Sustainability policy and strategy
Eksfin shall work responsibly and according to high ethical standards.
1. Purpose and application
This policy addresses Eksportfinansiering Norge’s (Eksfin’s) risk exposure based on its financial products and portfolio. The purpose of this sustainability policy is to describe the overall framework for promoting sustainable practices, as well as Eksfin’s overall due diligence requirements for environmental and social due diligence. Furthermore, the policy describes Eksfin’s expectations of customers’ and partners’ approach to responsible business conduct.
Efforts to combat corruption, money laundering, and the financing of terrorism and to uphold international sanctions are also important aspects of sustainability. This is covered in a separate policy (Policy for working to prevent money laundering and the financing of terrorism, anti-corruption, and sanctions).
In addition to managing Eksfin’s risks in its transaction portfolio, Eksfin shall responsibly manage its own actions. This is rooted in Eksfin’s Ethical Principles, and incorporated in various policies and guidelines. Eksfin will be a responsible employer, and strive to reduce its own environmental footprint. Management of environmental and social aspects for Eksfin’s day-to-day activities is described in Eksfin’s HR policy and policy for risk management and internal management controls.
Due diligence is a process that involves mapping potential risks and preventing and reducing potential negative impacts related to business activities. For Eksfin, this means assessing the risks and impacts associated with offers of loans and guarantees.
Responsible business conduct
Responsible business conduct is to ensure compliance with international standards and laws including environmental protection, human rights, labour relations and financial accountability, as part of the company’s own business conduct, as well as throughout their value chain.
A sustainable company balances economic gain with managing its social and environmental footprint in order to ensure long-term value creation. The aim is to meet the needs of the present without compromising the ability of future generations to meet their needs.
“Do no harm” principle
”Do no harm” means that environmental and social risks and impacts are identified, assessed and reduced in a systematic manner in order to meet with international recognised standards and practices, as well as in compliance with local regulation.
ESG stands for “Environmental, Social and Governance”. Due diligence of a transaction is often referred to as an ESG assessment or analysis. Governance refers to assessments of anti-corruption, risk of sanctions and money-laundering. The “G” of ESG is covered by other policies and guidelines in Eksfin.
This term refers to the financing of business activities that is good for the climate and/or other environmental aspects.
“No net loss” principle
No net loss is defined as the point at which project-related biodiversity impacts are mitigated to have an overall zero net loss of biodiversity over the life-time of the project. This can be through various mitigation measures at an appropriate geographic scale (e.g., local, landscape-level, national, regional) such as avoiding sensitive areas, avoiding fragmentation of habitats and creating corridors, as well as on-site restoration and offsets.
“Net positive impact” principle
Net Positive Impact (NPI) on biodiversity is a target for a project outcome in which the impacts on biodiversity caused by the project are outweighed by the actions taken to avoid and reduce such impacts, rehabilitate affected species/landscapes and offset any residual impacts.
SDG – Sustainable Development Goals
This term refers to the UN’s global Sustainable Development Goals, or SDGs. There are 17 objectives that cover environmental, social, and societal aspects to achieve a better and more sustainable future for all.
3. Main principles
Eksfin seeks to promote Norwegian export in a responsible and sustainable manner. This is illustrated in the figure below.
3.1 Risk approach and material issues
Eksfin will apply a proactive attitude to environmental and social risk management in its daily business, including new transactions and its portfolio. The approach to environmental and social due diligence is risk based and built on the “do no harm” principle. The purpose of due diligence is to identify and assess risks, and develop mitigation measures such as to avoid, reduce, restore or compensate for potential negative impacts associated with the transactions where applicable.
Eksfin’s environmental and social risk exposure follows from the portfolio composition, which in turn depends on the type of applications that are received and approved. Eksfin identifies and reviews its material issues based on the portfolio composition, developments within sustainability norms and expectations, and with input from key stakeholders. Eksfin’s material issues, risks, and impacts are regularly assessed. The results are integrated into Eksfin’s strategy and framework. The most important material issues, and the management of these, are described below.
Labour and Human rights
Eksfin expects companies to support and align with internationally recognised human rights as outlined in the UN Guiding Principles on Business and Human Rights (UNGP), both in their own operations and through the supply chain.
Eksfin will not offer guarantees or loans where a project has serious and/or systematic breaches of internationally recognised human rights, and where there is no agreement on a corrective action plan to implement necessary changes to improve the situation(s).
Eksfin encourages companies to identify and assess possible risks and develop mitigation measures to reduce greenhouse gas emissions, as well as developing adaptation measures (where relevant) for their own operations and where relevant in their supply chain. Furthermore, Eksfin encourages companies in carbon-intensive sectors to publicly report on climate-related information.
Projects that are expected to to have considerable greenhouse gas emissions will be subject to added due diligence, and will be subject to additional requirements and follow-up prior to a final offer of financing.
Eksfin will not support projects related to the establishment of new coal-fired power plants or that relate to the expansion or life extension of existing coal-fired power plants, nor thermal coal extraction.
