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Norway’s Government Pension Fund Global (GPFG) does not use a simple blacklist. The Ministry of Finance sets ethical rules, an independent five-member Council on Ethics investigates possible breaches and normally recommends action, and Norges Bank’s Executive Board makes the final decision. Depending on the evidence and the risk of future misconduct, the board can exclude a company, place it under observation, pursue active ownership, or take no action.
Who has authority to exclude a company?
The GPFG’s ethical framework starts with the Norwegian Ministry of Finance. The ministry establishes the ethical guidelines that define which products and business conduct are unacceptable for the fund. Those guidelines are implemented through the fund’s owner, Norges Bank.
The main investigative body is the Council on Ethics, an independent five-member body appointed by the Ministry of Finance after a nomination from Norges Bank. It monitors companies in the portfolio, gathers evidence, assesses possible breaches against the wording of the guidelines and relevant parliamentary guidance, and normally sends a documented recommendation to Norges Bank.
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Outbyte Driver Updater FREEFix the driver behind crashes, sound loss and screen glitchesFind Drivers →Outbyte PC Repair FREEClear out junk files and repair common Windows errorsFree Scan →Norges Bank’s Executive Board has the final say. It decides whether a company should be excluded, observed, followed up through ownership rights, or left without action. The guidelines also permit Norges Bank to start a case on its own initiative for specified criteria, so every decision does not have to originate with a Council on Ethics recommendation.
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This division matters when reading a decision. The Council’s report is an evidentiary and ethical assessment; it is not itself an exclusion order. The Executive Board’s published decision is the operative outcome.
The two screens used by the GPFG
The guidelines combine a product-based screen with a conduct-based screen. Product rules ask what a company makes or sells. Conduct rules ask how the company operates and whether there is an unacceptable risk of serious future harm.
Product-based criteria
| Product or activity | How the rule works | Examples in official decisions |
|---|---|---|
| Weapons that violate fundamental humanitarian principles | Companies can be barred when they produce weapons whose normal use violates fundamental humanitarian principles. | Product-based weapons exclusions are distinct from cases about a company’s conduct in a conflict. |
| Tobacco | Companies that produce tobacco are covered by the product prohibition. | Turning Point Brands and RLX Technology were cited for tobacco production in official materials available by 11 August 2026. |
| Weapons or military materiel supplied to restricted states | A company can face action for selling weapons or military materiel to states subject to the fund’s restrictions on government-bond investment. | The rule concerns the specified sales relationship, not every defence-related activity. |
| Thermal coal | Mining companies and power producers can face action when at least 30% of income or operations are based on thermal coal. Forward-looking plans are considered as part of the assessment. | The 30% threshold is a guideline test, not a claim that every coal-linked company is automatically excluded. |
The coal rule is deliberately more than a snapshot of current revenue. A company’s plans and the expected direction of its operations can affect the assessment. Conversely, falling below a threshold does not by itself settle a case if other ethical criteria apply.
Conduct-based criteria
| Conduct ground | What the board evaluates |
|---|---|
| Serious or systematic human-rights violations | Whether there is an unacceptable risk that the company contributes to or is responsible for grave, repeated or systematic abuses. |
| Serious violations of rights in war or conflict | Whether the company’s business relationships or activities create an unacceptable risk of contributing to serious violations connected with armed conflict. |
| Severe environmental damage | Whether the company is linked to environmental harm severe enough to meet the guidelines’ high ethical threshold. |
| Aggregate greenhouse-gas emissions | Whether the company’s overall emissions-related conduct creates an unacceptable ethical risk, rather than merely having a single high-emission facility. |
| Gross corruption | Whether corruption is sufficiently serious, and the company’s responsibility or contribution sufficiently established, to meet the exclusion standard. |
| Other particularly serious violations of fundamental ethical norms | A residual category for conduct that is exceptionally grave even if it does not fit neatly into another listed ground. |
These are risk standards. A case does not require a criminal conviction or a completed proceeding in another jurisdiction. It does require evidence strong enough to show an unacceptable risk under the guideline language.
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Why the threshold for exclusion is deliberately high
The Ministry of Finance’s 2025 review describes the governing philosophy in unusually direct terms: Exclusions are limited to the gravest forms of ethical norm violations. The threshold for excluding companies from GPFG shall be high. The guidelines are forward-looking and concern the risk of ongoing or future unacceptable conditions. Exclusion is not a mechanism based on concluded company actions that lie in the past.
That passage explains two features that can otherwise seem contradictory. First, the fund can act before every consequence has occurred if the evidence indicates an unacceptable risk of continuing or future harm. Second, a serious incident that is fully concluded does not automatically produce exclusion if the company has changed course and the relevant future risk is no longer present.
The board therefore looks beyond the headline allegation. It considers the company’s responsibility, the persistence and scale of the problem, remediation, governance changes, and the likelihood that the conduct will continue. The same facts can lead to observation or ownership follow-up in one case and exclusion in another.
How a case moves from suspicion to a final decision
- Portfolio monitoring identifies a possible issue. Information can arise from monitoring of holdings, public reporting, company disclosures, specialist evidence or other sources relevant to the guidelines.
- The Council on Ethics gathers and tests evidence. It examines the company’s activities, ownership or contribution, the applicable guideline wording and parliamentary guidance. The purpose is to establish whether the facts support an unacceptable-risk finding, not merely to repeat an allegation.
- The Council sends a documented recommendation. Its recommendation normally proposes exclusion or observation, but the record can support another course if the threshold is not met or a different measure is more suitable.
- The Executive Board considers alternatives. Norges Bank’s decision notices state that, before exclusion, it shall consider whether other measures, including exercising ownership rights, may be better suited.
