Our responsible investment policy framework

To demonstrate and disclose our vision andapproach on Responsible Investment (RI), NN Group developed the ResponsibleInvestment Framework policy. With seven key principles, we highlight the measures we willtake to responsibly invest our own assets, as well the assets that ourcustomers entrust to us.

NN applies different Responsible Investment(RI) strategies, such as norms-based, voting, engagement, ESG integration and,as a measure of last resort, restriction. Our approach is a reflection of our investmentbeliefs, the organisation’s values, relevant laws, and internationally recognisednorms and standards, based on which minimum requirements have been developed forthe investment process.

More detail on our RI approach can be foundin the ResponsibleInvestment Framework policy.


NN expects the companies it invests in to actin accordance with the United Nations Global Compact and OECD Guidelines. If weassess companies to severely and systematically violate these standards, anengagement process will be started. We will only decide to restrict individualcompanies when engagement is not or no longer considered feasible to change theconduct or involvement in specific business activities of those companies. Sucha decision will not be taken lightly and only where we believe that restrictionis a balanced and proportionate response.

Restrictions may also arise when companiesdemonstrably have activities in the trade of arms to central governments ornon-state actors that are sanctioned by a UN or EU arms embargo. This is alsothe case for companies that develop, produce, maintain or trade ‘controversialweapons’. Weapons that we define as controversial include anti-personnellandmines, cluster munitions, biological weapons, chemical weapons, depleteduranium ammunitions, and white phosphorus weapons. Furthermore, companiesinvolved in nuclear weapon activities are also restricted under certainconditions.

Furthermore, NN applies restrictions tocorporate issuers involved in the production of tobacco products. In addition,NN does not invest in sovereign issuers against which arms embargoes have beenissued by the UN Security Council.

The most recent Exclusion List can be downloaded here.

Guidance papers

We use guidelines, such as the UN Global Compact to help us evaluate the corporate behaviour of  companies in which we (may) invest. The UN Global Compact is a set of 10 principles for responsible corporate behaviour in four areas: human rights, labour relations, environment, and anti-corruption. For these areas, NN is developing papers, with the objective of providing guidance to our asset managers. The first papers are on Human Rights and the Environment.

Global Voting Policy

Part of investing responsibly means exercising our voting rights as shareholders. NN has a Global Voting Policy in place to guide our actions when voting on standard resolutions. The policy lays down the high-level voting principles that every NN Group business follows. Every vote that NN Investment Partners casts at shareholder meetings – including proprietary and third-party asset voting – can be reviewed on the proxy voting website.