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KLP list Companies excluded as of December 1st, 2016 * The company is excluded for more than one reason. 1 Company Country Industry Reason for exclusion Human rights AES USA Utilities AES operates the hydropower dam Chan 75 in Panama, which according to UN reports is associated with violations of the human rights of the Ngöbe people. In 2008, the UN sent appeals to the state of Panama, warning of forced displacement, loss of housing, destruction of arable land and widespread use of violence and arrests of members of the indigenous group that opposed project plans. Construction of the dam has resulted in flooding and forced displacement of the Charco la Pava community, but the residents are reported to not have been consulted. The company was excluded in 2008. Alstom France Capital goods In 2007, a special representative for the UN Human Rights Council called on companies involved in the Merowe Dam project in Sudan to halt operations due to reports of human rights violations in connection with the massive forced displacement of local residents; approximately 50,000 people are estimated to have been forced to move owing to the dam's construction. Alstom was among the involved companies, as the main supplier of electric equipment to the project. None of the companies followed the UN special representative's recommendation. The company was excluded in 2007. POSCO DAEWOO South Korea Capital goods Formerly, Daewoo International Corporation POSCO DAEWOO is one of the largest buyers of cotton from Uzbekistan. The Uzbek state maintains a monopoly on the sale of cotton abroad and the use of child labor during the cotton harvest has long been confirmed by international sources. The use of

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Page 1: KLP listenglish.klp.no/polopoly_fs/1.35190.1481279099!/menu/standard/file... · KLP list Companies excluded ... indigenous group that opposed project plans. Construction of the dam

KLP list Companies excluded as of December 1st, 2016

* The company is excluded for more than one reason.

1

Company Country Industry Reason for exclusion

Human rights

AES USA Utilities AES operates the hydropower dam Chan 75 in Panama, which according

to UN reports is associated with violations of the human rights of the

Ngöbe people. In 2008, the UN sent appeals to the state of Panama,

warning of forced displacement, loss of housing, destruction of arable

land and widespread use of violence and arrests of members of the

indigenous group that opposed project plans. Construction of the dam has

resulted in flooding and forced displacement of the Charco la Pava

community, but the residents are reported to not have been consulted.

The company was excluded in 2008.

Alstom France Capital goods In 2007, a special representative for the UN Human Rights Council called

on companies involved in the Merowe Dam project in Sudan to halt

operations due to reports of human rights violations in connection with the

massive forced displacement of local residents; approximately 50,000

people are estimated to have been forced to move owing to the dam's

construction. Alstom was among the involved companies, as the main

supplier of electric equipment to the project. None of the companies

followed the UN special representative's recommendation.

The company was excluded in 2007.

POSCO DAEWOO

South Korea

Capital goods

Formerly, Daewoo International Corporation

POSCO DAEWOO is one of the largest buyers of cotton from Uzbekistan. The Uzbek

state maintains a monopoly on the sale of cotton abroad and the use of child labor

during the cotton harvest has long been confirmed by international sources. The use of

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2

child labor has steadily declined, but has been replaced with a corresponding increase

in the use of adult forced labor. The companies are aware of the risk, but have no plans

to change their sourcing practices and have not implemented measures designed to

ensure that forced labor and child labor are not used in their supply chain in the future.

The company was excluded in 2014.

L-3 Communications

USA

Capital goods

The US Army's report on abuse and torture at the Abu Ghraib prison in

Iraq from 2003-2004 determined that employees of the company Titan

were complicit or present during the abuses. According to the report,

Titan has not addressed these issues adequately, nor given sufficient

instructions to its employees. Titan was subsequently acquired by L-3

Communications, which thereby took over responsibilty. The company

continues to deliver interpretation services to the US Army. The company

must therefore establish mechanisms to avoid the occurrence of future

human rights violations.

The company was excluded in 2005.

Olam

International

Singapore

Food and staples

retailing

Olam International sources 10,000 tons of cotton from Uzbekistan annually. The Uzbek

state maintains a monopoly on the sale of cotton abroad and the use of child labor

during the cotton harvest has long been confirmed by international sources. The use of

child labor has steadily declined, but has been replaced with a corresponding increase

in the use of adult forced labor. The company is aware of the risk and over the last few

years has reduced significantly the amount of cotton it purchases from Uzbekistan.

Nevertheless, the company continues to purchase cotton despite its inability to monitor

whether forced labor or child labor are used within its supply chain in Uzbekistan going

forward.

The company was excluded in 2014.

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POSCO South Korea Materials POSCO is the majority shareholder in POSCO DAEWOO , a company that is among

the largest purchasers of cotton from Uzbekistan (see discussion of POSCO

DAEWOO). The Uzbek state maintains a monopoly on the sale of cotton abroad and

the use of child labor during the cotton harvest has long been confirmed by

international sources. The use of child labor has steadily declined, but has been

replaced with a corresponding increase in the use of adult forced labor. The companies

are aware of the risk, but have no plans to change their sourcing practices and have not

implemented measures reasonably designed to ensure that forced labor and child labor

are not used in their supply chain in the future.

