Aktie-Ansvar UN Global Compact Communication on Progress 2021

Participant
Published
  • 2021/12/14
Time period
  • December 2020  –  December 2021
Format
  • Stand alone document – Basic COP Template
Differentiation Level
  • This COP qualifies for the Global Compact Active level
Self-assessment
  • Includes a CEO statement of continued support for the UN Global Compact and its ten principles
  • Description of actions or relevant policies related to Human Rights
  • Description of actions or relevant policies related to Labour
  • Description of actions or relevant policies related to Environment
  • Description of actions or relevant policies related to Anti-Corruption
  • Includes a measurement of outcomes
 
  • Statement of continued support by the Chief Executive Officer
  • Statement of the company's chief executive (CEO or equivalent) expressing continued support for the Global Compact and renewing the company's ongoing commitment to the initiative and its principles.

  • Stockholm, 14 December 2021

    To our stakeholders:

    I am pleased to confirm that Aktie-Ansvar reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

    In this annual Communication on Progress we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

    Aktie-Ansvar is one of Sweden's oldest fund companies. Aktie-Ansvar was founded in 1965 with a strong connection to the sobriety movement and the social responsibility that the movement stood for. The first fund, Aktie-Ansvar Aktiefond, was the first explicitly ethical fund in Sweden. Ever since Aktie-Ansvar is a fund company with a clear set of values that is based on active management and responsible investments. We do not invest in companies operating in industries that are incompatible with this value base. The company excludes investments in weapons, gambling, tobacco, alcohol, narcotic drugs (incl. cannabis), pornography and fossil fuels as well as companies that violates international conventions based on the UN Global Compact in the areas of human rights, labor law and corruption.

    Our investors should feel confident that their funds are invested responsibly, with due regard to ethics and sustainability, and based on sound and well-founded analysis.

    From the outset, Aktie-Ansvar’s investment philosophy had a clear ethical focus which resulted in exclusion of investments in companies active in the alcohol, weapons and tobacco industries. Based on a stable set of values, the company has continuously developed its work with responsible investments as the world around us has evolved with new conditions and new challenges.

    The core of Aktie-Ansvar's values has always been to safeguard social vulnerability and human rights. There was also an environmental debate in 1965, but the greenhouse gas problem was still unknown. As the world has evolved, it has become clear how different types of emissions affect the climate. Based on Aktie-Ansvar’s values, the company has chosen to gradually relate to global warming by joining UNPRI, imposing exclusion criteria for fossil fuels and implementing a positive bias of sustainable alternatives. We have also signed the Net Zero Investment Manager initiative.

    During 2021 Aktie-Ansvar made a thorough review of its Policy for responsible investments. This was partly as a result of joining the UN Global Compact, but also as a result of adapting to new legislation and updating our values and how we approach them from an investment perspective as the world evolves. Ensuring compliance with UN Global compact and UNPRI was a key focus for the updated policy.

    Aktie-Ansvar has also developed a new Code of conduct to ensure compliance from business partners.

    During the year Aktie-Ansvar has made its utmost to act as responsible owners. We adopted a new set of Principles of shareholder engagement and a new Ownership governance policy. During 2021 the company have participated (and voted) at shareholder meetings corresponding to 78% of equity assets under management.

    Sincerely yours,

    Martin Abrahamson
    CEO
    Aktie-Ansvar

Human Rights
  • Assessment, policy and goals
  • Description of the relevance of human rights for the company (i.e. human rights risk-assessment). Description of policies, public commitments and company goals on Human Rights.

  • Human rights have been a central part of Aktie-Ansvar’s core values since the company was founded in 1965 and we strongly support the Universal Declaration of Human Rights.

    Aktie-Ansvar’s code of conduct clearly states that the company considers and acts actively to counteract risks of human rights being violated. Aktie-Ansvar does not tolerate any form of discrimination or harassment and takes human rights into account in all business decisions.

