Norges Bank Investment Management(NBIM) response to the Business & Human Rights Resource Centre, 11 July 2024:

"Norges Bank Investment Management (NBIM) response to the statement from the UN Experts on arms transfers to Israel

Norges Bank Investment Management (NBIM) manages the Government Pension Fund Global with a mission to safeguard and generate wealth for future generations. ...We align our practices with the UN Guiding Principles and other relevant international standards.

As a responsible investor, we have expectations towards companies across a range of sustainability topics. These formulate how companies should conduct their business to identify, mitigate, and prevent adverse environmental and social outcomes. ...We conduct ongoing due diligence to meet our commitments as a responsible investor. More details about our work on responsible investment can be found in our 2023 Responsible Investment report and on our webpages.

In our expectations on human rights, we stipulate that companies should develop policies to ensure respect for human rights and comply with the UN Guiding Principles on Business and Human Rights. Companies should identify salient human rights risks, and integrate actions into their strategy and risk management to handle, mitigate, and prevent human rights violations.

When conflicts break out, risks of adverse human rights impacts are increased. In these circumstances, we expect heightened human rights due diligence from companies, in alignment with the UN Guiding Principles.

We have implemented systems and screens to monitor sustainability-related risks in our portfolio, including on human rights in high-risk environments. The ongoing conflict in Gaza is an example of a situation when enhanced due diligence by companies is required. When made aware of risks or issues, we consider the tools we have at our disposal to address them, including through divestment, engagement and voting.

As part of our own enhanced due diligence, we have had a targeted engagement with companies operating in conflict-affected and high-risk areas about their human rights management. Since 2020, we have engaged with 29 companies as part of this dialogue. This includes companies with operations linked to the Occupied Palestinian Territories. ...We track and communicate the results of this and our other thematic dialogues in our 2023 Responsible Investment report.

Beyond our active ownership activities, the independent Council on Ethics for the Government Pension Fund Global evaluates and makes recommendations on whether the fund’s investments are aligned with the fund’s Ethical Guidelines. ...The Council on Ethics monitors the portfolio for companies whose operations may be in breach of the Guidelines. Over the years, multiple companies have been placed under observation or excluded from the fund’s investment universe on the basis of these criteria. Some of these decisions have related to business activities on the occupied Palestinian territories. A full list of exclusions and observations is publicly available on NBIM’s webpage. The Council’s recommendations are published on their webpage.

As a responsible investor, we are committed to respect human rights in our activities. As the state of conflicts change, we will continue to monitor and use our leverage in line with our investment framework and due diligence processes."