by NEI ESG Services Team.

Russia’s invasion of Ukraine sparked swift retaliatory action from governments, investment managers, and companies all over the world seeking to implement and support crippling sanctions.

Editor’s note: This article first appeared in our Active Ownership Report from Q1, 2022 

On March 7, NEI announced we had committed to selling securities of companies domiciled in Russia, which at that point were already negligible, while putting in place a moratorium on the purchase of new securities. We also committed to using corporate engagement to pressure companies with operations and/or economic interests in Russia to pause or end their involvement in the country. (This press release has the details.)

On that last point we are making strong headway on our initial assessment of actions taken, or intended to be taken, by companies in our funds. The table below summarizes the results as of March 31. We prioritized companies for review and initial outreach by first focusing on our most material holdings. We assessed how their response aligned with international sanctions and human rights expectations. For companies that had not publicly disclosed their action plan, we asked them about their near-term plans. Where it was unclear from disclosures whether a company was exposed to Russia and/or Ukraine, we reached out to them to assess such exposure. Regarding financial institutions specifically, we sought to understand whether and how they are engaging their clients and to what extent the conflict might lead them to enhance their approach to country risk assessment.


Number of companies*

65 Were sent email

40 Responded to email

62% Response rate


Initial findings

  • We were happy to see that many companies had proactively issued a statement regarding their intentions, which indicated an effort to align with international sanctions
  • Many of the companies were responsive to our initial request for information, and a handful of names that we had never engaged before in direct dialogue asked for a more in-depth meeting
  • We would not describe any company as defensive in its response to our request for information, though we are still awaiting responses from some companies

One of the key elements we are looking for in company responses is an understanding of what action they are taking and how human and labour rights considerations have influenced those decisions. This could be seen by, for example, whether companies have a plan to provide financial support for refugees and employees in the region where the business has had to suspend or halt operations.

Our intention is to help companies answer the question, “What does a responsible and human rights centred corporate response to this conflict look like?” We must act quickly, yet without sacrificing the level of thoughtfulness and collaboration required to navigate these complex and difficult circumstances.


*The total number of companies engaged represented approximately $979.5M in NEI equity AUM at of March 31, 2022. We considered whether companies had “direct” and/or “indirect” exposure to Russia, defined respectively as a physical footprint and sales, suppliers, or other commercial interests in the country. Exposure was determined by review of publicly available information or by asking companies directly.

 This material is for informational and educational purposes and it is not intended to provide specific advice including, without limitation, investment, financial, tax or similar matters. The views expressed herein are subject to change without notice as markets change over time. Information herein is believed to be reliable but NEI does not warrant its completeness or accuracy. Views expressed regarding a particular security, industry or market sector should not be considered an indication of trading intent of any funds managed by NEI Investments. Forward-looking statements are not guaranteed of future performance and risks and uncertainties often cause actual results to differ materially from forward-looking information or expectations. Do not place undue reliance on forward-looking information.

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