White Paper · 2026

Stewardship
Under Scrutiny

How stewardship has evolved across the asset management industry and what it means for every link in the capital chain.

40
Firms
covered
126
Reports analysed
2020–2025
5
Themes
explored
Foreword

From Disclosure to Fiduciary Infrastructure

Stewardship has become one of the most visible expressions of responsible investment, yet one of the most unevenly evidenced. Climate change, biodiversity loss, labour standards, and governance failures are now recognised as systemic risks that shape portfolio outcomes across entire markets and time horizons. They cannot be diversified away, nor addressed through disclosure alone.

This paper draws on 126 stewardship reports across 40 firms published between 2020 and 2025. The pattern it reveals is consistent: a small group invested seriously in people, systems, and governance. Much of the market has not.

When we started building Maanch, the problem was hiding in plain sight. Stewardship reports existed, but the intelligence inside them was trapped, unstructured, incomparable, inaccessible. Asset owners couldn't track how their managers were stewarding on their behalf. Consultants spent hundreds of hours reading reports to answer questions that structured data could answer in minutes. Managers reported on stewardship retrospectively, rather than proactively. In ongoing consultation with the industry, Maanch continues to build and evolve the measurement infrastructure that makes stewardship quantifiable across the entire investment chain.

Stewardship must now be treated as fiduciary infrastructure: designed to support oversight, evidence, and defensibility, rather than as a collection of activities or a reporting obligation.

DG
Darshita Gillies
Founder & CEO, Maanch
Important Notice

This paper draws on publicly available UK Stewardship Code reports, analysed using AI-assisted interpretation. It reflects what firms have reported in their own published reports, which have not been independently verified. Maanch Limited, the authors and contributors, make no representation as to the completeness or accuracy of third-party disclosures.

Charts, tiers, and capability descriptions are illustrative. They do not constitute ratings, rankings, or formal assessments of stewardship quality or performance, and should not be relied upon as such.

Nothing in this paper constitutes ESG ratings, investment, legal, or other professional advice. Nothing should be construed as a recommendation to buy, sell, or hold any security, or to appoint, retain, or terminate any asset manager. Independent professional advice should be sought before making investment, procurement, or governance decisions.

Authors & Contributors
DG
Darshita Gillies
Foreword · Founder & CEO, Maanch

Darshita founded Maanch to bridge the gap between stewardship data and stewardship action. She works with asset owners, managers, and consultants across the UK and international stewardship landscape.

LinkedIn →
SS
Susie Steyn
Author

Susie brings deep expertise in stewardship policy, institutional investment, and responsible finance. She led the research and drafting of this paper, drawing on five years of published stewardship reports.

LinkedIn →
JH
Junming He
Analyst

Junming led the AI-assisted extraction and structuring of 126 stewardship reports, building the analytical dataset that underpins this paper’s findings.

LinkedIn →
OW
Oliver Wright
Contributor

Oliver contributed research and editorial input across the themes of governance, voting, and client communication, drawing on his background in institutional investment and stewardship practice.

LinkedIn →
Contents

Table of Contents

Executive Summary
AThe Stakes Have Changed
A1Why stewardship is now a board-level governance question
A2From ESG factors to systemic risk: the reframe that changes everything
A3The 2026 Stewardship Code: what the updated requirements mean in practice
BFrom Activity to Outcomes
B1Multi-year campaigns: sustained engagement over episodic contact
B2Outcome measurement: the gap between claiming and evidencing
B3Net zero: from commitments to accountability
CVoting and Escalation as Strategy
C1Voting: from administrative exercise to deliberate signal
C2Collaboration: from individual action to collective leverage
C3Escalation: from dialogue to multi-tool approach
DPeople, Governance and Integrity
D1Team professionalisation: the infrastructure behind the report
D2Governance architecture: from ad hoc to systematic
D3Conflicts of interest: from policies to independent oversight
EData, Clients and the New Frontier
E1Technology and data: the limits of what is visible
E2Client communication and proxy choice
E3Fixed income stewardship: the new frontier
Landscape overview, capability framework, trustee questions, conclusion, and about Maanch
Executive Summary

The Five-Year Transformation in Brief

Between 2020 and 2025, stewardship practice underwent a clear and measurable evolution. ESG integration began to give way to systemic risk management. Climate-only approaches expanded to include biodiversity and social factors. Annual, reactive engagement was increasingly replaced by multi-year thematic campaigns. Voting shifted from a compliance exercise toward a deliberate escalation tool.

