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Banks, pensions and nuclear weapons:Investing in change

The Nuclear Weapons Financing Research Group consists of representatives of the Baptist Union of Great Britain,Church of Scotland, Christian CND, Don't Bank on the Bomb Scotland, Ecumenical Council for CorporateResponsibility, Methodist Church, Nipponzan Myohoji, Quakers in Britain, Pax Christi UK, Soka Gakkai International-UKand United Reformed Church. The group is grateful to the Christian Campaign for Nuclear Disarmament for providingthe funding for the design of this report and our website.The agencies share a commitment to the implementation of the Treaty on the Prohibition of Nuclear Weapons andsome are partners of International Campaign to Abolish Nuclear Weapons (ICAN).

BANKS, PENSIONS AND NUCLEAR WEAPONS: INVESTING IN CHANGEForewordTHE DEBATE around nuclear weapons has reached a critical point. A renewed appreciationof the devastating humanitarian consequences of nuclear weapons has convinced amajority of states that complete elimination is both essential and urgent.The spread of COVID-19 has demonstrated the need for both constructive internationalcooperation and investment in healthcare in the face of pandemic risks and health challengesarising from climate change. Estimates put the global nuclear weapon modernisation spend atabout 1 trillion over the next 10 years. This diversion of finite resources is unjustifiable in thelight of public health demands, which we now appreciate more than ever are crucial to ourmutual wellbeing across the globe. Yet it is still difficult to engage nuclear weapon states, including the UK, inconstructive dialogue on approaches to disarmament.Long-term treaties are facing non-renewal and some nuclear-armed states are using alarming rhetoric featuring nuclearweapons. Meanwhile threat of low yield nuclear weapons could change the threshold at which states couldcontemplate using nuclear arms. The prospect of further states seeking to possess nuclear weapons is equallyconcerning. However there is hope for real change.The UN Treaty on the Prohibition of Nuclear Weapons (TPNW) was agreed in 2017. Once this is ratified by 50 states andcomes into effect as a new piece of international law, the implications will be significant for nuclear armed states andfinancial institutions alike. The biggest banking corporations have a global reach and cannot disregard international law.We must ensure that the current, apparent legitimacy of nuclear weapons is brought to an end. Parliamentarians havean important duty here, but governments are slow to act. Consequently, it is vital that citizens make their voices heard,particularly within the UK and other nuclear-armed countries and their allies.Today many financial institutions express their desire to be a force for good in society but may not realise that their loansand investments finance the development of new nuclear weapons. PAX publishes the ‘Don’t Bank on the Bomb’ reportto monitor the progress of financial institutions in divesting from nuclear weapons. This new UK study builds on thatwork.I call on UK citizens who are bank customers or pension fund members to find out how your money is invested. This is arevealing report that enables us all to write to our banks and pension providers with some knowledge of their currentpractice. We can bring about change. We need the finance industry to be excluding from investment those companiesthat are significantly involved in the development or maintenance of nuclear weapons. Please join in this effort. Use theresources and draft letters on the project website to write to your bank or pension provider. I am convinced thattogether we can make a difference.Baroness Susan Miller, Member of the House of LordsMember of Parliamentarians for Nuclear Non-Proliferation and Disarmament1

Executive SummaryTHE Nuclear Weapons Financing Research Group comprises representatives from UK-based faith groupsconcerned with the significant amount of corporate financing that supports nuclear weapons production.The group has entered into dialogue with UK-based banks and pension providers to assess current andevolving practice. Our dialogue has revealed an openness on the part of several banks and pension funds todetermine the views of their customers on nuclear weapons.In this report, we provide important data and analysis comparing policy, practice and transparency regardingnuclear weapons investment across a range of financial institutions. This information can be used to support thesuggested actions by individuals. Future editions of this report will be able to track progress towardsdisinvestment. Our key findings and possibilities are as follows: Nearly 32 billion is invested in companies producing nuclear weapons by UK financial institutions.1 The UN Treaty on the Prohibition of Nuclear Weapons is anticipated to transform the way investment innuclear weapons is treated under international law. Most banks and pension providers are financing companies that are producing nuclear weapons. Many institutions claim to be listening or are prepared to review policies. Customers of UK financial institutionstherefore have an opportunity to challenge investment in nuclear weapons at this pivotal time.So how can we best bring about change in the investment policies and practices of major financial institutions?This report provides an outline of the current state of play, and then makes a number of recommendations forthose with bank accounts and/or pension funds.2

