Risk management

We analyse risks related to environmental, social and governance issues. We follow up selected issues across companies in the portfolio and attach importance to developing and improving the available data. We have also formulated expectations for how companies should manage risk and report on their activities.

Norges Bank Investment Management has adopted a risk-based approach to responsible investment and is keen to strengthen the analysis of risk for all of the fund’s investments. Because the risk picture is complex, our assessments need to be forward-looking and have a long horizon.

The fund is invested in most markets, countries and sectors in order to capture global value creation and diversify risk as best possible. We conduct risk assessments at market, sector and company level. We have selected a number of focus areas to guide our work: climate change, water management and children's rights.

We have developed criteria for what we do and do not want to invest in. There may be companies in specific sectors and countries that we choose not to invest in as a result of challenges related to the long-term profitability of business models or the external impacts of companies' activities. There may also be situations where we choose to divest completely from companies following an assessment of environmental and social risks.

The Ministry of Finance has issued guidelines on the observation and exclusion of companies endorsed by the Norwegian parliament. Norges Bank’s Executive Board takes the decision on excluding a company or putting it under observation on the basis of advice from the Council on Ethics, whose members are appointed by the Ministry of Finance.

Through our environment-related investment mandates, we invest extra in environmental technology. These are investments in areas such as renewable energy, energy efficiency and natural resource management, all subject to the same return requirements as the rest of the fund.

Monitoring risk

We identify, measure and manage the risks that the fund faces, using various models and analyses. Monitoring environmental, social and governance risks in the portfolio is an important aspect of our responsible investment management.

We take a systematic approach to risk monitoring. Our approach means that we perform general assessments before going into specific issues in greater depth. Risk is assessed at the market, sector and company level. The assessments contribute to a greater understanding of risk in the portfolio.

More on risk monitoring

Industry initiatives

We prioritise selected issues across the companies in the portfolio, through thematic or industry initiatives. Topics include our focus areas children’s rights, water management and climate change.

Our work on industry initiatives has three main angles: we wish to develop and improve the information available to investors, we wish to support initiatives that can help companies manage risk, and we wish to contribute to improved industry practices. These initiatives are typically closely related to our efforts within standard setting and ownership. 

More on our industry initiatives

Focus areas

Through our focus areas, we work on selected issues that are relevant across multiple sectors. We have three focus areas dealing directly with environmental and social issues: children’s rights, water management and climate change. We have formulated expectations in each of these areas for how companies should manage risk and report on their activities.

Each year, we assess whether companies disclose guidelines, strategies, business plans and reports that suggest that they are well equipped to manage these risks. The assessments cover sectors that we consider especially relevant and are used to identify companies with good reporting and those that need to improve their disclosure. An important general issue is to move from words to numbers, so that investors can evaluate companies’ efforts.

Climate change

Water management

Children’s rights

Human rights

Norges Bank Investment Management, as a financial investor, expects companies to respect human rights, and address human rights issues in their business practices. We have developed a set of expectations towards companies with regards to human rights.

Go to the expectations

Tax and transparency

Norges Bank Investment Management, as a financial investor, expects multinational enterprises to exhibit appropriate, prudent and transparent tax behaviour. We have developed a set of expectations towards companies with regards to tax.

Go to the expectations


As a financial investor, we expect companies to work against corruption in all its forms. We have developed a set of expectations towards companies with regards to anti-corruption.

Go to the expectations

Ocean sustainability

The ocean is a vital part of the biosphere and an important part of the global economy. The degradation of the ocean could reduce companies’ ability to generate value for investors in the long term. We have developed a set of expectations towards how companies manage the challenges and opportunities related to sustainable uses of the ocean.

Go to the expectations

Environment-related mandates

We invest extra in environmental technology through our environment-related mandates. The mandate from the Ministry of Finance requires these investments to amount to between 30 and 60 billion kroner. We have also made a number of risk-based divestments in recent years. Some sectors present particular environmental and social challenges.

Risk-based divestments

We have divested from a number of companies in recent years following a wide-ranging financial assessment that includes environmental and social issues.

Our risk-based approach means that we select sectors and areas where we see elevated levels of risk for our investments in the long term, and where adjusting the portfolio may be an appropriate solution. Where we have substantial investments in a company, divestment will normally not be the most suitable approach, as we generally have better analytical coverage and contact with such companies. Our assessment of whether a company's business is long-term sustainable includes an evaluation of changes in its operating conditions.


The Ministry of Finance has issued guidelines on the observation and exclusion of companies. The criteria for observation and exclusion have been endorsed by the Norwegian parliament.

These criteria relate to specific product types and entail that the fund must not invest in companies which themselves, or through entities they control, produce weapons that violate fundamental humanitarian principles through their normal use, produce tobacco, or sell weapons or military materiel to certain countries. Companies may also be excluded if there is an unacceptable risk of behaviour that is considered grossly unethical.

Norges Bank’s Executive Board takes the decisions on the observation and exclusion of individual companies on the basis of advice from the Council on Ethics, an independent body appointed by the Ministry of Finance.

Until the end of 2014, it was the Ministry that took the decisions on observation and exclusion, based on the applicable guidelines and the advice of the Council on Ethics.

List of companies excluded or placed under observation