9 Our Responsible Investment Journey 2021 - Danske Bank

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9 Our Responsible Investment Journey 2021 - Danske Bank
Our Responsible
Investment Journey
2021

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9 Our Responsible Investment Journey 2021 - Danske Bank
2   Our Responsible Investment Journey 2021
9 Our Responsible Investment Journey 2021 - Danske Bank
Contents

       Chapter 1 – Introduction
04     A paradigm shift for sustainability
06     A green reboot of the financial markets
08     Raising the bar with new sustainability target

       Chapter 2 – Incorporating sustainability

10  Our blueprint for delivering investment value and sustainable progress
14  Taking sustainability in solutions investment products to the next level
16  Developing analytical tools to capture value
18	Rigorous sustainability assessment of external managers
20  Supporting the sustainable transition through index investments
22  Funnelling investments into the sustainable transition
24  Companies must adapt to climate trends
26  Companies expected to take social responsibility
28  Governance is a key issue when investing in developing countries

       Chapter 3 – Active ownership

30     A challenging year and a turning point for sustainability
32     Company engagements in 2020
34     Corona crisis amplified focus on the green transition
36     Voting in 2020
38     Pushing companies to curb their climate impact
40     Voting guidelines need to reflect best practice

       Chapter 4 – Screening and restrictions

42     Restricting investments with harmful business practices
44     Development of process to promote enhanced sustainability standards in investments
46     Tightened restrictions on activities that result in a significant negative impact on the climate
48     Introducing ‘Sustainability risk challenger’

       Chapter 5 – Reporting and communication

50     Making sustainability more transparent
52     What are ESG and sustainable investment products?
9 Our Responsible Investment Journey 2021 - Danske Bank
4      Our Responsible Investment Journey 2021

A paradigm shift for sustainability
While sustainability has been high on            SFDR product framework. By leveraging       will not become green overnight, but we
society’s agenda for many years, the             our deep sustainability expertise and       will continue to influence their climate
outbreak of COVID-19 marked a new                processes built up over the years and       strategies and thus support the sustain-
era, with sustainability taking a quan-          further improving our sustainability        able transition. By remaining engaged,
tum leap forward as the cornerstone for          structure in the past 12 months, we are     we maximise our contribution towards
creating resilient societies and healthy         able to offer a wide range of high-qual-    making societies more sustainable.
lives. Meanwhile, the first part of the          ity ESG investment products. Among
Sustainable Finance Disclosure Regula-           other initiatives, we have introduced       Collaborating to propel sustainability
tion (SFDR), a central plank of the EU’s         a “Sustainability risk challenger” and      forward
Action Plan for financing sustainable            enhanced our investment restrictions        The sustainable agenda is rapidly
growth, came into force in March 2021.           framework and voting guidelines to help     picking up speed, and with the rollout
SFDR ensures greater transparency on             promote the environmental and social        of the EU Action Plan and its various
the degree of sustainability incorporated        characteristics of our products and         regulations, we are fully focused on
into financial products, and its objec-          to capture issues related to principal      constantly improving our sustainability
tive is to ensure further transparency           adverse sustainability impacts on           efforts to stay ahead of the curve and
on sustainability risk considerations            society. Moreover, we have reinforced       be one of the best Nordics banks for
in the financial sector and investment           our proprietary ESG analytical tool         responsible investments. In the coming
products. COVID-19 and SFDR have                 mDASH®, so it supports product-spe-         year, we plan to, for example, signifi-
been game changers for the financial             cific sustainability characteristics. To    cantly expand our product offering in
industry, setting a clear course for our         ensure our products comply with the         ESG and sustainable investments, set
ambitions for responsible investments            extensive regulatory requirements and       fully tailored and binding sustainability
and our efforts to create value for our          honour the spirit of SFDR, we have cho-     targets for products, and develop a
investors and society.                           sen a conservative approach to labelling    framework for measuring our products’
                                                 our product according to their sustaina-    contribution towards achieving the UN
A catalyst for sustainable change                bility-related characteristics.             Sustainable Development Goals.
Sustainability has been a guiding star                                                            At Danske Bank, we are truly
directing our investments for many               The green transition is a top priority      excited about the possibilities that lie
years and shaping our actions as a               Climate change poses one of the big-        ahead and look forward to collaborating
responsible investor. We therefore               gest financial risks and threats to the     with our investors, peers, policymakers
welcome the new EU regulation, as it             well-being of global society. We have       and other stakeholders in shaping an
feeds into our ambition of fostering sus-        subsequently tightened our investment       investment industry that advances
tainable change. To further advance our          restrictions on thermal coal, tar sands     sustainability and benefits society. By
efforts, we have set sustainability tar-         and peat-fired power generation by          joining forces with our investors and
gets that lay down a clear path for our          lowering our revenue threshold from         society, we can make it easier for inves-
commitment to help investors invest in           30 to 5 per cent, which is a further step   tors to make sustainable choices.
products that promote sustainability or          towards phasing out investments in
have sustainability objectives. We have          these fossil fuels by 2040 at the latest
also set a target of having a net-zero           and being a net-zero asset manager
greenhouse gas emissions investment              by 2050. However, propelling society
portfolio by 2050 or sooner as part of           towards a greener future is not only
our support for the Paris Agreement.             about restricting companies. More
These targets underpin our ambition to           importantly, it is about actively taking
contribute to decarbonising the econ-            part in the change by influencing com-
omy and to enable capital to work for            panies to shift from carbon-intensive
sustainable change.                              activities to more energy-efficient and
                                                 climate-friendly solutions. Climate was
High-quality products with a robust              therefore at the top of our engagement
sustainability foundation                        agenda in 2020, when we through
In order to align with the objectives of         dialogue with company management
SFDR, we have also adopted a new                 pushed for greener business models
Responsible Investment Policy and                and the acceptance of a greater share       Erik Eliasson
categorised our products according               of responsibility for supporting the        Head of Responsible Investments
to the disclosure requirements of the            decarbonisation of society. Companies       Danske Bank Asset Management
9 Our Responsible Investment Journey 2021 - Danske Bank
CHAPTER 1
                                                                                                                       Introduction

                                                                                                                  See our
                                                                                                                Responsible
                                                                                                             Investment Policy
                                                                                                                   here.

