NN Group is an international insurance and asset management company, headquartered in the Netherlands. NN became an independent group after it separated from Dutch bank ING in 2014. NN is active in 18 countries. It’s asset manager has €195 billion in assets under management[1]. In 2017, NN took over Dutch insurance company Delta Lloyd[2], which was formerly listed in the Runners-up section of this report.
NN’s defence sector policy recognizes the “indiscriminate effect and the likelihood of civilian consequences” of nuclear weapons. However, the policy only excludes nuclear weapon producers “when those companies are either: (i) domiciled in countries that are not a signatory to the NPT, or (ii) derive a majority of revenues from defence related activities.”[3] Together, these criteria mean that all companies producing nuclear weapons for non-NPT countries are excluded, but other producers are excluded only when they derive a majority of their revenues from defence related activities.
The exclusion applies to most asset management activities of the group, with the exception of clients’ assets managed via discretionary mandates and mutual funds managed externally. However, clients investing through such mandates can choose to implement their own exclusion list or NN Group’ restrictions.
The policy has additional requirements for NN’s assets on own account managed (internally and externally) through fully discretionary mandates. These mandates represent a large majority of NN’s own assets. For these investments, the policy excludes all companies involved in nuclear weapons.[4]
NN makes use of an exclusion list to implement the policy based on research by Sustainalytics. This list is not publicly available.[5]
We commend NN for having a policy restricting investments in producers of nuclear weapons. We recommend NN improve its policy by excluding all nuclear weapon producers, regardless of their location or other activities. The policy should also be expanded to cover all types of investments, including investments on behalf of clients and all externally managed assets. We look forward to engaging with NN, so a strong and comprehensively applied policy may be listed in the Hall of Fame in a future update of this report.
[1] Nationale Nederlanden, “Securing financial futures: NN Group N.V. 2016 Annual Review”, page 1 & page 5, NN website (https://www.nn-group.com/nn-group/file?uuid=a6450bdf-caa9-4df1-916c-b880aa846e3d&owner=c5df72fd-8a65-4f75-956d-5e37307aa50c&contentid=1585), viewed 23 January 2018.
[2] Financial Times, “Delta Lloyd agrees to NN Group takeover”, 23 December 2016, https://www.ft.com/content/a5ddfdb3-083c-3a8c-9cff-22f20f2912c7, viewed 23 January 2018.
[3] NN Group, “Defence Policy”, November 2015, page 4, NN website (https://www.nn-group.com/nn-group/file?uuid=68f855a6-52c8-4c58-bcbb-6b00baacf9ce&owner=c5df72fd-8a65-4f75-956d-5e37307aa50c&contentid=1073), viewed 23 January 2018.
[4] NN, “Defence Policy”, November 2015, page 6, NN website (https://www.nn-group.com/nn-group/file?uuid=68f855a6-52c8-4c58-bcbb-6b00baacf9ce&owner=c5df72fd-8a65-4f75-956d-5e37307aa50c&contentid=1073), viewed 23 January 2018; NN, written response to PAX, 21 December 2017.
[5] NN, written response to PAX, 21 December 2017.
Last updated March 2018