The Institutional Shareholders’ Committee (ISC) published its Code on 16th November 2009, following extensive consultation with institutional investors. It represents part of the industry’s response to the weaknesses identified in the aftermath of the financial crisis. Its provisions cover asset owners, such as pension funds, and their agents, including advisers and investment managers. The Code has received broad support from Sir David Walker (labelled the “Stewardship Code”) and the Financial Reporting Council, both of whose governance reviews were published shortly afterwards. They have proposed that the  Code be brought under the supervision of the FRC.

This document sets out the ISC Code’s Principles, along with suggestions as to how funds should apply them. We have particularly focussed on those funds, whatever their size, which delegate investment management to a third party. The Principles apply equally to self-managed funds.

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