The company was excluded in 2014.

Vedanta Limited* India Materials Formerly, Sesa Sterlite.

Vedanta Limited is a joint venture partner in the aluminum factory currently under

construction in Orissa, India, in which Vedanta Resources is the controlling

shareholder. See Vedanta for the rationale for exclusion.

Vedanta Resources* UK Materials Vedanta Resources is in the process of establishing aluminum production in Orissa,

India. According to Indian authorities, during this process, the company has violated

Indian environmental laws, misled authorities, and caused serious environmental

damage. The facility's establishment requires the felling of several square kilometers of

forest in one of India's most biodiverse regions, which is home to several threatened

species. Furthermore, the company is accused of illegally expanding production,

irresponsible hazardous waste management, violations of indigenous rights, and poor

wages and dangerous working conditions in its mines and factories.

The company was excluded in 2007.

Zuari Agro Chemicals India Materials Zuari Agro Chemicals Ltd. (Zuari) is excluded due to an unacceptable risk that the

company, through its production of hybrid seeds, is complicit in the worst forms of

child labor.

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The Council on Ethics for the Government Pension Fund – Global researched the scale

of child labor in the company's hybrid seed production in 2011 and 2012. On average, it

was discovered that from 20 to 30 percent of the workforce involved in the production

of seeds for the company consisted of children. In its evaluation, the Council has placed

emphasis on the systematic use of children in the company's production. The children's

young age and the health risk to which they are exposed through this work, including

the use of pesticides, indicates that this can be considered among the worst forms of

child labor. The Council on Ethics has furthermore emphasized that the risk of child

labor is well known within the industry, that the company is in close cooperation with

the farmers that employ child labor, and that the company does not have any concrete

measures to reduce the incidence of child labor.

The company was excluded in 2013.

Labor rights

Wal-Mart Stores

USA

Food and staples

retailing

A constant stream of reports in the media and court cases indicate the existence of

systematically poor working conditions at Wal-Mart. The company is criticized for

repeated violations of labor rights in several areas. The criticism involves child labor,

factories that exploit workers, discrimination against women and efforts to resist

unionization. One example is that 67,500 former and current employees in 2008 won a

court case in which Wal-Mart was found to have systematically withheld employee

wages. The judgement was handed down from the highest court in Massachusetts, and

more than 30 similar cases against Wal-Mart are active in other American states.

Another example is a class action lawsuit where 1,6 million employees and former

employees accuse the company of systematically discriminating against women.

The company was excluded in 2003.

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Environment

Barrick Gold

Canada

Materials

Barrick Gold, the world's largest gold producer, operates, inter alia, the Porgera mine

in Papua New Guinea. The company uses a natural river system for the transportation

and deposition of mine waste. This has both a physical and chemical impact that affects

water quality, human beings and animal life. The release of heavy metals such as

mercury will be highly problematic long into the future. The waste contains high

concentrations of, inter alia, arsenic, cadmium, copper, lead and zinc. The

environmental damage that depositing mine waste in river systems can cause is well

known, but the company has not implemented significant measures to prevent or reduce

this damage.

The company was excluded in 2009.

Chevron USA Energy (oil and gas) A court case against Chevron began in 2004 over waste management in the Ecuadorian

rainforest where ChevronTexaco, as the company was then known, operated from the

1960's to the 1990's. The court found against Chevron in 2013. The company is accused

of having, over many years, dumped larged quantities of poisonous, carcinogenic

waste, and thereby polluted water and soil for many local communities. Chevron

contests the findings in several of the investigations that have been made, but in 2008,

an independent investigation confirmed that 42 of 46 waste sites have high levels of

poison, and that the majority of these are not included in Chevron's remediation

program, which the company and the Ecuadorian authorities had agreed upon. As a

result, the court case against Chevron involves not only the environment, but also

claims of fraud.

The company was excluded in 2002.

Duke Energy Corp.,

including the

subsidiaries Duke

Energy Carolinas

USA Utilities The company was previously excluded for coal-based activities. As this know

comprises a smaller proportion of the company's revenues, the exclusion is now based

on the risk of severe environmental damage. Duke Energy and the named subsidiaries

are excluded from the Government Pension Fund Global for repeated violations

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LLC, Duke Energy

Progress LLC,

Progress Energy Inc.

connected to the treatment of ash waste from coal power plants in the USA. The waste

depots are not expected to be removed before 10 to 15 years from now.

The company was excluded in 2016.

Freeport McMoRan

USA Materials Freeport McMoRan Copper & Gold operates the world's largest gold mine and second

largest copper mine on New Guinea in Indonesia. The company deposits mine waste in

a natural river system, and heavy metal runoff has from the company's landfills for

waste rock and tailings has been documented. The company dumps as much as 230,000

tons per day. Comprehensive documentation shows that the company's activities have

caused widespread and permanent environmental damage to the ecosystems in and

along the entire watercourse and that the company has only to a limited extent

implemented measures to prevent or mitigate this damage.

