Our exclusion criteria
We do not invest in industries which operate at the expense of future generations. The following criteria are strictly exclusionary. We will not invest a single cent in companies and industries which violate these criteria.
Ensuring basic needs
We exclude all business areas which massively compromise our health and lives. This includes the production, trade and use of biocides, pesticides, asbestos and fungicides which are especially harmful according to the WHO.
In addition, we exclude the trade and use of human embryonic cells and embryos from our investments.
Intensive livestock farming as well as the processing of meat from very restrictive farming methods (such as battery cages for hens or crates for pigs or calves) are an absolute no go. The same applies to fishing which does not meet the criteria of the Marine Stewardship Council.
In addition, food speculation as well as the use of mineral fertilizer violate our criteria.
Empowerment
We do not tolerate any violation of the core working standards of the International Labour Organization. The elimination of child and forced labor us just as important to us as the elimination of any form of discrimination (for example based on age, gender, origin, political views, or sexual orientation).
Another violation of our criteria is the systematic evasion of minimum safety and health standards.
Climate protection
The promotion of fossil energy and nuclear energy is an absolute no go. This includes companies extracting, trading or producing energy from gas, coal, oil, and uranium in any possible form. The exclusion applies to all companies in the value chain as well. This includes the production of core components for fossil and nuclear power stations as well as the operation of these facilities, as well as the construction of oil- and gas-pipelines.
In addition, we exclude companies which generate more than 15% of their current revenues from supplying the fossil fuel industry.
We refuse any investment in (big) projects with a negative impact on the ecosystem (such as pipelines, water projects, embankment dams, and biogas plants). We follow the Equator Principles and consider further guidelines from for example the Roundtable on Sustainable Biomaterials and the World Commission on Dams. We hold project developers and investors just as much accountable as suppliers and operators.
We consider any fossil-fueled automobile, shipping or aviation company to be part of yesterday’s industries. Therefore, we exclude these as well as their main suppliers.
Companies emitting CO₂ or other pollutants (such as ammoniac, sulfur, and particulate matter) are not eligible for funding unless they have a suitable emission reduction strategy in place.
The exclusion as well applies to the production and trade of organochlorine mass products, fluorocarbon (PFCs) and persistent organic pollutants (POPs). We strongly refer to the regulations of the Stockholm Convention. The exclusion extends to other ozone-depleting and internationally restricted chemicals.
Nature
We do not tolerate any violation of the 5 Freedoms of Animals in the production or any sales of products which are suspected of violating said guidelines. This includes, in our view, among others animal transports longer than 8 hours as well as the exploitation for entertainment purposes.
Furthermore, we exclude companies which carry out or commision non-statutory tests with negative consequences for living animals. The same applies to companies whose production, site development and research negatively impact whales and other marine mammals.
In line with the EU Conflict Minerals Regulation any mining and trade of conflict minerals violates our criteria.
In addition, the illegal sourcing of raw materials (such as wood) is inacceptable. So is the use of illegally sourced materials. The exclusion further applies to (forest) areas which are exploited without regard for the rights of the local indigenous population.
We also exclude projects with the aim to convert High Conservation Value Areas (HCVA), High Carbon Stock (HCS) areas and other protected areas (for example through the Ramsar Convention) into land for agriculture, housing, etc. This includes among others moors and forests.
Our policy excludes companies which convert HCS areas in general.
We exclude any companies which release harmful waste in rivers or oceans or whose products contribute substantially to the pollution of waters.
We do not tolerate the purchase of water rights in areas with water scarcity if this worsens the situation. Therefore, we expect companies to analyze the impact on the local water supply extensively before the purchase.
We do not invest in companies which are responsible for deforestation and degradation of natural areas and thus for permanent damage to water and material cycles, soil fertility, and biodiversity. The same applies to practices harming areas protected by the IUCN or other internationally accepted conventions (such as UNESCO World Heritage). Equally inacceptable is the trade and endangerment of animals and plants at the risk of extinction (as per the IUCN Red List and CITIES).
In addition, we exclude production, research and trade of genetically modified organisms, especially genetic material and seeds of animals and plants for agricultural purposes.
Fairness
In our view, businesses bear a special responsibility towards society. Therefore, we consider any support of anticonstitutional organizations and anti-climate lobbying a violation of our criteria.
The same applies to doing business at risky locations. We define locations as risky if they are occupied according to international humanitarian law or if daily operations or accidents could lead to uncontrollable consequences for the environment and for society.
In addition, we exclude the production and promotion of addictive substances or behavior (such as tobacco, alcohol, and gambling) as well as controversial industries such as pornography.
We also exclude activities that do not comply with the FPIC (Free Prior and Informed Consent) principle from the United Nations Human Rights. Consultation and participation are essential components particularly when it comes to legislation, projects or policies that affect indigenous peoples and their rights.
We exclude any company without transparent reporting in regards of the following financial and nonfinancial aspects. Reporting should be in line with GRI principles and must contain:
direct and indirect emission of greenhouse gases
financial owner of the company, employed full-time representatives, and complete business structure (including joint ventures and indirect investments)
political activities (lobbying and involvement in political decision making)
revenues and profits
tax payments, per country and including company-specific tax rates and subsidies
outcome of existing court cases
We require companies to comply with gender, women and labor rights as well as with environmental regulations, data protection regulations, and relevant international conventions, such as the United Nations’ Convention on Biological Diversity. We do not tolerate violations of the UN Guiding Principles on Business and Human Rights or the International humanitarian law.
Equally unacceptable is the illegal acquisition of land and natural resources, meaning without the informed and voluntary consent of the affected population.
We condemn any form of corruption and the use of improper benefits. This includes offering, promising and receiving bribes.
The same applies to illegal business practices such as accounting fraud, price fixing, tax fraud, and especially tax evasion. We demand companies, holdings and subsidiaries based in tax havens to justify this choice in their reporting. This means that we expect companies to make all business activities, owners as well as the specific reasons for choosing this location transparent in their reporting.
In short, any violation of legal obligations and universally accepted standards of fair conduct is intolerable. In this case, companies will not be eligible for funding.
We strictly exclude any investments in arms and military goods which could harm humans. This includes firearms, cluster munition and lethal autonomous weapons (LAWs) as well as overall weapons and radar systems, autonomous or artificially intelligent robots and other additional technical services, materials or substances which is capable of producing great bodily harm or death from the manner it is used or intended to be used.
Production, trade and use of armaments and weapons is intolerable. The same applies to pre-production and services specifically for the arms industry. This criterion applies explicitly to products or services essential for military purposes even in the case of companies that produce dual-use goods as listed on the EU’s common military list and also sell to non-civilian end users.