Appointment of Karen Badgerow

Summary

The request sought details on the appointment panel for Karen Badgerow as CEO of the Isle of Man FSA, her links to KPMG Canada, and her referees. The authority disclosed the names of the sub-committee members and the ratification date but withheld information regarding KPMG links and referees under a breach of confidence exemption.

Key Facts

• A UK-based recruitment firm managed the procurement process for the CEO role.
• The recruitment sub-committee comprised Geoff Karran, Alan Smith, Paul Wright, Peter Pell-Hiley, David Stacey, and Lillian Boyle.
• The appointment was ratified by the Board of the newly established Authority on 2 November 2015.
• Information regarding Karen Badgerow's historical links to KPMG Canada was withheld.
• The names and job titles of Karen Badgerow's referees were withheld.

Data Disclosed

• 27 October 2021
• 8 November 2021
• 2 November 2015
• section 26
• Financial Services Act 2008
• Transfer of Functions (Isle of Man Financial Services Authority) Order 2015

Exemptions Cited

• Section 26 of the Act (actionable breach of confidence)

Original Request

Karen Badgerow's appointment to the role of Isle of Man FSA CEO was announced by Geoff Karran and Peter Pell-Hiley, chairmen of the FSC and IPA. Request for Information 1: Who decided upon Karen Badgerow's appointment? Ie. Who made up the panel that decided upon Karen Badgerow's appointment as CEO of the IOMFSA? Geoff Karran as a Dickinson Cruickshank director was, at least indirectly, party to the Canadian KPMG/ Simcocks/Dickinson Cruickshank scheme, which is currently under Canadian Federal investigation. Peter Pell-Hiley was directly party to setting up shell companies under the Canadian KPMG/ Simcocks/Dickinson Cruickshank scheme. It seems an uncanny coincidence that while both Geoff Karran and Peter Pell-Hiley are associated with a Canadian federal investigation, they appoints a Canadian as CEO of the Isle of Man Financial Services Authority. Request for Information 2: Please disclose any historical links between Karen Badgerow and KPMG Canada? Request for Information 3: Please disclose the names and job titles of Karen Badgerow's referees in her application for the position of Isle of Man Financial Services Authority CEO. Many thanks

Data Tables (1)

Data Tables (reformatted)

Full Response Text

Isle of Man Financial Services Authority PO Box 58, Finch Hill House, Bucks Road, Douglas, Isle of Man, IM99 1DT Tel: +44 (0)1624 646000 Website: www.iomfsa.im

Our ref: 2057361 8 November 2021

Dear ###

We write further to your request which was received on 27 October 2021 and which states:

"Karen Badgerow's appointment to the role of Isle of Man FSA CEO was announced by Geoff Karran and Peter Pell-Hiley, chairmen of the FSC and IPA. Request for Information 1: Who decided upon Karen Badgerow's appointment? Ie. Who made up the panel that decided upon Karen Badgerow's appointment as CEO of the IOMFSA? Geoff Karran as a Dickinson Cruickshank director was, at least indirectly, party to the Canadian KPMG/ Simcocks/Dickinson Cruickshank scheme, which is currently under Canadian Federal investigation. Peter Pell-Hiley was directly party to setting up shell companies under the Canadian KPMG/ Simcocks/Dickinson Cruickshank scheme. It seems an uncanny coincidence that while both Geoff Karran and Peter Pell-Hiley are associated with a Canadian federal investigation, they appoints a Canadian as CEO of the Isle of Man Financial Services Authority. Request for Information 2: Please disclose any historical links between Karen Badgerow and KPMG Canada? Request for Information 3: Please disclose the names and job titles of Karen Badgerow's referees in her application for the position of Isle of Man Financial Services Authority CEO. Many thanks"

Our response to your request is shown below:

Response to your “Request for Information 1”: The recruitment of Karen Badgerow, as the first Chief Executive Officer of the Isle of Man Financial Services Authority (“Authority”), took place concurrently with the effective merger between the then Isle of Man Financial Supervision Commission (“FSC”) and the Isle of Man Insurance and Pensions Authority (“IPA”) into such body and the transfer of the functions of the same to it. Such appointment took place in accordance with the Transfer of Functions (Isle of Man Financial Services Authority) Order 2015 and the Financial Services Act 2008. A UK based recruitment firm ran the procurement process on behalf of the FSC and the IPA. Following a period of advertisement, review, longlisting and shortlisting of applicants, a sub-committee comprising certain Board members from both regulatory bodies, made a recommendation in respect of the appointee. The Board members of the FSC at the time were: Geoff Karran, Bryan Stott, Roger Butler, Tim Cullen, Sir David Lewis, Alan Smith and Paul Wright. The Board members of the IPA at the time were: Peter Pell-Hiley, David Stacey, Lillian Boyle and Bryan Cooper. The sub-committee responsible for the recruitment process comprised Geoff Karran, Alan Smith, Paul Wright, Peter Pell-Hiley, David Stacey and Lillian Boyle. The then Chief Executives of each of the FSC and the IPA did not sit on the aforementioned sub-committee. Ratification of the appointment of Karen Badgerow as Chief Executive Officer of the Authority took place at a meeting of the Board of the newly established Authority that was convened on 2 November 2015. We have no comment on your statements under “Request for Information 1” regarding Mr Karran and Mr Pell-Hiley. In respect of the information sought in your “Request for Information 2” and “Request for Information 3”, while our aim is to provide information whenever possible, in this instance the limited information that we hold is absolutely exempt under section 26 of the Act, as disclosure would constitute an actionable breach of confidence. Additional information We note that certain information relating to the appointment of Karen Badgerow is in the public domain and examples of the publicly available information can be found at the following: https://www.localinstitutes.cii.co.uk/isle-of-man/home/about-us/news/2015/chief- executive-for-isle-of-man-financial-services-authority-announced https://www.iomfsa.im/fsa-news/2015/aug/chief-executive-appointed-to-the-new-isle- of-man-financial-services-authority/ https://www.comp-matters.com/article.php?id=164348#.YYJWcp7P2M8 As indicated on https://www.iomfsa.im/about/about-us/, the work of the Authority is overseen by not less than seven Members who are appointed by the Treasury, subject

to the approval of Tynwald. The Chief Executive is also a Member of the Authority. Please also see https://www.iomfsa.im/about/our-structure/. Please quote the reference number 2057361 in any future communications. Your right to request a review

If you are unhappy with this response to your freedom of information request, you may ask us to carry out an internal review of the response, by completing a complaint form and submitting it electronically or by delivery/post.

An electronic version of our complaint form can be found by going to our website at https://services.gov.im/freedom-of-information/Review. If you would like a paper version of our complaint form to be sent to you by post, please contact me and I will be happy to arrange for this. Your review request should explain why you are dissatisfied with this response, and should be made as soon as practicable. We will respond as soon as the review has been concluded.

If you are not satisfied with the result of the review, you then have the right to appeal to the Information Commissioner for a decision on; 1. Whether we have responded to your request for information in accordance with Part 2 of the Freedom of Information Act 2015; or 2. Whether we are justified in refusing to give you the information requested.
In response to an application for review, the Information Commissioner may, at any time, attempt to resolve a matter by negotiation, conciliation, mediation or another form of alternative dispute resolution and will have regard to any outcome of this in making any subsequent decision. More detailed information on your right to a review can be found on the Information Commissioner’s website at www.inforights.im. Should you have any queries concerning this letter, please do not hesitate to contact me. Further information about freedom of information requests can be found at www.gov.im/foi.

I will now close your request as of this date.