‘We agree that the Charity Governance Code should not be significantly altered at this stage as this could cause confusion for those charities who have implemented the Code already, and also act as a deterrent to others considering adopting it.
‘That said, there are enhancements that the Steering Group should be reviewing, particularly around the integrity principle. Research we conducted last year suggested that this is one of the worst applied principles of the Code. This may be due in part to the principle being too broad as it encompasses so many areas such as integrity, ethics, public trust and culture. In addition, the recommended practice is insufficiently definable and explicit. We believe that changes should be made to make this more precise and actionable.
‘Our research also identified that larger charities are better at applying the Code possibly because they have more human and financial resources. It may therefore be beneficial to have some additional guidance on the scalability of the Code for smaller charities to distinguish between how actions might differ between a charity with an income of £2m say, as opposed to a charity with an income of £20m.
‘Finally, given the urgent focus on tackling global climate change, the Code could put a greater emphasis on charities’ environmental responsibilities. Recommendations could include considering the environmental impact of the organisation as a whole and the actions that trustees have taken to reduce this.’