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We represent our members and seek to influence policy makers to act in the best interests of charity investors.  In the past we have worked with other third sector representative bodies to publish best practice guidance.

Drafting a Charity Investment Policy Statement

The attached document, is a useful guide to helping draft your charity's Investment Policy Statement and can be used to help frame trustees views on their charity investments in conjunction with the Charity Commission guidance on investment, CC14


In January 2020 the Charity Commission launched a consultation to hear from charity trustees, charity investment managers, employees or anyone with an interest in responsible investment to share their thoughts.


The Commission wanted to hear of experiences and current considerations around responsible investments.


Specific issues of focus included, any barriers to more widespread responsible investments and what more could be done to support trustees to invest in a way that reflects the charity’s purpose and values.


The Charity Investors Group submitted a response on 31 March 2020, which can be read here


29th March 2017


You will hopefully be aware of the Common Reporting Standard, which affects investment managers, but also charities who classify as an ‘investment entity’.   I am asking investment manager members to please highlight this new regulation to your charity clients in case they are unaware of their new obligations.

Which charities are affected?

Charities that are affected are those that get more than 50% of their income from investments over the preceding three years and whose investments are managed on a discretionary basis – where trustees have outsourced the decision making.  Please note, a single holding in a unit trust/CIF does not constitute discretionary management if the trustees have made the decision to invest.   

What are their due diligence and reporting obligations?

Investment entities have due diligence and reporting obligations. They must identify their ‘account holders’, carry out due diligence on these account holders and fulfil their reporting obligations to HMRC.  There is no requirement to file ‘nil returns’.

For charitable trusts or unincorporated charities these account holders include all grantees and settlors. Due diligence requires tax residence data to be collected on all grantees and settlors, and to report any who are tax resident in a reportable jurisdiction to HMRC.

Incorporated charities (including those established by Royal Charter or Acts of Parliament) are likely to be less affected, although still have to report any equity or debt interest holders resident in a reportable jurisdiction. Please note incorporated charities may still hold assets in trust (e.g. permanent endowment) and may therefore have additional reporting obligations.

Reporting for 2016 should be submitted to HMRC online by the end of May 2017.


Further resources

Richard Jenkins, Head of Policy at ACF and a CIG committee member, has prepared some useful material available on the ACF website – including a flow chart to help identify how an individual charity is likely to be affected.

Further guidance can be found on the HMRC website

Any queries do get in touch, and of course I am happy for you to use the above text for your own communications if useful.


Kind regards

Kate Rogers

Chair, Charity Investors Group

12th October 2016


It gives me great pleasure to announce the launch of the new Charity Authorised Investment Fund structure.  As you will know this has been a work in progress for a number of years and I’m delighted to have finally got it ‘over the line’.  Many thanks must go to Julian Smith and Grania Baird of the Charity Law Association and Peter Capper of the Investment Association who have worked tirelessly to bring this to fruition.


You will find a model trust deed and a basic guide on the Investment Association’s website here

The members letter can be accessed here.

We will be organising an eveng in November to discuss the new structure.  In the meantime, do get in touch with any questions

Kate Rogers, Chair, Charity Investors Group



Charity Finance Group and Charity Investors' Group have launched a support guide to help charities in writing their investment policy, 'Writing your charity's investment policy - a guide'. 


This guide includes a model template covering all the core aspects that should be included in a charity's investment policy and a range of good practice examples. We are also pleased that the Charity Commission will direct trustees to this guide from their online guidance ‘Charities and investment matters’.


Download the guide here


We responded to the Charity Commission consultation on the future of common investment fund regulation in 2013.

See our response here 

CC14 Update 2012

We hosted meetings with the Charity Commission to allow members to express their views on the new guidance at the draft stage.  We subsequently worked with the Charity Commission on the final draft.


We responded to the Treasury consultation on Charity Pooled Funds in 2009.

See our response here

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