Responsible Investments Report 2025

Appendices

43

RI Initiatives

NAM is a member and signatory in several RI initiatives and forums.

Investor statements and letters

EU policy – Investor joint statement on the European Commission’s “Omnibus” legislation: Nordea Asset Management supported a joint investor statement coordinated by PRI, IIGCC and Eurosif regarding the European Commission’s proposed “Omnibus” package. The statement, signed by more than 160 investors representing €6.6 trillion in assets under management, highlighted concerns that the proposed legislative changes could weaken key elements of the EU’s sustainable finance framework, including the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD). Investors emphasised that maintaining a stable and ambitious regulatory framework is critical for investment certainty and for supporting the transition to a net-zero economy. IIGCC collective investor statement on the EU Methane Emissions Regulation: Nordea Asset Management joined 44 institutional investors representing more than €4.85 trillion in assets in calling on the European Commission, the European Parliament and EU Member States to maintain and swiftly implement the EU Methane Emissions Regulation as adopt- ed. The statement emphasised that regulatory certainty is essential for long-term investment planning and for enabling companies and investors to manage methane-related risks and emissions effectively.

CERES investor statement on methane regulation: We sup- ported a CERES-led investor statement calling for the imple- mentation of performance-based methane regulations and timely policy action to improve the reliability, transparency, and comparability of methane emissions data.

ICGN letter to the Governor of Texas on proxy advisory regulation: In June 2025, Nordea Asset Management sup- ported a letter coordinated by the International Corporate Governance Network (ICGN) to Texas Governor Greg Abbott regarding Senate Bill 2337 on proxy advisory services. The letter expressed concerns that the proposed legislation could interfere with investors’ ability to fulfil their fiduciary duties and exercise effective proxy voting. It also highlighted that imposing additional disclosure requirements on proxy advi- sors could increase costs for investors and potentially reduce market efficiency and the competitiveness of Texas-based companies. Proxy advisory services play an important role in supporting institutional investors in exercising their voting rights efficiently, while investors retain full control over their voting decisions and policies.

Investor initiatives

Children and the Digital Environment It is collaborative investor engagement focusing on Swedish investors and Swedish companies gaming, telecoms and social media and with support from UNICEF Sweden as the expert on child-related aspects. China Climate Engagement Initiative The China Climate Engagement Initiative (CCEI) aims to promote green, low-carbon and high-quality transition of companies in China, through facilitating institutional investors in leveraging active influence and engaging in broader and more sophisticated dialogues with industries. This initiative is supported by the PRI. Climate Action 100+ Nordea Asset Management is a signatory of the Climate Action 100+, a collaborative five-year global initiative led by investors to engage with the world’s largest corporate greenhouse gas emitters to improve governance on climate change, curb emissions and strengthen climate-related financial disclosures.

Access to Medicine Index Access to Medicine Index analyses the top 20 research-based pharmaceutical companies on how they make medicines, vaccines and diagnostics more accessible in low- and middle-income countries. It highlights best and innovative practices, and areas where progress has been made and where action is still required. Canada Climate Engagement (CEC) Climate Engagement Canada (CEC) is a collaborative engage- ment initiative targeting the country's heaviest emitters. It is co- ordinated by Canada's Responsible Investment Association, the Shareholder Association for Research and Education (Share) and Ceres. Nordea Asset Management joined CEC in 2023 as the first international supporter. Carbon Disclosure Project (CDP) Nordea is a signatory to the CDP, a project that aims to collect and share information on greenhouse gas emissions and climate change strategies. We are also represented on the CDP Water Advisory Council.

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