Collective Engagement Framework 2025

For members only

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, and no one simple set of rules or procedures can guarantee full compliance.

The Forum’s approach has been to seek guidance from a panel of law firms which has worked with the Executive to establish a coherent framework for the management of Engagements, which we refer to as the “Collective Engagement Framework”. This has included putting in place a legal, operating and governance structure which helps to meet the Forum’s objectives whilst minimising risk to participants; framing the key legal and regulatory risks; and flagging key points or circumstances during Engagements and non-Engagement activities which might require heightened attention.

The 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 legal and regulatory risks (Investor Forum Collective Engagement: 10 Key Features).

The procedures have been drawn up to take into account key legal and regulatory concerns:

• Inside and Confidential Information / the Market Abuse Regime;
• Concert party formation under the Takeover Code;
• US regulatory considerations such as group filing requirements under SEC rules and the US Federal Reserve Bank Holding Company Act; and
• Competition law.

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 Forum’s procedures are regularly reviewed in light of practical experience as well as any changes to law and regulation, if applicable.

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.

Do get in touch if you have any questions or would like to learn more.