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KLP list Companies excluded as of December 2017

* The company is excluded for more than one reason.

1

Company Country Industry Reason for exclusion

Human rights

Enbridge Canada Oil & gas storage &

transportation

Enbridge is one of four companies involved in the construction of the Dakota Access

Pipeline in the United States. The pipeline route crosses underneath Lake Oahe, the

drinking water source for the Standing Rock Sioux Tribe and less than a kilometer

from the Tribe's reservation. In February 2017, the US Army Corps of Engineers

granted the final easement to complete construction of the pipeline, cancelling a

planned environmental impact statement. In March, the UN Special Representative on

the Rights of Indigenous Peoples announced that the pipeline licenses were granted

without sufficient consultation with affected tribes.

The company was excluded in 2017.

Energy Transfer

Partners

USA

Oil & gas storage &

transportation

Energy Transfer Partners is the operator of the joint venture involved in the

construction of the Dakota Access Pipeline in the United States. The pipeline route

crosses underneath Lake Oahe, the drinking water source for the Standing Rock Sioux

Tribe and less than a kilometer from the Tribe's reservation. In February 2017, the US

Army Corps of Engineers granted the final easement to complete construction of the

pipeline, cancelling a planned environmental impact statement. In March, the UN

Special Representative on the Rights of Indigenous Peoples announced that the

pipeline licenses were granted without sufficient consultation with affected tribes.


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2

Marathon Petroleum

USA

Oil & gas refining &

marketing

Marathon Petroleum is one of four companies involved in the construction of the

Dakota Access Pipeline in the United States. The pipeline route crosses underneath

Lake Oahe, the drinking water source for the Standing Rock Sioux Tribe and less than

a kilometer from the Tribe's reservation. In February 2017, the US Army Corps of

Engineers granted the final easement to complete construction of the pipeline,

cancelling a planned environmental impact statement. In March, the UN Special

Representative on the Rights of Indigenous Peoples announced that the pipeline

licenses were granted without sufficient consultation with affected tribes.


Phillips 66

USA

Oil & gas refining &

marketing

Phillips 66 is one of four companies involved in the construction of the Dakota Access

Pipeline in the United States. The pipeline route crosses underneath Lake Oahe, the

drinking water source for the Standing Rock Sioux Tribe and less than a kilometer

from the Tribe's reservation. In February 2017, the US Army Corps of Engineers

granted the final easement to complete construction of the pipeline, cancelling a

planned environmental impact statement. In March, the UN Special Representative on

the Rights of Indigenous Peoples announced that the pipeline licenses were granted

without sufficient consultation with affected tribes.





3

POSCO DAEWOO

South Korea

Capital goods

Formerly, Daewoo International Corporation

POSCO DAEWOO is one of the largest buyers of cotton from Uzbekistan. The Uzbek

state maintains a monopoly on the sale of cotton abroad and the use of child labor

during the cotton harvest has long been confirmed by international sources. The use of

child labor has steadily declined, but has been replaced with a corresponding increase

in the use of adult forced labor. The companies are aware of the risk, but have no plans

to change their sourcing practices and have not implemented measures designed to

ensure that forced labor and child labor are not used in their supply chain in the future.


Olam

International

Singapore

Food and staples

retailing

Olam International sources 10,000 tons of cotton from Uzbekistan annually. The

Uzbek state maintains a monopoly on the sale of cotton abroad and the use of child

labor during the cotton harvest has long been confirmed by international sources. The

use of child labor has steadily declined, but has been replaced with a corresponding

increase in the use of adult forced labor. The company is aware of the risk and over the

last few years has reduced significantly the amount of cotton it purchases from

Uzbekistan. Nevertheless, the company continues to purchase cotton despite its

inability to monitor whether forced labor or child labor are used within its supply chain

in Uzbekistan going forward.





4

POSCO

South Korea

Materials

POSCO is the majority shareholder in POSCO DAEWOO , a company that is among

the largest purchasers of cotton from Uzbekistan (see discussion of POSCO

DAEWOO). The Uzbek state maintains a monopoly on the sale of cotton abroad and

the use of child labor during the cotton harvest has long been confirmed by

international sources. The use of child labor has steadily declined, but has been

replaced with a corresponding increase in the use of adult forced labor. The companies

are aware of the risk, but have no plans to change their sourcing practices and have not

implemented measures reasonably designed to ensure that forced labor and child labor

are not used in their supply chain in the future.


Zuari Agro Chemicals

India

Materials

Zuari Agro Chemicals Ltd. (Zuari) is excluded due to an unacceptable risk that the

company, through its production of hybrid seeds, is complicit in the worst forms of

child labor.

