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Thematic dialogues on social and environmental topics

Dialogue Themes Number of

companies Started Status

Tax policies Anti-corruption and tax 15 2019 Ongoing

Corruption risk in the industrials sector Anti-corruption and tax 8 2020 Ongoing

Low tax jurisdictions Anti-corruption and tax 32 2020 Ongoing

Environmental impact of cement and concrete Climate and environment 12 2019 Completed

Environmental impact of fashion industry Climate and environment 12 2019 Completed

Climate transition and responsible ship recycling Climate and environment 10 2019 Completed

Bank financing of high emitters Climate and environment 17 2020 Completed

Low carbon transition in the steel industry Climate and environment 14 2020 Ongoing

Climate lobbying in EU heavy industries Climate and environment 9 2020 Ongoing

Forest risk commodities in consumer goods Climate and environment 12 2020 Ongoing

Net zero targets for high emitters Climate and environment 11 2021 Ongoing

Sustainable fisheries Climate and environment 10 2020 Ongoing

Water metrics and targets Climate and environment 13 2020 Ongoing

Environmental risks and opportunities in global food

systems Climate and environment 13 2021 Ongoing

Integrated oil and gas climate engagement Climate and environment 7 2021 Ongoing

Working arrangements in food delivery and transport

companies Human rights 6 2020 Ongoing

Enhanced due diligence in conflict areas Human rights 21 2020 Ongoing

Child safety online Human rights 11 2021 Ongoing

Forced labour risks in electronics and consumer

supply chains Human rights 40 2019 Ongoing

Responsible marketing of infant formula Human rights 13 2018 Ongoing

Infineon Technologies AG. We also wrote to the boards of a number of companies. We have noticed in this dialogue that some companies have chosen to transfer activities from countries with no income taxes to countries which have higher tax rates but still offer incentives that affect how much tax companies pay.

Incident-based dialogue

We also follow up unwanted incidents that could indicate weak corporate governance or management of

environmental and social risks. Examples of this work in 2021 include Adani Ports & Special Economic Zone Ltd’s operations in Myanmar, TotalEnergies SE’s approach to the development of the East African Crude Oil Pipeline, The Bank of New York Mellon Corp’s potential financing of the Carmichael mine in Australia, and emissions of the

greenhouse gas fluoroform by The Chemours Company. We followed up McDonald’s Corp’s efforts to prevent gender-based violence and sexual harassment in its operations and at franchisees, which is also the subject of an ongoing case being considered by Norway’s National Contact Point for responsible business conduct.

Dialogue on ethical criteria

The ethical guidelines issued by the Norwegian Ministry of Finance state that, before making a decision on observation or exclusion, Norges Bank should consider whether other measures, including the exercise of ownership rights, may be more suited to reduce the risk of continued norm violations, or whether such alternative measures may be more appropriate for other reasons.

Serious violations of human rights

In April 2018, Norges Bank’s Executive Board decided to ask Norges Bank Investment Management to raise the risk of child labour with UPL Ltd as part of our active ownership work. The aim of our dialogue with UPL is to reduce the use of child labour at its subsidiary Advanta Seeds Pty Ltd, which produces various types of seed in India. We had regular contact in 2021, including two meetings with representatives from both UPL and Advanta.

The companies continued to develop and improve their information campaigns during the year, and updated their policies and contracts with farmers. They prioritised improvements to supply chain monitoring, including new tools and staff training. The companies continued to participate in the industry initiative ECHO Forum, and commissioned an external evaluation with field surveys of child labour in seed production which had promising results.

