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Norwegian Government Pension Fund Global (Norwegian Ministry of Finance and Norges Bank Investment Management)

PRI reporting framework 2017

Export Public Responses

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LEA 17. Voting policy & approach

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17.1. Indicate whether your organisation has a formal voting policy.

17.2. Indicate what your voting policy covers:

17.3. Attach or provide a URL to your voting policy. [Optional]

17.4. Provide a brief overview of your organization’s approach to (proxy) voting.

We vote in a principled and consistent manner to maximise the long term performance of the fund. We base our principles and voting decisions on internationally recognised standards, such as the G20/OECD Principles of Corporate Governance, UN Global Compact, UN Guiding Principles for Business and Human Rights, and the OECD Guidelines for Multinational Enterprises.                       Where appropriate, we will takes company and local factors into consideration.                                      Our vote decisions will be published on one day after a general meeting has concluded.   We may also publish voting intentions ahead of general meetings for a selected number of companies, and for certain fundamental issues that we emphasize in particular.

Our global voting guidelines can be found at:


17.5. Provide an overview of how you ensure your voting policy is adhered to, giving details of your approach when exceptions to the policy are made (if applicable).

We continuously works to improve the voting process. Given the high number of shareholder meetings, we are dependent on a reliable voting chain. In 2016, in partnership with Citibank N.A., our global  custodian, we initiated a project to test the feasibility of a standardised model for final vote confirmation. This pilot project is part of our efforts to establish a process where we would have confirmation that all our voting rights were exercised at each shareholder meeting and that each resolution was voted as per our electronic instruction (known as end-to-end confirmation).

The majority of our voting decisions fall within the scope of our public voting guidelines. There are, however, cases where the global voting guidelines are less relevant due to the nature of the resolution. Some resolutions may be contentious or simply fall outside the general voting guidelines’ framework. In such cases, we analyse the agenda items individually and vote on the basis of what we deem to be in the fund’s best long-term interest. One common example of such cases is an extraordinary general meeting called to vote on a merger or acquisition.

We have an integrated voting process where we incorporate investment knowledge from portfolio managers into the final voting decision. By incorporating the insights of investment teams, we are in a position to consider company factors on a case-by- case basis. Voting decisions at 521 companies were made in collaboration with portfolio managers in 2016. These companies accounted for approximately 48 percent of the equity portfolio’s market value.