The Council on Ethics for the Government Pension Fund – Global researched the scale

of child labor in the company's hybrid seed production in 2011 and 2012. On average,

it was discovered that from 20 to 30 percent of the workforce involved in the

production of seeds for the company consisted of children. In its evaluation, the

Council has placed emphasis on the systematic use of children in the company's

production. The children's young age and the health risk to which they are exposed

through this work, including the use of pesticides, indicates that this can be considered

among the worst forms of child labor. The Council on Ethics has furthermore

emphasized that the risk of child labor is well known within the industry, that the

company is in close cooperation with the farmers that employ child labor, and that the

company does not have any concrete measures to reduce the incidence of child labor.





5

Labor rights

Wal-Mart Stores USA Food and staples

retailing

A constant stream of reports in the media and court cases indicate the existence of

systematically poor working conditions at Wal-Mart. The company is criticized for

repeated violations of labor rights in several areas. The criticism involves child labor,

factories that exploit workers, discrimination against women and efforts to resist

unionization. One example is that 67,500 former and current employees in 2008 won a

court case in which Wal-Mart was found to have systematically withheld employee

wages. The judgement was handed down from the highest court in Massachusetts, and

more than 30 similar cases against Wal-Mart are active in other American states.

Another example is a class action lawsuit where 1,6 million employees and former

employees accuse the company of systematically discriminating against women.


Environment

Bharat Heavy

Electricals Ltd.

India Industrials Bharat Heavy Electricals Ltd. (BHEL) was awarded a contract to construct a coal power

plant in a vulnerable natural area of unique biodiversity in Bangladesh. The Sundarbans is

one of the world’s largest mangrove forests, and is rich in biodiversity. Two world heritage

sites lie within the national park itself, while a further world heritage site lies across the

border on the Indian side. Bharat Heavy Electricals has not implemented adequate measures

to reduce the risk of serious damage to a vulnerable area. It is also questionable whether it is

even possible to complete the project in this area safely.





6

Barrick Gold

Canada

Materials

Barrick Gold, the world's largest gold producer, operates, inter alia, the Porgera mine in

Papua New Guinea. The company uses a natural river system for the transportation and

deposition of mine waste. This has both a physical and chemical impact that affects water

quality, human beings and animal life. The release of heavy metals such as mercury will be

highly problematic long into the future. The waste contains high concentrations of, inter

alia, arsenic, cadmium, copper, lead and zinc. The environmental damage that depositing

mine waste in river systems can cause is well known, but the company has not implemented

significant measures to prevent or reduce this damage.


Duke Energy Corp.,

including the

subsidiaries Duke

Energy Carolinas

LLC, Duke Energy

Progress LLC,

Progress Energy Inc.

USA

Utilities

The company was previously excluded for coal-based activities. As this know comprises a

smaller proportion of the company's revenues, the exclusion is now based on the risk of

severe environmental damage. Duke Energy and the named subsidiaries are excluded from

the Government Pension Fund Global for repeated violations connected to the treatment of

ash waste from coal power plants in the USA. The waste depots are not expected to be

removed before 10 to 15 years from now.


Freeport McMoRan

USA

Materials

Freeport McMoRan Copper & Gold operates the world's largest gold mine and second

largest copper mine on New Guinea in Indonesia. The company deposits mine waste in a

natural river system, and heavy metal runoff has from the company's landfills for waste rock

and tailings has been documented. The company dumps as much as 230,000 tons per day.

Comprehensive documentation shows that the company's activities have caused widespread

and permanent environmental damage to the ecosystems in and along the entire watercourse

and that the company has only to a limited extent implemented measures to prevent or

mitigate this damage.





7

Genting Berhad

Malaysia

Hotels, restaurants &

leisure

Genting Berhad, through its subsidiary, Genting Plantations Berhad, is excluded due to an

unacceptable risk that the company's ongoing conversion of rainforest to oil palm

plantations in Indonesia will cause a serious loss of biodiversity. The company has not

indicated it will engage in mitigating measures sufficient to lessen the risk of severe

environmental damage.


Genting Plantations

Berhad

Malaysia

Food products

Genting Plantations Berhad is excluded due to an unacceptable risk that the company's

ongoing conversion of rainforest to oil palm plantations in Indonesia will cause a serious

loss of biodiversity. The company has not indicated it will engage in mitigating measures

sufficient to lessen the risk of severe environmental damage.


IJM Corporation

Berhad

Malaysia

Construction and

engineering

IJM Corporation Berhad, through its subsidiary, IJM Plantations Berhad, is engaged in the

conversion of rainforest to palm oil plantations in an area of rich and unique biodiversity in

Indonesia. The company has not announced how it has mapped high conservation values

within the affected concessions. Nor has it announced significant mitigating measures to

stem the potentially irreversible loss of biodiversity.


