Worldwide investments in CLUSTER MUNITIONS

How to gain a place in the Hall of Fame?
To gain a place in the Hall of Fame, UBS should extend its policy to all actively managed funds and
third-party investments, as well as its passively managed funds.
2.2.44 UniCredit Group (Italy)
UniCredit Group is a large Italian banking group that provides corporate, investment and private banking
services. 612 It operates in seventeen European countries. 613
UniCredit’s position statement on the defense/weapons industry states that UniCredit abstains from
financing transactions involving the development, manufacture, maintenance or trade in controversial/
unconventional products such as cluster bombs. 614 UniCredit’s 2007 sustainability report shows that
companies involved in these activities are excluded. 615 The policy applies to UniCredit’s commercial banking
and investment banking activities. 616
In 2011, Pioneer Investments, UniCredit’s’ asset management arm, decided to exclude investments in
companies involved in the production of cluster munitions. This policy applies to Pioneer Investments’
actively managed funds. It makes an exception for quant funds and funds following an index. In addition,
it does not apply to US-domiciled funds or to all Pioneer portfolios’ third-party funds. 617
UniCredit makes use of an exclusion list, but the list is not publicly available. The list is based on
information from external sources such as Oekom Research, MSCI ESG Research and EC Capital. 618
How to gain a place in the Hall of Fame?
To be listed in the Hall of Fame, UniCredit should apply its policy to all products it offers, including quant
funds, funds following an index, US-domiciled funds and all third-party funds.
2.2.45 Van Lanschot (the Netherlands)
Van Lanschot Bankiers offers private banking to wealthy private customers, entrepreneurs and family
companies, and merchant banking to business professionals and executives, healthcare professionals,
associations and foundations. Van Lanschot holds offices in the Netherlands, Belgium and Switzerland. 619
Van Lanschot does not finance or invest in companies involved in the development, production, testing,
storing, maintenance and selling of controversial weapons, including cluster munitions, or essential
elements thereof. 620
Van Lanschot’s exclusion policy applies to its commercial banking, investment banking and its own asset
management activities. 621 Van Lanschot instructs its external asset managers to comply with the responsible
investment policy. However, investments in external passively managed funds, including funds that follow
an index, containing less than 5% of cluster munitions companies are not covered. XXXIX 622 This means that
such funds may still contain the specified percentage of cluster munitions producing companies.
XXXIX This is in line with the Dutch prohibition on direct and demonstrable investments. The prohibition contains several
exceptions, such as for transactions following an index, when individual companies that produce, sell, or distribute cluster munitions
account for less than five per cent of the index. The ban contains a similar exception for transactions in investment funds managed
by third parties. This means that funds following an index and investment funds may still contain the specified percentage of cluster
munitions producing companies. This exception weakens the prohibition, especially since companies involved in the production of
cluster munitions usually do not represent more than 5% in funds that follow an index or investment funds.
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