Our foundation for creating value
for investors and society
Our new Responsible Investment Policy is based on five principles that support our ambition to create attractive
return for our investors and contribute to positive and sustainable development.

                Principle 1
                We incorporate sustainability risks into investment analyses and investment decision-
                making processes.

                Principle 2
                We are active owners and incorporate environmental, social and governance criteria as
                well as sustainability issues into our ownership guidelines and practices.

                Principle 3
                We incorporate sustainability risk into advice on investment products, aim to identify our
                investment customers’ sustainability preferences and seek to provide them with products
                that meet their ethical and sustainability needs.

                Principle 4
                We report on our activities and progress towards implementing Responsible Investments
                and disclose the impacts of our investments.

                Principle 5
                We promote the development of Responsible Investments across our industry.
9 Our Responsible Investment Journey 2021 - Danske Bank
6       Our Responsible Investment Journey 2021

A green reboot of the financial markets
Funding the transition to a low-carbon economy and the ambition of creating a sustainable
Europe requires a mobilisation of capital. This puts the financial sector front and centre and
subjects it to new regulation, with the goal of funnelling more capital into the green transition.

The European Commission has com-                  credentials of investment funds, and a         underlines how important it is that
menced the implementation of its exten-           new EU Taxonomy, which aims to define          asset managers take responsibility and
sive Action Plan intended to transform            ‘green’ economic activities for the first      help steer investment capital towards
the financial markets in Europe. The              time. The EU also plans to enhance the         companies that make a real contribu-
objective is clear: to redirect capital flow      sustainability requirements of invest-         tion to achieving carbon-neutrality. We
into sustainable activities and so create         ment advisory.                                 at Danske Bank are committed to help-
a green and sustainable Europe. This                   “We welcome the ambition to create        ing our investors invest in the sustain-
regulatory push is the most ambitious             a uniform understanding and defini-            able transition. By employing sustaina-
in many years and aims to encourage               tion of sustainability and to set clear        bility targets, we have set a clear path
investors to ramp up efforts to acceler-          sustainability requirements for products       for funnelling more capital into a green
ate the low-carbon transition, accord-            if they are to be marketed on the basis        future,” concludes Marjo Grandell.
ing to Marjo Grandell, Head of Liquid             of their sustainability credentials. As
Investments.                                      investor demand for products with sus-
    “The EU Action Plan on sustainable            tainability characteristics is expected to
finance stems from the EU’s commit-               grow substantially in the coming years,
ment to channel private financial flows           this incentivises the providers of invest-
into investments that support the Paris           ment products to step up their sustaina-
Agreement’s target of a carbon-neutral            bility efforts in order to remain relevant,”
economy by 2050 and, more broadly,                states Marjo Grandell.
the United Nations Sustainable Devel-
opment Goals. The Action Plan address             Helping to close the funding-cap
aspects such as climate change, pollu-            The climate goals set for Europe are
tion reduction and biodiversity protec-           ambitious and call for prompt action
tion,” explains Marjo Grandell.                   from all financial players to successfully
    In her view, the legislative pro-             complete the energy transition of our
gramme defines a much-needed                      economies, according to Marjo Gran-            We at Danske Bank are
common language and increases                     dell. However, moving the transition
transparency and standards with regard            forward requires funding. Indeed, the
                                                                                                 committed to helping our
to sustainability.                                European Commission estimates the              investors invest in the
                                                  investment deficit to be EUR 260bn             sustainable transition. By
Incentivising a green path                        annually, i.e. EUR 260bn more needs to         employing sustainability
The Action Plan is part of a wider sus-           be invested annually between now and
tainable finance framework backed by a            2030 if we are to meet the 2030 goal           targets, we have set a clear
broad set of new and enhanced regula-             of reducing CO2 emissions by at least          path for funnelling more
tions. These include a new Sustainable            40 per cent.                                   capital into a green future.
Finance Disclosure Regulation, which                  “The massive need for reallocating
aims to better classify the sustainability        investments to sustainable activities          Marjo Grandell
9 Our Responsible Investment Journey 2021 - Danske Bank
CHAPTER 1
                                                                                                                                                           Introduction

The EU Action Plan explained
The Action Plan is the EU’s roadmap for creating a sustainable economy. It comprises multiple actions and legislative tools
designed to reorient Europe’s capital towards sustainable investments, ensure that sustainability risks are integrated into the
financial system and that long-term implications are considered. The various regulatory initiatives will be implemented over the
next couple of years.

GOAL
                                            Help achieve the Paris Agreement                             Contribute to the UN Sustainable Development Goals

OBJECTIVES
                              Reorienting capital flow towards                   Mainstreaming sustainability                          Fostering transparency
                               more sustainable investments                          in risk management                                  and long-termism

KEY ACTIONS
                              • E  stablish a taxonomy of                     • B  etter integrate sustainability               • S trengthen corporate sustain-
                                  environmentally sustainable                      in ratings and market research                    ability disclosure
                                  activities                                   • C  larify institutional investors’              • Improve sustainable corporate
                              • C  reate standards and labels for                 and asset managers’ duties                        governance; reduce short
                                  green financial products                     • Incorporate sustainability in                     termism
                              • F oster investment in sustain-                   prudential requirements
                                  able projects
                              • Incorporate sustainability into
                                investment advisory
                              • D  evelop sustainability bench-
                                  marks

SELECTED
                              Taxonomy Regulation                    Low-Carbon                         MiFIDII Amendments                   Disclosure Regulation
REGULATIONS
                              To be implemented in                   Benchmarks                         To be implemented in                 First part implemented
                              2022 and 2023                          Implemented in 2020                2022                                 10 March 2021

                          The EU taxonomy is a clas-           This introduces two                   This obliges investment
                          sification system defining           low-carbon benchmarks                 managers to take into
                          minimum criteria that                with predefined environmen-           account their clients’ sus-
                          economic activities should           tal, social and governance            tainability preferences when
                          comply with in order to be           disclosure requirements.              assessing their investment
                          considered environmentally           These are the “Climate Tran-          objectives and providing
                          sustainable. The aim is to           sition Benchmark” and the             investment advice.
                          prevent “greenwashing” and           “Paris-Aligned Benchmark”,
                          help investors understand            which are intended to pro-
                          whether an economic activ-           vide an investor-friendly tool
                          ity is sustainable.                  for comparative analysis of
                                                               carbon footprints.

