AP2’s primary aim is to influence change. This is best achieved by remaining as owner of companies and working to ensure that measures are taken to prevent future violations. Nevertheless, there are situations in which the Fund excludes or divests companies.

Read about the work of the Council on Ethics here.

The Fund distinguishes between divestments and exclusions as follows:


  • The Fund divests if international conventions aim to restrict the use, scope or distribution of certain products or activities. At the same time, such products may be allowed to be manufactured and activities to be carried out, according to applicable laws and regulations. Individual companies cannot therefore, in principle, be considered to be in breach of these conventions.
  • The Fund may divest from companies with the support of the provisions of the AP Funds Act regarding exemplary management.
  • The Fund may divest from companies due to sustainability risks.
  • The Fund is managed in line with the EU Paris-Aligned Benchmark. This means that, based on certain criteria, companies in the energy sector are not included in the Fund’s benchmark indices.
  • Divested companies are not disclosed when it is entire sectors in which the Fund is no longer invested.


  • The AP Funds’ Council on Ethics recommends that the AP Funds exclude companies that knowingly contribute to the violation of an international convention that Sweden has ratified.
  • The Council on Ethics recommends exclusion if they consider that a continued dialogue with the company will not result in positive changes or when the dialogue has been going on for four years without significant progress.
  • The Fund may exclude a company if it considers that the circumstances are of such a serious nature that exclusion is warranted even though no breach of convention has occurred or can be shown.
  • Excluded companies are disclosed.

AP2 also complies with UN and EU sanctions decisions.

AP2 has developed a country framework to identify countries where there are financial, operational or sustainability reasons not to invest.

Companies and businesses in which the Fund does not invest in

AP2 has excluded and divested from companies in some businesses/sectors.

Excluded due to breach of convention

Cluster weapons and mines

The Anti-Personnel Mine Ban Treaty and the Convention against Cluster Weapons state that countries that have signed and ratified the treaty shall cease to produce, trade in and use anti-personnel mines and cluster bombs, respectively. The AP Funds’ Council on Ethics has recommended that the four AP Funds divest companies that produce anti-personnel mines or cluster bombs and AP2 therefore does not own any such companies. The companies that have been excluded on this basis are listed here.


The AP Funds’ Council on Ethics has recommended that the AP Funds exclude cannabis companies based on the UN Convention on Narcotic Drugs. However, cannabis may be used for medical and scientific purposes. AP2 has therefore decided to exclude companies active in cannabis for non-medical use or for religious purposes. The companies AP2 has identified are listed here.

Divested due to the purpose of a convention

Nuclear weapons

AP2 believes that modernisation and upgrading of nuclear weapons are not compatible with the spirit of the Non-Proliferation Treaty (NPT), which aims to make the world nuclear-free in the long-term. Therefore, based on the legal regulations for the AP Funds regarding exemplary management, AP2 has divested from companies involved in the maintenance and modernisation of nuclear weapons systems.


Divestments from tobacco companies support the aim of the Convention on Tobacco Control, to significantly reduce tobacco consumption and the harmful effects of tobacco smoking. AP2 has divested from tobacco companies on the basis of legal regulations for the AP Funds regarding exemplary management.

Divested due to the Paris-Aligned Benchmark

Coal, oil, gas, energy companies

In 2020, AP2 implemented the EU Paris-Aligned Benchmark (PAB) for the Fund’s internally managed global equities and corporate bonds. This means that AP2 does not invest in companies that derive more than a certain percentage of their sales from coal, oil and/or natural gas or in energy companies that receive more than 50 per cent of revenues from fossil fuels. The maximum share for coal is 1%, for oil 10% and for gas 50%.


In the case of direct holdings, AP2 has full power to determine the holdings in the portfolio. In the event of both divestments and exclusions, the companies are removed from the Fund’s investment universe and benchmark indices.

For indirect investments through funds, investment decisions on individual portfolio companies are not made by AP2. Should they have holdings in companies from which the Fund has excluded or divested, the Fund engages in a dialogue with the managers.

Excluded companies

If AP2 has reason to suspect that any of the companies in which the Fund has invested is seriously and systematically acting in breach of an international convention to which Sweden is a party or has expressed the intention to become a party, the facts must be investigated.

This includes a dialogue with the company in question. If the suspicions are confirmed, the company will be requested to provide an explanation and develop an action plan. In its assessment of the case, the Fund shall take into account the nature of the incident, and any action taken (or to be taken) to ensure that the incident does not recur. If the contacts with the company do not provide a satisfactory result, AP2 will, after an overall assessment, decide whether the company should be excluded. The Fund may also decide on exclusion if it considers that the circumstances are of such a serious nature as to warrant exclusion, despite the fact that no breach of the convention has occured or can be demonstrated.

The First – Fourth AP Funds have jointly agreed on common guidelines on which assets the Funds will not invest in.

AP2’s exclusion list for listed equities and interest-bearing securities contains approximately 20 companies in whose securities the Fund may not invest. If it is verified that the problems in the companies have ceased, they are removed from the exclusion list.

List of excluded companies:

CompanyYear excludedCountryBasis for exclusionReason
Aurora Cannabis2018CanadaProductProduction of cannabis
AviChina Industry & Technology Company Limited2023ChinaConductHuman rights
Barrick Gold2014USAProductEnvironment
Cannopy Growth2018CanadaProductProduction of cannabis
China Northern Rare Earth (Group) High-Tech Co Ltd.2023ChinaProductEnvironment
China Spacesat Co Ltd.2020ChinaProductProduction of cluster munitions
Cronos Group Inc.2019CanadaProductProduction of cannabis
Elbit Systems Ltd.2010IsraelConductHuman rights
Freeport McMoran Copper & Gold Inc.2013USAConductEnvironment
HEXO Corp2019CanadaProductProduction of cannabis
Incitec Pivot Ltd.2013AustraliaConductHuman rights
Metallurgical Corporation of China Ltd.2023ChinaProductEnvironment
Motorola Solutions2015USAConductHuman rights
Poongsan Corp.2008South KoreaProductProduction of cluster munitions
Tilray Brands Inc.2018CanadaProductProduction of cannabis
Vale S.A.2019BrazilConductHuman rights and environment
Zijin Mining2016ChinaConductEnvironment