40
firms covered, spanning 126 reports from 2020 to 2025
The gap between stewardship leaders and laggards has widened materially in capability terms
2026
Updated UK Stewardship Code takes effect, with a clear focus on outcomes, not just activities

However, this evolution has been uneven. A small group of organisations invested significantly in people, systems, and governance, developing outcome-focused approaches capable of withstanding scrutiny. Much of the market remains reliant on fragmented reporting, third-party data, and retrospective narratives.

The research shows a widening gap between stewardship that is procedurally compliant and stewardship that is substantively effective. Asset owners who continue to rely on legacy models face increasing difficulty defending their approach.

The table below maps where the industry started in 2020–21 and where leaders now operate across each of the five themes this paper explores.

Theme 2020–2021
Starting point
2024–2025
Where leaders operate now
A · Stakes & Scope ESG factors, compliance framing, limited board involvement Stewardship as board-level fiduciary governance with independent oversight
B · Activity → Outcomes Annual engagement letters; activity counts; no outcome tracking Documented outcome chains; investment decisions linked to engagement evidence
C · Voting & Escalation Blanket voting policies; compliance-driven; no escalation logic Voting as strategic signal; documented escalation paths; public rationale disclosure
D · People & Governance Small ESG generalist teams; informal conflicts management Specialist teams; independent conflicts oversight; stewardship embedded in investment process
E · Data & Clients Equity-only scope; third-party data dependency; passive client reporting Multi-asset stewardship; proxy voting choice; climate-nature integration; real-time client reporting

How to read this paper: Each of the five themes (A–E) maps to a row in this table. The analysis in each section draws directly on the 126 stewardship reports in the dataset, showing where the evidence confirms this evolution, where it stalls, and where the gap between stated intent and actual practice is widest.

A
Theme A
The Stakes Have Changed
Stewardship has moved from operational reporting to board-level fiduciary governance. The reframe changes who is accountable, for what, and how.
A1

Why Stewardship Has Become a Board-Level Issue

Stewardship has shifted from an operational function to a matter of board oversight. While execution remains delegated, accountability sits with asset owners. Governance structures between 2020 and 2025 evolved accordingly, drawing boards and trustees directly into stewardship oversight.

In the early 2020s, stewardship oversight was often confined to ESG or responsible investment teams, with limited board involvement. Between 2022 and 2024, this changed materially. State Street established an ESG Committee with responsibility for stewardship philosophy, voting, and engagement oversight. LGIM formalised board-level oversight through investment stewardship committees, often chaired by independent non-executive directors.

Under the UK Stewardship Code 2020, oversight is explicit. Boards are no longer expected merely to approve policies, but to understand how stewardship decisions are made and escalated.

A2

From ESG Factors to Systemic Risk: The Reframe That Changes Everything

Between 2020 and 2025, stewardship moved from being framed primarily as an extension of ESG integration toward being understood as a mechanism for managing systemic risk. This shift is visible in how investment beliefs and stewardship objectives were reformulated, particularly among more advanced asset owners.

2020–21
ESG as
Risk Factor
2021–22
Climate
Compliance
2022–23
Systemic
Risk Lens
2024+
Fiduciary
Infrastructure

Aviva UK Life's 2021 stewardship reporting positioned climate risk in relation to the UK Prudential Regulation Authority's SS3/19 requirements, a compliance orientation. By 2023, Railpen had reformulated its investment beliefs to recognise that a long investment horizon exposes a pension scheme to societal and systemic risks such as climate change. This reframing moved ESG issues into the core of fiduciary thinking.

Key implication: Systemic risks cannot be diversified away, delegated entirely, or addressed through disclosure alone. They accumulate across portfolios and time horizons, directly affecting beneficiaries with long-dated liabilities.

A3

The 2026 Stewardship Code: What the Updated Requirements Mean in Practice

Stewardship agendas between 2020 and 2022 were dominated by climate change. From 2023 onwards, leading firms began integrating biodiversity and nature, reflecting a more mature understanding of interconnected environmental risk. Robeco's engagement history illustrates this: its Climate Action programme ran from Q1 2018 to Q1 2021, and its Net-Zero Carbon Emissions programme from Q4 2020 to Q4 2023. From 2023, Robeco finalised its Biodiversity Investment Framework and became a founding signatory of Nature Action 100.

