Investing in line with purpose and values

CCLA’s response to the Charity Commission’s consultation

In March 2019, a group of charities wrote to the Charity Commission seeking ‘urgent clarification’ on the extent to which their investments should align with their charitable objectives.

There is currently no regulation to say that charities should have a responsible investment policy; and there is a widely held view that the law needs to be updated. Current Charity Commission CC14 guidance is based on the Bishop of Oxford case in 1992. Richard Harries, the bishop, challenged the Church Commissioners over their investment policy.  The conclusion: ‘Most charities need money; and the more of it there is available the more trustees can seek to accomplish.’

Therefore, the purposes of the charity are usually best served by seeking a maximum return. This is the basis of the current guidance. Under CC14, trustees can decide to invest ethically, as long as one of the following reasons applies:

  1. A particular investment conflicts with the aims of the charity.
  2. The charity might lose supporters or beneficiaries if it does not invest ethically.
  3. There is no significant financial detriment.

The guidance is negative, vague and far from reassuring:

‘Trustees must ensure that any decision that they take about adopting an ethical investment approach can be justified within the criteria above. They must be clear about the reasons why certain companies or sectors are excluded or included. Trustees should also evaluate the effect of any proposed policy on potential investment returns and balance any
risk of lower returns against the risk of alienating support or damage to reputation. This cannot be an exact calculation but trustees will have to assess the risk to their charity.’

There are no examples of how, for instance, non-environmental charities can consider climate change in their investment policy. Although superficially unrelated, they are in fact intrinsically intertwined. Perceptions have changed. 

In summary, our stance can be seen as a progressive reading of the current guidance:

  • We believe it is no longer possible (or desirable) for charities to separate financial returns from their mission.
  • Investment markets, and the returns that they can deliver, are only as healthy as the people, communities and environment that supports them. How we respond to these issues will dictate how economies – and portfolios – perform.
  • Charities should have an obligation to incorporate environmental, social and governance (ESG) criteria into investment decision making and take steps to align financial assets with values and mission.

In practice, a simple performance comparison between CCLA’s two flagship multi-asset funds (the COIF Charities Investment Fund and the COIF Charities Ethical Investment Fund) should allay any fears that an increased emphasis on responsible investing will reduce returns. The broad ethical exclusionary policy applied to the Ethical Investment Fund has had no material impact on performance (see chart). In addition, we have large-scale engagement programmes in place to tackle some of the most pressing environmental and social problems that we face today. The debate continues. Some say that the Charity Commission should compel charities to invest sustainably. Others fear reputational risk and litigation that may come with a specific ruling. Once the Commission releases the new guidance, we will publish a comprehensive guide to responsible investing.

Investments and investment markets provide much needed funding for the charitable sector. At CCLA we manage approximately £10bn on behalf of over 35,000 not for profit organisations. The income delivered by these investments alone contributes approximately £217m to charities every year; this supports a substantial amount of good work.

Furthermore, over the past decade, charities and foundations have been at the forefront of exploring the different ways that investments can be used to deliver change. From Shareholder Activism to Programme Related or Mixed Motive investment we have seen countless examples of how social and environmental aims can be delivered through the creative use of financial resources. However, irrespective of how charities choose to invest their money, we agree that it is no longer possible, or desirable, for charities to separate the pursuit of investment returns from that of their mission. Instead, it is increasingly clear that investment markets, and the returns delivered by the businesses listed upon them, can only be as healthy as the communities and the environment that supports them. From climate change to the recovery from the COVID-19 public health crisis that has gripped the world as we write this submission, over the coming years and decades we face unprecedented social and environmental challenges. How we respond to these issues will dictate how global economies, and the investment portfolios that fund charitable activity, perform for years to come.

For this reason, we believe that as investors with unrivalled experience of delivering positive change charities have both a financial and missional obligation to incorporate environmental, social and governance (ESG) issues into investment decision making and to take steps to align their financial assets with their values and mission. To unleash the full transformative and creative power of the sector in this way, we believe that charity trustees will need a permissive regulatory framework that allows a variety of different approaches to investment. Therefore, we believe that trustees should face only two obligations when it comes to managing their charities’ financial assets:

  1. Trustees should have a duty to use their financial resources in a way that they believe will best help the charity achieve its purposes.
  2. They should report annually on how they have discharged this duty.