BANKS, PENSIONS AND NUCLEAR WEAPONS: INVESTING IN CHANGE1. The scale of private sectorinvolvement in nuclear weaponsWhilst significant progress is being made in the UnitedNations to prohibit nuclear weapons, private sectorinvestment in the industry has increased significantly.2The 2019 ‘ICAN/PAX report 'Shorting our Security’revealed that the private sector is investing 748 billionannually in companies with an involvement in nuclearweapons, a 42% increase from 2018.3 Financialinstitutions based in the UK make up a significantproportion of this, investing 31.6 billion between 2017and 2019.4However, there is a growing perception among clientsand shareholders that investing in nuclear weaponproducers represents a reputational and financial risk,and this has made a material difference. Major fundssuch as the Norwegian Government’s pension fund (thesecond largest pension fund in the world) have changedtheir investment approach with respect to nuclearweapons producers.5 Several financial institutions andfunds have explicitly highlighted the UN Treaty on theProhibition of Nuclear Weapons (TPNW) in their decisionto cease nuclear weapon investment, includingAmalgamated Bank (based in the US), ABP (the fifthlargest pension fund in the world, based in theNetherlands, a country that hosts US nuclear weapons),and KBC (based in Belgium, which also hosts US nuclearweapons).6 Combined with diplomatic pressure, thegrowing grassroots movement calling for sociallyresponsible investment is making a difference. TheCOVID-19 pandemic has further reinforced the demandfor responsible investors to outline the life and healthimpacts of their operations.2. The UK’s nuclear weapons programmeThe Government is in the process of replacing thesubmarine carrying its nuclear weapons. The currentVanguard Class submarines will be replaced by theDreadnought Class, due to enter into service in the early2030s. This is part of a wider modernisation programme,which will also include new warheads. The estimatedcost, including in-service running costs, amounts to 205billion over the lifetime of the new submarines.7 The delivery of new submarines is being overseen bythe Submarine Delivery Agency. BAE Systems, RollsRoyce and Babcock International have been designatedTier One industrial partners. BAE Systems estimates that 85% of the Dreadnoughtsupply chain will be based in the UK, involving around850 companies.8 Many will be providing standardservices or dual-use equipment and, from aninvestment perspective, need to be treated differentlyto Tier One industrial partners. The Atomic Weapons Establishment (AWE) isresponsible for the design, manufacture andmaintenance of the warheads for Trident. The AWE site at Aldermaston is owned by the Ministryof Defence but is overseen by AWE, a consortiummade up of US companies Lockheed Martin and JacobsEngineering, as well as the UK-based Serco Group.3. A new humanitarian and legaldevelopment: The 2017 UN Treaty onthe Prohibition of Nuclear WeaponsThe Government maintains its nuclear programmedespite evidence that the use of nuclear weapons –whether accidental or deliberate – would havecatastrophic humanitarian and environmentalconsequences. In 2017, the majority of nationsnegotiated and agreed the UN Treaty on the Prohibitionof Nuclear Weapons (TPNW) in order to outlaw nuclearweapons. Once ratified by 50 countries, the TPNW willenter into force as an international treaty, and thusbecome legally binding on its state parties.9The TPNW: prohibits nations from developing, transferring,testing, possessing, and using nuclear weapons provides a framework and pathways for nuclear-armedstates to undertake stockpile destruction andelimination obliges signatories to provide medical, psychologicaland socio-economic assistance to individuals affectedby nuclear weapon testing and use, and to take stepsto help remediate damaged environments10 allows nuclear weapon states to join so long as theyagree to destroy their weapons in accordance with alegally binding plan, and host nations so long as theyagree to remove nuclear weapons from their territoriesby an agreed deadline.11The UK Government has refused to join the TPNW butthere are moves within Parliament to engage withdiplomatic efforts towards disarmament. The House ofLords International Relations Committee recentlyrecommended that the government should take theconcerns of the TPNW’s supporters seriously, adopt a “lessaggressive tone”, and seek opportunities to work with3