Sustainable Finance Disclosure Regulation in a nutshell
The Sustainable Finance Disclosure Regulation           SFDR achieves these objectives by imposing                     •   Categorising products according to their
(SFDR) introduces and defines transparency              new disclosure requirements on sustainability                      sustainability characteristics as set out in
requirements for financial product charac-              in investments – it applies to both financial enti-                the SFDR product framework. The two cat-
teristics such that they can be compared on             ties and products. Requirements include:                           egories are: article 8 products (promoting
the basis of their degree of sustainability. Its                                                                           environmental and/or social characteris-
phased-in implementation started on 10 March            •    disclosing how sustainability risks are                       tics) and article 9 products (sustainable
2021 and has two main objectives:                            incorporated into decision-making                             investment as an objective). In addition,
                                                        •    disclosing whether the principal adverse                      disclosing how these products attain their
•   To make it easier for investors to invest in             impacts on sustainability factors that                        sustainability characteristics on websites,
    products that support sustainable develop-               investment decisions may cause are con-                       in pre-contractual agreements and in peri-
    ment                                                     sidered (these are the negative effects on                    odic reporting.
•   To prevent products from seeming more                    environmental, social or employee matters,
    sustainable than they actually are and thus              as well as on respect for human rights,
    hinder “greenwashing”                                    anti-corruption or anti-bribery that result
                                                             from an investment decision)
9 Our Responsible Investment Journey 2021 - Danske Bank
8      Our Responsible Investment Journey 2021

Raising the bar with new
sustainability targets
We have set targets for investments in ESG and sustainable investment products and have
committed to supporting the goal of net-zero greenhouse gas emissions by 2050 or sooner.
This will support our investors in investing in the green transition.

To support society’s sustainability goals        commitment to help investors invest         promoting environmental or social char-
and the low-carbon transition, we are            in products that promote sustainability     acteristics to DKK 400bn by 2023,
raising the bar by launching concrete            or have sustainability objectives. These    corresponding to around three quar-
sustainability targets for our investment        goals are set in accordance with the        ters of the assets currently under our
business. To advance our efforts as a            new Sustainable Financing Disclosure        management. In addition, the goal is to
facilitator of sustainable change, we            Regulation (SFDR) product framework.        funnel at least DKK 150bn into sustain-
have set specific sustainability tar-                Our short-term goal is that investors   able investment products by 2030.
gets that plot a clear direction for our         increase their investments in products          “For our investors, sustainability
9 Our Responsible Investment Journey 2021 - Danske Bank
CHAPTER 1
                                                                                                                          Introduction

                                             Aspiring to help society reduce its
                                             negative impact
                                             In the long term, we are stepping up
                                             efforts to support society’s ambition of
                                             decarbonising the economy. Achieving
                                             the climate goals of the Paris Agree-
                                             ment requires corporates to shift their
                                             business model from polluting technol-
                                             ogies and products to more energy-effi-
                                             cient and climate-friendly solutions. As
                                             investors, we can play a significant role
We will continue our efforts                 in shaping tomorrow’s companies and          Our investors increasingly
                                             influencing them to reduce their climate     evaluate the companies and
to strengthen and expand                     footprint. This is why we became a sig-
our ESG product shelf and                    natory of the Net Zero Asset Manager
                                                                                          products into which they put
innovate new sustainable                     Initiative, which represents a group of      their money according to how
investment products. This
                                             international asset managers commit-         the companies contribute to
                                             ted to supporting the goal of net-zero       combating climate change
will advance our ambition                    greenhouse gas emissions by 2050
of becoming a facilitator for                or sooner, in line with the Paris Agree-     and other societal challenges.
sustainable change.                          ment’s target of limiting global warming     Our new targets reflect this –
                                             to 1.5 degrees Celsius.                      we want to make measurable
                                                  “As an investor and distributor of
Marjo Grandell                                                                            efforts and progress in our
                                             investment products, we have a vital
                                             role in driving the low-carbon transition,   offering.
                                             thereby helping society achieve its cli-
                                                                                          Christian Heiberg
continues to gain in importance; a trend     mate ambitions. By joining the Net Zero
that is advancing by the hour. They          Asset Manager Initiative, we will bolster
increasingly evaluate the companies          our climate efforts, and we will work
and products into which they put their       in collaboration with our investment
money according to how the companies         customers to set decarbonisation goals
contribute to combating climate change       for all assets under our management,”
and other societal challenges. Our new       concludes Thomas Otbo, Chief Invest-
targets reflect this – we want to make       ment Officer at Danske Bank Asset
measurable efforts and progress in our       Management.
offering, while at the same time aligning
with the new SFDR regulation,” says
                                                  We will set milestone targets for
                                             carbon reduction in late 2021 to ensure                 DKK 400bn
Christian Heiberg, Head of Danske Bank       progress on our net-zero commitment.              in investment products that
Asset Management.                                                                            promote environmental or social
                                                                                                 characteristics by 2023
Enabling investors to invest in the
sustainable transition
To achieve our new sustainability
targets, we will expand our product
offering to cater to investor sustaina-
bility preferences, so they can choose
investment products aligned with their                                                               DKK 150bn
ambitions and goals.                                                                         in investment products that have
     “Setting measurable and ambitious                                                       sustainability objectives by 2030.
targets for our responsible investment
efforts is a central pillar for delivering
on investor expectations going for-
ward. We will continue our efforts to
strengthen and expand our ESG product        As an investor and distributor
shelf and innovate new sustainable           of investment products, we
investment products, which we expect         have a vital role in driving the
to be able to offer in the near future.                                                           Investments aligned with
                                             low-carbon transition, thereby
This will advance our ambition of
becoming a facilitator for sustainable       helping society achieve its                      net-zero emissions
change,”states Marjo Grandell, Head          climate ambitions.                                      by 2050 or sooner.
of Liquid Investments at Danske Bank
Asset Management.                            Thomas Otbo
9 Our Responsible Investment Journey 2021 - Danske Bank
10     Our Responsible Investment Journey 2021

Our blueprint for delivering investment
value and sustainable progress
Sustainability is becoming more important for companies and for the investment
community due to stricter sustainability-related regulations and increased investor
demands for sustainable products. This brings new risks and opportunities for companies,
making it important for us to analyse and assess how companies navigate the sustainable
transition in order to choose the best possible investments for our investors.

