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Final mark: 15 / 20

You do a very good analysis of the case.


In particular, you propose a holistic final recommendation.
Your could push your analysis further by developing on:

The stakeholder relations: three governance structures of the Norwegian Fund, each with a different
stakeholder dynamics: the Ministry of Finance, the NBIM and the Ethical Council. It would have been useful to
analyze different stakeholder pressures each structure is exposed to and implications of these for the
funds strategy and for ESG based divestments.

Key organizational factors such as the underlying reasons for a divestment: does Norwegian Fund divest to
avoid being complicit or does the Ethical Council have an undeclared agenda of also changing the behavior
of the companies by making the divestment list public? The key issues for the fund could accordingly be
identified as:

lack of a clear philosophy for engagements / divestments

lack of coordination between NBIM and Ethical Council / conflicts between the long term profitability
objective of the fund and the activist agenda of the council

weak research at NBIM and reliance on unsubstantiated reports etc.

The attributes of a good solution based on the current priorities of the fund (or Walmart, if you have chosen
this perspective). A good solution shall, for instance:
o

be coherent with Norwegian Funds values

help addressing the Norwegian public opinion

help changing companies behavior (improving labor conditions etc.)

decrease cost of addressing ethical concerns

help ensuring long term focus etc.

The alternative ways of facing the issue at hand, before jumping to the conclusion / final recommendation put
based on the stated criteria. Some actions that other students proposed (which varied depending on their
diagnoses) were to:
o

enable more coordination between the NBIM team for engagements and the Ethical Council

include international members in the latter for less biased decision-making

outsource custom audits to confirm cases of ESG abuse and substantiate claims against companies

collaborate with other funds/investors to put pressure on companies for better disclosure

lobby through governments or NGOs

increase the maximum ownership limit (currently set at 5%) for more influence on companies

progressively transfer investment portfolio from traditional high risk industries to emerging ones (online
businesses, environmental protection etc.)

set and advertise clear, objective and quantifiable guidelines for selecting companies in which to
invest

open cases to public consultation among the companies stakeholders etc.

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