parties to the TPNW towards disarmament.12 It alsoencourages the Government to consider more closely thehumanitarian impact of nuclear weapons, the approachthat underpins the TPNW.nuclear weapons (also referred to as ‘verticalproliferation’) is inconsistent with the intention of theNPT as this usually amounts to an increase in thecapabilities of nuclear-armed states.The global ban will have major implications on the abilityof financial institutions to continue investing in nuclearweapon-producing companies.13 The TPNW containslanguage regarding ‘assistance’ similar to that containedin the Convention on Cluster Munitions, which manycountries have interpreted as prohibiting acts that coverfinancing, and includes the conduct of individuals andcompanies. This will have legal implications forinvestments in nuclear weapon producers in countriesthat join the TPNW. Companies with a global profile,many of whom do not discriminate by jurisdiction butrather have blanket policies, are likely to face pressure tochange their investment activities in all countries,including the United Kingdom.With the advent of the TPNW there is a growingrecognition that nuclear weapons ought to be defined as‘controversial’, and should therefore be barred from anyinvestment activity in a manner comparable with clustermunitions and landmines. This is demonstrated by recentdevelopments in industry reporting standards such as UNPRI and FTSE4Good.4. Controversial weapons:What weapons are included and howdoes the finance industry viewnuclear weapons?Controversial weaponsCertain weapons are described within the financeindustry as ‘controversial’, either because they are illegal –their production and use is prohibited by internationaltreaty law – or because they are inherently indiscriminatein their effect. International humanitarian law requiresthat parties to a conflict distinguish between combatantsand civilians.Controversial weapons may include anti-personnel mines,cluster munitions, and weapons of mass destruction suchas nuclear weapons, biological weapons and chemicalweapons. Financial institutions may typically permitlimited investment in defence activities while entirelyexcluding investment activity in controversial weapons.However, as we have seen above, there is substantialcorporate finance in nuclear weapons. A report fromShareAction states that only one of nine pensionproviders surveyed exclude the financing of nuclearweapons producing companies as they would otherforms of controversial weapons.14Many financial institutions (particularly those based innuclear weapons states) are unaware that the NuclearNon-Proliferation Treaty (NPT) places restrictions onnuclear-armed states. For example, modernisation of4UN Global Compact and the UN Principles forResponsible InvestmentThe UN Principles for Responsible Investment (PRI) were, inpart, derived from the UN Global Compact, which askscompanies to take UN treaties into account whenimplementing environmental, social and governance (ESG)policies in business. The UN PRI expects participatinginvestment institutions to develop and report on their ESGpolicies, including those concerned with controversialweapons. The PRI initiative does not take a prescriptiveapproach to a definition of ‘controversial weapons’ or theinclusion of nuclear weapons in this category. The hopemust be that once the TPNW enters into force andbecomes a part of international treaty law, the UN PRImight urge financial institutions to report on new policieswith respect to nuclear weapons.The reports of financial institutions to the UN PRI areavailable online and they usefully contribute to thetransparency of policy and practice. Those participatingwith the UN PRI can be asked by their customers ormembers to report their policies with respect to nuclearweapons. Some financial institutions already referencetheir policy on investment in nuclear weapons’production and stockpiling when reporting oncontroversial weapons in UN PRI returns.FTSE4GoodFTSE4Good is a tool for investors interested in how theproducts of a company impact society. The FTSE4Goodselection criteria are developed in consultation withindustry, overseen by an independent expert committee.FTSE4Good has included nuclear weapons among the listof ‘controversial weapons’ for many years. The criteriadetermining material involvement in nuclear weaponshave been a subject of ongoing discussion withinFTSE4Good. The criteria exclude companies involved inmanufacturing “specific and critical parts or services for