Stewardship Theme Coverage: Industry Adoption Rate 2020–2025

Based on disclosure analysis across 126 stewardship reports. Figures represent proportion of firms addressing each theme in their published reports.

By 2024, many firms were actively preparing for the updated UK Stewardship Code, which takes a clearer outcomes focus and introduces a more flexible reporting structure. References to the update shifted from generic acknowledgements to concrete governance and process changes.

Policy & Context
New disclosure every 4 years, setting the strategic framework
Activities & Outcomes
Annual report showing Principle application and results
Apply & Explain
Flexibility mechanism, but outcomes must be evidenced

The Code sets high stewardship standards for those investing money on behalf of UK savers and pensioners, and those that support them. Reports must link to organisational governance and policies.

UK Stewardship Code 2026, Financial Reporting Council

The grid below shows where industry-level disclosure is strongest and where persistent gaps remain across the 12 Principles, based on analysis of 126 reports. The labels reflect the breadth and consistency of disclosed evidence, not a rating of any individual firm.

P1
Purpose, Strategy & Culture
Widely disclosed
P2
Governance & Resources
Partially disclosed
P3
Conflicts of Interest
Partially disclosed
P4
Well-Functioning Markets
Inconsistently disclosed
P5
Review & Assurance
Inconsistently disclosed
P6
Client & Beneficiary Needs
Partially disclosed
P7
ESG Integration
Widely disclosed
P8
Monitoring Managers
Inconsistently disclosed
P9
Engagement
Widely disclosed
P10
Collaboration
Partially disclosed
P11
Escalation
Inconsistently disclosed
P12
Rights & Responsibilities
Inconsistently disclosed

Industry-level disclosure patterns across the 12 UK Stewardship Code Principles, based on analysis of 126 published reports (Maanch, 2025). Labels reflect breadth of disclosure observed, not an assessment of any individual firm.

Stewardship Signal · In Practice

126 reports. 40 firms. All structured against the 12 Principles, without reading a single PDF.

Stewardship Signal structures and makes searchable the public disclosures of UK Stewardship Code signatories, mapped to the 12 Principles. What used to take an analyst days to read, compare, and compile is now queryable in minutes, with source citations back to the original published report. It is a disclosure transparency tool: it presents what firms have stated, so users can draw their own conclusions.

Explore Stewardship Signal →
B
Theme B
From Activity to Outcomes
Engagement volume is no longer the signal. What matters is whether stewardship changed anything, and whether you can evidence it.
B1

Multi-Year Campaigns: Sustained Engagement Over Episodic Contact

Early stewardship relied on annual, reactive engagement. Between 2022 and 2025, leading firms shifted toward multi-year thematic campaigns with defined objectives and milestones, enabling sustained influence over company behaviour rather than point-in-time dialogue.

Engagement Approach Evolution: Industry Distribution

Illustrative distribution based on disclosure patterns observed across 126 published reports.

State Street's 2024 reporting describes stewardship initiatives that typically span multiple years: "We prioritise our stewardship efforts through key stewardship initiatives, each addressing significant ESG factors affecting our clients' holdings." Robeco's thematic engagements routinely ran for two to four years, enabling progress to be assessed over time.

B2

Outcome Measurement: The Gap Between Claiming and Evidencing

Between 2021 and 2022, stewardship engagement focused heavily on improving corporate disclosure. From 2023 onwards, leading firms pivoted toward outcome measurement, explicitly linking stewardship activity to observable change in company behaviour and real-economy impact.

Critical finding: Outcomes remain the weakest data layer across the stewardship industry. Where outcomes are recorded, they are often high-level ("ongoing", "in progress"). Few engagements clearly close the loop with achieved change, escalation, or capital reallocation.

Impax took this shift further in its 2024 UK Stewardship Code statement by introducing a "stewardship impact value chain." The framework articulates how stewardship inputs (dedicated resources and governance structures) and actions (research, collaboration, escalation) are intended to lead to defined outcomes and real-economy impact.

