Worldwide investments in CLUSTER MUNITIONS

2.2.22 Intesa Sanpaolo (Italy)
Intesa Sanpaolo is the banking group that resulted from the merger of two Italian banks, Banca Intesa and
Sanpaolo IMI. The Italian company has a strong presence in Central-Eastern Europe and on the Mediterranean
market. The group offers its services to about 11.1 million customers. 481
Intesa Sanpaolo’s 2015 policy states that it bans all banking activity linked to production of or trade in
controversial weapons or weapons banned by international treaties, like cluster bombs. 482 The policy covers
credits and investment banking. 483 Intesa Sanpaolo excludes cluster munitions producers from the active
funds that it manages: Eurizon Ethical International Equity, Eurizon Ethical Diversified and Eurizon Ethical
Bonds. 484 Intesa Sanpaolo has stated it is preparing a more detailed cluster munitions policy for internal
asset management activities and that “the policy will include some restraints for own funds following
an index.” 485 However, to this day, Intesa Sanpaolo has not published such a renewed policy.
To implement its policy, Intesa Sanpaolo uses a non-public exclusion list, adopted by analyzing several
international reports. 486
How to gain a place in the Hall of Fame?
To be listed in the Hall of Fame, Intesa Sanpaolo should exclude cluster munitions producers from all its
asset management activities, including passively managed funds. Moreover, the policy does not explicitly
forbid financing a holding company’s civilian operations even when one of its subsidiaries is involved in
producing cluster munitions. Intesa Sanpaolo has said that it keeps careful watch to avoid indirectly
financing such subsidiaries through the parent company. However, this is insufficient since a company can
easily reallocate money within the group. Intesa Sanpaolo should therefore exclude holding companies
when one of its subsidiaries is involved in the production of cluster munitions.
2.2.23 Ireland Strategic Investment Fund (Ireland)
The Ireland Strategic Investment Fund (ISIF) succeeded the Irish National Pensions Reserve Fund (NPRF) in
December 2014. This resulted from a decision by the Irish government to reorient NPRF from a long-term
pension fund to an investment fund that will support economic activity and employment. 487 All assets of
NPRF were transferred to ISIF.
ISIF operates the same responsible investment policy as NPRF. 488 On 2 December 2008, Ireland passed the
2008 Cluster Munitions and Anti-Personnel Mines Act. Consequently, ISIF avoids investments in companies
that develop or produce cluster munitions or anti-personnel mines. 489 The exclusion policy applies to all of
ISIF’s asset management activities, whether managed by internal or by external asset managers. The policy
does not cover investment in exchange-traded funds (ETFs) and other derivatives products. ISIF claims that
where possible it avoids the use of such financial products that may expose it to cluster munitions
companies. 490
ISIF’s exclusion list currently contains the following companies for involvement in cluster munitions or
anti-personnel mines: Aerostar, Aryt Industries, Doosan Corporation, General Dynamics, Hanwha
Corporation, L-3 Communications, Lockheed Martin, Northrop Grumman, Orbital ATK, Poongsan
Corporation, Poongsan Holdings Corporation, Raytheon, Samsung Techwin, Singapore Technologies
Engineering and Textron. 491
How to gain a place in the Hall of Fame?
To be listed in the Hall of Fame, NRPF should extend its exclusion policy to all ETFs and other derivatives
products.
174