Norges Bank Investment Management

In terms of its approach towards impact management, NBIM acknowledges that its financing activities have both positive and negative impacts and it identified and prioritised its impacts through internationally recognised frameworks. The responsibility for sustainability issues within the NBIM lies with the Executive Board. The financial institution has a gender-balanced board of directors where 5 out of 10 members are women. It also has an engagement policy where it describes its approach on sustainability themes and impact topics with investees, including its approach to engagement escalation. NBIM publishes a responsible investment report describing how the engagement policy is applied in practice.

NBIM discloses absolute financed emissions and the underlying data quality and coverage. It discloses the key sectors and companies it has identified as priorities to engage with on climate change, specifically on the topic of alignment with the Paris Agreement. Further, it discloses the aggregate amount of investment it devotes to climate solutions and specifies what these solutions are. NBIM discloses the investment criteria it uses to ensure the protection of nature and biodiversity and provides evidence that it requires its investees to have a strategy addressing their nature- and biodiversity-related impacts.

NBIM describes the process for identifying human rights risks and impacts in its investment activities. It has a grievance mechanism accessible to all workers to raise human rights complaints or concerns. The financial institution discloses the proportion of women in its total direct operations workforce for each employee category. NBIM has a policy prohibiting bribery and corruption and takes steps to identify and address bribery and corruption. It also discloses a global tax strategy.

In terms of its approach to senior leadership accountability, NBIM could link the remuneration of its executive or management teams to additional sustainability performance criteria to diversity targets. The financial institution could also commit to gender equality and women’s empowerment and has an opportunity to disclose the proportion of women in senior leadership roles as well as how it addresses any gender pay gaps.

NBIM has an opportunity to disclose a target to reach net-zero financed emissions by 2050. It could also disclose whether it collectively engages with its investees on the topic of alignment with the Paris Agreement. While NBIM expects its investees to set a 1.5°C-aligned strategy, it has an opportunity to make this a requirement. Further, it could align its climate solutions with internationally recognised frameworks and disclose time-bound targets for them. No evidence was found regarding the NBIM’s approach to fossil fuels that spans across the fossil fuel value chain and across its assets under management, such as the amount or share of finance it directs towards fuels, or its stance on investing in companies with new fossil fuel projects.

NBIM has a publicly available policy statement committing it to respect human rights, but it has an opportunity to extend this commitment to all its activities. Further, while the financial institution provides a grievance mechanism accessible to all stakeholders, it should specify that complainants have the option to identify themselves or remain anonymous. It could also disclose the proportion of its total direct operations workforce for each employee category by age group. To provide transparency on financial inclusivity, NBIM has an opportunity to disclose the amount of investments directed towards low-income developing countries.