Outcome Measurement: Disclosure Depth by Tier

Reflects depth of outcome-related disclosure observed in published reports; "Leaders", "Mid-Pack", and "Laggards" are descriptive groupings based on disclosed characteristics, not assigned ratings.

Key development: The industry moved from asking "did the company disclose?" to "what real-world change occurred?", but most asset owners still lack the infrastructure to answer the latter question with rigour and consistency.

B3

Net Zero: From Commitments to Accountability

Net-zero commitments provide a clear illustration of how stewardship has moved from headline pledges toward implementation, and how progress is now being tested by political backlash and shifting alliances. The trajectory can be understood in three phases.

2020–21
Public
Commitment
2022–23
Detailed
Implementation
2024–25
Retreat &
Recalibration
2025+
Fiduciary
Accountability

In 2024, the US House Judiciary Committee wrote to 60+ NZAM signatories. BlackRock withdrew; NZAM suspended operations. Yet BlackRock's sustainability-linked assets reached ~USD 1 trillion by end of 2024, roughly doubling since 2021. Climate stewardship was reconfigured, not abandoned.

Asset-owner implication: Net-zero stewardship now sits squarely within the realm of fiduciary infrastructure. Boards must look beyond initiative memberships to assess whether managers have robust plans, credible escalation tools, and defensible implementation pathways.

Stewardship Signal · In Practice

The outcome gap is visible in the data, if you know where to look.

Stewardship Signal structures and makes searchable the engagement disclosures published by UK Stewardship Code signatories. Asset owners and consultants can search by engagement theme, view what outcomes firms have reported, and compare depth of disclosure across the signatory base, drawing directly on what each firm has stated in their own published reports.

Explore the platform →
C
Theme C
Voting and Escalation as Strategy
Voting is no longer an administrative function. It is the final signal of whether engagement is credible, and whether the firm means what it says.
C1

Voting: From Administrative Exercise to Deliberate Signal

Between 2020 and 2022, proxy voting at many firms remained primarily policy-driven, with decisions framed through pre-defined guidelines rather than clearly documented links to engagement outcomes. From 2023 onwards, leading firms began articulating voting more explicitly as an escalation mechanism.

Phase 1: Reporting (2020–21)

Aggregate statistics and alignment with house policy. Voting against management framed as exception, justified by predefined thresholds.

Phase 2: Integration (2022–23)

Railpen introduces new thematic voting lines. Voting begins acknowledging the limitations of purely rules-based approaches. Engagement and voting narratives start connecting.

Phase 3: Contextual Escalation (2023–24)

State Street votes against Compensation Committee Chair following governance shortcomings. Votes in director elections explicitly described as more effective than shareholder resolutions.

Phase 4: Decision-Grade Voting (2025+)

Visible escalation logic: engagement → voting → capital decisions. Time-based triggers, documented rationales, demonstrable connection to fiduciary strategy.

State Street's 2024 policy evolution abandoned numerical limits for director overboarding in favour of voting against the chair of the nominating and governance committee at S&P 500 companies that fail to disclose their internal policy on director time commitments: "Making subjective decisions to determine the calibre and time commitment of individual directors should be the job of well-governed boards themselves, not asset managers."

C2

Collaboration: From Individual Action to Collective Leverage

Systemic risks drove a shift toward collaborative engagement. Robeco expanded collaborative initiatives across multiple themes. Railpen led authorship of an International Corporate Governance Network (ICGN) viewpoint on systemic stewardship. These are not simply examples of industry participation; they represent a deliberate strategic shift toward collective leverage as a primary engagement tool.

The Exxon-Arjuna case provides the clearest illustration of modern collaborative escalation: coordinated action combining public statements, voting escalation, direct engagement, and public commentary from 38 global investors representing USD 5.2 trillion in assets.

Escalation Toolkit in Practice: Exxon-Arjuna Case Study
Collective Statement

38 global investors representing USD 5.2 trillion signed public statement criticising ExxonMobil's actions

Voting Escalation

Net zero voting policy implemented throughout engagement, with post-proxy letters to Executive Chair

Direct Engagement

Engaged Company Secretary, Chief of Staff to Larry Fink, Investor Relations, and Global Head of Investment Stewardship

Public Commentary

Published blog post setting out position on shareholder rights, with follow-up letter to BlackRock on climate commitments

C3

Escalation: From Dialogue to Multi-Tool Approach

The presence of an escalation policy is no longer sufficient. Asset owners increasingly need to understand who oversees escalation decisions, how independent that oversight is, and what triggers the move from engagement to more forceful tools, including voting against management, filing resolutions, public statements, or ultimately capital reallocation.

