ACT FAQS

What sort of firm signs up to the ACT Framework, Asset managers or Fund Investors?

The Framework can be used by different types of investment companies. Asset managers complete the ACT Framework via the Door Platform, which they can then share with professional fund investors. Those on the client side can make requests for disclosure from their managers via Door to share their completed ACT reporting, or start the process. The Door platform allows consistent and comparable information collection over time, which is helping to drive wider adoption across the industry.

Wealth managers can also complete ACT reporting and may be particularly interested to share an Executive Summary version of the Framework with public stakeholders.

Can ACT help create a more diverse and inclusive culture?

Yes. ACT was designed for and with investment companies. The Framework supports firms to provide a structured narrative with the context that clients need to understand the business. At the same time, the reporting entity gets a gap analysis from the disclosure process that can be shared internally across senior leadership and teams, and with the Board.

This approach enables both the reporting firms and their clients to pinpoint good performance, where to improve and how to create the challenge to do so. It then provides a way for internal stakeholders to understand the firm’s values and culture, objectives for change and the direction of travel.

This process and the Guidance that we provide, which explains why each question is being asked and the type of activity that can be reported, can help firms to move towards a more inclusive culture.

What are the benefits of being a Signatory?

Signatory firms can publicly share their status by using the ACT Mark on factsheets, their brochures, website, email signatures and other materials. It is a symbol of trust that signals to clients and stakeholders the firm has committed to an independent, third-party disclosure process. The firm also gets the gap analysis and benefits from reporting, which will help with internal monitoring. Crucially, the disclosure helps with client communication, by normalising a subjective topic that is of increasing importance, and by building trust in client relationships on how firm culture contributes to and reinforces the firm approach to investment and client delivery.

Is this a rating?

The ACT Framework is designed to enable the firm to create a true picture of its actions and progress. The type of activity and speed of progress will differ from firm to firm. As such, this is not a rating. However, the Signatory ACT Mark can be used on factsheets and on data platforms to signal a firm’s commitment to transparency and accountability.

Is this global?

The ACT Framework is designed to be global and is agnostic on approach, recognising that cultural norms can vary across territories and that regulatory and legal requirements vary across jurisdictions. Door is a global utility and can be accessed in any country for both asset managers and professional fund investors, no matter the size.

How does an asset manager demonstrate successful completion of the ACT Framework?

Asset managers report via the Door Platform as an entire module that is designed to be completed in full to give visibility to a firm’s approach and outcomes. On completion, Asset Managers can obtain a obtain a licence from City Hive to demonstrate they have completed the ACT reporting framework and can display the ACT Mark on factsheets, websites, email footers or other materials.

License fees vary according to global AUM (US$) to be inclusive and fair. The fee goes towards expenses related to establishing, maintaining, and developing the ACT standard.

What is DOOR?

Door is a digital platform that streamlines the exchange of due diligence information in the investment management industry. Combining the benefits of digital and standardization, Door replaces the archaic due diligence questionnaire process. In collaboration with industry practitioners, the platform provides best practice defined question sets comprised of the most commonly asked questions.

Door allows asset managers to respond to information requests leveraging on existing content, proactively invite and push updates to their fund investor clients, and keep track of who has access. Fund investors on Door can easily access, compare and monitor information change over time, by receiving real-time alerts as asset managers make updates to their content.

How long does it take to report?

The process of finding the right internal advocates and collecting information can take time. However, using the Door platform means firms can report once and share widely.

It is expected that the full cycle may take some months for completion and sign off, and some months for the review to identify gaps, ways to progress and success stories to build upon. Once completed, firms can expect to make an annual review - although many firms choose to update sections more frequently as they understand the type of information that might be useful to share with clients.

We understand that the questions and the overall Framework relate to structural, multi-year projects and objectives, and so some data will not necessarily change in the short-to-medium term. Contextual signalling data such as implementation of policy, practice or other milestones indicating direction of travel, are all useful to include.

Who can access the information?

Any professional fund investor firm conducting manager research can request access to asset managers’ content via the Door platform. City Hive will also be able to request access to asset managers’ content in order to verify reporting is complete for Signatory firms.

How is this different from other diversity initiatives?

The ACT Framework provides a way for firms to capture their approach to culture and inclusion in a digestible way for clients and stakeholders that will support better decision making, risk and relationship management. It goes further than being a commitment or a disclosure framework, in helping firms to understand how to progress towards a more inclusive culture. Firms are also contributing to an emerging industry data set that can be used to signal trends and behaviours to relevant stakeholders, including regulators that are showing interest in these topics.

The Framework is also designed to be useful for multiple stakeholders, creating a common language for more efficient communication and understanding of a subjective topic.

Why use Door to access City Hive’s ACT Framework?

City Hive have exclusively partnered with Door to deliver the ACT Standard. Door allows asset managers to complete the framework digitally in order to ensure transparency, signalling to their clients their support in fostering corporate culture change.

Through Door’s technology, asset managers can keep the information up to date going forward and use the same content to respond to multiple clients. Report once, share widely.

Fund investors can access their managers’ responses to the ACT Framework in one standardized place, be notified of changes, compare content between managers, and be well versed of how asset managers are incorporating changes and supporting the wider industry movement for diversity and inclusion.

How do asset managers provide information on Door?

Once registered, asset managers populate firm and product level information through online questionnaire forms. Participating asset managers also have access to response management tools that allow for easy reuse of information across products, an audit trail of previous responses and changes to responses, and the ability to share information with fund investor clients via the invite capability. Door even provides integration capabilities for leading content management systems for asset managers, allowing them to pull through updates from their content libraries directly to Door.

How does the Door platform work?

Door preserves the established protocol of the due diligence information exchange – fund investors issue requests to asset managers for due diligence information, and asset managers provide responses on the Door platform and then grant access to the fund investors to view those responses. Responses are stored and can be used for multiple clients, including ability for asset managers to invite their clients to view their content, creating further efficiencies. In this way, Door is permissions based and asset managers can feel comfortable providing detailed information to known, named, professional fund investors. What Door eliminates is the friction of producing and exchanging documents, whilst cutting down on repetitive questionnaires through Door’s standard question sets, allowing for quicker responses and turnaround times.

The City Hive ACT Framework is accessible through the Door platform by completing the DEI Question Set. Asset managers can complete the DEI questions on Door and invite their clients to see it. Fund investors can also request access to the DEI information and have ongoing access, receiving alerts as their managers make updates. When you sign up to ACT, the Door team will provide training on how to use the platform.