Below is the list of activities excluded from our programme.
- Investments issued by sovereigns and/or corporates, or mainly listed in countries, or related to individuals and/or other entities in a particular country identified and as specified in the United Nations Security Council Sanctions List, the list of high-risk jurisdictions subject to a “Call for Action” identified by the Financial Action Task Force and/or the European Sanctions List.
- Investments issued by companies involved in the manufacturing of controversial weapons and/or essential components or services or through owned entities. These include anti-personnel mines, cluster munitions, chemical, biological weapons, white phosphorus, depleted uranium weapons and nuclear weapons.(2)
- Activities prohibited by national legislation or international conventions relating to the protection of biodiversity resources, or cultural heritage.(3)
- Investments that could have significant adverse risks and/or impacts related to involuntary resettlement or indigenous peoples without prior consent of such peoples.
- Activities subject to international phase out or bans, including production of or trade in products containing Polychlorinated Biphenyls (PCBs); production, placing on the market and use of asbestos fibres(4); production, use of or trade in ozone depleting substances(5) and other substances which are subject to international phase-outs or bans, including pharmaceuticals, pesticides/herbicides, chemicals(6), and other hazardous substances; trade in mercury, mercury compounds, and a large range of mercury-added products(7); production or use of or trade in persistent organic pollutants(8); production or trade in wildlife or wildlife products regulated under the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES).
- Activities relating to the deliberate release of genetically modified organisms (GMO).(9)
- Cross-border trade in waste and waste products, unless compliant with the Basel Convention and the underlying regulations.(10)
- Collection, treatment and disposal of hazardous waste, and waste incineration.
- Alcohol: Production of or trade in alcoholic beverages, excluding beer and wine.
- Tobacco: Investments issued by companies deriving revenue from the production, sales and/or distribution of any traditional tobacco products, as well as tobacco-related products (including without limitation e-cigarettes and next- generation tobacco/nicotine products) and/or tobacco-supporting services (including without limitation filters and smoking halls).
- Energy sector: Investments related to the following activities:
- Coal (thermal and metallurgical), Oil and Gas: prospection, exploration, production, mining, processing (refining, liquefaction, regasification), transport, distribution and storage, provision of supporting products or services for thermal coal extraction, oil and gas; and
- Energy production from fuels: power generation technologies resulting in GHG emissions above 100 gCO2 per kWh of electricity generated, averaged over the lifetime for gas-fired power plants seeking to integrate low carbon fuels and large-scale heat production infrastructure based on unabated oil, natural gas, coal or peat.
- Nuclear energy: production, sales and distribution of uranium extraction, uranium concentration, refining, conversion and enrichment, the production of nuclear fuel structures, the construction and use of nuclear reactors, the treatment of spent nuclear fuel, nuclear decommissioning and radioactive waste management;
- Hydropower: Hydropower plants with a dam height of greater than 15 meters (from the fundament) or 5-15 meters dam height and a water reservoir of more than 3 million m³.
- Biomass:
- Business activities involving the production of bio-liquids or bio-fuels from non-waste sources (for the avoidance of doubt, the PI may invest in biogas or biomass projects).
- Co-firing of biomass with fossil fuels, peat or hazardous waste (including waste wood that has been treated with wood preservation chemicals).
- Sourcing of biomass from primary moist tropical forests or from natural forests.
- Minerals: Extraction of mineral deposits from the deep sea(11), as well as extraction or mining of conflict minerals and metals(12).
- Radioactive materials: Production of or trade in radioactive materials(13), including nuclear reactors and components.
- Conventional weapons and munitions: Investment issued by companies derive any revenue from firearms. It includes manufacturers of firearm weapons such as guns, rifles, and pistols, manufacturers of components and munitions of these weapons and retailers.
- Adult entertainment: Investments issued by companies deriving any revenue from adult entertainment. This includes without limitation producers of adult movies, cinemas that show adult movies, adult entertainment magazines, and the broadcasting of adult entertainment.
- Gambling: Investments issued by companies deriving any revenue from gambling services (such as operation of casinos, lotteries, bookmaking, online gambling, etc.), gambling products (such as slot machines and other gambling devices) or supporting products/services to gambling operations.