    Aktie-Ansvar’s policy for responsible investments commits to the ten principles stated in UNPRI in the investment processes of its mutual funds and in all investment decisions. The policy further commits to the ten fundamental principles of Global Compact.

    Aktie-Ansvar's Policy for responsible investments prohibits investments in companies that violate international standards or agreements. This includes companies on sanction lists published of U.S. Pat. Office of Foreign Assets Control (“OFAC”), UN Security Council and European Union. In those cases other leading asset management organizations published relevant analyzes that are applicable to Aktie Ansvar's investment principles, these are also taken into account. That is, Aktie-Ansvar’s Policy for responsible investments prohibits investments in companies that violates the international declaration regarding human rights.

    The human rights related risks in Aktie-Ansvar’s daily business is assessed as low. The main risks are within the asset management part of the business. While Aktie-Ansvar’s mutial funds only invest in regulated markets where human rights violations are considered to be at a very low level, the companies we invest in can have operations anywhere globally and may have exposure to human rights violations. This is a key factor in Aktie-Ansvar’s fundamentally driven investment process. Our aim is to do a thorough analysis of every company we invest in, not only from a financial point of view but also to comply with our policy for responsible investments.

    During 2021 Aktie-Ansvar has had no incidents related to human rights and that is the goal also for 2022.

  • Implementation
  • Description of concrete actions to implement Human Rights policies, address Human Rights risks and respond to Human Rights violations.

  • The CEO is responsible for the protection of Human Rights within the company. The fund managers of the mutual funds are responsible for detecting and analysing human rights violations among the portfolio companies on the basis of Aktie-Ansvar’s Policy for responsible investments. Aktie-Ansvar’s function for risk control has a responsibility for second line control.

    Aktie-Ansvar has a clearly defined due diligence process of all counterparties where they must comply with Aktie-Ansvar’s code of conduct. In addition to this, Aktie-Ansvar’s fund managers interacts with companies that we invest in or are considering to invest in when they see human rights related risks.

  • Measurement of outcomes
  • Description of how the company monitors and evaluates performance.

  • Aktie-Ansvar’s asset management organisation utilizes fundamental investment analysis combined with a set of screening tools to ensure compliance with the Policy for responsible investments. We work with ESG analysis as an integral part of the investment process and it can play a crucial role in investing in individual securities. In addition to the investment team’s in-depth analysis, Aktie-Ansvar’s risk control function performs independent (second line) post investment screening to ensure compliance. The results are reported to the board.

    If Aktie-Ansvar discovers that its code of conduct has been breached by a counterparty, a discussion is initiated with the counterparty and the situation is carefully analysed. If Aktie-Ansvar determines that the solution proposed by the counterparty is unsatisfactory, the contract or business relationship may be terminated.

    Upon detection of an incident in a portfolio company (i.e. a direct investment in individual stocks or fixed income instruments) Aktie-Ansvar follows a defined process. The first step is for the manager to gather as much information as possible about the incident. This can be done through direct contact with the company in question or through contact with analysts with whom Aktie-Ansvar has partnerships, but also through various sources of information. Once sufficient information has been gathered, the fund manager will contact the company in question to discuss the incident and, in some cases, to request improvements. If the improvement requirements are not met within a reasonable time, the fund manager must decide whether or not the investment is suitable. In some cases, the fund manager may dispose of the investment if it is considered too risky to keep the company in the portfolio.

    Examples of interactions within our investment universe during the year:

    • Our fixed income team was in contact with a European computer games company, to which our funds lend money, following an acquisition where the acquired company had games with content that could be considered explicit (bordering on pornography). The company clearly stated that it would modify or discontinue such games to avoid explicit content.

    • Our equity team have had discussions with a large European pulp and paper company regarding their export of pulp for viscose production. The company announced that it will stop producing so-called dissolving mass and has since stopped sending cellulose to Xinjiang. The background to this work is reports from a Hong Kong-based newspaper that the company's cellulose is processed into viscose in factories near "retraining camps".