IJM Plantations

Berhad

Malaysia

Food products

IJM Plantations Berhad is engaged in the conversion of rainforest to palm oil plantations in

an area of rich and unique biodiversity in Indonesia. The company has not announced how it

has mapped high conservation values within the affected concessions. Nor has it announced

significant mitigating measures to stem the potentially irreversible loss of biodiversity.





8

Lingui Development

Malaysia

Paper and forest

products

Lingui Developments Berhad produces, among other things, timber and wood products.

Investigations by the Council on Ethics for the Government Pension Fund – Global

documented what appears to be comprehensive and repeated violations of concession

requirements and regulations in all of the company concessions that were investigated.

Some of the violations were extremely serious, such as logging outside of the concession

areas, logging in protected areas that were excluded by the authorities from the concession

for inclusion in an existing national park, and the completion of second-generation logging

without an environmental impact assessment.


Madras Aluminium

Company

India

Metals and mining

Madras Aluminium Company (Malco) is a listed subsidiary of Vedanta. The company is

recommended excluded by the Council on Ethics for the Government Pension Fund –

Global in the same recommendation as the parent company. Malco generates significant

quantities of pollution and hazardous waste. The accusations have been directed especially

at the disposal of red mud, a waste prouct from refining bauxite. It is, however, also

reported that operation of the mines, smelters and power plants entails significant

environmental consequences and health damage for the local population.





9

Noble Group Ltd.

Singapore

Capital goods

Noble Group owns through two subsidiaries concession areas in, respectively, Papua and

West Papua, in Indonesia, where the company plans to convert forest to palm oil

plantations. The area has a unique biological diversity that cannot be found in any other part

of the world. The company has completed pre-development studies of the concession areas'

conservation value, known as "high conservation value" or "HCV" assessments. Technical

experts retained by the Council on Ethics for the Government Pension Fund – Global have

identified significant weaknesses in these HCV assessments, which in KLP's estimation the

company has not addressed in a sufficient manner. Neither does the company have any

plans to undertake new assessments, or submit the existing assessments for third party peer

review. Although the company is a member of the Roundtable on Sustainable Palm Oil, that

organization's currently applicable requirements are more stringent than those which

prevailed when the HCV assessments were undertaken. Due to all of the above reasons,

KLP determines that there exists an unacceptably high risk that the company, through the

conversion of rainforest to palm oil plantiations, will cause serious environmental damage.


Norilsk Nickel

Russia

Materials

Norilsk Nickel's Polar division in Siberia has emitted large quantities of sulfur dioxide,

nickle and heavy metals for many years. These emissions have lead to the death or

significant damage of vegetation up to 20 kilometers from the facilities. The air pollution

has also led to significant health problems among the local population. Respiratory illness

and various forms of cancer are far more common here than in other parts of Russia. The

environmental damage is comprehensive, long-term, and in some cases, irreparable.

Although the company has implemented measures in recent years to reduce the release of

metals into the environment, the levels remain high and sulfur dioxide emissions are

essentially unchanged. In the Council's opinion, the company does not appear to be in

compliance with national environmental standards, and does not appear to have plans to

remediate polluted areas.





10

Rio Tinto

UK

Metals and mining

Together with Freeport McMoRan, Rio Tinto owns the world's largest gold mine and the

world's next largest copper mine on New Guinea in Indonesia. The Grassberg mine emits

large quantities of tailings, approximately 230,000 tons per day, directly into a natural river

system. These tailings will increase going forward, in conjunction with expansion of the

mine. Furthermore, there is a large risk that the runoff of heavy metals from the company's

landfills for waste rock and tailings pollute the soil and watercourses. The mine is expected

to be operational through 2041, which must be considered to imply a severe impact on the

environment as nothing indicates that the company will change these practices in the future.


Samling Global

Malaysia

Paper and forest

products

The Malaysian forestry company Samling Global is recommended for exclusion by the

Council on Ethics for the Norwegian Government Pension Fund – Global due to illegal

logging and serious environmental damage. The Council on Ethics has investigated the

company's activities in Sarawak (Malaysia) and Guyana.


Ta Ann Berhad

Holdings

Malaysia

Materials

Ta Ann Holdings Berhad (Ta Ann) is excluded due to an unacceptable risk that the

company, through its forestry operations, is responsible for severe environmental damage.

Ta Ann is a Malaysian forestry company with its principal place of business on Borneo in

Sarawak, Malaysia. The company engages in logging of tropical forest, and is in addition in

the process of converting large forest areas to plantations for the production of wood and

palm oil.

The Council on Ethics for the Government Pension Fund – Global has evaluated the

environmental impact connected to logging and deforestation in Ta Ann's concession areas

in Sarawak. The Council has evaluated in particular to what extent the concession areas

overlap with areas of high ecological value, and the consequences that conversion of forest

entails for threatened species and their habitat.





