Responsible investment policy framework

To demonstrate and disclose our vision and approach on Responsible Investment (RI), NN Group developed the Responsible Investment Framework policy. With seven key principles, we highlight the measures we will take to responsibly invest our own assets, as well the assets that our customers 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 investment beliefs, the organisation’s values, relevant laws, and internationally recognized norms and standards, based on which minimum requirements have been developed for the investment process. More detail on our RI approach can be found in the Responsible Investment Framework policy.


NN expects the companies it invests in to act in accordance with the United Nations Global Compact and OECD Guidelines. If we assess companies to severely and systematically violate these standards, an engagement process will be started. We will only decide to restrict individual companies when engagement is not or no longer considered feasible to change the conduct or involvement in specific business activities of those companies. Such a decision will not be taken lightly and only where we believe that restriction is a balanced and proportionate response. Restrictions may also arise when companies demonstrably have activities in the trade of arms to central governments or non-state actors that are sanctioned by a UN or EU arms embargo. This is also the case for companies that develop, produce, maintain or trade ‘controversial weapons’. Weapons that we define as controversial include anti-personnel landmines, cluster munitions, biological weapons, chemical weapons, depleted uranium ammunitions, and white phosphorus weapons. Furthermore, companies involved in nuclear weapon activities are also restricted under certain conditions. Furthermore, NN applies restrictions to corporate issuers involved in tobacco production, or oil sands production and controversial pipelines, or the mining of thermal coal. Finally, NN does not invest in sovereign issuers against which arms embargoes have been issued by the UN Security Council. The most recent Exclusion List can be downloaded here.

Statement on Coal

The restriction of companies that derive more than 30 percent of revenue from coal mining is part of our Statement on Coal. The statement describes all the steps that NN is taking to address the risks and environmental concerns associated with coal. These include steps to engage with companies as well as a phase out of thermal coal in our proprietary investments and insurance business. Taking together, we believe that these steps will further our efforts to support the transition to a low-carbon economy.

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.

Our values

Our Seven Responsible Investment (RI) Principles

NNIP's voting activity for Client and Proprietary Assets


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