    Aktie-Ansvar has a screening system supporting fund managers and second line risk control in analyzing and monitoring Human rights risks and violations.

    Should there be any violations of the policy these are reported to the board. There have been no violations with respect to the area of Human Rights in the past reporting period.

Labour
  • Assessment, policy and goals
  • Description of the relevance of labour rights for the company (i.e. labour rights-related risks and opportunities). Description of written policies, public commitments and company goals on labour rights.

  • Aktie-Ansvar has adopted several policies to insure internal compliance. This includes a Policy for work environment (states how to handle crisis, rehabilitation and a prohibition for discrimination) and a Policy for work safety representative.

    Aktie-Ansvar’s code of conduct requires business partners to adhere to the company’s principles on labour. The code of conduct clearly states that the company strives to counteract risks of labour law being violated. Aktie-Ansvar rejects forced labour and child labour as well as the suppression of the right of association and collective bargaining. Aktie-Ansvar has policies that clarify employees' rights, responsibilities, compensation, benefits and that aim to counteract discrimination in recruitment and work tasks.

    Aktie-Ansvar has a clearly defined due diligence process for all counterparties where they must comply with Aktie-Ansvar’s code of conduct. In addition to this, Aktie-Ansvar’s fund managers interacts with companies that we invest in or are considering to invest in when they detect major risks of labor law violations.

    Aktie-Ansvar’s Policy for responsible investments prohibits investments in companies that violate international standards or agreements. This includes companies on sanction lists published of U.S. Pat. Office of Foreign Assets Control (“OFAC”), UN Security Council and European Union. Where other leading asset management organizations have published relevant analyzes that are applicable to Aktie-Ansvar's investment principles, these are also taken into account. That is, Aktie-Ansvar’s Policy for responsible investments prohibits investments in companies that violates the UN Global compact principles on Labour.

    Aktie-Ansvar’s asset management organisation utilizes fundamental investment analysis combined with a set of screening tools to ensure compliance with the Policy for responsible investments. We work with ESG analysis as an integral part of the investment process and it can play a crucial role in investing in individual securities. In addition to the investment team’s in-depth analysis, Aktie-Ansvar’s risk control function performs independent (second line) post investment screening to ensure compliance. The results are reported to the board.

    The risk of breaches of the Global Compact principles on labour in the daily business is assessed as low. The main risks are within the asset management part of the business. While Aktie-Ansvar’s mutual funds only invest in regulated markets where risks of labour law violations are considered to be at a very low level, the companies we invest in can have operations anywhere globally and may have exposure to companies that violates the Global Compact principles on labour. This is a key factor in Aktie-Ansvar’s fundamentally driven investment process. Our aim is to do a thorough analysis of every company we invest in, not only from a financial point of view but also to comply with our policy for responsible investments.

    During 2021 Aktie-Ansvar has had no incidents related to the Global Compact principles on labour and that is the goal also for 2022.

  • Implementation
  • Description of concrete actions taken by the company to implement labour policies, address labour risks and respond to labour violations.

  • Aktie-Ansvar has adopted policies to insure internal compliance. This includes a Policy for work environment (states how the health and safety of all employees is ensured, how to handle crisis, rehabilitation and a prohibition for discrimination) and a Policy for work safety representative. These policies are easily accessible for all employees.

    All employees have a wellness and health benefit. Through our occupational health services we are also provided with health services and different kinds of training for employees.

    Regarding allocation of responsibilities for the protection of labour rights within our organisation we also have a health and safety representative who performs recurring checks.

    Consultations with employees are performed through employee surveys, one-on-one talks with CEO and staff meetings. The employee surveys and the whistleblowing function (anonymous) also contributes to prevent discrimination of all kinds.

    Aktie-Ansvar also has a Policy against discriminatory treatment and harassment.

