewhere, let’s take up the CP86 ideas and embed them into the rules and regulations. We have the Senior Managers and Certification Regime (SMCR) coming into the UK very soon and there are some great aspects of this such as the Senior Management Functions (SMF) and the Statement of Responsibilities (SOR) but, I would advocate taking it further to fully embrace the CP86 rules. There is no hiding whatsoever and the challenging environment with independent Boards means that Funds are run within a strong regulatory framework. The issue is, of course, can a company launching a Fund take an independent rocket from a Fund’s Board to behave or suffer the consequences?

Meanwhile, the AIC has been making hay whilst the sun shines as they have talked endlessly about the liquidity issues of Investment Trusts as well as the Independence of their Boards. I agree with both points unequivocally and would welcome the same for all open-ended Funds. What is stopping the introduction of these? I think we need to get our house in order or at least check the foundations aren’t cracked before it’s too late and underpinning is required!

Have a great long weekend and may the sun continue to shine for the Bank Holiday.


Stuart Alexander


In other news...


You must submit your agreement before access to the site can be granted


This website is directed at institutional clients and individuals who have taken appropriate professional advice, who possess the necessary experience, knowledge and expertise to make their investment decisions and properly assess the risk that it incurs.

Gemini Capital Management (Ireland) Limited, trading as GemCap, is a limited liability company registered under the registered number 579677 under Irish law pursuant to the Companies Act 2014 which is regulated by the Central Bank of Ireland, reference number C155302. Its principal office is at Ground Floor, 118 Rock Rd, Booterstown, Co. Dublin, A94 V0Y7 and its registered office is at 1 WML, Windmill Lane, Dublin 2, D02 F206.

GemCap acts as management company and global distributor to GemCap Investment Funds (Ireland) plc.

GemCap Investment Funds (Ireland) plc is an umbrella fund with segregated liability between sub-funds incorporated as an investment company with variable capital registered under the registered number 485081 under Irish law pursuant to the Companies Act 2014 and authorised by the Central Bank of Ireland, reference number C67292, pursuant to the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011 (as amended) ), having its registered office at 1 WML, Windmill Lane, Dublin 2, D02 F206(“the Fund”) .

The contents of this site have been prepared solely for information purposes and is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation. GemCap and the Fund does not give or make any guarantee, representation, warranty or other promise or confirmation (whether express or implied) as to its accuracy or completeness.


Risk Warnings

Please remember that the value of investments and the income from them can fluctuate (this may partly be the result of exchange rate fluctuations) and you may not get back the full amount invested. Past performance may not a reliable guide to future performance. A comprehensive list of risk factors is detailed in the Prospectus and the key investor information document (“KIID”) and an investment should not be contemplated until the risks are fully considered. The Prospectus and KIID can be viewed at www.geminicapital.ie

GemCap does not provide financial, investment, tax or any other professional advice in any way and none of the information on this site should be construed as such. None of the information contained on this site constitutes an offer to buy or sell or a solicitation, recommendation, invitation by or on behalf of GemCap to buy or sell any security, product, service or investment. Any opinions expressed on this site do not constitute investment advice and independent advice should be sought where appropriate. The view and/or opinions expressed by GemCap through this or any other platform, may be subject to change.

The shares in the Fund have not been and will not be registered under the US Securities Act of 1933 (the “1933 Act”) as amended or the securities laws of any of the states of the United States. The Shares may not be offered, sold, transferred, pledged or delivered, directly or indirectly, in or into the United States or to or for the account or benefit of any US Person except pursuant to an exemption from, or in a transaction not subject to the registration requirements of the 1933 Act and any applicable state laws, nor in any jurisdiction in which the Fund is not authorised to be publicly sold. The Fund is available only in jurisdictions where their promotion and sale are permitted.

The information contained on the website may not be redistributed directly or indirectly to any citizen or resident of the United States or any other jurisdiction where its distribution may be restricted by law. It is the responsibility of persons accessing the website to ensure compliance with the above.

Disclaimer for Investors in Switzerland

The Fund and its sub-funds, Calamos Global Convertible Fund and Third Avenue Real Estate Value Fund has been approved by the Swiss Financial Market Supervisory Authority FINMA (“FINMA”) for offering to Swiss non-qualified investors.

This website may contain advertising.

In Switzerland, the representative is ACOLIN Fund Services AG, Leutschenbachstrasse 50, CH-8050 Zurich, whilst the paying agent is Banque Cantonale Vaudoise, Place St.-François 14, CH-1003 Lausanne.

