ACCA's comments align with those made in 2023 on the UK Corporate Governance Code, alongside the G20 Principles of Corporate Governance revisions released in Sept 2023.

ACCA has the following reflections:

• We strongly support the draft guideline's focus on demonstrating the actual outcomes of stewardship activities. This necessitates that asset managers and owners not only report on what they do but also on the impact their actions have. Effective stewardship requires a balanced and holistic approach that includes both.
• There could be a benefit to the inclusion of specific examples in the guidance related to areas where changes are underway in the business environment, such as developments relating to employment practices.
• We would encourage the FRC to include explicit elements in the guidance that encourage signatories to disclose how they integrate environmental and societal considerations into investment decisions and engagement activities. This would help them better understand the long-term sustainable value for clients and beneficiaries and therefore, crucially, further enhance trust and accountability.
• Additionally, we would encourage the FRC to address the role of stewardship concerning fraud risk oversight and prevention, given today's threats and their devastating effects on the economy and society at large. Board members and investors have a critical role to play in identifying cultural, governance, and control weaknesses that enable the rising risks of fraud. 
• We welcome the FRC's approach in treating 2026 as a transition year, during which no existing signatory will be removed from the list.