  • Measurement of outcomes
  • Description of how the company monitors and evaluates performance.

  • Demographics of management and employees by diversity factors are considered upon new hires.

    After the health and safety representative have performed one of his/hers recurring checks the employees and the management are provided with a report. If shortcomings or risk for shortcomings are identified in the reports these are dealt and measured with.

    Periodic review of results from for example the employee surveys and the whistleblowing function are performed by senior management. If shortcomings or risk for shortcomings are identified in the employee surveys and/or through the whistleblowing function these are dealt and measured with.

    Upon discovery of a breach of Aktie-Ansvar’s code of conduct by a counterparty, a discussion with the counterparty is initiated and the situation is thoroughly analyzed. If Aktie-Ansvar determines that the proposed resolution by the counterparty is unsatisfactory, the contract or business relation may be discontinued.

    Upon detection of an incident in a portfolio company (i.e. a direct investment in individual stocks or fixed income instruments) Aktie-Ansvar follows a defined process. The first step is for the manager to gather as much information as possible about the incident. This can be done through direct contact with the company in question or through contact with analysts with whom Aktie-Ansvar has partnerships, but also through various sources of information. Once sufficient information has been gathered, the fund manager will contact the company in question to discuss the incident and, in some cases, to request improvements. If the improvement requirements are not met within a reasonable time, the fund manager must decide whether or not the investment is suitable. In some cases, the fund manager may dispose of the investment if it is considered too risky to keep the company in the portfolio.

    Our asset management team interact with companies that we are invested in or are considering investing in. One example of interactions within our investment universe during the year is from our equity team which interacted with a European car company prior to its IPO, and one of our fund’s participation in the IPO, regarding their policy regarding subcontractors as many are in China. The company’s main owner, who operates similar operations in China, has been singled out in the media as customers of companies that use dubious labor. We received a detailed answer on how the European car company handles the issue which we deemed as satisfactory.

Environment
  • Assessment, policy and goals
  • Description of the relevance of environmental protection for the company (i.e. environmental risks and opportunities). Description of policies, public commitments and company goals on environmental protection.

  • Aktie-Ansvar’s code of conduct requires business partners to adhere to Aktie-Ansvar’s principles on sustainability. The code of conduct clearly states that the company works actively for sustainable development, both in its own operations and through influence and collaboration through other organisations. Aktie-Ansvar takes environmental aspects into account in all business decisions and thus works to strengthen environmental awareness.

    The environment is a central part of Aktie-Ansvar’s Policy for responsible investments and focus on how to deal with fossil fuels in the investment process. Fossil fuels are the largest source of greenhouse gas emissions, which contribute to global warming. Aktie-Ansvar has therefore decided to exclude investments related to fossil fuels.

    The restriction is aimed at producers and distributors of fossil fuels. The definition of fossil fuels refers to oil, gas, coal, oil sands and shale oil/gas. Producers refer to companies active in the extraction, exploration or refining of fossils fuels. Distributors refer to companies with wholesale operations or companies with sales directly to the end customer. Aktie-Ansvar applies zero tolerance for the Arctic gas/oil drilling and coal mining. This applies to both production and exploration.

    A basic principle for Aktie-Ansvar’s asset management is that companies with sustainable business models and sustainable activities that demonstrate social responsibility in a longer perspective constitute better investments than less sustainable companies. This principle means that we reward the more sustainable investment in our funds' investment processes in cases where our fund managers' investment analysis finds that it is the best investment for our funds’ unit holders. In case of two investment options that are equivalent from a financial point of view, we actively choose the more sustainable alternative, i.e. all other things being equal, the manager should invest in the more sustainable option.

    In addition to UNPRI and UN Global compact, Aktie-Ansvar has joined the Net Zero Asset Manager's initiative to commit to achieving net zero emissions. Aktie-Ansvar has been working with responsible investments since 1965. Signing the Net Zero Asset Manager's initiative means that we take another important step in that work. By implementing the initiative, we promise to do our part to create the conditions for achieving net zero emissions by 2050 and to set intermediate goals for reducing emissions already before 2030. Our goal is that through continued collaboration with portfolio companies and industry colleagues, we will create the right opportunities for future generations.

