So, you’re looking into the Aviva Investors investment exclusions list 2023. Honestly, it’s one of those documents that sounds incredibly dry—like something you’d find at the bottom of a filing cabinet in a basement—but it’s actually a pretty big deal in the world of ethical money.
It isn't just a list of "bad" companies. It’s basically a line in the sand.
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For a long time, fund managers just chased the highest return. Period. If a company made money by selling landmines or burning mountains of coal, well, that was just business. But in 2023, things shifted. Aviva Investors, which is the asset management arm of the UK insurance giant, updated its rulebook on who gets a seat at the table and who gets kicked out.
The Baseline: The "Absolutely Not" List
Aviva breaks things down into levels. Think of Level 1 as the firm-wide baseline. This applies to everything they touch. If a company is on this list, it’s persona non grata.
What’s on it?
First off, controversial weapons. We’re talking cluster munitions and landmines. In 2023, they were very clear: if you make these, you’re out. No exceptions. They also set a hard cap on civilian firearms. If a company makes more than 5% of its revenue from manufacturing guns for civilians, Aviva won’t touch them.
Then there’s the fossil fuel side of things.
The 2023 policy was particularly aggressive about thermal coal. If a company gets 5% or more of its revenue from mining thermal coal or generating power from it, they’re excluded. They also targeted Arctic oil and oil sands, with a 10% revenue threshold.
Tobacco is another big one. 20% production revenue or 25% from sales? You’re gone.
Why 2023 Was a Bit Messy
Now, here’s where it gets interesting. Even with these rules, things aren't always perfect.
You might have heard that in late 2023 and into 2024, the Luxembourg regulator (the CSSF) actually fined Aviva Investors. Why? Because some of their funds—specifically the Emerging Markets Bond Fund—were found to be holding assets that didn't quite match their ESG promises.
Specifically, about 5.5% of that fund's net assets were in bonds from five countries that had ESG scores "well below" what they should have. Aviva had to update their prospectus wording in July 2023 to be more honest about what they were actually doing. It goes to show that even the biggest players can trip up when trying to balance complex exclusion lists with real-world trading.
Breaking Down the Three Levels
Aviva’s strategy isn't a one-size-fits-all thing. They use a tiered approach that gets stricter depending on the specific fund.
- Level 1 (Baseline): Applies to everything. Includes the weapons, coal, and tobacco stuff mentioned above. It also includes "UN Global Compact" violators—basically companies that ignore basic human rights or environmental standards.
- Level 2 (Sustainable Transition): This is for their "Green" funds. The rules here are way tighter. For instance, the revenue threshold for thermal coal drops to 0%. If you touch coal at all, you're out.
- Level 3 (Social/Natural Capital): This is the niche stuff. If a fund is focused on "Social Transition," they might exclude predatory lenders. If it’s "Natural Capital," they might look closer at biodiversity and land use.
The "Engagement" Loophole?
One thing that often confuses people is the "Science-Based Targets" exception.
Basically, Aviva says they might still invest in a "bad" fossil fuel company if that company has a validated plan to change. This is the "engagement over exclusion" argument. They’d rather own a piece of the company and yell at the board of directors to change than just sell the stock and lose their influence.
Whether you think that’s a smart strategy or a convenient excuse depends on how cynical you’re feeling today.
Human Rights: The New Frontier
In 2023, Aviva really leaned into the Human Rights aspect of their exclusion policy. They were one of the founding members of an initiative to fix "norms breach" data.
The problem is that a lot of data providers (the people who tell investors which companies are "good" or "bad") are actually pretty terrible at tracking human rights abuses in real-time. Aviva’s 2023 update pushed for better transparency in how these breaches are reported, especially in conflict zones.
What This Means for You
If you’re an investor or just someone curious about where the world’s money is going, there are a few takeaways here.
- Read the Prospectus: As the Luxembourg fine showed, the "marketing" version of an exclusion list isn't always the "reality" version. Look for the fine print on revenue thresholds.
- Coal is the First to Go: If you’re looking at your own portfolio, thermal coal is the easiest thing to strip out if you want to align with big institutional players like Aviva.
- Revenue Thresholds Matter: Very few big companies are 100% "clean." Most exclusions work on a 5%, 10%, or 25% rule.
If you want to see the specific companies currently blocked, you won't usually find a simple PDF list on their homepage. These lists change monthly based on new data from providers like MSCI or Sustainalytics.
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To stay on top of this, you should look for the Annual Sustainability Review or the SFDR Periodic Disclosures for the specific fund you're interested in. That’s where the "dirty" secrets—and the progress—actually live.
The next step is to check your own pension or brokerage account. Most of them now offer an "ESG" filter that mimics the Aviva Investors investment exclusions list 2023 criteria, often using the same 5% revenue benchmarks for coal and weapons.