The company was excluded in 2006.

Genting Berhad

Malaysia

Hotels, restaurants &

leisure

Genting Berhad, through its subsidiary, Genting Plantations Berhad, is excluded due to

an unacceptable risk that the company's ongoing conversion of rainforest to oil palm

plantations in Indonesia will cause a serious loss of biodiversity. The company has not

indicated it will engage in mitigating measures sufficient to lessen the risk of severe

environmental damage.

The company was excluded in 2015.

Genting Plantations

Berhad

Malaysia

Food

products

Genting Plantations Berhad is excluded due to an unacceptable risk that the company's

ongoing conversion of rainforest to oil palm plantations in Indonesia will cause a

serious loss of biodiversity. The company has not indicated it will engage in mitigating

measures sufficient to lessen the risk of severe environmental damage.

The company was excluded in 2015.

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IJM Corporation

Berhad

Malaysia Construction and

engineering

IJM Corporation Berhad, through its subsidiary, IJM Plantations Berhad, is engaged in

the conversion of rainforest to palm oil plantations in an area of rich and unique

biodiversity in Indonesia. The company has not announced how it has mapped high

conservation values within the affected concessions. Nor has it announced significant

mitigating measures to stem the potentially irreversible loss of biodiversity.

The company was excluded in 2015.

IJM Plantations

Berhad

Malaysia

Food

products

IJM Plantations Berhad is engaged in the conversion of rainforest to palm oil

plantations in an area of rich and unique biodiversity in Indonesia. The company has

not announced how it has mapped high conservation values within the affected

concessions. Nor has it announced significant mitigating measures to stem the

potentially irreversible loss of biodiversity.

The company was excluded in 2015.

Lingui Development Malaysia Paper and forest

products

Lingui Developments Berhad produces, among other things, timber and wood products.

Investigations by the Council on Ethics for the Government Pension Fund – Global

documented what appears to be comprehensive and repeated violations of concession

requirements and regulations in all of the company concessions that were investigated.

Some of the violations were extremely serious, such as logging outside of the

concession areas, logging in protected areas that were excluded by the authorities from

the concession for inclusion in an existing national park, and the completion of second-

generation logging without an environmental impact assessment.

The company was excluded in 2011.

Madras Aluminium

Company

India Metals and mining Madras Aluminium Company (Malco) is a listed subsidiary of Vedanta. The company

is recommended excluded by the Council on Ethics for the Government Pension Fund –

Global in the same recommendation as the parent company. Malco generates

significant quantities of pollution and hazardous waste. The accusations have been

directed especially at the disposal of red mud, a waste prouct from refining bauxite. It

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is, however, also reported that operation of the mines, smelters and power plants entails

significant environmental consequences and health damage for the local population.

The company was excluded in 2008.

Noble Group Ltd.

Singapore

Capital goods

Noble Group owns through two subsidiaries concession areas in, respectively, Papua

and West Papua, in Indonesia, where the company plans to convert forest to palm oil

plantations. The area has a unique biological diversity that cannot be found in any other

part of the world. The company has completed pre-development studies of the

concession areas' conservation value, known as "high conservation value" or "HCV"

assessments. Technical experts retained by the Council on Ethics for the Government

Pension Fund – Global have identified significant weaknesses in these HCV

assessments, which in KLP's estimation the company has not addressed in a sufficient

manner. Neither does the company have any plans to undertake new assessments, or

submit the existing assessments for third party peer review. Although the company is a

member of the Roundtable on Sustainable Palm Oil, that organization's currently

applicable requirements are more stringent than those which prevailed when the HCV

assessments were undertaken. Due to all of the above reasons, KLP determines that

there exists an unacceptably high risk that the company, through the conversion of

rainforest to palm oil plantiations, will cause serious environmental damage.

The company was excluded in 2015.

Norilsk Nickel Russia Materials Norilsk Nickel's Polar division in Siberia has emitted large quantities of sulfur dioxide,

nickle and heavy metals for many years. These emissions have lead to the death or

significant damage of vegetation up to 20 kilometers from the facilities. The air

pollution has also led to significant health problems among the local population.

Respiratory illness and various forms of cancer are far more common here than in other

parts of Russia. The environmental damage is comprehensive, long-term, and in some

cases, irreparable. Although the company has implemented measures in recent years to

reduce the release of metals into the environment, the levels remain high and sulfur

dioxide emissions are essentially unchanged. In the Council's opinion, the company

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does not appear to be in compliance with national environmental standards, and does

not appear to have plans to remediate polluted areas.

The company was excluded in 2009.

Rio Tinto UK Metals and mining Together with Freeport McMoRan, Rio Tinto owns the world's largest gold mine and

the world's next largest copper mine on New Guinea in Indonesia. The Grassberg mine

emits large quantities of tailings, approximately 230,000 tons per day, directly into a

natural river system. These tailings will increase going forward, in conjunction with

expansion of the mine. Furthermore, there is a large risk that the runoff of heavy metals

from the company's landfills for waste rock and tailings pollute the soil and

watercourses. The mine is expected to be operational through 2041, which must be

considered to imply a severe impact on the environment as nothing indicates that the

company will change these practices in the future.

