The Charity Investment Governance Principles (CIGP) have been published but what are they and how can you use them? Emma Abbott, CFG, reports from the CIGP launch event and answers your most common questions.
They’ve been 12 months in the making and involved hundreds of experts and organisations from across the charity sector. On 16 January 2025, an online event hosted by CFG drew in more than 200 people from across the charity and investment sectors to hear more about the newly launched Charity Investment Guidance Principles (CIGP).
CFG’s Head of Policy, Richard Sagar, began by thanking the organisations and experts who helped to develop the principles, including the hundreds of people who took part in the consultation and focus groups: “CFG is enormously proud to be hosting these principles, and we owe an enormous debt of gratitude to those who have given up their time to make them what they are.”
Richard went on to introduce the guest speakers – project lead and consultant Gail Cunningham; Elizabeth Jones from Farrer & Co; Luke Fletcher from Bates Wells; Mark O'Kelly, Finance Director at Barrow Cadbury Trust, and Sam Jackson, Assistant Director of Policy from the Charity Commission for England and Wales.
Gail presented a comprehensive overview of the background and development of the principles and explained how to make best use of them [see FAQs below]. Gail pointed out that the CIGPs will evolve over time and stressed the importance of user feedback. A future phase of the project will look to refine and clarify the principles, she said. “This is the first time something like this has been attempted, so we're keen to hear your feedback as you work through the principles.”
Vital observers and expert input
Sam Jackson, Assistant Director of Policy at the Charity Commission, gave a brief overview of the Commission’s role as an independent observer to the project and explained why the Commission supported the CIGPs. “As an independent observer, we [the commission] haven't been decision makers, but we've supported the steering group around the expression of the key legal principles and given advice.
“All trustees of charities with investments must follow CC14, but most people would acknowledge that navigating the practicalities of investment governance can be particularly complex. It is something that's challenging for trustees who may be new to those conversations and new to trusteeship. So, it follows that it's a topic where it's important to have complementary resources and initiatives.”
Elizabeth Jones, a partner at Farrer and Co specialising in charity law, echoed Sam’s remarks and noted that the 2022 Butler-Sloss case confirmed the latitude of trustees in adopting an investment policy suitable for their charity: “That presents a challenge to trustees to determine that right approach where trustees assess the extent to which investments, or classes of investment, have the potential to conflict with charitable purposes or are otherwise thought to pose reputational risk.”
She concluded: “This tool will help support the governance of charities in working through the structure that the law has set out, and making those complex decisions as to what, in the view of the charity trustees, is in the charity's best interests.”
Mark O’Kelly from Barrow Cadbury Trust shared useful advice for trustees still uncertain about their next steps: “Just make a start on them. Read them and know that you can dip in and out of them. Choose your priorities and start talking about them with other trustees. You don't have to come up with all the solutions at once.”
The final words go to Luke Fletcher, partner at Bates Wells, who pointed out that charity advisors will also find them “educational and informative, simple to read and understand”, adding: “I think advisors will be signposting the principles where relevant to clients, and encouraging clients to reflect on particular principles where those principles are relevant to issues advisors are seeing or problems clients are bringing to advisors.”
The webinar ended with a lively Q&A session - see below for FAQs inspired by the event.
1. What are the Charity Investment Governance Principles (CIGP)?
The Charity Investment Governance Principles (CIGP) are comprehensive guidelines designed to help charities strengthen governance in managing their investments.
They complement the Charity Commission’s CC14 guidance and the Charity Governance Code, providing a practical framework for trustees, staff, and committees.
The principles address key areas such as decision-making, risk management, and engagement with external advisors, to ensure effective investment governance.
The principles were shaped by extensive consultations, including surveys, focus groups, and diversity, equity and inclusion consultants, and feedback from more than 100 charitable organisations and the Steering Group. Participants ranged from fundraising charities to endowed foundations and universities.
Inspired by the Charity Governance Code, the CIGP aims to ensure alignment and usefulness, with examples and explainers built into the resource to support practical application.
2. What do the principles look like?
You can find the principles here: www.cigp.org.uk. You’ll notice that they are organised into seven distinct categories for ease of use.
Each individual principle has a description, a rationale and key outcomes which is followed by practice, and each is coded as either: ‘must’, ‘recommended’ or ‘consider’. This coding helps the users to understand which principles are legal and regulatory requirements and those that can be used to strengthen decision-making.
The principles also link through to the relevant guidance and legal documentation, for example the Charity Commission’s guidance for trustees on investing charity money, CC14.
The principles include sections that contain guidance on responsible, impact and social investment and investment policies. Helpful case studies and examples have been included too.
3. Can any size charity in the UK use these principles when managing their investments?
The principles are designed for charities of all sizes in England and Wales and are available in English and Welsh.
Smaller charities investing primarily in cash will find a simplified section tailored to their needs. Larger organisations will want to work through the full principles.
Charities are encouraged to approach the principles as a working tool to use as and when, rather than to read all at once. It’s also recommended that charities read the sections and principles, taking into consideration their own priorities, capacity and goals.
Although the principles have been developed for England and Wales (based on the legal and regulatory requirements) trustees and leaders of charities in Scotland and Northern Ireland may find useful application in them.
4. Aren’t most charities already doing what’s recommended and required?
Yes! We expect the principles to feel familiar to most because many charities will already be putting the principles into practice. That said, we expect there will be many key areas and principles that will still be able to guide thinking, discussions and decision-making.
5. Why were these principles developed then?
The principles were developed to address the many and varied challenges reported by charity trustees and staff. This became particularly evident following the Butler-Sloss legal case in 2022.
Sector experts and leaders recognised a need for a resource to support trustees without specific investment expertise. The aim was to make investment governance accessible, practical, and aligned with the unique challenges charities face.
6. Doesn’t the Charity Commission’s CC14 cover that?
The Charity Commission updated CC14 in 2023 to make it articulate the law and trustee duties around investment, including social investment, and to ensure consistency with the Butler- Sloss judgement. The update is more concise and comprehensive and was well received across the sector.
However, it was acknowledged that more work could be done to provide practical support to those charities making investment decisions. The Charity Commission was an observer to the development of the principles and noted that investment is “a topic where it's important to have complementary resources and initiatives.”
7. What’s next, and how can users contribute to their development?
The principles are a living resource intended to evolve. Charity users are encouraged to provide feedback via the dedicated feedback sections on the website and share examples or case studies to enrich future development.
Whether your charity has implemented innovative practices or encountered gaps, your input will help to refine and expand this vital tool for the benefit of all charity leaders.
Explore the principles today and help shape the future of charity investment governance by sharing your insights and feedback. Email questions or feedback to the Policy team at CFG and we'll get back to you.
The project has been possible thanks to:
- Charity Finance Group (CFG)
- Association of Charitable Foundations
- National Council for Voluntary Organisations
- Wales Council for Voluntary Action
- Secretariat of the Charities Responsible Investment Network
- Luke Fletcher, partner at Bates Wells,
- Elizabeth Jones, partner at Farrer & Co
- Kristina Kopic, Head of Charity and Voluntary Sector, ICAEW
- The Social Justice Collective
- The Social Investment Consultancy
- Charity Commission for England and Wales
- Barrow Cadbury Trust
- Friends Provident Foundation
- City Bridge Foundation
- Access – The Foundation for Social Investment
- The Climate Change Collaboration: The Aurora Trust, JJ Charitable Trust, Mark Leonard Trust
- Joseph Rowntree Foundation
- And many others