- Palm oil: Investments issued by companies deriving more than 5% revenue from extracting, producing or distributing palm oil and that are not members of the Roundtable on Sustainable Palm Oil (RSPO) are excluded. These include companies involved in the upstream (plantations, mills) or downstream (refining/trading) palm oil value chain.
- Forests: Investments issued by companies involved in the conversion of natural forests into plantation. This includes without limitation irrigated forests(14), logging, clear cutting or degradation of (and commercial concessions over) tropical natural forests or high conservation value forests in all regions, as well as the purchase of logging equipment for this purpose.
- Fishing: Unsustainable fishing methods (such as drift net fishing in the marine environment using nets in excess of 2.5 km in length and blast fishing).
- Animals: Animal and human reproductive cloning, as well as activities involving live animals for scientific and experimental purposes, including gene editing and the breeding of these animals.(15)
(1) Internationally recognised standards include without limitation the following:
(2) Relevant international conventions include, without limitation, the Geneva Protocol (1925) (on chemical and biological weapons); the Treaty on the Non-Proliferation of Nuclear Weapons (1968); the Convention on the prohibition of biological weapons (1972); the Convention on Cluster Munitions (2008); Protocol III to the Convention on Certain Conventional Weapons (1980) (on incendiary weapons); the Convention on the Prohibition of Chemical Weapons (1993); the Convention on the Prohibition of Anti-Personnel Mines (Ottawa Treaty) (1997); the Treaty on the Prohibition of Nuclear Weapons (2017).
(3) The underlying risks and impacts must be identified, assessed and systematically monitored throughout the investment cycle. Relevant international conventions include, without limitation, the Convention on the Conservation of Migratory Species of Wild Animals (Bonn Convention); the Convention on Wetlands of International Importance, especially as Waterfowl Habitat (Ramsar Convention); the Convention on the Conservation of European Wildlife and Natural Habitats (Bern Convention); the World Heritage Convention; Convention on Biological Diversity and Protocols.
(4) Commission Regulation (EU) 2016/1005 of 22 June 2016 amending Annex XVII to Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards asbestos fibres (chrysotile).
(5) Ozone depleting substances (ODS) are chemical compounds that react with and remove stratospheric ozone, resulting in holes in the ozone layer. The Montreal Protocol on Substances that Deplete the Ozone Layer lists ODSs and their target reduction and phase-out date.
(6) Based on Regulation (EU) No. 649/2012 of the European Parliament and of the Council of 4 July 2012 concerning the export and import of hazardous chemicals as amended; the United Nations Consolidated List of Products whose Consumption and/or Sale have been Banned, Withdrawn, Severely Restricted or not Approved by Governments; the Convention on the Prior Informed Consent Procedures for Certain Hazardous Chemicals and Pesticides in International Trade (Rotterdam Convention); the World Health Organization Recommended Classification of Pesticides by Hazard.
(7) Regulation (EU) 2017/852 of the European Parliament and of the Council of 17 May 2017 on mercury.
(8) Based on Stockholm Convention on Persistent Organic Pollutants (POPs) as amended in 2009.
(9) Unless in compliance with EU Directive 2001/18/EC and EU Directive 2009/41/EC, and related country legislation, as further amended.
(10) Based on Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal; Regulation (EC) No 1013/2006 of 14 June 2006 on shipments of waste; and Decision C(2001)107/Final of the OECD Council concerning the revision of Decision C(92)39/Final on the control of transboundary movements of wastes destined for recovery operations.
(11) Deep sea is defined as the areas of the ocean below 200 m — The International Seabed Authority and Deep Seabed Mining. United Nations.
(12) Minerals and metals covered by the Regulation (EU) 2017/821 laying down supply chain due diligence obligations for European Union importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected and high-risk areas, as amended.
(13) This does not apply to the purchase of medical equipment, quality control (measurement) equipment and any equipment where the radioactive source is trivial and/or adequately shielded.
(14) Except for temporary watering in the first three years after planting, which is allowed for the seedlings to develop deep rooting systems to ensure high survival rates.
(15) Unless in compliance with (EU) Directive 2010/63/EU as amended by Regulation (EU) 2019/1010 of the European Parliament and of the Council on the protection of animals used for scientific purposes.