Nordea

Red Line	Text of policies	Comments	Score
Regulatory requirements
Ensure Legality	Responsible investment policy All Nordea funds are subject to an annual norm-based screening. The screening is used to identify listed companies allegedly involved in breaches of international law, and norms on environmental protection, human rights, labour standards and anti-corruption. Sustainability Policy Nordea recognizes the importance of participating in and supporting international commitments that enable businesses to operate in a more sustainable way. These include: • UN Environmental Program Finance Initiative • UN Global Compact • UN Universal Declaration of Human Rights • UN Guiding Principles on Business and Human Rights • ILO-conventions • OECD Guidelines for Multinational Enterprises • Equator Principles • Paris Pledge for Action in support of COP 21 • UN Convention against Corruption • Rio Declaration on Environment and Development • UN Principles for Responsible Investments	Nordea actively screens its clients on compliance with international laws	partly
No Corruption and Tax Evasion	AML policy Nordea is committed to complying with all applicable AML/CTF laws and regulations in the jurisdictions in which it operates. Code of Conduct 3.2 We comply with laws, regulation, industry standards and internal rules (...) • We are alert to illegal activities by knowing our customers. Responisble investment policy Transparency requirements, both voluntary and mandatory, are being developed requiring companies to disclose information on corporate and ownership structures, on their anticorruption programs, and do country-by-country reporting on taxes and government payments. As investors we demand that business take a proactive approach towards corruption, implement adequate anticorruption measures and improve transparency.	The responsible investment policy requires clients to act against corruption and to be transparent on taxes	partly
Ensure ESIA for mills and plantations	Sustainability Policy Nordea recognizes the importance of participating in and supporting international commitments that enable businesses to operate in a more sustainable way. These include: • Equator Principles	ESIAs are expected to be required when the Eps apply. No requirements for other cases were found	partly
Social requirements
Ensure FPIC	Sustainability Policy Nordea recognizes the importance of participating in and supporting international commitments that enable businesses to operate in a more sustainable way. These include: (...) ILO-conventions	Nordea recognizes the importance of the ILO conventions, thus inlcuding the ILO 169 requirements for FPIC, but this only applies to indigenous peoples.	partly
Respect Human Rights	Code of Conduct: 3.11 We support and respect human rights • We respect fundamental and internationally recognised human rights in all areas of operation and have a responsibility to ensure our business activities do not negatively impact human rights; Responsible Investment Policy We expect companies to obey internationally recognized human rights principles and to prevent and manage its impact on human rights. Human rights related issues includes complicity in human right abuses, modern slavery and child labour, occupational safety and health, the rights of indigenous people and displacement of local communities, freedom of association and collective bargaining and international humanitarian law. Sustainability Policy: Nordea recognizes the importance of participating in and supporting international commitments that enable businesses to operate in a more sustainable way. These include: • UN Environmental Program Finance Initiative; • UN Global Compact; • UN Universal Declaration of Human Rights; • UN Guiding Principles on Business and Human Rights; • ILO-conventions; • OECD Guidelines for Multinational Enterprises; • Equator Principles; • Paris Pledge for Action in support of COP 21; • UN Convention against Corruption; • Rio Declaration on Environment and Development; • UN Principles for Responsible Investments	Nordea expects companies to obey internationally recognized human rights principles	well
Respect Indigenous rights and customary land use rights	Responsible Investment Policy We expect companies to obey internationally recognized human rights principles and to prevent and manage its impact on human rights. Human rights related issues includes complicity in human right abuses, modern slavery and child labour, occupational safety and health, the rights of indigenous people and displacement of local communities, freedom of association and collective bargaining and international humanitarian law.	Nordea recognizes the rights of Indigenous people, but does not mention customary land rights of local communities.	partly
No forced resettlement	We expect companies to obey internationally recognized human rights principles and to prevent and manage its impact on human rights. Human rights related issues includes complicity in human right abuses, modern slavery and child labour, occupational safety and health, the rights of indigenous people and displacement of local communities, freedom of association and collective bargaining and international humanitarian law.	Nordea does not specify which International human rights principles clients must comply with, but this can be assumed to include IFC criteria, which protect partly	partly
Environmental Requirements
No forest degradation and deforestation		No publicly available policies or documentation were found that cover this criteria.	not
Protect endangered species		No publicly available policies or documentation were found that cover this criteria.	not
No high-risk species		No publicly available policies or documentation were found that cover this criteria.	not
No fire		No publicly available policies or documentation were found that cover this criteria.	not
Protect peat		No publicly available policies or documentation were found that cover this criteria.	not
No persistent pollution		No publicly available policies or documentation were found that cover this criteria.	not
Corporate association / scope of the policy
Corporate association / scope of the policy		No publicly available policies or documentation were found that cover this criteria.	not

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