International societies have embarked            sustainable solutions and products are     face, making sustainability a key strate-
on a journey to make economies more              megatrends that influence companies        gic business priority.
sustainable. Stricter regulation on              and thereby our investors. This devel-         We believe it is paramount to
companies, the Paris Agreement, the              opment is disrupting business models       capture these sustainability risks and
UN Sustainable Development Goals                 and altering the risks and opportunities   opportunities fuelled by the sustainable
and consumers’ increased demand for              that businesses and the financial sector   transition, as this supports our ambition
CHAPTER 2
                                                                                                                Incorporating sustainability

of protecting and growing our investors’       Addressing sustainability through              ate if they meet international norms
assets. Incorporating sustainability           a materiality lens                             and standards for corporate social
risks has been part of our investment          Sustainability risks are systemati-            responsibility, such as the UN Global
teams’ investment processes for many           cally incorporated into the investment         Compact and the OECD Guidelines for
years, and we continuously develop             process of our entire product range.           Multinational Enterprises (learn more
and enhance our sustainability analysis        Investment teams identify and assess           on page 44). In addition to incorporating
tools and infrastructures, so our invest-      those sustainability factors that pose         sustainability risks into the investment
ment teams are able to assess risks            risks and could have a negative impact         analysis, investment teams use active
and opportunities holistically and make        on the return potential of investments,        ownership, screening and restrictions
the best possible investment decisions.        i.e. factors that are financially material.    to address and mitigate sustainability
                                               As part of that process, companies             risks (learn more on pages 30 and
                                               and countries are analysed to evalu-           42).

    Utilising data to make better investments

    Having a robust process for incorpo-        matters. These include a company’s           Learn more about the data platform
    rating sustainability risks and quality     labour and human rights practices,           here.
    investment products requires ESG            a company’s carbon footprint from
    data. We have therefore built a data        their own operations,
    platform consisting of more than            products and supply
    8,000 high-quality sustainability           chains, board diver-
    data points listing those sustaina-         sity, anti-bribery, biodi-
    bility aspects that are relevant and        versity and deforesta-
    critical for businesses and their           tion policies, product
    financial performance. The data             safety, gender pay
    platform currently comprises 11             gap, animal welfare
    different ESG data sources, which           and waste manage-
    are used by our investment teams to         ment processes.
    assess how companies are address-
    ing and performing on sustainability

                mDASH®                          Identifying material sustainability
                                                aspects with mDASH®

                                                which sustainability aspects are             noise’ and identify material sus-
                                                important for individual compa-              tainability aspects and assess how
                Central to making sound         nies from a financial standpoint.            individual companies address and
             investments is our invest-         To ensure a systematic approach,             manage those aspects. This enables
          ment teams’ focus on sustain-         we have developed our proprietary            our teams to make better-informed
       ability issues that are likely to        analytical tool called mDASH (short          investment decisions that can bene-
    affect a company’s business and             for materiality dashboard). The tool         fit our investors.
    ability to deliver attractive returns to    organises and categorises data
    our investors. This is called financial     from companies and external data             Learn more about mDASH® on page
    materiality and is the focal point          providers, so that our investment            16 and in our white paper here.
    when investment teams analyse               teams can cut through ‘information
12      Our Responsible Investment Journey 2021

Sustainability analysis built on a                platform and proprietary ESG analysis
robust foundation                                 tool mDASH® to identify and analyse
Adding new features to our infrastruc-            those sustainability factors that are
ture ensures investment teams capture             likely to be business-critical for specific
relevant and material sustainability              companies. In addition, our Responsible
aspects. This reinforces the environ-             Investment team, consisting of ESG
mental and social characteristics                 specialists and analysts, supports our
of our products and enables us to                 investment teams across the Nordics
accommodate our investors’ current                in deploying a systematic incorporation
and future sustainability preferences             of sustainability factors. Moreover,
and values. For example, our invest-              investment teams regularly undertake
ment teams leverage our ESG data                  training programmes to raise their
                                                  sustainability competencies, so they
                                                  can constantly improve and strengthen
                                                  their ability to incorporate sustainability   Consumer preferences,
                                                  into the selection of investments. Many       company operations and
                                                  of our investment teams have recently         regulations are rapidly
                                                  completed the European Federation of
                                                  Financial Analysts Societies ESG Analy-
                                                                                                changing, spurred by increased
                                                  sis training programme.                       awareness of the impact of
                                                       By building robust sustainability        climate change and global
                                                  processes, expanding ESG data and             ambitions to push society in
                                                  developing analytical tools, we continue
                                                  to enable teams to systematically man-
                                                                                                a more sustainable direction.
                                                  age and mitigate the potential sustaina-      These changes will most likely
                                                  bility risks of investments – and unlock      accelerate even more going
                                                  investment opportunities spurred by, for      forward, which is why we
                                                  example, a company’s ability to leverage
                                                  the low-carbon transition to grow their       have a rigorous process for
Companies that fully                              business and achieve a competitive            identifying climate-related
integrate sustainability into                     advantage.                                    risks and opportunities.
their businesses can to a                         Double materiality                            Cecilie Hoffmeyer, Senior Portfolio Manager
greater extent use it as a                        It is in our DNA to take responsibility
business enabler and be better                    and contribute to making societies
                                                  more sustainable while creating
positioned than competitors                       prosperous and healthy lives. We
to create growth and                              are therefore mindful of not only how         may cause. Applying this so-called
development.                                      investment performance is affected            double materiality assessment across
                                                  by sustainability factors, but also the       our investment products – meaning the
Joel Backesten, Portfolio Manager                 material principal adverse impact on          financially material topics that influence
                                                  society that our investment decisions         enterprise value as well as topics mate-
CHAPTER 2
                                                                                                            Incorporating sustainability

