[Full response attached]

We welcome the report from Fair Finance and recognize the important issues they highlight. Investors are in part dependent on these reports to better access information on companies, especially in high-risk countries such as Qatar, and to further calibrate how they prioritise risks in their investments.

Storebrand has been aware of the condition of workers and especially migrant workers in Qatar and other Gulf countries for several years and has taken measures to avoid and mitigate our exposure to salient risks in line with the UNGPs, although this is not reflected adequately in the report.

We appreciate the report's acknowledgement of our policies and due diligence procedures covering these issues. Our policies not only cover these issues, but also show how we as investors conduct human rights due diligence to identify, assess, address, and mitigate human rights risk in our portfolios by referencing the UN Guiding Principles for Business and Human Rights, OECD Guidelines for Institutional investors, Norwegian law and EU regulation requiring human right risk assessments.

How we work

We identify, manage and mitigate actual and potential adverse impacts by using several methods. These are the main ones:

1. Continuously monitoring our investments for controversies in breach of the Storebrand Standard (minimum requirements to companies to be invested in), conducting reactive engagements and excluding companies where the breach does not cease after engagement efforts. Please see full list of exclusions covering human rights in general (labour rights, gender equality or indigenous rights to name a few) but also war and conflict zones, such as occupied territories.
2. Assessing specific Principal Adverse Impacts within our investments as required by the EU Sustainable Finance Disclosure Regulation. [...]
3. Mapping portfolios to identify industries with largest investment exposure against salient human rights risks inherent to these industries and prioritisation of engagement to mitigate the risk.

[...]

How we have addressed Qatar

Storebrand scores poorly in this report due to lack of engagement with 8 international companies Storebrand is invested in, of a total of 16 identified with operations in Qatar by the report.

As mentioned above, Storebrand has been aware of the condition of workers and especially migrant workers in Qatar and other Gulf countries for several years. [...] Therefore, during our human rights diligence of our portfolios connected to country risk, Qatar and other Gulf Countries were flagged as high risk.

Considering the 'state-institutionalised risk' for human rights abuses in Gulf countries, Storebrand has decided so far, to withhold investing in these countries' sovereign bonds, state-owned companies or domiciled companies, in order to mitigate the risk of contributing to severe human rights abuses. This is also the case for Qatar. [...]

We assessed the most salient human rights risks to be linked to the state, state-owned and domicile companies. This risk was mitigated in Gulf countries, including Qatar, by avoiding investing directly in these countries, and their state-owned or domicile companies. We also assessed our human risk exposure in Qatar via international companies in comparison to our total exposure in other countries and sectors for severe human rights violations. However, this does not mean that we did not see a risk of international companies also being exposed to these risks, but we assessed it as lower, at least for their own core operations, not at suppliers or sub-contractors from Qatar. (We do not provide loans or underwritings for construction projects.)

We therefore chose to mitigate our risk through avoiding investments in the state of Qatar, its state-owned and Qatar-domiciled companies, and rather prioritise our proactive engagement with companies where we have larger holdings in other sectors also exposed to similar issues such as forced labour, poor working and wages conditions. In these proactive engagements we could collaborate with other investors for more leverage in other geographical regions and over longer periods of time to increase the possibilities for more positive impact...