11

Tokyo Electric Power

Company

Japan

Utilities

In 2011, the nuclear power plant Fukushima Dai-ichi, which is owned by Tokyo Electric

Power Company (TEPCO), was hit by an earthquake and accompanying tsunami. Although

TEPCO and the company's leadership did all that they could to prevent the catastrophic

consequences the accident caused, and can be considered to have done everything correctly

in an emergency situation, the consequences of the tsunami and the accident could have

been reduced, and perhaps avoided entirely, through greater attention to risk in advance. In

addition, the company has not managed to obtain control over the situation following the

accident, nor to prevent additional spills. There remains a large risk of further leakages of

radioactive material from the nuclear power plant. KLP therefore considers investment in

TEPCO to entail a risk of complicity in severe environmental damage, and therefore a

violation of KLP's guidelines for responsible investment.


Vedanta Limited*

India

Materials

Formerly, Sesa Sterlite.

Vedanta Limited is a joint venture partner in the aluminum factory currently under

construction in Orissa, India, in which Vedanta Resources is the controlling shareholder.

See Vedanta for the rationale for exclusion.

Vedanta Resources*

UK

Materials

Vedanta Resources is in the process of establishing aluminum production in Orissa, India.

According to Indian authorities, during this process, the company has violated Indian

environmental laws, misled authorities, and caused serious environmental damage. The

facility's establishment requires the clearing of several square kilometers of forest in one of

India's most biodiverse regions, which is home to several threatened species. Furthermore,

the company is accused of illegally expanding production, irresponsible hazardous waste

management, violations of indigenous rights, and poor wages and dangerous working

conditions in its mines and factories.





12

Volcan Compañia

Minera

Peru

Materials

The Council on Ethics for the Government Pension Fund – Global recommends exclusion

of the Peruvian company Volcan Compañia Minera SAA (Volcan) due to the unacceptable

risk that the company, through its mining operations in Cerro de Pasco, Peru, is complicit in

serious environmental damage. Volcan is Peru's largest producer of lead and silver, as well

as the country's second largest producer of zinc. The mine is located within a city of 70,000

inhabitants. Since mining operations take place within populated areas of the city, the

Council has placed emphasis on the consequences of mining operations for human life and

health, especially the risk of illness and injury among children, owing to high lead

concentration in the soil and water.


WTK Berhad

Holdings

Malaysia

Materials

WTK Holdings Berhad (WTK) is excluded due to an unacceptable risk that the company,

through its logging operations, is responsible for serious environmental damage. WTK is a

Malaysian forestry company that engages in logging and the production of plywood and

lumber.

The Council on Ethics for the Government Pension Fund – Global has placed emphasis on

the environmental damage connected to the conversion of tropical forest to plantations,

environmental damage from logging, and that the company's operations appear to violate

the usual concession conditions and can therefore be assumed to be illegal. In its evaluation,

the Council emphasized the scale of the damage and the extent to which it entails long-term

or irreversible effects, whether the environmental damage violates national standards and

international norms, and what the company has done to mitigate the effect of the damage.





13

Zijin Mining Group

China

Materials

Zijin Mining Group Co. Ltd. (Zijin) is excluded due to an unacceptable risk that the

company, through its operations, will cause serious environmental damage. Zijin is a large

producer of gold, copper and zinc, and has several facilities for mineral extraction and metal

production. Over the past few years, there have been several serious incidents at the

company's facilities where landfill dams for mining and process waste have collapsed,

leading to widespread pollution and the loss of human life. The incidents involved landfill

dams that have collapsed, such that large quantities of mining waste, industrial waste and

hazardous chemicals have washed into waterways or flooded settlements and arable land. In

the span of the past ten years, seven such incidents have been reported at the company's

facilities in China.


Corruption

Centrais Eletricas

Brasileiras SA

(Eletrobras)

Brazil Electric utilities Eletrobras is excluded due to an unacceptable risk of gross corruption. According to its

reports to US financial authorities, the company's contracts with suppliers have been

inflated over a period of nearly seven years, with the excess paid to Brazilian politicians,

political parties and company executives. Until October 2016, Eletrobras risked delisting

from the New York Stock Exchange. This was due to incomplete accounting for corruption

in its financial reports after the company's auditor refused to approve the reports for 2014

and 2015. The company no longer faces delisting, but writes to US financial authorities that

it could take close to two years before a comprehensive anticorruption program is in place.





14

China Railway Group,

Ltd.

China

Capital goods

China Railway Group, Ltd. has been associated with serious corruption, inter alia, through

the payment of bribes to public officials in China to secure the company railway contracts.

The bribe recipients have later been punished through the court system and the Communist

Party's disciplinary processes. CRG's leadership is essentially unchanged since that time,

and publicly available information about the company's ethical guidelines indicate major

omissions relative to the routines in operation in the rest of the industry. Neither has the

company responded to KLP's inquiries about the case. Therefore, the risk that CRG will be

involved in future serious corruption is considered to be unacceptably high.


