Union Investment response to the Business & Human Rights Resource Centre, 9 July 2024:

"Thank you for the opportunity to respond to the recent statement from UN Experts calling on investors and businesses to ensure they are not directly or indirectly involved in arms transfers to Israel. In the context of conflict affected areas, we conduct heightened Human Rights Due Diligence (hHRDD), applying a principled approach to the specific situation and firmly based on human rights and international humanitarian law.

We maintain a robust framework of clear standards and processes meticulously outlined in our Guidelines for Responsible Investment and Human Rights Policy Statement. Beyond observing the relevant applicable laws and regulatory requirements we are guided in our approach of responsible investment by leading national and international standards. These constitute the benchmark for our actions. As an active asset manager, we incorporate the insights derived from our ESG analyses in our securities portfolios. This encompasses:

Exclusion of entities:

Investment universe:

• We do not invest in companies who are involved in manufacturing banned weapons (such as land mines and cluster bombs). Furthermore, our mutual funds must not hold securities of companies directly involved in the manufacture and maintenance of nuclear weapons systems, nor do we invest in such securities, unless these activities are performed on behalf of a legitimate NATO nuclear power in accordance with the Nuclear NonProliferation Treaty and do not exceed minor turnover (< 5% share of turnover). Based upon our exclusion policy, the following entities listed in the recent statement from UN Experts are excluded from our investment universe: BAE Systems, Boeing, General Dynamics, Lockheed Martin, Northrop Grumman, and RTX.
• Issuers may also be excluded from our investment universe in case of grave violations of leading national and international standards, if we are unable to achieve a positive outcome through engagement dialogue with issuers.

Sustainable investment strategies:

For sustainable investment decisions, we continue to apply the fundamental principle that the damage and suffering that can be caused by weapons makes securities of arms manufacturers ineligible for direct investment from an ESG perspective.

Engagement

Engagement is an integral part of sustainable investment, as laid out in detail in our Engagement Policy. It clearly defines our expectations based upon compliance with recognized and established standards and frameworks, such as the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises.

We continue to closely monitor the development in Gaza and will apply our tools for responsible investing accordingly."