4 – Corporate governance and ethics

4.1 Corporate governance

NBIM invests in equities in more than 3 500 companies. Corporate governance reflects how we exercise our ownership rights in these companies and hence influence the companies and markets in which NBIM invests.

According to the ethical guidelines for the Government Pension Fund – Global, as laid down by the Ministry of Finance, the overriding objective of NBIM's exercise of ownership rights is to protect its financial assets. Corporate governance is based on a long investment horizon and a broadly diversified portfolio in the markets included in the investment universe. It should primarily be based on the UN's Global Compact and the OECD's principles of corporate governance and guidelines for multinational companies. The guidelines issued by the Ministry of Finance stipulate that NBIM's internal guidelines for the exercise of ownership rights should reflect how the principles in the documents mentioned are integrated into corporate governance. Norges Bank has provided for this in "Principles for Corporate Governance and the Protection of Financial Assets", which was adopted by Norges Bank's Executive Board in December 2004. Norges Bank's Executive Board has approved the application of the same principles to the Bank's foreign exchange reserves.

The principles stipulate that the companies in NBIM's portfolio shall act in accordance with the internationally recognised principles mentioned above. A number of criteria apply to the companies regarding their objectives, strategy and transparency. Moreover, criteria have been formulated as to companies' management and structure, as well as long-term sustainability in that companies must take account of the impact of their activities on the environment and the wider society. The principles also include a discussion of instruments of corporate governance and NBIM's reporting on its corporate governance activities. Norges Bank's Executive Board has defined its priority areas of corporate governance in its Strategic Plan for NBIM (cf. Section 5.1). In a separate feature article, the priority areas of corporate governance for the coming years are discussed in further detail. Another feature article sheds light on how and why voting is an important instrument for securing sound management of financial assets.

4.1.1 Activities 2006

Since 2003, NBIM has been gradually building up capacity and competence in corporate governance. Previously, external managers exercised voting rights for the assets under their management on behalf of NBIM. As from 1 January 2005, all voting in the equity portfolio was transferred to NBIM in order to achieve more concise and consistent voting in accordance with NBIM's principles. In 2003 and 2004, NBIM voted in a limited number of companies in the internally managed portfolios, but as from 2005 NBIM has covered most of the companies in the portfolio, and has focused more attention and resources on controversial issues, i.e. complex issues that require deeper analysis. Internal systems and databases containing information on matters to be discussed at companies' general meetings have been developed.

NBIM established a separate corporate governance group in the latter half of 2005, and the governance activities have since been intensified. Over the year, NBIM has been engaged in a wide range of matters, particularly in connection with voting. In addition, analysis and research have been conducted to select priority areas that NBIM considers particularly important to ensure long-term returns and sustainability. The importance of establishing cooperation with other investors with mutual interests and prospective mutual benefits is reflected in the work NBIM has invested in building up networks and cooperation with other international pension funds.

In 2006, the group was able to draw on resources equivalent to 6 person-years. The group should comprise around ten employees by the end of 2007, with a budget of NOK 10 million allocated for execution of proxy voting, the development and purchase of IT systems, external analysis, and communications and external consultancy services related to specific areas.

Strategic plan for corporate governance

In its corporate governance strategy, NBIM has chosen to focus on six priority areas, related to both ownership rights and social and environmental sustainability. Key criteria for the selection of these areas included: the importance for long-term returns, the probability of an investor like NBIM being able to bring about actual changes, the possibility of identifying relevant companies, industries and jurisdictions, and the potential for cooperation with other investors that would increase the likelihood of success.

The priority areas are discussed in more detail in a separate feature article ("Priority areas for the exercise of ownership rights: corporate governance, children and the environment") and include four areas generally related to ownership rights:

• the right to vote
• the right to nominate and elect board members
• the right to trade shares freely
• the right to open, timely information

These are central rights that are necessary to achieve real influence and dialogue with companies. They are also a necessary basis for working on social and environmental issues. At the same time, these rights are to a varying degree restricted or are poorly developed in a number of markets, including in Europe and the US.

Priority will also be given to the following two areas for future social and environmental sustainability:

• Children's rights within the value chains of multinational companies, particularly related to limiting child labour and measures to protect children's health;
• Companies' response to national and supranational authorities on issues related to long-term environmental change – including the risk of a pronounced climate change, the destruction of ecosystems and biodiversity, the extensive and long-term depletion of water resources and declining access to clean water.

