ACTIAM's Fundamental Investment Principles prevents us from investing in activities that cause serious environmental damage and/or harmful to human life, among others. In 2019, the regular screening has shown that a company that was under Responsive Engagement for past controversies in both topics was responsible again for severe damages to the environment, as well as the death of several people. Despite the company's responsiveness to engagement until then, the company reincurred in severe violations. ACTIAM considered this an evidence of irrecuperable failure by the company, deciding then to exclude it from its investable universe.

Given the severe violation, despite engagement, the company was excluded from the investable universe, resulting in divestment.

Several ESG topics are incorporated into the ESG Score of the investees. For Corporate (financials), product safety is among the various material topics. During 2019, the ESG Score of a company was downgraded following an update that has shown very low performance and significant controversies related to financial product safety by the company.

The significant downgrade of the company's ESG Score has led FI portfolio managers less interested in the issuer, selling some of the assets held in the active portfolios and substituting for names of higher ESG Score.

During a regular screening, and according to the 2019 update of ACTIAM's Sustainable Policy, a company was found to be non-adaptive due to their Fossil Fuel use (high share of coal-fired power generation, as well as plans for new coal-fired power plants). In-house assessment has shown no potential for responsive engagement. The company was thus excluded from the investable universe.

By excluding the company, no investments can be done by the portfolio managers, dimishing the investment universe.

Our Fundamental Investment Principles prevent ACTIAM from investing in companies involved in severe damage to the environment. Activities such as mountain top removal and riverine tailings disposal are considered extremely harmful and lead to exclusion. Every year, all companies excluded from ACTIAM's investable universe to date are reviewed through a screening. The 2019 review has shown that one of the excluded companies no longer applied such activities. A fundamental analysis of the company's current practices confirmed such information. The ESG Committee has therefore decided for inclusion of the company in the investment universe.

The re-inclusion of the company enables investment again, expanding the investable universe for FI portfolio managers.

In the end of 2018, a renewable energy company announced an asset swap, leading to reduction of their renewable power generation assets. The company had previously launched a Green Bond, in which ACTIAM participated, with a use of proceeds for renewable energy generation projects. The asset swap meant a change on use of proceeds by the company, now allocated to grid projects.

ACTIAM analysed the reallocation of use of proceeds by the company. We concluded that the reallocation of assets did not show strong ambitions. The reallocation from solely renewable energy to connecting renewables and smart meters, coupled with the already large amount going to grid investments related to the wind energy made the level of ambition of that framework doubtful. There were no strong plans for making the grid “greener”. Additionally, following the swap, it was not clear how the pool of green assets and projects would grow over time. ACTIAM has concluded the ESG Score of the bond should be downgraded due to the diminishing of ambition. The ESG Score was adjusted from 85 to 75, the minimum ESG Score for Green Bonds.