Thematic dialogues on social and environmental topics

Dialogue Themes Number of

companies Started Status

Tax policies Anti-corruption and tax 15 2019 Ongoing

Corruption risk in the industrials sector Anti-corruption and tax 8 2020 Ongoing

Low tax jurisdictions Anti-corruption and tax 32 2020 Ongoing

Environmental impact of cement and concrete Climate and environment 12 2019 Completed

Environmental impact of fashion industry Climate and environment 12 2019 Completed

Climate transition and responsible ship recycling Climate and environment 10 2019 Completed

Bank financing of high emitters Climate and environment 17 2020 Completed

Low carbon transition in the steel industry Climate and environment 14 2020 Ongoing

Climate lobbying in EU heavy industries Climate and environment 9 2020 Ongoing

Forest risk commodities in consumer goods Climate and environment 12 2020 Ongoing

Net zero targets for high emitters Climate and environment 11 2021 Ongoing

Sustainable fisheries Climate and environment 10 2020 Ongoing

Water metrics and targets Climate and environment 13 2020 Ongoing

Environmental risks and opportunities in global food

systems Climate and environment 13 2021 Ongoing

Integrated oil and gas climate engagement Climate and environment 7 2021 Ongoing

Working arrangements in food delivery and transport

companies Human rights 6 2020 Ongoing

Enhanced due diligence in conflict areas Human rights 21 2020 Ongoing

Child safety online Human rights 11 2021 Ongoing

Forced labour risks in electronics and consumer

supply chains Human rights 40 2019 Ongoing

Responsible marketing of infant formula Human rights 13 2018 Ongoing

Severe environmental damage

In October 2013, the Ministry of Finance asked Norges Bank to include oil spills and environmental conditions in the Niger Delta in our ownership work with the oil and gas companies Eni SpA and Royal Dutch Shell PLC for a period of five to ten years. In 2018, Norges Bank decided to continue to engage with mining company AngloGold Ashanti Ltd for a further three years.

The aim of our dialogue with Eni SpA and Royal Dutch Shell PLC is to contribute to a reduction in the number and volume of oil spills and ensure immediate and effective remediation of spills. We followed this up at three meetings with the companies in 2021.

The number of spills from pipelines operated by Eni SpA was stable during the year, while the volume of spills decreased slightly. The company reported that the security situation had deteriorated, due partly to high oil prices, making it harder both to produce oil and to prevent spills. Eni has worked on strengthening its dialogue with the local community and the various security forces in recent years, and improved its monitoring and response times for spills.

The year saw fewer spills due to operating errors.

Spills from pipelines operated by Royal Dutch Shell PLC decreased in 2021 but were still high. Royal Dutch Shell PLC and its partners in Nigeria have implemented various measures, including maintenance, better protection of wellheads and closer collaboration with local communities.

The clean-up of affected areas was hampered by the pandemic, and the backlog has increased considerably. The company is working with the Nigerian authorities to clean up legacy pollution in Ogoniland and is continuing to pay its share of the clean-up costs.

Royal Dutch Shell PLC announced early in 2021 that it was considering selling its onshore business in Nigeria. We stressed the importance of a buyer continuing to operate responsibly.

We continued our dialogue with AngloGold Ashanti in 2021.

The aim of the dialogue is to encourage the company to clean up previous pollution and operate the Obuasi mine in Ghana in accordance with internationally recognised standards. We held two meetings with the company during the year in addition to ongoing correspondence. The company reported good progress in both its modernisation programme and the restoration of polluted areas, although the pandemic continued to cause delays.

Gross corruption

In March 2021, the Executive Board decided to ask Norges Bank Investment Management to include anti-corruption in its ownership work with ThyssenKrupp AG over a period of four years. The aim of this dialogue is to ascertain that the company’s board and management have taken effective action to prevent corruption. There is a particular focus on risk assessments and actions relating to third-party relationships. We also want to understand how the company’s governance structure affects its anti-corruption work, as allegations of corruption may be a sign of

underlying legal, operational or governance risks and high risk tolerance.

We had two meetings in 2021 with the company’s chairman and representatives of the department responsible for anti-corruption. We also had a dialogue with one of the company’s largest shareholders. We have the impression that the company is working actively on reducing the risks associated with third parties, especially sales agents and consultants offering services related to offset agreements.

In August 2020, the Executive Board decided to ask Norges Bank Investment Management to follow up anti-corruption work at PetroChina Co Ltd as part of our active ownership efforts. The aim of the dialogue is to explore how the company’s board and management prevent corruption with effective systems and measures. We have had two meetings with the company since the Executive Board’s decision. Due to the pandemic, it has not been possible to take up PetroChina’s invitation to visit the company in China to continue this dialogue.

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