Publications

The Investor Forum updates the Collective Engagement Framework

(London, 30th June 2025)

On 30th June 2025 the Investor Forum published the fourth update of the Collective Engagement Framework. The 2025 review again confirms that the Framework is “fit for purpose.”

One of the key challenges in fostering collective engagement by institutional investors has been a concern to prevent inadvertent violation of legal or regulatory requirements. This has been complicated by the increasingly global nature of share ownership and management, with the possibility of multiple jurisdictions being involved in cross-border investment decisions. This is a complex and ever-evolving topic.

At a time when collaborative initiatives around the world are being scrutinised, this Framework demonstrates the strong foundations on which the Forum’s engagement activity is built and provides evidence that all of the Forum’s activities are underpinned by a rigorous assessment of key global legal and regulatory risks, supported by robust internal processes designed to keep Members safe.

As part of this fourth review of the Framework, we undertook an in-depth analysis of certain rule amendments and guidance updates published by the U.S. Securities and Exchange Commission (“SEC”) as it relates to the Forum’s activities. These concern the Section 13 beneficial ownership reporting regime that may impact institutional investor engagement relating to both environmental, social and governance (ESG) and traditional corporate governance and executive compensation topics.  

This edition also updates the protocols used to cover the wide range of activities which the Forum now undertakes.

We believe that the Framework represents a critical part of the UK public market infrastructure and its worth has been proven repeatedly in our practical experience since 2015.  It has made an important contribution to the development of engagement practice and plays a crucial role in enabling effective collective engagement. The Framework is, and will remain, a living document which adapts and evolves over time with law, regulation and practical experience. 

We are enormously thankful to the panel of law firms who support us.

The Collective Engagement Framework is a unique asset for the Investor Forum and our Members. The full Framework is available to Members and a summary version is publicly available here.

Chris Kinder, CEO of the Investor Forum, said:

“This Framework is a critical component of the Investor Forum’s license to operate and is a major differentiator in the collective engagement ecosystem. The fact that we can once again confirm that we offer a safe and secure platform for our Members to fulfil their stewardship responsibilities and constructively engage with listed companies is incredibly encouraging in these challenging times.

On behalf of the Investor Forum team, I would like to express our huge gratitude to our outstanding Legal Panel.  Their unwavering dedication and deep expertise have been instrumental in shaping this important update, and we are immensely grateful for their continued support.”

Sacha Sadan, Director of Sustainable Finance at the FCA, said:

“Effective stewardship plays a vital role in supporting well-functioning markets. The Investor Forum’s updated Collective Engagement Framework sets out an approach to collaborative engagement which should benefit both investors and companies. Practical initiatives like this not only reinforce market integrity but also help protect the interests of beneficial owners.”


Richard Moriarty, CEO of the FRC said:

“The new Stewardship Code reinforces the need for investors to engage constructively with investee companies, and one method for achieving this is through collaboration with others. Frameworks such as the one developed by the Investor Forum can help investors collaborate constructively, either for insight or as a means of escalation.”

Contacts:                                        

Investor Forum

Chris Kinder, [email protected]

NOTES TO EDITORS:

  • The Investor Forum is an independent, not for profit organisation which was founded in October 2014. At June 2025, 51 organisations are Members, including asset managers, insurance companies, pension funds, and endowments.
  • The purpose of The Investor Forum is to position stewardship at the heart of investment decision making by facilitating dialogue, creating long-term solutions, and enhancing   value.  
  • Our Legal Panel currently comprises:
  • Will Pearce, Matthew Yeowart and Maxim Van de moortel of Davis Polk & Wardwell;
  • Michelle Kirschner of Gibson Dunn;
  • Craig Kelly and Patrick Tsitsaros of Skadden, Arps, Slate, Meagher & Flom.
  • Jonathan Baird retired as Chair of the Forum’s Legal Panel in December 2024; we are grateful for his wise counsel over the previous ten years and are delighted to be able to continue to benefit from this through his appointment as a Director onto our Board.  We are pleased to welcome Michelle Kirschner as the new Chair.
  • We would like to thank Susan Sternglass Noble, an independent consultant to the Investor Forum, for her excellent work in coordinating this update and helping to ensure that our processes and procedures continue to evolve.

For more information go to the following link: The Investor Forum