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Article last updated 21 September 2026.
Charity trustees routinely scrutinise investment performance, risk, fees and stewardship. They may, however, have far less visibility over the culture of the asset managers responsible for managing their funds.
This matters because investment decisions are made by people working within organisations. How those organisations operate shapes the environment in which decisions are made, including who has authority, how views are challenged, what behaviours are rewarded, where accountability sits, and how firms respond when things go wrong.
Culture is sometimes viewed mainly through the lens of values or ethics. In an investment context, it can also provide insight into decision-making, resilience, governance and risk.
Looking beyond investment performance
An asset manager can change while the fund it manages continues to look much the same on paper.
Key people may leave, investment teams may be restructured, leadership can change and firms can merge or be acquired. Incentives, ownership or resources can also shift.
None of these changes automatically signals a problem, but they can alter the environment in which investment decisions are being made.
Trustees already have established ways of monitoring performance, risk, costs and stewardship. Information about culture and organisational practice adds a different perspective, helping trustees understand how an asset manager operates, where accountability sits and whether changes within the organisation warrant further questions.
Making culture easier to assess
The challenge is that culture can feel subjective.
Most asset managers can describe their values. What is harder for trustees to establish is how those values translate into practice.
The ACT Corporate Culture Standard was developed to address this information gap. ACT is a disclosure standard designed specifically for the investment industry. It does not score or rate asset managers and does not prescribe what a good culture should look like.
Instead, participating asset managers provide structured information about their culture, governance and organisational practices. The framework is built around three pillars:
- Action: what a firm is doing
- Challenge: how its approach is tested
- Transparency: what it shares
The disclosures cover areas including how culture connects to purpose and values, how firms invest in and support their people, and how responsibility is assigned and progress reported. This makes culture something that can be examined rather than simply discussed.
A practical toolkit for trustees
City Hive has launched the ACT Toolkit for Charity Trustees, giving trustees a structured way to incorporate asset manager culture into manager selection, ongoing monitoring and investment governance.
Based on the ACT Framework, the toolkit provides practical guidance on how trustees can use ACT as part of their investment governance. It explains how to access ACT disclosures, what to look for and how the information can be incorporated into due diligence, manager reviews and board reporting.
The toolkit includes practical examples showing how ACT can support trustees in five areas:
- Demonstrating responsible stewardship
- Meeting ethical and sustainability-related investment expectations
- Managing reputational and long-term risk
- Supporting effective trustee challenge
- Improving transparency and stakeholder reporting
It can be used directly by trustee boards or incorporated into the due diligence and manager-monitoring processes undertaken by their investment consultants.
