We may decide to exclude the securities of a company from the NZ Super Fund. We typically aim to engage with a company before moving to exclusion.
A decision to exclude a company is based on our Responsible Investment Framework.
Responsible Investment Framework
Companies may be excluded because of the products they make or because of their environmental, social and governance (ESG) practices. Sovereign exclusions may be introduced because of sanctions against nation states.
Product exclusions apply to companies based on their products and take account of restrictions or prohibitions by international conventions New Zealand has signed, and of New Zealand law or significant Crown actions.
Companies that are directly involved in the following products/activities are excluded from the portfolio, based on specific criteria contained in our exclusions policy documents (see column at right):
- the manufacture of cluster munitions
- the manufacture or testing of nuclear explosive devices (NEDs)
- the manufacture of anti-personnel mines
- the manufacture of tobacco
- the processing of whale meat
- recreational cannabis
- the manufacture of civilian automatic and semi-automatic firearms, magazines or parts
Environmental, social and governance (ESG) practices
We may exclude a company where we believe that there is a serious risk of breaches of standards of good corporate practice and that exclusion is the right course of action.
Generally it is best practice to engage with companies to encourage improved performance on ESG, rather than excluding them. However, engagement can take a significant amount of time and resource and so we focus our engagement efforts on priority issues.
In making a decision to engage, we assess a number of factors including the significance of our holding in the company, ability to join collaborative engagement initiatives and the potential effectiveness of engagement. If a company isn’t responsive to engagement, we may consider exclusion.
We may move straight to exclusion where engagement is unlikely to be effective or is a poor use of resource, for example because of the company’s operating context, or because our shareholding is small. Other relevant factors are considered on a case-by-case basis.
We disclose our exclusions every six months, including the relevant category of exclusion.
Sovereign bond exclusions
Our Responsible Investment Framework states that we will exclude the government (sovereign) bonds of any nation state where there is widespread condemnation or sanctions by the international community and New Zealand has imposed meaningful diplomatic, economic or military sanctions aimed at that government.
In March 2022, following the invasion of Ukraine, we excluded Russian Federation sovereign bonds.
How we apply exclusions
For individual company exclusions, our exclusion policy applies to all investments where securities are held directly, and the exclusion list is produced using their international issuer identification number (International Securities Identification Number).
Collective Investment Vehicles (CIVs) are pooled funds with other investors. We endeavour to apply exclusions to CIVs to the extent this is feasible and commercially prudent. CIVs are evaluated on a case-by-case basis and agreements are entered into where possible. The potential for indirect exposure to excluded securities through CIVs is factored into the selection of access points.
To the extent commercially and operationally feasible, exposure to excluded securities through derivative instruments tracking market indices is reversed.
The portfolio is monitored on an ongoing basis to ensure compliance with exclusions.
We are legally required to comply with sanctions imposed by the New Zealand Government. Under New Zealand law, we are also required to comply with sanctions imposed by the United Nations (UN) Security Council.
This includes the sanctions against certain Russian and Belarusian entities and individuals implemented by the New Zealand Government earlier this year, following the invasion of Ukraine in 2022.