The company was excluded in 2008.

Samling Global Malaysia Paper and forest

products

The Malaysian forestry company Samling Global is recommended for exclusion by the

Council on Ethics for the Norwegian Government Pension Fund – Global due to illegal

logging and serious environmental damage. The Council on Ethics has investigated the

company's activities in Sarawak (Malaysia) and Guyana.

The company was excluded in 2010.

Ta Ann Berhad

Holdings

Malaysia Materials Ta Ann Holdings Berhad (Ta Ann) is excluded due to an unacceptable risk that the

company, through its forestry operations, is responsible for severe environmental

damage. Ta Ann is a Malaysian forestry company with its principal place of business

on Borneo in Sarawak, Malaysia. The company engages in logging of tropical forest,

and is in addition in the process of converting large forest areas to plantations for the

production of wood and palm oil.

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The Council on Ethics for the Government Pension Fund – Global has evaluated the

environmental impact connected to logging and deforestation in Ta Ann's concession

areas in Sarawak. The Council has evaluated in particular to what extent the concession

areas overlap with areas of high ecological value, and the consequences that conversion

of forest entails for threatened species and their habitat.

The company was excluded in 2013.

Tokyo Electric Power

Company

Japan Utilities In 2011, the nuclear power plant Fukushima Dai-ichi, which is owned by Tokyo

Electric Power Company (TEPCO), was hit by an earthquake and accompanying

tsunami. Although TEPCO and the company's leadership did all that they could to

prevent the catastrophic consequences the accident caused, and can be considered to

have done everything correctly in an emergency situation, the consequences of the

tsunami and the accident could have been reduced, and perhaps avoided entirely,

through greater attention to risk in advance. In addition, the company has not managed

to obtain control over the situation following the accident, nor to prevent additional

spills. There remains a large risk of further leakages of radioactive material from the

nuclear power plant. KLP therefore considers investment in TEPCO to entail a risk of

complicity in severe environmental damage, and therefore a violation of KLP's

guidelines for responsible investment.

The company was excluded in 2013.

Vedanta Limited* India Materials Formerly, Sesa Sterlite.

Vedanta Limited is a joint venture partner in the aluminum factory currently under

construction in Orissa, India, in which Vedanta Resources is the controlling

shareholder. See Vedanta for the rationale for exclusion.

Vedanta Resources* UK Materials Vedanta Resources is in the process of establishing aluminum production in Orissa,

India. According to Indian authorities, during this process, the company has violated

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Indian environmental laws, misled authorities, and caused serious environmental

damage. The facility's establishment requires the clearing of several square kilometers

of forest in one of India's most biodiverse regions, which is home to several threatened

species. Furthermore, the company is accused of illegally expanding production,

irresponsible hazardous waste management, violations of indigenous rights, and poor

wages and dangerous working conditions in its mines and factories.

The company was excluded in 2007.

Volcan Compañia

Minera

Peru Materials The Council on Ethics for the Government Pension Fund – Global recommends

exclusion of the Peruvian company Volcan Compañia Minera SAA (Volcan) due to the

unacceptable risk that the company, through its mining operations in Cerro de Pasco,

Peru, is complicit in serious environmental damage. Volcan is Peru's largest producer

of lead and silver, as well as the country's second largest producer of zinc. The mine is

located within a city of 70,000 inhabitants. Since mining operations take place within

populated areas of the city, the Council has placed emphasis on the consequences of

mining operations for human life and health, especially the risk of illness and injury

among children, owing to high lead concentration in the soil and water.

The company was excluded in 2013.

WTK Berhad

Holdings

Malaysia Materials WTK Holdings Berhad (WTK) is excluded due to an unacceptable risk that the

company, through its logging operations, is responsible for serious environmental

damage. WTK is a Malaysian forestry company that engages in logging and the

production of plywood and lumber.

The Council on Ethics for the Government Pension Fund – Global has placed emphasis

on the environmental damage connected to the conversion of tropical forest to

plantations, environmental damage from logging, and that the company's operations

appear to violate the usual concession conditions and can therefore be assumed to be

illegal. In its evaluation, the Council emphasized the scale of the damage and the extent

to which it entails long-term or irreversible effects, whether the environmental damage

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violates national standards and international norms, and what the company has done to

mitigate the effect of the damage.

The company was excluded in 2013.

Zijin Mining Group China Materials Zijin Mining Group Co. Ltd. (Zijin) is excluded due to an unacceptable risk that the

company, through its operations, will cause serious environmental damage. Zijin is a

large producer of gold, copper and zinc, and has several facilities for mineral extraction

and metal production. Over the past few years, there have been several serious

incidents at the company's facilities where landfill dams for mining and process waste

have collapsed, leading to widespread pollution and the loss of human life. The

incidents involved landfill dams that have collapsed, such that large quantities of

mining waste, industrial waste and hazardous chemicals have washed into waterways or

flooded settlements and arable land. In the span of the past ten years, seven such

incidents have been reported at the company's facilities in China.

