This report shows public data only. Is this your organisation? If so, login here to view your full report.

Danske Bank

PRI reporting framework 2019

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

01.3. Indicate if the investment policy covers any of the following

01.4. Describe your organisation’s investment principles and overall investment strategy, interpretation of fiduciary (or equivalent) duties,and how they consider ESG factors and real economy impact.

Sustainable investments is a cornerstone of our ambition to integrate societal impact into our core business and our vision to be recognised as the most trusted financial partner. When our customers entrust us with their assets and savings, it is our duty to serve their interests by providing investment solutions with the goal to deliver competitive and long-term performance. Our firm commitment to sustainable investment is an integral part of this duty.

The Sustainable Investment Policy (“the SI Policy”) governs and outlines our approach for: 

- Environmental, social and corporate governance (ESG) integration 

- Active ownership through dialogue, voting, and collaboration  

- Screening and restrictions 

- Communication and reporting.


Our sustainable investment approach is based on environmental, social, and corporate governance (ESG) integration, active ownership, collaboration, and disclosure and reporting, in line with the UN-supported Principles for Responsible Investment as well as the Danish Stewardship Code.


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

We integrate ESG matters into the investment process as factors alongside financial factors. Based on external ESG data and information, and internal expertise and advice, we assess portfolio companies’ ESG performance, identify risks and opportunities, and engage through dialogue on material matters to support business growth and good governance and standards of conduct. 

We believe that fund-manager-driven dialogue with portfolio companies is the most effective as the investment teams are the experts of their respective strategies and portfolios, and tasked with the buy/sell decision. Our investment teams engage on a regular basis with portfolio companies on material ESG matters to understand their risks and opportunities, and to support their growth and development.  We log and monitor company dialogue and progress to ensure a structured engagement process.

The annual general meeting is an opportunity to voice our opinion, vote on issues of key importance to the running of a company, and contribute to the good governance of the company. We exercise our right to vote at annual general meetings of Nordic and European companies where we represent relevant holdings. Unless required by special circumstances, holdings in passively managed funds are not subject to voting activities. We vote either by ourselves or through a service provider.  We log and publish our voting records.

When appropriate, we collaborate with peers, like-minded investors and other relevant parties to exercise active ownership, engage through joint dialogue, and contribute to a positive impact. We also participate in investor initiatives to encourage increased transparency and sustainability standards in companies and financial markets, such as e.g. the Carbon Disclosure Project, Institutional Investors Group on Climate Change, Paris Pledge for Action, The Task Force on Climate-Change Financial Disclosure, and the UNsupported Principles for Responsible Investment.

We screen our investment universe to identify ESG risks related to portfolio companies with reference to industry best practice, international norms and voluntary frameworks for corporate responsibility. Based on our assessment and company dialogue, we may from time to time decide to divest or restrict investments in a company, in a specific investment strategy or across multiple strategies.

We screen portfolios and funds that are set up with restrictive criteria or thresholds relating to certain sectors, products, or companies in order to meet customer needs.

We apply overall investment restrictions across the investment universe based on Danske Bank Group sustainability positions on Climate Change and Arms & Defence. This covers certain companies according to their involvement in thermal coal and tar sands, and weapons prohibited by international law or deemed controversial due to its indiscriminate effects or disproportionate harm they cause. 

The investment restrictions of the SII policy do not apply to structured products, derivatives, Danske Bank’s capital market activities (including but not limited to market making, securities trading etc.) or externally managed funds.

01.6. Additional information [Optional].

I confirm I have read and understood the Accountability tab for SG 01 I confirm I have read and understood the Accountability tab for SG 01

SG 01 CC. Climate risk (Not Applicable)

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.

02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.

02.3. Additional information [Optional].

Responsible Investment Issues

In 2016, we published five position statements that describes how we work with industries known to have elevated environmental, social and governance risks. The statements focus on credit and investment procedures. In 2017 we had 7 postion statements. All have been updated in 2018 and Human Rights have been added - URL is provided below:


Mining and metals

Arms and defence

Fossil fuels

Climate change


Modern Slavery

Human Rights




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.

As part of Danske Bank A/S, the Group Conflict of Interest Policy applies to Danske Bank Asset Management. This Policy regulates the management of conflicts of interests for all employees. The Policy regulates conflicts that may arise between customers, employees, group or other entities, including Inducements, Gifts and Hospitality, Personal Account Transactions and more. Conflicts of interest are recorded in a conflicts of interest register. Furthermore, arrangements such as segregation of duties, information barriers and oversight and control are in put in place, in accordance with the Policy.

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

The policy was updated in december 2018. 

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)