Both of these topics harmonise well with NBIM's long-term perspective as investor and are dealt with in the inter-national standards mentioned earlier on which NBIM's principles of corporate governance are based.

Communicating NBIM's principles of corporate governance

In 2006 NBIM continued to work on communicating NBIM's principles for corporate governance, among portfolio companies as well as other investors. The most important forms of written communication, apart from direct contact with companies, were the Annual Report for 2005 and its feature articles, articles published in periodicals, newspaper articles, lectures, and papers presented at seminars and conferences. NBIM staff members have given lectures and participated on a number of panels for leading investors and active corporate governance practitioners at international conferences. NBIM's corporate governance activities have also been featured in the international press.

NBIMs principles of corporate governance are available on NBIM's website and in a paper edition. These principles will be revised and updated in 2007.

It is also important to NBIM to communicate with interested communities in Norway on the subject of corporate governance and its underlying principles. NBIM therefore contributed with a number of public lectures in 2006 about NBIM's activities and strategy for corporate governance and ethics.

Voting and contact with portfolio companies

Voting at companies' general meetings is an important instrument of corporate governance and provides a platform for all further contact with the company. Voting is conducted in accordance with the corporate governance guidelines. This ensures concise, focused and global voting. In 2006, NBIM covered most of the companies in the portfolio, and focused more attention and resources on controversial issues, i.e. complex issues that require deeper analysis. Voting in 2006 is presented in more detail below.

Voting is by proxy, i.e. via a representative who attends the general meeting and is authorised to vote on behalf of NBIM. The majority of institutional investors make use of proxy voting, particularly when voting is conducted across national borders. Between 30 and 80 per cent of shares in listed companies in European countries are owned by non-nationals, but national legislation on general meetings and voting has not been adjusted accordingly. There are no common standards to regulate voting practices. Requirements may vary even within one and the same market. In many countries, voting rules that historically may have been well founded, have not been adapted to proxy voting.

Voting across national borders can therefore be resource-intensive, costly and in many cases difficult to conduct. As part of the process to operationalise the strategy area The right to vote at general meetings, NBIM started a comprehensive project in 2006 to identify participants, market practices and regulations relevant for voting in the Fund's most important markets with the aim of promoting effective global voting. This project is an important basis for NBIM's work to simplify cross-border voting and limit the use of resources.

Through its corporate governance activities, NBIM seeks to ensure that shareholder interests are sufficiently protected by a company's governing bodies. In its contact with a company, NBIM will therefore mainly communicate with the company's board of directors, primarily the chairman. As an owner, NBIM always seeks to act in a well-prepared and predictable manner. This is important to ensure that NBIM's portfolio companies and other investors have confidence in its corporate governance activities. Contact with companies is in principle always confidential. However, NBIM seeks to be as transparent as possible about the areas and the type of issues that are in focus, and the principles underlying its activities.

In 2006, NBIM also included direct contact with companies in its corporate governance activities, in addition to voting, network-building, maintaining contact with the authorities and working on (and publishing) its main principles. In this context, considerable weight was given to basic company and sector analyses and engagement activities which will be fully implemented in 2007, particularly related to our priority areas. We also approached companies directly in 2006. In a number of matters where NBIM chose to withold its support for the board in the voting at a general meeting, NBIM contacted the company to explain NBIM's views, and in some cases to request further communication on the issues. Contact with these companies was related to matters involving both ownership rights issues and social and environmental issues. In 2006, NBIM approached 11 companies as part of its work related to the priority areas and as a follow-up of voting.

Active contact between owner and company will occur over time and take many forms. Exactly how this will take place will depend on the matter at hand, developments that have occurred, how the company responds and not least to what extent other owners or interest groups also become involved.

In some controversial matters related to issues of control, for example where a large shareholder wishes to replace some members of the board because it is felt that the board's strategy is not in the best interest of the company, NBIM has communicated with the various stakeholders prior to the vote in order to establish a more solid basis for the final vote. In several cases where NBIM supported a shareholder's proposal that won the majority vote but where the board was not obliged to implement the proposal and in fact did not do so, NBIM subsequently contacted the company to follow up the matter.