- The Executive Board chooses the outcome. It can exclude the company, place it under observation, pursue active-ownership engagement, or decide that no action is warranted.
- The decision is published and can later change. Exclusions and observations are not necessarily permanent. A decision may be revoked, replaced by another measure or ended when circumstances develop.
This sequence is why it is inaccurate to say that the Council on Ethics “blacklists” companies. The council investigates and recommends; Norges Bank’s Executive Board decides.
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Exclusion, observation, active ownership and no action
| Outcome | Meaning in the GPFG process | When it may fit |
|---|---|---|
| Exclusion | The company is removed from the fund’s investable universe under the ethical guidelines. | The evidence indicates a sufficiently high and forward-looking risk of a grave violation, or a product criterion is met. |
| Observation | The company remains subject to enhanced scrutiny and a published observation decision. | The risk is serious but developing, uncertain, or dependent on whether promised changes occur. |
| Active ownership | Norges Bank uses shareholder rights and engagement rather than immediately excluding the holding. | Influence on company behavior is judged more effective or proportionate than withdrawal. |
| No action | The case does not result in an ethical measure under the guidelines. | The evidence, responsibility, risk or applicable threshold is insufficient. |
An observation is not a softer word for exclusion. It keeps the company in the portfolio while making the risk and the monitoring status explicit. Active ownership is also a separate tool: it is an attempt to change conduct, not a finding that the company has satisfied the ethical requirements.
What the recent numbers show
Norges Bank Investment Management reported 10 company exclusions, three observation placements, one reversed exclusion and one ended observation during 2025. Those figures describe activity under the guidelines in force during that year; they are not a count of every exclusion in the fund’s history.
The current public exclusion page was last updated 11 August 2026. It states that the list is updated regularly, that earlier exclusions or observations can be revoked or ended, and that the framework moved to interim guidelines after November 2025. A decision made under an earlier version of the rules should therefore not be read as proof that the same facts would produce the same outcome under the interim framework.
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Examples of the grounds used in decisions
The following examples are identified in official materials available by 11 August 2026. Their status can change if an exclusion is revoked, an observation ends or a new measure replaces it.
| Company | Ground identified in the official notice | What the example illustrates |
|---|---|---|
| China State Construction Engineering | Gross corruption | A conduct-based corruption case, rather than a product prohibition. |
| Tianjin Pharmaceutical Da Re Tang | Severe environmental damage | Environmental harm can meet the ethical threshold even where the company is not excluded for a prohibited product. |
| Larsen & Toubro | Production of key nuclear-weapons components | A product-related weapons criterion focused on specific components. |
| General Dynamics | Production of key nuclear-weapons components | The same product category can apply to a different company and corporate structure. |
| Turning Point Brands | Tobacco production | A direct product-based tobacco exclusion. |
| RLX Technology | Tobacco production | Another tobacco case, showing that the product screen is not limited to traditional cigarette manufacturers. |
| Adani Ports | Unacceptable risk of contributing to serious violations of rights in war or conflict | A conduct-based conflict case based on contribution risk, not simply the company’s industry label. |
| Bezeq | Unacceptable risk of contributing to serious violations of rights in war or conflict | Shows that the conflict-related criterion can apply to infrastructure or service relationships. |
| Eramet | Severe environmental damage and serious human-rights violations | More than one ethical ground can be cited in the same decision. |
How to compare two exclusion cases accurately
Use three axes rather than comparing company names or headlines alone.
- Product versus conduct: A tobacco or specified weapons case turns on what the company produces. A corruption, conflict, environmental or human-rights case turns on conduct, responsibility and future risk.
- Exclusion versus observation or ownership: Two companies can face similar allegations but receive different outcomes because the evidence, remediation, timing or effectiveness of engagement differs.
- Council recommendation versus Norges Bank decision: The council’s assessment explains the evidence and guideline analysis. The Executive Board’s decision determines the investment outcome.
Add a fourth check: the date and applicable framework. The public list can be revised, and the rules changed after November 2025 when interim guidelines took effect. A current status check is essential before describing a company as excluded or observed.
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An exclusion is an ethical investment decision within the GPFG. It does not constitute a criminal judgment, a court-ordered ban on the company, or a universal prohibition on every investor buying its shares. The decision means that the fund applies its own mandate and will not keep the company in its investable universe while the exclusion is in force.
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Nor does inclusion prove that a company has been ethically cleared. A company may be under observation, subject to active ownership, outside the scope of a particular criterion, or simply not have reached the high threshold for exclusion on the available evidence.
Why the list can change after publication
The framework is designed to respond to changing conditions. A company can improve controls, end a disputed activity, alter ownership or supply relationships, or provide evidence that changes the assessment of future risk. Conversely, new information can justify moving from observation to exclusion or from ownership engagement to another measure.
That is why the public page warns that earlier decisions may be revoked or ended. Readers should describe a company’s status with an “as of” date, identify the stated ground, and check whether the decision remains active rather than relying on an old article or a static list copied elsewhere.
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A practical checklist for reading a GPFG decision
- Identify whether the ground is product-based or conduct-based.
- Read the exact ethical criterion, including any percentage threshold or specified relationship.
- Check whether the finding concerns an ongoing or future risk, not only a completed historical event.
- Separate the Council on Ethics’ recommendation from Norges Bank’s final decision.
- Look for the alternative considered: observation, active ownership or no action.
- Record the decision date and the guideline framework then in force.
- Confirm the company’s current status because exclusions and observations can be revoked, ended or replaced.
The result is a deliberately layered process: political authorities define the ethical boundaries, an independent council develops the case, and Norges Bank’s Executive Board chooses the investment response. The high threshold and forward-looking test are intended to reserve exclusion for the gravest and continuing ethical risks while leaving room for observation or ownership engagement when those tools are more appropriate.
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