Dutch pension funds are behind on implementing a pact on sustainable investing dating from 2018.

Only 13% of funds have fully implemented the so-called IMVB-covenant – an agreement for international responsible investing – in their investment policy, while this figure should have now stood at 100%.

According to the monitoring commission of the pact, which revolves around addressing non-financial sustainability risks, pension funds have made little progress in its implementation compared to a year ago. At the time, the commission also concluded pension funds were behind schedule.

The IMVB pact has 78 pension fund signatories accounting for more than 90% of Dutch pension assets.

While the Dutch pensions federation hailed the “clear progress” made on some sub-indicators, it noted a “sprint to the finish” was necessary to reach all goals in time for the deadline at the end of 2022.

“A sprint to the finish on the specific sub-goals that currently have not been implemented sufficiently, is necessary for a good end result,” according to Pensioenfederatie president Ger Jaarsma.

Pension funds are behind schedule in implementation on all four lead indicators – policy, outsourcing, monitoring of outsourcing and reporting. The situation regarding policy is of most concern to the commission. Only 13% of funds have fully implemented the pact’s policy guidelines.

This is an improvement compared to the previous monitoring report almost a year ago, when not a single fund had yet implemented the pact fully in their investment policy.

However, according to the schedule for IMVB, 100% of funds were supposed to have done so by now. Larger funds only do marginally better than smaller ones in policy implementation: the funds that have implemented the pact account for just 17% of pension assets under management.

Lack of focus

The lagging progress in policy implementation can be mainly attributed to a lack of explanation of how pension funds perform due diligence with investee companies and a poor explanation of their thematic investment policies.

Only 41% of funds has correctly explained how they monitor the companies in question on ESG criteria.

“The monitoring commission concludes that last year’s recommendation to clarify due diligence has led to action, but hasn’t had the desired effect,” the commission wrote.

Pension funds often seem to be satisfied with the information given to them by their asset managers, while the latter expect more guidance from pension funds on what to report on, the commission noted.

The “lack of focus” when it comes to thematic investing is also up for improvement. Many funds mention human rights, the environment and good governance as spearheads of their policy, “but in reality this means no real choice is being made because these themes are so wide-ranging”, according to the commission.


While most pension funds indeed missed the deadline in implementing the pact in their investment policy, they have one more year to do so in the areas of outsourcing, monitoring of outsourcing activities and reporting. At the end of 2022, the pact needs to be fully implemented by all participating schemes.

Most funds are, however, also behind schedule in all four areas. When it comes to outsourcing, larger funds do better than smaller schemes. For example, the large funds have made significantly more progress in measuring the negative impact of their investments, and are also more serious about engagement.

More generally, the commission said pension funds tended not to have an escalation plan in case engagement with a company failed. If and why investments were then sold, was usually not made clear either.

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