The four AP Funds that are members of the Council on Ethics invest globally in diversified portfolios of several thousand companies. A large proportion of the assets of the Funds are passively managed, which means that the Funds have a wide spread of ownership, with relatively small stakes in a range of companies. Obviously, the Council on Ethics does not have the resources for active management in all of the holdings. The Council therefore applies a systematic process for identifying where active management will reap the greatest benefit. The process helps us to ensure a good spread of issues, geographical locations and assets, so that not all of our work is derived from the same industry or relate to the same issues.
Information from a number of different sources
To monitor the occurrence of incidents, the AP Funds and Council use a large number of sources, including the media, trade association and UN bodies. Nevertheless, there is always the risk that individual incidents will be overlooked. Any information that comes to the attention of the Council about such an incident or violation is incorporated into its systematic process.
The working process of the Council on Ethics manage a flow of dialogues that can develop in different directions over time
1. Review of the Corporate holdings of the AP-Funds
The Council receives systematic business intelligence covering approximately 3,500 companies. Among the sources are media, other investors, trade associations, UN bodies and nongovernmental organisations.
Nevertheless, there is always the risk that an individual incident will not be captured. If the Council on Ethics receives information about such an incident, information is included in the systematic work process.
2. In-depth examination
The Council performs a review and overall analysis of companies, industries, problem areas and investor initiatives.
Approximately 100–200 companies every year are reviewed further for suspected implication in violation of international conventions.
3. Choice of companies and dialogue objectives
The Council chooses companies and preventive projects. The choice of focus areas does not represent a statement that some areas are more important than others but is simply a deliberate strategy to devote the resources of the Council to issues that are most likely to benefit from them.
The Council pursues direct dialogue with a number of companies whose violations of international conventions are evident and well documented.
In addition, the Council collaborates with various service providers to dialogue with another hundred companies in response to alleged violations of international conventions.
4. Dialogue efforts
In-depth corporate analyses and possible comparisons with minimum requirements and best practice for the industry in question.
Additional pressure, such as collaboration with other investors, submitting proposals to general meetings and voting at general meetings.
5a. The objecitve of the dialogue has been achieved
The dialogue has been concluded.
The dialogue has been concluded. The company is closely monitored for five years.
5b. The objective of the dialogue has not been achieved
The dialogue continues if it is constructive.
Unless a dialogue has produced the desired results after four years, the Council recommends that the AP Funds to divest the company. Each AP Fund makes its own divestment decisions.
Companies that the Council on Ethics has recommended the AP Funds to exclude. The Council checks once a year to see whether the situation has changed and the company is now operating in compliance with international conventions.
For more information about see Recommended Excusions.