The company was excluded in 2013.

Corruption

Centrais Eletricas

Brasileiras SA

(Eletrobras)

Brazil Electric

utilities

Eletrobras is excluded due to an unacceptable risk of gross corruption. According to its

reports to US financial authorities, the company's contracts with suppliers have been

inflated over a period of nearly seven years, with the excess paid to Brazilian

politicians, political parties and company executives. Until October 2016, Eletrobras

risked delisting from the New York Stock Exchange. This was due to incomplete

accounting for corruption in its financial reports after the company's auditor refused to

approve the reports for 2014 and 2015. The company no longer faces delisting, but

writes to US financial authorities that it could take close to two years before a

comprehensive anticorruption program is in place.

The company was excluded in 2016.

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China Railway Group,

Ltd.

China

Capital

goods

China Railway Group, Ltd. has been associated with serious corruption, inter alia,

through the payment of bribes to public officials in China to secure the company

railway contracts. The bribe recipients have later been punished through the court

system and the Communist Party's disciplinary processes. CRG's leadership is

essentially unchanged since that time, and publicly available information about the

company's ethical guidelines indicate major omissions relative to the routines in

operation in the rest of the industry. Neither has the company responded to KLP's

inquiries about the case. Therefore, the risk that CRG will be involved in future serious

corruption is considered to be unacceptably high.

The company was excluded in 2015.

Petróleo Brasileiro

S.A. (Petrobras)

Brazil

Energy

Petrobras is involved in the largest corruption scandal in Brazilian history. Over more

than a decade, the company's contracts with suppliers were routinely inflated by three

percent of the contract sum, with the proceeds paid in bribes to Brazilian politicians,

political parties and Petrobras executives. Despite the company's many remedial

measures and continued outside pressure, KLP remains convinced that there remains an

unacceptable risk that the company will be involved in corruption in the future.

The company was excluded in 2016.

ZTE Corporation

China

Technology Hardware

& Equipment

ZTE Corporation has been under investigation for 10 corruption cases. It has been

temporarily barred from public bidding processes and, in one case, received a corporate

criminal conviction. In sum, the allegations encompass over 18 countries. ZTE

Corporation has not communicated any new measures undertaken to prevent

recurrence. KLP concludes that the company continues to face an unacceptably high

risk for involvement in corruption.

The company was excluded in 2016.

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Rights of individuals in war and conflict

AFI Group Israel Real estate AFI Group is involved in the construction of Israeli settlements in the Occupied Palestinian

Territories. In 2009, subsidiary Danya Cebus constructed housing in three settlements in the

region. According to international law, especially the Fourth Geneva Convention relative to

the Protection of Civilian Persons in Time of War, the Israeli settlements are illegal. Several

UN Security Council Resolutions and an International Court of Justice Advisory Opinion

have concluded that the establishment of Israeli settlements on occupied Palestinian territory

is illegal according to this convention.

The company was excluded in 2010.

Danya Cebus Israel Engineering and

construction

See the reason for exclusion of AFI Group.

The company was excluded in 2010.

Shikun & Binui

Israel

Engineering and

construction

Shikun & Binui Ltd. is involved in the construction of Israeli settlements in East Jerusalem

and has previously also been involved in the building of settlements on occupied territory in

the West Bank and in East Jerusalem. The International Court of Justice, the UN Security

Council and the International Committee of the Red Cross (ICRC) have all determined that

the construction of Israeli settlements in the West Bank and in East Jerusalem violates the

Fourth Geneva Convention. The purpose of this convention is to protect civilians in time of

war and occupation.

The company was excluded in 2012.

Other ethical norms

Agrium Inc. Canada Materials Agrium has confirmed that the company imports phosphate from Western Sahara. The

International Court of Justice has determined that Morocco has no legal claim to Western

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Sahara and, accordingly, none to Western Sahara's natural resources. Extraction of natural

resources from occupied territory, in particular, in Western Sahara, has also been declared

illegal by the UN Under-Secretary-General for Legal Affairs in 2002.

The company was excluded in 2014.

Cairn Energy UK Oil & Gas

exploration

Through a 20 % ownership stake in a joint venture with Kosmos Energy Ltd. and the Office

National des Hydrocarbures et des Mines (ONHYM), Cairn holds a license issued by

Moroccan authorities for oil exploration off the coast of Western Sahara. KLP and the KLP

Funds consider investment in Cairn to be in violation of the KLP and KLP Funds' guidelines

for responsible investment, and the company's activities on the continental shelf off the

coast of Western Sahara are associated with violations of fundamental ethical norms.

The company was excluded in 2016.