Eksfin expects companies to assess their impact on the ocean from their own operations, as well as the associated supply chain. Companies engaged in fisheries are expected to monitor and have traceability systems of the catches to minimise the risk of overfishing as well as possible illegal or unregulated fishing in their value chains.
Eksfin will seek to support projects that promote or contribute to healthy oceans, as well as people and societies that live off the ocean or by the coast. Eksfin evaluates potential ocean related impacts (where relevant) and seeks to ensure that customers develop relevant mitigation measures to reduce potential negative impact.
Eksfin will actively participate in (inter)national initiatives related to the sustainable use of ocean resources and sustainable oceans.
Eksfin expects companies to assess potential negative impact on biodiversity, from their own operations and due to activities in their supply chain. In cases where there is a significant risk or impact to biodiversity, Eksfin aims to align with the principle “No Net Loss”. For critical biodiversity areas, Eksfin aims to align with the principle “Net Positive Impact” (cf. IFC Performance Standard 6).
Eksfin encourages companies with a significant impact to biodiversity to publicly report on impacts and mitigation measures.
In order to facilitate exports with long-term value creation, Eksfin emphasises the principles of sustainability and a green transition. Eksfin will conduct robust due diligence and develop adhering action plans (where relevant) that the customer is accountable for implementing. Financing from Eksfin aims to support sustainable and responsible business practices that go beyond the OECD Common Approaches. Eksfin adheres to international initiatives that promote sustainability in the areas that are important for Norwegian exporters and seeks to contribute to positive developments through participation in the selected arenas. Through Eksfins’ advisory capacity, and in co-operation with Norwegian exporters, Eksfin will seek to contribute to responsible business conduct and to sustainable development.
Eksfin cooperates with other financial institutions on specific projects and transactions. Eksfin actively participates in several international forums, including the OECD and UN Global Compact, to create and promote a level playing field across national borders and in different regulatory environments.
Eksfin’s risk approach with regard to sustainability is reflected in the environmental and social frameworks that the agency has committed itself to, and as outlined below.
Applicable frameworks and guidelines
- International conventions and local laws and regulations
- Letter of allocation from the Norwegian Ministry of Trade, Industry and Fisheries
- UN Guiding Principles on Business and Human Rights (UNGP)
- OECD Guidelines for Multinational Enterprises (OECD MNE)
- OECD Common Approaches
- Equator Principles
- Norway’s other international obligations, including responsible financing principles
Additional obligations that Eksfin has committed itself to
3.3 Process description
Environmental and social due diligence
Exporters and customers have an independent responsibility to carry out satisfactory due diligence of their business operations, their project developments and relevant parties in their value chain. The assessments are expected to be in line with current laws, the OECD Guidelines for Multinational Enterprises (OECD MNE), and the UN Guiding Principles on Business and Human Rights (UNGP).
In addition, Eksfin assesses the environmental and social risks of new projects and transactions based on information received from potential customers and relevant parties. This due diligence is risk based. Eksfin will rely on other Norwegian government agencies for mitigating environmental and social risks and impacts of activities in Norway, and avoid any overlap with their responsibilities.
Eksfin offers support and advice to customers, exporters, and project developers as part of evaluating the transaction and, together with relevant parties, plays an active role in identifying measures to avoid or reduce the negative impacts associated with a particular transaction.
Eksfin has a clear requirement for compliance with applicable laws and regulations. Eksfin will not offer guarantees or loans where relevant parties in the transaction have serious and/or systematic breaches of applicable laws and regulations, and where there is no agreement on a corrective action plan to implement necessary changes within a reasonable time frame.
For a more detailed description of Eksfin’s approach to environmental and social due diligence, please see environmental and social due diligence.
Credit risk, loss provisions, and ownership interests
Eksfin will evaluate how the consequences of sustainability risks associated with a transaction could affect the credit risk. Sustainability risks must also be assessed in relation to loss provisions and asset depreciations (both overall premises and individual company evaluations), as well as in the annual review of commitments. For ownership interests as a result of breaches and recovery cases, sustainability must be safeguarded (cf. the report to the government on the state’s direct ownership of companies – sustainable value creation (2019-2020)).
Transactions involving ships and other mobile units will be evaluated for environmental and social risks and impacts. The assessment will include labour and human rights during construction, operation, and disposal of the unit.
Mobile units that are going to a specific location, or where its use is associated with specific risks, will be assessed in line with Eksfin’s guidelines for environmental and social due diligence.
4. Compliance and reporting
The sustainability policy shall be reviewed at least once a year. Any updates must be approved by the board.
Eksfin wants to be transparent about its transactions and their associated environmental and social risks and impacts.
The Eksfin website provides information on transactions that fall within OECD Common Approaches and that are risk categorised as A or B (this applies to projects with a significant or moderate environmental and social impact) before Eksfin makes a final decision.
In addition, Eksfin will report on its sustainability work as part of the annual report, as well as other external reports where sustainability reporting would be a natural element.
Eksfin holds annual status meetings with its owner (the Norwegian Ministry of Trade, Industry and Fisheries) on the agency’s efforts to contribute to sustainability and responsible business conduct.
For further information on Eksfin’s environmental and social due diligence for an application process, please see “Environmental and social due diligence“