BANKS, PENSIONS AND NUCLEAR WEAPONS: INVESTING IN CHANGEnuclear weapons systems”. Where suitable informationcan be obtained, this includes companies that providedelivery platforms (submarines such as the newDreadnought class, for example) that are a part of anuclear weapons programme.15The 2019 investor initiative on controversialweapons and the major stock market indexesIn 2019 an international coalition of investors, led bySwiss Sustainable Finance, has called for producers ofcontroversial weapons to be excluded from themainstream market indexes such as the FTSE 100, S&P500 or Nikkei 225. This would prevent passivelymanaged investments (investment funds that determinecompany holdings by tracking a stock-market index suchas the FTSE 100) from inadvertently investing in somenuclear weapons. While the call applies only to nuclearweapons in states that are not party to the Nuclear NonProliferation Treaty, it nevertheless raises awareness of theneed for the investment industry to protect investorsfrom exposure to controversial weapons.In summary, we can see a growing recognition thatnuclear weapons must be included under the category of‘controversial weapons’ and excluded from mainstreaminvestment. The dialogue with financial institutionsundertaken for this survey reveals that knowledge of thisarea within the industry is still patchy. It comes as nosurprise that most respondents in this survey return lowscores with respect to their current policy and practice.Encouragingly, several responses state their willingness tolisten to their members on this subject, or their opennessto a review of their policies. Customers of UK banks andpensions funds have an opportunity to challengeinvestment in nuclear weapons at this pivotal time.5. What the survey revealsMethodology: Our approach to an assessmentof policy, practice and transparencyBanks and pension providers have quite distinct roles andfinancial activities. Banks tend to concentrate on businessbanking services, providing companies with strategicloans and underwriting or purchasing company bonds.Banking executives point out that the confidentiality ofthe banker-client relationship places limitations ontransparency. Nevertheless, in our view it is feasible for abank to publish detailed policies and to explain in generalterms how policy enters into a bank’s dialogue withclients. In contrast, pension providers, in common withother investment management firms, concentrate on thepurchase of shares, bonds or other financial instrumentsand should be accountable to their pension members onwhere funds are invested and their dialogue withcompanies in which they invest.This survey uses a broadly similar set of metrics to assessboth banks and pensions providers, while also taking intoaccount the particular nature of the business activities ofeach. After sometimes lengthy engagement withrespondents, we have rated each financial institution in theareas of policy, practice and transparency, with a score outof ten in each area. A description of the methodologyemployed is available on the project websitewww.moneyoutofnukes.wordpress.com. For some, theissues around investment in nuclear weapons are rathernew and several in this survey achieve a low score out of apossible total of 30 (see appendix on pages 7-8). Everyeffort has been made to objectively assess each financialinstitution and to check findings with participants, and wewelcome further discussion, clarification and engagement.Financing nuclear weapons:The state of play Among pension providers, a policy on restrictinginvestment in nuclear weapons is frequently limited toethical funds only, including Legal and General, Nest,Quilter, Royal London and Standard Life Aberdeen.These funds typically cover only a small proportion ofthe firm’s investments. While limited in overall value,this does mean that the pension provider will have hadto think through how to define nuclear weapons andrelated activities, and how to go about screeningcompanies to ensure compliance with its policy. Standard Chartered and HSBC both have policiesrelating to ‘direct financing’ of nuclear weapons. Thepolicies only prohibit loans and bond activities at thelevel of a nuclear weapons project or subsidiarycompany. As nuclear weapons producers will typicallyseek loans at the group level and then re-distributethat finance across the group, a policy that is limited todirect financing only lacks authentic impact. Some financial institutions will not invest in or provideloans or banking services to companies for whom apercentage of their business is in armaments ordefence. For HSBC and Standard Chartered thisrequires the exclusion of some of the major nuclearweapons producers that are identified in the Paxreport ‘Producing Mass Destruction: Private companiesand the nuclear weapon industry’. But other nuclearweapons producers are diversified engineering andtechnology companies with nuclear weapons as asideline. Nuclear weapons, given their devastating and5