Leonardo SpA

Italy

Capital goods

Previously, Finmeccanica

Leonardo SpA has been excluded since January 2006 for its involvement in nuclear weapons production. Production of this type of weapon has since ended, but KLP has delayed including the company due to concerns about Leonardo SpA's involvement in multiple serious corruption cases. The company has been involved in serious cases of corruption, which is alleged to have taken place in four countries between 2009 and 2014. Three of the cases are still under investigation, while two former senior executives have recently been convicted in Italy for gross corruption in connection with a contract in India. In every case, it is claimed that the company, via agents, bribed public officials. In dialogue with the company, KLP has not gained confidence that Leonardo SpA has implemented sufficient measures to reduce the risk of future gross corruption. KLP has changed the rationale for exclusion from production of nuclear weapons to unacceptable risk of gross corruption.





15

PetroChina

China

Energy

The corruption case in PetroChina Co. Ltd. spans three countries over the period 1999 to 2014. Several members of the leadership team have been convicted for corruption, including the CEO from 2000 to 2013, who was also the board chair from 2007 to 2011. As many as 65 leaders and middle managers from the company are under investigation. PetroChina Co. Ltd has improved its internal controls since 2014, but the company provides few details about how these are implemented and their effectiveness. Aside from those who have been convicted of corruption, the PetroChina leadership team remains essentially unchanged. KLP has concluded that the risk of serious corruption remains unacceptably high and the company is therefore excluded. The company was excluded in 2017.

Petróleo Brasileiro

S.A. (Petrobras)

Brazil

Energy

Petrobras is involved in the largest corruption scandal in Brazilian history. Over more than

a decade, the company's contracts with suppliers were routinely inflated by three percent of

the contract sum, with the proceeds paid in bribes to Brazilian politicians, political parties

and Petrobras executives. Despite the company's many remedial measures and continued

outside pressure, KLP remains convinced that there remains an unacceptable risk that the

company will be involved in corruption in the future.


ZTE Corporation

China

Technology

Hardware &

Equipment

ZTE Corporation has been under investigation for 10 corruption cases. It has been

temporarily barred from public bidding processes and, in one case, received a corporate

criminal conviction. In sum, the allegations encompass over 18 countries. ZTE Corporation

has not communicated any new measures undertaken to prevent recurrence. KLP concludes

that the company continues to face an unacceptably high risk for involvement in corruption.





16

Rights of individuals in war and conflict

AFI Group Israel Real estate AFI Group is involved in the construction of Israeli settlements in the Occupied Palestinian

Territories. In 2009, subsidiary Danya Cebus constructed housing in three settlements in the

region. According to international law, especially the Fourth Geneva Convention relative to

the Protection of Civilian Persons in Time of War, the Israeli settlements are illegal. Several

UN Security Council Resolutions and an International Court of Justice Advisory Opinion

have concluded that the establishment of Israeli settlements on occupied Palestinian territory

is illegal according to this convention.


Danya Cebus

Israel

Engineering and

construction

See the reason for exclusion of AFI Group.


Shikun & Binui

Israel

Engineering and

construction

Shikun & Binui Ltd. is involved in the construction of Israeli settlements in East Jerusalem

and has previously also been involved in the building of settlements on occupied territory in

the West Bank and in East Jerusalem. The International Court of Justice, the UN Security

Council and the International Committee of the Red Cross (ICRC) have all determined that

the construction of Israeli settlements in the West Bank and in East Jerusalem violates the

Fourth Geneva Convention. The purpose of this convention is to protect civilians in time of

war and occupation.





17

Other ethical norms

Agrium Inc. Canada Materials Agrium has confirmed that the company imports phosphate from Western Sahara. The

International Court of Justice has determined that Morocco has no legal claim to Western

Sahara and, accordingly, none to Western Sahara's natural resources. Extraction of natural

resources from occupied territory, in particular, in Western Sahara, has also been declared

illegal by the UN Under-Secretary-General for Legal Affairs in 2002.


Cairn Energy

UK

Oil & Gas

exploration

Through a 20 % ownership stake in a joint venture with Kosmos Energy Ltd. and the Office

National des Hydrocarbures et des Mines (ONHYM), Cairn holds a license issued by

Moroccan authorities for oil exploration off the coast of Western Sahara. KLP and the KLP

Funds consider investment in Cairn to be in violation of the KLP and KLP Funds' guidelines

for responsible investment, and the company's activities on the continental shelf off the

coast of Western Sahara are associated with violations of fundamental ethical norms.


