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

Above that foundation stands our policy for responsible investments which includes the themes climate, environment, biodiversity, responsible tax, governance, anti corruption, bribery, human and labour rights. 

As a responsible investor we are aware that our investments may have both positive and adverse impact on the mentioned themes. And we have focus on preventing and handling adverse impact. 

Our work with responsible investments is based on three pillars:

1. Firstly, P+ actively chooses sustainable investments.
2. Secondly, we perform a so-called ESG due diligence. This implies that we as far as possible perform a thorough assessment of the investment that takes Environment, Social and Governance into consideration.
3. Thirdly, we exercise active ownership. This mians that we work to encourage the companies we invest in to develop according to our policy for responsible investments.

By focusing on these three areas we believe that we work for a sustainable development in the best possible way.

Divestment is not always a solution
When investors choose not to invest in a company, it often attracts great attention. But when you choose not to invest in a company, it reduces your possibility of exerting pressure on a responsible development in the company. 

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

If engagement is pointless, we can divest companies. But as far as possible, we choose active ownership. And we go through our restricted list regularly to assess if the companies have improved enough to invest in them. This way, we believe to support an actual transition and development best possible. 

Responsibility is firmly anchored in our investment decisions
The work with responsible investments is integrated in the decision-making in P+. The Board of Directors have the final responsibility for complying with its policy for responsible investments. The operational responsibility lies with the pension fund's Head of ESG who is responsible to the pension fund's CIO. 

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

The investment committee must ensure:

• that there is a clear correlation between the level of risk and return 
• that the risk-based investment process is integrated in the entire organisation
• that the CRO can provide input and be heard in significant investment decisions to ensure that the risk mapping and measurement are handled correctly
• that the performed due diligence related to actual investments complies with the internal procedures, including that the pension fund when investing complies with national or international regulation and legislation applying to the area
• that investing complies with the pension fund's policy for responsible investments, changes to the pensions fund's restricted list as well as other relevant subjects related to responsibility.