The new proposals to change the ethical framework governing Norway’s Government Pension Fund Global could significantly weaken independent human rights oversight, reduce transparency and make it harder to exclude companies linked to serious abuses, Amnesty International said today.
Norway’s Government Pension Fund Global, the world’s largest sovereign wealth fund, is reviewing its ethical governance framework. The Gjedrem Committee, set up for this purpose, has proposed weakening the independent Council on Ethics, allowing some of its assessments to remain confidential, and making it harder to exclude companies linked to serious human rights risks.
“The proposed ethical governance changes in the Norwegian fund risk weakening accountability and integrity and dismantling key human rights protections and amount to the most significant weakening of its human rights safeguards in two decades. When the world’s largest sovereign wealth fund changes its standards, the consequences do not stop at Norway’s borders. Other investors pay attention, and companies do too,” said John Peder Egenæs, Secretary General of Amnesty International Norway.
“Under the new proposals, the Council on Ethics would lose its ability to recommend exclusion, while some companies could remain in the portfolio despite serious human rights risks and failed engagement efforts. This risks weakening independent ethical scrutiny precisely when it is most needed and making certain investments too big to exclude. This is a dangerous approach and in practice imply that companies at risk of contributing to serious violations of international law are never excluded from the fund.”
Greater discretion demands greater scrutiny
The new proposals recommend that the Council of Ethics would continue to assess the risk of companies contributing to or being responsible for serious ethical violations, but without recommending exclusion or observation. Instead, the central bank of Norway, the Norges Bank (NBIM), would determine the response.
The proposals also allow the Council’s risk assessments to be withheld from public disclosure where specified conditions relating to the fund’s economic interests or NBIM’s ability to fulfil its management responsibilities are met. This is a major setback for transparency, integrity and accountability.
“First, the watchdog loses its teeth. Then the curtains are drawn. The fund belongs to the Norwegian people, yet they risk losing access to information about any serious abuses that their money could be linked to,” said Egenæs.
While limited confidentiality during company engagement may sometimes be justified, the public must still be able to scrutinize why NBIM retains investments in companies linked to serious human rights risks.
“The Norwegian people have a right to know what the bank is asking companies to change, whether those changes are actually implemented, and why it continues to invest when serious human rights risks remain,” said Egenæs.
Technology suppliers’ ongoing role must be examined
The Gjedrem Committee report recognizes that cloud computing, artificial intelligence and data analysis can be used in surveillance, intelligence gathering and military targeting, but proposes that sales of generic products should normally fall outside conduct-based exclusion criteria.
For major technology companies, the committee states that diversification considerations may carry decisive weight when assessing exclusion.
“Military use alone is insufficient to establish a company’s involvement in human rights abuses. But civilian applications cannot be used to avoid scrutiny of the role technology may play in any serious rights violations. Too often, the dual-use nature of these technologies is invoked to avoid meaningful scrutiny of the risks they create,” said Egenæs.
“The fund must examine what the supplier knows, how its services are used, and what it does to prevent or stop the misuse. There is an important distinction between selling a standard product and continuing to operate, adapt and support services used in serious abuses.”
Engagement cannot justify indefinite delay
Under the proposed framework, engagement with the company in order to address ethical concerns would replace exclusion as the primary response when risks of serious ethical violations are identified. NBIM would be required to exclude a company only where engagement has failed or has no realistic prospect of succeeding within a reasonable time, unless exclusion would limit the fund’s ability to remain broadly diversified globally. This exception risks allowing financial considerations to override human rights concerns. It also risks weakening the fund’s leverage over companies.
“An abuse does not become less serious because a company is large or an investment profitable. Applying the same ethical standard means little if the fund can retain the investment after efforts to secure change have failed,” said Egenæs.
“Engagement is a tool, not an end in itself. Without a credible possibility of exclusion, engagement risks becoming a conversation without consequences. In situations of armed conflict or occupation, the urgency of protecting people must guide the response. An ongoing dialogue is not, by itself, evidence that risks are being reduced.”
Weapons safeguards would be weakened
The committee further proposes an exception to the nuclear weapons exclusion criterion for producers based in states that are both recognized nuclear-weapon states under the Nuclear Non-Proliferation Treaty and NATO allies of Norway. This would allow certain producers based in the United States, the United Kingdom and France to become eligible for investment.
“The catastrophic humanitarian consequences of nuclear weapons – the most inhumane and destructive weapons ever to be created – do not change with the nationality of their producer. Norway’s alliances must not determine which nuclear weapons producers the fund considers acceptable investments; all companies involved must be excluded,” said Egenæs.
The committee also recommends removing the specific criterion addressing arms sales to states that use those weapons to commit serious and systematic violations of international humanitarian law.
It proposes retaining the criterion concerning serious violations of individuals’ rights in war and conflict, and expanding a separate criterion concerning arms sales to states subject to sanctions or arms embargoes supported by Norway.
“These remaining safeguards matter. But removing an explicit criterion addressing arms transfers used in serious violations of international humanitarian law risks weakening scrutiny of suppliers and the human rights impacts of their products,” said Egenæs.
Amnesty International is calling on the Norwegian government and parliament to ensure and maintain strong, independent, ethical oversight of the fund, ensure meaningful public transparency and participation and preserve exclusion as a vital safeguard when engagement cannot effectively mitigate serious human rights risks.
The revised framework must be grounded in the United Nations Convention against Corruption, UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, including risk-based and heightened human rights due diligence in conflict-affected settings.
“Human rights and independent oversight cannot be optional when they become inconvenient or costly. Norway should apply the same principles to the management of its own wealth that it expects others to uphold. It must ensure that transparency, accountability and human rights remain at the heart of how its wealth is managed. The Gjedrem Committee proposal must not be operationalized,” said Egenæs.
Background
The Norwegian government appointed the committee, chaired by former central bank governor Svein Gjedrem, in November 2025 to review the ethical framework governing the Government Pension Fund Global. The committee submitted its unanimous report on 15 October 2026. Its recommendations do not themselves change the fund’s rules.
Amnesty International has previously called on Norway to divest the fund from companies involved in maintaining Israel’s unlawful occupation of the Occupied Palestinian Territory and to rigorously screen investments in line with international business and human rights standards.