City Hive launches ACT Toolkit to enhance charity trustees’ oversight of asset managers

  • New ACT Toolkit helps charity trustees assess whether their asset managers’ culture and conduct align with their charity’s purpose and values

  • Structured disclosures support stronger manager selection, ongoing monitoring andidentification of governance and reputational risks

  • Free resource launches amid growing expectations around trustee accountability, stewardship and investment oversight

A new toolkit has been released to help charity trustees assess whether the culture and conduct of their asset managers align with their charity’s purpose, values and long-term responsibilities.

Think tank and advocacy group City Hive has launched the ACT Toolkit for Charity Trustees, designed to give trustees a structured way to incorporate asset manager culture into manager selection, ongoing monitoring and investment governance.

Based on the ACT Framework, a corporate culture standard developed specifically for the investment industry, the Toolkit gives trustees a practical way to evaluate whether an asset manager’s internal culture aligns with their charity’s purpose, values and responsibilities.

Bev Shah, co-CEO of City Hive, commented: “Charity trustees are responsible not only for where their charity’s money is invested, but for ensuring those investments continue to support its purpose, values and long-term interests.

“Financial performance is clearly central to manager oversight, but it does not provide a complete picture. The culture of an asset management firm shapes how decisions are made, how risks are challenged, how people are supported and how openly the firm responds when problems arise.”

Mandy Kirby, co-CEO of City Hive, added: “The ACT Toolkit gives trustees a practical way to bring those considerations into their existing governance and manager-review processes. Trustees do not need to become culture specialists. They need access to the right questions, consistent information and evidence that supports informed challenge.”

The ACT Toolkit supports trustees by providing clear questions, consistent disclosures and a repeatable process through which they can identify potential cultural, governance and reputational risks.

It can be used directly by trustee boards or incorporated into the due diligence and manager-monitoring processes undertaken by their investment consultants.

Culture is increasingly recognised as a governance and risk consideration. How an asset management firm sets its priorities, makes decisions, challenges established thinking, rewards its people and responds when things go wrong can have a direct bearing on its resilience, investment approach and ability to deliver good long-term outcomes.

The Toolkit’s launch comes as charity boards face growing expectations around governance, stewardship and investment oversight. It also reflects the wider regulatory and governance context facing trustees, including:

The Charity Commission’s guidance on investing charity money, CC14* makes clear that trustees must act in their charity’s best interests, consider the suitability and diversification of investments, take advice where appropriate and review investment arrangements at suitable intervals.

The Charity Governance Code** was also revised in 2025. Its eight principles include specific expectations relating to ethics and culture, decision making, the management of resources and risk, and board effectiveness.

Meanwhile, the UK Stewardship Code 2026*** places an increased focus on the selection and oversight of asset managers, alongside transparent reporting on stewardship activities and outcomes.

Where an asset manager is not already an ACT Signatory, trustees can ask the firm to complete an ACT disclosure. This sends a clear signal that cultural alignment, transparency and accountability are part of the charity’s expectations of its investment partners.

Gemma Gooch, Head of Charities Distribution, Rathbones said: “As expectations on charity trustees continue to rise, the ACT Toolkit gives boards a clear and consistent way to assess investment managers beyond performance alone. By supporting greater transparency around culture, conduct and accountability, it can help trustees make better-informed decisions and encourage higher standards across the sector.”

David Coombs, Head of Multi-Asset Investments, Rathbones Asset Management said: “Values are often prominent in an organisation’s public messaging, but trustees need to understand how those commitments are reflected in the way investment partners operate. The ACT Toolkit gives charity investment committees a practical way to assess culture, conduct and accountability alongside investment performance. That should support more informed oversight and help ensure asset managers are aligned with a charity’s values and long-term priorities.”

The ACT Toolkit for Charity Trustees is available free of charge. To request access, visit: https://www.investorsact.com/board-toolkits

It follows the launch of the ACT Investment Trust Toolkit, with further toolkits for different stakeholders currently in development.

* https://www.gov.uk/government/publications/charities-and-investment-matters-a-guide-for-trustees-cc14

** https://www.charitygovernancecode.org/wp-content/uploads/2025/10/CCG_English_FINAL_highres.pdf

*** https://www.frc.org.uk/library/standards-codes-policy/stewardship/uk-stewardship-code-2026-guidance/

Notes to Editors: 

The ACT Toolkit for Charity Trustees includes practical examples showing how ACT can support trustees in five key areas:

  1. Demonstrating responsible stewardship

  2. Meeting ethical and sustainability-related investment expectations

  3. Managing reputational and long-term risk

  4. Supporting effective trustee challenge

  5. Improving transparency and stakeholder reporting

The ACT Framework is structured around three pillars - Action, Challenge and Transparency - and three core areas:

  • Purpose, vision and values

  • Accountability and disclosure

  • Investing in and valuing people

Rather than scoring firms or imposing a generic culture model, ACT asks asset managers to explain what they are doing, how they are doing it and how their approach is evidenced.

ACT Signatories have completed an independently overseen disclosure process and made information about their culture available for scrutiny. Trustees can access these disclosures as individual reports or comparable data and use them to support manager selection, ongoing monitoring and board reporting. There are currently 42 Signatory firms representing £13.9trn in assets under management (as at 1 July 2026). 

The ACT Stewardship Council of fund gatekeepers, responsible for over £2trn in assets under advice and monitoring firms joining or leaving the list, is looking forward to seeing which firms commit to be the first 50 Founding Signatories.

ACT Informed is a new recognition designed to help investment organisations demonstrate how culture and behaviour are incorporated into governance, oversight and decision making.  

For more information on ACT, interview opportunities and photos please email: 

nataliekenway@cityhive.co.uk or visit the new City Hive Press Centre.

For more information on ACT: https://www.investorsact.com/

Or for the ACT Stewardship Council: https://www.investorsact.com/stewardship-council 

For more information on City Hive: https://www.cityhive.co.uk/ 

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