Norges Bank aims to pre-disclose all voting ahead of company AGMs

New three-year strategy document published by influential investor

Norges Bank Investment Management (NBIM), the arm of the Norwegian central bank which runs the assets of the giant Government Pension Fund Global sovereign fund, says it aims to be able to publish all of its voting intentions ahead of company meetings by the end of 2022.

Norges says in its new 2020-2022 strategy plan: “By the end of the strategy period, we aim to publish all our voting instructions ahead of shareholder meetings where this is practicable.”

NBIM has disclosed how it voted at AGMs since 2013 and it started to pre-disclose some voting intentions in 2015, starting with its intentions on the “Aiming for A” shareholder resolutions on climate reporting at BP and Shell.

This year it has pre-disclosed three times (Grupo Mexico, Kellogg Company and Pilgrim’s Pride), on specific agenda items.

All told it has pre-disclosed its voting intentions 19 times. Given that the fund holds more than 9,000 companies, the expansion in this reporting will be a major undertaking.

The strategy also gives some insight into the influential fund’s position on renewable energy infrastructure.

“We seek to invest in unlisted renewable energy infrastructure to improve the overall risk-return characteristics of the fund.” The focus will be on Europe and North America given their tested regulatory frameworks and experience with private funding.

“Our primary investment focus is wind and solar power generation assets. We will focus on projects with low power price risk, stable cash flow and limited risk to the principal investment.

“We will invest alongside high-quality partners with proven operational experience.“We favour equity investments but can invest in other parts of the capital structure. We prefer direct co-investments but will consider investing in renewable funds.” Staff dedicated to this asset class “is expected to be around 20 professionals”.

It goes on to say: “Our industry-based environmental mandates and specialised capital markets mandates will be a smaller part of our activities.”

The 24-page document also reveals that NBIM wants to integrate securities lending more closely with portfolio management.

It notes it has an “efficient outsourced securities lending programme” through an agent and that it supplements this with “internal capabilities to maintain profitability”.

It adds: “We seek to further integrate our lending decisions into the portfolio management process. Investment banks are our most important borrowers, but we will seek to diversify to other counterparties. We will expand our internally managed synthetic lending programme to new markets.”

The document sets the institution’s strategic direction for the next three years and builds on its 2017–2019 predecessor.


The aim by Norges Bank to pre-disclose its voting intentions – where practicable – represents a significant move towards greater transparency by an investor that holds huge chunks of the global equity market. Norges does things its own way: it eschews investor initiatives like the Climate Action 100+ project and is sceptical about stewardship codes. But this is a major statement. The administrative burden of such transparency is not to be underestimated — but the signal this sends to companies and investors is unmistakable: disclosure is the way forward.