Dear Business & Human Rights Resource Centre

We have been made aware of your survey regarding company activity and the private sector response to the war in Ukraine. Unfortunately, we did not receive your enquiry, which is why you have not yet heard from us. However, we would like to inform you of AkademikerPension’s response to Russia’s invasion of Ukraine and our general approach to investments in conflict-affected areas. Below, I have listed

• AkademikerPension is committed to the UN Guiding Principles on Business and Human Rights (UNGP) and the OECD Guidelines for Multinational Enterprises. Our investment practices are aligned with these international standards and respect international humanitarian law.
• Our approach to responsible investing is described in detail in the AkademikerPension’s Policy for Responsible Investments which i.a. covers both human rights, labour rights and investments in conflict-affected areas, as well as how the policy is implemented when investing in different asset classes.
• AkademikerPension has published a position paper on conflict-affected areas.
• The Principles for Responsible Investments (PRI) has published a case study on AkademikerPension’s approach to responsible investment in sovereign bonds.
• As of 24 February 2022, AkademikerPension have excluded Russian sovereign bonds as well as Russian state-owned companies from the portfolio.
• AkademikerPension has actively engaged companies (such as Carlsberg and FLSmidth) to make clear our expectation that they are to assess their risks of contributing to the Russian invasion and perform an enhanced human rights due diligence process as required by the UNGP and the OECD Guidelines. We have engaged companies both through direct dialogue and by addressing these pressing issues publicly in the media and at annual general meetings.
• AkademikerPension has also on many occasions publicly disclosed our position regarding business activities in Russia following the invasion of Ukraine as well as our general approach to responsible investing. I have attached a few articles on the subject (4 in Danish, 1 in English).   

If you have any questions regarding our approach to responsible investment, please do not hesitate to contact me.