Oberbank distances itself from industries, companies and business practices that, in its view, could result in unacceptable impacts on the environment, social aspects and governance (ESG).
Financing and account business
The following exclusion criteria based on sustainability aspects are mandatory for new customer business as well as for new fields of business that existing customers may enter into, and they are not subject to any option for approval. In the event of a revision or update of this policy, an assessment of the existing portfolio shall be conducted to ensure continued compliance with the criteria for existing customers as well.
Asset management
In the asset management, the following exclusion criteria do not apply, but rather special Minimum Standards tailored specifically to asset management.
Non-trading portfolio
In case of new investments by Oberbank, the following exclusion criteria must be fully observed. Compliance with the exclusion criteria in the area of own investments is also laid down in Oberbank's investment policy.
Private individuals
Private individuals are not covered by the exclusion criteria, but some transactions by private and corporate customers – for example in the betting and gambling, adult entertainment and weapons sectors – require approval from the Management Board under money laundering law, unless their transactions are already excluded due to the exclusion criteria. In the Know Your Customer (KYC) process, private customers are therefore also subject to numerous checks.
1. Sector-specific exclusion criteria
Oberbank considers the following economic activities and industries to have an increased ESG risk potential and excludes them. The assessment primarily focuses on the company’s core business activities. If the relevant revenue share is only marginal, an exclusion may be waived (e.g. a tobacco shop that also offers magazines containing adult entertainment content).
|
Industry / Criterion
|
Exclusion of
|
|
Nuclear energy
|
-
Production and predominant distribution of nuclear energy
-
Construction of new and refurbishment of existing nuclear power plants
-
Mining and enrichment of uranium, plutonium, thorium and mixed oxides of plutonium and uranium
-
Handling or trading in radioactive waste or hazardous waste or receiving commissions from such trading
-
Radioactive materials, except for medical materials and quality control equipment, where the radioactive source is trivial and adequately shielded
|
|
Gems and conflict minerals
|
|
|
Fishing
|
- Companies that are active in the fishing industry or process or sell fishery products and do not compliy with nationally and internationally recognised standards (e.g. EU Species Protection Regulation, MARPOL Convention, Marine Stewardship Council, FAO Code of Conduct for Responsible Fisheries)
|
|
Trade in protected animals or export leather, as well as animal testing
|
-
Trade in endangered or specially protected animal species or in animal species covered by the Washington Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), or trade in parts of such animals.
-
Arranging hunts or the hunting of such animals
-
Activities with live animals carried out for research purposes (animal testing) to test end products in the area of consumer goods and other non-medical products (e.g. cosmetics, detergents) that involve the risk of causing harm and suffering to the animals involved and are not legally required according to the respective national legal system.
|
|
High volume fracking and extraction of oil sands
Crude oil
|
-
Companies whose business purpose is high-volume fracking
-
Extraction of oil sands
-
New purpose-bound business activities for new unconventional oil projects aimed at expanding the oil infrastructure (e.g. shale oil, oil sands, Arctic oil********, ultra-deepwater oil)
|
|
Coal
|
-
Extraction (mining) and production of coal
-
Energy generation from coal
-
Construction of new and refurbishment of existing coal-fired power plants
New business with companies whose primary business purpose is trading in coal
|
|
Heavy weapons
|
- Production of and trade in heavy weapons falling within the seven main categories of the United Nations Register of Conventional Arms (UNROCA), including battle tanks, large-calibre artillery systems, combat aircraft, and warships.
|
|
Embryo research
|
|
|
Pornography industry and comparable industries (“red light district”; adult entertainment)
|
-
Among other things, the following are excluded:
- the production of pornographic content of any format (e.g. films, magazines, etc.),
- the offering of sex tourism,
- the operation of brothels and
- the distribution of pornographic content (revenue limit: 10%)
|
****** e.g. tin, tantalum, tungsten or gold, which are mined in the Democratic Republic of Congo and its neighbouring states, among others. This region is heavily affected by armed conflict, with the warring parties often financing themselves through the control of mines
******* Definition according to the Kimberley Agreement: smuggled diamonds that have financed or are financing various wars in Africa.
******** The Arcitc Monitoring & Assessment Programme (AMAP) defines its scope and thus the geographical region of the Arctic as follows: "High Arctic, extending to the sub-Arctic areas of Canada, the Kingdom of Denmark (Greenland and the Faroe Islands), Finland, Iceland, Norway, the Russian Federation, Sweden and the United States, including associated marine areas".
********* An exception in the sense of a possibility of authorisation exists only for the area of heavy weapons. An exceptional permit for the financing of heavy weapons may be granted by the responsible risk director on the Management Board if justifiable, documented and overriding national/supranational interests prevail.
2. Strictly excluded business
In addition, Oberbank excludes business relationships with companies operating in any of the following sectors or activities:
|
Industry / Criterion
|
Exclusion of
|
|
Illegal substances (narcotics)
|
|
|
Mining
|
|
|
Harmful substances
|
- Prohibited chemical compounds or chemical compounds that are being progressively banned and other harmful substances (e.g. hazardous or highly hazardous pesticides or pharmaceuticals, such as unbound asbestos fibres).
|
|
Controversial weapons
|
-
Production of and trade in controversial weapons, including biological and chemical weapons, cluster munitions, nuclear weapons, and anti-personnel landmines.
|
|
Illegal Betting and gambling
|
|
3. Exclusion criteria for countries
In keeping with the principle of regionalism, Oberbank focuses on companies in those countries in which it is active or which have their registered office in the EU or belong to a UNIDO member state. In addition, we do not engage in proprietary transactions with central governments, which are excluded by the following criteria:
|
Criterion
|
The following are excluded
|
|
FATF list
EU liste of high-risk countries
|
Countries on the black, dark grey or grey list of the Financial Action Task Force on Money Laundering (FATF)
Countries on the EU list of high-risk countries set out in the Regulation (EU) 2020/855
|
|
Climate protection
|
Countries that have not ratified the 2015 Paris Climate Agreement (Ratification of the Paris Climate Agreement)
|
|
Freedom of the press and media
|
Countries with a “very serious situation” or “difficult situation” according to the “Reporters Without Borders” press freedom ranking
|
|
Sanctions
|
Countries subject to UN-, US- or EU-sanctions, unless Oberbank has specially defined policies and procedures in place to migrate the risks in question to an appropriate extent and in legally compliant manner
|
Our criterion excludes sovereign issuers that have not ratified the Paris Agreement. Since the United States formally ceased to be a party to the Agreement in 2026, it would automatically fall under this exclusion criterion. As the United States is the largest issuer of USD-denominated securities and therefore represents a key component of the USD investment universe, the U.S. market must be considered systemically relevant due to its importance for the Bank’s proprietary investment activities. Consequently, the United States as an issuer is exempt from this policy and remains an eligible investment.
4. Dealing with corporate groups
Within a group, those companies whose business activities violate the above exclusion criteria are excluded or not financed. The other companies in the group remain eligible for financing.
