SWE – FI Fines for Late Shareholding Disclosure Reporting

SWE – FI Fines for Late Shareholding Disclosure Reporting

On 23 August 2021, SWE FI fined Redmile Group SEK 1mn for late shareholding reporting.

  • SWE FI issued penalty fee for Redmile Group for late flagging in Hansa Biopharma.


  • On 9July 2020, Redmile Group, LLC announced it had increased its shareholding in Hansa Biopharma AB so that it exceeded five percent of all shares and votes.
  • SWE FI explained that it only received the notification on 8 September 2020.

SWE FI Investigation

  • On 15 January 2021, SWE FI raised the question of whether the company's notification was received too late and whether the company should therefore pay a penalty fee.
  • Company said that as investment manager it bought shares in Hansa Biopharma, which on 9 July 2020 funds together held +5% of shares, votes in Hansa Biopharma.
  • At this time, there was a lack of knowledge about the Swedish notification rules.
  • As soon as the company became aware of these, a Swedish representative was hired and a report was sent in, and the staff received training in the Swedish flagging rules.
  • Also, Hansa Biopharma has been put on a special restriction list, preventing merchants from carrying out transactions in Hansa Biopharma without involving compliance team.
  • Measures taken to ensure flagging, other notifications happen as per Swedish law.
  • Threshold value of 10% of Hansa Biopharma's shares, votes now also been exceeded.
  • Notification regarding this change in shareholding was submitted to SWE FI in time.
  • Company submitted Hansa investment fund list, funds' holdings list on 8-9 July 2020.

Penalty Fee

  • Redmile was obliged to notify change in holdings to SWE FI no later than 14 July 2020.
  • SWE FI received the report on 8 September 2020, giving grounds for imposing penalty fee.
  • The company's report was received by SWE FI more than 40 trading days late.
  • Applying the standard model, the penalty fee can thus be calculated at SEK 1mn.
  • The fact the company trained its staff and put Hansa Biopharma on a special list does not constitute mitigating circumstances that mean the fee must be reduced.
  • Nor are there other mitigating/aggravating circumstances to take into account.