Elbit Systems

Israel

Capital goods

Elbit Systems supplies an electronic surveillance system that is a component in the

separation barrier that Israeli authorities have constructed along the West Bank. The

sections of the barrier that lie within the Occupied Palestinian Territories are considered

illegal under international law. Through its supply of this system, Elbit contributes to

support illegal activities.





18

Glencore plc

UK

Metals and mining

Glencore is conducting exploration and seismic studies of possible oil reserves under the

continental shelf off the coast of Western Sahara. KLP considers investment in Glencore to

be in conflict with KLP's guidelines for responsible investment and has conclude that the

company's operations on the continental shelf off the coast of Western Sahara are associated

with a violation of fundamental ethical norms.

The company was excluded in 2015

HeidelbergCement

Germany

Materials

HeidelbergCement is excluded due to the company's extraction of natural resources from

occupied territory. Through a subsidiary, HeidelbergCement operates a quarry in Area C in

the West Bank, an area under full Israeli civil and military control. The quarries were

established after the occupation began and license fees and royalties are paid to the Israeli

state. Based on a review of the law of belligerent occupation, KLP concludes that the

activities are not consistent with the international law principle that occupation shall be

temporary. Neither does this resource extraction benefit the local population. Therefore, the

operation of a quarry on occupied territory that was opened after the occupation constitutes

an unacceptable risk of violating fundamental ethical norms.


Incitec Pivot

Australia

Chemicals

Incitec Pivot imports phosphate rock from Western Sahara, which is under Moroccan

occupation. The International Court of Justice has determined that Morocco has no legal

claim to Western Sahara, and by extension, no legal claim to Western Sahara's natural

resources. Extraction of natural resources from occupied territory, in particular, in Western

Sahara, has also been declared illegal by the UN Under-Secretary-General for Legal Affairs

in 2002.





19

Kosmos Energy Ltd.

USA

Oil & Gas

exploration

Through a 55 % ownership stake in a joint venture with Cairn Energy Plc. and the Office

National des Hydrocarbures et des Mines (ONHYM), Kosmos holds a license issued by

Moroccan authorities for oil exploration off the coast of Western Sahara. Kosmos is also the

operator. KLP and the KLP Funds consider investment in Kosmos to be in violation of the

KLP and KLP Funds' guidelines for responsible investment, and the company's activities on

the continental shelf off the coast of Western Sahara are associated with violations of

fundamental ethical norms.


Potash Corp

Saskatchewan

Canada

Chemicals

Potash has confirmed that a fully-owned subsidiary imports phosphate rock from Western

Sahara. The International Court of Justice has determined that Morocco has no legal claim

to Western Sahara, and by extension, no legal claim to Western Sahara's natural resources.

Extraction of natural resources from occupied territory, in particular, in Western Sahara, has

also been declared illegal by the UN Under-Secretary-General for Legal Affairs in 2002.


San Leon Energy PLC

Ireland

Energy

San Leon Energy conducts oil exploration off the coast of Western Sahara on the basis of a

contract with the Moroccan authorities. KLP considers investment in San Leon Energy to be

in conflict with KLP's guidelines for responsible investment and has conclude that the

company's operations on the continental shelf off the coast of Western Sahara are associated

with a violation of fundamental ethical norms.





20

Weapons producers

Aerojet Rocketdyne

Holdings

USA Capital goods Formerly, GenCorp.

Aerojet Rocketdyne Holdings produces cluster munitions components. The company

markets warheads for the weapons systems GMLRS, MLRS and ATACMS on its website.

All three meet the definition of cluster munitions as set out in the Convention on Cluster

Munitions. Aerojet Rocketdyne Holdings is also involved in the production of nuclear

weapons. The company produces propellants for missiles that have no other function than to

deploy nuclear warheads.


Airbus Group,

including bonds issued

by Airbus Group

Finance B.V.

The

Netherlands

Capital goods

The company is complicit in the production of nuclear weapons. Formerly, EADS.


BAE Systems

UK

Aerospace and

defense

BAE Systems is involved in the production of nuclear weapons through its contract with the

US Air Force for maintenance and upgrading of the Minuteman III ICBM weapons system,

valid through 2021. This is considered nuclear weapons production as components must be

updated and replaced on a rolling basis in order to keep a several-decades-old weapon

system technologically updated.





21

Boeing

USA

Capital goods

According to information on its website, Boeing supplies various forms of maintenance and

upgrades of the Minuteman III ICBM. ICBMs are the main component in US land-based

strategic nuclear weapons.


BWX Technologies

Inc.

USA

Capital goods

Previously, Babcock & Wilcox Company.

BWX Technologies is involved in the development and operation of central elements and

services connected to nuclear weapons. The company operates two nuclear weapons

facilities on behalf of the US military.


Fluor Corp.