Elbit Systems

Israel Capital goods Elbit Systems supplies an electronic surveillance system that is a component in the

separation barrier that Israeli authorities have constructed along the West Bank. The

sections of the barrier that lie within the Occupied Palestinian Territories are considered

illegal under international law. Through its supply of this system, Elbit contributes to

support illegal activities.

The company was excluded in 2009.

Glencore plc

UK Metals and mining Glencore is conducting exploration and seismic studies of possible oil reserves under the

continental shelf off the coast of Western Sahara. KLP considers investment in Glencore to

be in conflict with KLP's guidelines for responsible investment and has conclude that the

company's operations on the continental shelf off the coast of Western Sahara are associated

with a violation of fundamental ethical norms.

The company was excluded in 2015

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HeidelbergCement

Germany Materials HeidelbergCement is excluded due to the company's extraction of natural resources from

occupied territory. Through a subsidiary, HeidelbergCement operates a quarry in Area C

in the West Bank, an area under full Israeli civil and military control. The quarries were

established after the occupation began and license fees and royalties are paid to the

Israeli state. Based on a review of the law of belligerent occupation, KLP concludes that

the activities are not consistent with the international law principle that occupation shall

be temporary. Neither does this resource extraction benefit the local population.

Therefore, the operation of a quarry on occupied territory that was opened after the

occupation constitutes an unacceptable risk of violating fundamental ethical norms.

The company was excluded in 2015.

Incitec Pivot Australia Chemicals Incitec Pivot imports phosphate rock from Western Sahara, which is under Moroccan

occupation. The International Court of Justice has determined that Morocco has no legal

claim to Western Sahara, and by extension, no legal claim to Western Sahara's natural

resources. Extraction of natural resources from occupied territory, in particular, in

Western Sahara, has also been declared illegal by the UN Under-Secretary-General for

Legal Affairs in 2002.

The company was excluded in 2009.

Kosmos Energy Ltd. USA Oil & Gas

exploration

Through a 55 % ownership stake in a joint venture with Cairn Energy Plc. and the Office

National des Hydrocarbures et des Mines (ONHYM), Kosmos holds a license issued by

Moroccan authorities for oil exploration off the coast of Western Sahara. Kosmos is also the

operator. KLP and the KLP Funds consider investment in Kosmos to be in violation of the

KLP and KLP Funds' guidelines for responsible investment, and the company's activities on

the continental shelf off the coast of Western Sahara are associated with violations of

fundamental ethical norms.

The company was excluded in 2016.

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Potash Corp

Saskatchewan

Canada Chemicals Potash has confirmed that a fully-owned subsidiary imports phosphate rock from

Western Sahara. The International Court of Justice has determined that Morocco

has no legal claim to Western Sahara, and by extension, no legal claim to Western

Sahara's natural resources. Extraction of natural resources from occupied territory,

in particular, in Western Sahara, has also been declared illegal by the UN Under-

Secretary-General for Legal Affairs in 2002.

The company was excluded in 2010.

San Leon Energy PLC Ireland Energy San Leon Energy conducts oil exploration off the coast of Western Sahara on the basis of a

contract with the Moroccan authorities. KLP considers investment in San Leon Energy to be

in conflict with KLP's guidelines for responsible investment and has conclude that the

company's operations on the continental shelf off the coast of Western Sahara are associated

with a violation of fundamental ethical norms.

The company was excluded in 2016.

Weapons producers

Aerojet Rocketdyne

Holdings

USA Capital goods Formerly, GenCorp.

Aerojet Rocketdyne Holdings produces cluster munitions components. The company

markets warheads for the weapons systems GMLRS, MLRS and ATACMS on its website.

All three meet the definition of cluster munitions as set out in the Convention on Cluster

Munitions. Aerojet Rocketdyne Holdings is also involved in the production of nuclear

weapons. The company produces propellants for missiles that have no other function than to

deploy nuclear warheads.

The company was excluded in 2008.

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Airbus Group,

including bonds issued

by Airbus Group

Finance B.V.

The

Netherlands

Capital goods The company is complicit in the production of nuclear weapons. Formerly, EADS.

The company was excluded in 2005.

BAE Systems

UK Aerospace and

defense

BAE Systems is involved in the production of nuclear weapons through its contract with

the US Air Force for maintenance and upgrading of the Minuteman III ICBM weapons

system, valid through 2021. This is considered nuclear weapons production as

components must be updated and replaced on a rolling basis in order to keep a several-

decades-old weapon system technologically updated.

The company was excluded in 2015.

Boeing

USA

Capital goods

According to information on its website, Boeing supplies various forms of maintenance and

upgrades of the Minuteman III ICBM. ICBMs are the main component in US land-based

strategic nuclear weapons.

The company was excluded in 2006.

BWX Technologies

Inc.

USA

Capital goods

Previously, Babcock & Wilcox Company.

BWX Technologies is involved in the development and operation of central elements and

services connected to nuclear weapons. The company operates two nuclear weapons

facilities on behalf of the US military.

The company was excluded in 2011.

