Board Toolkits
Supporting boards in strengthening fiduciary oversight.
The ACT Framework provides fiduciaries with a structured and transparent approach to assessing and monitoring organisational culture, strengthening accountability and mitigating conduct and reputational risks.
The ACT Toolkit is designed to support board directors apply the ACT framework in practice, providing the resources needed to evidence effective governance.
How ACT Supports Investment Trust Boards
Investment trust boards operate at the intersection of governance, stewardship, and accountability. The evolving regulatory landscape — including the UK Corporate Governance Code (2024), AIC Code (2024), and FCA Consumer Duty — now expects boards to demonstrate cultural awareness as part of effective oversight. The ACT Framework creates a consistent approach across the investment ecosystem.
-
Challenge: Boards delegate investment management but retain responsibility for governance and investor protection. Assessing whether a manager’s internal culture aligns with fiduciary duty is often informal or inconsistent.
How ACT helps: ACT provides a structured, repeatable method for assessing the cultural health of investment managers — allowing boards to demonstrate transparent, evidence-based oversight.
Regulatory reference: AIC Code of Corporate Governance (2024) – Principle B; UK Corporate Governance Code (2024) – Section 2, Provision 2.
-
Challenge: Regulators increasingly view culture as a driver of risk and outcomes — yet few boards have a consistent way to assess it.
How ACT helps: ACT enables boards to integrate cultural assessment into governance reviews, supporting FCA expectations and demonstrating oversight beyond financial performance.
Regulatory reference: FCA DP23/2 – Finance for positive sustainable change; FCA Consumer Duty (PRIN 2A).
-
Challenge: Weak culture within an asset manager — poor leadership, misaligned incentives, high turnover — exposes boards to conduct and reputational risk.
How ACT helps: ACT identifies early-warning indicators by assessing factors such as team stability, inclusion, and purpose, helping boards anticipate issues and evidence strong risk management.
Regulatory reference: UK Corporate Governance Code (2024) – Principle O; AIC Code – Section 3.
-
Challenge: Boards must ensure that managers’ ESG and stewardship practices align with the trust’s objectives — yet it’s often unclear how culture influences these outcomes.
How ACT helps: ACT evaluates cultural alignment with stewardship and ESG values, improving board–manager dialogue and supporting reporting under SDR and the UK Stewardship Code.
Regulatory reference: FCA ESG Sourcebook (ESG 2.1.2R); UK Stewardship Code (2020) – Principle 2.
-
Challenge: Investors and regulators expect boards to show that governance is embedded in behaviour, not just policy.
How ACT helps: ACT delivers measurable, comparable cultural data — supporting transparent reporting, accountability, and investor confidence.
Regulatory reference: AIC Code (2024) – Principle M; FCA Listing Rules LR 9.8.6R.
-
Challenge: Boards must ensure that management decisions deliver fair outcomes and sustainable value — but visibility into cultural drivers is often limited.
How ACT helps: ACT links culture to value creation, helping boards identify whether management behaviours and incentives support fairness, responsibility, and long-term performance.
Regulatory reference: FCA PRIN 2A.5R; FCA FG22/5 – Governance under Consumer Duty.
Request the ACT Toolkit
Boards interested in applying the ACT Framework can request access to the Investment Trust Board Toolkit. This includes guidance, templates, and sample reporting to support effective governance integration.
