UKSIF Competition Law Policy

Updated April 2026

The UK Sustainable Investment and Finance Association (UKSIF) provides members the lawful opportunity to meet to advance UKSIF’s mission, transact association business and further their legitimate goals.

Such lawful activities include: the petitioning of UK government departments on issues that have an impact on members as a whole; the promotion of the industry; the conducting of educational conferences and events; the publication of research, and other activities consistent with the role of a membership association in the UK.

It is important that all participants (“Participants”) in discussions and meetings convened by UKSIF, including discussions at meetings of the Board of Directors, Advisory Committees, member events such as forums and roundtables, and other meetings, both virtual and in-person where more than one competing company may be present (“UKSIF Meetings”), observe UKSIF’s Competition Law Policy to avoid potential competition law risk. This policy is often featured under the Rules for Participation in UKSIF Activities, which additionally includes expectations of conduct from Participants on wider areas such as bullying and harassment.

Because participants in UKSIF Meetings are companies with competing, and sometimes opposing, economic interests, UKSIF’s actions are subject to anti-competitive scrutiny. UKSIF complies with competition law and participants in all UKSIF Meetings are reminded of their need to do so as well.

UKSIF has a zero-tolerance approach to all anticompetitive conduct. As such, all UKSIF employees, members, committee and Board members, and partners are required to read and understand this Competition Law Policy and Protocol and comply with it at all times. Deliberately or recklessly ignoring any part of it may result in disciplinary action (if staff) or removal from a meeting (if from UKSIF membership or other participant in UKSIF activities).

If any employee, member or other individual has concerns in relation to any of the issues outlined in this policy, these should be reported to the UKSIF Chief Executive.

The purpose of this policy is to ensure all UKSIF members, participants and employees understand and comply with competition law, and to mitigate the risk of financial harm, criminal liability or reputational damage that may incur as a result of a competition law investigation.

All UKSIF Meetings, events and other activities must follow the procedure outlined below for any and all meetings within the governance framework of UKSIF, committees and working groups.

All UKSIF Meetings should have a clear written agenda and an attendee list should be held on file by UKSIF. Participants should join the meeting for their agenda items only.

Written minutes should be prepared for all UKSIF Meetings, and Participants should be asked to review these after the meetings have been completed.

Participants at UKSIF Meetings should not exchange Competitively Sensitive Information (CSI). In particular, there should be no exchange of non-public information on: future pricing intentions or customer strategy; or current or recent information on pricing, customers, margins, capacities or input/supply costs – although it should be noted that CSI can take other forms.

If an inappropriate topic is ever discussed at a UKSIF meeting, the Chair should terminate the discussion, this should be noted in the minutes (avoiding the inclusion of confidential, competitively sensitive information that could worsen the infringement), and the discussion should be reported to the UKSIF Chief Executive immediately. The Participant(s) in the inappropriate discussion should also be asked to leave the meeting.

It should be noted, however, that unlawful information exchange could take place outside of the context of formal UKSIF Meetings, such as at ‘unofficial meetings’, coffee breaks, social or training events. All Participants must be vigilant about any sharing of CSI that takes place, including by immediately reporting any instances of inappropriate discussions to the UKSIF Chief Executive.

Further, if UKSIF staff or representatives somehow obtain CSI which is not in the public domain (e.g. through a bilateral communication with a member), care must be taken to ensure this is not passed on. If UKSIF’s members are able to exchange CSI with each other through UKSIF, the organisation could be held liable as a ‘hub’ for that information exchange (informally known as ‘hub and spoke’ collusion).

The following statement is to be shared with all Participants before the start of all UKSIF Meetings. At minimum this will be shared with all Participants in advance of attending by email and will be accessible from the UKSIF website. At some Meetings this will also be displayed on a slide at the start of the Meeting:

“UKSIF reminds all participants of their need to comply with competition law and that they may not discuss or exchange confidential or commercially sensitive information. Participation in UKSIF meetings does not require the disclosure or discussion of competitively sensitive information (including business strategy, pricing, details of customer or supplier relationships and commercial preferences) and no agenda topic shall require such disclosure or discussion. By attending UKSIF meetings, participants confirm both their understanding of UKSIF’s Competition Law Policy [hyperlink to this document] and their agreement to abide by it. If participants have questions about their antitrust obligations they should take advice from their respective organisations’ legal teams.”

Reporting a breach

If you believe a breach of anti-competition law takes place in a UKSIF Meeting, this can be raised immediately with the Chair of the meeting, who will stop the meeting and address the issue. All details will be recorded in the meeting minutes (avoiding the inclusion of confidential, competitively sensitive information that could worsen the infringement). Alternatively, and for reasons of confidentiality, the matter can be raised with the UKSIF Chief Executive after the meeting on info@uksif.org. UKSIF will investigate the breach, ensure it is dealt with, and will record details as appropriate.

Protocol for participation in UKSIF Meetings

1. UKSIF Meetings will be governed by a written agenda, circulated in advance, and a record of attendance at, and minutes of, each meeting will be kept.
2. UKSIF Meetings have no binding decision-making power or function over the actions of third parties.
3. UKSIF Meetings may include live discussion from Participants regarding the purposes of UKSIF as set out above and in the agenda for the meeting.
4. All comments are to be directed only to the subject matter of the meeting.
5. Participants must not disclose confidential or competitively sensitive information. Competitively sensitive information includes business strategy, pricing, details of customer or supplier relationships, and commercial preferences. If Participants are unsure whether something is competitively sensitive, they should refrain from sharing and consult their legal counsel or other relevant support team at their organisation for advice.
6. Participants must observe the following limitations regarding any proposed “best practices” discussed in UKSIF meetings:
   a) Participants generally may discuss and reach a conclusion as to the terms of what a proposed “best practice” should be.
   b) Each Participant must decide unilaterally whether, and how, to follow any proposed “best practice”.
   c) Participants should refrain from stating whether or how they plan to follow any particular “best practice”.
   d) In no event will any firm be asked whether, or how, it will agree to follow any proposed “best practice”.
7. If it appears at any time that discussions are at risk of entering into areas that might be inconsistent with these guidelines, the organiser will immediately bring such discussions to a close.