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PRI reporting framework 2020

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Basic information

OO 01. Signatory category and services

01.1. Select the type that best describes your organisation or the services you provide.

01.3. Additional information. [Optional]

The Fund, AP3,  is a governmental authority whose operations are regulated in the Swedish National Pension Funds Act (2000:192). On 1 January 2019, the rules in the National Pension Insurance Funds (AP Funds) Act changed and a new goal was introduced. The Funds shall manage fund resources in an exemplary manner through responsible investment and ownership. Particular attention shall be paid to how sustainable development can be promoted.

AP3 is one of five so-called buffer funds in the Swedish national pension system. Together, the buffer funds hold around 14% of total pension system assets. AP3 is tasked by the Swedish Parliament to generating maximum possible benefit for the income pension system by managing the fund capital and deliver strong investment returns at a low level of risk. AP3 has two roles in the pension system:

  1. serve as a buffer when inflows and outflows cause imbalance in the system
  2. promote the overall financial stability of the system.

The Fund is more independent than most government agencies. The Board, appointed by the Government, has sole responsibility for the operations of the Fund and Sweden’s national pension funds are regulated solely by legislation. The Ministry of Finance reviews the national pension funds’ performance on an annual basis.

AP3 manages a diversified global portfolio of listed equities, fixed income assets and alternative investments. Alternative investments consist of private equity, real estate, timberland, infrastructure and ILS and constitute around 26% of the total portfolio.

The value of AP3's portfolio stood at SEK 393.7 bn on 31 December 2019.

AP3 bases its values on international conventions (environment, human rights, labour protection, anti-corruption and inhumane weapons) signed by the Swedish government. The values also include support provided by Sweden to initiatives such as the OECD's Principles of Corporate Governance and Guidelines for Multinational Enterprises, the UN Global Compact, and Sweden's stance on issues of international law. The Pension Funds Act requires the AP funds to responsibly address environmental,social  corporate governance issues without compromising the ultimate objective of achieving high returns at a low level of risk.

AP3 strives to ensure that investee companies identify and manage environmental, ethical and social risks in a way that creates value for shareholders. Enterprises should conduct risk analysis and have governance and management systems and external reporting procedures in place. They should also have codes of conduct and policies that demonstrate their approach to ESG/Sustainability  both internally and externally with regard to stakeholders, including business partners and suppliers.

AP3 prefers to use the term sustainability and not the acronym ESG. ESG is of course vital and constitutes the mayor part of sustainability but in our view it does not fully mirror the processes and work that we see define responsible and sustainable investing and investment management.

AP3 believes that well managed companies offer investors superior returns and lower risk over time. Sustainability means both risks and opportunities for AP3, just as it does for all companies. The Fund incorporate sustainability into its investment strategy to creating long-term value for the Swedish state pension system. AP3 has an holistic view on sustainability, meaning that it comprises the whole organisation and the whole portfolio, all asset classes. The responsible investment strategy has to be long term cost efficient and follow the mission of the fund and the strategy the fund has chosen to achieve its target return. It should consider the ownership and exposures of the fund. The asset management is responsible for sustainability and all asset management mandates include a sustainability perspective.It is a matter of risk assessment both on the downside and the upside (opportunities). On a daily basis a team of two people are responsible to see to that the sustainability process  and work continue to develop, both from a corporate governance angle as from an integration perspective.

Within the framework of the mission of the Fund, AP3 has a process that is

  • Formalised with an overall process and principles how AP3 work with sustainability
  • Integrated with tools and means for the managers to fulfil their mandates, sustainability is a natural part of the investment discussions and decisions
  • Proactive, a dedicated group is responsible for the development of sustainability, a yearly review is carried to assess the work done and pinpoint areas for change and or improvement.
  • Reactive, how the Fund should act in connection with investee company incidents etc.

The overall strategy is

  • Risk diversification - a diversified portfolio,among and within asset classes
  • Risk limitation - Analytics and engagement
  • Risk elimination - exclusions, reduced exposure


  • Active ownership, engagement, dialogue and voting
  • Active selection both positive and negative (limited scope as divestments seldom solves the real problem)

The Sustainability team is, together with Strategic Allocation and Quant, part of the Portfolio Strategy team.

