Amundi Asset Management response to the Business & Human Rights Resource Centre, 16 July 2024:

We thank you for the opportunity to share actions taken by Amundi to ensure that our capital and business operations are not linked or contributing to violations of international human rights and humanitarian laws, and measures taken towards our investee companies in relation to direct or indirect transfer of arms, munitions and other military equipment to Israel.

Our strong commitment to responsible investment and our approach to human rights are set out in a dedicated policy, which is part of our Global Responsible Investment Policy... (https://www.amundi.com/institutional/responsible-investment-policies-reports-3). Our responsible investment policy is in line with the UN Global Compact principles and the UN Guiding Principles on Business and Human Rights, we recognize the need to respect the principles set up by the International Bill of Rights and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work.

Amundi's Global Responsible Investment Policy excludes issuers operating in certain weapons sectors, with a particular impact on defence companies... Moreover, Amundi restricts investments in nuclear weapons companies involved in the production of core components of the nuclear weapon or dedicated components.

Beyond exclusions, as a responsible asset manager, we aim to assess how investees take into account human rights and address human rights abuses in their operations, relying on internal research tools, and on our proprietary ESG rating tool that assesses issuers using available human rights data from our data providers.

Amundi considers that companies -- in all sectors (including defence activities) -- need to develop a comprehensive strategy to ensure respect for human rights principles both in their direct and indirect operations, throughout their value chain. Amundi’s Human Rights approach focuses on dialoguing with corporates on the protection and promotion of respect for human rights by ensuring that companies are taking the steps needed to identify salient human rights risks within their global operations, prevent abuses to occur, and provide or advocate for effective remediation when issues are identified. When an issuer demonstrates severe and repeated violations without appropriate remediation, and for issuers that have faced controversies with poor remediation plans or for which engagement has not borne fruit, Amundi can use escalation through voting, and will adjust its ESG rating, leading to a potential exclusion when the issuer is clearly deemed to be in breach of the UN Global Compact. With respect to conflict-affected contexts, we endeavour to identify controversial involvement in such settings through our research and controversy monitoring processes. Where relevant, we encourage companies to adopt heightened human rights due diligence and/or downstream human rights due diligence. In cases where our analysis suggests involvement that may put companies in breach of international norms, we initiate engagement leading to potential exclusion from our actively managed portfolios and ESG ETFs and index funds. Additionally, we engage with stakeholders and subject matter experts to develop recommendations for companies exposed to conflict-related risks, and with data providers to enhance the provision of information on human rights risks, including information on conflict-affected areas.

For the defence sector, we recognise that suppliers of components for aerospace and defence (A&D) are particularly exposed to human rights risks in conflict-affected and high-risk areas. Consequently, Amundi has started engaging with A&D companies since 2021 to better assess human rights risks exposure and encourage them take concrete actions to prevent and address issues should they occur.

Where risks associated with the issuer are high and engagement is not progressing in a satisfactory manner, escalation tools may be applied in line with our Global Responsible Investment Policy. This process can eventually lead to exclusion from our actively managed portfolios and ESG ETFs and index funds.

Finally, in order to enhance risk prevention, and as part of its commitment to preventing unethical, criminal and delinquent behaviour and its legal obligations in this area, Amundi has set up a whistleblowing mechanism available to our stakeholders. This mechanism makes it possible to support third parties wishing to exercise their right to alert in accordance with the law. It enables the reporting of alerts relating to, among other areas, human rights, health and safety or the environment. At present, as a large institutional investor, where possible, we seek to enable remedy for stakeholders affected by our investee companies through company engagement.