NBIM contacted some companies that had included matters related to human rights on their agenda at the general meeting in 2006, in particular those focusing on working conditions for subcontractors. NBIM encouraged one company, for example, to publish its guidelines for foreign suppliers. In other cases, NBIM requested the companies to provide more information on how they would follow up and report to the shareholders on measures related to labour rights and human rights in connection with the company's activities abroad.

NBIM also contacted a group of companies in the energy sector which conduct activities in areas where there was a risk of serious human rights violations as a direct result of these activities. As well as expressing its views, NBIM requested the company to provide concrete answers as to the consequences of the company's activities for the local population in the relevant areas, and whether the companies themselves had instigated measures to prevent human rights violations.

With another group of investors, NBIM contacted the board members of a large European energy company in connection with a proposed merger. The group of investors expressed concern that the exchange ratio for the shares did not reflect the company's real value and that the largest shareholder in the merged company would have full control without paying the minority shareholders a control premium.

In a number of cases, the contact established, as in the examples above, will be followed up in 2007 with a view to initiating further processes. NBIM will also approach a number of other companies in connection with the preparations for portfolio companies' general meetings in spring 2007.

Contact with regulatory authorities

In 2006, NBIM provided input to consultative rounds etc to help ensure that government agencies, stock exchanges and other regulatory authorities develop and monitor regulations that enhance the protection of ownership rights in accordance with NBIM's principles. NBIM participated in the round of consultation conducted by the IASB (International Accounting Standards Board), which formulates international accounting standards, about which information that is important to the company's position, beyond the purely financial, should be included in the CEO's report in annual reports.

NBIM has also been in contact, by letter and dialogue, with the US Securities and Exchange Commission (SEC) in connection with proposed changes to executive pay disclosure rules for US companies, and in connection with the ongoing discussion about the possibilities open to shareholders to elect and replace board members in US companies. As part of the priority area The right to nominate and elect board members, NBIM participated in the debate on the interpretation of the SEC's role in the approval of shareholder proposals submitted to US companies' general meetings. In this connection, meetings with the chairman and commissioners of the SEC were prepared in the last quarter of 2006 and held in Washington in January 2007.

Contact and collaboration with other investors

Owner activity to influence companies and market standards is resource-intensive. The costs will be borne by the investors conducting the activities while the results achieved will benefit all the shareholders. Owners will be able to strengthen their influence by coordinating their activities. NBIM therefore recognises the strategic importance of participating in informal and more formalised networks.

Broad global and regional networks are platforms for establishing contact, exchanging views, spreading information and formulating representative views vis-a-vis regulatory authorities and other standard-setters in the markets.

NBIM is a member of the International Corporate Governance Network (ICGN), a world-wide network for investors and suppliers of services in the field of ownership rights and corporate governance. ICGN members are estimated to manage assets exceeding USD 10 000 million. The network arranges global and regional meetings to discuss central topics related to owner participation and corporate governance and organises the work of various expert committees. ICGN engages with national and supranational authorities, accounting standard-setters and other leading market participants.

In 2006, NBIM took part in the Council of Institutional Investors (CII), a forum for the promotion of corporate governance comprised of institutional shareowners in the US. In addition to facilitating dialogue with authorities and other standard setters, the network seeks to improve market practices by various means, one of which is to draw up a list of companies whose governance systems and practices are regarded as unsatisfactory.

NBIM is engaged in informal network-building among larger, globally diversified investors. These networks are considered useful for handling ad-hoc matters, particularly in relation to individual companies, and for improving investor coordination in the longer term.

In autumn 2006, NBIM collaborated with the large Dutch pension funds ABP and PGGM and British Hermes on a joint statement to the SEC concerning the opportunities available to investors to influence the election and replacement of board members in US companies (see above).

NBIM took part in the formulation of the UN "Principles for Responsible Investment" (PRI) in 2005-2006 and when the principles were launched in April 2006. The Principles are based on the understanding that the environment, social conditions and corporate governance can influence funds' returns. Traditionally, investors and managers have focused little attention on these factors. In signing the six principles, investors undertake to analyse these factors, collaborate in their implementation, be active owners, require adequate reporting from companies and report on their own activities. NBIM presented and discussed the principles at meetings with large institutional investors in Japan in October, and at a UN conference in Africa in November.