     We consider principal adverse impacts on sustainability factors
     We consider the principal adverse impacts that our investment decisions may have on the sustainability of society. In
     other words, investment decisions that have negative effects on sustainability aspects, such as environmental, social
     or employee matters, or human rights, anti-corruption or anti-bribery issues. Adverse impacts are currently measured
     via these indicators, which we seek to continuously expand:

     •   Greenhouse gas emissions
     •   Carbon footprint
     •   Greenhouse gas intensity
     •   Exposure to companies active in the fossil fuel sector
     •   Share of non-renewable energy
     •   Violations of UN Global Compact principles or OECD Guidelines for Multinational Enterprises

     We use a wide range of tools, frameworks and data to identify the principal adverse impacts on sustainability factors.
     These are also addressed through active ownership and we have, for example, incorporated the indicators into our
     voting guidelines. In addition, we may exclude companies due to principal adverse impacts, and we have, for instance,
     excluded certain companies that contribute significantly to climate change, damage biodiversity, violate human rights,
     have insufficient labour rights or are involved in corruption.

     Learn more about our processes for identifying and addressing principal adverse impacts on sustainability factors in
     our full statement at danskebank.com.

rial to the economy, environment and         corruption, bribery and other practices      responsible investor, we engage with
people – is as an integral element of our    harmful to sustainability.                   companies with the goal of solving the
investment business. We analyse and              To address and reduce principal          matter and thus mitigating a compa-
assess how a company addresses and           adverse impacts we, for example,             ny’s negative impact on society. This
tackles a series of sustainability issues,   restrict companies involved in harmful       underpins our ambition of mitigating our
ranging from carbon emissions, fossil        products or behaviour, including weak        negative impact on society, fostering
fuel exposure, waste levels to gender        human rights or tax practices, car-          change and helping our investors invest
diversity and due diligence over human       bon-intensive business models, water         in the sustainable transition while deliv-
rights and a company’s efforts to avoid      pollution or corruption. Moreover, as a      ering strong investment performance.
14      Our Responsible Investment Journey 2021

Taking sustainability in solutions
investment products to the next level
Danske Bank Asset Management has a wide selection of so-called solutions investment
products that cater to the different needs of investors. These are multi-asset products
comprising actively and passively managed components, such as equity or bond funds, and
range from retail-friendly investment solutions like Flexinvest or Horisont to Global Portfolio
Solutions for investors with more sophisticated needs. We have asked Thomas Otbo, Chief
Investment Officer at Danske Bank Asset Management and Head of Solutions, to elaborate
on why and how sustainability and responsible investment practices are rooted in these
solutions products.

What is important from a                          we can deliver to our investors. This
sustainability perspective when it                makes integrating sustainability into
comes to our solutions investment                 our investment processes important,
products?                                         as it helps us make better-informed
Our sustainability approach is founded            investment decisions and provide our
on materiality and having a robust                investors with investment solutions
process for integrating sustainability            capable of delivering competitive, long-
matters into all aspects of our solutions         term performance. On the other hand,
products. This requires a well-developed          we also have a responsibility as an
foundation of ESG data, tools and exper-          asset manager to address the principal
tise – all of which we have developed in          adverse impacts that our investments
recent years and which enables us to              may cause. By having sustainability
derive investment value from sustaina-            considerations ingrained in our solu-           As Chief Investment Officer,
bility. As Chief Investment Officer, I am         tions products we can promote sustain-
focused on utilising our infrastructure           able development and make a positive
                                                                                                  I am focused on utilising our
to ensure that sustainability is consid-          impact.                                         infrastructure to ensure that
ered throughout the entire investment                                                             sustainability is considered
process of our solutions products, from           How will the new EU regulation                  throughout the entire invest-
asset allocation, selection of compo-             change our solutions products?
nents or investments, to portfolio con-           Coming EU regulations integrating               ment process of our solutions
struction and risk management . In my             sustainability aspects in investment            products, from asset alloca-
view, it is paramount that every step of          advisory mandate that as part of                tion, selection of components
our process works to promote the same             the advisory process we will have to
environmental or social characteristics           match our investors’ sustainability
                                                                                                  or investments, to portfolio
or achieve the desired sustainability             preferences with the ESG character-             construction and risk manage-
outcome while delivering strong invest-           istics or sustainability objectives of          ment.
ment performance.                                 our products. This will necessitate the
                                                                                                  Thomas Otbo
                                                  development of products with explicit
Why is sustainability important for               ESG characteristics or objectives. We
these products                                    have started to design these products,
On the one hand, sustainability aspects           so we are ready to meet the needs of            investors’ desire to invest sustainable is
have, like conventional financial factors,        investors with an appetite for specific         set to amplify in the coming years, and
an impact on the potential returns that           sustainability themes. We believe that          we are keen to develop a product shelf

                          Asset                                          Portfolio               Selection of                   Risk
                        allocation                                     construction              components                  management

      Selection of                                          Active             Promoting sustaina-              Sustainability
      components                                           ownership           bility characteristics            objectives
CHAPTER 2
                                                                                                           Incorporating sustainability

                                                                                         Do all underlying components have
                                                                                         the same sustainability approach?
                                                                                         Solutions products often contain mul-
                                                                                         tiple components or multiple layers of
                                                                                         investment analysis and decision-mak-
                                                                                         ing. This is because a solutions product
                                                                                         commonly invests in portfolios or funds
                                                                                         (components) that are managed by sep-
                                                                                         arate investment teams with separate
                                                                                         investment processes and objectives.
                                                                                         This also means that the investment
                                                                                         analysis and investment decisions in a
                                                                                         solutions product are made from a top-
                                                                                         down perspective, where we assess the
                                                                                         investment strategy and sustainability
                                                                                         integration of the underlying compo-
                                                                                         nents, which might differ. Over the
                                                                                         coming year, we will include sustaina-
                                                                                         bility-related metrics or indicators in the
                                                                                         portfolio construction process in order
                                                                                         to have solutions products that clearly
                                                                                         promote specific environmental or
                                                                                         social characteristics or have tangible
                                                                                         sustainability objectives. This includes,
                                                                                         for instance, our proprietary mSCORE®
                                                                                         or carbon risk rating indicators. We will
                                                                                         also include pre-defined filters in the
                                                                                         selection of underlying components
                                                                                         to augment the selection process and
                                                                                         ensure sustainability-related aspects
                                                                                         are taken sufficiently into account in the
                                                                                         decision-making process.

