NN Group

In terms of senior leadership accountability, the responsibility for sustainability issues within NN lies with the Supervisory Board. Moreover, the financial institution links the remuneration of its executive team to sustainability performance criteria. In terms of female representation in leadership positions, the financial institution has a gender-balanced board of directors where 44% of members are women. It also has a target to increase the representation of women in senior management to 40% by 2023. In terms of its approach towards impact management, the financial institution acknowledges that its financing activities have both positive and negative impacts. Moreover, NN discloses a list of trade associations of which it is a member including sustainability- and non-sustainability-related organisations.

As a member of the Glasgow Financial Alliance for Net Zero (GFANZ), NN has set a target of net-zero financed emissions by 2050. The financial institution discloses the key companies it has identified as priorities to engage with on climate change, and the rationale for choosing these priorities. As a member of Climate Action 100+, the financial institution discloses that it collectively engages on the topic of climate change. It also engages on nature and biodiversity-related topics. The financial institution discloses the aggregate amount and share of finance it devotes to climate solutions. It aims to finance EUR 6 billion in climate solutions by 2030. NN also provides a definition of priority sectors and areas with the highest dependency and impact on nature and biodiversity, as well as the process for identifying them.

NN has a publicly available policy statement committing it to respect human rights and the ILO core labour rights. It also has a grievance mechanism accessible to all workers and external stakeholders to raise human rights, as well as bribery and corruption concerns or complaints. Moreover, the financial institution has a policy prohibiting bribery and corruption. In terms of workforce diversity, the financial institution discloses the proportion of women in its total direct operations workforce for each employee category. It also discloses the proportion of its total direct operations workforce covered by collective bargaining agreements. Furthermore, NN discloses a global tax strategy.

NN has an opportunity to link the remuneration of its management team to sustainability performance criteria. On the topic of remuneration, the financial institution could disclose the ratio of basic salary and remuneration of women to men in its total direct operations workforce for each employee category. Furthermore, NN has an opportunity to describe its engagement approach on sustainability themes and impact topics with clients and investees, across all its financing activities.

While NN has interim emission reduction targets for its corporate investments and real estate portfolio, it has an opportunity to disclose an interim target which covers all its financing activities. Moreover, while the financial institution engages with oil, gas and utilities companies on the topic of 1.5°C, it could require these companies to have a strategy aligned with 1.5°C. In terms of financing for climate solutions, the financial institution has an opportunity to disclose progress against its EUR 6 billion by 2030 financing target. There is no evidence that NN discloses the amount or share of finance linked to high-emitting sectors and fossil fuel sectors. Furthermore, there is no evidence that the financial institution discloses a strategy to phase out the provision of financial services to existing projects and companies across the fossil fuel value chain.

NN has an opportunity to describe the process for identifying its human rights risks and impacts through its relevant financing activities. In terms of workforce diversity, the financial institution discloses the ages of its supervisory board and management board, but has an opportunity to disclose this information for each employee category. To provide transparency on financial inclusivity, NN has an opportunity to disclose the amount of finance directed towards, for example, women-owned businesses, small- and medium-sized enterprises (SMEs) or low-income developing countries.