Governance resources and toolkits
Supporting boards in strengthening fiduciary oversight.
The ACT framework provides boards, trustees and other fiduciaries with a structured and transparent approach to assessing and monitoring the corporate culture of organisations that manage investments.
ACT toolkits help fiduciaries apply the framework in practice, with resources that support effective governance, accountability and the consideration of conduct and reputational risks.
If an investment manager is an ACT signatory, the toolkit helps users apply its ACT reporting in review and monitoring. If not, it helps users ask whether the manager will report against ACT and set clear expectations around transparency.
Investment Trust Board Toolkit
Investment trust boards delegate investment management but retain responsibility for governance, oversight and investor protection. The evolving governance environment, including the UK Corporate Governance Code, AIC Code and FCA Consumer Duty, places greater emphasis on how boards evidence oversight beyond financial performance.
The Investment Trust Board Toolkit helps boards apply the ACT framework when assessing the corporate culture of investment managers, supporting more structured questioning, review and accountability.
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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.
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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).
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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.
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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.
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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.
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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.
Charity trustee Toolkit
Charity trustees must ensure investment decisions serve the charity’s best interests, reflect its charitable purpose and are made with appropriate care. Whether trustees invest directly, take advice or appoint investment managers, they remain responsible for understanding, overseeing and being able to explain how the charity’s money is invested.
Charity Commission guidance places emphasis on informed decision-making, relevant factors, reputational risk and transparent reporting. The Charity Trustee Toolkit helps trustees apply the ACT framework when assessing the corporate culture of investment managers, supporting more structured questioning, values alignment, oversight and accountability.
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Challenge: Charity trustees must be sufficiently informed when making or overseeing investment decisions, including where advice or investment management is provided by others.
How ACT helps: ACT gives trustees structured questions and disclosures to support assessment of an investment manager’s culture, governance, decision-making and alignment with the charity’s purpose and values.
Regulatory reference: Charity Commission CC14; Charity Commission CC27 — decision-making principles.
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Challenge
Trustees must ensure investment decisions reflect the charity’s purpose, values and long-term interests.How ACT supports this
ACT provides a structured way to assess whether an investment manager’s corporate culture, governance and decision-making are aligned with the charity’s mission and ethical position.Regulatory reference
Charities Act 2011, s.292C(3); Charity Commission guidance CC14 — Investment of Charitable Funds. -
Challenge
Trustees must consider the ESG, stewardship and reputational implications of their investment decisions.How ACT supports this
ACT helps trustees review how investment managers embed stewardship, governance and accountability through their corporate culture, providing a more consistent basis for discussion and oversight.Regulatory reference
Charity Commission CC14, paragraphs 41–48; UK Stewardship Code. -
Challenge
Misalignment between a charity’s values and an investment manager’s behaviour can create reputational risk and undermine confidence in investment oversight.How ACT supports this
ACT supports structured assessment of cultural alignment, helping trustees identify areas for further questioning and evidence ongoing oversight of manager behaviour and governance.Regulatory reference
Charity Governance Code — Principle 4: Decision-making, risk and control. -
Challenge
Many trustees need a more structured way to challenge professional investment managers and advisers.How ACT supports this
ACT gives trustees consistent questions and disclosures to support informed, evidence-based engagement with managers.Regulatory reference
Charities (Protection and Social Investment) Act 2016 — trustees must exercise reasonable care and skill. -
Challenge
Trustees must be able to explain investment decisions and show how investments align with charitable aims.How ACT supports this
ACT creates a clearer documentation trail for reporting on cultural alignment, stewardship quality and oversight of investment managers.Regulatory reference
Charity Commission CC14, paragraphs 58–60.
More toolkits in development
Additional ACT governance toolkits are being developed for other fiduciary and oversight audiences.