Our work on responsibility is based on legislation and international agreements, guidelines and principles, including UN PRI, the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights as well as the Paris Agreement. 

On top of this foundation stands our policy for responsible investments which includes, among other things, the themes of climate, environment, biodiversity, responsible taxation, governance, anti corruption, bribery, human and workers' rights. 

As a responsible investor, we are aware that our investments can have both positive and negative impacts on the above-mentioned themes. We work with a focused effort to prevent and address negative impacts. 

Our work on responsible investment is based on three pillars:

1. Firstly, P+ actively selects sustainable investments.
2. Second, we carry out a so-called ESG due diligence. This means that, wherever possible, we conduct a thorough assessment of investment considerations relating to Environment, Social and Governance factors.
3. Third, we exercise active ownership. This means that we work to influence the companies we invest in so that they develop in accordance with our policy for responsible investments.

By focusing on these three areas, we believe we can best work towards sustainable development.

Divestment is not the primary approach
When investors choose not to invest in a company, it often attracts a great deal of attention. But when you choose not to invest in a company, it reduces your ability to push for responsible development within the company. 

In P+ we see divestment as one of many tools in our tool box - and not as a goal in itself. 

If engagement proves pointless, we may divest companies. However, we prioritise active ownership wherever possible. We also continuously review our restricted list regularly to assess whether companies have improved to the point where investment may be considered again. This way, we believe we best support genuine transition and development. 

Responsibility is firmly embedded in our investment decisions
Responsible investment is fully integrated into the decision-making processed in P+. The board has ultimate responsibility for ensuring that P+ works in accordance with our policy for responsible investments. Operational responsibility lies with the pension fund's Head of Responsible Investments who reports to the Chief Investment Officer. 

New investments are discussed in P+'s investment committee where the Head of Responsible Investments has a permanent seat alongside the CEO, CIO, CFO, CRO and two external members.

The investment committee must ensure:

• that there is a clear link between return and risk levels 
• that the risk-based investment process is embedded throughout the organisation
• that the CRO can provide input and is heard in material investment decisions to ensure that the risk mapping and measurement are handled correctly
• that the due diligence carried out on specific investments has been performed in accordance with internal procedures, including that the pension fund complies with national or international regulation and legislation in the area at the time of the investment
• that investments are made in accordance with the pension fund's policy for responsible investments. The investment committee discussed responsibility in investments, changes to the pensions fund's restricted list as well as other relevant topics related to responsibility.