Swiss investors may obtain free of charge from the representative in Switzerland, the relevant fund documents, namely the prospectus, the key investor information documents, the articles of association, as well as the annual and semi-annual reports.


Past performance results are no indication of future results. Issuance and redemption commissions are not included in the performance figures. Performance results referring to a period of less than twelve months (year-to-date-performance, start of investment fund within the last twelve months) are no reliable indicator for future results due to the short comparison period.


Additional information for Qualified Investors in Switzerland:

The below-mentioned investment funds, which are also disclosed on this website, are neither registered with FINMA nor under contract for representation to Swiss investors. These investment funds may not be distributed neither to Swiss non-qualified and qualified investors nor exclusively to Swiss qualified investors:


GemCap Investment Funds (Ireland) Plc

Atlantic House Defined Returns Fund

Atlantic House Global Defined Returns Fund

Atlantic House Total Return Fund

Atlantic House US Enhanced Equity Fund

Causeway Defined Growth Fund

GSI Global Sustainable Value Fund

GSI Global Sustainable Focused Value Fund

London & Capital Global Balanced Fixed Income Fund

London & Capital Global Conservative Fixed Income Fund

London & Capital Global Defensive Equity Fund (this Fund has terminated and accordingly, Shares in this Fund are no longer available for investment)

London & Capital Global Growth Fund

London & Capital Global Growth Fixed Income Fund

London & Capital Global Star Equity Fund

London & Capital Global Balanced Fund

Principal Asset Allocation Fund

Semper Total Return Fund

TEAM International Equity Fund




This GemCap website and material contained herein (including information from third parties) is provided ‘as is’, without any representation or endorsement made and without warranty of any kind whether express or implied, including, but not limited to, the implied warranties of satisfactory quality, fitness for a particular purpose, non-infringement, compatibility, security, completeness and accuracy.

By entering this site, you acknowledge and agree that the use of this site is at your own risk and to the extent permissible by applicable law, in no circumstances, including (but not limited to) negligence, shall GemCap be liable for any direct, indirect, incidental, special, consequential, or punitive damages, losses, costs or expenses nor for any loss of profit that results from the use of, or inability to use this site or any material on any site linked to this site (including but not limited to any viruses or any other errors or defects or failures in computer transmissions or network communications) even if we have been advised of the possibility of such damage. In addition, no liability can be accepted by GemCap in respect of any changes made to the content of this site by unauthorised third parties. All express or implied warranties or representations are excluded to the fullest extent permissible by law. We do not warrant that this site does not infringe any intellectual property rights of third parties.

No data transmission over the internet can be guaranteed as totally secure. Whilst GemCap strives to protect such information and every effort has been made to implement security protocols, in line with relevant legislation to ensure safe processing and storage of any data transmitted, we do not guarantee and cannot ensure the security of any information which you transmit to us. Accordingly, any information which you transmit to us is transmitted at your own risk.

The GemCap website is not a substitute for independent professional advice and users should obtain any appropriate professional advice relevant to their particular circumstances.

The information on this site is issued by GemCap.



If you use the internet quite a bit, there’s a good chance you’ve heard of cookies.

But what are they?

Also known as HTML cookies, tracking cookies or magic cookies, these tiny files are automatically downloaded by your computer when you’re browsing online. Don’t worry – they’re perfectly safe. But we’d still like to take a moment to explain what cookies do, which ones we use and how to remove them – if you really want to.

Are Cookies Safe?

Yes, cookies are safe. The information they collect is completely anonymous. We never, ever, collect personal information using cookies. What’s more, cookies are not harmful to your computer, they take up minimal space and they can be removed with just a few clicks.

GemCap’s Cookie Functionality

  • Cookies provide enhanced functionality and speed to our site
  • These cookies help us to recognise your computer when you visit Gemini-Capital.ie and enable us to improve your visits to our website
  • Cookies assist us in identifying what kind of visitor/user you are, for us to provide you with the most relevant content

How Can I Remove Cookies?

Most computers are set to download cookies automatically, so if you’re happy with everything you’ve read, simply carry on as you were. However, if you’re at all concerned about having cookies on your computer, deleting them is simple.

Show me how to remove cookies

Likewise, you can also change your computer settings so that it won’t download any more cookies.

Show me how to change my cookie settings

The information on this site is issued by Gemini Capital Management (Ireland) Ltd, which is registered in Ireland No. 579677. The registered address for the company is 1 WML, Windmill Lane, Dublin 2, D02 F206, Ireland.