This would allow charities to use their assets, and reflect their charitable mission, in a wide variety of ways. This includes the prevalent ‘Invest and Fund’ model that permits charities to maximise their investment returns within an appropriate risk budget, to provide funding for their charitable operations.

As we expect ‘Invest and Fund’ will remain the predominant method adopted by trustees we believe that it would be beneficial for the Charity Commission to update their guidance to charities who use this approach. Specifically, we would encourage the Commission to:


Clearly state that investment managers who act on behalf of charities must:

  • Integrate ESG factors into their investment analysis and decisionmaking processes, in a way that is consistent with the charity’s real investment time horizon
  • Encourage high standards of ESG performance in the companies that they invest in through voting and engagement
  • Report on how they have implemented these commitments. As this relates to maximising investment performance, rather than aligning investments with the charity’s values, such a position would be in line with emerging best practice as adopted by other sectors (such as the Pensions Regulator), the findings of the UN Environment Programme Finance Initiative and Principles for Responsible Investment supported Fiduciary Duty in the 21st Century Project, and several leading charitable investors.


Clarify that trustees of charities that have adopted the ‘Invest and Fund’ model have the ability to avoid investing in companies and sectors that they believe are detrimental to their charities’ purpose. This is in line with the 2015 Opinion produced by Christopher McCall QC.


Encourage charities that use ‘Invest and Fund’ to take other steps to align their portfolio with their mission. As per the current CC14 guidance this can include instructing their investment manager to conduct shareholder activism, on issues that matter to the charity, with companies in their portfolio. Whilst a progressive reading of the existing CC14  guidance provides the ability for charities to invest in this manner, we believe that trustees would benefit from revised guidance providing them with the reassurance that they can be creative in how they use their resources to achieve their purpose.

20 August 2020


Terms and conditions

Website terms of use policy

CCLA Website Terms of Use

Welcome to CCLA's website for:

  • fund management services for  CCLA Funds (details of and documentation relating to all CCLA Funds is available on CCLA’s website); and
  • discretionary investment management services for individual client portfolios.

This page provides you with information about CCLA and the legal terms and conditions (Terms of Use or Terms) on which you can access and use this website.

By using or accessing any part of this website, you confirm that you accept these Terms of Use and that you agree to comply with them.  Please read these Terms of Use carefully and make sure that you understand them before using this website. If you do not wish to be bound by these Terms you must not use or access this website.

Where necessary, we may amend these Terms of Use from time to time by updating this page.  We therefore recommend that you check this page periodically to ensure that you understand the Terms which will apply from time to time.

1. About us (CCLA)

1.1 Any reference to CCLA or we/us on this website (including these Terms of Use) means CCLA Investment Management Limited and/or CCLA Fund Managers Limited (as applicable).

1.2 CCLA Investment Management Limited (CCLA IM) is a company registered in England and Wales with company number 2183088. It is authorised and regulated by the Financial Conduct Authority under the Financial Services and Markets Act 2000 (FSMA), and is entered on the Financial Services Register under registration number 119281.

1.3 CCLA Fund Managers Limited (CCLA FM) is a company registered in England and Wales with company number 8735639.It is authorised and regulated by the Financial Conduct Authority under FSMA and is entered on the Financial Services Register under registration number 611707.

1.4  The registered office of CCLA IM and CCLA FM is Senator House, 85 Queen Victoria Street, London, EC4V 4ET.You may also contact CCLA by emailing

2. Who may use this website

2.1 The information on this website is intended for investors and prospective investors in the CCLA Funds and or clients or prospective clients of CCLA's services. Only certain types of investor are eligible to invest in the CCLA Funds (in summary these are charities and local authorities and certain of the CCLA Funds are restricted to particular types of these investors).

  • Charities for these purposes are charities or charitable organisations registered with the Charity Commission of England and Wales, or charities exempt from registration, or other persons eligible to participate in collective investment schemes constituted under the Church Funds Investment Measure 1958, section 24 of the Charities Act 1993 (now amended to section 96 of the Charities Act 2011), or section 25 of the Charities Act 1993 (now amended to 100 of the Charities Act 2011), or equivalent organisations in Scotland or Northern Ireland.
  • Local authorities for these purposes are local authorities as defined in section 23 of the Local Government Act 2003.

2.2 Please ensure that you understand whether or not you are an eligible investor in respect of the CCLA Funds, investments and investment services referred to on this website.

