"Directors have a duty to disclose or avoid conflicts of interest so they can be addressed by the board."
Angela Burns is an experienced UK investment professional and the chief executive of her own investment consultancy.
From January 2009 until May 2011, she was also a non-executive director at two mutual societies and served as the chair of their investment committees.
Both mutual societies were seeking investment manager services and looked to Burns for expert advice and guidance.
Burns participated in discussions about Vanguard Asset Management, a well-known US investment manager that had just opened offices in the UK, at both mutual societies.
She was simultaneously soliciting work from Vanguard by referring to her NED positions at the mutuals, but did not tell either society that she was simultaneously seeking consultancy work with Vanguard.
Mark Steward, executive director of enforcement and market oversight at the FCA, said: "Directors have a duty to disclose or avoid conflicts of interest so they can be addressed by the board.
In this case, Ms Burns placed herself in a position where her duty as a non-executive director may have conflicted with concurrent opportunities she was pursuing. This was neither disclosed nor, as a consequence, could it be addressed by the board. This was inappropriate and inconsistent with the standards of integrity expected from senior managers."