Pensioenfonds APF

Pensioenfonds APF is a Dutch mandatory pension fund for employees of AkzoNobel.[i] It serves over 35,000 clients (including active participants, former participants and pensioners.)[ii] At the end of 2015, APF held EUR112,8 million in assets.[iii]

Pensioenfonds APF excludes companies involved in the development, testing, production, maintenance, selling or distribution of nuclear weapons.[iv] The exclusion criteria also prohibit investment in companies involved in the development, manufacture and maintenance of missiles that are primarily used for carrying nuclear munitions and of submarines equipped with ballistic missiles.[v]

The exclusion policy applies to all investments made by the pension fund’s external asset manager Syntrus Achmea, including direct investments in European, U.S. and Japanese assets. Pensioenfonds APF also invests in several Emerging Markets Funds, for which nuclear weapons are not an exclusion criterion. Pensioenfonds APF’s exclusion policy regarding nuclear weapons applies to approximately 93% of its investment portfolio.[vi]

The exclusion list, which is based on the findings of external research organisation Ethix SRI Advisors, currently contains 49 companies for involvement with controversial weapons: AECOM; Aerojet Rocketdyne Holdings; Aeroteh; Airbus Group; Areva; Aryt Industries; Babcock International Group; BAE Systems; The Boeing Corporation; Booz Allen Hamilton Holding; Brookfield Asset Management; Brookfield Business Partners; BWX Technologies; CACI International; China Shipbuilding Industry; Cohort; Constructions Industrielles de la Mediterranee; Engility Holdings; Exelis; Fluor; General Dynamics; GrafTech International; Hanwha; Harris; Honeywell International; Huntington Ingalls Industries; Jacobs Engineering Group Inc; L-3 Communications Holdings; Larsen & Toubro; Leidos Holdings; Leonardo-Finmeccanica; Lockheed Martin; Moog; Motovilihinskie zavody; Northrop Grumman; Orbital ATK; Poongsan; Poongsan Holdings; Premier Explosives; Raytheon; Rolls-Royce Holdings; S&T Dynamics; S&T Holdings; Safran ; Serco Group ; SGL Carbon ; Textron; Thales; Ultra Electronics Holdings; United Technologies Corp; Walchandnagar Industries. [vii]

We commend Pensioenfonds APF for adopting a public policy on nuclear weapons. We recommend Pensioenfonds APF apply the policy to all of its financial products including investments in Emerging Markets Funds . We look forward to engaging with Pensioenfonds APF, so a strong and comprehensively applied policy may be listed in the Hall of Fame in a future update of this report.

Pension fund APF’s policy on nuclear weapons is leaky; send them a message and tell them to fix it!

To send APF a message, please go to this contact form:

Send this email!
You can write your own message, or copy this message into the contact form.

Congratulations APF. I saw on 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 APF 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 APF made the following change to make the policy airtight:
• Apply the policy to all of its financial products including investments in Emerging Markets Funds.

With kind regards,



[i] Pensioenfonds APF, “Organisatie”, website Pensioenfonds APF (, viewed 17 October 2016.

[ii] Pensioenfonds APF, “Jaarverslag 2015 in vogelvlucht”, website Pensioenfonds APF (, viewed 17 October 2016.

[iii] APF, “Jaarverslag 2015”, page 25, available at, viewed 30 October 2016.

[iv] Pensioenfonds APF, “Stichting Pensioenfonds APF Uitsluitingsbeleid”, page 1, available at, viewed 17 October 2016; Pensioenfonds APF, written response to Profundo dated 7 July 2014.

[v] Pensioenfonds APF, “Stichting Pensioenfonds APF Uitsluitingsbeleid”, available at, viewed 17 October 2016.

[vi] Pensioenfonds APF, “Stichting Pensioenfonds APF Verantwoord beleggen beleid”, p.2, available at, viewed 17 October 2015; Pensioenfonds APF, written response to Profundo dated 7 July 2014.

[vii] Pensioenfonds APF, “Rapportage Verantwoord Beleggen. Eerste halfjaar 2016”, p.6, available at, viewed 17 October 2016.



Who divests?

Policy Research

The financial institutions presented all have publicly available policies – or summaries thereof – excluding investments in nuclear weapons producing companies. Since the banking group usually sets the investment policy and since the group directly or indirectly supervises its subsidiaries, we research the group policy only.

The Hall of Fame section highlights financial institutions that have comprehensive policies preventing investments in nuclear weapon producers. These policies meet all of the criteria.
The Runners-Up provides information on existing policies and makes recommendations for how to strengthen them.


Hall of Fame finanical institution policies policy must:

1. Exclude all nuclear weapon associated companies

The policy excludes:

  • whole companies not only nuclear weapons related projects
  • companies associated with nuclear weapons including through joint ventures
  • companies regardless of their country of origin
  • companies regardless their country of operation

2. Exclude all nuclear weapon associated activities

The policy excludes companies associated with:

  • development, testing, production, maintenance or trade of nuclear weapons related technology, parts, products or services, and;
  • delivery systems such as missiles, that are specifically developed for nuclear tasks. This includes technology that is designed for ‘dual use’ (military and civilian) but excludes technology that is not designed for, but can be used in nuclear warfare. It does not include delivery platforms such as bombers and submarines.

3. Apply to all the institution’s products and services

The institution applies the policy:

  • for the entire Group, including subsidiaries
  • in all markets
  • to all asset management classes – passive and active, internal and external.
  • to all existing and future investments.

The financial institutions in the Hall of Fame have not engaged in any financial relationships with any of the nuclear weapon associated companies listed in this report. The policies of over 80 financial institutions were analysed for this report.

Runners-Up are financial institutions whose nuclear weapons policy does not meet all of the above criteria .


To identify financial institutions with a policy on nuclear weapons, we research a variety of sources: NGO reports, screening-agency information, financial institution reports and websites, information from campaigners and other public sources. For practical reasons, the scope of this report is limited to those financial institutions that have an investment policy or a summary of that policy in English. The list of institutions in the Hall of Fame is not exhaustive. We welcome additions from those able to provide them.

For the purposes of this report, nuclear weapon producers are defined as companies that produce key components to test, develop, maintain, modernise and deploy nuclear weapons. There are countless companies involved in the broad nuclear weapons complex, and this report only details those most heavily involved in the production and maintenance of nuclear warheads and their delivery systems (such as missiles and launch tubes). The report does not include companies involved in the production of delivery platforms (such as nuclear capable bombers and submarines).

In advance of this report, all financial institutions not previously reported on were asked to fill in a standardised questionnaire with detailed questions on the scope and content of their policies. Financial institutions that did not respond are not included. Of the financial institutions listed in the Hall of Fame, several publish a list of companies that they exclude from their investment universe. The companies excluded are listed in the profiles of the financial institutions as a resource. Some financial institutions in the Hall of Fame work with an inclusion list rather than an exclusion list, while others do not make their lists public.

Each financial institution profile in the Hall of Fame includes a brief description of the institution, a summary of key policy elements, and the exclusion list if applicable. We researched investments in companies on our producers list for each of the financial institutions listed in the Hall of Fame. None of the financial institutions listed in the Hall of Fame invest in any of the 27 identified nuclear weapon producers.