3. The purpose of this website

3.1 This website is for information purposes only and is intended as a general introduction to CCLA and the Funds it manages and/or provides investment management services to. The website content and any products and/or services described within it are subject to change without notice.

3.2 Nothing contained on this website constitutes the provision of investment, tax, legal or other advice. This website should not be regarded as constituting a distribution or an offer or solicitation to sell shares or units in any of the funds managed by CCLA outside the UK. Any opinions expressed on individual funds, services or products represent our views at the time of preparation and should not be interpreted as a personal recommendation to buy or sell any of the investments that may be referred to.

3.3 In using this website you may navigate between different pages which relate to different Funds. Each webpage will clearly identify the Fund to which it relates and bespoke information presented on each webpage will relate to the identified Fund.

4. Risk warning

4.1 The value of the CCLA Funds’ units and/or shares and the income from them can fall as well as rise and an investor may not get back the amount originally invested. Past performance is no guarantee of future returns.

4.2 Please refer to the Funds’ individual scheme particulars or prospectus for an overview of the investment risks identified by CCLA and the applicable terms and conditions for investing in the Funds, including rules concerning when sums invested may be realised by the investor. Any estimates of future capital or income returns or details of past performance on this website are for information purposes and are not to be relied on as a guide to future performance.

4.3 Persons who do not have professional experience in matters relating to investments are strongly encouraged to consult with a financial adviser before making any investment decision.

5. Complaints and compensation

8.1  All complaints will be handled in accordance with CCLA’s Complaints Policy  which can be found at

 If either CCLA IM or CCLA FM cannot meet its obligations (for example, where it has stopped trading and there are insufficient assets to meet its obligations), investors may be eligible to claim compensation up to a maximum of £85,000 from the Financial Services Compensation Scheme. There are limits on who is eligible to claim and which funds are covered. For further information about the Financial Services Compensation Scheme please refer to or phone 0800 678 1100.

6. CCLA's liability

6.1 We give no warranty or representation and accept no liability for the accuracy, completeness or appropriateness of the information and material available on this website. Your use of any information or materials is entirely at your own risk and we accept no liability for any damage or loss including loss of profit whether direct, indirect or consequential in respect of the use of this website or its content; however, we do not exclude or restrict any liability that we may have under FSMA.

6.2 Due to the nature of the Internet, errors, interruptions and delays may occur at any time. Accordingly, this website is provided on an "AS IS" and "AS AVAILABLE" basis without any warranties of any kind. We shall have no liability, contingent or otherwise, or any responsibility whatsoever, for any interruption in availability of this website regardless of whether the connection or communication service is provided by CCLA or a third party service provider.

6.3 Transmission of information via the Internet is not completely secure and we cannot guarantee the security of your data transmitted to this website. Any transmission is at your own risk. We will use strict procedures and security features to try to prevent unauthorised access and we will do our best to protect your information (including personal data). However, we accept no liability in the unlikely event of a breach of our secure computer servers.

6.4 We will use reasonable endeavours to ensure that this website does not contain or promulgate any viruses or other malicious code. However, it is recommended that you should virus check all materials downloaded from this website. We will not be liable for any viruses, code, files or programs designed to interrupt, restrict, destroy or otherwise compromise the integrity of the website or any hardware on which it is hosted. We exclude to the fullest extent permitted by applicable laws all liability in connection with any damage or loss caused by computer viruses or other malicious code originating or contracted from this website.

7. Third party websites

7.1 This website may provide links to certain websites sponsored and maintained by third parties. CCLA is not responsible for the accuracy of information contained within websites provided by third parties and makes no representations concerning the content of such third party websites. The fact that CCLA may provide a link to another website does not constitute an endorsement, authorisation, sponsorship, or affiliation by CCLA with respect to that website, its owners, or its providers. You will be responsible for complying with the terms and conditions of use for any linked website.

8. Copyright and trade marks

8.1 CCLA is the owner or the licensee of all intellectual property rights in this website, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

8.2 You must not use any part of the materials on this website for commercial purposes without obtaining a licence to do so from us or our licensors.

8.3 No use of CCLA's name, logos and/or other trademarks (whether registered or unregistered) may be made by you without separate express written agreement being given by us, which shall be at our sole discretion.

9. Data protection

9.1 We will hold any personal information that you may provide to us through our CCLA website in confidence and in accordance with CCLA’s Privacy Notice and current Data Protection Legislation. CCLA is the data controller of any such information for these purposes.