USA

Construction and

engineering

Through a joint venture with Honeywell and Huntington Ingalls Industries, Fluor Corp.

provides the US military with its sole source of tritium gas. Tritium is a central component

in nuclear warheads. The companies deliver the gas in a concentration intended for weapons

use only.


General Dynamics

USA

Capital goods

General Dynamics is involved in nuclear weapons production and in the US nuclear

weapons defense system. In addition, the company has produced cluster munitions, but

stated in 2010 that it no longer markets or produces this type of weapon. Nevertheless, the

company will not guarantee that it will not produce cluster munitions in the future.





22

Hanwha

South Korea

Materials

Hanwha Corporation has confirmed to the Council on Ethics for the Government Pension

Fund – Global that it produces air- and surface-delivered cluster munitions. The company

also markets these on its website.


Honeywell

International

USA

Capital goods

Through its subsidiary Honeywell Technology Solutions Inc., the company is responsible

for the repair, development, calibration, operation and maintenance of measuring

instruments, as well as the registration of data for nuclear weapons detonation simulations at

White Sands Missile Range in New Mexico.


Huntington Ingalls

Industries

USA

Aerospace and

defense

Through a joint venture with Honeywell and Fluor Corp., Huntington Ingalls Industries

provides the US military with its sole source of tritium gas. Tritium is a central component

in nuclear warheads. The companies deliver the gas in a concentration intended for weapons

use only.


Jacobs Engineering

USA

Construction and

engineering

Jacobs Engineering Group is involved in the development of central elements and services

connected to nuclear weapons. The company's joint venture, Atomic Weapons

Establishment (AWE), is involved in the production and maintenance of warheads for the

Trident II missile system, which is a part of the British nuclear defense system.





23

Lockheed Martin

USA

Capital goods

The company is involved in the development of central components and services connected

to nuclear weapons. The company's joint venture Atomic Weapons Establishment (AWE) is

involved in the production and maintenance of warheads for the Trident II missile system,

which is part of the British nuclear defense system.


Northrop Grumman

USA

Capital goods

The company is, according to its own press release, contracted to complete maintenance and

upgrading of the US Air Force’s Minuteman III ICBMs. ICBMs constitute the main

component of the United States' land-based, strategic nuclear weapons.


Orbital ATK

USA

Capital goods

Formerly, Alliant Techsystems.

Orbital ATK has been involved in several weapon projects, both as a supplier of special

components and as the main producer of whole cluster munitions. The company no longer

produces cluster munitions, but follows US policy on the subject and will produce if there is

demand. Alliant Techsystems is also involved in the production and maintenance of nuclear

weapons (US nuclear defense system).


Poongsan Corporation

South Korea

Materials

Poongsan Corporation produces various types of ammunition for military use, hereunder,

cluster munitions. On its website, the company describes three variations of this type of

weapon.





24

Poongsan Holdings

Corporaiton

South Korea

Materials

Poongsan Holdings owns 32 percent of Poongsan. See the reason for exclusion of

Poongsan.


Raytheon

USA

Capital goods

Raytheon is involved in the development of central elements and services connected to

nuclear weapons. The company is involved in the Trident II missile system, which is a part

of the US nuclear defense system. According to its website, the company also produces

JSOWs (joint stand off weapons) and cluster ammunition for these. This weapon is

considered a cluster munition. This information is confirmed by Jane’s Information Group.


Safran Group

Frankrike

Capital goods

Safran is the parent company for the companies Snecma and Sagem, which according to

Jane’s Missiles and Rockets are producing a new missile system (M51) for strategic nuclear

weapons for the French Navy.


Serco Group

UK

Commercial services

and supplies

Serco Group has confirmed that the company produces weapons that can be characterized as

nuclear weapons. Through a joint venture with Atomic Weapons Establishment, the

company maintains the UK's nuclear weapons.





25

Textron

USA

Capital goods

Textron develops, produces and markets cluster munitions and components of cluster

munitions that are prohibited under the Convention on Cluster Munitions. The company

claims that altering the design of this type of weapon could be a possibility in order to

comply with the convention, but that the company is not "convinced that this would be the

best solution to eliminate the unacceptable risk for civilians."





