The PRI defines stewardship as: “The use of investor rights and influence to protect and enhance overall long-term value for clients and beneficiaries, including the common economic, social and environmental assets on which their interests depend.”
Effective stewardship benefits companies, investors and the economy as a whole. In publicly listed companies, responsibility for stewardship is shared. The primary responsibility rests with the board of the company, which oversees the actions of its management; but investors in the company also play an important role in holding the board to account for the fulfilment of its responsibilities.
In the UK, the UK Corporate Governance Code identifies the principles that underlie an effective board; while the UK Stewardship Code sets out the principles of effective stewardship by investors, both of which are the responsibility of the Financial Reporting Council (FRC). As well as voting, activities can include monitoring and engaging with companies on matters such as strategy, performance, risk, capital structure, and corporate governance, including culture and remuneration. Engagement is a purposeful dialogue with companies on these matters, as well as on issues that are the immediate subject of votes at general meetings. Broader stewardship activities can involve engagement with policymakers, asset managers, industry groups and other stakeholders.
In July 2010, the Financial Reporting Council (FRC) published the first version of the UK Stewardship Code (the ‘Code’), with subsequent editions in 2012 and 2020. The table below summarises the history of the Code and NILGOSC’s signatory status. More information about the history of the Code can be found on the FRC’s website.
| The Code | Date | Signatory requirements | NILGOSC’s Signatory Status |
|---|---|---|---|
| The UK Stewardship Code 2010 | July 2010 | Statement of Adherence | Signatory |
| UK Stewardship Code: September 20212 | September 2012 | Statement of Adherence | Signatory |
| Tiering of 2012 Stewardship Code Signatories | 2016 – 2019 (discontinuation of 2012 code) | Statement of Adherence (assessed) | Signatory – Tier 1 |
| The UK Stewardship Code 2020 | October 2019 | Annual report (assessed) | Signatory (September 2022 – February 2025) |
The FRC recently revised the Stewardship Code again, with the intention of ensuring that the principles continue to drive the right stewardship outcomes for investors, while not unduly contributing to reporting burdens. The UK Stewardship Code 2026 was published in June 2025, and applies from 1 January 2026 for reporting thereafter. More information about the Code is available at: www.frc.org.uk/investors/uk-stewardship-code.
NILGOSC supports the principles set out in the Code and seeks to promote these principles both directly and indirectly through the mandates given to its investment managers.
To be named as a signatory to the 2026 Code, organisations must prepare a Stewardship Code Submission comprising; Policy and Context Disclosures, which should be submitted every four years, and an annual Activities and Outcomes Report, demonstrating how they have applied the Code’s principles over the year.
To support its application to remain a signatory to the UK Stewardship Code 2026, NILGOSC prepared its Stewardship Code Submission 2025 (covering the 12 month-period ending 30 June 2025) and submitted it to the FRC in May 2026. The submission has not been assessed in 2026. Instead, the FRC is treating the first year of reporting against the UK Stewardship Code 2026 as a transition year, and all existing signatories who have submitted a renewal application will remain on the signatory list. NILGOSC was pleased to receive confirmation, in July 2026, that it will continue to be listed as a signatory to the UK Stewardship Code.
NILGOSC’s most recent Stewardship Report is available in the downloads box below.