                                                                                         Does active ownership play a role in
                                                                                         solutions products?
that caters to the various sustainability   opportunities and the negative and pos-      Active ownership is an essential part of
objectives of investors.                    itive impacts of these processes, which      our products and is applied to manage
                                            should support our ambition of creat-        investment risks, maximise returns and
How will this be done in practice?          ing attractive risk-adjusted returns for     contribute to a positive impact on the
Incorporating ESG and sustainability        investors. Sustainability considerations     environment and society in general. We
aspects into solutions products involves    often relate to long-term time horizons,     subsequently ensure that challenging
many different layers and processes         so we focus on including sustainability      sustainability issues are addressed
that are much more complex compared         aspects in the strategic asset alloca-       through dialogue and voting in the
to integrating sustainability consider-     tion as opposed to the tactical asset        underlying companies as a means of
ations into a single actively managed       allocation process. Consequently, we         advancing sustainability standards. We
equity product. We are therefore            are currently working on a number of         exercise active ownership in solutions
factoring tailor-made sustainability        initiatives aimed at further strengthen-     products at different levels and ensure
considerations into the entire invest-      ing the asset allocation process from a      that our activities work towards the
ment process – from the allocation of       sustainability perspective. This includes    same objective. As a result, relevant
assets, construction of the portfolio and   developing an analytical framework that      active ownership efforts are in place
management of risk to active ownership      makes it possible to include sustaina-       in the underlying components and are
activities.                                 bility factors in long-term capital market   always logged, so we can monitor the
                                            assumptions across asset classes, and        activities and their impact on improving
Can you detail how sustainability           developing a scenario analysis frame-        sustainability performance. Moreover,
considerations are integrated into          work and tools to identify those sus-        we have developed voting processes
the asset allocation process?               tainability risks and opportunities that     and voting guidelines that ensure we
The asset allocation process is a           can impact strategic asset allocation        use our power to influence as an inves-
vital part of the investment process.       targets and the investment universe.         tor and vote on relevant and material
Depending on the investment strategy,       Furthermore, we are also defining a          sustainability proposals at the general
it determines how a product is exposed      process that will improve our ability to     meetings of companies in the underly-
to, for example, asset classes, regions,    capture sustainability characteristics or    ing components.
sectors, themes and factors. We             objectives in our allocation of regional
consider material sustainability risks,     exposures and sectors.
16     Our Responsible Investment Journey 2021

Developing analytical tools
to capture value
Our analytical tool, mDASH®, is an important key enabler for us to meet the requirements of
the EU’s new sustainability regulation for financial products’ sustainability-related disclosures.

The Sustainable Finance Disclosure                   Sustainability Insights & Analytics at            “mDASH® thus helps investment
Regulation (SFDR) is all about increas-              Danske Bank.                                  teams describe the manner in which
ing transparency on the sustainabili-                    In particular, mDASH® supports our        sustainability risks are integrated
ty-related aspects of financial products.            efforts to comply with the new regula-        into the investment decision-making
It places a great deal of emphasis on                tion in three specific areas:                 process by assessing the likely impact
describing our processes for managing                                                              of sustainability risks on financial
various sustainability characteristics in            1. Management of sustainability               return and explaining the reasoning for
our investment decision-making.                      risks                                         whether sustainability risk is deemed
     “At Danske Bank, mDASH® is our                  The regulation requires sustainability        to be material or not,” explains Antti
proprietary sustainability research                  risks to be managed and disclosed at          Malava.
platform that enables investment teams               product level. mDASH® explicitly iden-
to form a holistic view of companies’                tifies those industry-specific sustaina-      2. Promotion of sustainability
sustainability performance. mDASH®                   bility risks that are most likely to impact   principles and practices
is therefore a key tool for complying                the financial or operational performance      SFDR contains a disclosure require-
with the requirements of the new SFDR                of companies, and scores how each             ment relevant to the promotion of envi-
regulation in terms of our investment                individual company manages those risk         ronmental and social characteristics for
decisions,” says Antti Malava, Head of               exposures.                                    article 8 products and demonstration of

                             All companies must have a viable business plan for embedding sustainability into
                             their operations, otherwise they risk a lack of refinancing opportunities for their
                             bonds. Simply put, a company’s sustainability strategy is a decisive component in
                             my selection of companies that I believe are positioned for long-term growth and
                             can deliver an attractive return.
                             Rikke Zink Secher, Senior Portfolio Manager
CHAPTER 2
                                                                                                        Incorporating sustainability

  sustainable investment objectives for      3. Management and disclosure of
  article 9 products.                        adverse sustainability impacts
       “We have developed robust screen-     SFDR requires management and
  ing processes that enable investment       periodic disclosure of the adverse
  strategies to ensure low exposure          sustainability impacts of our investment
  towards investments with a negative        decisions. An important concept here is
  impact on the climate or society as a      principal adverse impacts (PAI).
  whole and to ensure good governance            “PAIs aim to capture the negative,
  in investee companies. This means          material effects of our investments
  we address standards of corporate          on sustainability factors. We are in
  governance and sustainability within       the process of integrating PAIs into
  areas such as emissions, energy use,       mDASH®, so investment teams can
  biodiversity, water, waste, social and     identify principal adverse impacts in the   mDASH® thus helps invest-
  employee matters, human rights as well     investment decision-making process,”
                                                                                         ment teams describe the
  as anti-corruption. mDASH® displays,       says Antti Malava.
  for example, which restrictions apply to       Article 9 products have sustainable     manner in which sustainabil-
  specific companies and the reasoning       investment as their objective. Meet-        ity risks are integrated into
  behind those restrictions,” points out     ing this requirement necessitates a         the investment decision-mak-
  Antti Malava.                              framework that defines how economic
       Furthermore, our portfolio managers   activities contribute to an environmental
                                                                                         ing process by assessing the
  can identify company-specific sustain-     or social objective. Furthermore, article   likely impact of sustainability
  ability issues of interest and concern     9 products must ensure that such            risks on financial return and
  that they might want to address in their   sustainable investments do not signifi-     explaining the reasoning for
  ongoing dialogue with investee compa-      cantly harm any other environmental or
  nies. mDASH® embeds this information,      social objectives in the framework and      whether sustainability risk is
  including a portfolio manager evaluation   meet minimum social safeguards. We          deemed to be material or not.
  of how a company has addressed a           are now developing a robust article 9
  particular issue, and hence allows us to   framework, and mDASH® will incor-           Antti Malava
  track progress within areas of interest    porate relevant data to describe and
  and concern.                               measure such sustainable investment
                                             objectives.

