Hall of Fame and Runners-Up

Fortunately, more and more financial institutions have acknowledged that cluster munitions producers are not ethical or viable long-term business partners and have installed a public policy to end investments in these companies. Some of them are listed in our Hall of Fame; others are listed in the Runners-Up.

Financial institutions are listed in the Hall of Fame when they have installed and implemented a comprehensive policy banning all financial links with cluster munitions producers.

Some financial institutions have installed a policy on cluster munitions that shows certain shortcomings. These financial institutions are listed in the Runners-Up category. We commend the financial institutions in the Runners-Up category for their efforts while at the same time suggest ways to strengthen their policy.

Check out the Hall of Fame here

To find out more about the methodology used in the research for the Hall of Fame, please see here.

Check out the Runners-Up here

The financial institutions listed in the Runners-Up category took steps to ban investments in cluster munitions producers, but their policies regarding cluster munitions have certain flaws. We commend these financial institutions for their efforts while pointing out the remaining steps necessary to acquire a place in our Hall of Fame. The most common shortcomings are:

  • Taking only the financial institutions’ own involvement into account, not that of third parties
  • Exempting project financing for civil purpose
  • Exempting funds following an index

To find out more about the methodology used in the research for the Runners-Up, please see below.


Methodology

Hall of Fame

The Convention on Cluster Munitions provides a strong legal basis for banning cluster munitions. In its wake, a growing group of financial institutions has come to accept responsibility for implementing a clear and far-reaching policy on dealing with cluster munitions producers. These financial institutions do not consider cluster munitions producers acceptable business partners. They do not condone business relations with cluster munitions producers, regardless the nature of the business relation and regardless the activity of the cluster munitions producer they want to invest in. Producing cluster munitions, regardless of their importance in a company’s total turnover, makes a company a no-go business partner for these investors. We welcome these initiatives and see them as examples for other financial institutions.

We have listed these financial institutions in our Hall of Fame.

To identify financial institutions with a policy on cluster munitions, research company Profundo researched a variety of sources: NGO reports, screening-agency information, financial institutions’ reports and websites, information from campaigners worldwide and other public sources. We worked within the limits imposed by language (English and Dutch) and accessibility. In some cases we have received translations of disinvestment policies that were not available in Dutch or English in the public domain, but in most cases we were limited to policies’ availability in Dutch or English.

The Hall of Fame is far from comprehensive. We believe that the financial institutions listed are only the tip of the iceberg. It is impossible to research the policies of every financial institution worldwide. Financial institutions that did not respond to our questions on their published policies were not included in this chapter. Our Hall of Fame is an invitation to financial institutions with a comprehensive policy banning investment in cluster munitions to provide us with their policies and to publish it on their websites in order for us to include them in either the runners-up category or the Hall of Fame.

Since the banking group usually sets the investment policy and since this group directly or indirectly supervises its subsidiaries, we researched the group’s policy.

We contacted all financial institutions in this list prior to publication to verify our research findings and to be sure we interpreted their policies correctly. We only include policies publicly available at the time of writing.

Financial institutions must meet the following criteria to be included in our Hall of Fame:

  • An investor must be transparent and accountable on its cluster munitions policy. This means that the investor has published its policy and/or a summary of it.
  • Its policy must exclude investment in cluster munitions producers (recalling past investment and avoiding further investment).
  • The policy must have an ‘all-in’ comprehensive scope:

–     no exceptions for any type of cluster munitions producers

–     no exceptions for any type of activities by cluster munitions producers

–     no exceptions for any type of financing or investment

We researched investment in red flag companies for each financial institution in our Hall of Fame. This included shareholdings under the thresholds we use for the Hall of Shame. We chose to do so because any involvement at all in a cluster munitions producer, after publication of a policy excluding this, is evidence of poor implementation. When we found evidence that financial institutions listed in our Hall of Fame had financial links with cluster munitions producers, we contacted the institution to confront it with our findings. When there were no legal constraints preventing a financial institution’s disinvestment, we removed it from our Hall of Fame.

Runners up:

Financial institutions included in the runners-up have also made significant efforts to ban cluster munitions from their investment portfolios. Still, their policies are not sufficiently comprehensive for our Hall of Fame. They have policies, but loopholes in these could still permit them to finance cluster munitions producers.

The runners-up category is much diversified and the policies’ scope differs widely. In some cases, a policy does not apply to all a company’s activities, or does not cover all of a financial institution’s services. Other financial institutions may have a more extensive policy, yet be weak on implementation. These financial institutions’ policies could still allow for links with cluster munitions producers, even though this runs contrary to their stated principles.

The runners-up category is far from comprehensive. We believe that the financial institutions listed are only the tip of the iceberg. It is impossible to research the policy of every financial institution worldwide. The runners-up category can be seen as an invitation to financial institutions that have comprehensive policies prohibiting investment in cluster munitions to provide us with their policy and to publish it on their websites. We look forward to including them as runners-up or members of our Hall of Fame.

We commend the financial institutions in the runners-up category for their policies, but take the liberty of pointing out a few shortcomings.

Financial institutions have to meet the following criteria to be considered a runner-up:

  • An investor must be transparent and accountable on its cluster munitions policy. This means that the investor has published its policy and/or a summary of it.
  • Its policy must exclude investment in cluster munitions producers (recalling past investment and resolving to avoid further investment).

The runners-up category lists financial institutions which meet the two foregoing criteria. They differ from those in our Hall of Fame in that they do not yet meet the following criteria:

  • The policy must have an ‘all-in’ comprehensive scope:

–     no exceptions for any type of cluster munitions producers

–     no exceptions for any type of activities by cluster munitions producers

–     no exceptions for any type of financing or investment

–     no breaches of this all-in comprehensive policy after the publication or announced implementation date of the policy.

Since the banking group usually sets the investment policy and since this group directly or indirectly supervises its subsidiaries, we researched the group’s policy.

We contacted all the financial institutions in this list prior to publication to verify our research findings and to be sure we understood their policy correctly.

 


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