The new bar: Firms that can document the decision logic for a specific escalation, including when dialogue moved to voting and why, provide meaningfully more useful evidence than those describing escalation in principle without citing practice.
External context · ShareAction, Point of No Returns 2025
Escalation gaps visible from the outside

ShareAction's benchmarking of 76 asset managers found that only 10 achieved more than half of their key stewardship standards, and that European managers, including Robeco and APG, dominate the top rankings. The research highlights persistent gaps in fossil fuel escalation follow-through, consistent with the patterns observed in the underlying stewardship reports: engagement activity is rising, but escalation to voting, public statements, or capital decisions remains the exception rather than the rule.

Read our joint report with ShareAction →
Stewardship Signal · In Practice

Where does the evidence of escalation actually sit?

Stewardship Signal structures what UK Stewardship Code signatories have disclosed about their escalation approaches, including which firms document a clear path from engagement to voting to capital decisions, and which describe escalation in principle without providing evidence of it in practice. The data reflects what has been published; Stewardship Signal makes it searchable and comparable.

Explore the platform →
D
Theme D
People, Governance and Integrity
Stewardship is only as strong as the team behind it, the governance around it, and the rigour with which conflicts are managed. Without the right infrastructure, the report is the ceiling.
D1

Team Professionalisation: The Infrastructure Behind the Report

Stewardship resourcing shifted from peripheral and generalist to professionalised and specialised. Between 2022 and 2024, dedicated teams and clearer governance structures emerged as a key differentiator of disclosed stewardship capability.

By 2022, RBC Brewin Dolphin expanded its stewardship team, explicitly linking responsible ownership to improved outcomes. Railpen's evolution between 2023 and 2024 illustrates a more advanced stage: a multidisciplinary team incorporating governance expertise, investment management experience, a dedicated climate analyst, and administrative support.

Stewardship Team Resourcing: Disclosed Configuration by Tier

Based on what firms disclosed about team size and structure in their published reports. Figures are illustrative of the range observed, not a precise count.

Evolution: Stewardship moved from a peripheral compliance function to a core investment capability with dedicated specialists. The next phase requires these teams to be held accountable not just for activity, but for building the decision-grade infrastructure that boards need.

D2

Governance Architecture: From Ad Hoc to Systematic

The period from 2020 to 2024 saw a marked evolution in how stewardship is embedded within firms' governance architecture. Relatively siloed ESG committees with unclear authority gave way to cross-functional structures with formal board-level oversight.

State Street's ESG Committee, established in January 2022, comprises senior staff from investment, client-facing, legal, compliance, risk management, and operational teams. LGIM's Investment Stewardship Committee is chaired by an independent non-executive director, making stewardship subject to the same independent challenge as other key investment governance areas.

D3

Conflicts of Interest: From Policies to Independent Oversight

LGIM's 2024 UK Stewardship Code summary provides a clear example of the direction of travel. The oversight of conflicts of interest related to stewardship is delegated to the Investment Stewardship Committee and to a separate Conflicts of Interest Committee that includes multiple independent non-executive directors.

The new bar: The presence of a conflicts policy is no longer sufficient. Asset owners increasingly need to understand who oversees conflicts in stewardship, how independent that oversight is, and how escalation works when stewardship priorities and commercial interests collide.
Stewardship Signal · In Practice

What does published stewardship governance actually look like across the market?

Stewardship Signal structures disclosures across the 12 UK Stewardship Code Principles, including governance arrangements, committee structures, and conflicts management, making it straightforward to review what firms have disclosed about their internal governance and how this has changed year on year.

Explore the platform →
E
Theme E
Data, Clients and the New Frontier
The tools firms use and how they communicate now determine whether stewardship is real or performative. Fixed income, private assets, and non-equity stewardship remain largely unaddressed.
E1

Technology and Data: The Limits of What Is Visible

Investment in stewardship data and technology increased across leading firms, but system fragmentation remains a practical challenge. Robeco expanded its Sustainable Investing Open Access programme. Railpen announced plans to appoint a dedicated stewardship database and reporting provider. Despite this investment, asset owners still receive fragmented, retrospective data.