indiscriminate effects, should be treated differently torifles, artillery or other conventional weapons. As is thecase with cluster munitions and landmines, anymaterial involvement by a company in nuclearweapons ought to require a bar to investment in thatcompany. Some respondents, including Lloyds, RBS, RoyalLondon and Standard Life Aberdeen, have a highlygeneralised description of a ‘nuclear weapon’, whichmight therefore mean their concerns are withwarheads and missiles only. We are looking for therespondents to have thought through how to avoidinvesting in critical components of nuclear weaponsinfrastructure, including command and control centres,fissile material stocks, and research centres dedicatedto nuclear weapons. We are also seeking exclusionsrelating to the construction of submarines that arededicated to the task of carrying and potentiallylaunching nuclear weapons. Finally, on transparency, financial institutions in thesurvey are scored on the basis of information that theymake available to the public (usually through corporatewebsites). Pension providers have a particularresponsibility to be transparent to their members. Thesurvey gives additional credit to those such as NESTand People’s Pension who have committed to consultwith their members on this issue.The best performing UK financial institution inthe survey: The Co-operative BankThe Co-operative Bank states that it will not do businesswith companies that are in any way involved in nuclearweapons. It is the only financial institution in our surveyto apply this principle across all of their business activities.The bank thankfully has not waited for internationaltreaty law to provide guidance. Instead it has for manyyears recognised that nuclear weapons are intrinsicallyindiscriminate and are therefore incompatible withinternational humanitarian law.16The worst performer: Janus HendersonInvestorsThe London-based global investment firm JanusHenderson provides investment services for institutionaland private investors. According to the data gathered bythe PAX/ICAN 'Don't Bank on the Bomb’ project, JanusHenderson invests more in nuclear weapons-producingcompanies than any other financial institution in thissurvey, primarily through investment in shares. In itscontact with this project, Janus Henderson did notregister any interest in reviewing its policy or practice.66. Actions for bank customers andpension scheme membersAmong the UK public there is a growing desire toknow where their money is invested. A surveyconducted for Good Money Week 2019 revealed thatwhile only one in eight people have asked where theirpension is invested, almost half of those surveyed saythat they want their pension to marry up with theirvalues.17 Transparency in investments is clearlyimportant; many pension members will be surprised tolearn that their contributions are being invested incompanies that are producing nuclear weapons.The data and analysis in this report gives bankcustomers and pension scheme members a tool theycan use to engage with financial institutions in whichtheir money is invested. Customers can use the reportto seek to influence future investment practice. Forexample, letters and emails can be written drawingattention to contrasts in policy, practice andtransparency between institutions. Questions can beasked regarding the institution’s plans to review policy,change practice or improve transparency. Like-mindedcustomers could apply pressure together.The COVID-19 pandemic has demonstrated the need forinvestment in health infrastructure and for cooperationacross national boundaries in this respect. Investments innuclear weapons that threaten mass destruction runcounter to the humanitarian principles that are critical toaddressing common threats. Such principles are not thepreserve of governments but belong to all of us.Companies subscribing to the UN Global Compact alsoendorse them.Most of the banks and pension providers surveyed herehave said that they value customer engagement aroundthe Social Environmental and Governance aspects of theirwork. There appears to be significant potential forcustomers to effect change in nuclear weaponsinvestment at this time. This report intends to help UKcitizens to demand that their money is not invested inindiscriminate and devastating nuclear weapons or in theindustry that has built up around them. The projectwebsite provides further guidance on corresponding withbanks and pension funds. Our hope is that supporters ofthis project will exercise their voices on this issue and thatthis will lead to a substantial change in practice across theinvestment community in the UK. "

BANKS, PENSIONS AND NUCLEAR WEAPONS: INVESTING IN CHANGECompanyPolicyPracticeTransparencyThe Co-operative Bank885The Co-operative Bank is the onlyfinancial institution in this survey toprohibit business with a nuclearweapons producing company. Itsbanking and investment services will beattractive to those wanting to ensurethat their investments cannot contributeto nuclear weapons production.HSBC425HSBC has an exclusion policy on projectloans, and avoids financial involvementwhere armaments are above 33%threshold of business. Beyond this, thereis no specific policy to treat nuclearweapons differently from otherweapons. HSBC provided the projectwith an opportunity for a constructivemeeting.Royal Bank of Scotland244RBS has engaged with campaigners andhas a policy that excludes financing ofnuclear weapons in countries outsideNATO. It applies some restrictions in thecases of the UK, US and France.Standard Chartered406Standard Chartered avoids ‘directinvestment’ in ‘prohibited activities’,including nuclear weapons. It also avoidscompanies with 20% defence exposure;yet it has invested in loans and bonds tocompanies heavily involved in defenceequipment (and in nuclear weapons)such as Boeing for example.Lloyds Bank212Lloyds has a very brief statement onthe Defence sector, which is availableon its website. The statement doesnot extend to components and sites.They exclude doing business withnuclear weapons producers except forprogrammes in the US, UK andFrance (where the vast majority of thenuclear weapons business is located).Barclays202Barclays implements and reports to theUN PRI. Their policy is “not to financemanufacture of nuclear weapons” butis unspecific as to what this means. It isthe second-most significantly-exposedcompany to nuclear weapons producingcompanies. It has not suggested that itwould review policy in light of theTPNW.BANKS7

