Commerzbank is an international commercial bank with branches in more than 50 countries. Its core markets are Germany and Poland. Commerzbank offers banking and capital market services to nearly 16 million private customers and 1 million business and corporate clients.[i] As of 30 June 2016, Commerzbank held €532.6 billion in total assets.[ii]
According to Commerzbank’s policy on the armaments sector, the bank “does not in any circumstances involve itself in transactions related to controversial weapons.”[iii] For a definition of controversial weapons, Commerzbank refers to the German War Weapons Control Act[iv], which provides an elaborate definition of nuclear weapons based on the revised Brussels Treaty of 1954.[v]
In principle, this means that Commerzbank excludes all companies that are involved in controversial weapons. However, if the involvement constitutes only a small part of the company’s businesses, Commerzbank allows investment as long as the bilateral contract specifically states that funds will not be used for any activity that is related to controversial weapons.[vi]
The exclusion policy applies to the bank’s commercial banking and investment banking activities, as well as to the investments made on its own account and its actively managed funds. However, the policy is not applied to passively managed funds and in addition, clients can request the execution of a buying-order of a specific investment that may contain a nuclear weapon producer. The same applies to orders of such investments through Online-Banking.[vii]
Commerzbank does not publish its exclusion list, which is based on the findings of data provider Sustainalytics.[viii]
Commerzbank was also found to have several investments in nuclear weapon producing companies identified by this report, more information can be found in the Hall of Shame.
We commend Commerzbank for adopting a public policy on nuclear weapons. We recommend Commerzbank apply its policy to all nuclear weapon producers, including companies whose involvement in controversial weapons constitutes only a small part of their activities. Furthermore, Commerzbank’s should apply its exclusion policy to all financial products it offers, including assets managed, and requests from clients that explicitly ask for or choose funds that contain controversial weapons producers should be refused. We look forward to engaging with Commerzbank, so a strong and comprehensively applied policy may be listed in the Hall of Fame in a future update of this report.
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Congratulations ABN Amro. I saw on www.dontbankonthebomb.com that you have a policy limiting investments in nuclear weapons. I think it’s really important that you share my concern about these weapons, and I appreciate that there is a public policy.
However, the policy does have some loopholes and the Don’t Bank on the Bomb report shows how you still might invest in nuclear weapons producers. I am concerned about this, because ABN Amro also invests my money and I don’t want to be associated in any way with the production of these inhumane weapons.
It would be great if ABN Amro made the following changes to make the policy airtight:
• Extend the policy to all companies, regardless of their country of origin;
• Apply the policy to cover all financial products the bank offers, including passively managed funds;
• Apply the policy to assets managed by external parties.
With kind regards,
[i] Commerzbank, “Commerzbank at a glance”, Commerzbank website (www.commerzbank.de/en/hauptnavigation/konzern/commerzbank_im__berblick/commerzbank_ueberblick.html), viewed 1 October 2016.
[ii] Commerzbank, “Interim Report as at 30 June 2016”, page 2, available at: https://www.commerzbank.de/media/en/aktionaere/service/archive/konzern/2016/q2_2016/zwischenbericht_q2_2016.pdf, viewed 1 October.
[iii] Commerzbank, “Positions and Directives”, website Commerzbank (https://www.commerzbank.de/en/nachhaltigkeit/nachhaltigkeitsstandards/positionen_und_richtlinien/positionen_und_richtlinien.html), viewed 1 October 2016.
[iv] Commerzbank, “Positions and Directives”, website Commerzbank (https://www.commerzbank.de/en/nachhaltigkeit/nachhaltigkeitsstandards/positionen_und_richtlinien/positionen_und_richtlinien.html), viewed 1 October 2016.
[v] IUSCOMP, “War Weapons Control Act (Kriegswaffenkontrollgesetz, KrWaffKontrG)”, website IUSCOMP (http://www.iuscomp.org/gla/statutes/KrWaffKontrG.htm), viewed 1 October 2016.
[vi] Commerzbank, written response to Profundo dated 3 June 2014.
[vii] Commerzbank, written response to Profundo dated 9 October 2013; Commerzbank, written response to Profundo dated 3 June 2014.
[viii] Commerzbank, written response to Profundo dated 3 June 2014.