9.2 You agree that the CCLA may process your personal data to: (i) confirm your identity and carry out background checks (which may involve sharing your personal data with third parties such as credit reference agencies); (ii) provide our services to you; (iii) follow up with you after you request information; (iv) comply with any requirement of any applicable statute, regulation, Financial Conduct Authority Rule and good practice and to fulfil our obligations under any reporting agreement entered into with any tax authority or revenue service(s); (v) prevent and detect abuse of our services or any of our rights and to protect our (and others’) property and rights; (vi) contact you by post, e-mail or telephone to bring to your attention additional products or services which may be of interest to you (you may inform CCLA at any time if you do not want to receive such communications); and (vii) as otherwise agreed by you. Failure to provide the personal data requested (or to agree to the above or below uses) may mean that CCLA is unable to provide the services requested.

9.3 CCLA may pass your personal data to any other firm within CCLA but will not pass on any personal data to any other third party except: (i) where, in relation to the performance of its services to you, CCLA sub-contracts part of the services or any support services; (ii) as agreed by you; or (iii) where required to do so for regulatory purposes as set out above.

9.4 CCLA may in exceptional circumstances transmit and process your personal data outside of the UK  in countries that do not provide the same level of data protection as the UK. In such unusual circumstances, you agree that it may do so subject to CCLA endeavouring to ensure that the arrangements comply with the standards required by the UK Information Commissioner.

9.5 Your use of this website (and your interest in particular webpages or particular CCLA products or services) may be monitored by CCLA. CCLA may keep records of all business transactions for at least five years.

9.6 By accepting these Terms of Use, you agree to the processing and disclosure of personal information as above. You are entitled to request details of information we may hold about you and to require us to correct any inaccuracies in your personal data. CCLA will treat all clients' records as confidential and so reserve the right to provide copies of your particular record, rather than allow access to files which may contain information about other clients. If you wish to access copies of your personal data or ask about the above arrangements, please contact CCLA's Data Protection Adviser at CCLA Investment Management Limited, Senator House, 85 Queen Victoria Street, London, EC4V 4ET.

9.7 Full details of CCLA’s Privacy Notice is available on CCLA’s website. Full details of CCLA’s Data Protection Policy, are available on request.

10. Cookies

10.1 This website uses cookies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse the website and also allows us to improve the website.

10.2 When you confirm you have read this page we will place a cookie on your computer to recognise you and prevent this page reappearing should you access this website on future occasions. The cookie will expire after six months, or sooner should there be a change to this important information.

10.3 You can activate the setting on your Internet browser to refuse the setting of all or some cookies. However, if you use your Internet browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the website. To help us provide a more personalised viewing experience we recommend that you view this website with a JavaScript enabled browser.

10.4 For more information about cookies, including how to set your Internet browser to reject cookies, please visit

11. Recording of communications

 Your telephone calls and electronic communications with CCLA may be recorded. You agree that CCLA may deliver copies or transcripts of such recording to any court or competent regulatory authority.  Such records of conversation and/or communications with you will be available on request for a period of five years (or, where requested by the FCA, for a period of up to seven years) from the date when a record is made.

12. General

12.1 Each of the paragraphs of these Terms of Use operates separately. If any court or relevant authority decides that any of them are unlawful or unenforceable, the remaining paragraphs will remain in full force and effect.

12.2 If we fail to insist that you perform any of your obligations under these Terms of Use, or if we do not enforce our rights against you, or if we delay in doing so, that will not mean that we have waived our rights against you and will not mean that you do not have to comply with those obligations.

12.3 These Terms of Use are governed by English law and are available only in English. You and we both agree that the courts of England and Wales will have non-exclusive jurisdiction over any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with these Terms of Use.

18 August 2021             




Public sector funds

Public sector funds

The Local Authorities Property Fund (“LAPF” or “the fund”) is an unregulated collective investment scheme. As such, only persons who have been assessed as elective professional clients by CCLA in respect of the fund (or are already investors in the fund) are able to access details of the fund on this website.

If you have not been assessed as an elective professional client by CCLA or are not an existing investor in the fund, please contact us to discuss this fund:

Client Services

0800 022 3505

I confirm that I am a local authority/public sector body as defined in section 23 of the Local Government Act 2003. I also confirm that I have been assessed as an elective professional client by CCLA and/or I am an existing investor in the LAPF.