                             mDASH® in brief
 010100010010100101011010100010011001
         • To support our ambition of truly integrating sustainability into our
           investment decision-making, we have developed our own analytical
   00100101         0101000100101001010110
           tool mDASH®.

0001001100100100101                               01010001001010011
         • mDASH® is a materiality dashboard that sources the best available raw
           ESG data from company disclosures and a number of third-party data and

 0101101010001001100100100101
           ratings providers to form the basis for assessing what is material to the
           companies we invest in.                                                    0101
00010010100101011010100010011001001
         • We can also transform scope and data inputs into a material sustainability
           risk score for each company in our universe – this we term an mSCORE®,
  001010101000100101001010110101000
           which we have developed as one output from mDASH®.

1001100100100101                      010100010010100101
         • mDASH® helps us identify investment value in ESG data, make holistic
           assessments and take ownership of our sustainability integration, thus

   01101010001001100100100101
           supporting better-informed investment decision-making.
                                                                                      0101000
100101 10010100101011010100010011001
18     Our Responsible Investment Journey 2021

                            We were keen to develop a more structured approach to monitoring existing
                            managers and selecting new investment managers, so we could attain a greater
                            understanding of their sustainability-related processes, activities and resources.
                            Mads Steinmüller

Rigorous sustainability assessment
of external managers
We collaborate with external investment managers around the world, and the EU’s new
Sustainable Finance Disclosure Regulation has created a need to strengthen these
partnerships. A new assessment framework has been developed that includes a review of
how external managers promote environmental or social characteristics or have sustainable
objectives for their funds.

Danske Bank’s ambition is to take a              awareness about responsible invest-          though the majority of the external man-
leading position and become one of               ments in the Nordics is high, and that       agers we collaborate with have strong
the best banks in the Nordics in terms           investors are increasingly requesting        sustainability processes, we decided
of responsible investments. The EU’s             exposure to sustainability themes and        to classify the funds as article 6 as of
recently adopted Sustainable Finance             objectives.                                  10 March 2021 (non-sustainable).
Disclosure Regulation (SFDR) has                                                              However, all external managers are very
defined a new regulatory framework               Assessing sustainability processes           positive about the SFDR requirements
for investment funds, which must now             In spring 2020, the Responsible              and we are currently working with many
comply with a number of disclosure               Investments team developed a new             of them so we can market their funds
principles in order to be marketed as an         assessment framework for all external        as ESG or Sustainable investment
ESG fund or a sustainable fund.                  managers. As well as regular monitor-        funds (article 8 or article 9 funds),” says
     This also applies to externally man-        ing by the Manager Selection team,           Mads Steinmüller.
aged funds in the Danske Invest fund             all external managers are sustainabil-            Danske Bank’s ambition is that
universe. These are funds not managed            ity-assessed annually to monitor and         all externally managed funds should
by Danske Bank Asset Management                  evaluate their progress in working with      become ESG or Sustainable funds. That
but other managers like Fidelity, Aber-          responsible investments.                     ambition is aligned with our long-term
deen and NN Investment Partners.                      “We were keen to develop a more         goal of having at least DKK 400bn
External managers are often used for             structured approach to monitoring            invested in funds that promote environ-
asset classes or geographies where               existing managers and selecting new          mental or social characteristic by 2023
they have specialist competences or              investment managers, so we could             and at least DKK 150bn in sustainable
are closer to the investment universe            attain a greater understanding of their      investment products by 2030.
than Danske Bank Asset Management.               sustainability-related processes, activ-
     “Across the Nordic region, we               ities and resources,” explains Mads
service numerous investors, large and            Steinmüller.
small, retail and business, who have a                The assessment is rooted in the Dan-    All external managers are
diverse set of values, preferences and           ske Bank Responsible Investment strat-
needs. We have to ensure we are able             egy, which focuses on sustainability Inte-
                                                                                              very positive about the SFDR
to serve our investors’ diverse needs            gration, Active Ownership and Report &       requirements and we are
with an attractive product range of              Disclose. However, the assessment was        currently working with many
responsible investments, regardless of           updated after the SFDR regulation came       of them so we can market their
whether they are investing in American           into force and now includes a review of
high yield bonds or Chinese equities,”           how external managers promote environ-       funds as ESG or Sustainable
says Mads Steinmüller, who is Senior             mental or social characteristics or have     investment funds (article 8 or
ESG Specialist and part of Danske                sustainable objectives for their funds.      article 9 funds.
Bank’s Responsible Investment team.                   “We spoke to all external managers
     He adds that the general level of           about SFDR in the autumn, and even           Mads Steinmüller
CHAPTER 2
                                                                                                      Incorporating sustainability

Sustainability assessment of external managers
We assess how external managers integrate sustainability into investment decisions and continuously
discuss how their processes can be improved.

Sustainability Integration                Active Ownership                        Report & Disclose
• ESG education, data & resources         • Engagement approach                   • Strategy level reporting
• Material ESG risk/opportunities         • Themes and topics                     • Firm-wide level reporting
   in the investment analysis             • Investor initiatives & collabora-
• Environmental/social character-            tions
   istics or sustainable investment
   objectives
• Climate change risk mitigation
20       Our Responsible Investment Journey 2021

Supporting the sustainable transition
through index investments
Two new climate benchmarks have been introduced as part of the EU Action Plan on
Sustainable Finance. These serve as tools for investors to actively align their decarbonisation
efforts in index investments with the climate targets of the Paris Agreement. We have already
started to help investors use these benchmarks as a means to strengthen their climate profile
while maintaining broad market exposure at a low cost.

