NN Group

The financial institution has a stewardship policy that supports environmental transitions and social best practices aligned with its sustainability strategy. The policy also covers client engagement, advocacy, and partnerships, with defined criteria for successful outcomes, escalation routes and conditions for escalation. Additionally, it publishes an engagement report on sustainability impact topics.

The financial institution has a publicly available policy committing to respect ILO core labour rights, which it also expects from suppliers. It discloses the results of human rights risk assessments and specifies that it does not make political contributions while disclosing lobbying expenditures. A gender balance of 40-60% is maintained at the senior executive level, with decision-making and oversight for the sustainability strategy assigned to the highest governance body. Performance criteria for senior executive remuneration are linked to sustainability targets, and responsibility for implementing the strategy is assigned to specific functions or committees within the institution.

Furthermore, the institution has a publicly available human rights policy and discloses its trade association memberships. It identifies key sectors, clients, and investees for engagement on climate and nature-related impacts, influencing them to develop strategies for protection and restoration. Moreover, it provides examples of how its offerings support climate adaptation and resilience. Finally, it monitors its Scope 1-2 emissions as well as emissions from associated financing activities (Scope 3 category 15) and business travel.

The financial institution identifies material sustainability impacts across its value chain but could provide more detail on the criteria and evidence used for their identification and prioritisation. Although third-party assurance has been performed, it is unclear whether targets are included. Furthermore, there is an opportunity for the financial institution to disclose a commitment to refrain from using lobbying and political engagement to influence adverse sustainability outcomes.

While the financial institution has a roadmap for biodiversity, a strategy for nature protection and restoration covering priority sectors/areas is recommended. The institution discloses the share of its corporate investment portfolio impacting nature but could also refer to total provision of products, services and capital linked to priority sectors and areas representing their highest negative impact on nature. Although it states that some investments in climate solutions have co-benefits for biodiversity, the aggregate amount of products, services and capital nature-positive solutions is unspecified. Moreover, while a time-bound target for climate solutions is stated, the specific share devoted to climate mitigation remains unclear.

Recommendations include disclosing the breakdown of clients by income group, processes to avoid divestment from low-income countries, risk assessment processes related to ILO fundamental rights, and mitigation strategies for identified risks, as well as identifying social risks associated with the net zero transition.

This scorecard refers to information in English which was publicly available by July 15 2024. AuM and Total assets are stated in USD for comparability and have been calculated based on reported local currency values multiplied by applicable IMF currency converter values.