In December 2015 AP3 announced four sustainability targets that were all achieved by end 2018:

The carbon footprint of listed equities and credits to be halved by 2018 compared to 2014. Urge all companies to issue reports regularly their carbon footprint.  Triple the holdings of green bonds to SEK 15 billion. Double its strategic sustainability investments, for example in water treatment, to SEK 20 billion. Work to ensure that Vasakronan, Scandinavia's largest real estate company (in which AP3 owns a 25% equity stake), will continue to lead the way in sustainability in the real estate sector in Sweden. Make it a priority to ensure that AP3's other real estate investees (Hemsö, Trophi, Regio et al) adopt ambitious sustainability policies as they mature.

For the period 2019 - 2025 three new goals/targets have been set and decided by the board:

  1. AP3’s long-term portfolio will continue to contribute actively to reducing the risk of global warming.
  2. AP3 will double its thematic sustainable investments by 2025.
  3. AP3’s expects its directly owned unlisted investee companies to be sector leaders in sustainability.

Responsible Asset Allocator Initiative (RAAI)  selected in 2019 AP3  (and the other AP Funds) in their  List of Leaders, a  selection based on a rigorous analysis of 200 of the largest asset owners in the world.

OO 02. Headquarters and operational countries

02.1. Select the location of your organisation’s headquarters.


02.2. Indicate the number of countries in which you have offices (including your headquarters).

02.3. Indicate the approximate number of staff in your organisation in full-time equivalents (FTE).

58 FTE

02.4. Additional information. [Optional]

By year end 2019 the number of staff was 58 people. 


OO 03. Subsidiaries that are separate PRI signatories

03.1. Indicate whether you have subsidiaries within your organisation that are also PRI signatories in their own right.

03.3. Additional information. [Optional]

AP3 does not have any subsidiaries.

OO 04. Reporting year and AUM

04.1. Indicate the year end date for your reporting year.


04.2. Indicate your total AUM at the end of your reporting year.

Include the AUM of subsidiaries, but exclude advisory/execution only assets, and exclude the assets of your PRI signatory subsidiaries that you have chosen not to report on in OO 03.2
Total AUM
trillions billions millions thousands hundreds
Assets in USD
trillions billions millions thousands hundreds

04.5. Additional information. [Optional]

The AuM is impacted of both the result of the year and net payments to the pension system of SEK 6.5 bn.

OO 06. How would you like to disclose your asset class mix

06.1. Select how you would like to disclose your asset class mix.

Internally managed (%)
Externally managed (%)


Listed equity 10-50% 22 10-50% 22
Fixed income 10-50% 31 0 0
Private equity 0 0 <10% 5
Property 10-50% 14 0 0
Infrastructure <10% 1 <10% 3
Commodities 0 0 0 0
Hedge funds 0 0 0 0
Fund of hedge funds 0 0 0 0
Forestry 0 0 <10% 1
Farmland 0 0 0 0
Inclusive finance 0 0 0 0
Cash 0 0 0 0
Money market instruments 0 0 0 0
Other (1), specify <10% 1 0 0
Other (2), specify 0 0 0 0

`Other (1)` specified

          Insurance Linked Securities,ILS

06.2. Publish asset class mix as per attached image [Optional].

06.3. Indicate whether your organisation has any off-balance sheet assets [Optional].

06.5. Indicate whether your organisation uses fiduciary managers.

06.6. Provide contextual information on your AUM asset class split. [Optional]

AP3 divides its asset management in a risk class structure rather than the traditional asset class structure thus the division into asset classes is calculated.

The picture will be found in the AP3 Annual Report (available in English late March 2020).Årsredovisning_2019.pdf page 5

OO 07. Fixed income AUM breakdown

07.1. Provide to the nearest 5% the percentage breakdown of your Fixed Income AUM at the end of your reporting year, using the following categories.

Internally managed
85 SSA
5 Corporate (financial)
5 Corporate (non-financial)
5 Securitised
Total 100%

OO 08. Segregated mandates or pooled funds (Private)

OO 09. Breakdown of AUM by market

09.1. Indicate the breakdown of your organisation’s AUM by market.

93 Developed Markets
7 Emerging Markets
0 Frontier Markets
0 Other Markets
Total 100% 100%

09.2. Additional information. [Optional]

The absolute major part of the EM exposure is listed equity.Årsredovisning_2019.pdf  page 17