The AP Funds’ expectations of companies with connections to conflict-affected and high-risk areas are based on international conventions and frameworks endorsed by Sweden, as well as relevant positions from Sweden, the EU, and the UN.
Companies connected to these areas are expected, in addition to respecting human rights – including international humanitarian law – to apply heightened Human Rights Due Diligence (hHRDD) to address and mitigate potential adverse impacts.
Not acting in line with international law may form the basis for the AP Funds’ Council on Ethics recommendation to exclude a company.
Guiding international conventions and frameworks
Within the scope of international law, several conventions address the respect for human rights in conflict-affected and high-risk areas. These include instruments of international humanitarian law (also known as the laws of war) such as the Geneva Conventions, as well as the UN Universal Declaration of Human Rights.
Guiding international frameworks and principles for responsible business conduct include the UN Guiding Principles on Business and Human Rights[1], the OECD Guidelines for Multinational Enterprises[2], and UN guidelines[3] for companies operating in conflict-affected areas.
Sweden’s and the EU’s positions on specific conflicts, and where applicable, statements from relevant UN or EU bodies, also guide the Council on Ethics’ assessments.
The AP Funds’ expectations of companies
The AP Funds expect companies to respect human rights, including international humanitarian law, in their operations and value chains.
Conflict-affected and high-risk areas pose a higher risk of serious human rights violations. Companies with links to these areas therefore bear a particular responsibility to ensure their operations comply with international humanitarian law. The AP Funds expect such companies to apply heightened human rights due diligence (hHRDD) in line with international frameworks and guidelines.
According to these frameworks, companies should continuously identify and act to prevent or mitigate adverse impacts that they are linked to. This work should include conducting conflict analysis and assessing the company’s impact on the conflict, including in relation to international humanitarian law. A company should also provide and enable remedy where the company has caused or contributed to harm. In addition, companies should report transparently on their hHRDD processes. If a company decides to exit operations linked to conflict-affected or high-risk areas, then the exit should be carried out responsibly.
Basis for the Council on Ethics’ recommendation for exclusion
Not acting in line with international law may serve as grounds for the Council on Ethics’ recommendation to exclude a company. The recommendation is company-specific and based on the Council on Ethics’ assessment of involvement and alignment with international law in the specific conflict.
A list of current exclusion recommendations, including short explanations, is available via this link.
The position statement was updated on 12 September 2025.
Regarding specific conflicts
Israel–Palestine conflict
The Council on Ethics bases its assessment of the Israel–Palestine conflict on the positions of the EU[4] and Sweden[5]. The Council on Ethics considers that companies which actively and consciously contribute to the permanence of settlements or the maintenance of the separation barrier in occupied territories – by offering tailor-made products and services – defy international law, which may form the basis for a recommendation of exclusion.
Western Sahara conflict
The Council on Ethics bases its assessment of the Western Sahara conflict on the UN's statement[6] that exploration and extraction of mineral resources in Western Sahara violate international law, the UN Covenant on Civil and Political Rights and the UN Covenant on Economic, Social and Cultural Rights. The Council on Ethics considers that companies engaged in exploration and extraction of mineral resources in Western Sahara defy international law, which may form the basis for a recommendation for exclusion. The Council on Ethics does not consider renewable resources to be covered by the UN's statement.
Myanmar conflict
The Council on Ethics bases its assessment of the Myanmar conflict on positions and statements from the UN[7], EU[8], and Sweden[9]. The Council on Ethics considers that companies selling weapons to Myanmar’s military may contribute to human rights violations, which may form the basis for a recommendation of exclusion.
How the Council on Ethics works
The Council on Ethics engages in dialogue with foreign companies that may be linked to breaches of international conventions and frameworks endorsed by Sweden. The purpose of these dialogues is to encourage companies to address the issues, and to adopt policies and processes that prevent potential future breaches of international conventions and frameworks. If dialogue does not lead to the desired change, the Council on Ethics may, as a last resort, recommend that the AP Funds exclude the company.
[1] https://www.ohchr.org/en/publications/reference-publications/guiding-principles-business-and-human-rights
[2] https://www.oecd.org/en/publications/oecd-guidelines-for-multinational-enterprises-on-responsible-business-conduct_81f92357-en.html
[3] Examples of guidelines:
https://www.ohchr.org/sites/default/files/documents/issues/business/bhr-in-challenging-contexts.pdf and https://www.undp.org/publications/heightened-human-rights-due-diligence-business-conflict-affected-contexts-guide
[4] https://www.eeas.europa.eu/eeas/israelpalestine-statement-spokesperson-announcement-confiscate-occupied-land_en
[5] https://www.regeringen.se/sveriges-regering/utrikesdepartementet/sveriges-forbindelser-med-omvarlden/mellanostern-och-nordafrika/israel/handel-med-israel-och-palestina/
[6] https://news.un.org/en/story/2002/02/26862
[7] https://digitallibrary.un.org/record/3930690?ln=en&v=pdf
[8] https://www.consilium.europa.eu/en/policies/sanctions-against-myanmar/
[9] https://www.regeringen.se/globalassets/regeringen/dokument/utrikesdepartementet/mr-rapporter/myanmar-mr-rapport-2021.pdf