What do we not invest in?

Exclusions are an important part of our work with responsible investment and external managers to ensure that the management of the fund is conducted in accordance with the principles we want for our own funds and on behalf of clients. These principles are largely based on the UN Global Compact with its 10 principles for corporate and organisational social responsibility. The principles form the basis for minimum requirements for all companies in which we invest, and a material breach of one of the principles cannot be outweighed by good practice for all other principles. In this work, we use third-party assessments to provide a complete basis for assessing individual companies. This assessment uses the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights with conventions.

• The human rights criteria are broad and can to some extent also be strongly linked to labour rights and contributions to human rights violations through support for/trade with regimes that commit significant violations, e.g. through arms trafficking. Some examples are the delivery of critical infrastructure that enables the oppression of an entire population or certain ethnic groups, developments that deprive indigenous peoples of rights to land or water resources, major security breaches with consequences for private data, and facilitation of technology that hinders freedom of expression. The Universal Declaration of Human Rights is the starting point for forming the basis for these assessments. 

• Workers' rights are primarily based on the International Labour Organization's (ILO) labour conventions. The reasons for exclusions are many and include lack of rights to organisation, systematic lack of equal treatment, weak security routines and forced labour.

• The environmental criteria cover emissions to water, land and air, developments with major biological consequences, animal welfare and unnecessarily large greenhouse gas emissions. As of today, exclusions are not an important tool for us to achieve our net zero emissions strategy, but over time more sectors will also emerge as uninvestable given this strategy. 

• Anti-corruption is substantially broader than the category of principles indicates based on underlying conventions, and also includes money laundering, tax evasion, accounting manipulation and generally poor business ethics. An important source for the assessments is the OECD Guidelines for Multinational Enterprises. 

• Weapons that are considered to target civilians in a particularly inhumane way based on international conventions such as the Convention on Cluster Munitions, the Mine Ban Treaty (the Ottawa Convention on Antipersonnel Mines) and the Nuclear Non-Proliferation Treaty. The Treaty on the Non-Proliferation of Nuclear Weapons varies, but we exclude all involvement in nuclear weapons production that is considered specially adapted or critical to the use of the weapons. 

In very special cases where we believe we have a strong opportunity to influence the company that is considered to be in breach of our principles, we may choose to put the company on an observation list in order to drive influence through our market power as an investor and potentially also as a customer. This opportunity is rarely used.