Leonardo -

Finmeccanica

Italy Capital goods Previously, Finmeccanica

Leonardo-Finmeccanica is part-owner in the joint venture company MBDA.

MBDA has according to Jane’s Air Launched Weapons a contract to develop and

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produce the ASMP-A missile for the French air weapons system. ASMP-A is

described as a "nuclear warhead air-to-surface missile”.

The company was excluded in 2006.

Fluor Corp.

USA Construction and

engineering

Through a joint venture with Honeywell and Huntington Ingalls Industries, Fluor

Corp. provides the US military with its sole source of tritium gas. Tritium is a

central component in nuclear warheads. The companies deliver the gas in a

concentration intended for weapons use only.

The company was excluded in 2015.

General Dynamics USA Capital goods General Dynamics is involved in nuclear weapons production and in the US

nuclear weapons defense system. In addition, the company has produced cluster

munitions, but stated in 2010 that it no longer markets or produces this type of

weapon. Nevertheless, the company will not guarantee that it will not produce

cluster munitions in the future.

The company was excluded in 2005.

Hanwha South Korea Materials Hanwha Corporation has confirmed to the Council on Ethics for the Government

Pension Fund – Global that it produces air- and surface-delivered cluster

munitions. The company also markets these on its website.

The company was excluded in 2008.

Honeywell

International

USA Capital goods Through its subsidiary Honeywell Technology Solutions Inc., the company is

responsible for the repair, development, calibration, operation and maintenance of

measuring instruments, as well as the registration of data for nuclear weapons

detonation simulations at White Sands Missile Range in New Mexico.

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The company was excluded in 2006.

Huntington Ingalls

Industries

USA Aerospace and

defense

Through a joint venture with Honeywell and Fluor Corp., Huntington Ingalls

Industries provides the US military with its sole source of tritium gas. Tritium is a

central component in nuclear warheads. The companies deliver the gas in a

concentration intended for weapons use only.

The company was excluded in 2015.

Jacobs Engineering

USA

Construction and

engineering

Jacobs Engineering Group is involved in the development of central elements and services

connected to nuclear weapons. The company's joint venture, Atomic Weapons

Establishment (AWE), is involved in the production and maintenance of warheads for the

Trident II missile system, which is a part of the British nuclear defense system.

The company was excluded in 2010.

Lockheed Martin USA Capital goods The company is involved in the development of central components and services

connected to nuclear weapons. The company's joint venture Atomic Weapons

Establishment (AWE) is involved in the production and maintenance of warheads

for the Trident II missile system, which is part of the British nuclear defense

system.

The company was excluded in 2005.

Northrop Grumman USA Capital goods The company is, according to its own press release, contracted to complete

maintenance and upgrading of the US Air Force’s Minuteman III ICBMs. ICBMs

constitute the main component of the United States' land-based, strategic nuclear

weapons.

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The company was excluded in 2006.

Orbital ATK USA Capital goods Formerly, Alliant Techsystems.

Orbital ATK has been involved in several weapon projects, both as a supplier of

special components and as the main producer of whole cluster munitions. The

company no longer produces cluster munitions, but follows US policy on the

subject and will produce if there is demand. Alliant Techsystems is also involved

in the production and maintenance of nuclear weapons (US nuclear defense

system).

The company was excluded in 2005.

Poongsan Corporation South Korea Materials Poongsan Corporation produces various types of ammunition for military use,

hereunder, cluster munitions. On its website, the company describes three

variations of this type of weapon.

The company was excluded in 2008.

Poongsan Holdings

Corporaiton

South Korea Materials Poongsan Holdings owns 32 percent of Poongsan. See the reason for exclusion of

Poongsan.

The company was excluded in 2007.

Raytheon USA Capital goods Raytheon is involved in the development of central elements and services

connected to nuclear weapons. The company is involved in the Trident II missile

system, which is a part of the US nuclear defense system. According to its website,

the company also produces JSOWs (joint stand off weapons) and cluster

ammunition for these. This weapon is considered a cluster munition. This

information is confirmed by Jane’s Information Group.

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The company was excluded in 2007.

Safran Group Frankrike Capital goods Safran is the parent company for the companies Snecma and Sagem, which

according to Jane’s Missiles and Rockets are producing a new missile system

(M51) for strategic nuclear weapons for the French Navy.

The company was excluded in 2007.

Serco Group UK Commercial services

and supplies

Serco Group has confirmed that the company produces weapons that can be

characterized as nuclear weapons. Through a joint venture with Atomic Weapons

Establishment, the company maintains the UK's nuclear weapons.

The company was excluded in 2008.

Singapore

Technologies,

including bonds issued

by ST Engineering

Financial

Singapore Capital goods The company has confirmed that it produces landmines – not for export, but for

Singapore's defense. Singapore has not signed the Anti-Personnel Mine Ban

Convention.

The company was excluded in 2001.

Textron USA Capital goods Textron develops, produces and markets cluster munitions and components of

cluster munitions that are prohibited under the Convention on Cluster Munitions.

