NN Group extends its Thermal Coal Policy

We have updated our Thermal Coal Policy by strengthening restrictions on large thermal coal producers and companies developing new coal projects. In addition, we have expanded the scope of exemptions and formalised the process for assessing and granting them. 

Our Thermal Coal Policy, first introduced in 2019, guides how we manage our proprietary investments in companies involved in thermal coal production and coal-fired power generation as part of our commitment to phase out thermal coal exposure in our corporate investment portfolio by 2030.

Thermal coal is among the most carbon-intensive energy sources and reducing our exposure remains an important part of our broader sustainability approach. Since introducing the Policy, we have reduced our thermal coal-related investments from around EUR 1.8 billion in 2019 to approximately EUR 300 million at the end of 2025. This reduction reflects a combination of investments reaching maturity, companies reducing their thermal coal activities and selective divestments.

Broadening our assessment of coal exposure

As we have implemented the Policy, we have seen that percentage-based thresholds remain useful, but do not always provide a complete picture of a company's involvement in thermal coal. For example, a company may generate relatively little revenue from coal while still being a significant producer.

To address this, we have introduced additional restrictions covering large thermal coal producers, large coal-fired power generators, and companies developing new coal mines or coal-fired power plants. While the update is expected to have only a limited impact on our current portfolio, it ensures that companies with significant coal-related activities or expansion plans are more consistently captured by our policy. This strengthens our ability to assess both current activities and future direction.

Supporting the wider transition

Our objective is not only to reduce our own exposure to thermal coal, but also to support the broader transition taking place in the real economy.

For the remaining thermal coal-related investments in our portfolio, we will continue to monitor progress against credible phase-out plans and engage with companies where feasible. Where transition plans are not credible, or progress is insufficient, we will not make new investments.

We have also formalised how exemptions are assessed. In limited cases, companies that exceed our restriction criteria may be considered for an exemption where deeper analysis shows credible transition plans and progress. This reflects our view that a rigid application of thresholds, or a single deadline, may not always fully capture a company's transition progress.

We also recognise that social, regional and employment impacts from phasing out thermal coal can affect the pace and feasibility of transition in some circumstances. Just transition considerations are therefore taken into account when assessing exemptions, where wider societal impacts justify a more nuanced assessment.

Importantly, these updates do not change our commitment to phase out thermal coal exposure by 2030. They strengthen our ability to deliver on that commitment, balancing clear restrictions with a practical assessment of real-world transition progress.

This approach reflects the balance we seek to maintain: staying firm on the need to phase out thermal coal, while supporting companies that are making real progress in their transition.