The international initiative EITI ("Extractive Industries Transparency Initiative") aims to combat corruption and increase transparency in countries rich in natural resources. NBIM has endorsed the section of the EITI entitled "Investors' Statement on Transparency in the Extractives Sector". According to the initiative, it is in the interest of the portfolio companies themselves to operate in a business environment characterised by stability, transparency and respect for the law. The investors therefore support principles regarding disclosure by private and public stakeholders of all payments and agreements related to the extraction of raw materials and natural resources. On the basis of this initiative, NBIM requires transparency from the companies in extractive industries in which it invests, particularly those operating in countries with poor regulatory frameworks and widespread corruption.

4.1.2 Voting in 2006

NBIM's voting guidelines are based on the Principles of Corporate Governance. The fundamental objective is to protect the long-term financial interests of the portfolio. In accordance with the Principles of Corporate Governance, NBIM has supported issues that promote the following:

• that the company has a clearly defined business strategy that is endorsed by the board of directors
• that the company must present accurate, adequate and timely information concerning its financial position and other relevant information
• that internal management and control systems adapted to activities have been established
• that the company's board of directors protects the interests of all shareholders
• that the board of directors consists of a sufficient number of members with relevant and adequate qualifications and that more than the majority of its members are independent
• that the board of directors shall be accountable for its decisions
• that the company openly reports its policy and actions related to human rights and the company's impact on the environment and the local community

A closer account of NBIM's voting in 2006 is presented below and shows how voting was distributed by main types of issue. Issues where NBIM supported shareholder proposals and opposed the management's own recommendations are described in particular detail. NBIM has started work to promote even greater detail in reporting. Such publication will take place as from 2007, in connection with the annual reporting on corporate governance.

Number of meetings

An overview of the number of meetings where NBIM exercised its voting rights is presented in Table 4-1:

Table 4-1: Voting in 2006 / Number of meetings

I 2006, NBIM voted at 2 928 general meetings, or 79 per cent of the meetings held. NBIM's voting percentage was lower in European markets than in the other regions. This is primarily due to the practice of share-blocking, which prevents investors from selling shares in the period between voting and the general meeting. Share-blocking restricts portfolio managers' ability to trade shares, and NBIM therefore only votes in special cases at general meetings of companies that practise share blocking. An increasing number of markets and companies are moving away from the practice of blocking shares, and NBIM therefore expects to vote at more meetings in this region in the future.

As shown in Chart 4-1, 26 per cent of the meetings where NBIM has voted have been in companies in the US, 17 per cent in European companies and 22 per cent in Japanese companies.

Chart 4-1: Voting in 2006/Regional distribution 2006

Number of items

In the close to 3 000 general meetings NBIM voted on 26 826 agenda items. For each proposal, shareholders can vote for, vote against or abstain. Shareholders must vote on all items on the agenda. Proposals are generally submitted by the management, but shareholders can also submit proposals. Close to 3 per cent of the proposals NBIM voted on were shareholder proposals. Shareholder proposals are very common in the US, relatively common in Japan but more unusual in Europe. NBIM voted against 8 per cent of management proposals and for 52 per cent of shareholder proposals.

The various issues to be voted on at the general meetings may be divided into seven categories as shown in Chart 4-2.

Chart 4-2: Voting 2006/voting issues

Close to 55 per cent of the proposals were in the category Director related, including those concerning the election of board members and other proposals related to the board's structure. 20 per cent of proposals were more routine matters and are categorised under Routine/business. The category Routine/business includes proposals related to changes in the articles of association, approval of the accounts, the annual report and dividends, as well as approval of auditors and their fees. 10 per cent of proposals were related to bonuses and pay schemes in the form of equity instruments, and these are categorised under Non-salary compensation. 8 per cent of the proposals were included in Capitaliation, while 4 per cent were categorised under Reorganisation, which includes proposals for general meeting approval of acquisitions and mergers. 3 per cent were shareholder proposals and, finally, less than 1 per cent were included in the category Anti-takeover mechanisms, which are matters related to different mechanisms that may be employed to resist a takeover bid.

Table 4-2: Voting 2006 / Against management's recommendation

Voting against management proposals

NBIM voted against the management in 2 164 matters. NBIM supported 92 per cent of management proposals, which is natural since in most cases NBIM has confidence in the way the company is being managed. More than half of the cases where NBIM voted against the management were companies in the Asia/Oceania region, a third in the Americas region and about a tenth were companies in Europe. More than 40 per cent of the cases where NBIM voted against management proposals were in the Director related category, while a quarter were related to pay.

