The Council on Ethics of the Swedish National Pension Funds summarises an eventful year

During the year, the Council on Ethics engaged in dialogues with companies regarding potential links to both serious incidents and violations, while at the same time further developing its work on major systemic issues. Particular emphasis was placed on responsible mining and the impact of big tech companies on human rights. Work involving companies with links to conflicts was particularly extensive and required deep analysis and prioritisation.

The increasingly severe global conflict situation led to a specific focus on companies with connections to conflict‑affected areas. Through company dialogues, the Council on Ethics followed up on risks, verified facts, and communicated the AP Funds’ expectations. In parallel, the AP Funds, through the Council on Ethics, updated a joint position statement setting out clear expectations for companies with links to conflict areas.

Fredric Nyström, Chair of the Council on Ethics during 2025:

“In a turbulent global environment, the importance of the Council on Ethics’ work becomes particularly clear. With joint analytical capacity and a strong voice in engagement efforts, the Council on Ethics plays an important role in the AP Funds’ long‑term sustainability work.”

The Council on Ethics’ core mandate is to identify and act on signals of severe violations within the AP Funds’ portfolios. Following a review of just over 3,000 companies during 2025, such signals resulted in dialogues being conducted with 60 companies. Several company dialogues were concluded during the year as all established requirements and objectives were met.

The Council on Ethics also works proactively to achieve long‑term and tangible improvement in areas identified by the AP Funds as material systemic risks. The work is conducted within five focus areas: Antimicrobial Resistance; Child Labour and Forced Labour; Climate Transition; Technology Companies and Human Rights; and Water. Through in‑depth work with clear priorities, the Council on Ethics sets concrete objectives for individual companies while also working to promote positive development at both industry and system level.

Jenny Gustafsson, Executive Director of the Council on Ethics:

“During the year, the Council on Ethics made a number of important advances in several prioritised focus areas. For example, we stepped up our work in the Mining 2030 project, which focuses on the responsible extraction of critical minerals. This has resulted in concrete recommendations for the mining industry and investors, which we see as a very positive development. In addition, we continued our collaboration with other investors within the Big Tech & Human Rights project. Together, we advocate for the big tech companies to take responsibility for how their products impact society and human rights.”

In total, reactive and proactive dialogues were conducted with 155 companies during 2025, with the aim of driving positive change.

2025 at a glance

• 3,007 companies reviewed for involvement in violations of international conventions and guidelines
• 155 companies engaged in dialogue during the year
• 7 companies met established objectives and reactive dialogues were therefore concluded
• 9 projects within five proactive focus areas, including one new project addressing risks of child labour in the cocoa industry

Annual report 2025 Council on Ethics for the Swedish National Pension Funds