    The environmental footprint of Aktie-Ansvar is assessed to be very low. However, the mutual funds that Aktie-Ansvar manages invests in companies where the environmental footprint could be considerable. Aktie-Ansvar has therefore, as stated above, developed a Policy for responsible investments with a clear focus on how to deal with fossil fuels in the investment process. The equity and fixed income funds managed by Aktie-Ansvar all scores well when assessed by MSCI ESG ratings. Assessing the environmental footprint is a key factor in Aktie-Ansvar’s fundamentally driven investment process. Our aim is to do a thorough analysis of every company we invest in, not only from a financial point of view but also to comply with our policy for responsible investments.

    Our environmental goals for 2022:
    - to set targets in line with the Net Zero Investment Managers Initiative for at least one of our mutual funds.
    - to publish carbon footprint for all funds managed by Aktie-Ansvar given that data with satisfactory quality becomes available.
    - to further improve our investment processes to manage environmental challenges.

  • Implementation
  • Description of concrete actions to implement environmental policies, address environmental risks and respond to environmental incidents.

  • The CEO of Aktie-Ansvar is also Head of sustainability and monitors the processes that ensures compliance with the Policy for responsible investments on a continuous basis. Violations are reported to the Aktie-Ansvar board of directors.

    Aktie-Ansvar follows Garantum group’s policies on business travel and environment.

    Aktie-Ansvar’s asset management organisation utilizes fundamental investment analysis combined with a set of screening tools to ensure compliance with the Policy for responsible investments. We work with ESG analysis as an integral part of the investment process and it can play a crucial role in investing in individual securities. In addition to the investment team’s in-depth analysis, Aktie-Ansvar’s risk control function performs independent (second line) post investment screening to ensure compliance. The results are reported to the board.

    Examples of interactions with cooperating organizations during the year:
    • On 2021-09-23, Aktie-Ansvar in cooperation with UNPRI and 53 other signatories, signed an investor statement in support for EU Corporate Sustainability Reporting Directive (CSRD). The CSRD proposal is a prime example of policy coherence between investor and corporate disclosure obligations, building an end-to-end disclosure framework that will enable investors to scale up their contribution to the EU Green Deal and wider sustainability goals.
    • Ahead of COP26, Aktie-Ansvar signed The Investor Agenda 2021 calling on all governments to increase their climate policy ambition with # COP26 in November. Investor signatories to the statement were calling on all governments to undertake five priority actions before the 26th United Nations Climate Conference in Glasgow in November (COP26):
    1. Strengthen their NDCs for 2030 before COP26, to align with limiting warming to 1.5-degrees Celsius and ensuring a planned transition to net-zero emissions by 2050 or sooner.
    2. Commit to a domestic mid-century, net-zero emissions target and outline a pathway with ambitious interim targets including clear decarbonization roadmaps for each carbon-intensive sector.
    3. Implement domestic policies to deliver these targets, incentivize private investments in zero-emissions solutions and ensure ambitious pre-2030 action through: robust carbon pricing, the removal of fossil fuel subsidies by set deadlines, the phase out of thermal coal-based electricity generation by set deadlines in line with credible 1.5-degrees Celsius temperature pathways, the avoidance of new carbon-intensive infrastructure(e.g. no new coal power plants) and the development of just transition plans for affected workers and communities.
    4. Ensure COVID-19 economic recovery plans support the transition to net-zero emissions and enhance resilience. This includes facilitating investment in zero-emissions energy and transport infrastructure, avoiding public investment in new carbon-intensive infrastructure and requiring carbon-intensive companies that receive government support to enact climate change transition plans consistent with the Paris Agreement.
    5. Commit to implementing mandatory climate risk disclosure requirements aligned with the Task Force on Climate-related Financial Disclosures (TCFD) recommendations, ensuring comprehensive disclosures that are consistent, comparable, and decision-useful.