Index investments are a central pillar             market exposures while contributing to      in the coming years, as many investors
in the investment strategy of many                 the climate goals of the Paris Agree-       are seeking to reinforce and extend their
institutional investors in particular,             ment? According to Jasper Riis, Head        sustainability profile.
and many of these investors have high              of Quant & Overlay at Danske Bank, the
ambitions when it comes to contributing            two new climate benchmarks provide          Advisory that moves sustainability
to the low-carbon transition and making            an effective means of combining cli-        ambitions forward
societies more sustainable. So how can             mate ambitions with an attractive risk/     Our ability to successfully help inves-
investors successfully combine invest-             return profile. The EU’s “Paris-Aligned     tors transition their index investments
ing in low-cost indexes with attractive            Benchmark” and the “Climate Transi-         to the climate benchmarks is rooted in
                                                   tion Benchmark” can be leveraged by         our own high sustainability ambitions,
                                                   investors to emphasise their climate        insights, tools and know-how that we
                                                   action and create climate-resilient index   have built up in recent years.
                                                   portfolios.                                     “Our interests and sustainability
                                                       “Using the two benchmarks is a          ambitions are aligned with our investor
                                                   forceful way to actively express your       clients, and being a sparring partner
                                                   climate ambitions in index investments,     and engaging in strategic discussions
                                                   which are passive by nature. Many           are ingrained in our advisory. We have
                                                   investors, especially large institutional   capabilities and access to extensive
                                                   investors, have committed to having         ESG data and quantitative analytical
                                                   a net-zero investment portfolio by          tools that many of our investors do not,
                                                   2050, and this allows them to carry         and we closely collaborate with them
                                                   on investing in cost-effective index        from the initial planning and assess-
                                                   portfolios, have a diversified investment   ment phase to concrete recommen-
                                                   strategy with attractive return potential   dations for the portfolio construction
The quantitative overlay                           and at the same time deliver on their       and execution phase. In essence, we
ensures that investors are in                      sustainability targets and promises to      leverage our deep sustainability exper-
the vanguard of supporting                         their boards and customers,” explains       tise to tailor and boost our investors’
                                                   Jasper.                                     climate profiles in their index portfolios,
society’s climate agenda.                              He adds that Danske Bank has            exemplified by us being able to help
In my view, using the                              already assisted an institutional           early-movers, such as the institutional
benchmarks clearly signals                         investor in implementing the “EU Par-       investor wanting to be at the forefront of
an investor’s commitment to                        is-aligned Benchmark” in their global       the climate agenda,” says Jasper, who
                                                   equity index portfolio, thus lowering       adds:
redirecting its investments                        their carbon emissions by 50 per cent           “We want to be a leading bank in
towards opportunities in the                       compared to the broad market index          the Nordics on sustainability, and to
energy transition.                                 and significantly reducing their annual     drive the transition to net-zero carbon
                                                   carbon emission levels going forward.       emission investments that is necessary
Jasper Riis.                                       Jasper believes this trend will amplify     to fulfil the climate targets of the Paris
CHAPTER 2
                                                                                                               Incorporating sustainability

Agreement. To achieve this ambition,          help our investors funnel capital to fund     are in the vanguard of supporting
we are building stellar investment advi-      the sustainable transition.                   society’s climate agenda. In my view,
sory services, enhancing and expanding                                                      using the benchmarks clearly signals
our ESG data architecture and ana-            Investments aligned with EU’s                 an investor’s commitment to redirecting
lytical tools and are fully focused on        sustainability targets                        its investments towards opportuni-
engineering investment solutions that         From Jasper’s perspective, using the          ties in the energy transition, broadly
                                              EU’s climate benchmarks is a gateway          encompassing products and services
                                              to aligning index portfolios with the         related to renewable energy and energy
                                              EU Action Plan and its support of the         efficiency,” explains Jasper Riis.
                                              Paris Agreement climate goals as well              To make it possible for investors
                                              as complying with EU sustainability           of all types to invest in the low-carbon
In essence, we leverage our                   regulations.                                  transition, Danske Bank is currently
                                                  “By implementing these bench-             exploring the possibility of using these
deep sustainability expertise to
                                              marks, the index portfolio is aligned         climate benchmarks in index prod-
tailor and boost our investors’               with the Sustainable Finance Disclosure       ucts. This will enable us to offer index
climate profiles in their index               Regulation, and we automatically adjust       products that meet the sustainability
portfolios                                    the portfolio if regulators adjust the        requirements set out for article 8 and
                                              benchmark requirements. The quanti-           9 products in the Sustainable Finance
Jasper Riis.                                  tative overlay ensures that investors         Disclosure Regulation.

     What are the EU’s climate benchmarks?
     The two benchmarks provide a robust and consistent framework for investors to incorporate specific objectives related
     to greenhouse gas emission reductions and the transition to a low-carbon economy through the selection and weighting
     of underlying investments. The benchmarks are predicated on the Paris Agreement target of limiting global warming to
     ideally below 1.5°C by the end of the century, and the goal is to help further mobilise and move investor capital towards
     activities that contribute to fighting climate change.

                                              E
                                               U Climate Transition                       E
                                                                                            U Paris-Aligned
                                              Benchmark                                    Benchmark

     Minimum carbon intensity          30%                                           50%
     reduction compared to
     investable universe

     Baseline exclusions               Excludes companies involved in:
                                       • Controversial weapons         • Violating social norms

     Activity exclusions               None                                          Excludes companies with:
                                                                                     • Coal revenue of more than 1%
                                                                                     • Oil revenue of more than 10%
                                                                                     • N
                                                                                        atural gas revenue of more than
                                                                                       50%
                                                                                     • H
                                                                                        igh carbon-intensity electricity
                                                                                       producers with more than 50%
                                                                                       revenue from production emitting more
                                                                                       than
                                                                                       100g CO2 e/kWh

     Year-on-year self-decarbo-        At least 7% on average per annum: in line with or beyond the decarbonisation
     nisation of the benchmark         trajectory from the UN’s Intergovernmental Panel on Climate Change 1.5°C scenario.

     Exposure constraints              Minimum exposure to sectors highly exposed to climate change issues is at least
                                       equal to equity market benchmark value.
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