In 2009, the late and great John C. Bogle, founder of The Vanguard Group, wrote a passionate and persuasive article entitled ‘The Fiduciary Principle: No Man Can Serve Two Masters’. In this piece, Bogle called for the restoration of the principles of ethical responsibility and fiduciary duty within investment funds governance. Mr Bogle recognised the challenge of maintaining the integrity of investment fund governance. Many academics, principally in the US, have also explored investment fund governance challenges in the context of a disconnect between the legal and regulatory constructs that prevail in the sector (i.e. the investment fund appoints the investment manager and is regulated accordingly) versus the practical reality within which investment fund boards operate (i.e. the investment fund is a product of the investment manager1 and all of the key appointment and related decisions are controlled by the investment manager) (Mundheim, 1967, Ambler, 2005, Radin and Stevenson, 2006, Roiter, 2015, Cullen, 2011, Cullen and Brennan, 2017). These regulatory challenges are exacerbated in a European context where, often the domicile of the investment fund and the domicile of the investment manager are different. Investment fund boards must navigate these challenges, putting investor protection at the heart of what they do while ensuring regulatory compliance in the jurisdiction of domicile.