    In addition to cooperation with other organisations, the Aktie-Ansvar asset management team interacts with companies within its investment universe and other stakeholders.

    Examples of interactions within our fixed income team:
    • At the beginning of 2021, we joined the initiative to promote and demand better ESG transparency among Nordic High Yield issuers, among other things by requesting answers to a specific question battery in the ESG area before we participate in the Nordic High Yield companies' bond issues.
    • We engaged with a major ETF provider in the development of an ESG Asia High Yield ETF. Aktie-Ansvar was a speaking partner and made contributions to the design and scope of the exclusion criteria to be applied in the product the aim being to have the criteria as much aligned as possible to our own criteria.
    • We have asked a number of companies about how they prepare for SFDR and for the taxonomy.
    • We have participated in issues of green and sustainability-linked bonds.
    • We have had an extensive dialogue with our system and data providers regarding the lack of coverage of certain companies' ESG data in their database.

    Examples of interactions within our equities team:
    • Following an event which also was reported on in Swedish media, we held a meeting with the management of a company that processes chickens for food about their process for killing chickens and the presence of campylobacter in consumer products. The incident led to the CEO resigning.
    • After an in-house analysis, we have taken a more restrictive view of the salmon farming companies which led us to sell our holding in a Norwegian salmon farming company. Over the years, it has been shown that salmon farming at sea in open bags has a huge impact on the environment and the wild salmon stock. Some countries, such as Argentina, have banned the cultivation of open bags. Canada and Sweden have also banned farming in some places as it threatens wild salmon. The problem is eutrophication and various diseases that affect the farmed salmon and spread to the wild.
    • A second concern with salmon farming is the salmon feed which contains soy. The soy mainly comes from Brazil which may contribute to rainforest harvesting to make plantations. Only two of the Norwegian salmon farmers have committed to cut off all connections with companies that can be linked to rainforests harvesting. The seven largest have not made any commitments.

    Examples of interactions within our asset allocation team are:
    • Aktie-Ansvar’s allocation fund invests in index-based ETF products. A major problem with investing in index products is that the portfolio manager's ability to influence the components of a broad index is very limited. The situation is further complicated by the fact that the underlying index, and hence the index products, continuously change holdings. This usually happens quarterly. An index that contains good (bad) companies today may contain bad (good) companies after such changes. An example from a fund holding of Aktie-Ansvar’s global allocation fund Saxxum Aktiv is an ETF investing in global value shares. This ETF had an MSCI ESG-rating which during the year fluctuated between BBB and AA, despite the fact that the strategy was unchanged.

    There are indices and products that focus on ESG or some specific theme such as the climate or the green transition. A problem is that the investor is then often forced to give up fundamental or other factors that are important. Aktie-Ansvar’s strategy, based on the policy for responsible investments, is, all other things being equal, the fund will choose the product with the best ESG ranking or similar.

    During the year, Aktie-Ansvar has had extensive discussions with all EFT managers that we invest in influencing them on ESG matters in order to improve the ESG profile of the products that we invest in. We have also had an extensive dialogue with all our system and data providers to improve the quality of ESG data.

  • Measurement of outcomes
  • Description of how the company monitors and evaluates environmental performance.

  • Upon discovery of a breach of Aktie-Ansvar’s code of conduct by a counterparty, a discussion with the counterparty is initiated and the situation is thoroughly analyzed. If Aktie-Ansvar determines that the proposed resolution by the counterparty is unsatisfactory, the contract or business relation may be discontinued.

    The CEO of Aktie-Ansvar is also Head of sustainability and monitors the processes that ensures compliance with the Policy for responsible investments on a continuous basis. Violations are reported to the Aktie-Ansvar board of directors.