The fundamental gap: Most stewardship systems capture activity (engagements conducted, votes cast); few capture escalation logic (when did engagement move to voting? why?) or cross-theme linking. This is a decision-grade infrastructure deficit, not merely a technology gap.
E2

Client Communication and Proxy Choice

Railpen's 2023 reporting describes the launch of a Sustainable Ownership Review, alongside twice-yearly Sustainable Ownership Client Forum meetings, member-focused blogs, and animated explainer videos. Aviva recorded over 5,000 external participants across six CPD-accredited ESG training modules, a shift from passive reporting to active client education.

Proxy voting choice extended this empowerment further. State Street's 2022 programme offers eligible investors a range of voting policies: sustainability-oriented, social responsibility, labour-focused, faith-based, pro-management, and standard. By the 2023 proxy season, investors in more than 40% of index equity assets could exercise voting choice. BlackRock's Voting Choice initiative saw nearly USD 600 billion opt into the scheme by end of 2023.

E3

Fixed Income Stewardship: The New Frontier

Prior to 2022, fixed income stewardship was largely neglected; engagement, voting, and escalation frameworks were designed primarily for equity markets. State Street hired a full-time fixed income stewardship specialist in 2023. Robeco's Net Zero Roadmap explicitly included sovereign bond dialogue as one of its six key implementation actions.

External context · ShareAction, Point of No Returns 2025
How does the industry look from the outside?

ShareAction's Point of No Returns 2025 benchmarks 76 asset managers representing £63 trillion in AUM across governance, stewardship, climate, biodiversity, and social issues. Top performers include Robeco (76%) and APG (75%), with Aviva Investors among the top five UK-domiciled managers overall. The research focuses on policy positions and public commitments rather than stewardship report disclosure quality, but the directional findings are consistent with the patterns observed across the 126 reports in this dataset.

Read our joint report with ShareAction →
Stewardship Signal · In Practice

The data behind the report, structured and searchable.

Stewardship Signal is purpose-built to address the transparency gap this section describes. It extracts and structures what UK Stewardship Code signatories have disclosed, making it possible to search across published reports, compare disclosed approaches by theme or principle, and track how disclosures have changed year on year. The platform presents what firms have stated in their own reports; users draw their own conclusions.

Explore the platform →
Landscape Overview

Stewardship Capability: A Dimensional View

The chart below maps the relative characteristics of stewardship disclosure across eight dimensions, grouping firms into three tiers based on patterns observed in their published reports. This provides a composite picture of the stewardship landscape as it stands in 2025. The positions are illustrative of disclosed characteristics; they do not reflect scores assigned to any individual firm.

Stewardship Capability Dimensions: Illustrative Comparison by Tier (2025)

Illustrative only. Positions reflect the range of disclosed characteristics observed across the dataset, not scores assigned to any individual firm or group of firms.

Leaders
Consistent evidence across all dimensions: Railpen · Robeco · Impax · State Street
Mid-Pack
Active disclosure; gaps in outcomes and escalation. Growing 2026 compliance risk.
Laggards
Activity metrics only; limited outcomes or escalation evidence disclosed
Appendix 1: Capability Framework

Three Tiers of Disclosed Stewardship Capability

Based on analysis of 126 published reports, three distinct tiers of stewardship capability are visible across the UK asset management industry in 2025. The characteristics below describe what firms in each tier have disclosed, not a rating of any individual firm. The gap between Tier 1 and Tier 3 is now visible to regulators, beneficiaries, and rating agencies.

Tier 1 · Leaders

Decision-Grade Infrastructure

Multi-year thematic campaigns · Integrated climate-nature-social frameworks · Proprietary analytics · Dedicated specialist teams · Systematic outcome measurement · Documented escalation logic · Board-level independent oversight

Tier 2 · Mid-Pack

Activity-Based Reporting

Basic ESG integration · Reactive engagement · Annual cycles · Reliance on third-party data · Activity-based reporting · Limited outcome tracking · Informal escalation · Climate-first with nature emerging. Growing 2026 compliance risk in outcomes and escalation disclosure.

