Hargreaves Lansdown, St. James’s Place and Cazenove among the first to adopt ACT Informed designation

Think tank and advocacy group City Hive has unveiled ACT Informed, a new recognition designed to help investment organisations demonstrate how culture and behaviour are incorporated into governance, oversight and decision making.  

Fund research teams at Hargreaves Lansdown, St. James’s Place, Cazenove and EQ Investors are the first to evidence integration of the ACT (Action, Challenge, Transparency) Framework within their investment processes, and to describe themselves as ACT Informed organisations.

Expectations around culture, behaviour and governance in financial services are continuing to rise, alongside increasing scrutiny of how investment decisions are made. ACT Informed provides a simple and credible way for organisations to evidence how these factors are considered in practice.

ACT Informed applies where ACT is used as an input into governance, oversight or research processes. It is a recognition focused on evidencing how ACT outputs are used — not on assessing, rating or endorsing organisations, managers or products.

The recognition supports stronger governance and risk management without adding cost, regulatory burden or operational complexity, and is designed to sit alongside existing due diligence and investment frameworks.

ACT Informed is relevant for organisations involved in appointing, overseeing, distributing, rating or evaluating investment managers and funds. This includes wealth managers and advisers, investment platforms, ratings agencies, asset owners and institutional investors, investment consultants, pension and charity trustees, and investment trust boards.

By integrating independent culture data into governance and decision-making processes, ACT Informed organisations can strengthen due diligence, enhance risk management and improve decision discipline.

Importantly, ACT Informed does not replace fiduciary responsibility, investment discretion or existing due diligence processes. It provides a structured way to incorporate independent culture insights as an input into decision-making.

Organisations adopting the recognition can publicly describe themselves as ACT Informed and use the recognition to signal disciplined use of ACT within governance and oversight.

They also gain access to supporting resources to help embed ACT in practice, and enable individuals within their organisations to participate in the ACT Collective - a peer network providing insight and support in understanding and interpreting ACT outputs.

Participants may also have opportunities to contribute to stewardship or advisory activity related to the ACT Framework, including representation on the ACT Stewardship Council, an independent cross-industry body providing strategic guidance and oversight.

Andy Ford, head of responsible investment at St. James’s Place, commented: 

“Culture is central to long‑term investment performance, and we believe the ACT framework can play an additive role in our ongoing manager oversight. It can help guide conversations with managers and  support more transparent, comparable and constructive engagement on culture.”

Emma Wall, chief investment strategist at Hargreaves Lansdown and chair of the ACT Stewardship Council, said: 

“We’re proud to integrate the ACT questionnaire into our due diligence process – if you are not transparent about your culture, you can’t be included in our solutions. The Framework helps us better understand the environment that the managers we’re backing operate in, which in turn impacts their ability to deliver for our clients.”

Stuart Derrick, head of manager selection, Cazenove Capital commented:

“Being ACT Informed reflects our established focus on corporate culture as part of our investment due diligence. We believe culture is a meaningful indicator of leadership quality, governance and long-term value creation”.

Bev Shah and Mandy Kirby, co-CEOs at City Hive, also said: “We’re encouraged to see early adoption from firms such as Hargreaves Lansdown, St. James’s Place and Cazenove. It reflects a clear shift towards more intentional consideration of culture within investment oversight. ACT Informed provides a practical way for organisations to evidence that in their governance and decision-making.”

We are pleased to announce the launch of ACT Informed following the unveiling of the ACT List 2026 in January with 40 Signatory firms - 43% growth on the previous year.

Notes:

Organisations interested in becoming a part of ACT Informed, or those already integrating ACT within their governance processes, can contact hq@cityhive.co.uk or visit www.investorsact.com to discuss adoption or confirm ACT Informed status.

About City Hive

City Hive is a think tank dedicated to improving the culture of the investment management industry. Through research, collaboration and initiatives such as the ACT Framework, City Hive works to encourage greater transparency, stronger governance and more inclusive industry practices.

For more information on ACT, interview opportunities and photos please email: nataliekenway@cityhive.co.uk or visit the 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/

CEO Letter

At the time of launching ACT in 2022, City Hive wrote to over 100 fund group CEOs to say investment firms are neglecting to support their most valuable assets, their employees, and asking them if they want to be the leader that is forced to make changes, or the leader that is part of the solution investing in creating a long-term, positive, impact on the industry.

The ACT Framework is comprised of three key pillars, each with three components: