Issued 19 May 2011
Last updated 3 November 2020
The purpose of this policy is to outline the scope and framework for responsible investment management at Norges Bank Investment Management (NBIM), in accordance with the Executive Board Principles for Responsible Investment Management and the Management Mandate for the Government Pension Fund Global. This policy includes the relevant provisions in the Guidelines for observation and exclusion from the Government Pension Fund Global issued by the Ministry of Finance.
NBIM works to safeguard the fund's long-term value and build financial wealth for future generations. Responsible investment management supports the objective of the fund in two ways: First, NBIM seeks to further the long-term economic performance our investments. Secondly, NBIM seeks to reduce financial risks associated with the environmental and social practices of companies in its portfolio. Responsible investment management further reflects the special characteristics of the fund:
As a global investor, NBIM relies on sustainable economic growth across the globe as a determining factor for the fund's long-term rate of return. NBIM recognises the potential for climate change and other global developments to have a significant impact on economies and markets over time.
As a market participant, NBIM has a strong interest in well-functioning, resilient and sustainable financial markets that facilitate long-term growth and are less prone to shocks. Responsible investment is premised on efficient market outcomes and stable and transparent frameworks for markets and companies. This includes standards for governance and sustainability that raise the bar for all companies.
As an asset owner and shareholder, NBIM promotes long-term value creation in its investee companies and fair distribution of benefits to shareholders. NBIM actively exercises its ownership to ensure that it has the ability to influence the companies in which it invests, including on material issues of sustainability and governance.
Taking into account the fund's purpose and characteristics, NBIM will integrate responsible investment management into its investment strategy and establish a chain of measures for responsible investment, including standard setting, ownership and risk management. Responsible investment management will be guided by internationally recognized principles, including the UN Global Compact, the OECD Guidelines for Multinational Enterprises, the United Nations Guiding Principles on Business and Human Rights, and the OECD Principles for Corporate Governance.
- As a global investor, NBIM will take into account how sustainability issues could have a significant impact on the fund's investments performance and long-term value. NBIM will support research and initiatives to understand the long-term impact of sustainability issues on economies and markets.
- As a global investor, NBIM will respect human rights in line with applicable international standards. NBIM expects its investee companies to exhibit responsible business conduct, to respect human rights and, as appropriate, to address human rights issues in their direct operations, supply chains and other business relationships.
- As a market participant, NBIM will engage in the development of regulatory frameworks and industry-wide standards to promote well-functioning, legitimate and efficient markets.
- As an asset owner and shareholder, NBIM will work to ensure that company boards are accountable to shareholders and that its members represent shareholder interests. NBIM will work to ensure the equal treatment of shareholders to protect shareholder value.
- As an asset owner and shareholder exposed to environmental and social risks across markets and sectors, NBIM will strive to monitor and, as appropriate, address and mitigate unwanted exposure to such risks and to promote market outcomes and sustainable business operations in line with the financial interests of the fund.
- In addition, NBIM will engage with external stakeholders, e.g., through periodic working-level meetings with non-governmental organisations (NGOs). NBIM may also seek external advice to support on its responsible investment management, including through the establishment of advisory committees and the contracting of experts.
- NBIM will contribute to the development of market practices that serve the long-term interests of the fund. To this end, NBIM will establish a process for identifying, analysing, formulating and promoting relevant policy issues. The starting point for this process will be the priorities set by the Executive Board and the Ministry of Finance, developments in regulation and international standards, market developments, and internal NBIM considerations.
- NBIM will use a combination of tools to ensure wider market impact for its standard setting activities, including publishing policies for responsible investment and active ownership, and actively engaging with regulators and other standard setters.
- NBIM will publish its policies as expectations towards companies, positions on specific issues, voting guidelines, and in other suitable formats. NBIM will work to ensure that its policies are well known across the organisation.
- NBIM will engage with regulators and other standard setters, companies, industry partners, and other stakeholders by making submissions and participating in relevant fora and discussions on responsible investment.
- NBIM will support academic research to improve the empirical and theoretical foundations for its responsible investment management. NBIM will promote the findings of such research to inform market standards, data development and its own investment and ownership decisions.
- NBIM will work with companies, investors and other stakeholders to advance relevant standards, increase the information available to investors, and promote good practices. NBIM will prioritise initiatives in focus areas - children's rights, water management, and climate change - and as a follow-up to other relevant expectation documents.
- NBIM will support, or establish its own, well-defined initiatives, on sustainability practices and disclosure, and on corporate governance. These initiatives will support NBIM investment and ownership decisions, and promote sustainable market outcomes and sound company practices.
- NBIM will engage with companies and their boards, taking into account its ownership policies, as well as a broader set of company and sector specific issues. NBIM will track company engagement at a company and issue level.
- NBIM will prioritise its ownership activities according to the type of activity, materiality of issue, significance of its holding, and likely impact.
- Certain securities will be restricted from lending to facilitate NBIM’s ownership priorities.
- Shareholder meetings are the main formal opportunity for NBIM to hold boards accountable and influence the companies in which it is invested. NBIM will vote at every shareholder meeting where there is no significant obstacle to do doing so.
- NBIM will vote in a principled and consistent manner to maximise the long-term performance of the fund. NBIM will base its voting decisions on publicly available information, but seek dialogue with companies when required.
- NBIM will integrate information from portfolio managers into voting decisions and accommodate company specific circumstances where necessary. NBIM may take market specific practices and regulation into consideration where appropriate.
- In the interest of transparency, NBIM will publish voting guidelines, which set out its approach to voting and the overarching policies that guide voting decisions.
- NBIM will publish its voting decisions one working day after the shareholder meeting is adjourned. On a selective basis, NBIM will disclose its voting intention ahead of a shareholder meeting.
- NBIM considers investment dimensions of environmental, social and governance issues as both risks and opportunities.
- NBIM will perform general assessments of environmental, social or governance issues that may influence the long-term value of the fund's investments.
- To support this work, NBIM will promote the development of high-quality data and corporate disclosure on material environmental, social and governance issues and will incorporate such information in its databases of non-financial data. This data is integrated in relevant analyses and processes including assessments and actions at the portfolio, sector and individual company level.
- NBIM will monitor and analyse risks from environmental, social and governance issues as part of the overall risk management of the fund. When relevant risks are identified, they will be analysed and strategically considered for further responsible investment activities such as ownership measures, standard setting, continued risk monitoring or additional risk management measures.
- Risk assessments may lead to adjustments to the portfolio or to restrictions affecting specific markets, sectors or companies. Accordingly, NBIM may divest from companies that are closely associated with unsustainable business models or practices; NBIM's divestments follow from the application of our integrated risk model.
- NBIM will make additional allocations to environmental technologies through its environment-related mandate.
Decisions by the Executive Board under the Guidelines for Observation and Exclusion
- The Guidelines for Observation and Exclusion from the Government Pension Fund Global (the Guidelines), issued by the Ministry of Finance, are part of the formal framework for Norges Bank's management of the fund.
- Norges Bank makes decisions on observation and exclusion under the Guidelines, based on advice from the Council on Ethics. Such decisions can be based either on the product or on the conduct of companies. Norges Bank can decide to exclude companies under the 2016 coal product criterion, independently of any recommendation from the Council.
- Before making any such decision, Norges Bank ensures that sufficient information is available to inform a given case, considers the grounds for a recommendation against the criteria and stipulations of the Guidelines, and assesses the appropriateness of alternative measures, such as the exercise of ownership rights, to reduce the risk of future norm violations.
- Norges Bank and the Council on Ethics regularly share information about its activities toward portfolio companies and coordinate company contact. Norges Bank also submits matters to the Council for consideration.
- NBIM will contribute to the coherent and consistent operationalisation of the Guidelines, and will provide such advice as required by the Executive Board.
- NBIM will provide an annual public summary of its responsible investment activities and
high-level priorities. Reporting on responsible investment will otherwise be integrated
into NBIM financial and management reporting.