Tier 3 · Laggards

Compliance-Minimum

Stewardship treated as compliance function · Minimal resourcing · Generic proxy voting · Limited collaborative participation · No outcome tracking · No escalation logic disclosed · Activity metrics only. Significant regulatory exposure heading into 2026.

Capability Framework: What Good Looks Like by Dimension

The table below describes the range of disclosed practice observed across the dataset. It is a descriptive framework, not a scoring tool.

Dimension Laggard pattern Mid-pack pattern Leader pattern
Team Resourcing Part-time, ESG generalist Dedicated, single theme Multidisciplinary, cross-asset
Outcome Measurement Activity counts only Some outcome reporting Systematic, real-economy impact
Thematic Depth Climate only Climate + 1–2 others Integrated climate-nature-social
Technology & Data Third-party feeds only In-house analytics, fragmented Proprietary systems, AI/ML
Engagement Approach Reactive, annual Mix of annual & multi-year Multi-year with milestones
Escalation Logic Mechanical voting policy Engagement + voting, some linkage Documented framework with triggers
Collaborative Leadership Peripheral participation Active member Co-leads, policy authorship
Board Visibility Annual summary Quarterly reporting Real-time decision-grade systems
Appendix 2: Trustee Questions

Six Questions Every Board Must Be Able to Answer

These questions separate stewardship that is procedurally compliant from stewardship that is substantively defensible. Asset owners should ask their stewardship managers, and themselves, these questions regularly.

Six Questions Every Board Must Be Able to Answer

1
On prioritisation: Can we explain why we prioritised these issues over others? What is the fiduciary logic? How does it connect to systemic risk across the portfolio?
2
On escalation: Can we show how escalation decisions were made? When did engagement move to voting? Why? What were the decision criteria? When is disengagement or capital reallocation warranted?
3
On outcomes: Can we evidence outcomes, not just activity? What real-world change has stewardship delivered? Where has engagement stalled, and what action did we take?
4
On cross-theme linking: How do climate engagement outcomes feed into governance decisions? How do social risks affect voting or capital allocation? Is stewardship fragmented or integrated?
5
On accountability: Could we defend our stewardship approach under regulatory scrutiny today? Could we explain it to beneficiaries? Could we evidence it in an audit?
6
On infrastructure: Do we have decision-grade systems to track escalation logic, outcomes, and cross-theme connections? Or are we relying on narrative and retrospective reporting?
Conclusion

What to Do Next

The evidence across 126 stewardship reports is consistent: the market has moved. But knowing it has moved is not enough. The value of this paper is in what it surfaces for action, and that looks different depending on where you sit in the investment chain.

If you're an asset owner

Ask your managers to show you the escalation path from a real engagement this year, not the policy, but the documented decision logic. If they can't, that is the gap to close first. Structured disclosure tools mean you no longer have to rely on manager self-presentation to prepare for oversight meetings.

If you're a consultant

Trajectory matters more than snapshot. A manager whose published disclosures have materially improved over three years often tells a more useful story than one whose reports haven't changed. The ability to compare what managers have actually disclosed, year on year, side by side, is now a research infrastructure question, not just a reading hours question.

If you're an asset manager

Your published stewardship report is already being read and structured by tools like Stewardship Signal. The question is whether your own team has the same visibility your clients are starting to gain. The 2026 Code's outcomes focus rewards firms who can connect engagement activity to investment decisions, in their report and in reality.

Three questions worth asking now, regardless of your role: Can you explain how stewardship influenced a decision in the past twelve months, not just that engagement happened, but what changed as a result? Is the governance around stewardship decision-making visible and defensible? And could you describe the escalation path taken in at least one material engagement, from first contact to outcome?

Disclosure Maturity vs Regulatory Expectation: Illustrative, 2025

Illustrative only. Based on patterns observed in published reports; not a measure of any individual firm's performance or regulatory standing.

The question is no longer whether stewardship matters; it's whether the infrastructure behind your stewardship can withstand scrutiny from regulators, beneficiaries, and the investment chain.

Maanch Stewardship Under Scrutiny, 2026
Industry Infrastructure · Investment Association

"Fostering effective stewardship practices and outcomes requires all stakeholders across the investment chain to work collaboratively, aligned with the common goal of sustainable value creation for the end-saver."