Table 4-2 shows to what extent NBIM voted against the management by region and category of proposal. In the Americas, NBIM voted against 8 per cent of management proposals, in Europe the figure was 4 per cent and in Asia/Oceania 10 per cent. In the Americas, NBIM voted against the management on 5-15 per cent of in all the categories. In Europe, NBIM's opposition to management was greatest in matters related to remuneration. In Asia/Oceania, NBIM did not support management proposals in more than 60 per cent of matters related to anti-takeover mechanisms, and voted against the management in close to a third of matters related to remuneration, capital structure and acquisitions.

NBIM voted against management proposals in the following categories:

Routine/business

NBIM voted against the management's recommendation in 4 per cent of matters of a more routine nature. NBIM voted against the proposed auditor due to strong conflicts of interest and a lack of independence; this particularly applied to Japan. NBIM did not support the approval of an annual report due to lack of information and because the proposed dividend was considered too low in light of the company's strong results over several years. In many cases, NBIM did not support proposed changes in company articles of association due to a lack of information and because the changes would transfer more authority to the board as some decisions would no longer be deliberated at the general meeting.

Director related matters

NBIM voted against the management's recommendation in 6 per cent of board-related matters. In a number of US and Asian companies, NBIM voted blank or against the board members proposed by the management because independent board members were not in the majority, or because board members that were not independent of the board were members of important board committees (nomination, executive remuneration and audit committees). In US companies, shareholders can either support the candidate proposed by the management or abstain. This means that a candidate may be elected on the strength of only one vote and that the shareholders have little real influence on the choice of board members.

NBIM abstained in the re-election of the chairman of the board in many US companies because this individual was also the company's CEO. NBIM abstained in the election of board members that had been members of board remuneration committees in companies where the CEO was awarded an enormous pay increase although the company's short-term and long-term performance had been poor. NBIM also abstained in the re-election of board members who had not participated sufficiently in the board's work without good reason. In some cases, NBIM abstained in the re-election of board members in US companies who had disregarded shareholder proposals that had been supported by a majority of the general meeting for several years in a row.

Non-salary compensation

NBIM voted against the management's recommendation in 22 per cent of proposals related to remuneration. NBIM voted against the approval of compensation schemes that were not performance-based, that permitted option repricing, that resulted in a relatively considerable dilution of existing shareholders' ownership interests and that involved over-generous pension schemes and pension bonuses for board members and auditors. NBIM also voted against a number of compensation schemes due to inadequate information.

Capitalisation

NBIM voted against the management's recommendation in 12 per cent of proposals related to capital structure, including proposals for new share issues that would significantly dilute existing shareholders' ownership interests, or where these shares would be priced considerably below the market price. At the general meetings of many Hong Kong companies, NBIM voted against share issues where the offer was made to a small group of shareholders at a very favourable price. NBIM also voted against share issues that would contribute to a further deviation from the principle of "one share – one vote". In Japanese companies, NBIM voted against proposals to pay dividends that were considered to be too low in relation to earnings and against share issues where shareholders did not receive adequate information.

Reorganisation

NBIM voted against the management's recommendation in 20 per cent of proposals related to reorganisation. NBIM voted against proposed mergers because the offer was considered financially unsatisfactory and the strategy proposed for the merged company was not considered viable, or because a better offer was available. In many Japanese companies, NBIM voted against proposed changes in articles of association that would transfer more authority to boards to decide on dividends and share buy-backs, decide whether the company should start up activities in new areas and a number of other changes that would provide greater scope for board discretion.

Anti-takeover mechanisms

NBIM voted against the management's recommendation in 32 per cent of proposals related to anti-takeover mechanisms. NBIM voted against proposals to give the board unrestricted authority to issue shares in the event of a takeover bid, so-called poison pills, which make it less attractive to buy a company. NBIM voted against proposals to change the articles of association so as to depart from annual elections of all board members, and proposals to increase the majority required to support a proposal to replace a board member for the decision to be approved. Proposed changes to articles of association that would increase boards' authority and thereby increase their potential power to resist mergers were not supported.

Chart 4-3: Voting 2006/Against the management in the different regions

Shareholder proposals

Shareholder proposals are not normally supported by the management, and a vote in favour of such a proposal is often a vote against the management. Shareholder proposals accounted for close to 3 per cent of the proposals that received NBIM's support in the vote. Shareholder proposals are most common in the US, are somewhat less frequent in Japan and even less so in Europe. At general meetings where NBIM voted, it supported 52 per cent of shareholder proposals. In 2005, NBIM supported 41 per cent of shareholder proposals.