CompanyPolicyPracticeTransparencyPension or investment fundsLegal and General432Legal and General has an Ethical Trust ISA policyexcluding nuclear weapons, but there has beenlimited engagement with this project andresponses suggested some lack of awareness ofthis issue.Quilter324Quilter has an ethical policy and refers to the UNPRI, but does not confirm that the entry into forceof the TPNW would be sufficient to require ablanket exclusion policy on nuclear weapons.People’s Pension204People’s Pension has committed to raising nuclearweapons as a potential issue with members infuture correspondence, but holds investments in anumber of companies that have a materialinvolvement in nuclear weapons projects.Royal London222Responses lacked clarity regarding policy andpractice. Royal London has a policy that appears torelate solely to their ethical fund. The defaultpension fund has no exclusion policy either fornuclear weapons or more broadly for defence. Thisbroadly invested fund will have exposure to nuclearweapons producersStandard LifeAberdeen112Nuclear weapons are not covered under a policy togovern a global investment approach. StandardLife Aberdeen has an ethical policy, but does notexclude components, nuclear weapons platformsor management of sites that stockpile fissilematerial or house missiles/warheads.NEST103NEST offers an ethical fund that has a policy onnuclear weapons. It has promised to ‘look todevelop’ a position on nuclear weapons for thedefault fund, especially if members’ sentimentrequired this.Aviva220Aviva have scored low on transparency becausetheir website and reports do not adequatelydescribe their position on controversial weapons.Nuclear weapons are referred to only withreference to their ethical funds.Childrens’ Investment 0Fund30Childrens’ Investment Fund has no discernablepolicy on nuclear weapons. Interestingly, itpreviously had investments in nuclear weaponsproducing companies, but has since disinvested.Janus HendersonGroup01Janus Henderson Group has a general policy onweapons, but only applied to an ethical fund.The company states that it does not have aspecific policy on nuclear weapons. It has alarger investment in nuclear weapons producingcompanies than any other investor in the survey.81

BANKS, PENSIONS AND NUCLEAR WEAPONS: INVESTING IN CHANGEEndnotes1234567891011121314151617Susi Snyder, ‘Shorting our security: Financing the companies that make nuclear weapons’ (PAX, 2019). Available 19/06/2019 HOS web.pdf (accessed October control(accessed October /uploads/2019/06/2019 HOS web.pdf (accessed October try (accessed October2019).See Maaike Beenes and Susi Snyder, ‘Don’t Bank on the Bomb: A Global Report of the Financing of NuclearWeapons Producers’ (PAX and ICAN, 2019). Available at 0/2018 Report web.pdf. The Government of Norway itself has not yet joined the treaty.Susi Snyder, ‘Happy Birthday TPNW - time for divestment!’ (Pax, 2018). Available ve-some-divestment/ (accessed October -trident/ (accessed October k/documents/CBP-8010/CBP-8010.pdf (accessed October 2019).For the latest status of the TPNW, see United Nations Office for Disarmament Affairs Disarmament TreatiesDatabase, ‘Treaty on the Prohibition of Nuclear Weapons: Status of the Treaty’, available at:http://disarmament.un.org/treaties/t/tpnw (accessed October 2019).For the full text of the TPNW, see United Nations Office for Disarmament Affairs Dis

1. The scale of private sector involvement in nuclear weapons Whilst significant progress is being made in the United Nations to prohibit nuclear weapons, private sector investment in the industry has increased significantly.2 The 2019 'ICAN/PAX report 'Shorting our Security' revealed that the private sector is investing 748 billion

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