Open letter to data platforms and providers from ACT Stewardship Council

October 2024

Dear Data Platforms and Providers,

We are writing in our capacity as users of research and data platforms of collective investment vehicles and as members of the ACT Stewardship Council, a cross-industry body of representatives from collective investment vehicles acting on behalf of over $2trn in clients assets. 

Your organisations play a crucial part in the research and selection of collective investment vehicles, which we believe gives you an important role to play in the work of ACT, a Corporate Culture Standard and disclosure framework for the investment industry. The purpose of this letter is to explain how we’d like you to help disseminate this work. 

ACT is a disclosure framework that focuses on culture and how culture can impact client outcomes. By signing up to the ACT Framework asset managers commit to a high degree of openness and granularity regarding their culture and how it drives investment results. Disclosing that an asset manager is a signatory to ACT is fast becoming an important element of a fund selection process. You can read more here: Investors ACT. 

Amid certain scandals in recent years and as regulatory and supervisory trends have evolved, a more robust conversation about the role of culture is underway. Whilst regulation is in the pipeline alongside growing stakeholder demands for disclosure, there is little guidance for investment companies to be able to tell their story. 

In the last year the regulatory environment has seen an uptick in requirements for firms to demonstrate why their culture leads to good outcomes for clients:

• Consumer Duty clearly sets out that firms should describe how their culture helps to meet the Duty requirements. The guidance stated: “Diversity of thought and inclusive behaviours in financial services will help to deliver better consumer and market outcomes including fair value, fair treatment, suitability, confidence and access” and the FCA has noted this will require many firms to make significant changes. 

• The 2024 FRC Corporate Governance Code amendments strengthen the importance of the role of culture and values, stating it should be consistent with firm strategy as well as execution in policies and process. Boards are asked to be more transparent and accountable with regard to how culture is assessed, monitored and how effectively it has been embedded.

• SDR and European legislation has clear intentionality to reduce greenwashing in how not just products are marketed, but how firms are talking about their own capabilities.

• The 2023 FCA consultation on diversity and inclusion emphasised that improvement “can create better outcomes for consumers and markets by supporting healthy work cultures, reducing groupthink, unlocking talent and improving understanding of diverse consumer needs”. 

Despite this regulatory environment, fund selectors are often left with an insight gap, which can affect outcomes if they cannot properly consider how the business works or how teams are built. Insight on culture supports decisions about the suitability of the products on offer and the teams that are providing them. It helps understand how fees are being allocated - whether that is through remuneration or in how the firm markets itself, or the initiatives it supports. We believe that lessons are being learned from the sustainability/ESG investment space and in order to reduce the likelihood of greenwashing equivalent, a comparable, structured approach is needed to create the language and vocabulary for better dialogue between stakeholders.  

The ACT Framework has been created to address these gaps, as a standardised way for investment companies to understand, create and progress cultural change and be able to communicate progress effectively via reporting.

We are asking data platforms and providers to add ACT Signatory Status and the year a firm became a Signatory. This is vital firm-level information that can also be added to individual funds.  By using ACT signatory status as a data point, it will enable analysts to quickly understand that a firm is committed to the disclosures and can act as a screening tool for behaviours, by transforming qualitative information into a quantitative metric.  

ACT disclosures take place via the Door due diligence platform, enabling transparency of disclosures. Over 125 firms are already reporting and responding to client requests for disclosure and momentum for uptake is strong.

We are very keen to engage with your organisation to see how ACT Framework data and disclosures could be incorporated into your research and data platform offering. 

Yours sincerely, 

ACT STEWARDSHIP COUNCIL MEMBERS:

Bev Shah, co-CEO, City Hive & co-Chair of ACT Stewardship Council

Mandy Kirby, co-CEO, City Hive & co-Chair of ACT Stewardship Council

Abika Martin, Investment Manager, LGT Wealth

Andrew Summers, CIO, Omnis Investments

Ben Seager-Scott, CIO, Forvis Mazars

Cameron Falconer, Head of Investment Oversight and Manager Research, Aviva Investors

Daniel Babington, Portfolio Manager, TAM Asset Management

Daniela Barone Soares OBE, CEO, Snowball

Darren Ruane Head of Portfolio Construction, Investec Wealth & Investment UK

David Coombs, Head of Multi-asset Investments, Rathbones Asset Management

David Storm, CIO, RBC Wealth Management

Dewi John, Head of Research, UK and Ireland, LSEG Lipper 

Elizabeth Savage, co-CIO, Rathbones

Ellie Brown, Senior Client Relationship Manager, DOOR Ventures

Emma Wall, Head of Platform Investments, Hargreaves Lansdown

Genevra Banszky von Ambroz, Partner, Evelyn Partners

Heidi Ridley, CEO and co-founder, Radiant Global Investors

Ian Aylward, former Head of Manager Selection and Responsible Investing, Barclays Wealth Management

Jake Moeller, Associate Director, Responsible Investment, Square Mile Investment Consulting & Research

James Hart, Investment Director, Witan Investment Trust

Jasper Thornton-Boelman, Investment Director, Parmenion

Joe Wiggins, Director of Research, St. James’s Place

Justin Onuekwusi, CIO, St. James’s Place

Kalinka Dyankova, Senior Fund Analyst, Kleinwort Hambros

Kathryn McDonald, co-Founder, Head of Investments and Sustainability, Radiant Global Investors

Katie Trowsdale, Head of Client Investment Solutions, Abrdn

Lucy Walker, Chair, Aurora Investment Trust

Mariella Rice-Jones, Responsible Investment Lead, Brooks McDonald

Matt Wiles, Head of Fund Research, EQ Investors

Mona Christensen, Head of Product Governance, Ascot Lloyd

Mona Shah, Senior Sustainability Strategist, Lombard Odier Investment Managers

Nick Samuels, Managing Director, Client Portfolio Manager, Jennison

Paris Jordan, Head of Responsible Investing, Charles Stanley

Peter Clark, CEO and Co-Owner, Bentley Reid

Shilpan Patel, Head of Sales and Client Relations (EMEA), DOOR Ventures

Simon Evan-Cook, Fund Manager, Downing Fund Managers

Sophie Kennedy, joint-CEO, EQ Investors 

Sophie Meatyard, ESG Fund Research Director, MainStreet Partners

Stuart Derrick, Head of Manager Selection, Cazenove Capital