Shareholder proposals have seen an increase in the US in recent years, and in particular proposals related to social and environmental issues. Most of the shareholder proposals submitted at companies in Europe and Asia have been related to board elections, although proposals related to social and environmental issues have also been filed.

Shareholder proposals constitute a heterogeneous group and are submitted both by large, influential pension funds and other institutional funds and by individuals who represent special interests and who own a small number of a company's shares. The proposals are primarily related to protecting shareholder rights, to board work and structure and to management remuneration, but proposals related to social and environmental issues are also submitted. The subjects of these proposals are often very relevant, but in many cases NBIM does not vote in favour because of the form of the proposal or because of the demands made on the company. The company's management may already have dealt with the subject in a more appropriate manner or the shareholders may not benefit from approving such proposals due to their form, seriousness, feasibility and financial consequences. This means that even though NBIM votes against some of the proposals, we are not necessarily against promoting the issues involved, and in many cases we will be able to promote such issues more effectively through other corporate governance activities.

NBIM voted in favour of shareholder proposals that demanded:

• equal voting rights for all shares
• that the CEO cannot be the chairman of the board
• that shareholders may propose board candidates under certain conditions
• that options must be expensed
• that the general meeting must approve any anti-takeover mechanisms and over generous pension schemes and bonuses
• that the granting of options and other remuneration in the form of equity instruments must be performance-based
• that board members must be elected by a majority vote
• that the majority of the board members must be independent
• annual re-election of all board members
• that a simple majority is sufficient for approval of all types of resolutions
• that reports on remuneration must be submitted to the general meeting in the form of a proposal to which shareholders are asked to give their support (advisory vote)
• that executive pay is disclosed in the annual report
• that the company must have guidelines specifying how bonuses and other forms of remuneration are to be dealt with in the event of changes in reported financial results (claw-backs)
• that companies draw up ethical guidelines related to human rights and report on their compliance with these guidelines, particularly for operations in countries where human rights have traditionally not been respected
• that companies report on sustainability and on the company's economic, social and environmental impact (triple-bottom-line accounting)
• that companies report on their guidelines for equal rights for all employees and on the steps taken by the company to safeguard equal treatment
• that companies in the petroleum sector report on the impact of their operations for the ecosystem in specific geographical areas
• that companies in the petroleum sector report on how they will prepare for and adapt to regulatory changes related to climate change, and the effect this might have on their competitive situation
• that companies disclose their support for political parties
• that companies publish or introduce guidelines based on internationally recognised standards concerning foreign suppliers working conditions, and that audits of these conditions are carried out and reports submitted.

A feature article included in this annual report provides further detail on why and in what way voting is an important instrument for ensuring sound Fund management. See also the box on shareholder influence.

4.2 Exclusion of companies

Norges Bank is responsible for corporate governance in accordance with the guidelines issued by the Ministry of Finance. Norges Bank's Executive Board has adopted principles of corporate governance. Norges Bank's corporate governance activities in 2006 are discussed in Section 4.1 and presented in more detail in two feature articles in this Report. The government has appointed an Advisory Council on Ethics, which will advise the Ministry of Finance on negative screening and company exclusions. The Ministry makes the final decision on the exclusion of companies and instructs Norges Bank accordingly.

Since 2002, 20 companies with a combined value in the portfolio of NOK 14.2 billion have been excluded. The excluded companies correspond to 1.8 per cent of the Pension Fund's benchmark portfolio for equities. Norges Bank has estimated the total transaction costs associated with exclusion to NOK 47.7 million. This is expected to be only a small portion of the potential financial losses resulting from exclusion. However, it is of little relevance to estimate potential return losses over periods of only a few years.

The Ministry of Finance decided in 2006 to exclude four companies from the Fund's investment universe. The decisions were based on recommendations from the Advisory Council on Ethics. The background for the exclusions is discussed in greater detail in press releases from the Ministry of Finance. The Council's recommendations are available on the Ministry of Finance's website. Table 4-3 provides an overview of the companies that have been excluded. The total value of the investments at the time the exclusion decision was made was NOK 3.2 billion.

Table 4-3: Companies that the Ministry of Finance has excluded from the investment universe