PenSam is a Danish pension fund that manages occupational pension schemes for about 400,000 clients in Danish municipalities and regions and private organisations. PenSam also offers banking and insurance products.[i]

PenSam’s guidelines on ethical investments state that PenSam avoids “companies that contribute to the production or development of cluster bombs, nuclear weapons or any sub-components used only for such weapons.[ii] Pensam excludes companies involved in the production, development, trade, maintenance of nuclear weapons and specifically designed delivery systems for nuclear weapons.[iii] It does not exclude producers of dual use goods and services.

The exclusion policy applies to all of the pension fund’s investments, including those managed by external asset managers.[iv]

PenSam maintains a publicly available exclusion list based on research by EIRIS to implement its policy.[v] As of March 2016, the list contains the following companies for involvement with nuclear weapons: Babcock & Wilcox; BAE Systems; Boeing; EADS[vi]; Finmeccanica; Fluor Systems; GenCorp[vii]; Huntington Ingalls; Honeywell International; Jacobs Engineering; Northrop Grumman Corp; Northrop Grumman Space; Safran; Serco and United Technologies.[viii]

We commend PenSam for adopting a public policy on nuclear weapons. We recommend PenSam expand the scope of its policy to cover all types of nuclear weapons producing companies including producers of dual use goods and services. We look forward to engaging with PenSam, so a strong and comprehensively applied policy may be listed in the Hall of Fame in a future update of this report.

Pensam has a leaky policy on nuclear weapons. Tell them to fix it!


Congratulations Pensam!

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Click on “Read the Petition” if you want to modify the text!
Congratulations Pensam. 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 Pensam 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 Pensam made the following change to make the policy airtight:
• Expand the scope of the policy to cover all types of nuclear weapons producing companies   including producers of dual use goods and services.

With kind regards,



[i] Pensam, “What is Pensam?”, website Pensam (, viewed 17 October 2016.

[ii] Pensam, “Ethical investments”, website Pensam (, viewed 17 October 2016.

[iii] Pensam, written response to PAX dated 13 May 2015.

[iv] Pensam, written response to PAX dated 13 May 2015.

[v] Pensam, written response to PAX dated 13 May 2015.

[vi] EADS renamed itself in 2014 and is now known as Airbus Group.

[vii] GenCorp renamed itself in 2015 and is now known as Aerojet Rocketdyne.

[viii] Pensam, “Udelukkelsesliste marts 2016”, March 2016, website Pensam (’s%20udelukkelsesliste%20selskaber%20marts2016.pdf), 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.