Andrew Ninian, Director of Stewardship and Corporate Governance, Investment Association

From Realigning Stewardship: Delivering Sustainable Value Through Stewardship, Investment Association, which sets out 10 recommendations for reframing stewardship around outcomes, reducing reporting burdens, and enhancing transparency across the investment chain.

What boards should do now

Test
Whether current managers can evidence outcomes, not just activity, and show how escalation decisions were made
Decide
Where stewardship sits in the board and committee structure, and who has independent oversight
Build
A 12–24 month plan to move from activity-based reporting to decision-grade stewardship infrastructure
What This Means for You

Implications by Stakeholder

The five-year evolution described in this paper has different practical implications depending on where you sit in the investment chain.

Asset Managers Reporting Firms

The most important questions to ask now: Can you demonstrate that stewardship influenced investment decisions, not just that activity happened? If your lead stewardship analyst left tomorrow, could you maintain quality? Can you show, from your own published report, how your engagement approach compares with the 2026 Code's expectations on outcomes?

Key priorities: outcome measurement infrastructure · multi-year engagement planning · published vote rationales · fixed income stewardship capability.

See how your published disclosures sit alongside peer reports on Stewardship Signal →
Investment Consultants Advisers & Researchers

Trajectory matters as much as current positioning, a manager with clear improvement across their published disclosures year on year often tells a more useful story than one whose reports haven't changed. The ability to query and compare what managers have actually disclosed, without relying on their self-presentation, is a material research advantage.

Key priorities: structured comparison of published disclosures · tracking changes year on year · identifying gaps between stated policy and reported practice.

Search and compare published stewardship disclosures across the signatory base →
Asset Owners & Pension Funds Trustees & Boards

Delegation does not delegate accountability. The six critical questions in Appendix 2 are the right starting point: can you explain why you prioritised certain issues, how escalation decisions were made, what outcomes were achieved, and could you defend your approach under scrutiny today?

Key priorities: board-level visibility into how managers report escalation and outcomes · structured oversight across your manager panel · stewardship governance with independent oversight.

Review your managers' published stewardship disclosures, structured and searchable →
Fund Selectors & Allocators Wealth Platforms & DFMs

Stewardship disclosure quality is an increasingly useful signal in fund selection, not as a definitive assessment, but as a lens into how firms think about long-term risk and governance. The ability to view what managers have actually published, structured and comparable, supports more informed due diligence without replacing it.

Key priorities: stewardship disclosure as part of manager due diligence · identifying consistency between stated approach and reported practice · fixed income and private asset stewardship coverage.

Review published stewardship disclosures across your buy list →
About Maanch

Two Products. One Mission.

Maanch builds infrastructure for stewardship intelligence and delivery. Our two products serve different sides of the investment chain, and together they address the gap this paper documents: the distance between what stewardship reports say and what stewardship practice looks like.

Stewardship Signal
Intelligence · Oversight · Transparency

Stewardship Signal extracts and structures information from publicly available UK Stewardship Code reports using AI-assisted interpretation. It does not produce ESG ratings, investment advice, or assessments of stewardship quality. It presents what firms have disclosed in their own published reports: structured, searchable, and comparable.

Asset owners, investment consultants, and fund selectors use Stewardship Signal to review manager disclosures, track changes year on year, and prepare for manager oversight meetings, without reading hundreds of pages of PDFs.

Launched at Asset Owner Day 2026. Growing beyond the 40 firms in this whitepaper.

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Maanch Engagement Tracker
Delivery · Tracking · Reporting

The Maanch Engagement Tracker is an operational platform for asset managers and stewardship teams. It centralises engagement plans, interactions, votes, actions, and outcomes, creating a clean evidence trail for outcomes-focused reporting under the 2026 Code.

Teams use it to tag activity to objectives and themes, track escalation logic, link engagement to investment decisions, and produce proportionate reporting across asset classes, including fixed income and private markets, without the end-of-year scramble.

Purpose-built for Code 2026 outcomes-focused reporting requirements.

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Get in touch

To learn more about either product or to speak with the team, visit maanch.com or reach out directly. We work with asset owners, managers, and consultants across the UK stewardship landscape.

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