Responsible Investment Policy

Transcription

1 Respnsible Investment Plicy 1. Backgrund and purpse Respnsible Investment (RI) is a crnerstne in ur ambitin t be recgnised as the mst trusted financial partner. We are cmmitted t respnsible investment practices and believe that integrating envirnmental, scial and gvernance (ESG) perspectives in ur investment prcess is key t sustainable value creatin fr cmpanies, investrs and scieties. Based n this cre belief, we cnsider ESG t be ne f the imprtant value drivers in ur investment prcess, similar t the way we lk at financials r market mmentum. When ur custmers entrust us with their savings, it is ur bligatin t serve their interests by creating bth cmpetitive and sustainable returns. T d s we integrate ESG cnsideratins in ur investment practices. In additin, we expect cmpanies t respect internatinal nrms and principles fr crprate respnsibility and cllabratin within the investr cmmunity t the benefit f ur custmers and sciety in general. Our cmmitment t respnsible investments can at times create dilemmas. We aim t be pen abut these dilemmas and engage in dialgue with ur custmers and stakehlders t navigate and t find the best pssible slutins. The Respnsible Investment Plicy ( the RI Plicy ) gverns ur respnsible investment practices. 2. Scpe and applicatin The RI Plicy applies t all emplyees, all functins, all units in the Grup, and all separate legal entities nce adpted by their Executive Bard r Bard f Directrs. In case a Grup Plicy cnflicts with lcal needs r requirements, the Bard f Directrs r Executive Bard f the subsidiary can apprve a Grup Plicy with reservatins. Any material deviatins frm the Grup Plicy must be reprted t the Bard f Directrs f the Grup as well as the administratr f the Respnsible Investment Plicy. The RI Plicy applies, when we invest n behalf f ur custmers. Custmers with discretinary mandates can chse t fllw their wn RI plicies and beliefs. Our RI Plicy is integrated in funds and ther investment fferings marketed under the name f Danske Invest, Danica r Danske Bank. Our exclusin criteria d nt apply t structured prducts, derivatives and exchange-traded funds (ETF s). Als, the exclusin criteria d nt apply t investment funds frm external prviders. Regarding investment funds frm external prviders that are part f a Danske Invest, Danica r Danske Bank investment prduct, e.g. fund-f-funds, we aim t use funds frm prviders with a RI Plicy similar t urs. In alternative investment funds managed by Danske Private Equity, specific RI practices shall be negtiated between Danske Private Equity and the investrs, when such funds are established, with the aim t be cnsistent with the verall aims f the RI Plicy then prevailing. The RI Plicy is nt applicable t Danske Bank s trading bk, s that the bank can perfrm its rle as a market maker.

2 3. Target grup The RI Plicy is relevant fr all emplyees in the Grup. Certain functins whse wrk is influenced by respnsible investing activities will find the RI Plicy particularly relevant fr their daily wrk. This includes, but des nt limit t, investment teams, respnsible investment team, sales managers, client managers, system develpers and administratrs. It is the respnsibility f each manager t ensure that this Plicy is knwn and cmplied with where relevant within his/her respective area f respnsibility. 4. Objectives and pririties This Plicy cntains a set f general bjectives and pririties that are integrated in daily decisinmaking: Internatinal principles In line with Danske Bank s Respnsibility Plicy s supprt fr internatinal principles and guidelines, the RI Plicy is based n internatinal cmmitment t prmting crprate respnsibility regarding human rights, labur rights, the envirnment, and anti-crruptin as set ut in: The UN Glbal Cmpact The OECD Guidelines fr Multinatinal Enterprises The UN Guiding Principles n Business & Human Rights The UN-backed Principles fr Respnsible Investments (PRI) The UN Envirnmental Prgram Finance Initiative (UNEPFI) The Universal Declaratin f Human Rights The ILO Declaratin f Fundamental Principles f Rights at Wrk Additinal industry-specific internatinal principles and cnventins guide ur activities and expectatins twards custmers, prtfli cmpanies and business partners. Fr mre infrmatin, please see ur Psitin Statements n credit and investment prcedures n Cnsequently, we expect cmpanies we invest in t respect these principles and pursue transparency n their crrespnding management effrts. Further, ur investments cmply with internatinal sanctins adpted by Danske Bank Grup. Screening & Exclusins We screen ur investment universe and hldings n an nging basis t ensure we are nt investing in cmpanies and assets that d nt sufficiently address crprate respnsibility with reference t internatinal principles. We d nt want t invest in cmpanies that prduce illegal r sanctined weapns, and we have a restricted apprach t cmpany invlvement in nuclear weapns prgrammes. Finally, we adpt a cautius apprach t investing in svereign bnds issued by fragile r cnflict-affected states. Our general exclusins, which are publicly

