Not a single one of the more than 80 Dutch pension funds that signed an agreement on furthering responsible investment two years ago has yet implemented all of its guidelines, a monitoring commission has found.

The commission has found this “worrisome”, it said in a report it published just before Christmas. The so-called IMVB-covenant – an agreement for international responsible investing – has been signed by more than 80 pension funds, accounting for more than 90% of total Dutch pension assets.

It focuses on the non-financial risks of pension funds’ investments, with the schemes pledging to implement OECD and United Nations guidelines to address the negative social effects of companies’ activities or its supply chain.

According to the intermediary objectives of the agreement, half of the pension funds concerned should by now have implemented these guidelines in their investment policy. This is not an enforceable goal though.

However, not a single pension fund has fully implemented the agreement yet. According to the commission, this is worrisome as implementation in the investment policy is only a first step.

Subsequent steps such as implementation of the guidelines in a fund’s outsourcing policy and monitoring tends to be only fully possible once a proper investment policy is in place.

It’s therefore not surprising that the implementation targets for outsourcing (13% compared to the goal of 34%), monitoring of outsourcing (7% versus the goal of 39%) and investment reporting (1% versus the goal of 26%) have also been missed, according to the commission.

At first sight it seems pension funds have hardly made any progress, but the underlying numbers show a more nuanced picture.

According to the commission, half of the signatories have developed a policy that is in line with OECD guidelines concerning human and labour rights. In practice this often means funds have copied draft texts referring to these guidelines.


The largest obstacle for pension funds is the due diligence they are required to do on companies according to the OECD guidelines. The commission said pension funds, especially smaller funds and those with a passive investment style, are struggling with putting this into practice due to a lack of resources.

The largest funds ABP and PFZW, which together account for almost half of total Dutch pension assets, score much better than average on most of the criteria examined by the monitoring commission.

The commission is calling for pension funds to cooperate more in order to reach full implementation by 2023. “The participating funds are losing time by trying to invent the wheel all by themselves,” it noted in its report.

“We are therefore arguing for concrete ‘how to’ manuals and case studies that can help pension funds implementing the guidelines.”

The full text of the ‘IMVB-convenant’ in English can be found here.

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