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.

Commerzbank's policy on nuclear weapons is leaky. Tell them to fix it!


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Congratulations ABN Amro. 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 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,

Or :

Tweet: Even @commerzbank knows investing in #nuclear weapons should be restricted. Strengthen the policy & say #goodbyenukes!


Website: Twitter: Facebook: @commerzbank


[i] Commerzbank, “Commerzbank at a glance”, Commerzbank website (, viewed 1 October 2016.

[ii] Commerzbank, “Interim Report as at 30 June 2016”, page 2, available at:, viewed 1 October.

[iii] Commerzbank, “Positions and Directives”, website Commerzbank (, viewed 1 October 2016.

[iv] Commerzbank, “Positions and Directives”, website Commerzbank (, viewed 1 October 2016.

[v] IUSCOMP, “War Weapons Control Act (Kriegswaffenkontrollgesetz, KrWaffKontrG)”, website IUSCOMP (, 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.


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.