The company claims that altering the design of this type of weapon could be a

possibility in order to comply with the convention, but that the company is not

"convinced that this would be the best solution to eliminate the unacceptable risk

for civilians."

The company was excluded in 2008.

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Tobacco producers

Company Country Al Eqbal for Investment Jordan

Alliance One International USA

Altria Group USA

British American Tobacco UK

Ceylon tobacco Sri Lanka

Grupo Carso Mexico

Gudang Garam Indonesia

HM Sampoerna Indonesia

Huabao International Holdings Hong Kong

Imperial Tobacco UK

ITC India

Japan Tobacco Japan

KT&G Corp South Korea

Lorillard USA

Philip Morris USA

Reynolds American USA

Sabanci Holdings (Haci Omer) Turkey

Schweitzer-Mauduit USA

Shanghai Industrial Holdings Hong Kong

Souza Cruz Brazil

Swedish Match Sweden

Universal Corp USA

Vector Group USA

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Coal companies

Company Country Industry Group Aboitiz Power Corp. Philippines Utilities

Adani Power Ltd. India Utilities

Adaro Energy Tbk Indonesia Coal and other fuels

AES Gener SA Chile Utilities

AGL Energy Ltd. Australia Utilities

Allete Inc. USA Utilities

Alliant Energy USA Utilities

Ameren Corp. USA Utilities

American Electric Power Co., Inc. USA Utilities

Appalachian Power Co. USA Utilities

Banpu Public Comp. Ltd. Thailand Coal and other fuels

Capital Power Corp. Canada Utilities

CESC Ltd. India Utilities

China Coal Energy Comp., Ltd. China Coal and other fuels

China Power International Development China Utilities

China Resources Power Holdings Comp. Ltd. China Utilities

China Shenhua Energy Comp. China Coal and other fuels

Cleco Corporate Holdings LLC USA Utilities

CLP Holdings Ltd. Hong Kong Utilities

Coal India Ltd. India Coal and other fuels

CONSOL Energy, Inc. USA Coal and other fuels

Datang International Power Generation Comp., Ltd. China Utilities

DMCI Holdings, Inc. Philippines Capital goods

Drax Group PLC UK Utilities

DTE Energy Co. USA Utilities

Dynegy Inc. USA Utilities

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E-CL SA Chile Utilities

Electric Power Development Japan Utilities

Electricity Generating PCL Thailand Utilities

Emera Inc., including bonds issued by Emera US Finance LP Canada Utilities

Exxaro Resources Ltd. South Africa Coal and other fuels

FirstEnergy Corp. USA Utilities

Glow Energy Public Co. Thailand Independent power producers and energy traders

Gujarat Mineral Development Corp. Ltd. India Coal and other fuels

HK Electric Investments Ltd. Hong Kong Utilities

Hokkaido Electric Power Co. Inc. Japan Utilities

Hokuriku Electric Power Comp. Japan Utilities

Huadian Power International China Utilities

Huaneng Power International Inc. China Utilities

IDACORP Inc. USA Utilities

Indiana Michigan Power Co. USA Utilities

Indo Tambangraya Megah Tbk PT Indonesia Coal and other fuels

Inner Mongolia Yitai Coal Co., Ltd. China Coal and other fuels

Jastrzebska Spólka Weglowa SA Polen Steel

Korea Electric Power South Korea Utilities

Lubelski Wegiel Bogdanka SA Poland Coal and other fuels

MGE Energy Inc. USA Utilities

New Hope Corp. Ltd. Australia Coal and other fuels

Northern States Power Co. MN USA Utilities

NRG Energy, Inc. USA Independent power producers and energy traders

NTPC Ltd. India Utilities

OGE Energy Corp. USA Utilities

Okinawa Electric Power Co. Inc./The Japan Utilities

Peabody Energy Corp. USA Coal and other fuels

Pinnacle West Capital USA Utilities

PNM Resources Inc. USA Utilities

Public Power Corp. SA Greece Utilities

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Public Service Co. of Colorado USA Utilities

Public Service Co. of New Mexico USA Utilities

Reliance Infrastructure India Utilities

Reliance Power Ltd. India Utilities

Shikoku Electric Power Japan Utilities

Shougang Fushan Resources Group Ltd. Hong Kong Steel production

Southwestern Public Service Co. USA Utilities

Tambang Batubara Bukit Asam Tbk PT Indonesia Coal and other fuels

Tata Power Co., Ltd. India Utilities

Teco Energy Inc., including bonds issued by Teco Finance USA Utillities

The Southern Company USA Utilities

TransAlta Corp. Canada Utilities

Union Electric Co. (d/b/a/ Ameren Missouri) USA Utilities

WEC Energy Group USA Utilities

Westar Energy, Inc. USA Utilities

Whitehaven Coal Ltd. Australia Coal and other fuels

Wisconsin Electric Power Co. USA Utilities

Xcel Energy USA Utilities

Yanzhou Coal Mining Comp. Ltd. China Coal and other fuels