    Aktie-Ansvar’s asset management organisation utilizes fundamental investment analysis combined with a set of screening tools to ensure compliance with the Policy for responsible investments. We work with ESG analysis as an integral part of the investment process and it can play a crucial role in investing in individual securities. In addition to the investment team’s in-depth analysis, Aktie-Ansvar’s risk control function performs independent (second line) post investment screening to ensure compliance. The results are reported to the board.

    Upon detection of an incident in a portfolio company (i.e. a direct investment in individual stocks or fixed income instruments) Aktie-Ansvar follows a defined process. The first step is for the manager to gather as much information as possible about the incident. This can be done through direct contact with the company in question or through contact with analysts with whom Aktie-Ansvar has partnerships, but also through various sources of information. Once sufficient information has been gathered, the fund manager will contact the company in question to discuss the incident and, in some cases, to request improvements. If the improvement requirements are not met within a reasonable time, the fund manager must decide whether or not the investment is suitable. In some cases, the fund manager may dispose of the investment if it is considered too risky to keep the company in the portfolio.

Anti-Corruption
  • Assessment, policy and goals
  • Description of the relevance of anti-corruption for the company (i.e. anti-corruption risk-assessment). Description of policies, public commitments and company goals on anti-corruption.

  • Aktie-Ansvar has an Ethic policy including rules on receiving gifts etc in order to avoid corruption and bribery. The Ethic policy further describes how the company and its employees aims to counteract corruption and bribery.

    Aktie-Ansvar has a Policy for anti-money laundering and makes an annually assessment of the risk of the own business being used for money laundering, including the risk of staff being threatened or exposed to extortion.

    Aktie-Ansvars policy for responsible investments states a prohibition to invest in companies that permit corruption and bribery.

    Aktie-Ansvar has a code of conduct that urges its business partners to adhere to the Global Compact anti-corruption principles. The code of conduct states that Aktie-Ansvar has zero tolerance for corruption, bribery and extortion. The company has processes in place to assess and mitigate the risks of corruption and bribery in its operations and has procedures in place in the event that an employee is subjected to bribery or extortion.

    Aktie-Ansvar is member of industry organisations whose missions are to work for good ethics and a high level of trust in the securities market.

  • Implementation
  • Description of concrete actions to implement anti-corruption policies, address anti-corruption risks and respond to incidents.

  • Aktie-Ansvar systematically performs recurring risk assessments regarding AML and terrorist financing. Aktie-Ansvar has adopted policies, a code of conduct and internal instructions to insure internal compliance. This includes a Policy for AML/anti-terrorist financing, instructions for KYC, transaction monitoring and for tightening measures. The company conducts annual compulsory training for employees in risk assessment regarding anti money laundering which also includes risk indicators for corruption and bribery.

    Aktie-Ansvar also has a grievance mechanisms through its whistleblowing function.

    On the basis of Aktie-Ansvar’s code of conduct, the company assess compliance by business partners in connection with an annual due diligences process.

    Aktie-Ansvar’s fund managers assess a potential investment and its risk exposure to corruption and bribery before an investment decision and during the holding period of the investment. Hence, asset management team applies criteria specified in the Policy for responsible investments when excluding an investment that is identified as unacceptable due to its connection with corruption and bribery.

  • Measurement of outcomes
  • Description of how the company monitors and evaluates anti-corruption performance.

  • The assessment of the risk of the own business being used for money laundering is low due to the products that the business provides, its customers, geographical areas and channels for distribution.

    Aktie-Ansvar do not operate in any country that is assessed by the Corruption Perceptions Index 2020 (Transparency International) as a high risk of corruption.

    Aktie-Ansvar has incorporated sustainability risk, including anti-corruption and bribery, in the risk management framework. The risk function is independent to the business and is monitoring the stated risk appetite to ensure consistency with anti-corruption commitments. The risk function is reporting the result to the board and CEO.