26

Tobacco producers

Company Country Al Eqbal for Investment Jordan

Alliance One International USA

Altria Group USA

British American Tobacco UK

Ceylon tobacco Sri Lanka

Grupo Carso Mexico

Gudang Garam Indonesia

HM Sampoerna Indonesia

Huabao International Holdings Hong Kong

Imperial Tobacco UK

ITC India

Japan Tobacco Japan

KT&G Corp South Korea

Lorillard USA

Philip Morris USA

Reynolds American USA

Sabanci Holdings (Haci Omer) Turkey

Scandinavian Tobacco Group Denmark

Schweitzer-Mauduit USA

Shanghai Industrial Holdings Hong Kong

Souza Cruz Brazil

Swedish Match Sweden

Universal Corp USA

Vector Group USA




27

Coal companies

Company Country Industry Group Aboitiz Power Corp. Philippines Utilities

Adani Power Ltd. India Utilities

Adaro Energy Tbk Indonesia Coal and other fuels

AES Corp USA Utilities

AES Gener SA Chile Utilities

Albioma France Utilities

Allete Inc. USA Utilities

Alliant Energy USA Utilities

Ameren Corp. USA Utilities

American Electric Power Co., Inc. USA Utilities

Appalachian Power Co. USA Utilities

Arch Coal Canada Utilities

Banpu Public Comp. Ltd. Thailand Coal and other fuels

Capital Power Corp. Canada Utilities

CESC Ltd. India Utilities

CEZ AS Czech

Republic Utilities

China Coal Energy Comp., Ltd. China Coal and other fuels

China Power International Development China Utilities

China Resources Power Holdings Comp. Ltd. China Utilities

China Shenhua Energy Comp. China Coal and other fuels

Cleco Corporate Holdings LLC USA Utilities

CLP Holdings Ltd. Hong Kong Utilities

Coal India Ltd. India Coal and other fuels

CONSOL Energy, Inc. USA Coal and other fuels

Datang International Power Generation Comp., Ltd. China Utilities

DMCI Holdings, Inc. Philippines Capital goods




28

Drax Group PLC UK Utilities

DTE Energy Co. USA Utilities

Dynegy Inc. USA Utilities

E-CL SA Chile Utilities

Electric Power Development Japan Utilities

Electricity Generating PCL Thailand Utilities

Emera Inc., including bonds issued by Emera US Finance LP Canada Utilities

Empire District Electric Company USA Utilities

Eneva SA Brazil Utilities

Exxaro Resources Ltd. South Africa Coal and other fuels

FirstEnergy Corp. USA Utilities

Glow Energy Public Co. Thailand Independent power producers and energy

traders

Great Plains Energy Inc. USA Utilities

Great River Energy USA Utilities

Guangdong Electric Power Development Co. Ltd. China Utilities

Gujarat Mineral Development Corp. Ltd. India Coal and other fuels

HK Electric Investments Ltd. Hong Kong Utilities

Hokkaido Electric Power Co. Inc. Japan Utilities

Hokuriku Electric Power Comp. Japan Utilities

Huadian Energy Co Ltd China Utilities

Huadian Power International China Utilities

Huaneng Power International Inc. China Utilities

IDACORP Inc. USA Utilities

Indiana Michigan Power Co. USA Utilities

Indo Tambangraya Megah Tbk PT Indonesia Coal and other fuels

Inner Mongolia Yitai Coal Co., Ltd. China Coal and other fuels

Jastrzebska Spólka Weglowa SA Polen Steel

Korea Electric Power South Korea Utilities

Lubelski Wegiel Bogdanka SA Poland Coal and other fuels

Malakoff Corporation Bhd. Malaysia Utilities




29

MGE Energy Inc. USA Utilities

New Hope Corp. Ltd. Australia Coal and other fuels

Northern States Power Co. MN USA Utilities

NRG Energy, Inc. USA Independent power producers and energy

traders

NTPC Ltd. India Utilities

OGE Energy Corp. USA Utilities

Okinawa Electric Power Co. Inc./The Japan Utilities

Otter Tail Corporation USA Utilities

Peabody Energy Corp. USA Coal and other fuels

PGE Polska Grupa Energetyczna SA Poland Utilities

Pinnacle West Capital USA Utilities

PNM Resources Inc. USA Utilities

Public Power Corp. SA Greece Utilities

Public Service Co. of Colorado USA Utilities

Public Service Co. of New Mexico USA Utilities

Reliance Infrastructure India Utilities

Reliance Power Ltd. India Utilities

SDIC Power holdings Company Ltd. China Utilities

Shikoku Electric Power Japan Utilities

Shougang Fushan Resources Group Ltd. Hong Kong Steel production

Southwestern Public Service Co. USA Utilities

Tambang Batubara Bukit Asam Tbk PT Indonesia Coal and other fuels

Tata Power Co., Ltd. India Utilities

Teco Energy Inc., including bonds issued by Teco Finance USA Utillities

Tenaga Nasional Bhd. Malaysia Utilities

The Chugoku Electric Power Company Japan Utilities

The Southern Company USA Utilities

TransAlta Corp. Canada Utilities

Union Electric Co. (d/b/a/ Ameren Missouri) USA Utilities

WEC Energy Group USA Utilities




30

Westar Energy, Inc. USA Utilities

Whitehaven Coal Ltd. Australia Coal and other fuels

Wisconsin Electric Power Co. USA Utilities

Xcel Energy USA Utilities

Yanzhou Coal Mining Comp. Ltd. China Coal and other fuels


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