Group Guidelines for Ethical investment guidelines for DNB

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The guidelines are based on the group policy for corporate social responsibility. Purpose. The guidelines shall ensure t
Group Guidelines for Ethical investment guidelines for DNB The guidelines apply to DnB NOR's financial investments through Vital Forsikring ASA, DnB NOR Asset Management and Group Investments. The guidelines are based on the group policy for corporate social responsibility.

Purpose The guidelines shall ensure that DnB NOR does not contribute to human or labour rights violations, corruption, serious environmental harm or other actions which may be perceived to be unethical.

Ethical management principles Ethical principles for investment management should be promoted based on the following three measures: Exercise of ownership rights to promote long-term financial returns based on the UN Global Compact and the OECD's guidelines for multinational companies.  Negative screening from the investment universe of companies which either themselves or through the companies they control:  produce weapons 1 which through normal use violate basic humanitarian principles,  produce tobacco, or  produce pornography  Exclusion of companies from the investment universe when there is considered to be an unacceptable risk of involvement in:  serious or systematic violations of human rights, such as murder, torture, deprivation of liberty, forced labour, the worst types of child labour and other exploitation of children  grave violations of individual rights in wars or conflict situations  serious violations of basic labour rights  grave harm to the environment  serious corruption  other particularly critical violations of basic ethical norms 

External suppliers DnB NOR's investment guidelines also apply to suppliers of mutual funds in which the Group invests or which are offered to the Group's customers.

Ethical Investment Committee A special committee has been established in DnB NOR to administer and follow up approved ethical investment guidelines throughout the DnB NOR Group. The head of External Relations chairs the committee, which has group-wide responsibility for coordinating ethical aspects of the Group's investment activities. The committee collects information about companies and makes sure that matters are as well elucidated as possible before issuing a recommendation regarding a possible exclusion of companies from the investment portfolio. The committee issues such recommendations to the heads of Asset Management, Group Investments and Vital Forsikring ASA, who serve as decision-makers for their respective units. The committee will regularly consider whether the grounds for excluding a company still exist. Based on new information, the committee may recommend that the decision to exclude a company be revoked. The committee is regularly updated on DnB NOR's exercise of ownership rights. In cases where these efforts are unsuccessful, the committee will recommend the exclusion of the relevant company.

Exercise of ownership rights DnB NOR Asset Management is responsible for exercising ownership rights. Through dialogue, meetings, the exercise of voting rights and other measures, DnB NOR Asset Management seeks to influence companies suspected of acting contrary to the principles in the UN Global Compact and the OECD's guidelines for multinational companies to make them correct their actions. If these efforts are unsuccessful, the matter will be presented to the Ethical Investment Committee.

Publication Decisions on new exclusions will be made known through regular updates of a publicly available list of the number of companies excluded from the investment portfolio. DnB NOR will be open about the subjects the Group focuses on in its exercise of ownership rights. DnB NOR will also make available information on how DnB NOR Asset Management and Vital have voted at general meetings in controversial matters and matters relating to corporate social responsibility practices.

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DnB NOR will not finance or invest in companies which are involved in the production of anti-personnel mines and cluster weapons, or in companies which develop and produce central components for use in weapons of mass destruction as a key part of their operations. Weapons of mass destruction are defined as ABC weapons (atomic, biological and chemical). _________________________________ Version: Approved by: Effective as of:

1.0 Group chief executive 19 05 2010