3 available, apply t funds and ther investment fferings by Danske Invest, Danica and Danske Bank and the Grup s wn strategic prtflis, with the exemptins mentined in this plicy s paragraph 2 n scpe and applicatin. ESG Integratin We integrate ESG cnsideratins in ur investment practices t assess hw the management f envirnmental and scial risks as well as pprtunities and crprate gvernance practices can ptentially affect value creatin. We d this by incrprating ESG analysis in ur decisinmaking and mnitring prtflis ESG quality. Engagement, Dialgue & Vting We seek t influence cmpanies directly, especially where we represent relevant hldings. A central part f ur active wnership activities is t engage with prtfli cmpanies, when they d nt sufficiently address crprate respnsibility. We als enter int dialgue with cmpanies n ther ESG related and financial matters such as the cmpany s strategy, management, remuneratin plicy, risk management, culture, capital structure and dividend plicy. Input frm these dialgues is essential fr ur active wnership effrts as investment managers and enable lng-term value creatin. If we are nt cmfrtable with a cmpany s utlk, we can intensify ur dialgue with the cmpany and ultimately decide t sell ur investments. We vte at general meetings f Nrdic and Eurpean cmpanies, where we hld vting rights and represent relevant hldings. We vte either by urselves r thrugh a service prvider. We believe that vting activity shuld be perfrmed in accrdance with the dialgue between the investment team and a cmpany s management. Therefre and unless required by special circumstances hldings in passively managed funds are nt subject t vting activities. Engagement, dialgue and vting must always benefit each investment fund s investrs in rder t avid cnflicts f interest and prperly act as a fiduciary fr ur investrs. Cnflicts f interests are managed with reference t Danske Bank Grup s plicy n this area. Cllabratin & Initiatives In cmpany specific cases and when apprpriate, we can cnsult and cllabrate with ther investrs and relevant parties in rder t btain the best pssible basis fr decisin-making and increase ur impact. Especially utside the Nrdics, where ur direct impact is smaller than in ur hme markets, we prefer t participate in cllabrative investr initiatives t encurage cmpany- and industry-wide respect fr internatinal principles and t prmte transparency f crprate respnsibility. Cmmunicatin We maintain an pen dialgue with cmpanies, ur custmers and ther stakehlders. In additin, we cmmunicate n an nging basis n ur webpage, and annually in ur crprate respnsibility reprt and reprting t the UN PRI. We publish ur vting recrds as part f ur reprting.

4 5. Gvernance The Executive Bard receives updates n the implementatin f the RI Plicy annually frm the Head f Wealth Management, wh has the final wnership f the RI Plicy. The cntinuus justificatin and validity f the RI Plicy will be part f this annual briefing. The RI Plicy is supprted by the RI Strategy, which sets the fcus areas f ur effrts. The respnsibility fr develping the RI Strategy lies with the Respnsible Investment Bard ( RIB ). The RIB is chaired by the Head f Wealth Management and includes senir management members in Wealth Management as well as Grup functins. The RI Strategy is verseen and apprved by the Grup s Business Integrity Bard. Implementatin f the RI Strategy is the respnsibility f relevant departments and Grup functins with supprt frm the RI team. The RI team is respnsible fr the crdinatin acrss the Grup as well as the implementatin f selected initiatives and reprting n prgress. The RI Bard evaluates the quality and adequacy f ur pririties listed in Sectin 4 in its quarterly meetings and the annual review f the RI Plicy n an nging basis. 6. Review The belw stakehlders have been invlved in the cnsultatin prcess and endrsed this Plicy:

5 Change lg Date Versin number Cmments/changes 25 Octber First apprved versin 24 Octber Secnd apprved versin