Refreshed charity investment guidance (CC14): what next?
6 September 2023

Gemma Cartwright, head of investment practice and partnership at ACF, reflects on the recent publication of investment guidance and considers next steps for foundations. 

Last month, the Charity Commission for England and Wales published its long-awaited refreshed guidance on charity investments (CC14). It comes at a time of acute social, economic and environmental challenge for our members, whilst balancing the impact of their investments. 

As the membership body for UK foundations and independent grant-makers, with over 440 members holding assets of over £55bn, ACF was invited to feed into the refresh of the guidance. We welcomed the publication of the refreshed guidance in a statement on our website.

Why was the guidance refreshed?
A High Court judgement on charity trustees’ investment duties (the ‘Butler-Sloss’ case) last year made the need to provide trustees with confidence when making investment decisions even more acute. 

This followed the Charity Commission’s consultation and listening exercises to refresh the guidance that began in 2020. 


What is new in the guidance?
Helen Stephenson, chief executive of the Charity Commission said, “we want to stress that investment approaches are trustees’ decision to make, and this guidance is designed to help you do so with confidence, and in line with the law.”

The key changes in the refreshed guidance are: 

  • Simplification of terminology and clearer explanation through examples 
  • Merging of previously separate social investment guidance into CC14
  • Clarity on trustee responsibilities on investment – they must act in the best interests of their charity
  • More detail on setting investment policy
  • The importance of taking professional advice, how to gain it and manage conflict. 

Charity Finance Group said, the “updated guidance is shorter and more accessible, but by no means less comprehensive. It more clearly details both trustees’ legal duties and recommended best practice. This will give trustees greater confidence when deciding what is or isn’t in the best interests of their charity.” 

NCVO said “Investments can be an important source of funding for charities, so they maximise money to spend on work which will further their missions. Therefore, the Charity Commission’s updated guidance is really useful for trustees, as it makes it clear they have a significant amount of discretion in how they make decisions when it comes to investments.”

We acknowledge guidance can always do more – whilst appreciating the levels of work to update guidance, it must evolve alongside the world of investment and wider social and environmental responsibility. 

What can foundations do next? 

  • Review the guidance and consider what it means for their foundation - we recommend that senior staff and trustees of trusts and foundations review the refreshed guidance and consider what it means for their responsibilities.

  • Watch this space for the development of charity governance investment principles - ACF intends to partner with NCVO, Charity Finance Group, the Charities Responsible Investment Network and the Institute of Chartered Accountants for England and Wales in the development of charity governance investment principles that will complement CC14 guidance, building on the CC14 examples and referencing ACF’s Stronger Foundations initiative.

  • Attend our upcoming event on the CC14 guidance - To hear directly from the Charity Commission, members can sign up for our event on Wednesday 20 September, 2-3pm online. There will be an opportunity to hear more about what the guidance means for trust and foundation trustees and to pose questions to the Charity Commission.

  • Attend our upcoming investment seminars - ACF will host its next investment seminars on 27 and 28 November in collaboration with our Official Partners, where trustees and senior staff new to the foundation world are empowered to hold discussions about their foundation’s investments, how to develop an investment policy and deliver good practice.

  • Join an event hosted by some of our Official Partners - Mercer and Cazenove

  • Become involved with our Social Impact Investors Group (SIIG) – Our event with the Charity Commission will be facilitated by the co-chairs of the Social Impact Investors Group (SIIG) hosted by ACF, supporting foundations exploring or already carrying out social impact investing. To get involved with SIIG, please email Gemma on [email protected].

Investment seminars

27 and 28 November, central London

Book your place