Exclusion list

Finnfund has an exclusion list, covering those sectors which Finnfund does not finance. It is based on the common exclusion list with other European finance institutions (EDFI).

Finnfund will not finance any activity, production, use, distribution, business or trade involving:

1. Forced labor¹ or child labor²
2. Activities or materials deemed illegal under host country laws or regulations or international conventions and agreements, or subject to international phase-outs or bans, such as:

• ozone depleting substances, PCB’s (Polychlorinated Biphenyls) and other specific, hazardous pharmaceuticals, pesticides/herbicides or chemicals;
•  wildlife or products regulated under the Convention on International Trade in Endangered Species or Wild Fauna and Flora (CITES); or
• unsustainable fishing methods (e.g., blast fishing and drift net fishing in the marine environment using nets in excess of 2.5 km in length).

3. Cross-border trade in waste and waste products, unless compliant with the Basel Convention and the underlying regulations.
4. Destruction³ of High Conservation Value areas⁴
5. Radioactive materials⁵ and unbonded asbestos fibers.
6. Pornography and/or prostitution
7. Racist and/or anti-democratic media
8. In the event that any of the following products form a substantial part of a project’s primary financed business activities⁶:

a) Alcoholic Beverages (excluding beer and wine);
b) Tobacco;
c) Weapons and munitions; or
d) Gambling, casinos and equivalent enterprises.

In addition, from October 2020 onwards Finnfund follows the following investment exclusions for all new Direct Financing, for Indirect Equity through new commitments to investment funds, and new dedicated lending⁷ via financial institutions:

9. Coal prospection, exploration, mining or processing
10. Oil exploration or production
11. Standalone fossil gas exploration and/or production⁸
12. Transport and related infrastructure primarily⁹ used for coal for power generation
13. Crude Oil Pipelines
14. Oil Refineries
15. Construction of new or refurbishment of any existing coal-fired power plant (including dual)
16. Construction¹⁰ of new or refurbishment of any existing HFO-only or diesel-only power plant producing energy for the public grid and leading to an increase of absolute CO2 emissions¹¹
17. Any business with planned expansion of captive coal used for power and/or heat generation¹²

^{1) Forced labor means all work or service, not voluntarily performed, that is extracted from an individual under threat of force or penalty as defined by ILO conventions.}

^{2) Persons may only be employed if they are at least 14 years old, as defined in the ILO Fundamental Human Rights Conventions (Minimum Age Convention C138, Art. 2), unless local legislation specifies compulsory school attendance or the minimum age for working. In such cases the higher age shall apply.}

^{3) Destruction means the (1) elimination or severe diminution of the integrity of an area caused by a major, long-term change in land or water use or (2) modification of a habitat in such a way that the area’s ability to maintain its role is lost.}

^{4) High Conservation Value (HCV) areas are defined as natural habitats where these values are considered to be of outstanding significance or critical importance (See http://www.hcvnetwork.org).}

^{5) This does not apply to the purchase of medical equipment, quality control (measurement) equipment or any other equipment where the radioactive source is understood to be trivial and/or adequately shielded.}

^{6) For companies, “substantial” means more than 10 % of their consolidated balance sheets or earnings. For financial institutions and investment funds, “substantial” means more than 10% of their underlying portfolio volumes.}

^{7) “Dedicated lending” is defined for these purposes as financing conditioned by a use of funds clause specifying that such financing will be used for one or more of the purposes described.}

^{8) Gas extraction from limnically active lakes is excepted from this exclusion.}

^{9) ”Primarily” means more than 50% of the infrastructure’s handled tonnage}

^{10) For indirect equity through investment funds, investments (up to a maximum of 20% of the fund) in new or existing HFO-only or diesel-only power plants are allowed in countries that face challenges in terms of access to energy and under the condition that there is no economically and technically viable gas or renewable energy alternative.}

^{11) I.e. where energy efficiency measures do not compensate any capacity or load factor increase.}

^{12) This does not apply to coal used to initiate chemical reactions (e.g. metallurgical coal mixed with iron ore to produce iron and steel) or as an ingredient mixed with other materials, given the lack of feasible and commercially viable alternatives}