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Danske Bank

PRI reporting framework 2017

Export Public Responses

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

01.4. Indicate what norms you have used to develop your investment policy that covers your responsible investment approach.

other (1) description

          Convention on Cluster Munitions, The Ottowa Treaty

other (2) description

          Biological Weapons Convention, Chemical Weapons Convention

01.6. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

The purpose of the Responsible Policy is serve our customers interests by creating both competitive and sustainable returns.

Therefore, we integrate ESG considerations in all our investment practices, as we believe that management of environmental and social risks and well-functioning corporate governance is a precondition for an optimization of the risk-adjusted return.

The Group will, when necessary, seek to influence companies primarily through dialogue with the management of companies and secondarily through voting at annual and special general meetings and participation in nomination committees.

We encourage companies to respect international principles for corporate responsibility and collaboration within the investor community to the benefit of our customers and society in general.

In addition, we invest with respect to international principles for human rights, labour rights, the environment and anti-corruption - as described in the UN Global Compact, OECD Guidelines for Mul­tinational Enterprises and UN Guiding Principles. Consequently, we strive to mitigate adverse impacts of our investment practices through appropriate due diligence, dialogue with companies or simply by refraining from investing in specific companies or assets.  

The RI Policy covers four focus areas: (1) Screening & Exclusions, (2) Engagement & Initiatives, (3) ESG Integration and (4) Dialogue & Voting. It is applicable to Danske Invest funds, Danske Capital and Danica Pension products and to Danske Bank's pooled accounts where the Group manages the investment of customer funds. The RI Strategy also apply to the Danske Bank Group's own investments.

The investment restrictions of the RI Policy do not apply to funds-of-funds, structured products, individual securities or derivatives, institutional mandates, institutional funds or managed accounts.

When we recommend clients to invest in funds other than Danske Invest, we strive to select funds that are based on internationally recognized principles for responsible investing.

During 2016 we focused on increasing our active ownership activities which is reflected in the listed equity active ownership section of this report. Finally, we proceeded with the integration of ESG data on all actively managed investment products.


SG 02. Publicly available RI policy or guidance documents

New selection options have been added to this indicator. Please review your prefilled responses carefully.

02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.



02.4. Additional information [Optional].

Responsible Investment Issues

In 2016, we have published five position statements that describe how we work with industries known to have elevated environmental, social and governance risks. The statements focus on credit and investment procedures.


Mining and metals

Arms and defence

Fossil fuels

Climate change

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

Danske Capital has adopted a Conflicts of Interest policy in coherence with Danske Bank Group’s Conflict of Interest Policy and is a requirement by law.  The conflicts of Interest policy is the overall arrangement in regards to handling conflicts of interest. In addition Danske Capital has implemented various programs, which deals with possible conflicts that may arise in the different business areas of Danske Capital. 

These arrangements  include: Watch list and  Staff Trade Procedures, Chinese Walls Policy and Inducement Policy. 

For more information on Danske Bank group’s conflict of interest policy , please see link below:

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Not Completed)