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Norges Bank Investment Management ESG Initiatives in 2020 & Priorities for 2021

Norges Bank Investment Management (NBIM) increased its focus on social topics in 2020 and sets its 2021 engagement priorities including climate change, human rights, and tax transparency.


  • Governance-related topics continued to be the most frequently raised issues by NBIM, representing almost half of the topics raised in meetings during 2020 whilst engagement on social topics increased.

  • NBIM held fewer ESG-related meetings compared to 2019 and continued to prioritise large cap companies.

  • Climate change, human rights and tax transparency among engagement priority topics for 2021.


<<In 2020, we focused on effective boards, executive remuneration, capital allocation, climate change and environment, human rights, anti-corruption and tax.>>

NBIM Responsible Investments 2020 report (page 40)


Leaders Arena is proud to present its fifth annual summary of the Environmental, Social and Governance (ESG) investment priorities for Norges Bank Investment Management’s (NBIM) from its 2020 Responsible Investment report. Given that NBIM is widely regarded as a trend setter for ESG priorities, we hope Investor Relations, Communication and Sustainability Officers will find these insights useful in order to help prioritise ESG communication & sustainability goals and to support internal presentations.

The Government Pension Fund’s equity returns slowed in 2020, returning 12.1 percent, down from 19.9 percent in 2019.[1] Its environmental-related equity mandates, however, outperformed the global benchmark in both 2020 and over the last 5 years with a significant return of 34.3% in 2020.[2]

Managing USD 949.5bn invested across over 9,100 companies globally, NBIM continues to be one of the largest and one of the most influential Responsible Investors (RI) on the market.

Don’t hesitate to get in touch with us if you want to know what these drivers mean specifically to your company or sector. We will also be more than happy to provide you with a PowerPoint summary too. Feel free to contact us at:

Engagement with companies:

  1. The number of ESG-related meetings in 2020 fell by 16% (2,877 vs 3,412 in 2019). Likewise, the number of companies met also fell to 1,209 in 2020 vs. 1,474 in 2019. Whilst the number of meetings has fallen across all sectors, the Financials sector still attracts the largest number of meetings with NBIM, followed by Industrials and Consumer Goods.

  2. NBIM continued to prioritise meetings with large caps. The 1,209 companies NBIM met with only account for 13.3% of the total companies in their portfolio; however, they represent 71.7% of NBIM’s equity portfolio value – up from 67.4% in 2019.

  3. The most commonly raised ESG topics by NBIM during company meetings were related to capital management (14.7%), climate change (14.4%) and board effectiveness (6.8%). Newly added topics in 2019, “ocean sustainability” and “deforestation”, saw increased interest in 2020 as they alongside the topic of “biodiversity” as they were discussed on 1.7% of topics raised during meetings in 2020. This area remains a growing focus for NBIM with reiterated commitments on sustainable land use and land degradation in its 2020 Responsible Investment report.

Active ownership & voting:

  1. Support for sustainability-related resolutions (against management) slightly declined in 2020 vs. 2019 (35% vs. 40%). NBIM considers three key criteria for assessing shareholder resolutions: financial materiality, achievability, and current company commitments and practices.

  2. NBIM maintains its strong viewpoint on board composition, stating that the roles of chairman and CEO should be separated, even in the US where the combination of roles is still common. This topic was the second most common reason NBIM voted against board members in 2020, as it was in 2019.

Reporting areas where companies can improve in 2020:

  1. Frameworks: NBIM calls for reporting requirements based on globally accepted, financially material and standardised sustainability metrics. The sovereign fund believes that SASB and the GRI should be viewed as starting points for sustainability reporting. NBIM expects that corporate reporting should go further than the recommendations in these frameworks, particularly in light of the EU sustainable finance strategy. The Task Force on Climate-related Financial Disclosure (TCFD) recommendations are used in climate change assessments by NBIM.

  2. Disclosure quality: NBIM has been assessing the quality of companies’ environmental and social disclosures since 2008. The weakest sustainability reporting areas as assessed by NBIM were: water management, human rights, and tax transparency, where most companies in NBIM’s research samples failed to meet its standards. These therefore will be areas where NBIM is likely to push companies to improve in 2021 and beyond.

ESG focal points for NBIM in the near-term include:

  • E (Environmental) – NBIM updated and clarified their stance on climate change, stating that companies should report on their long-term climate strategy and emissions reduction targets in line with the goals of the Paris Agreement. Likewise, the Fund has updated its expectations in the last year, to include more on sustainable land use and land degradation.

  • S (Social) – engagements on social topics saw the largest gain in 2020 as discussions increased to 23% of topics discussed, up from 18% in 2019. NBIM engaged on topics such as human rights, tax, transparency & corruption, and human capital managements. In its 2021 expectations, NBIM expects more detailed description of how some business model features carry inherent human rights risks.

  • G (Governance) – during 2020, governance risks such as the efficacy and reporting of tax-transparency and anti-corruption programs were scrutinised by NBIM, which found that in follow-up engagements, companies generally failed to provide the additional information it requested on these topics.


<<Our expectations are primarily directed at company boards. The board should take overall responsibility for company strategy and address challenges presented by environmental and social issues. The board should also integrate material risks in these areas into strategy, risk management and reporting.>>

NBIM Responsible Investments 2020 report (page 24)


Recommendations for companies:

Integrate: Investor Relations, Corporate Communication and Sustainability Officers can use these insights to prioritise ESG investor communication and reporting in 2020

Engage: Proactively engage with key ESG Investors such as Norges Bank Investment Management to tell your company story.

Lead: 1. Own your story, don’t let 3rd party ESG data providers be the only source of sustainability information on your company. 2. Reap the rewards from this dialogue with ESG investors by bringing their perspective into internal company discussions on strategy.

Leaders Arena’s unique ESG market intel helps companies to better integrate, engage and lead their dialogue with Responsible Investors.


[1] NBIM Annual Report 2020

[2] NBIM Responsible Investment Report 2020


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