Worldwide investments in CLUSTER MUNITIONS

The exclusion policy applies to all commercial banking, investment banking and asset management
activities, except for passively managed funds such as funds that follow an index. Furthermore, clients can
request to invest in cluster munitions companies via execution only services. 428 The policy does not apply
to Credit Suisse’s external asset managers. 429
Credit Suisse’s uses an exclusion list to implement its policy, which is based on information provided by
external research provider Sustainalytics. The bank does not make this list public. 430
How to gain a place in the Hall of Fame?
To be listed in the Hall of Fame, the policy should apply to funds following an index. Credit Suisse should
also eliminate the exception for individual clients that explicitly ask to invest in a company known to be
a cluster munitions producer. Such requests should be refused. Furthermore, the policy should apply to
external asset managers as well.
2.2.15 Danske Bank (Denmark)
Danske Bank Group is a large Danish financial enterprise, operating in fifteen countries. The group offers
banking, insurance, mortgage finance and asset management services to Danish and international
customers. 431
Initially, Danske Bank adopted a SRI (socially responsible investment) policy for investing customer funds
and the group’s own strategic portfolio. This policy was based on several internationally recognised norms,
one of them being the Convention on Cluster Munitions. 432 This resulted in the exclusion of companies
involved in the production and development of cluster munitions. 433 In 2011, Danske Bank decided that
companies excluded from its investment universe would also be excluded from its other banking
activities. 434 As such, the policy applies to all commercial banking and investment banking activities of
Danske Bank. 435
With regard to asset management, the policy applies to investments for own account and funds where
Danske Bank manages the investment of customer funds. However, the policy is not applied to “funds-offunds,
structured products, individual securities or derivatives, institutional mandates, institutional funds
or managed accounts.” 436 For externally managed funds, Danske Bank strives to select funds that are based
on internationally recognised principles for responsible investing. It enters into dialogue with portfolio
companies to enforce the policy. 437
Danske Bank maintains an exclusion list to implement its policy. The list currently contains the following
companies for involvement in cluster munitions: Aeroteh, Aryt Industries, Hanwha Corporation, L-3
Communications Holdings, Lockheed Martin, Motovilikha Plants, Orbital ATK, Poongsan Corporation and
Textron. The list is based on the advice of Ethix SRI Advisors. 438
How to gain a place in the Hall of Fame?
To be listed in the Hall of Fame, Danske Bank should extend its policy to all its asset management activities.
The policy does not cover funds-of-funds, structured products, individual securities or derivatives,
institutional mandates, institutional funds and managed accounts.
2.2.16 Deutsche Bank (Germany)
Deutsche Bank is a large global bank from Germany. It offers a diverse range of products and services in
investment banking, private and commercial banking, transaction banking, and asset and wealth
management. Deutsche Bank enjoys a leading position in its home market, other parts of Europe, North
America and key emerging markets. 439
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